20230309Staff 1-7 to Rocky Mountain.pdf

MICHAEL DUVAL El DDEPUTYATTORNEYGENERAL
IDAHO PUBLIC UTILITIES COMMISSION 9 PM 1:()PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )FOR APPROVAL OF THE ASSET )CASE NO.PAC-E-23-02
TRANSFER AGREEMENT BETWEEN )ROCKY MOUNTAIN POWER AND THE )CITY OF IDAHO FALLS -BELLIN ROAD )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy Attorney General,requests that Rocky Mountain Power ("Company")
provide the followingdocuments and information as soon as possible,but no later than
THURSDAY,MARCH 30,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MARCH 9,2023
In addition to the written copies provided as responses to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please explain how effected customers are being notified of the
proposed asset transfer.
REQUESTNO.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).
REQUESTNO.3: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),includingthe Plant in Service,
Income Taxes,and Separation/EstimatorCosts.
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 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.
REQUESTNO.6:Please provide legible maps showing the location(s)of facilities to
be transferred.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MARCH 9,2023
REQUESTNO.7:Please provide copies of the 12 rnonthlyinvoices used for the
revenue component listed in Exhibit A.
DATED at Boise,Idaho,this day of March 2023.
Michael Duval
Deputy AttorneyGeneral
i:umisc:prodreqlpace23.2mdtj prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 MARCH 9,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9th DAY OF MARCH 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOROCKYMOUNTAINPOWER,IN CASE NO.PAC-E-23-02,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MARK ALDER DATA REQUEST RESPONSE CENTERJOEDALLASE-MAIL ONLY:ROCKY MOUNTAIN POWER [e-mail]
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
[e-mail]
IDAHO FALLS CITY POWER
BEAR PRAIRIE
140 SOUTH CAPITAL AVENUE
BOX 50220
IDAHO FALLS ID 83405
SECRE ARY
CERTIFICATE OF SERVICE