20150901IPC to ICIP Confidential Supplemental 2.pdf

SEffi*.
An IDACORP Company
LISA D. NORDSTROIIi
Lead Counsel
I [e-mail]
September 1,2015
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VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-15-17
Long Term Program Contract with Siemens Energy, Inc. - ldaho Power
Company's Supplemental Response to the lndustrial Customers of ldaho
Power's Request for Production No. 2
Dear Ms. Jewell:
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Supplemental Response to the lndustrial Customers of ldaho
Power's Request for Production No. 2.
ln addition, enclosed are four (4) copies of a confidentiat disk containing
information responsive to the lndustrial Customers of ldaho Power's request.
Please handle the confidential information in accordance with the Protective
Agreement executed in this matter.
Very truly yours,
6O[),%;/a-n--,^,
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ ida ho powe r. co m
Attomey for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF LONG.TERM
MAINTENANCE PROGMM CONTRACT
WITH SIEMENS ENERGY, SALE OF
SPARE PARTS INVENTORY TO SIEMENS
ENERGY, AND DEFERML OF
ASSOCIATED COSTS
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. !PC-E-15-17
IDAHO POWER COMPANY'S
SUPPLEMENTAL RESPONSE TO
THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER'S REQUEST
FOR PRODUCTION NO. 2
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company") and
supplements its response to the Industrial Customers of ldaho Powe/s Request for
Production No. 2 dated August 11,2015, as follows:
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER'S REQUEST FOR PRODUCTION NO. 2 - 1
I n14I ! l:?l
REQUEST FOR PRODUCTION NO. 2: Mr. Mahlum, at page 6 of his direct
testimony has the following Question and Answer:
O. Did the Company issue a request for proposal for the
services provided for under the LTP Contract?
A. No. However, ldaho Power did contract with a
professional knowledgeable in long-term program contracts
who contacted multiple third-party providers of gas plant
maintenance as part of a formal request for information
process. Those third-party proposals were analyzed by both
the Company and the contracted professional and it was
determined that there are cunently no other third-party
maintenance providers that could provide services
equivalent to those provided under the LTP Contract with
Siemens.
Please provide the names and positions of all those "professional knowledgeable in
long-term program contracts" that were contacted by the Company. Please also
provide all the "third-party providers of gas plant maintenance" that were contacted by
the knowledgeable professionals. Please provide all conespondence between the
knowledgeable professionals (emails, notes, documents, etc.) and ldaho Power.
Please document all inputs used to "determine ... that there are currently no other third-
party maintenance providers. . . "
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
Please see the non-privileged documents on the enclosed confidential CD provided in
response to the request for "all correspondence between the knowledgeable
professionals (emails, notes, documents, etc.) and Idaho Power." Because many of the
documents are e-mails and voluminous, they have not been labeled with the word
"confidential." However, please consider al! documents provided on the enclosed disk
to be confidential documents containing confidentia! information. The confidentia! CD
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER'S REQUEST FOR PRODUCTION NO.2 - 2
will only be provided to those parties that have executed the Protective Agreement in
this matter.
The response to this Request is sponsored by Lisa D. Nordstrom, Lead Counsel,
ldaho Power Company.
DATED at Boise, ldaho, this 1"t day of September 2015.
IDAHO POWER COMPANY,S SUPPLEi,IENTAL RESPONSE TOTHE INDUSTRIAL
CUSTOMERS OF IDAHO POWER'S REQUEST FOR PRODUCTION NO.2 - 3
Attomey for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1't day of September 20151 served a true and
conect copy of IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER'S REQUEST FOR PRODUCTION
NO. 2 upon the following named parties by the method indicated below, and addressed
to the following:
Commission Staff
Karl T. Klein
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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IDAHO POWER COMPANY,S SUPPLETIIENTAL RESPONSE TO THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER'S REQUEST FOR PRODUCTION NO. 2 - 4