HomeMy WebLinkAbout20020905Volume 6, pg 510-533.pdf
1 (The following proceedings were
2 had in open hearing.)
3 (Monsanto Exhibit Nos. 212 through
4 215 were admitted into evidence.)
5 COMMISSIONER SMITH: Mr. Olsen, do you
6 have questions?
7 MR. OLSEN: No, Chairman.
8 COMMISSIONER SMITH: Mr. Woodbury.
9 MR. WOODBURY: Madam Chair, the Staff
10 has no questions.
11 COMMISSIONER SMITH: Mr. Eriksson.
12 MR. ERIKSSON: Thank you.
13
14 CROSS-EXAMINATION
15
16 BY MR. ERIKSSON:
17 Q. Mr. Anderson, with respect to the
18 correction you just made to your testimony at page 9
19 regarding the change from 166 megawatts to 162, I
20 hope I'm not the only one that doesn't understand
21 this, but why is your number 162.5 and Mr. Schettler
22 just correct -- I'm sorry -- Mr. Smith corrected his
23 testimony to be 168 megawatts?
24 A. That's a very good question,
25 Mr. Eriksson. I was under the assumption that what
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HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 had been offered up by the Company on the three
2 furnaces was 162.5, and I noted that in
3 Mr. Schettler's discussion with Mr. Fell prior to
4 lunch that number was still being used. I had
5 actually had stricken 166 and put 168, and then
6 given Mr. Schettler and Mr. Fell's discussion I went
7 back to 162.5. So if it stands corrected as 168 as
8 Mr. Smith said, then that's what it should read.
9 Q. But it's your understanding that the
10 level of interruption for Monsanto's current
11 proposal at 1,000 hours is 162.5 megawatts maximum?
12 A. That is my understanding.
13 Q. Turning to your direct testimony at
14 page 5, you state: An interruptible customer can
15 provide the Company with an array of cost-effective
16 options to meet certain of the Company's
17 obligations.
18 And that's at lines 17 to 18. Do you
19 see that?
20 A. I do.
21 Q. And in that context, the cost
22 effective that you're talking about there, that's
23 based on what the Company would acquire in the
24 market or from its own resources?
25 A. True.
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HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 Q. And you would agree that cost
2 effectiveness varies over time?
3 A. Sure. At any one point, that cost
4 effectiveness test would be, perhaps could be.
5 Q. So would may be cost effective one
6 year may not be cost effective another year?
7 A. That's true.
8 Q. And what we have in this instance is
9 that Monsanto's seeking a five-year term to its
10 contract?
11 A. That's true.
12 Q. And during that time, Monsanto's price
13 as they propose would not be subject to change?
14 A. That's true.
15 Q. The mike doesn't pick up the nods.
16 A. Sorry.
17 Q. In fact, when -- well, would you agree
18 that the -- the longer the term to a contract, the
19 greater the risk to PacifiCorp that what was
20 initially cost effective becomes no longer cost
21 effective?
22 A. Actually, I would argue just the
23 opposite, Mr. Eriksson. I think what's cost
24 effective -- you used I think what was cost
25 effective one year could be used -- cannot be the
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HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 next year. You can even reduce that down to what's
2 cost effective one month or one week. The longer
3 you are able to spread out that volatility over time
4 and compare it to some baseline, I think in effect
5 it doesn't place -- I think it places or reduces the
6 Company's economic exposure. In other words, the
7 volatility market can be, if we have a baseline in
8 this case, a base price and a contract that's fixed
9 as proposed, over time, over any time period -- a
10 week, an hour, a year, that -- the market price
11 could be above or it could be below. If you go one
12 week, the chances of it could be above for one week.
13 If you spread that out to one month, now you're
14 going to pick up the lower of the lows.
15 Q. Now just focusing on the duration, the
16 longer the period of time --
17 I think I understand what you're
18 saying is that over time, it may be more cost
19 effective. Is that essentially what you're saying?
