20190717Staff 3-7 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
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
FOR LIGHT EMITTING DIODE
TECHNOLOGY
CASE NO. IPC-E-19-17
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
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?019 JUL l7 PH Z: 0lr
iDAri0 ilUBLIC
-JT ILITIES COIIMISSION
Street Address for Express Mail
472 W. 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 attomey of record,
Dayn Hardie, Deputy Attorney General, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
AUGUST 7,2019.
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
SECOND PRODUCTION REQUEST
TO IDAHO POWER I JULY 17,2OI9
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.3: Please provide workpapers in Excel with formulae intact and
enabled supporting lines 4-9, page 23, of Ms. Patteson's testimony. Please include:
a. the calculation of the current revenue requirement from Schedules 15 and 41
related to the cost components at issue in this case;
b. the current revenue requirements of the business-as-usual case; and
c. the revenue requirement for the LED installation scenarios.
REQUEST NO. 4: Please provide manufacturer specifications, datasheets, etc., for the
proposed lighting fixtures.
REQUEST NO. 5: Please provide documentation and evidence supporting the reduction
in maintenance needed for the LED installation scenario referenced on page 4 of the Application.
REQUEST NO. 6: Please provide the current cost for the lighting inventory identified
on lines l4-l9,page28, of Ms. Patteson's testimony and also the predicted future cost of needed
LED lighting inventory. Please provide evidence and justification to support your response.
REQUEST NO. 7: Please explain the necessary steps and associated expense for
removal and disposal of existing lighting from inventory.
DATED at Boise, Idaho, this l.?Sauy of July 2019
--l! dul /L
Dayn ltdrdie
Deputy Attomey General
i:umisc:prodreq/ipcel9. I Tdhrk prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 17,2OI9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ITth DAY OF JULY 2019,
SERVED THE FOREGOING SECOND PRODUCTION RE,QUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-19-17,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
[e-mail]
TIM TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
caschenbrenner@ idahopower. com
CERTIFICATE OF SERVICE