20200521Supplemental Response 1.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
May 1 ,2020
ELECTRONIC FILING
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-20-15
2019 Demand-Side Management Expenses - ldaho Power Company's
Supplemental Response to the First Production Request of the lndustrial
Customers of ldaho Power
Dear Ms. Hanian:
Attached for electronic filing is ldaho Power Company's Supplemental Response to
the First Production Request of the lndustria! Customers of ldaho Power. lf you have any
questions about the attached document, please do not hesitate to contact me.
Very truly yours,
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Lisa D. Nordstrom
AnD OOAPOompany
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Attachment
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ ida ho power. co m
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINIATION OF 2019 DEMAND.
SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURED
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CASE NO. !PC-E-20-15
IDAHO POWER COMPANY'S
SUPPLEMENTAL RESPONSE
TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO
POWER
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company") and
supplements its response to the First Production Request of the lndustrial Customers of
ldaho Powerdated April 10,2020, asfollows:
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER. 1
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 informa! as well as formal requests and oral as well as written requests.
SUPPLEMENTAL RESPONSE TO REQUEST NO. 1: Please see Idaho Powe/s
responses to the ldaho Public Utilities Commission Staffs Audit Request Nos. 5-6 that
have been uploaded to the FTP site created for discovery responses in this matter. The
attachments provided in response to Staffs Audit Request Nos. 5-6 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 lndustria! Customers of ldaho
Power.
The response to this Request is sponsored by Lisa Nordstrom, Lead Counsel,
ldaho Power Company.
DATED at Boise, ldaho, this 21st day of May 2O20
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LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER-2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 21st day of May 2020,1 served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY'S SUPPLEMENTAL
RESPONSE TO THE FIRST PRODUCTION REQUEST OF COMMISSION STAFF upon
the following named parties by the method indicated below, and addressed to the
following:
Commission Staff
Edward Jewe!!
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 837 20-007 4
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6h Street
Boise, ldaho 83702
lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho lrrigation Pumpers Assoc., lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
Hand Delivered
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IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER - 3
Gity of Boise
Abigail R. Germain
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701 -0500
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Je)4&
Sandra D. Holmes
Legal Adm inistrative Assistant
IDAHO POWER COMPANY'S SUPPLETIENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE INDI.'STRIAL CUSTOMERS
OF IDAHO POWER-4