20 A. Well, over time, the longer the time,
21 tends to blend out where the market is above and
22 where the market is below, so it tends to wash out
23 those kinds of effects.
24 Q. But if the cost of acquiring these
25 products, the interruptibility type product in the
513
HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 market, over time ends up being less than what is
2 fixed in the contract, the longer that period of
3 time, the greater the risk is to PacifiCorp, isn't
4 it?
5 A. Under the scenario that you suggested,
6 which I would consider fairly restrictive scenario,
7 that if the price, the market price, is actually
8 below the base price, the baseline price of the
9 contract, yes, in that very limited scenario, that
10 would be the case.
11 Q. And at this point, we don't -- there's
12 not certainty as to what's going to happen in the
13 market four years from now in terms of what the
14 price is available for these interruptible type
15 products that would otherwise be acquired in the
16 market if not acquired from Monsanto?
17 A. That's true. The market will move up
18 and down during that four-year period.
19 Q. Okay. Now the interruptibility that
20 we're talking about in this case, it is a service
21 provided by the customer to the Utility. Correct?
22 A. That's true.
23 Q. And another way to look at it would be
24 akin to the purchase by the Utility of a wholesale
25 product in the market?
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HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 A. I believe that's the way the Company's
2 policy is, yes.
3 Q. And wholesale transactions have been
4 the subject of challenge in prior PacifiCorp cases
5 that you've been involved in. Correct?
6 A. Numerous.
7 Q. And, in fact, you've challenged
8 PacifiCorp's wholesale transactions to the effect of
9 arguing for a disallowance or revenue imputation to
10 reduce revenue requirement?
11 A. On certain contracts. I believe there
12 are eight contracts historically that we looked at.
13 Q. All right. Now, suppose that we have
14 a five-year fixed-price contract for the
15 interruptible product or interruptible products, and
16 suppose also that those products are valued at a set
17 dollar amount in the contract, and also that those
18 terms are -- the terms of the contract are not
19 subject to reopeners. Do you have that in mind?
20 A. I do.
21 Q. Now, suppose in the third year the
22 market changes such that the price in the contract
23 is you would say overvalued, the Company's paying
24 more to Monsanto or giving a credit for more than
25 what it would cost to acquire that in the market.
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HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 Do you have that in mind?
2 A. I have that in mind.
3 Q. In the uncertain circumstance,
4 wouldn't you agree that PacifiCorp would certainly
5 be subject to challenges such as you've made in
6 PacifiCorp cases for a disallowance or an
7 imputation?
8 A. No.
9 Q. By nobody?
10 A. I'm sorry?
11 Q. By nobody? Are you saying nobody
12 could possibly challenge that?
13 A. I don't know. I can't speak for
14 everybody. If I understood your question, the
15 question was would I or anyone else challenge based
16 on the arguments that had been presented in the
17 power cost case an imputation.
18 Those arguments are a completely
19 different set of circumstances where the Company --
20 I was challenging the Company as well as other
21 witnesses on the business strategy on the short-term
22 plane arbitrage that put ratepayers at risk.
23 Q. I'm not tying the question to those
24 same arguments --
25 A. Oh.
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HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 Q. -- that were presented previously.
2 I'm just asking the question with respect to a
3 challenge that could be made on other bases of the
4 Company entering into the transaction that one would
5 argue was not a prudent transaction, that the
6 Company essentially gave a credit to
7 interruptibility that was too big. Don't you see
8 that as a risk?
9 A. Well, going back to the example you
10 gave, I think I understood your example. What
11 you're saying, in the third year of a five-year
12 contract all of a sudden the contract base price is
13 above market price, at that point, could you be
14 challenged. Perhaps, but I don't think there would
15 be much of an argument unless that -- that market
16 price had been below the contract price for the
17 entire duration of the contract. So in other words,
18 what's not known in that example and I think what
19 would be very critical in determining whether the
20 Company had acted imprudently in signing that
21 contract is what happened in the first two years and
22 what happens in the fourth and fifth year. In other
23 words, I don't think you can take -- this kind of
24 goes back to where we were in the opening line of
25 discussion -- I don't think you can take a five-year
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HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 stream across a market and base price and take a
2 snapshot and say it's below or above. What matters
3 is the five years.
