20190517Staff 1-10 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
RECEIVED
:$19 HiI l? [l{ llr S l
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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 PROFESSIONAL WAY _
BROADWAY ASSET PURCHASE AGREEMENT
AND TRANSFER OF SERVICE BETWEEN
ROCKY MOUNTAIN POWER AND THE CITY
OF IDAHO FALLS
CASE NO. PAC.E.19.O6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
MAY 31,2019.1
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
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER
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1 MAY 17,20t9
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 spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: 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.2: Please provide legible maps showing the location(s) of facilities to
be transferred for both the Professional Way and Broadway locations.
REQUEST NO.3: Please provide a scaled drawing of the area, or areas, containing the
assets to be transferred per the Company's Application. Include in the drawing: all property
lines, roadways, structures, and significant electrical equipment being sold/purchased. Please
title by name or identification tag those assets which are being sold/purchased.
REQUEST NO. 4: Please list all assets being sold/purchased by identification tag, year
in service, installed valuation, and current book value.
REQUEST NO. 5: Please provide the work papers, with all formulas intact, used to
determine the sale price for the assets shown in Exhibit A (Description of Assets Serving
Transferred Customers). Please provide the book value and depreciation of assets with these
work papers.
REQUEST NO. 6: In Exhibit A & B you provide a twelve months revenue at l67Yo for
Broadway in the amount of $329. Please provide supporting documentation for these revenues.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MAY 17,20t9
REQUEST NO. 7: Please explain how customers will be, are being, or were notified of
the proposed transfer.
REQUEST NO. 8: Are additional transfers planned in the general vicinity of this
proposed transaction? If so, please provide an explanation of potential transfers, location, and
when they may occur.
REQUEST NO 9: Please describe how the disposition of the assets in Exhibit A will be
recorded for accounting purposes. Please include applicable procedures and spreadsheets with
formulas intact and enabled.
REQUEST NO. 10: 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.
DATED at Boise, Idaho, this
i:umisc:prodreq/pace I 9,6dhjk prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
[.-
day of May 2019.t1
Dayn
Deputy Attorney General
J MAY 17,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17th DAY OF MAY 2019, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-I9-06, 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: [e-mail]
Daniel. solander@.pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareque st@pac i fl corp. c om
IDAHO FALLS CITY POWER
BEAR PRAIRIE
I4O S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
'r, ,4r2"r"1
SECRETARi/
CERTIFICATE OF SERVICE