20151229Staff 1-3 to PAC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 334-03s7
IDAHO BAR NO. 7956
Street Address for Express
472 W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
THE ASSET PURCHASE AGREEMENT
BETWEEN ROCKY MOUNTAIN POWER AND
THE CITY OF IDAHO FALLS.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-8.I5.15
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Brandon Karpen, Deputy Attomey General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than TUESDAY,
JANUARY 19,2016.
This Production Request is to be considered as continuing, and Rocky Mountain 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 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 identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER DECEMBER29,2Ol5
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide workpapers and spreadsheets (with calculations and
links enabled) used to determine the sales price for assets shown on Exhibit A - Description of
Assets. Explain how the sales prices were determined pursuant to paragraph 7(b) of the Idaho
Falls Allocation Agreement.
REQUEST NO. 2: Please provide a legible Exhibit C.
REQUEST NO. 3: Please explain the following based on Idaho Code $ 61-328 (3):
a) That the transaction is consistent with the public interest;
b) That the cost of and rates for supplying service will not be increased by reason of
such transaction; and
c) That the applicant for such acquisition or transfer has the bona fide intent and
financial ability to operate and maintain said property in the public service.
DATED at Boise, Idaho, tni, fiVaay of December 2015.
Technical Staff: Rick Keller
i:umisc:prodreq/pace I 5. I 5bkrk prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER DECEMBER29,2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF DECEMBER 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E.15-15, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
Daniel. solander@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@pacifi corp.com
JANICE FLOWERS
IDAHO FALLS CITY POWER
140 S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
CERTIFICATE OF SERVICE