4 Q. But at that point in time the fourth
5 and fifth year may not be known, and not everybody
6 may agree with the way you believe it ought to be
7 looked at. Correct?
8 A. Well, that's true. There may be
9 others who could see it differently.
10 Q. Turning to another topic, and that is
11 the issue of situs versus system treatment of
12 Monsanto costs and revenues. Now, you express your
13 view that the testimony in various other state cases
14 don't support Mr. Taylor's concern regarding situs
15 versus system treatment?
16 A. That's true.
17 Q. And that position that you have is
18 based on the lack of Commission Orders resolving the
19 issue?
20 A. I think there were two that were
21 cited. The Oregon case that Mr. Taylor cited, I
22 think my argument in the Oregon case was that
23 while -- and if I understand it correctly -- while
24 Oregon's Staff, Commission Staff, expressed concern
25 over special contract allocation, special contracts
518
HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 in other states allocations, the Company and the
2 Staff stipulated to a settlement in that -- in that
3 docket and the Commission while ruling on approval
4 of a settlement didn't necessarily address the
5 issues of allocation.
6 I think the other case was a Utah case
7 where the witness -- and if I believe correctly, it
8 was Miss Rebecca Wilson -- also brought up concerns
9 in the Utah proceeding on allocations on the Utah
10 proceeding, but it's not my -- I do not recall that
11 the Utah Commission basically took on that issue in
12 any Order that followed that discussion.
13 Q. Okay. And not withstanding the lack
14 of any specific Commission resolution of the issue,
15 is it your position that the Company should just
16 essentially ignore the risk that those different
17 positions create?
18 A. No. In fact, I don't think the
19 Company is ignoring it. That's just the point,
20 Mr. Eriksson. I think the Company at its initiation
21 commenced with this MSP or multistate process that's
22 sort of been referenced on the record here. The MSP
23 process perhaps had several different issues that
24 were the drivers behind it, but one of the key
25 issues was the allocation issue across the states.
519
HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 And my point is that at the Company's wish, every
2 state has now joined in that process. A lot of --
3 including everybody in this room -- a lot of time
4 and resources, human resources, are being spent in
5 that investigation, and let's wait to see where that
6 investigation comes. So I don't think -- I don't
7 think that the Company at all has paid no attention
8 to that risk. In fact, I think the Company perhaps
9 did the right thing by creating the docket in all
10 the states to basically create a forum to what is
11 ultimately a interstate problem.
12 Q. The multi- -- the existence of the
13 multistate process though doesn't preclude this
14 Commission from addressing the issue in this case,
15 does it?
16 A. Not at all. I mean, the Commission
17 ultimately -- I'm not an attorney, so I assume that
18 the Commission can choose whatever they see fit to
19 choose in this case. My only pardon and pleading to
20 the Commission would be that the forum already
21 existed in which those issues are being addressed.
22 Q. Okay. On page 16 of your direct
23 testimony --
24 A. I'm sorry?
25 Q. -- page 16, at line 6, carries on and
520
HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 you state that the Commission chose -- referring to
2 the Magcorp case -- the Commission chose not to
3 address the issue on a permanent basis, but instead
4 references the multistate process.
5 The use of the word "permanent," I
6 take it, is in there to address the fact that the
7 Utah Commission did state that it would allow the
8 use of situs treatment for the Magcorp contract?
9 A. Yeah. I, matter of fact, reread that
10 Order on Reconsideration this morning, and what --
11 what my interpretation of the Commission's Order is
12 that, as you say, the Company is allowed to use a
13 situs treatment of the Magcorp -- Magcorp contract
14 for the three years, but the Commission goes on to
15 note that it's doing so in the spirit of an
16 experiment; and then goes further to reference again
17 the MSP process is the more appropriate forum to
18 address the long-term issues on allocation.
