20200327Staff 1-4 to IPC.pdf

FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 27, 2020
JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5470

Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR
APPROVAL OF THE TRANSFER AND SALE
OF CERTAIN ASSETS TO THE CITY OF
NAMPA, IDAHO
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CASE NO. IPC-E-20-10

FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY

The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond Jr., Deputy Attorney General, request that Idaho Power Company (Company)
provide the following documents and information as soon as possible, or by FRIDAY,
APRIL 17, 2020.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company 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. Reference IDAPA
31.01.01.228.
RECEIVED
2020 March 27,PM2:30
IDAHO PUBLIC
UTILITIES COMMISSION
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 27, 2020
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. 1: Please provide workpapers and spreadsheets in native format, with all
calculations and links enabled, used to determine the sale price for the assets shown in Exhibit A
(Description of Assets), costs shown in Exhibit B, (Summary Breakdown), and facility cost in
Exhibit C (Facilities).

REQUEST NO. 2: Please explain how customers are being notified of the proposed
transaction and associated change.

REQUEST NO. 3: Please provide the most recent Distribution Facilities Investment
Report (DFI) provided to the Customer. Please identify all items in the DFI that would be
transferred under the Asset Purchase and Transfer of Title Agreement (Agreement).

REQUEST NO. 4: Please provide a system diagram showing all facilities that would be
transferred under the Agreement. Please include current and proposed meter locations.

DATED at Boise, Idaho, this 27th day of March 2020.

_______________________________________
John R. Hammond
Deputy Attorney General

i:umisc:prodreq/ipce20.10jhtnckkmm prod req1
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF MARCH 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-20-10, BY E-MAILING A COPY
THEREOF, TO THE FOLLOWING:

LISA D NORDSTROM
SHELLI D STEWART
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
[e-mail]

GRANT T ANDERSON
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]

/s/ Reyna Quintero __
SECRETARY