20180629Staff 8-12 to PAC.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
RECEIVED
?$18 Jil-H 29 PH 2r l2
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Street Address for Express Mail:
472 W. 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
(NINA, CHARLA AND MERLIN DRIVE).
CASE NO. PAC.E-18-04
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 Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than tr'RIDAY,
JULY 20,2018.
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
SECOND PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER
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JUNE 29,20181
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. 8: Regarding the Company's response to Production Request No. 3,
were there any expenses, such as estimator, accounting, finance, regulation, or legal, related to
this transaction?
REQUEST NO. 9: Regarding the Company's response to Production Request No. 3,
please explain the separation costs of $2,414.
REQUEST NO. 10: Regarding the Company's response to Production Request No. 3,
please describe the source of the "Reconstruction Cost New" costs, listed in Column L of tab
Pioneer Rd in Attachment 3.
REQUEST NO. 1l: In the Company's response to Production Request No. 4, 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 hrst time customers are notified. If not, please described
how initial customer notihcation is managed.
REQUEST NO. 12: In the Company's response to Production Request No. 7, the
Company explained that all the affected property was purchased by a commercial developer who
requested to be served by Idaho Falls. Therefore, notification had taken place. Please explain
the response, because it appears that the affected property consists of individual residential
properties.
SECOND PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 JUNE 29,2018
DATED at Boise, Idaho, tnir?dbaay of June 2018.
N1lLFer:Sean Costello
Deputy Attorney General
Technical Staff: Brad Iverson-Long (8-10)
Kevin KeY (11-12)
i:umisc:prodreq/pacel S.4scmmkkbl prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J JLINE 29,2018
CBRTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29th DAY OF JUNE 2018,
SERVED THE FOREGOTNG SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTATN POWER, rN CASE NO.
PAC-E-I8-04, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWNG:
TED WESTON
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
Daniel. solander@,pErcifi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@paci fi corp. com
JANICE FLOWERS
IDAHO FALLS CITY POWER
140 S CAPITAL AVE
BOX s0220
IDAHO FALLS ID 83405
-t,lrkSECRETARY/
CERTIFICATE OF SERVICE