20200116Staff 1-5 to Jeff Comer.pdf

EDWARDJEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BARNO. 10446
RECEIVED
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Street Address fbr Express Mail:
I I331 W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, ID 837I4
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
FoRMAL COMPLAINT OF JEFF COMER
AGAINST IDAHO POWER COMPANY CASE NO. IPC.E.I9.28
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Edward Jewell, Deputy Attomey General, request that JeffComer (Mr. Comer) provide the
following documents and information as soon as possible, or by THURSDAY,
FEBRUARY 6,2020.
This Production Request is continuing, and Mr. Comer is requested to provide, by way ol
supplementary responses, additional documents that he or any person acting on his behalf may later
obtain that will augment the documents produced.
Please provide answers to each question. Mr. Comer 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. Reference IDAPA 31.01.01.228.
FIRST PRODUCTION REQUEST
TO JEFF COMER JANT]ARY 16.2020
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I'IRST PRODUCTION
REQITE,ST OF THE
COMMISSION STAFF TO
.IEFF COMER
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REQUEST N0. l: Please provide all documentation establishing a bonafide legal
partnership between Mr. Comer and Mr. Goodman for the development and operation of the small
hydroelectric facility at issue in this complaint.
REQUEST NO. 2: Please provide documentation showing funding contributions by both
Mr. Goodman and Mr. Comcr for the Goodco partnership, or construction and operation of the
hydroelectric facility.
REQUEST N0.3: Please provide all relevant documentation from state and federal
administrative agencies demonstrating rights and responsibilities in the name ofGoodco Power.
Examples include but are not limited to water rights issued by the state ofldaho, and any licenses
issued by the Federal Energy Regulatory Commission.
REQUEST NO. 5: Please provide documentation showing Idaho Power sends a usage
statement for Goodco Power to Mr. Goodman's address.
DATED at Boise, Idaho, this tC' dav ol'Januarv 2020
Edward J
Deputy Attoiney General
i:unlisc:prodreq/ipcel9.28ej prod rcql
FIRST PRODUCTION REQUEST
1'O.IEFF COMER
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REQUEST NO. 4: Please provide documentation oi correspondence between either
Mr. Goodman, Mr. Comer, or Goodco Powcr and Idaho Power Company demonstrating that Idaho
Power worked cooperatively with the project developers to design, construct, and interconnect the
project to comply with the Company's tariffs.
.IANUARY 16,2O2O
Cf,RTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l6th DAY OF JANUARY 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO JEFF COMER, IN CASE NO, IPC-E-19-28, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, 1'O THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
KRISTY PATTESON
IDAHO POWER COMPANY
PO BOX 70
BOISE lD 83707-0070
E-mail:daho f.conl
E-mail : lnordstronrr2t);i dahopower.com
dockets,2idahollo\\'el'.colI
JEFF COMER
4186N ll00E
BUHL ID 83316
SECRET
CFRTIFICATF, OF SERVI(-I-,
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