20191004Staff 1-9 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
RECTIVED
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Street Address for Express Mail:
1 1331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION TOR )
APPROVAL OF THE LINCOLN ROAD ASSET
PURCHASE AGREEMENT BETWEEN ROCKY
MOUNTAIN POWER AND THE CITY OF
IDAHO FALLS
CASE NO. PAC-E-19-13
FIRST PRODUCTION
RE,QUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney 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,
ocToBER 1.8, 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.
I 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 MOLINTAIN POWER
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I OCTOBER 4,2019
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
the person preparing the documents. Please also 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 any supporting evidence for the
following (ref. Idaho Code $ 6l-328 (3)):
a. That the transaction is consistent with the public interest; and
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 a scaled drawing indicating how the Company
currently serves the customer proposed to be transferred, including connection back to the
interconnected distribution transformer. On the same drawing indicate from which direction, and
the distance required to interconnect the new service to the customer.
REQUEST NO. 3: Please provide a scaled drawing of the area containing the assets to
be transferred per the Company's Application. Include in the drawing: a legend, all property
lines, roadways, structures, and significant electrical equipment included in the transaction.
Please title by name or ID those assets which are included in the transaction.
REQUEST NO. 4: Please provide a list of all assets included in the transaction by ID,
year in service, installed valuation, and current book value.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 OCTOBER 4,2019
REQUEST NO. 5: Please provide the workpapers, with all formulas intact and enabled,
used to determine the fair market value of the assets shown in Exhibit A (Description of Assets)
serving transferred customer.
REQUEST NO. 6: Please provide copies of the most recent l2-monthly bills for the
meter listed in Exhibit B.
REQUEST NO. 7: Please explain how the customer will be, is being, or was notif,red 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 provide the accounting treatment used for: (a) the sale
transaction of these assets, and (b) for the removal of these assets from the Company's books
Please include spreadsheets with formulas intact and enabled.
LlhDATED at Boise, Idaho, this day of October 2019.
Dayn Hardie
Deputy Attorney General
i:umisc:prodreq/pace 19. I 3dh prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER aJ OCTOBER 4,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY oF OCToBER 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-19-I3, 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]
Dani e1. sol ander@pacifi corp. com
IDAHO FALLS CITY POWER
BEAR PRAIRIE
140 S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
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CERTIFICATE OF SERVICE