20200416IPC to Staff 1-4.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

April 16, 2020

VIA ELECTRONIC FILING

Diane Hanian, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-20-10
Transfer and Sale of Certain Assets to the City of Nampa, Idaho – Idaho
Power Company’s Response to the First Production Request of the
Commission Staff

Dear Ms. Hanian:

Attached for electronic filing in the above matter is Idaho Power Company’s
Response to the First Production Request of the Commission Staff. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.

If you have any questions about the enclosed documents, please do not hesitate to
contact me.

Very truly yours,

Lisa D. Nordstrom

LDN:kkt
Enclosures
RECEIVED
2020 April 16,AM11:44
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

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

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated March 27, 2020, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
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).
RESPONSE TO REQUEST NO. 1: Please see the Confidential Attachment
provided with this response for the workpapers 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). The confidential attachment will
be provided to those parties that have executed the Protective Agreement in this matter.
A brief description of each is below:
• Exhibit A (Description of Assets): The assets included in Exhibit A can be
found on the “DFI Nampa WWTP” tab in columns A through J, rows 35
through 119.
• Exhibit B (Summary Breakdown): The costs shown in Exhibit B are on the
“Summary” tab. All calculations and links are enabled, so the components
of the purchase price can be traced to the source.
• Exhibit C (Facilities): The facility cost included in Exhibit C can be found
on the “DFI Nampa WWTP” tab. Specifically, the section in Exhibit C titled
“Removed Facilities” can be found in columns L through U, rows 41 and
42, and the section titled “Shifting Facilities” can be found in columns L
through U, rows 37 through 40 and 43 through 52.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 2: Please explain how customers are being notified of the
proposed transaction and associated change.
RESPONSE TO REQUEST NO. 2: The Company does not intend to notify
customers of the proposed transaction. The assets only serve the City of Nampa, and
the sale will not affect the delivery and reliability of electric service to other customers.
Also, the sale price methodology is intended to ensure the cost of supplying service will
not increase, and rates will not be impacted. Application at 3.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Analyst, Idaho Power Company.
.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
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).
RESPONSE TO REQUEST NO. 3: Please see the Confidential Attachment
provided with this response for a copy of the most recent DFI on the “DFI” tab, and a
detailed list of all items that would be transferred under the Agreement on the “Asset
Purchase Detail” tab. The confidential attachment will be provided to those parties that
have executed the Protective Agreement in this matter.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
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.
RESPONSE TO REQUEST NO. 4: Please see the Confidential Attachment
provided with this response for a system diagram showing the Point of Delivery before
and after the proposed asset sale. All equipment beyond the Point of Delivery after the
asset sale would be transferred under the Agreement. The confidential attachment will
be provided to those parties that have executed the Protective Agreement in this matter.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Analyst, Idaho Power Company.
DATED at Boise, Idaho, this 16th day of April 2020.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 16th day of April 2020 I served a true and
correct copy of IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:

Commission Staff
John R. Hammond
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 8371
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email [e-mail]

________________________________
Kimberly Towell, Executive Assistant