20180914PAC to Staff 1-11.pdf

Y ROCKY MOUNTAIN
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J. Ted Weston
Manager, Regulation
Enclosures
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1407 W North Temple, Suite 330
Salt Lake City, Utah &4116
September 14,2018
Diane Hanian
Edward Jewell
Idaho Public Utilities Commission
472W. Washinglon
Boise,ID 83702-5918
diane.holt@nuc. idaho. gov (C)
RE: ID PAC-E-18-06
IPUC Data Request (1-11)
Please find enclosed Rocky Mountain Power's Responses to IPUC Data Requests l-l l. Also
provided are Attachments IPUC 4, 6, 7,8, 9, 10, I 1.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J,Trol 1,026" /fu
PAC-E-18-06 / Rocky Mountain Power
September 14,2018
IPUC I't Set Data Request I
IPUC Data Request I
The Company captions its filing as an Asset Purchase Agreement which would
fall under t.C. $ 6l-328; however, the Company included a Customer Transfer
Agreement with its application, which would fall under I.C. $ 61-333. Please
explain how these two statutes apply in this case.
Response to IPUC Data Request 1
The caption is incorrect. The Company's Application was incorrectly described
as an Asset Purchase Agreement, but is actually a Customer Transfer Agreement.
A copy of the agreement was included with the Application
Recordholder: Daniel Solander
Sponsor: Ted Weston
PAC-E-18-06 / Rocky Mountain Power
September 14,2018
IPUC I't Set Data Request 2
IPUC Data Request 2
Please explain the following (ref, Idatro 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
insreased by reason of such agreement; and
c. Whether the transferee has the bona-fide inte,nt and financial ability to
operate and maintain said property in the public service.
Response to IPUC Data Request 2
Rocky Mountain Power was required to relocate its facilities by the City
of Idaho Falls, consistent with its statutory authority over its rights of way.
The customers being transferred to Idatro Falls Power are extre,mely small
and will have a negligible effect on costs and rates for Rocky Mountain
Power.
To the best of Rocky Mountain Power's knowledge, ldaho Falls Power
has the intent and financial ability to serve the customers being
transferred. There is no property or facilities being transferred to ldatro
Falls Power as part of this tansaction.
Recordholder: Daniel Solander
Sponsor: Ted Weston
a.
b.
c.
PAC-E-18-06 / Rocky Mountain Power
September 14,2018
IPUC I't Set Data Request 3
IPUC Data Request 3
Please explain the following (ref, Idatro Code $ 6l-333 and Idaho Code $ 6l-
332):
a. How the agreement promotes harmony betwee,n elecfric suppliers;
b. How the agre€,rnent does not include the'lirating" 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.
Response to IPUC Data Request 3
a. Rocky Mountain Power (RMP) and Idaho Falls Power (IFP) have entered
into a se,nrice allocation agreement designed to promote harmony between
the two utilities, which was approved by the Commission in Case No.
PAC-E-17-12. This request falls under that agreement. The City required
relocation of RMP facilities due to a road widening project. tFP serves all
of the customers along that section except for two very small loads; Cable
One and Century Link. Rather than maintaining the line to serve two
small loads, RMP has determined that removing the line and allowing IFP
to serve these minimal loads is in the best interests of customers and the
Company.
b. RMP and IFP have agreed togettrer that having IFP serve the two small
loads is in the best interests of the parties.
c. Removal of the RMP line results in only one utility serving the customers
in that section of the annexed area.
d. The service allocation agreement entered into by RMP and IFP has been
approved by the Idaho Public Utilities Commission.
e. The service allocation agreement approved by the IPUC is designed to
clarify service obligations and territory and permit the orderly transition of
customers permitted to be purchased under statute.
Recordholder: Tim Solomon / Justin Allen
Sponsor: Ted Weston
PAC-E-18-06 / Rocky Mountain Power
Septernber 14,2018
IPUC lstSet Data Request 4
IPUC Data Request 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.
Response to IPUC Data Request 4
No assets are being hansferred. Idaho Falls Power will serve the customers using
its own facilities. All existing facilities were removed for both utilities and
customers as part of the line relocation. Idaho Falls Power and both customers
installed new facilities on the new line and Rocky Mountain Power no longer has
facilities in this section.
Please refer to Attachment IPUC 4 for a summary of the most recent 12 months of
service for each customer.
