20160516IPC to ICIP 1-9.pdf

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LISA D. NORDSTROM
Lead Counsel
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May 16, 2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
47 2 W esl Wash ington Street
Boise, ldaho 83702
Re: Case No. IPC-E-16-08
2016-2017 Power Cost Adjustment - ldaho Power Company's Response to
the First Production Request of the lndustrial Customers of ldaho Power
Dear Ms. Jewel!:
Enclosed forfiling in the above matter please find an original and three (3) copies of
Idaho Power Company's Response to the First Production Request of the Industrial
Customers of ldaho Power.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing information responsive to the lndustrial Customers of ldaho Power's production
requests. Please handle the confidential information in accordance with the Protective
Agreement executed in this matter.
Very truly yours,
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n ord strom @ ida hopowe r. com
Attorney for ldaho Power Company
iiECEIVED
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BEFORE THE IDAHO PUBLIC UTILIT!ES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER
COST ADJUSTMENT (PCA) RATES FOR
ELECTRIC SERVICE FROM JUNE 1,2016
THROUGH MAY 31,2017
CASE NO. IPC-E-16-08
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, ldaho Power Company ("!daho Power" or "Comp?[y"), and in
response to the First Production Request of the lndustrial Customers of ldaho Power
dated May 3, 2016, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER. 1
REQUEST 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see Idaho
Power's responses to the ldaho Public Utilities Commission Staffs Audit Request Nos.
1-25 provided on the non-confidential and confidential CDs. The confidential CD will
only be provided to those parties that have executed the Protective Agreement in this
matter. All other responses to other parties'discovery have previously been provided to
the lndustrial Customers of ldaho Power.
The response to this Request is sponsored by Christa Bearry, Legal Assistant,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 2: Please provide a working electronic
copy of Table 1 contained in Matthew Larkin's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see the Excel
file provided on the non-confidential CD.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
REQUEST 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The Operating Plan
used for the Power Cost Adjustment ('PCA') forecast is part of the Risk Management
Committee minutes and is confidential. lt is available for on-site review. Please contact
Doug Jones at [phone] or Camilla McClusky at [phone] to schedule a
time to review the document.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
REQUEST FOR PRODUCTION NO. 4: Please provide a working electronic
copy of Table 4 contained in Matthew Larkin's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see the Excel
file provided on the non-confidential CD.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
REQUEST FOR PRODUCTION NO. 5: Please provide a working electronic
copy of Exhibit No.1 aftached to Matthew Larkin's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the Excel
file provided on the non-confidentia! CD.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
REQUEST FOR PRODUGTION NO. 6: Please provide a working electronic
copy of Exhibit No. 2 attached to Matthew Larkin's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Please see the Excel
file provided on the non-confidential CD.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 7: Please provide a working electronic
copy of Exhibit No. 5 attached to Matthew Larkin's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: Please see the Excel
file provided on the non-confidential CD.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
REQUEST FOR PRODUCTION NO. 8: Please provide a working electronic
copy of Attachment No. 2 to ldaho Power's Application.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Please see the Excel
file provided on the non-confidential CD.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
REQUEST FOR PRODUCTION NO. 9: Please provide copies of al!
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Please see the most
recent Securities and Exchange Commission Form 10-Q that was filed on April 28,
2016, provided on the non-confidential CD. On pages 4A, 47, and 48 of the document,
the Company discusses the current PCA filing with the ldaho Public Utilities
Commission.
The response to this Request is sponsored by Lawrence F. Spencer, Director of
lnvestor Relations, ldaho Power Company.
DATED at Boise, ldaho, this 16th day of May 2016.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1O
SA D. NOR OM
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 16th day of May 2016 I 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:
Commission Staff
Brandon Karpen
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Wash i ngton (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
lndustrial Gustomers 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, ldaho 83703
X Hand Delivered
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Overnight Mail
FAXX Email [e-mail]
Hand DeliveredX U.S. Mail
_Overnight Mail
FAX
Email peter@ richardsonadams.com
g reg@ richardsonad ams. com
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 11