20200522Staff 1-4 to PAC.pdf

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DAYN HARDIE
DEPUTY ATTORNEY GENERAL
TDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
Steet Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION FOR
APPROVAL OF A LEASE AGREEMENT
BETWEEN ROCKY MOUNTAIN POWER AI\D
EXTENET SYSTEM,INC.
CASE NO. PAC.E.2O.Os
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staffof 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,
JUNE 12,2020.
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
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I MAY 22,2020
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 legible maps showing the location(s) of facilities
(poles) where ExteNet equipment is or will be installed.
REQUEST NO.2: Please provide an explanation and evidence forthe following (ref.
Idaho Code 6r-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.3: Are additional leases planned with ExteNet? If so, please provide an
explanation of potential leases, locations, and when they may occur.
REQUEST NO.4: Please provide the accounting treatment to be used for ExteNet
transactions. Please include spreadsheets with formulas intact and enabled.
DATED at Boise, Idaho, this 22"d day of May 2020.
Dayn Hardie
Depuff Attorney General
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FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MAY 22,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22"d DAY OF MAY 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMIT{ISSION STAFF
TO ROCKY MOIINTATN POWE& IN CASE NO. PAC-E-20-05, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp.com
SECRETARY
CERTIFICATE OF SERVICE