20151215ICIP 1-3 to IPC.pdf

Peter J. Richardson (ISB No. 3195)
Greg Adams (ISB 7454)
Richardson Adams, PLLC
515 N.27th Street
P.O. Box 7218
Boise,Idatro 83702
Telephone: [phone]
Fax: [phone]
Peter@richardsonandol.*r..o'n
Attorneys for the Industrial Customers of Idaho Power
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR AN )
ORDER APPROVING THE TRANSFER JAND SALE OF CERTAIN ASSETS TO )
THE UNITED STATES DEPARTMENT OF)
)
)
)
)
JUSTICE FEDERAL BUREAU OF
INVESTIGATION.
CASE NO. TPC.E-15-26
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The lndustrial Customers of Idatro Power ('ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company
("Company") provide the following documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplementary responses additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at 6070 Hill Road, Boise, Idaho 83703, Tel:
ICIP First Production Request - IPC-E- l 5-26
[phone]; Fax: [phone] I ; [e-mail]
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
If some of the following requests include disclosures deemed by Idaho Power to be
confidential, the ICIP has already entered into Idaho Power's standard confidentiality agreement.
REOUEST FOR PRODUCTION NO. 1
Please provide all of the Company's discovery responses to all other parties regardless of
whether said requests for discovery were formal or informal.
REOUEST X'OR PRODUCTION NO. 2
Please provide a confidential copy of Attachment 1 that was attached to the Company's
application.
REOUEST FOR PRODUCTION NO. 3
The Application at pages 7 - 8 list items (a) through (e) that were used to derive the sale
price of the assets proposed to be transferred. Please provide, in electronic format where
possible, all documents, workpapers and spreadsheets used in the determination of the sale price.
Specifically please include the worksheets with an explanation of the inputs supporting the
calculation of:
A) Net Book Value
B) True-up[ of Past Levelized Rate of Retum
C) Near-term Rate of Retum Impact Resulting from the Sale of Assets
D) Near-term Operational Impact Resulting from the Sale of Assets
E) Net Tax Gross-up.
DATED this 15th day of December 2015.
ICIP Fint Production Request - IPC-E-I5-26
Richardson Adams, PLLC
Industial Customers of Idatro Power
ICIP Fint Pmduction Request- IPC-E-I5-26
CERTII'ICATE OF SERVICE
I HEREBY CERTIFY that on the 15th day of December.2}ll, a true and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POWER, in Docket No. IPC-E-15-26 was
served as indicated below to:
Ms. Jean Jewell
Commission Secretary
Idaho Fublic Utilities Commission
P O Box 83720
Boise [D 83720-0074
Lisa D. Nordstrom
Idaho Power Company
l22l West ldatro Steet
P.O. Box 70
Boise,Idatro 83707
lnordstrom@idahopower. com
dockets@idahopower. com
Tami White
Idatro Power Company
1221 West Idaho Steet
P.O. Box 70
Boise,Idaho 83707
ttatum@ idahopower. com
Nina Curtis
Administrative Assistant
X_ Hand Delivery
_ U.S. Mail, postage pre-paid
Facsimile
-X Hand Delivery
_ U.S. Mail, postage pre-paid
_ Facsimile
X Electronic Mail
X_ Hand Delivery
_U.S. Mail, postage pre-paid
_Facsimile
X* Electronic Mail
X_ Electronic Mail
ICIP First Production Request - IPC-E- l 5-26