20230330PAC to Staff 1-7.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
March 30, 2023 Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C) RE: ID PAC-E-23-02
IPUC Set 1 (1-7) Please find enclosed Rocky Mountain Power’s Responses to IPUC 1st Set Data Requests 1-7. Also provided are Attachments 6 and 7. Provided via BOX are Confidential Attachments IPUC 3 and 5. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 –
Information Exempt from Public Review, and further subject to the Protective Agreement executed in this proceeding. If you have any questions, please feel free to call me at [phone]. Sincerely, ____/s/____
Mark Alder
Manager, Regulation Enclosures
RECEIVED
2023 March, 30 3:52PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-02 / Rocky Mountain Power March 30, 2023 IPUC Data Request 1
IPUC Data Request 1 Please explain how effected customers are being notified of the proposed asset transfer.
Response to IPUC Data Request 1 There is no formal notification process in place for the proposed asset transfer
since the transfer was requested by the customer.
Recordholder: Timothy Solomon Sponsor: Timothy Solomon
PAC-E-23-02 / Rocky Mountain Power March 30, 2023 IPUC Data Request 2
IPUC Data Request 2 Please explain how the proposed transaction complies with Idaho Code § 61-328(3). This response should outline how the transaction is consistent with the
public interest and explain how the cost of-and rates for-supplying service will not
be increased by reason of such transaction. This response should also illustrate how "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." Idaho
Code § 61-328(c).
Response to IPUC Data Request 2 The Idaho Public Utilities Commission (IPUC) approved a Service Allocation Agreement (SAA) between Idaho Falls and Rocky Mountain Power (RMP or
Company) on December 5, 2017, under the Idaho Electric Supplier Stabilization
Act (ESSA). As provided by the IPUC: [T]he Service Allocation Agreement is the framework for implementing the
ESSA in transactions between the Company and the City. Under the Service
Allocation Agreement, the Company and the City have agreed that compensation for transferring customer service rights and responsibilities is 167% of the transferring customer or customers' most recent 12-months electric bills and the cost of the assets used in service of the customer or customers plus applicable legal transactional costs, separation costs, and tax
gross-up.1
The IPUC has approved several Asset Transfer Agreements (ATA) between RMP and Idaho Falls, including those within Case PAC-E-19-09, Case PAC-E-20-12,
Case PAC-E-20-06, and Case PAC-E-20-01, in accordance with the approved
SAA. IPUC found that these ATAs complied with the requirements in Idaho Code 61-328 and thereby authorized the transfer of assets between RMP and Idaho Falls in those proceedings. The ATA in this proceeding is similar to the prior agreements approved by the
IPUC and aligns with the terms of the approved SAA. The ATA ensures fair
compensation for facilities transferred between the parties, with an amount equal to 167 percent of the exiting customer’s revenues collected for the most recent 12 months. Moreover, RMP further represents that its cost-of and rates for supplying service will not increase due to this transaction. RMP has also consulted with
Idaho Falls, and the City has confirmed that, as a joint applicant in this proceeding and a subdivision of the State of Idaho, it has the bona fide intent and financial ability to operate and maintain the property in the public service. Considering the
1 In the Matter of the Join Application of the City of Idaho Falls and Rocky Mountain Power for Approval of a Service Allocation Agreement, Case No. PAC-E-19-09, Order No. 34418 (August 19, 2019).
PAC-E-23-02 / Rocky Mountain Power March 30, 2023 IPUC Data Request 2
above points and the customer’s request for the proposed asset transfer, this asset transfer is consistent with the public interest.
Recordholder: Joe Dallas
Sponsor: Joe Dallas
PAC-E-23-02 / Rocky Mountain Power March 30, 2023 IPUC Data Request 3
IPUC Data Request 3 Please provide the work papers, 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. Response to IPUC Data Request 3

Please refer to Confidential Attachment IPUC 3. Specifically, tab “878 S Bellin Road”, column “Sales Price”, cell N18, and tab “Price”, column “Sales Price”, cell G45. Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject to the Protective Agreement executed in this proceeding.

Recordholder: Nathan Bailey Sponsor: Shiree Holt
PAC-E-23-02 / Rocky Mountain Power March 30, 2023 IPUC Data Request 4
IPUC Data Request 4 Please provide a list of all assets included in the transaction by description, year in service, installed valuation, and current book value.
Response to IPUC Data Request 4 Please refer to the Company’s response to IPUC Data Request 3, specifically
Confidential Attachment IPUC 3, tab “878 S Bellin Road”.
Recordholder: Nathan Bailey Sponsor: Shiree Holt
PAC-E-23-02 / Rocky Mountain Power March 30, 2023 IPUC Data Request 5
IPUC Data Request 5 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; and

(c) Any other journal entries necessary to complete the transaction. Response to IPUC Data Request 5 Please refer to Confidential Attachment IPUC 5.

Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject
to the Protective Agreement executed in this proceeding
Recordholder: Jin-Jin Fan Sponsor: Shiree Holt
PAC-E-23-02 / Rocky Mountain Power March 30, 2023 IPUC Data Request 6
IPUC Data Request 6 Please provide legible maps showing the location(s) of facilities to be transferred.
Additional clarification provided by Idaho Public Utilities Commission (IPUC) staff on March 10, 2023:
• 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(s). On the same drawing indicate from which city interconnection, and the distance required to interconnect the city's service to the customer.
• Please provide a scaled drawing of the area containing the assets to be transferred per the Company's Application. Please 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. Response to IPUC Data Request 6 Please refer to Attachment IPUC 6.

Recordholder: Phillip Springer Sponsor: Justin Allen
PAC-E-23-02 / Rocky Mountain Power March 30, 2023 IPUC Data Request 7
IPUC Data Request 7 Please provide copies of the 12 monthly invoices used for the revenue component listed in Exhibit A.
Response to IPUC Data Request 7 Please refer to Attachment IPUC 7 which provides copies of redacted monthly
invoices matching Exhibit A.
Recordholder: Tony Worthington Sponsor: Shiree Holt