20200630Staff 1-11 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
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Street Address for Express Mail:
1133I W CI]TNDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AN ORDER
APPROVING THE TRANSFER OF CERTAIN
ASSETS ASSOCIATED WITH THE
HEMINGWAY SUBSTATION
CASE NO.IPC-E-20-25
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,
Dayn Hardie, Deputy Attomey General, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than TUESDAY, JULY
21,2020.
This Production Request is to be considered as continuing, and Idaho Power 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 or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. and the name, job title and telephone number of
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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JL|NE 30,2020
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide an explanation and any supporting evidence for the
following (Idaho Code $ 6l-328 (3)):
a. That the transaction is consistent with the public interest;
b. That the cost and rates for supplying service will not be increased by reason of such
transaction.
REQUEST NO. 2: Please provide a list of all assets, including land and improvements,
included in the transfer by ID, year in service, installed valuation, and current book value.
REQUEST NO.3: Are additional transfers planned in the general vicinity of this
proposed transfer? If so, please provide an explanation of potential transfers, location, and when
they may occur.
REQUEST NO.4: Please explain why the Company chose to grant the 1.91 Acre Parcel
to the County and did not seek financial compensation for this transfer.
REQUEST NO.5: Please provide any projected or budgeted maintenance or tax
expense for the access road and roadway.
REQUEST NO. 6: Please provide any financial projection, analysis, or similar
documentation or narrative that quantifies the "liability that accompanies ownership of access
roads used by the public" that is stated in p. 3 of the Application.
REQUEST NO. 7: Please provide a legible copy of the Record of Survey included in
Attachment No. 2.
FIRST PRODUCTION REQUEST
TO IDAHO POWER ,)JLrNE 30,2020
REQUEST NO. 8: Will the public still be using the Company's access road that is
outside of the transferred property area to access the Wilson Cemetery or other adjacent parcels?
If so, how does the Company plan to limit liability from the public's use of the access road and
who will maintain the portion used by the public? Please describe barriers or signage that will be
installed to indicate the Company's boundaries.
REQUEST NO.9: Please respond to the following related to Wilson Cemetery Road:
a. Who was responsible for the maintenance of Wilson Cemetery Road prior to the
transfer?
b. Why was Wilson Cemetery Road not maintained prior to the transfer?c. Who will be responsible for the maintenance of the access road identified as Wilson
Cemetery Road after the transfer, including sections of the road not included in the
transfer? Please provide all applicable documents or agreements between the
Company and Owyhee County regarding future maintenance of the road.
REQUEST NO. I0: Please explain why the Company did not submit an approval
application for the transfer of property prior to completing the transfer.
REQUEST NO. I l: Please explain the Company's plan if the road segment on the
transferred property is not maintained to a high enough standard for the Company to use for
access to the Hemingway Substation site.
DATED ar Boise, Idaho, this*day of June 2020
Dayn Hardie
Deputy Attorney General
i: urnisc:prodreq/ipce20.25dhksk prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 JI.INE 30,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3OTH DAY OF JUNE 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQI]EST OF TIIE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
TPC.E-20-25, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets @ idahopower.com
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: mlarkin@ idahopower.com
CERTIFICATE OF SERVICE