20151204Staff 1-3 to IPC.pdf

DAPHNE HUANG l.{ f; C I lV p: I rDEPUTY ATTORNEY GENERAL
rDAHo puBl-rc urrl.rrrEs coMMrssroN u0l5 [}EC _E pl{ l2r l0PO BOX 83720
BOISE, IDAHO 83720-0074 lDAI"l'J ijidi,,.
[phone] UTILITIES COF,{SilSSlgrl
IDAHO BAR NO. 8370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AN ORDER ) CASE NO. IpC-E-ts-26
APPROVING THE TRANSFER AND SALE OF )
CERTAIN ASSETS TO THE UNITED STATES ) FIRST PRODUCTION
DEPARTMENT OF JUSTICE FEDERAL ) REQUEST OF THE
BUREAU OF INYESTIGATION. ) COMMISSION STAFF TO
) rDAHO POWER
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that Idaho Power Co. provide the following
documents and information as soon as possible, by MONDAY, DECEMBER 28,2015.
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, supporting workpapers that provide detail or are
the source of information used in calculations. Idaho Power is reminded that responses pursuant
to Commission Rules of Procedure must 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 hearing if need be. IDAPA
31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 DECEMBER 4,2015
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. l: Please provide work papers and spread sheets (with calculations and
links enabled) used to determine the following cost components:
a. Net book value.
b. True-up of past levelized ROR. Please include an explanation of the Company's
calculations of present worth for declining debt/equity used in this calculation.
c. Near-term ROR impact resulting from sale of assets.
d. Near time operational impact resulting from the sale of assets.
e. Net tax gross-up.
REQUEST NO. 2: Please explain how Rule H requires the system protection package
described in section 4 (page 3) of the Agreement.
REQUEST NO.3: In the Application, the Company explained that it used a 3 year basis
to compute the near-term rate of return and operational impacts of the sale. The Company
explained that 3 years is a conservative proxy for the amount of time that may pass between
general rate case filings. Given that the Company's last general rate case involving distribution
plant was concluded in 2011, please explain why the Company believes it likely that another 3
years will pass before it applies for another general rate case with the Commission.
Dated at Boise,Idaho, this W day of December 2015.
Technical Staff: Mike Monison (1-3)
i : umisc:prodreq/ipce I 5.26djhmmrkmrde prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Daphrfe
Deputy Attorney General
DECEMBER 4, 2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF DECEMBER 20T5,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF IN CASE NO. IPC-E-15-26, BY MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
LISA D. NORDSTROM
SHELLI D. STEWART
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail: [e-mail]
sstewart@idahopower. com
TAMI WHITE
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]
CERTIFICATE OF SERVICE