20180824Staff 1-11 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t4
IDAHO BAR NO. 10446
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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
(HOLMES DRrVE).
CASE NO. PAC.E.18.O6
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,
Edward Jewell, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
SEPTEMBER 14,2018.
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 MOUNTAIN POWER
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1 AUGUST 24,2018
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: The Company captions its filing as an Asset Purchase Agreement,
which would fall under I.C. S 61-328; however, the Company included a Customer Transfer
Agreement with its application, which would fall under I.C. $ 6l-333. Please explain how these
two statutes apply in this case.
REQUEST NO.2: Please explain the following (ref. Idaho Code $ 61-328(3)):
a. How the agreement is consistent with the public interest;
b. How upward pressure on cost and rates for supplying service will not be
increased by reason of such agreement; and
c. Whether the transferee has the bona-fide intent and financial ability to operate and
maintain said property in the public service.
REQUEST NO. 3: Please explain the following (ref. Idaho Code $ 6I-333 and Idaho
Code $ 6l-332):
a. How the agreement promotes harmony between electric suppliers;
b. How the agreement does not include the "pirating" of consumers from an electric
supplier;
c. How the agreement discourages the duplication of electric facilities;
d. How the agreement provides for the active supervision of the electric suppliers
that are parties to the agreement, as the conduct relates to the Electric Supplier
Stabilization Act; and
e. How the agreement stabilizes the territories and consumers served by the electric
suppliers party to the agreement.
FIRST PRODUCTION REQUEST
TO ROCKY MOI-INTAIN POWER 2 AUGUST 24,2018
REQUEST NO. 4: Please provide a detailed description of the facilities, operated on
behalf of Centurylink and Cable One, being transferred in this case. Please include the rate
schedule and electric bills for each of the most recent 12 months of active service for each
customer.
REQUEST NO. 5: Please provide all journal entries that Rocky Mountain Power will
make related to this Asset Purchase Agreement.
REQUEST NO. 6: Please provide documentation demonstrating that CenturyLink and
Cable One do not object to the transfer of service from Rocky Mountain Power to the City of
Idaho Falls.
REQUEST NO. 7: On page 2 of its application, Rocky Mountain Power states that it
"...agreed to relocate the facilities on June 14,2018, and the facilities have been de-energized
and removed." Please provide the following:
a. A detailed list of the facilities that were de-energized and removed as part of the
June 14, 2018 agreement;
b. A description, FERC account, installation year, original cost, book value,
accumulated depreciation, and estimated replacement cost of the facilities that
were de-energized and removed;
c. Clarification as to whether the facilities were relocated, retired, or transferred to
the City of Idaho Falls;
d. A list of any customers and loads being served by these facilities prior to June 14,
2018 that have not already been described in the Company's responses to Staffs
Production Request Nos. 2 and 3; and
e. Rate schedules and electric bills for each of the most recent 12 months of active
service for each customer not already described in the Company's responses to
Staffs Production Request Nos. 2 and 3.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER aJ AUGUST 24,2018
REQUEST NO. 8: Please provide a legible map identifying the following:
a. The location of the CenturyLink and Cable One facilities at issue; and
b. The location of the equipment prior to being de-energized and removed as part of
the June 14,2018 agreement.
REQUEST NO. 9: Please provide copies of all documents filed in the Seventh District
Court that allege trespass related to the Rocky Mountain Power facilities on Holmes Drive that
are at issue in this case.
REQUEST NO. 10: Please provide a copy of the Notice and Order to Vacate
ConstructionZone the City served on Rocky Mountain Power on May 28,2018.
REQUEST NO. 11: Please provide any documents provided by Rocky Mountain Power
to the City pertaining to the de-energizing and removal of facilities on Holmes Drive.
DATED at Boise, Idaho, this L%.eday of August 2018.
J
Deputy General
i:umisc:prodreq/pace1 8.6ejmm prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
t(
4 AUGUST 24,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24th DAY OF AUGUST 2018,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE
NO. PAC-E-I8-06, 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 84116
E-MAIL: ted.weston@.pacificorp.c
Daniel. solander@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@pacifi corp. com
JACKIE FLOWERS
IDAHO FALLS CITY POWER
I4O S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
CERTIFICATE OF SERVICE