20190926Staff 1-3 to PAC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.00]4
[phone]
IDAHO BAR NO. 10655
RECEIVED
i01! $[P 2S AH ll: 03
Street Address for Express Mail:
I1331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83114
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION FOR
APPROVAL OF THE ASSET SALE BETWEEN
ROCKY MOUNTAIN POWER AND IDAHO
POWER
CASE NO. PAC.E.19.11
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission requests that Rocky Mountain Power
(Rocky Mountain; Company) provide the following documents and information as soon as
possible, by THURSDAY, OCTOBER 1.0, 2019.r
This Production Request is continuing, and the Company 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
I Staffis requesting an expedited response. Ifthis is problematic, please contact Staff's attorney at [phone]
or krr!klci n (q' puc.idaho.gov_
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I SEPTEMBER 26,2019
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3r.u.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the proposed journal entries associated with the sale
of assets in a spreadsheet with formulas intact.
REQUEST NO. 2: Please provide an explanation and the calculation of the sales
price. Please include in the explanation the source documents substantiating the book value
REQUEST NO. 3: Please provide an explanation and any supporting evidence for the
following (ref. Idaho Code 6l-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.
Dated at Boise, Idaho, this L (A day of September 2019
Matt Hunter
Deputy Attorney General
i/utility/umisc/production requests/pacel9.l lmh prod req I rocky mountain
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 26,2OI9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF SEPTEMBER 2O!9,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-19-11, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.westetrl@ pilcililelp.cg!1
daniel.solander @nacificoro.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
ciatareq uest @) pac il'icortl.conr
JULIA HILTON
IDAHO POWER COMPANY
T22I W IDAHO STREET
BOISE TD 83102
E-MAIL: j hi!_lon @r i clahopower.corrr
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SECRETAR/
CERTIFICATE OF SERVICE