20151228IPC to ICIP 1-3.pdf

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LISA D. NORDSTROM
Lead Counsel
December 28,2015
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-15-26
Application for Approval of the Transfer and Sale of Certain Assets to the
United States Department of Justice Federal Bureau of lnvestigation
- ldaho Power Company's Response to the First Production Request of the
Industrial Customers of ldaho Power
Dear Ms. Jewell:
Enclosed forfiling in the above matter please find an originaland three (3) copies of
ldaho Power Company's Response to the First Production Request of the Industria!
Customers of ldaho Power ("lClP').
ln addition, enclosed are four (4) copies of the confidential attachment provided in
response to lClP's Request No. 2. Please handle the confidential information in
accordance with the Protective Agreement executed in this matter.
lf you have any questions about this filing, please do not hesitate to contact me.
Very truly yours,-?.fir- e%^U.,,"^,
Lisa D. Nordstrom \-
LDN:kkt
Enclosures
/
LISA D. NoRDSTRoM (lSB No. 5733) i- [ t I :!'i: i]
ldaho Power Company ?nrr n!:^ 4,' h,, r . ,rF
1221 West ldaho Street (83702) ?BI5 DIC 2B Pl{ l: 25
P.O. Box 70 lij,\ii,.r t'u;tiij
Boise, ldaho 83707 UTtLlTl[$ 00i,{$rllli$l0l''l
Telephone: [phone]
Facsimile: [phone]
I no rdstro m @ ida hopowe r. co m
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF THE APPLICATTON OF )
IDAHO POWER COMPANY FOR AN ) CASE NO. !PC-E-15-26
ORDER APPROVING THE TRANSFER AND )
SALE OF CERTAIN ASSETS TO THE ) TDAHO POWER COMPANY',S
UNITED STATES DEPARTMENT OF ) RESPONSE TO THE FIRST
JUSTTCE FEDERAL BUREAU OF ) PRODUCTTON REQUEST OF
INVESTIGATION.) THE TNDUSTRTAL CUSTOMERS
) oF IDAHO POWER
COMES NOW, Idaho Power Company ("ldaho Powe/' or "Comp?fly"), and in
response to the First Production Request of the lndustrial Customers of ldaho Power
("|CIP") dated December 15,2015, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST NO. 1: Please provide al! of the Company's discovery responses to
all other parties regardless of whether said requests for discovery were formal or
informal.
RESPONSE TO REQUEST NO. 1: ldaho Public Utilities Commission
("Commission") Staff is the only party that has submitted discovery requests to date.
The response to Commission Staffs Firct Production Request was served on lClP at
the time the response was filed.
The response to this Request is sponsored by Kimberly Towell, Executive
Assistant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST NO. 2: Please provide a confidential copy of Attachment 1 that was
attached to the Company's application.
RESPONSE TO REQUEST NO. 2: Please see the confidential pages of the
attached Asset Purchase and Transfer of Title Agreement. The confidential pages will
only be provided to those parties that have executed the Protective Agreement in this
matter.
The response to this Request is sponsored by Zach Harris, Regulatory Analyst Il,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
REQUEST 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 transfened. 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 Return
C) Near-term Rate of Return lmpact Resulting from the Sale of Assets
D) Near-term Operational lmpact Resulting from the Sale of Assets
E) Net Tax Gross-up.
RESPONSE TO REQUEST NO. 3: Please see the confidential Excel file
provided on the confidential CD in the Company's response to Staffs Data Request No.
1.
The response to this Request is sponsored by Zach Hanis, Regulatory Analyst ll,
ldaho Power Company.
DATED at Boise, Idaho, this 28th day of December 2015.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28th day of December 20151 served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
upon the following named parties by the method indicated below, and addressed to the
following:
Gommission Staff
Daphne Huang
Deputy Attomey General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Customers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
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FAXX Email [e-mail]
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE ]NDUSTRIAL CUSTOMERS OF IDAHO POWER - 5