20180920Staff 12-14 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
REC E IV ED
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Street Address for Express Mail:
472 W. 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-18-06
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,
Edward Jewell, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than THURSDAY,
ocToBER 11,2018.
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 MOUNTAIN POWER
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1 SEPTEMBER 20, 20I8
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. 12: Following-up on Staffs Production Request No. 5, please provide
all journal entries that Rocky Mountain Power will make, or has made, related to the Customer
Transfer Agreement, including the retirement of assets and expenses incurred in removing and
retiring the assets.
REQUEST NO. 13: Following-up on Staffs Production Request No. 7, please provide
the depreciation schedule, as of 2018, for the assets listed in the Staff s Production
Request No. 7. Please include the net book value and accumulated depreciation for each asset.
REQUEST NO. 14: Is there a franchise agreement or other similar agreement between
Rocky Mountain Power and Idaho Falls Power or the City of Idaho Falls that details how costs
are allocated when the City or Idaho Falls Power determines Rocky Mountain Power assets need
to be relocated or removed?
DATED at Boise, Idaho, this lfdav of September 2018.
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Deputy Attorney General
i:umisc:prodreq/pacel 8.6ejmm prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 20, 20I8
CERTIFICATB OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF SEPTEMBER 2018,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE
NO. PAC-E-18-06, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
TED WESTON
DANIEL E SOLANDER
ROCKY MOLTNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
Daniel. solander@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
d atareq u e st@paci ficorp. com
JACKIE FLOWERS
IDAHO FALLS CITY POWER
140 S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
CERTIFICATE OF SERVICE