20160518ICIP 10 to IPC.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone : [phone]
Fax: [phone]
peter@richardsonadams. com
gre g@richardsonadams. com
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Attomeys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. TPC-E-16-08
APPLTCATION OF rDAHO POWER )
COMPANY FOR AUTHORITY TO ) SECOND PRODUCTION REQUEST
IMPLEMENT POWER COST ) OF THE TNDUSTRIAL CUSTOMERS
ADJUSTMENT ("pCA") RATES FOR ) OF IDAHO POWER
ELECTRIC SERVICE FROM JUNE I, )
2016 THROUGH MAY 3I.2OI7
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Industrial Customers of Idaho Power ('ICP") by and through their
attorney of record, Peter J. Richardson, hereby requests that tdaho 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:
[phone]; Fax: (208) 3 84- I 5 1 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. 10
On page l0 of the Direct Testimony of ldaho Power witness Matthew Larkin he states
this year's PCA forecast anticipates an increase of 257,857 MWh of PURPA generation
over last year's forecast. This increase is largely due to the expecte d 320 MW of solar
projects. The Pocatello Airport on May 16,2016 announced the solar project planned on
their property has been withdrawn. Please fully answer the following;
a) Was the Pocatello Airport solar project included in this year's PCA forecast?
b) If so what was the size of the solar project at the Pocatello Airport?
c) If so what should be the reduction in the projection of MWh from this year's PCA
forecast?
d) If so what should be the dollar reduction in the Account 555, PURPA that is
included in this year's PCA request by the Company?
e) Does the Company intend to update its Application in this matter to reflect this
change? Why or why not?
DATED this l8th day of May,20l6
SECOND PRODUCTTON REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-16-08
PAGE 2
Industrial Customers of ldaho Power
CERTIFICATE OF SERVTCE
I hereby certify that on May 3rd, 2016, copies of the foregoing First Production Request of the
Industrial Customers of tdatro Power in DocketNo. IPC-E-I6-08 were served electronically and
by HAND DELIVERY, to:
LisaNordstrom
Idatro Power Company
l22l West Idaho
Boise,Idatro 83702
Timothy E. Tatum
Idaho Power Company
1221 West Idatro
Boise,Idaho 83702
Gc"A/-
Kandi Walters
Administrative Assi stant
SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
rPC-E-16-08
PAGE 3
Jean Jewel
Secretary
Idatro Public Utilities Com'n
472 West Idatro
Boise,Idaho 83702