20200305Staff 1-9 to PAC.pdf

SVEDMATTHUNTER
DEPUTY ATTORNEY GENERAL
PM 3·58IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 SS N
[phone]
IDAHO BAR NO.10655
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION FOR )APPROVAL OF THE SUNNYSIDE/HOLMES )CASE NO.PAC-E-20-01STREETASSETTRANSFERAGREEMENT)BETWEEN ROCKY MOUNTAIN POWER AND )THE CITY OF IDAHO FALLS )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Matt Hunter,Deputy Attorney General,requests that Rocky Mountain Power provide the
followingdocuments and informationas soon as possible,but no later than WEDNESDAY,
MARCH 18,2020.1
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
I Staff is requesting an expedited response.These requests formalize Audit Requests previously made by Staff
onsite.If responding by this date will be problematic,please call Staff's attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MARCH 4,2020
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.
REQUESTNO.1:Please provide an explanation and any supporting evidence for the
followingIdaho 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 bonafide intent and
financial ability to operate and maintain said property in the public service.
REQUESTNO.2:Please provide a scaled drawing indicating how the Company
currentlyserves the customers proposed to be transferred,including connection back to the
interconnecteddistribution transformer(s).On the same drawing indicate from which city
interconnection,and the distance required to interconnect the city's service to the customers.
REQUESTNO.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.)a legend;and b.)all
property lines,roadways,structures,and significant electrical equipment included in the
transaction.Please title by name or description those assets which are included in the
transaction.
REQUESTNO.4:Please provide a list of all assets included in the transaction by
description,year in service,installed valuation,and current book value.
REQUESTNO.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 Customers),includingthe Plant in Service,Income Taxes,and
Separation/EstimatorCosts.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MARCH 4,2020
REQUESTNO.6:Please provide copies of the most recent 12 monthlybills for the
meters listed in Exhibit B.
REQUESTNO.7:Please explain how the customers will be,are being,or were notified
of the proposed transfer.
REQUESTNO.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.
REQUESTNO.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.
DATED at Boise,Idaho,this day of March 2020.
Matt Hunter
Deputy AttorneyGeneral
i:umisc:prodreq/pace20.lmhksk prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 MARCH 4,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF MARCH 2020,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOROCKYMOUNTAINPOWER,IN CASE NO.
PAC-E-20-01,BY MAILING A COPY THEREOF,POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON DATA REQUEST RESPONSE CENTER
RICHARD GARLISH E-MAIL ONLY:
ROCKY MOUNTAIN POWER [e-mail]
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
richard.garlish pacificorp.com
IDAHO FALLS CITY POWER
BEAR PRAIRIE
140 S CAPITAL AVE
BOX 50220
IDAHO FALLS ID 83405
SECRETARY
CERTIFICATE OF SERVICE