19 Q. And, well, let me put it this way:
20 Would you agree that the existence of
21 a substantial underrecovery by the Utility -- and
22 I'm speaking generally -- because of differences in
23 interstate jurisdictional approaches by various
24 states can lead to detrimental impacts on the
25 Utility, and detrimental obviously to shareholders
521
HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 that can exist, but I'm talking about detrimental
2 impacts to the public interest?
3 A. I guess it's going to be a matter of
4 degree, but to what extent the allocation has fallen
5 through the cracks and we compensate in terms of
6 that.
7 I think it can have an impact. It's a
8 matter of degree. And as I previously stated, I
9 felt that the Company acted correctly in creating
10 the MSP process to hopefully address this issue.
11 Q. Turning to page 20 of your testimony
12 where you're talking about potential changes in
13 reserve requirements --
14 A. Right.
15 Q. -- and you state that the change that
16 is being considered by WECC is not known and
17 measurable and, therefore, should not play a role in
18 this case. With respect to that, the known and
19 measurable concept that you're talking about there,
20 isn't that really a concept that is used in
21 typically general rate cases?
22 A. It is, and I used it in the sense
23 that -- just basically characterizing the WECC
24 potential change as being at this point simply
25 unknown. We just do not know if it's going to
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HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 happen and under what time frame that it's going to
2 happen.
3 Q. Don't you think that the existence of
4 that discussion going on is something that should
5 appropriately be considered by the Utility and by
6 this Commission in considering how long of a term of
7 a contract it ought to lock into at a fixed price
8 for an interruptible product, the value of which may
9 change by the change in the reserve requirements?
10 A. It is surely an issue worth noting.
11 Whether the Commission should take that as a
12 criteria for deciding the duration of a contract, I
13 actually at this point do not think that it's --
14 would be appropriate or so forth, and I say that
15 only because -- and I don't say this either tongue
16 in check or maliciously -- when Western utilities
17 historically have gotten together, the Decision
18 process or whatever the issue has been has not been
19 very quick and to the point. You've got some very
20 diverse utilities in the Western grid. We can look
21 at Indigo. We can look at the time it's taken to
22 invest in RTO discussions -- RTO West.
23 And so I don't know, sitting here, how
24 long it's going to take. The WECC is a collective
25 body of very disparite Western utilities to come to
523
HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 a Decision, and so I don't think we can hold this
2 contract's duration hostage to that deliberation.
3 Q. I suppose, as you put it, it's
4 something to note; that is, something to consider?
5 A. It is surely something that should be
6 brought up as a potential event on the horizon out
7 there.
8 Q. Thank you. And turning to page 26 of
9 your direct testimony, at line 12, you state it is
10 an interesting twist of facts that the Company
11 insists that the price of the Monsanto interruptible
12 service is to be priced at market, yet there exists
13 only a market characterized by a single buyer who,
14 by definition, has substantial market power.
15 Now, in stating that, you are not
16 saying that PacifiCorp has such substantial market
17 power that it establishes the value of the
18 interruptible products in the wholesale market?
19 A. Not at all.
20 Q. In your rebuttal testimony, you
21 address the '92 contract with Monsanto. As noted
22 earlier this morning, it's been referred to as the
23 '92 contract. It's actually entered into in '91,
24 wasn't it?
25 A. I believe that's what was agreed to
524
HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 this morning.
2 MR. ERIKSSON: May I approach the
3 witness?
4 COMMISSIONER SMITH: Yes, you may.
5 MR. ERIKSSON: And I'd ask that this
6 power supply agreement be marked as Exhibit No. 25.
7 COMMISSIONER SMITH: Okay, we'll mark
8 it. We'll mark this as Exhibit 25.
9 (PacifiCorp Exhibit No. 25 was
10 marked for identification.)
11 Q. BY MR. ERIKSSON: Mr. Anderson, is the
12 power supply agreement between Utah Power and Light
13 Company and Monsanto Company that's been marked as
14 Exhibit 25 the agreement which you've quoted in your
15 rebuttal testimony?
