20200410ICIP 1 to IPC.pdf

Peter J. Richardson ISB # 3195
Greg Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702
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IN THE MATTER OF IDAHO POWER'S
APPLICATION FOR A
DETERMINATION OF 2OI9 DEMAND
SIDE MANAGEMENT EXPENSES AS
PRUDENTLY TNCURRED
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Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-20.15
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the Industrial Customers of Idaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("Idaho
Power" or the "Company") provide the following documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplemental responses additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703,
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For each item, please indicate the name of the person(s) preparing the answer(s), along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
First Production Request of the Industrial Customers of Idaho Power
rPC-E-20-15
Page I
RECEIVED
2020 April 10,PM10:08
IDAHO PUBLIC
UTILITIES COMMISSION
REQUEST FOR PRODUCTION NO. 1:
Please provide copies of all of the company's responses to data requests from the IPUC
Staff (or any other party) in this matter. Please include responses to informal as well as formal
requests and oral as well as written requests.
Dated this lOth day of April2020
RICHARDSON ADAMS, PLLC
BY
Peter Richardson, ISB # 3195
Attorneys for the Industrial Customers
of Idaho Power
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1Oth of April 2020,a true and correct copy of the within
and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER in Docket No. IPC-E-20-15 was served, pursuant to
Commission Order No. 34602, exclusively via electronic mail to:
Idaho Public Utilities Commission
Diane Hanian, Secretary
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First Production Request of the Industrial Customers of Idaho Power
rPC-E-20-15
Page 2
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By:
Peter Richardson,
Attorney for the Industrial Customers of Idaho Power
First Production Request of the Industrial Customers of Idaho Power
IPC-E-20-15
Page 3
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