20200909Sierra Club 1-2 to IPC.pdf

Kelsey Jae, ISB No. 7899
LAW FOR CONSCIOUS LEADERSHIP
920 N. Clover Dr.
Boise, ID 83703
Telephone: [phone]
[e-mail]
Attorney for Sierra Club
Lisa Young
Michael Heckler
IDAHO SIERRA CLUB
503 W Franklin St
Boise, ID 83702
Telephone: [phone]
[e-mail]
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY’S 
APPLICATION FOR AUTHORITY TO MODIFY 
SCHEDULE 84’s METERING REQUIREMENT AND 
TO GRANDFATHER EXISTING CUSTOMERS WITH 
TWO METERS. 
IPC-E-20-26
IDAHO SIERRA CLUB’S
FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY
COMES NOW Idaho Sierra Club (“Sierra Club”), by and through its attorney of record,
Kelsey Jae of the firm Law for Conscious Leadership, request that Idaho Power Company
(“Idaho Power” or “the Company”) provide the following documents within 21 days, preferably
14 days to make requested data available prior to the September 28 staff workshop.
This Production Request is continuing, and Idaho Power is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced. Please provide answers to each question
Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-20-26
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RECEIVED
September 9, 2020 8:38:14 AM
IDAHO PUBLIC
UTILITIES COMMISSION
with supporting workpapers that provide detail or are the source of information used in
calculations. Please provide any Excel files with formulas active. Additionally, please include
the name and phone number of the person preparing the document, and the name, location, and
phone number of the record holder and, if different, the witness who can sponsor the answer at a
hearing if needed.
REQUEST NO 1.​ For the entire year of 2019 and for the months of January through
August of 2020, please provide in Excel format the date and hour-ending time of all load hours
per year (8760+ data points per whole year). For each of these data points, please provide the
load being served during that hour.
REQUEST NO 2.​ For the months of May through September inclusive during the years
2017 through 2019 and for the months of May through August of 2020, please provide in Excel
format the date and hour-ending time of all load hours per the months designated (3,672 data
points for years 2017-2019 and 2,952 data points for year 2020). For each of these data points,
please provide the total Schedule 24 load being served during that hour.

Dated this 9th day of September, 2020.

Respectfully submitted,

___________________________________
Kelsey Jae, Attorney for Sierra Club

Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-20-26
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CERTIFICATE OF SERVICE

I hereby certify that on this 9th day of September, 2020, I delivered true and correct
copies of the foregoing Request for Production to the following persons via electronic mail
delivery:

Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]

Idaho Public Utilities Commission Staff
Edward Jewell
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
Idaho Power Company
Lisa D. Nordstrom
Tim Tatum
Connie Aschenbrenner
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Idaho Conservation League
Benjamin J. Otto
[e-mail]

Idaho Irrigation Pumpers Assn
Eric L. Olsen
[e-mail]
Anthony Yankel
[e-mail]

Russell Schiermeier
[e-mail]

City of Boise City
Abigail R. Germaine
[e-mail]

Micron Technology
Jim Swier
[e-mail]

Austin Rueschhoff
Thorvald A. Nelson
[e-mail]
[e-mail]
[e-mail]
[e-mail]

_____________________________

Kelsey Jae
Attorney for Sierra Club

Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-20-26
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