20190718Staff 31 to IPC.pdf

RICEIVEDMATT HLTNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
TDAHO BAR NO. 10655
?OI9 JUL IB PH 2: I 2
iilAilC TUELIC
-!'l i L il' I E *q COHh{ ISS l0l'l
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2018 DEMAND-SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURRED
CASE NO. IPC.E-19-11
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(ldaho Power; Company) provide the following documents and information as soon as possible,
by THURSDAY, AUGUST 1,2019.r
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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
THIRD PRODUCTION REQUEST
TO IDAHO POWER
)
)
)
)
)
)
)
)
I JULY 18,2079
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0t.0t.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.31: Please provide the Company's DSM labor expense and DSM full-
time equivalent employees for 2017 and 2018.
Dated at Boise, Idaho, this day of July 2019.
Hunter
Deputy Attorney General
i/utility/umisc/production requests/ipcel 9. I lmhck prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 JULY I8,20I9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ISTH DAY OF JULY 2019,
SERVED THE FOREGOTNG THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-Ig-II, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
dockets@i dahopower. com
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83701-0010
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE ID 83702
E-mail: [e-mail]
ABIGAIL R GERMAINE
BOISE CITY ATTORNEY'S OFFICE
PO BOX 500
BOrSE rD 83701-0s00
E-MAIL: [e-mail]
\-O*.*r"R7--
CERTIFICATE OF SERVICE
ZOr-^