20220228ICIP 1-3 to Staff.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Sheet
Boise,ldaho 83702
Telephone: [phone]
Fax: [phone]
neter@ richardsonadams.com
gret(Drichardsonadams.com
Attorneys for the lndustrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
." 1.r11 if\rl', lLi\.:;L,,li'1
IN THE MATTER OF TDAHO POWER
COMPANY'S APPLTCATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOIDED COST CALCULATIONS
CASE NO.IPC.E-21-09
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
TDAHO POWER TO THE STAFF OF
THE IDAHO PUBLIC UTILITIES
COMMISSION
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Pursuant to Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission
(the "Commission"), the lndustrial Customers of [daho Power ("ICIP") by and through its
attorney of record, Peter J. Richardson, hereby requests that the Idaho PUC Staffprovide
responses to the following with supporting documents, where applicable.
This production request is to be considered as 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 responses or documents produced.
FIRST PRODUCTION REQUEST OF THE lCrP
TO THE IPUC STAFF
IN CASE NO. IPC-E-21-09 - PAGE I (corrected)
Please provide an additional electronic copy, or if unavailable, a physical copy, to Dr.
Don Readingrt:607A Hill Road, Boise, Idaho 83703, Tel: [phone]; Fax: (208) 384-l5l l;
dreading@mindspri ng.com.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
Some of the following requests may include disclosures deemed to be confidential.
Counsel for the ICIP (Peter Nchardson and Greg Adams) the ICIP's expert witness, Dr. Don
Reading, as well as counsel's legal assistant (Grace Hansen) are all prepared to execute an
appropriate confidentiality agreement should that be necessary in order to facilitate complete
responses.
REOUEST FOR PRODUCTION NO. 1
Please provide copies of all communications between the ldaho PUC and Idaho Power Company
regarding the Company's Application.
REOUEST FOR PRODUCTION NO. 2
Please provide copies of all responses to production requests (both formal and informal)
provided to any other party to this proceeding and that have not already been produced.
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FrRS't PRODUCTION REQT.JEST OF THE ICrp
TO THE IPUC STAFF
IN CASE NO. IPC-E-21-09 - PAGE 2 (conected)
REOUEST FOR PRODUCTION NO.3
Please provide updated 'published' avoided oost rates utilizing the SAR methodology for win(
solar and battery projects 100 kW or smaller and for all other types of QF projects l0 MW or
smaller utilizing the lirst deficit year contained in Idatro Power's Motion and Amended
Application filed on February 4,2022,in this docket. According to ldalro Power Company's
rcsporxr to ICIP Request No. 10, the requested rates arE, "calculated by the Staffoftlrc Idaho
Public Utilities Commission" and not ldaho Power Company.
of 2022.
Peter J. Riclrardson ISB # 3195
RICHARDSON ADAMS, PLLC
FIRST PRODUCTION REQT EST OF THE rCrP
TO THE TPUC STAFF
IN CASE NO. IPC-E-zLry - PAGE 3 (corrected)
I HEREBY CERTIFY that on the 28th day of February,2O22,a true and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST of the Industrial Customers of Idaho
Power to the Staffof the IPCU in Case No. IPC-E-21-09 was served, pursuant to Commission
OrderNo. 34602, by elecfronic copy only, to:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
Jan.nori)[e-mail]. gov
IdaHydro
c/o Tom Arkoosh
Arkoosh Law Offices
tom. [e-mail]
[e-mail]
Donovan Walker, Senior Counsel
Regulatory Dockets
dwalker@ idahopower.com
dockets@ idahopower. com
Michael Darrington, Energy Contracts
Idaho PowerCompany
[e-mail]
enersvcontracts@ idahopower. com
Dayn Hardie
Depu$ Attomey General
Idaho Public Utilities Commission
dayn.hardie@Fuc. idaho. sov
Peter Richardson
ISB # 3195
FIRST PRODUCTION REQUEST OF THE ICIP
TO THE IPUC STAFF
IN CASE NO. IPC-E-21-09 -PAGE 4 (corrected)