16 A. Yes, it is.
17 Q. And in particular, you quoted a
18 portion out of Section 3.7 --
19 A. Yes.
20 Q. -- regarding replacement power?
21 A. I believe it's on page 7.
22 Q. And just so that we have this in
23 context, what you quoted is in Section 3.7(e), which
24 makes reference back to Subparagraph 3.3(b)(2)?
25 A. That's true.
525
HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 Q. And if you would turn back to that on
2 page 4, right after the portion that is indented and
3 has two subparagraphs, would you read the sentence
4 that starts over to the left and it says "When"?
5 A. You're asking me to read it?
6 Q. Yes.
7 A. When Power Company's costs exceed
8 energy revenue derived from Monsanto for the
9 interruptible loads, Power Company shall offer
10 higher-cost power and energy to Monsanto subject to
11 the provisions of Subparagraph 3.7(e).
12 Do you want me to keep reading?
13 Q. No, that's fine.
14 MR. ERIKSSON: I would offer
15 Exhibit 25.
16 COMMISSIONER SMITH: Is there any
17 objection?
18 It will be admitted.
19 (PacifiCorp Exhibit No. 25 was
20 admitted into evidence.)
21 MR. ERIKSSON: That's all I have.
22 Thank you.
23 COMMISSIONER SMITH: Thank you,
24 Mr. Eriksson.
25 Do we have questions? Are there
526
HEDRICK COURT REPORTING ANDERSON (X)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 questions from the Commission?
2
3 EXAMINATION
4
5 BY COMMISSIONER SMITH:
6 Q. I just had one, and that was in
7 response to a question discussing the WECC, I
8 believe you characterized it as a body of disparite
9 Western utilities. Are you aware that the -- that
10 may have been what WSCC was, but that the WECC has a
11 totally different board configuration?
12 A. I am, Madam Chair. Matter of fact,
13 the president of the firm that I work for serves on
14 the board of directors.
15 Q. And I was just sitting here trying to
16 remember them all, but it seems to me out of 27
17 board seats, the utilities may have ten?
18 A. I didn't hear what you said.
19 Q. I said out of 27 board seats, the
20 utilities may have ten?
21 A. I'm not sure exactly.
22 Q. So you'd be open to the suggestion
23 perhaps that the WECC, as formulated, is something
24 more than a disparite -- a body of disparite Western
25 utilities?
527
HEDRICK COURT REPORTING ANDERSON (Com)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 A. Yeah, I would.
2 Q. Thank you.
3 COMMISSIONER SMITH: Any redirect,
4 Mr. Budge?
5 MR. BUDGE: Yeah, just a few if I may.
6
7 REDIRECT EXAMINATION
8
9 BY MR. BUDGE:
10 Q. Mr. Anderson, the Company in its
11 questions seemed to imply that Monsanto's five-year
12 contract if it were approved is going to expose the
13 Company to some type of market risk. Do you recall
14 that line of questions?
15 A. I do.
16 Q. And are you familiar with the life
17 expectancy of the Gadsby plant recently constructed
18 by the Company?
19 A. I'm not sure exactly what that plant
20 expectancy is.
21 Q. Do you know how it would be in
22 relationship to the five-year contract proposed by
23 Monsanto: Longer or shorter or much longer?
24 A. Much longer.
25 Q. And at the time that Gadsby plant gets
528
HEDRICK COURT REPORTING ANDERSON (Di)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 built, doesn't, in fact, the Company lock itself in
2 to the capital construction cost of that plant so
3 far as determining the price at which it will be
4 able to deliver energy to meet peak load in the
5 future?
6 A. With regard to the capital cost, yes.
7 Q. And if the Company goes in and seeks
8 rate base approval to include that Gadsby plant in
9 rate base, would not the Commission at that time
10 determine whether or not the expenditure was just
11 and reasonable to permit inclusion or exclusion from
12 rate base?
