20231218Staff 1-6 to PAC.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10221
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 )CASE NO.PAC-E-23-25
FOR APPROVAL OF THE ASSET )TRANSFER AGREEMENT BETWEEN )ROCKY MOUNTAIN POWER AND THE )FIRST PRODUCTION
CITY OF IDAHO FALLS -GOOSE LAKE )REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett,Deputy AttorneyGeneral,requests that Rocky Mountain Power ("Company")
provide the followingdocuments and information as soon as possible,but no later than
TUESDAY JANUARY 2,20241.
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
'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 DECEMBER 18,2023
the person preparing the documents.Please also identify 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 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 determinethe value of the items shown in Exhibit A of the
Application.
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;and
c.Any otherjournal entries necessary to complete the transaction.
REQUESTNO.5: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).
REQUESTNO.6:Please provide legible maps showing the location(s)of facilities to
be transferred.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 DECEMBER 18,2023
DATED at Boise,Idaho,this day of December 2023.
Adam Triplett
Deputy AttorneyGeneral
Technical Staff:Dylan Moriarty
Kevin Keyt
Leena Gilman
i:umisc:prodreq/PAC-E-23-25 PR#1
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 DECEMBER 18,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18th DAY OF DECEMBER 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.PAC-E-
23-25,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY,UT 84116 STE 2000
[e-mail] PORTLAND,OR 97232
[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
BEAR PRAIRIE
CITY OF IDAHO FALLS
140 SOUTH CAPITAL AVENUE
BOX 50220
IDAHO FALLS,ID 83405
[e-mail]
Ida Elmasian
CERTIFICATE OF SERVICE