20210310Staff 1-9 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
IDAHO BARNO.9917
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Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR APPROVAL OF
THE NON.EXCLUSIVE LIGHT POLE
ATTACHMENT LEASE AGREEMENT WITH
CINGULAR WIRELESS
CASE NO. PAC-8.2I.04
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 WEDNESDAY,
MARCH 3I,202I.
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 identifr the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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1 MARCH IO,2O2I
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 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.
REQUEST NO. 2: Please provide the accounting treatment to be used for the Cingular
Wireless transactions. Please include spreadsheets with formulas intact and enabled.
REQUEST NO. 3: Please explain how additional revenue generation from the
agreement with Cingular Wireless will benefit customers and mitigate rate pressure. Please
describe in detail the intended mechanism, referencing any Commission Order where applicable,
for passing on this benefit to customers.
REQUEST NO. 4: Please describe how future lease agreement issues and costs are
tracked and accounted for, such as: Unauthorized attachments, Unauthorized use of power, and
Removal and Disposal of equipment.
REQUEST NO. 5: Does the Company require a deposit for the future removal and
disposal of Cingular Wireless's equipment? If not; please explain what would occur if Cingular
Wireless did not have the financial means to remove and dispose of the equipment.
REQUEST NO. 6: Please describe how line extension construction payments are
processed and accounted for in the lease agreement.
FIRST PRODUCTION REQUEST
TO ROCKY MOI.]NTAIN POWER MARCH IO,2O2I2
REQUEST NO. 7: Where the Company could have more than one lease agreement
request to provide access to a single pole:
a. Can more than one antenna be attached to the individual pole?
b. If so, how would the Company as the lessor administer this under more than one
lease agreements.
c. Please explain each of the lease fee structures when considering this situation.
REQUEST NO. 8: Please provide the current number of poles leased by ExteNet under
the prior lease agreement filed in case PAC-E-20-05 - APPLICATION FORAPPROVAL OF A
LEASE AGREEMENT BETWEEN ROCKY MOUNTAIN POWER AND EXTENET
SYSTEMS INC. Order No. 34734.
REQUEST NO. 9: Does the addition of Cingular Wireless equipment as a pole
attachment reduce the life of the pole?
DATED at Boise, Idaho, this ilAday of Mar ch202l.
Deputy Attomey General
i:umisc:prodreq/pace2 1.4dhrk prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER )MARCH IO,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IOth DAY OF MARCH 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, N CASE
NO. PAC-E-21-04, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
JOHN HUTCHINGS
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.weston@oacifi corp.com
j ohn.hutchings@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@paci fi corp.com
SECRE Y
CERTIFICATE OF SERVICE