20190605Staff 1-2 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO MODIFY SCHEDULE 15, DUSK TO DAWN
CUSTOMER LIGHTING, AND SCHEDULE 4I,
STREET LIGHTING SERVICE, TO ALLOW
F'OR LIGHT EMITTING DIODE
TECHNOLOGY
CASE NO. IPC-E-I9.I7
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
RECEIVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that ldaho Power Company provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
JUNE 19,2019.r
This Production Request is to be considered as continuing, and Idaho Power 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 or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER I JI-iNE 5,2019
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide Exhibit No. 3 in Microsoft Excel electronic format,
with formulas intact and enabled. Additionally, please provide all workpapers supporting the
values in Exhibit No. 3, such as the changes to Electric Plant in Service Distribution Plant and
Operation and Maintenance Expenses.
REQUEST NO. 2: Please provide the workpapers, with formulas intact and enabled,
used to quantify the levelized energy savings of $250,000.00.
DATED at Boise, Idaho, this day of June 2019.
Deputy Attorney General
i:umisc:prodreq/ipce I 9. I Tdhrk prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 5,20T9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5th DAY OF JUNE 2019, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY,IN CASE NO. IPC-E-19-17, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail : [e-mail]
dockets@idahopower. com
TIM TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
caschenbrenner@ idahopower. com
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CERTIFICATE OF SERVICE