20190304Staff 1-11 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
{J
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 SANDY DOWNS ASSET
PURCHASE AGREEMENT BETWEEN ROCKY
MOUNTAIN POWER AND THE CITY OF
IDAHO FALLS.
CASE NO. PAC-8.19.02
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 MONDAY,
MARCH 25,2019.
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 MOUNTAIN POWER
)
)
)
)
)
)
)
)
1
rr rf 11r./ :.. I :- I rj - I jt -r':.1! L-i.?'
MARCH 4,2019
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 the workpapers, with all formulas intact, 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: Referencing Exhibit A, Description of Assets, please explain why
the $33 in FERC account 370 was left off of the Value of Inventory Plant In Service Sales Price.
REQUEST NO.3: Please describe how the disposition of the assets in Exhibit A and
customer accounts in Exhibit B will be recorded for accounting purposes. Please include
applicable procedures and spreadsheets with formulas enabled.
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 copies of the previous 12 monthly bills for all meters
listed in Exhibit B.
REQUEST NO. 6: Please provide a detailed enumeration of separation costs included in
the asset purchase agreement. Include applicable procedures and spreadsheets with formulas
enabled.
REQUEST NO. 7: Please provide a detailed enumeration of legal/transactions costs
included in the asset purchase agreement. Include applicable procedures and spreadsheets with
formulas enabled.
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 MARCH 4,2019
REQUEST NO. 8: Are additional transfers planned in the general vicinity of this
transaction and Sandy Downs? If so, please provide an explanation of potential transfers,
location, and when they may occur.
REQUEST NO. 9: 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. 10: Please explain how customers are being notified of the proposed
change.
REQUEST NO. 11: Please provide additional information in relation to the transfer of
Sandy Down's electric service:
a. Who requested the transfer?
b. Why is it necessary?
DATED at Boise, Idaho, this t{f^iuy of March 2019
Edward J
Deputy Attorney General
i:umisc:prodreq/pacel9.2ejtnc prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J MARCH 4,2079
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF MARCH 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAF'F TO ROCKY MOUNTAIN POWER, N CASE
NO. PAC-E-19-02, 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: [e-mail]
Daniel. solander@paci fi com.com
IDAHO FALLS CITY POWER
BEAR PRAIRIE
140 S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@pacifi com. com
CERTIFICATE OF SERVICE