20160503ICIP 1-9 to IPC.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27ft Street
Boise,Idaho 83702
Telephone : [phone]
Fax: [phone]
Peter@richardsonudrrt..o-
gre g@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
TMPLEMENT POWER COST
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER
RECE IVED
1016 Hf\Y -3 Pil 3: I I
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) cAsE NO. TPC-E-r6-08
APPLICATTON OF IDAHO POWER )
COMPANY FOR AUTHORTTY TO )
ADJUSTMENT ("PCA") RATES FROM )
JUNE I,2016 THROUGH MAY 3I,2OI7 )
Pursuant to Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission
(the "Commission"), The lndustrial Customers of ldaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idatro 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, Idatro 83703, Tel:
[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.
REOUEST FOR PRODUCTION NO. 1
Please provide all discovery responses related to this docket, whether 'formal' or
informal and all exchanges of information along with workpapers and attachments
provided IPUC Staff and/or other entities, whether or not they are a Party.
REOUEST FOR PRODUCTION NO. 2
Please provide a working electronic copy of Table I contained in Matthew Larkin's
Direct Testimony.
REOUEST FOR PRODUCTION NO. 3
Please provide a copy of ldaho Power's March 31,2016 Operating Plan that was used to
support the forecast in Table 1 of Matthew Larkin's Direct Testimony.
REOUEST FOR PRODUCTION NO. 4
Please provide a working electronic copy of Table 4 contained in Matthew Larkin's
Direct Testimony.
REOUEST FOR PRODUCTION NO. 5
Please provide a working electronic copy of Exhibit No. 1 attached to Matthew Larkin's
Direct Testimony.
REOUEST FOR PRODUCTION NO. 6
Please provide a working electronic copy of Exhibit No. 2 attached to Matthew Larkin's
Direct Testimony.
REOUEST FOR PRODUCTION NO. 7
Please provide a working electronic copy of Exhibit No. 5 attached to Matthew Larkin's
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-16-08
PAGE 2
Direct Testimony.
REQUEST FOR PRODUCTION NO. 8
Please provide a working electronic copy of AttachmentNo. 2 to Idaho Power's
Application.
REOUEST FOR PRODUCTION NO. 9
Please provide copies of all correspondence, reports or other written materials provided
to shareholders, financial institutions, stock rating agencies, governmental units or any
other entity discussing the impact or potential impact of the current PCA on the
Company's earnings, financial status and/or stock price.
DATED this 3rd day of May,20l6
Richardson Adams, PLLC*PN),M
Peter J. Richardson
lndustrial Customers of ldatro Power
FIRST PRODUCTTON REQUEST OF THE TNDUSTRIAL CUSTOMERS OF TDAHO
POWER
rPC-E-16-08
PAGE 3
CERTIFICATE OF SERVICE
I hereby certify that on May 3rd, 2016, copies of the foregoing First Production Request
of the Industrial Customers of Idatro Power in Docket No. IPC-E-16-08 were hand delivered to:
Lisa Nordstrom
Idatro Power Company
1221 West Idaho
Boise,Idaho 83702
Timothy E. Tatum
Idaho Power Company
1221 West Idaho
Boise,Idaho 83702
Jean Jewel
Secretary
Idatro Public Utilities Com'n
472West Idaho
Boise,Idaho 83702
"'tg^fg*Kandi Walters
Administative Assistant
FIRST PRODUCTION REQUEST OF THE TNDUSTRIAL CUSTOMERS OF IDAHO
POWER
rPC-E-16-08
PAGE 4