20160108Staff 4 to IPC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 ldaho Public Utilities Commission
[phone] ofiiceof.tne,flefrf;tav
IDAHO BAR NO. 8370
JAN 0 I 2016
Street Address for Express Mail:
472w ' WASHINGTON Boise' ldaho
BOISE, IDAHO 83702.59I8
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-15-26
APPROVING THE TRANSFER AND SALE OF )
CERTAIN ASSETS TO THE UNITED STATES ) SECOND PRODUCTION
DEPARTMENT OF JUSTICE FEDERAL ) REQUEST OF THE
BUREAU OF INVESTIGATION.) 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 FRIDAY, JANUARY 15, 2016.r
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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Stafls
attorney at (208) 334-03 I 8.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY I JANUARY 8,2016
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.
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. 4: In previous cases (IPC-E-05-16 and IPC-E-09-32), the Company's
methodology used only Net Book Value in its pricing methodology. In both cases, the Company
stated that the resulting sales price was revenue neutral, and would not affect the rates of other
Idaho Power Customers. In its current application, the Company states that its sale price
methodology ensures the cost of supplying service will not increase, and that rates will not be
impacted. The Company funher states that its pricing methodology used the following five
components:
a. Net Book Value
b. True-up of Past Levelized Rate of Retum
c. Near-term Rate of Return Impact Resulting from the Sale of Assets
d. Near-term Operational Impact Resulting from the Sale of Assets
e. Net Tax Gross-up
Please explain why these components were not considered in previous sales, and why it is
appropriate to include them in the present case.
Dated at Boise, Idaho, this ffi day of Janu ary 2016.
Technical Staff: Rick Keller (4)
i:umisc:prodreq/ipcel5.26djhmmrkmrde prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY
uang
Deputy Attorney Ge
JANUARY 8,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8th DAY OF JANUARY 2016,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF IN CASE NO. IPC-E-15-26, BY MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D. NORDSTROM
SHELLI D. STEWART
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
sstewart@ idahopower. com
PETER J zuCHARDSON
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE TD 83702
E-mail : [e-mail]
TAMI WHITE
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
CERTIFICATE OF SERVICE