20220902Staff 17-22 to Atlanta.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSTON
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO.9SIO
Street Address for Express Mail:
I133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
OF ATLANTA POWER COMPANY SERVICE
AND CUSTOMER RELATIONS
CASE NO. ATL.E.22.OI
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ATLANTA POWER
COMPANY
Staff of the Idaho Public Utilities Commission ("Staff'), by and through its attomey of
record, Chris Burdin, Deputy Attorney General, requests that Atlanta Power Company
("Company" or "Atlanta Power") provide the following documents and information as soon as
possible, but no later than FRIDAY, SEPTEMBER 16, 2022.r
This Production Request is to be considered as continuing, and Atlanta Power is requested
to provide, by way of supplementary responses, additional documents that it, or any person acting
on its behalt may later obtain that will augment the documents or information produced.
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
THIRD PRODUCTION REQUEST
TO ATLANTA POWER
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I SEPTEMBER2,2022
REQUEST NO. 17: Please provide the past 5 years of monthly kilowatt-hour ("kWh")
energy use for all meters located at the residence: 170 Middle Fork Rd., Atlanta, Idaho 83716.
REQUEST NO. 18: Please provide the past 5 years of Atlanta Power systems'
a. Annual average kWh energy generation;
b. Monthly kWh energy generation and;
c. Annual system peak load in kilowatts ("kW").
REQUEST NO. 19: Please provide all reports or system studies completed on Atlanta
Power's system over the past 5 years.
REQUEST NO.20: Please provide the following information regarding the land swap
from seller to buyer:
a. A complete legal description of RPM5Nl1EO3l lOA subsequent to transfer of the
section to the buyers;
b. A complete legal description of the newly transferred property;
c. A readable color version, that clearly indicates ownership by both parties, of
EXHIBIT B of the STOCK AND OWNERSHIP INTERESTS PURCHASE
AGREEMENT dated August 26,2022;
d. A list of all assets on the transfered property after the land swap that are owned by
Atlanta Power;
e. A list of all assets that are owned by Atlanta Power that will remain on Israel Ray's
property (RPM5N11EO311OA) following the land swap; and
f. Copies of all documents associated with the swap filed with Elmore County.
REQUEST NO.21: Please provide the bank statements from June 2021to present for all
accounts listed in Exhibit F of the Purchase Sale Agreement.
REQUEST NO. 22: Please provide an aged accounts receivable list for Atlanta Power as
of August 31,2022.
THIRD PRODUCTION REQUEST
TO ATLANTA POWER 2 SEPTEMBER2,2022
DATED at Boise, Idaho, this 2od day of September 2022.
(n LB"d^
Chris Burdin
Deputy Attorney General
i:umisc:prodroq/ade22. lcbksk prod req 3
TIIIRD PRODUCTION REQUEST
TO ATLANTA POWER 3 SEPTEMBER2,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY oF SEPTEMBER 2022,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF TIIE
COMMISSION STAX'F TO ATLAI\ITA POWER COMPANY, IN CASE NO.
ATL-E-22-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
ISRAEL RAY
ATLANTA POWER COMPANY
508 AUKLET PLACE
FAIRBANKS AK 99709
E-MAIL: israelra), [e-mail]
GENE HAUGHT
235 WEST YUBA DzuVE
ATLANTA ID 83716
E-MAIL: [e-mail]
CHRISTOPHER R NUNEZ
McANANEY & ASSOCIATES
I101 RTVER ST STE IOO
BOISE ID 83702
E-MAIL: crn@{ncananey.us
[e-mail]
[e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL : [e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE