20180629Staff 9-16 to PAC.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
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Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-5918
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
(PToNEER DRrVE)
CASE NO. PAC.E.18.O3
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SECOND 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 FRIDAY, JULY 20,2018.
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.
SECOND PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER JUNE 29,20181
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. 9: Regarding the Company's response to Staffs Production Request
No. 2, please explain why service drops are recorded in Accounts 365 and 367, and not in
Account No. 369 (Service Drops). Also, please explain the function of the 3 inch conduit
recorded in Account 366. Are these related to service drops, or to general distribution?
REQUEST NO. 10: In the Company's response to Staffs Production Request No. 3, the
Company explained that separation costs were calculated with an estimator using the Retail
Construction Management System (RCMS). Please describe how costs are determined and
maintained in RCMS. Include applicable spreadsheets and work instructions or procedures.
REQUEST NO. 11: Regarding the Company's response to Staffs Production Request
No. 3, please explain what the indirect costs are in the removal costs in the expenditure
requisition.
REQUBST NO. 12: Regarding the Company's response to Staffs Production Request
No. 3, please confirm that the City is paying book value for all assets being removed, as well as
those assets that will be physically transferred to the City. If not, please explain what valve is
used and provide the calculation.
REQUEST NO. 13: Regarding the Company's response to Staffs Production Request
No. 5, please describe the source of the "Reconstruction Cost New" costs, listed in Column L of
tab Pioneer Rd in Attachment 5-1.
SECOND PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 JI.INE 29,2018
REQUEST NO. 14: Regarding the Company's response to Staffs Production Request
No. 5, please explain why many of the accounts' electric bills had no activity within the past
year, and whether any adjustments were made to the actual charges to calculate the "72 Months
Revenue" portion of the sale price.
REQUEST NO. 15: In the Company's response to Staffs Production Request No. 6, the
Company stated that; "The customers in Exhibit B will be notified of their new provider and
their customer accounts will be closed with a final billing as per final meter read for their electric
usage." Please explain if this is the first time customers are notified. If not, please described
how initial customer notification is managed.
REQUEST NO. 16: Regarding the Company's response to Staffs Production Request
No. 8, did all affected customers request a transfer of service?
DATED atBoise, Idaho, thisfi
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Technical Staff: Michael Morrison (9,12,16)
Kevin Kelt (10, 15)
Brad Iverson-Long (1 1, 13-14)
Sean Costello
Deputy Attorney General
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SECOND PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER J JUNE 29,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29th DAY OF JUNE 2018,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO ROCKY MOUNTATN POWER, IN CASE NO.
PAC-E-I8-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWNG:
JANICE FLOWERS
IDAHO FALLS CITY POWER
140 S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
d atareq uest@,paci fl corp. com
Jol"k
SECRETY
CERTIFICATE OF SERVICE
TED WESTON
DANIEL E SOLANDER
ROCKY MOI-]NTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
Daniel. solander@pacifi corp.com