20180604Staff 1-8 to PAC.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION FOR
APPROVAL OF THE ASSET PURCHASE
AGREEMENT BETWEEN ROCKY MOUNTAIN
POWER AND THE CITY OF IDAHO FALLS
(PIONEER DRrVE)
CASE NO. PAC.E.18.O3
RECEIVED
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FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Sean Costello, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power,
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, but no later than MONDAY, JUNE 25,2018.
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.
This Production Request is to be considered as continuing, and Rocky Mountain 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.
FIRST PRODUCTION REQUEST
TO ROCKY MOI.]NTAIN POWER I JUNE 4,2018
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
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.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a legible map, identifying boundaries and facilities
being transferred.
REQUEST NO. 2: Please explain why no service drops (FERC Account No. 369) are
included in the value of inventory listed in Exhibit A.
REQUEST NO. 3: On page 2 of its Application, the Company refers to the Service
Allocation Agreement between the Company and the City that was approved by the Commission
on December 5,2017. Paragraph 6 of this agreement states that the purchasing utility will pay
the replacement costs of the facilities, minus depreciation, plus 167 percent of the existing
consumers'revenue collected during the most recent 12 months; however, the purchase price in
Section 2.02 of the April25,2018, Asset Purchase Agreement also includes expenses such as
S eparation Co sts and Le gal lTransaction C o sts.
a. What are separation costs and how are they calculated? Please provide a detailed
enumeration of separation costs included in the asset purchase agreement. Include applicable
procedures and spreadsheets with formulas enabled.
b. Please provide a detailed enumeration of the legal/transaction costs included in the
asset purchase agreement. Include applicable procedures and spreadsheets with formulas
enabled.
c. Why were these additional expenses included in the Asset Purchase Agreement, even
though they were not part of the compensation formula given in the Service Allocation
Agreement?
REQUEST NO. 4: Please explain the following (ref. Idaho Code $61-328 (3)):
a. That the transaction is consistent with the public interest;
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 JUNE 4,2078
b. That the cost 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.
REQUEST NO. 5: Please provide workpapers and spreadsheets (with calculations and
links enabled) used to determine the sales price for the assets shown in Exhibit A (Description of
Assets). Please provide the book value, replacement cost, and depreciation of assets with these
workpapers.
REQUEST NO. 6: Please describe how the disposition of the assets in Exhibit A and
customers in Exhibit B will be recorded for accounting purposes. Please include applicable
procedures and spreadsheets with formulas enabled.
REQUEST NO. 7: Please describe how the proceeds from this sale of assets will be
recorded for accounting purposes. Please include applicable procedures and spreadsheets with
formulas enabled.
REQUEST NO. 8: Please explain how customers are being notified of the proposed
change
Sean Costello
Deputy Attorney General
Technical Staff: Brad Iverson-Long
Kevin Keyt
Michael Morrison
i:umisc:prodreq/pacelS.3scblkskmm prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER J JLINE 4,2018
DATED at Boise, Idaho, this /4 Ourof June 2018.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF JUNE 2018, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-18-03, By
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
DANIEL E SOLANDER
ROCKY MOLTNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.weston@pacifi corp.com
Daniel. solander@pacifi com. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareque st@pacifi corp. c om
JANICE FLOWERS
IDAHO FALLS CITY POWER
I4O S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
CERTIFICATE OF SERVICE