13 A. Yes.
14 Q. And doesn't that process provide a
15 degree of protection to the Company from someone
16 looking backwards in hindsight down the road years
17 and years that now it's not prudent?
18 A. Yes.
19 Q. And, similarly, wouldn't you expect
20 that if this Commission determines Monsanto's
21 five-year contract to be fair, just, and reasonable,
22 that the Company would expect to be insulated or
23 protected as well from someone later suggesting that
24 the interruptible price paid Monsanto was not fair
25 and reasonable?
529
HEDRICK COURT REPORTING ANDERSON (Di)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 A. I believe so, yes.
2 Q. As I understand it, the current FERC
3 cap on energy is -- we're dealing with today -- is
4 in the $250 range?
5 A. I believe that's correct.
6 Q. Is that correct?
7 And are you aware that there's some
8 states that perhaps where that's been raised as much
9 as $1,000?
10 A. The cap?
11 Q. Yes.
12 A. It's my understanding that that is
13 part of discussion for certain states.
14 Q. If, in fact, that -- we set the price
15 of the value of the Monsanto interruptibility in
16 today's market where the cap is 250 and that cap
17 goes up to $1,000, isn't the possibility real that
18 the value of the interruptibility could actually
19 increase to the Company?
20 A. To the extent that the $1,000 cap be
21 applicable to the states in which the Company
22 operates, yes.
23 MR. BUDGE: No further questions.
24 COMMISSIONER SMITH: Well, I
25 apologize, Mr. Budge, but your final questions
530
HEDRICK COURT REPORTING ANDERSON (Di)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 caused me to have a question.
2 MR. BUDGE: Okay.
3
4 FURTHER EXAMINATION
5
6 BY COMMISSIONER SMITH:
7 Q. What cap are you referring to?
8 A. It's my understanding that the FERC
9 has issued --
10 Q. So this is the FERC-ordered rate cap.
11 It is going to 1,000 on October 1st. Okay.
12 Thank you.
13 MR. BUDGE: Nothing further, thank
14 you.
15 COMMISSIONER SMITH: Then I guess
16 we're ready for your next witness.
17 (The witness left the stand.)
18 MR. BUDGE: Call Kathryn Iverson.
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25
531
HEDRICK COURT REPORTING ANDERSON (Com)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 KATHRYN E. IVERSON,
2 produced as a witness at the instance of Monsanto,
3 being first duly sworn, was examined and testified
4 as follows:
5
6 DIRECT EXAMINATION
7
8 BY MR. BUDGE:
9 Q. Would you please state your name and
10 business address for the record?
11 A. My name is Kathryn Iverson, and my
12 business address is 5555 DTC Parkway, Suite B-2000,
13 Greenwood Village, Colorado, 80111.
14 Q. Mrs. Iverson, did you prefile on
15 behalf of Monsanto Company direct testimony, as well
16 as rebuttal testimony?
17 A. Yes, I did.
18 Q. And did you also present Exhibit
19 Nos. 216 through 220 as a part of your direct
20 testimony, as well as 237 and 238 as a part of your
21 rebuttal?
22 A. Yes, I did.
23 Q. And do you have any corrections you
24 wish to make to either your testimony or your
25 exhibits?
532
HEDRICK COURT REPORTING IVERSON (Di)
P.O. BOX 578, BOISE, ID 83701 Monsanto
1 A. No, I do not.
2 Q. If I were to ask you the same
3 questions today, would your answers be the same?
4 A. Yes, they would.
5 MR. BUDGE: With that, we'd move to
6 have Ms. Iverson's direct and rebuttal testimony
7 spread on the record, the exhibits admitted into
8 evidence, and would tender her for
9 cross-examination.
10 COMMISSIONER SMITH: If there's no
11 objection, it is so ordered.
12 (The following prefiled direct and
13 rebuttal testimony of Ms. Iverson is spread upon the
14 record.)
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533
HEDRICK COURT REPORTING IVERSON (Di)
P.O. BOX 578, BOISE, ID 83701 Monsanto