20181213Staff 1-8 to PAC.pdf

r.t tr r'tr l\/ [DEDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 334-03t4
IDAHO BAR NO, 10446
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THB 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 _
YELLOWSTONE HIGHWAY
CASE NO. PAC.E-18.11
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 THURSDAY,
JANUARY 3,2019.
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 DECEMBER 13,2018
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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 workpapers and spreadsheets (with calculations and
links enabled) used to determine the sale price for the assets shown in Exhibit A (Description of
Assets). Please provide the book value and depreciation of assets with these workpapers.
REQUEST NO.2: 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.3: Please provide copies of the previous 12 months bills for meter
numbers 66929781 and 40710094 listed in Exhibit B.
REQUEST NO. 4: 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.
REQUEST NO. 5: Please provide a legible copy of Exhibit C that identifies:
a. The facilities that will be transferred to the City of Idaho Falls.
b. The facilities owned by the Company in the Yellowstone Highway area.
c. The facilities owned by the City of Idaho Falls in the Yellowstone Highway area.
REQUEST NO. 6: Are additional transfers planned in the general vicinity of this
transaction and the Yellowstone Highway? If so, please provide an explanation of potential
transfers, location, and when they may occur.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 DECEMBER 13,2018
REQUEST NO. 7: Please provide an explanation and evidence for the following (ref.
Idaho Code $ 61-328 (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. 8: Please explain how customers are being notified of the proposed
change.
DATED at Boise, Idaho, this ti**day of December 2018
Edward
Deputy General
i :umisc:prodreq/pace I 8. I I ejkskmetnc prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER J DECEMBER 13,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I3TH DAY OF DECEMBER 2018,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-18-I1, 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: ted.weston@pacifi corp.com
Daniel. solander@pacifi corp. com
IDAHO FALLS CITY POWER
BEAR PRAIRIE
I4O S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp.com
SECRET
CERTIFICATE OF SERVICE