20200501IPC to ICIP 1.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

May 1, 2020

ELECTRONIC FILING

Diane Hanian, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-20-15
2019 Demand-Side Management Expenses – Idaho Power Company’s
Response to the First Production Request of the Industrial Customers of
Idaho Power

Dear Ms. Hanian:

Attached for electronic filing is Idaho Power Company’s Response to the First
Production Request of the Industrial Customers of Idaho Power. If you have any questions
about the attached document, please do not hesitate to contact me.

Very truly yours,

Lisa D. Nordstrom
LDN:kkt

Attachment
RECEIVED
2020 May 1,PM3:17
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
DETERMINATION OF 2019 DEMAND-
SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED

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CASE NO. IPC-E-20-15

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER

COMES NOW, Idaho Power Company, and in response to the First Production
Request of the Industrial Customers of Idaho Power to Idaho Power Company (“Idaho
Power” or “Company”) dated April 10, 2020, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST 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.
RESPONSE TO REQUEST NO. 1: Please see Idaho Power’s responses to the
Idaho Public Utilities Commission Staff’s Audit Request Nos. 1-4 that have been
uploaded to the FTP site created for discovery responses in this matter. The
attachments provided in response to Staff’s Audit Request Nos. 1-4 are confidential.
The password to the confidential folder on the FTP site will only be provided to those
parties that have executed the Protective Agreement in this matter. All other responses
to parties’ discovery have previously been provided to the Industrial Customers of Idaho
Power.
The response to this Request is sponsored by Kimberly Towell, Executive
Assistant, Idaho Power Company.
DATED at Boise, Idaho, this 1st day of May 2020.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 1st day of May 2020 I served a true and correct
copy of IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the
following named parties by the method indicated below, and addressed to the following:

Commission Staff
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Hand Delivered
U.S. Mail
Overnight Mail
FAX
X FTP Site
X Email [e-mail]

Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

Hand Delivered
U.S. Mail
Overnight Mail
FAX
X FTP Site
X Email [e-mail]

Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X FTP Site
X Email [e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707

Hand Delivered
U.S. Mail
Overnight Mail
FAX
X FTP Site
X Email [e-mail]

Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X FTP Site
X Email [e-mail]

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702

Hand Delivered
U.S. Mail
Overnight Mail
FAX
X FTP Site
X Email [e-mail]

City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney’s Office
150 North Capitol Boulevard
P.O. Box 500
Boise, Idaho 83701-0500

Hand Delivered
U.S. Mail
Overnight Mail
FAX
X FTP Site
X Email [e-mail]

________________________________
Kimberly Towell, Executive Assistant