20240515Staff 1-15 to PAC.pdf

RECEIVED
2024 May 15, 10:49AM
IDAHO PUBLIC
UTILITIES COMMISSION
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER ROCKY MOUNTAIN )
POWER'S APPLICATION FOR APPROVAL ) CASE NO. PAC-E-24-06
OF THE TRANSFER OF PORTIONS OF THE )
NORTH TEMPLE PROPERTY AND )
ACCOUNTING ORDER ) REDACTED FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY,JUNE 5, 2024.
This Production Request is to be considered as continuing, and the Company 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
REDACTED FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 1 MAY 15, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: The Application and Confidential Exhibit No. 2 provides multiple
maps with differing boundaries for the identified"Blocks."
a. Please provide maps with legal descriptions showing the location(s) of the parcel(s)
within each Block that are proposed to be transferred;
b. Please reconcile Block 3's boundaries from Application Figure 2 and Confidential
Transfer Agreement Exhibit A-2; and
c. Please reconcile Block 4's boundaries from Application Figure 2 and Confidential
Transfer Agreement Exhibit A-4.
REQUEST NO. 2: While reviewing the Blocks as described and shown in the
Application, it appears that there may be discrepancies between the Company-provided
information and the Salt Lake County Assessors map. Please reconcile all parcel(s) located
within each Block with the Salt Lake County Assessors map.
REQUEST NO. 3: The Company's Application describes how the Company intends to
construct a new headquarters ("New HQ") and potentially a new Energy Services Building
("New ESB"). Application at 7. Please explain where existing Company offices, shops, and
workspaces will be temporarily relocated. Confidential Transfer Agreement(I0)(c)(b). Please
include how uninterrupted regulatory function, grid operation, operational oversight, and the
continuation of providing fair, safe, and reliable services for Idaho customers will be maintained
during and after relocation.
REQUEST NO. 4: Please provide supporting Excel worksheets that detail the estimated
construction costs of the New HQ and New ESB. Please include the estimated temporary and
1 Reviewed the Blocks via 1)hlWs:Hslco.org/assessor/ (last visited May 8,2024);and 2)
https:Hslco.org/assessor/new/ParcelViewer/index.html?query=parcel_Viewer_external_3634_5.narcel_id(last
visited May 8,2024).
REDACTED FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 2 MAY 15, 2024

final relocation costs, as well as any additional costs associated with maintaining uninterrupted
facility fiunctions.
REQUEST NO. 5: Please explain how the fiords identified in the Confidential Exhibit J
"hupairnent Cost Schedule" that have already been released will be allocated to Idaho
customers. Please also explain if these fiords are now controlled by the Company, and if so,
please provide the associated journal entries.
REQUEST NO. 6: Please provide supporting documentation of the
including cost estimates for the environmental remediation, etc.
REQUEST NO. 7: Please explain the need for the
REQUEST NO. 8: Please provide the MDA. If not yet negotiated, please provide a
projected date for its execution and provide a copy as a supplemental filing when completed.
REQUEST NO. 9: The Company's Application provides a timeline for property
purchases from March 1, 2024, through December 31, 2039. However, in Confidential Exhibit
No. 2 (8)(e) at 13, Please
reconcile the difference between purchase option dates in the timeline and Confidential Exhibit
No. 2 (8)(e).
REQUEST NO. 10: Please provide the proposed accounting treatment for any
relocation and/or transmission upgrade costs associated with the asset transfer.
REQUEST NO. 11: The Master Plan includes a requirement for the Developer and the
Company to include
Confidential Exhibit No. 2 (8)(k)(viii) at 14. Please explain why the agreement includes plan
and design for property outside of the described Blocks in the Application.
REDACTED FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 3 MAY 15, 2024

REQUEST NO. 12: Please provide the timeline for the New HQ and ESP projects.
REQUEST NO. 13: Please provide documentation for the approved financing or how
the New HQ and ESP projects are being funded.
REQUEST NO. 14: Please provide an update to the Feasibility Period. The Developer
had until April 30, 2024, to confirm if they will proceed with this transaction or terminate this
agreement.
REQUEST NO. 15: Please provide the accounting treatment and journal entries for the
following: (Please include any spreadsheets with formulas intact and enabled.)
a. The removal of these real property assets from the Company's books; and
b. Any other journal entries necessary to complete the transaction.
DATED at Boise, Idaho,this 15'h day of May 2024.
Dayn HaVdie
Deputy Attorney General
REDACTED FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 4 MAY 15, 2024

CERTIFICATE OF SERVICE
' q�
I HEREBY CERTIFY THAT I HAVE THIS DAY OF MAY 2024,
SERVED THE FOREGOING REDACTED FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
06, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL: [e-mail] PORTLAND OR 97232
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequestCd,pacificoEp.com
PATRICIA JORDAN, 8ECRETARY
CERTIFICATE OF SERVICE