20200707IPC to ICIP Third Supplemental Response 1.pdf

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LISA D. NORDSTRO]II
Lead Coungel
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July 7, 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
Third Supplemenhl 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 Third Supplemenhl
Response to the First Production Request of the lndustrial Customers of ldaho Power. lf
you have any questions about the attached documents, please do not hesitate to contract
me.
Very truly yours,
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
I nordstrom @ ida hopower. com
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
THIRD 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 Supplemental Response to the First Production Request
of the lndustrial Customers of ldaho Power dated May 1 ,2020, as follows:
IDAHO POWER COMPANY'S THIRD SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER - 1
REQUEST NO. l: 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 wellas formal requests and oral as well as written requests.
THIRD SUPPLEMENTAL RESPONSE TO REQUEST NO. 1: Please see ldaho
Power's responses to the ldaho Public Utilities Commission Staffs Audit Request No. 14
that have been uptoaded to the FTP site created for discovery responses in this mafter.
The attachment and sample selections provided in response to Staffs Audit Request No.
14 are confidential. The password to the confidential folder on the FTP site will 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 7th day of July 2020.
"(*I.(,,*+,..*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S THIRD SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 7h day of July 2020, I served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY'S THIRD SUPPLETIENTAL
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
Dayn Hardie
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, fdaho 83720-0074
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
lndustrial Customerc of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 72',8
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho lrrigation Pumperr Assoc., lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
Hand Delivered
_U.S. Mail
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U.S. Mail
Overnight Mail
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_FA)(X FTPX Emai! [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FA)(X FTPX Emai! [e-mail]
IDAHO POWER COMPANY'S THIRD SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER .3
Clty of Bolse
Abigail R. Germain
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701-0500
_Hand Delivered
_U.S. Mail
_Ovemight Mail
_FN(X FTPX Email [e-mail]
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Sandra D. Holmes
Legal Adminiskative Assistant
IDAHO POWER COMPANYS THIRD SUPPLEMENTAL RESPONSE TO
THE FTRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POVVER.4