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Home My WebLink About20050519Monsanto 2nd Request to PAC.pdf' '" , ,:: ' - C_I 'if :. -l:J Randall C. Budge, ISB No. 1949 RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 r=-q , '".., -"-~-)"",, ii, . .\ ;/;-: - JiUv liP, I I.. i "-';)L_!t, UTILiTIES COI'-'iM!SSID.N Attorneys for Intervenor Monsanto Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF PACIFICORP DBA UTAH POWER & LIGHT COMP ANY FOR APPROV AL OF CHANGES TO ITS ELECTRIC SERVICE SCHEDULES Case No. PAC-O5- MONSANTO COMPANY'S SECOND DATA REQUEST TO P ACIFICORP MONSANTO COMPANY, by and through their attorneys, hereby submits this Second Data Request to Pacificorp, pursuant to Rule 225 of the Idaho Public Utility Commission s Rules of Procedure, IDAP A 31.01.01 , as follows: MONSANTO DATA REQUEST NO.: According to PacifiCorp s Response to Staff Production Request 56 , " there can be no 'change in cost of service' as a matter of law" with respect to the cost of service for Monsanto in this case. Please describe precisely and in detail the factual basis and legal authority which supports PacifiCorp s claim that there can be no change in cost of service as a matter of law. Please explain and provide all documents that support, refer or relate to Pacifi Corp claim there can be no change in cost of service "as a matter of law - Was it PacifiCorp s belief there could be no change in cost of service "as a matter of MONSANTO COMPANY'S SECOND DATA REQUEST TO PACIFCORP- law" when it supported the Revised Protocol Stipulation? Please explain. MO~SANTO DATA REQUEST NO.: According to PacifiCorp s Response to IPUC Staff Production Request 56, PacifiCorp claims that the cost of services for Monsanto has been determined by Final Order No. 29157, and "that finding is binding for purposes of cost of service in this proceeding. Please explain and provide all documents that support, refer or relate to PacifiCorp ' s claim that the finding is "binding" for purposes of cost of service in this proceeding. Please confirm or deny that Monsanto s cost of service determined in Final Order No. 29157 was premised on the Rolled-In inter-jurisdictional method. If denied, please explain. Is it also PacifiCorp s belief that Final Order No. 29157 precludes PacifiCorp from any change in cost of service to Monsanto related to the transition to Revised Protocol inter- jurisdictional allocation method? If not, why not? Please confirm or deny that PacifiCorp s belief is that Monsanto s cost of service determined in Final Order No. 29157 is "binding" only in the class cost of service study, but not for purposes of the inter-jurisdictional study. Please provide the normalized results of operations for Idaho based on the Revised Protocol assuming that all costs associated with Monsanto s loads have been determined by Final Order No. 29157 and as such are "binding MONSANTO DATA REQUES~O. : According to PacifiCorp s Response to IPUC Staff Production Request 37 , " overall Company costs have increased which increases the cost of service for all customer classes. Please confirm or deny that Company costs have increased for all Idaho customers. MONSANTO COMPANY'S SECOND DATA REQUEST TO PACIFCORP - 2 If denied, please fully explain. Over what period of time is PacifiCorp referring to when the statement is made overall company costs have increased" Indicate whether PacifiCorp s costs have increased or decreased each year since the last general rate case in Idaho. Does PacifiCorp project costs will increase in 2005 and 2006? If so, please explain what PacifiCorpbelieves will be the primary factors driving such cost increases. Does PacifiCorp anticipate filing a general rate case in Idaho in 2006? MONSANTO PATAREQUESTNO. 9 : PacifiCorp sResponseto IPUC Staff Production Request 37 references the "Rate Mitigation Adjustment, Schedule 94" and that this "altered the cost of service relationships for those classes in this case as compared to P A C- E-O 1-16." Please provide the necessary workpapers to understand how the RMA has altered the cost of service relationships. MO~SANTO DATA REQUEST NO. 10 : According to PacifiCorp s Response to IPUC Staff Production Request 37, the Company claims that "Because the cost of service for Monsanto is greater than the current revenues produced, the revenue shortfall from Monsanto is included in the cost of service for the other classes.Please provide the Company s estimate of the "revenue shortfall from Monsanto" and all supporting workpapers or references. DATED this 17th day of May, 2005. RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED MONSANTO COMPANY'S SECOND DATA REQUEST TO PACIFCORP - 3 CER TIFI CA TE OF MAILING I HEREBY CERTIFY that on this 17th day of May, 2005, I served a true, correct and complete copy of the foregoing document, to each of the following, via the method so indicated: Jean D. Jewell, Secretary (original and 7) Idaho Public Utilities Commission O. Box 83720 Boise, ID 83720-0074 E-mail: jjewell(g)puc.state.id.S. Mail John Stewart PacifiCorp 201 South Main, Suite 2300 Salt Lake City, Utah 84140-0023 john. stewart2(g)pacificorp. com S. Mail Data Request Response Center PacifiCorp 825 N. E. Multnomah, #800 Portland, OR 97232 datarequest(g)pacifi corp. com Electronically James M. Van Nostrand Stoel Rives LLP 900 SW Fifth A v., Suite 2600 Portland, Oregon 97204 jmvannostrand(g)stoelri ves. com S. Mail Scott Woodbury Kira Pfisterer Idaho Public Utilities Commission O. Box 83720 Boise, Idaho 83720-0074 scottwoodbury(g)puc.idaho. gov kirapfisterer(g)puc. idaho. gov S. Mail Eric L. Olsen Racine, Olson, Nye, Budge & Bailey O. Box 1391 Pocatello, Idaho 83204-1391 elo(g)racinelaw.net S. Mail MONSANTO COMPANY'S SECOND DATA REQUEST TO PACIFCORP - 4 Anthony Yankel 29814 Lake Road Bay Village, OH 44140 tony(g)yankel.net Conley Ward Attorney for Agrium Givens Pursley LLP o. Box 2720 Boise, ID 83701-2720 cew(g)givenspursley.com Dennis Peseau Utility Resources, Inc. 1500 Liberty St. SE, Suite 250 Salem, OR 97302 dpeseau(g)excite.com R. Scott Pasley J .R. Simplot Company O. Box 27 Boise, Idaho 83707 spasley(g)simplot. com David Hawk J .R. Simplot Company O. Box 27 Boise, Idaho 83707 dhawk(g)simplot.com Timothy J. Shurtz 411 S. Main Firth , Idaho 83236 tim(g)idahosupreme. com Brad M. Purdy Attorney at Law 2019 N. 17th Street Boise, Idaho 83702 bmpurdy(g)hotmail. com S. Mail S. Mail S. Mail S. Mail S. Mail S. Mail S. 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