20181121Staff 1 to IPC.pdf

SEAN COSTELLO
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NOS .8743
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY TO STUDY FIXED
COSTS OF PROVIDING ELECTRIC SERVICE
TO CUSTOMERS.
CASE NO.IPC.E.18.I6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(Idaho Power; Company) provide the following documents and information as soon as possible, and
no later than WEDNESDAY, DECEMBER 12, 2018.
This Production Request is 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 answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. See IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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NOVEMBER 2I, 2018I
REQUEST NO. 1: In Order No. 34046, the Commission ordered the Company to
"undertake a comprehensive customer fixed cost analysis" to include "exploring fixed-cost recovery
in basic charges and other rate design options." See Order No. 34046 at 23. Please provide all
relevant studies and reports conducted by the Company or on its behalf within the last 3 years.
DATED at Boise, Idaho, this 2 / day of November 2018
Sean Costello
Deputy Attorney General
i:umisc:prodreq/ipcelS.l6scmm prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 NOVEMBER 21, 2OI8
CBRTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21't DAY OFNOVEMBER2Ol8,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-I8-I6,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
TIM TATUM
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
ELECTRONIC ONLY
dockets@idahopower. com
SECRETARY
CERTIFICATE OF SERVICE