20190403Staff 1-2 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
n :,a r: l\,'r- nI!!*i'./.-l'C r-L/
!i'il *3 Fii 2: I I
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83102-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO INCREASE ITS RATES FOR ELECTRIC
SERVICE TO RECOVER COSTS ASSOCIATED
WITH THE NORTH VALMY PLANT.
CASE NO.IPC-E-19-08
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Idaho Power Company (Company) provide
the following documents and information as soon as possible, or by MONDAY, APRIL 81 2019.1
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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs attorney
at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER
)
)
)
)
)
)
)
)
I APRIL 3,2019
i1
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3 I .0 l .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.
REQUEST NO. 1: Please provide all workpapers, tables, and exhibits presented in both
Larkin and Harvey Direct Testimonies in electronic format with formulas intact. Staff also requests
a meeting with the Company, on or about April 11,2019. The purpose of this meeting is to allow
the Company to walk through the Company's application and workpapers to provide Staff with a
better understanding of the calculations in the case.
REQUEST NO.2: In reference to Larkin testimony pages 13 and 14, please provide
workpapers that document the$12.2 million reduction in overall costs for customers.
DATED at Boise,Idaho, this 3,])day of April2019
*-o / /L-
€, r:Edward Jewell
Deputy Attorney General
i:umisc:prodreq/ipce I 9.8ejrk prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 3,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF APRIL 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO. IPC-E-19-08,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA A HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail : j [e-mail]
dockets@ idahopower. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: botto@,idahoconservation.orq
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
Y
CERTIFICATE OF SERVICE