20200630IPC to ICIP Supplemental Response 2.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
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Lisa D. Nordstrom
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June 30, 2020
ELECTRONIC FILING
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Buifding 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-20-15
2019 Demand-Side Management Expenses - ldaho Power Company's
Second Supplemental Response to the First Production Request of the
Industrial Customers of ldaho Power
Dear Ms. Hanian:
Attached for electronic filing is ldaho Power Company's Second Supplemenhl
Response to the First Produc{ion Request of the lndustrial Customers of ldaho Power. If
you have any questions about the attached document, please do not hesitate to contact
me.
Very truly yours,
LISA D. NORDSTROM (!SB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom @ ida hopowel. 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
CASE NO. !PC-E-20-15
IDAHO POWER COMPANY'S
SECOND SUPPLEMENTAL
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, ldaho Power Company ('ldaho Power" or "Company") and
supplements its response to the Supplementa! Response to the First Production Request
of the lndustrial Customers of ldaho Power dated May 1 ,2020, as follows:
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER - 1
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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.
SECOND SUPPLEMENTAL RESPONSE TO REQUEST NO. 1: Please see
ldaho Power's responses to the ldaho Public Utilities Commission Staffs Audit Request
Nos. 7-13 that have been uploaded to the FTP site created for discovery responses in
this matter. The attachment provided in response to Staffs Audit Request No. I is
confidential. The password to the confidentialfolder on the FTP site willonly 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 lndustrial
Customers of ldaho Power.
The response to this Request is sponsored by Lisa Nordstrom, Lead Counsel,
ldaho Power Company.
DATED at Boise, ldaho, this 30th day of June 2020
X^!.('w,".*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IOAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 30th day of June 2020, I served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY'S SECOND
SUPPLEiIENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF upon the following named parties by the method indicated below,
and addressed to the following:
Gommission Staff
Dayn Hardie
Deputy Attorney Genera I
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
lndusfial Customerc of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (S3702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Idaho lrrigation Pumpera 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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Overnight Mail
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U.S. Mail
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_FAXX FTPX Email [e-mail]
IDAHO POWER COMPANY'S SECOND SUPPLEIUENTAL RESPONSE TO
THE FIRST PROOUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER - 3
City of Boise
Abigail R. &rmain
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box Sfi)
Boise, ldaho 83701-0500
Hand Delivered
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Sandra D. Holmee
Legal Adminisfrative Assistant
IDAHO PO/\,ER COfI,IPANYS 8EGO]{D SUPPLETEI{TAL RESPONSE TO
THE FIRST PROOUGTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO FOVI'ER-4