20180604Staff 1-7 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
Attorneys 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
(NINA, CHARLA AND MERLIN DRIVE).
CASE NO. PAC.E.18.O4
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,
Sean Costello, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than MONDAY,
JUNE 25,2018.
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
FIRST PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER
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I JUNE 4,2018
the person preparing the documents. Please identify 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 and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a legible map, identif,,ing boundaries and facilities
being transferred.
REQUEST NO. 2: Please explain the following (ref. Idaho Code g6l-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; 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.3: 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. 4: 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. 5: 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.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JI.INE 4,2018
RBQUEST NO. 6: The purchase price given in Section 2.02 of the Purchase Agreement
is$92,713; however, the sum of the property valuation (Exhibit A) and 167% of the revenue
obtained from the prior 12 months bills (Exhibit B) is only $81 ,192.12. Please explain this
discrepancy, and provide a detailed enumeration of the costs used to calculate the $92,113
purchase price.
REQUEST NO. 7: Please explain how customers are being notified of the proposed
change.
DATED at Boise, Idaho, this 'y'a aaVof June 2018.
J(
Sean Costello
Deputy Attorney General
Technical Staff: Mike Morrison
Kevin Keyt
Brad Iverson-Long
i:umisc:prodreq/pacel8.4scmmkkbl prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J JUNE 4,2018
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-I8-04, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
DANIEL E SOLANDER
ROCKY MOI-]NTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.weston@nacifi corp.com
Daniel. solander@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp.com
JANICE FLOWERS
IDAHO FALLS CITY POWER
I4O S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
..i-
sE RETTY
CERTIFICATE OF SERVICE