20140625EIR to Staff 1-8.pdf

AUSEY H. ROBNETT, III
PAINE HAMBLEN,LLP
7OI E FRONT AVENUE #1OI
P.O. BOX E
COEUR D'ALENE, IDAHO 83816-2530
Attomey for Eastern Idaho Railroad
TN THE MATTER OF EASTERN
IDAIIO RAILROAD'S OBJECTION TO
ITS 2014 ASSESSMENT FEE
RfiCHJ\/i:l]
20lri JUt{ 25 Pt{ Z: S0
iDAi-{[r i'i";,.i-ii )UTILITIIS CChii,,llli$ tCri,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
) CASE NO. ErR-R-14-01
)) EASTERN IDAHO RAILROAD'S
) RESPONSES TO REQUEST OF THE
) coMMrssroN STAFF To EASTERN
) rDAHO RAILROAD
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Eastem Idaho Railroad (Cornpany, Eastern
Idaho) provide the following documents and information as soon as possible, but no later than
WEDNESDAY, JUNE 18, 2014.
This Production Request is to be considered as continuing, and the Company 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,
Please provide answers to each question, supporting work papers that provide detail or
are the source of infonnation used in calculations, and the name, job title and telephone number
of the person preparing the documents. Please 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 and electronic files on CD with formulas activated.
RESPONSES TO FIRST PRODUCTION
REQUEST TO EASTERN IDAI]O RAILROAD JLINE 3,20I3
REQUEST NO. L: Please provide a spreadsheet of the line item back up for the
intrastate revenues for year ending 2013 totaling$3,236,286 by month. Please identify each type
of revenue: Freight Revenue, Switching Revenue, Demurrage Revenue, and Incidental Revenue.
RESPONSE TO REQUEST NO. 1: The information specified in this Request for
Production is being sent directly to the Commission, in the format prescribed, by Diane
Steffen, CPA under separate coyer. Some of the information contained in those responses
is confidential and proprietary and it is requested that it be treated as such by the ldaho
Public Utility Commission and its staff and protected from disclosure to members of the
public or outside third parties to the extent permitted by the laws of the state of Idaho
and/or the United States.
REQUEST NO. 2: Please provide a spreadsheet of the line item back up for the
interstate revenues for year ending 2013 totaling $16,336,596 by month. Please identify each
type of revenue: Freight Revenue, Switching Revenue, Demurrage Revenue, and Incidental
Revenue.
RESPONSE TO REQUEST NO.2: The information specified in this Request for
Production is being sent directly to the Commission, in the format prescribedo by Diane
Steffen, CPA under separate cover. Some of the information contained in those responses
is confidential and proprietary and it is requested that it be treated as such by the Idaho
Public Utility Commission and its staff and protected from disclosure to members of the
public or outside third parties to the extent permitted by the laws of the state of Idaho
and/or the United States.
REQUEST NO.3: Please provide details as to the cause of the erroneous reporting, and
the intemal controls being implernented to prevent this rnistake from occurring in the future.
RESPONSE TO REQUEST NO. 3: The information specified in this Request for
Production is being sent directly to the Commission, in the format prescribed, by Diane
Steffen, CPA under separate cover. Some of the information contained in those responses
is confidential and proprietary and it is requested that it be treated as such by the Idaho
Public Utility Commission and its staff and protected from disclosure to members of the
RESPONSES TO FIRST PRODUCTION
REQUEST TO EASTERN IDAHO RAILROAD 2 iuNE 3, 20r 3
public or outside third parties to the extent permitted by the laws of the state of ldaho
and/or the United States.
REQUEST NO. 4: Please provide a spreadsheet of the line item back up for the inhastate
revenues for year ending 2012by month. Please identify each type of revenue: Freight Revenue,
Switching Revenue, Demurrage Revenue, and Incidental Revenue.
RESPONSE TO REQUEST NO. 4: The information specified in this Request for
Production is being sent directly to the Commission, in the format prescribed, by Diane
Steffen, CPA under separate cover. Some of the information contained in those responses
is confidential and proprietary and it is requested that it be treated as such by the Idaho
Public Utility Commission and its staff and protected from disclosure to members of the
public or outside third parties to the extent permitted by the laws of the state of Idaho
and/or the United States.
REQUEST NO. 5: Please provide a spreadsheet of the line item back up for the
interstate revenues for year ending 2012by month. Please identify each type of revenue: Freight
Revenue, Switching Revenue, Demurrage Revenue, and Incidental Revenue
RESPONSE TO REQUEST NO. 5: The information specified in this Request for
Production is being sent directly to the Commission, in the format prescribed, by Diane
Steffen, CPA under separate cover. Some of the information contained in those responses
is confidential and proprietary and it is requested that it be treated as such by the Idaho
Public Utility Commission and its staff and protected from disclosure to members of the
public or outside third parties to the extent permitted by the laws of the state of ldaho
andi/or the United States.
REQUEST NO. 6: Please provide any additional spreadsheets necessary to show the
assignment of revenues by account and by month to Idaho on an intrastate basis.
RESPONSE TO REQUEST NO. 6: The information specified in this Request for
Production is being sent directly to the Commission, in the format prescribed, by Diane
Steffen, CPA under separate cover. Some of the information contained in those responses
is confidential and proprietary and it is requested that it be treated as such by the Idaho
RESPONSES TO FIRST PRODUCTION
REQUEST TO EASTERN IDAIIO RAILROAD 3 JUNE 3,2013
Public Utility Commission and its staff and protected from disclosure to members of the
public or outside third parties to the extent permitted by the laws of the state of Idaho
and/or the United States.
REQUEST NO. 7: Please provide a list of any revenue accruals for the Calendar Year
ending 2013.
RESPONSE TO REQUEST NO. 7: The information specified in this Request for
Production is being sent directly to the Commission, in the format prescribed, by Diane
Steffen, CPA under separate cover. Some of the information contained in those responses
is confidential and proprietary and it is requested that it be treated as such by the Idaho
Public Utilify Commission and its staff and protected from disclosure to members of the
public or outside third parties to the extent permitted by the laws of the state of Idaho
and/or the United States.
REQUEST NO. 8: Please provide a list of Accounts Receivable for Idaho Intrastate
Revenues for the Calendar Year ended 2013.
RESPONSE TO RBQUEST NO. 8: The information specified in this Request for
Production is being sent directly to the Commission, in the format prescribed, by Diane
Steffen, CPA under separate cover. Some of the information contained in those responses
is confidential and proprietary and it is requested that it be treated as such by the Idaho
Public Utility Commission and its staff and protected from disclosure to members of the
public or outside third parties to the extent permitted by the laws of the state of Idaho
and/or the United States.
DATED this ZH day of June,2074.
PAINE HAMBLEN LLP
Ausey H. Robnett, III, ISB #3218
Attorney for Eastern Idaho Railroad
RESPONSES TO FIRST PRODUCTION
REQUESTTO EASTERN IDAHO RAILROAD JUNE 3,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the J4 day of June,20l4,I caused to be served a true
and correct copy of the foregoing by the method indicated below, and addressed to the following:
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
P.O. Box 83720
Boise, ID 83720-0074
H:\CDADOCS\25 308\0013 2\D ISC\PRoD\C153 169v1
RESPONSES TO FIRST PRODUCTION
REQUEST TO EASTERN IDAHO RAILROAD
U,S. MAIL
HAND DELIVERED
I\_ OVERNIGHT MAIL
TELECOPY (FAX)
Dawna R. Stocker
JUNE 3,2013