20231122Staff 1-12 to IPC.pdf

ADAM TRIPLETT ÍJ
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION I $
PO BOX 83720
BOISE,IDAHO 83720-0074 SiCN(208)334-0318
IDAHO BAR NO.10221
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER IDAHO POWER )CASE NO.IPC-E-23-31
COMPANY'S APPLICATION FOR AN )ORDER APPROVING THE TRANSFER OF )CERTAIN ASSETS ASSOCIATED WITH )FIRST PRODUCTION
TRANSMISSION PLANT HELD FOR )REQUESTOF THE
FUTURE USE.)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
WEDNESDAY,DECEMBER 13,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY l NOVEMBER 22,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please provide the signed Purchase and Sale Agreement that details
the "Intentionally Deleted"portions for the followingsections:
a.8.3.3;
b.8.7;and
c.8.8.
REQUESTNO.2:Please provide a list of all assets,includingland and improvements,
included in the transfer by ID,year in service,installed valuation,and current book value.
REQUESTNO.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.
REQUESTNO.4:Please provide an explanation and any supporting evidence that the
followingrequirements of Idaho Code §61-328(3)are satisfied:
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.
REQUESTNO.5:Please provide supporting documentation for the original purchase
price and acreage of the land purchased in 1985 and at issue in this case.
REQUESTNO.6:Please indicate if any of the land referred to in this case is currently
used and useful.
REQUESTNO.7:Please indicate if there are current plans to use the easement rights in
the future.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 NOVEMBER 22,2023
REQUESTNO.8:Please indicate how the value of the $1,320.04was calculated for
plant held for future use.
REQUESTNO.9:Please explain how the values of $30 and $1,000 for closing costs
and selling costs were determined.Please provide supporting documentation.
REQUESTNO.10:Please explain how the sale price of $2,000 was determined.
Please provide supporting documentation.
REQUESTNO.11:Please explain how the value of the easement of $660.02 was
calculated.Please provide supporting documentation.
REQUESTNO.12:Please clarify what would happen if the land were to be used for
farming and the Company needed to install a structure,such as a tower,where crops are located.
a.Would the Company be able to build where crops or other obstacles are located?
b.Would the Company be required to reimburse the Buyer for damages?
DATED at Boise,Idaho,this ,,day of November 2023.
Adam Triplett
Deputy AttorneyGeneral
i:umise:prodreq/IPC-E-23-31 PR#l
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 NOVEMBER 22,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22nd DAY OF NOVEMBER 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-
31,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LISA D NORDSTROM MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
ROBERT &BARRI HAMEL
143 WILDE PL
McCALL ID 83638
Ida Elmasian
CERTIFICATE OF SERVICE