20220815Staff 1-6 to PAC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLTC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
Street Address for Express Mail:
1 I33I W CHINDEN BVLD, BLDG 8, SUTTE 2OI-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TITE APPLICATION
FOR APPROVAL OF THE ASSET
TRANSFER AGREEMENT BETWEEN
ROCKY MOUNTAIN POWER AND THE
CITY OF IDAHO FALLS FOR REED'S
DAIRY
CASE NO. PAC-8.22-1I
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attomey General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than MONDAY,
AUGUST 29,2022.1
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 Stuff it requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at (208) 334-03 18.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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AUGUST 15,2022
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 identifu 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 explain how customers are being notified of the proposed
change.
REQUEST NO.2: Please provide the workpapers, with all formulas intact and enabled,
including source documents, used to determine the fair market value of the assets shown in
Exhibit A (Description of Assets Serving Transferred Customers), including the Plant in Service,
Income Taxes, and Separation/Estimator Costs.
RJQUEST NO. 3: Please provide a list of all assets included in the transaction by
description,yail in service, installed valuation, and current book value.
REQUEST NO. 4: Please provide the accounting treatment and journal entries for the
following. Please include spreadsheets with formulas intact and enabled.
a. The gain or loss on the sale of these assets
b. The removal of these assets from the Company's books
c. Any other joumal entries necessary to complete the transaction
REQUEST NO. 5: Please provide copies of the 12 monthly invoices used for the
revenue component listed in Exhibit A.
REQUEST NO. 6: Please provide legible maps showing the location(s) of facilities to
be transferred.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 15,2022
DATED at Boise, Idaho, this l5e day of August 2022.
?
Riley Newton
Deputy Attomey General
i:umisc:prodreq/pace22.l lmhc prcd req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 15,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l5fl' DAY OF AUGUST 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQIIEST OF TIIE
CoMMISSTON STAFF TO ROCKY MOUNTAIN POWER, N CASE NO.
PAC.E-22-11, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : ted.weston@pacifi corp.com
idahodockets@pac ifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL OIILY:
datareq uest@pacifi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
IDAHO FALLS CITY POWER
BEAR PRAIRIE
140 SOUTH CAPITAL AVENUE
BOX 50220
IDAHO FALLS,ID 83405
i6,4,h
SECRETARY /
CERTIFICATE OF SERVICE