20230620Staff 1-7 to PAC.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL :0 9IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )POWER'S APPLICATION FOR APPROVAL )CASE NO.PAC-E-23-15
OF THE ASSET TRANSFER AGREEMENT )BETWEEN ROCKY MOUNTAIN POWER )FIRST PRODUCTION
AND THE CITY OF IDAHO FALLS -)REQUESTOF THE
PIONEER ROAD )COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy AttorneyGeneral,requests that Rocky Mountain Power ("Company")
provide the followingdocuments and information as soon as possible,but no later than
WEDNESDAY,JULY 5,2023.1
This Production Request is to be considered as continuing,and Rocky Mountain Power 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 telephone number of
i Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JUNE 20,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please explain how affected customers are being notified of the
proposed asset transfer.
REQUESTNO.2:Please provide the workpapers,with all formulas intact and enabled,
includingsource documents,used to determine the value of the assets shown in Exhibit A
(Description and Value of Assets Serving Transferred Customers),includingthe Plant in Service,
Income Taxes,and Separation/EstimatorCosts.
REQUESTNO.3:Please provide a list of all assets included in the transaction by
description,year in service,installed valuation,and current book value.
REQUESTNO.4:Please provide the accounting treatment and journal entries for the
following.Please include spreadsheets with formulas intact and enabled for the following:
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 journal entries necessary to complete the transaction.
REQUESTNO.5:Please provide copies of the 12 monthlyinvoices used for the
revenue component listed in Exhibit A.
REQUESTNO.6: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-supplyingservice 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).
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JUNE 20,2023
REQUESTNO.7:Please provide legible maps showing the location(s)of facilities to
be transferred.
DATED at Boise,Idaho,this )day of June 2023.
Claire Sharp
Deputy AttorneyGeneral
i:umise:prodreq/pace23.15cs1g prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JUNE 20,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF JUNE 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.PAC-E-
23-15,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MARK ALDER DATA REQUEST RESPONSE CENTER
JOE DALLAS E-MAIL ONLY:
[e-mail]
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
[e-mail]
IDAHO FALLS CITY POWER
BEAR PRAIRIE
140 S CAPITAL AVENUE
BOX 50220
IDAHO FALLS ID 83405
SECRETARY
CERTIFICATE OF SERVICE