Recordholder: Tim Solomon / Justin Allen
Sponsor: Ted Weston
PAC-E-18-06 / Rocky Mountain Power
September 14,2018
IPUC lst Set Data Request 5
IPUC Data Request 5
Please provide all journal entries that Rocky Mountain Power will make related to
this Asset Purchase Agreement.
Response to IPUC Data Request 5
Please refer to the Company's responses to IPUC Data Request I and 4. The
Company's Application was incorrectly described as an Asset Purchase
Agreement, but is acnrally a Customer Transfer Agreement, which is included
with the Application. As stated in item 6 of the Background section of the
Application, "B@ause the load and revenue associated with the se,nrice to the
communications facilities are minimal, the Company and the City have agreed to
transfer serrrice at no cost to any party." Thus, pertaining to the transfer of
customers, no journal entries were necessary.
Recordholder: Karl Mortensen
Sponsor: Ted Weston
PAC-E-18-06 / Rocky Mountain Power
September 14,2018
IPUC ls Set Data Request 6
IPUC Data Request 6
Please provide documentation dernonstrating that CenturyLink and Cable One do
not object to the transfer of senrice from Rocky Mountain Power to the City of
Idaho Falls.
Response to IPUC Data Request 6
Please refer to Attachment IPUC 6, which includes communications with the
parties indicating their agreemeirt.
Recordholder: Tim Solomon / Justin Allen
Sponsor: Ted Weston
PAC-E-I8-06 / Rocky Mountain Power
Septernber 14,2018
IPUC l't Set Data Request 7
IPUC Data Request 7
On page 2 of its application, Rocky Mountain Power states that it "...agreed to
relocate the facilities on June 14,20t8, 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 agreeurent;
b. A description, FERC account, installation year, original cost, book value,
accumulated depreciation, and estimated replacement cost ofthe facilities
that were de-energized and removed;c. Clarification as to whether the facilities were relocated, retired, or
hansferred to the City of Idatro 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 Companls
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 senrice for each customer not already described in the Company's
responses to Staffs Production Request Nos. 2 and 3.
Response to IPUC Data Request 7
a. Please refer to Attachment IPUC 7 for a list of the facilities retired.
b. Please refer to Attachment IPUC 7. Some of these data elernents were not
compiled since the activity did not actually involve an asset purchase or
sale.
c. The facilities were retired.
d. There were no additional customers and loads being served by these
facilities prior to June 14, 2018 other than those already provided in the
Company's responses to IPUC Data Requests 2 and 3.
e. See response to IPUC Data Request 7.d.
Recordholder: Vince Harmsen
Sponsor: Ted Weston
PAC-E-18-06 / Rocky Mountain Power
September 14,2018
IPUC I't Set Data Request 8
IPUC Data Request 8
Please provide a legible map identiffing the following:
a. The location of the CenturyLink and Cable One facilities at issue; andb. The location of the equipment prior to being de-energized and removed as
part of the June 14,2018 agreement.
Response to IPUC Data Request 8
Please refer to Attachment IPUC 8, which includes maps of the pertinent area.
Recordholder: Tim Solomon / Justin Allen
Sponsor: Ted Weston
PAC-E-18-06 / Rocky Mountain Power
Se,ptember 14,2018
IPUC ls Set Data Request 9
IPUC Data Request 9
Please provide copies of all documents filed in the Seventh Distict Court that
allege trespass related to the Rocky Mountain Power facilities on Holmes Drive
that are at issue in this case.
Response to IPUC Data Request 9
Please see Attachment IPUC 9.
Recordholder: Daniel Solander
Sponsor: Ted Weston
PAC-E-18-06 / Rocky Mountain Power
Septernber 14,2018
IPUC l't Set Data Request l0
IPUC Data Request 10
Please provide a copy of the Notice and Order to Vacate Construction Zone the
City senred on Rocky Mountain Power on May 28, 2018.
Response to IPUC Data Request 10
Please see Attaclunent IPUC 10.
Recordholder: Daniel Solander
Sponsor: Ted Weston
PAC-E-18-06 / Rocky Mountain Power
September 14,2018
IPUC l't Set Data Request I I
IPUC Data Request 1l
Please provide any documents provided by Rocky Mountain Power to the City
pertaining to the de-energizing and removal of facilities on Holmes Drive.
Response to IPUC Data Request 1l
Please see Attachment IPUC 11.
Recordholder: Daniel Solander
Sponsor: Ted Weston