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Home My WebLink About20070622Budge letter re extra copies.pdfBrian Dickman Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake City, Utah 84111 brian. dickman~JJacifi cot:p. com LOUIS F. RACINE (1917-2005) WILLIAM D. OLSON W. MARCUS W. NYE RANDALL C. BUDGE JOHN A. BAILEY, JR. JOHN R. GOODELL' JOHN B. INGELSTROM DANIEL C. GREEN" BRENT O. ROCHE KI RK B. HADLEY FRED J. LEWIS MITCHELL W. BROWN ERIC L. OLSEN CONRAD J. AIKEN'" RICHARD A. HEARN, M. DAVID E. ALEXANDERtt LANE V. ERICKSON" PATRICK N. GEORGE" SCOTT J. SMITH STEPHEN J- MUHONEN BRENT L- WHITING JUSTIN R. ELLIS JOSHUA D. JOHNSON* JONATHON S. BYINGTON DAVE BAGLEY CAROL TIPPI VOLYN** THOMAS J. BUDGE CANDICE M. MCHUGH'" LAW OFFICES OF RACINE OLSON NYE BUDGE 8: BAILEY CHARTERED BOISE OFFICE 101 SOUTH CAPITOL BOULEVARD, SUITE 20B BOISE, IDAHO 83702 TELEPHONE, (208) 395-001 I FACSIMILE' (208) 433-0167 201 EAST CENTER STREET POST OFFICE BOX 1391 POCATELLO, IDAHO 83204-1391 TELEPHONE (208) 232-6101 FACSIMILE (208) 232-6109 IDAHO FALLS OFFICE www.racinelaw.net 477 SHOUP AVENUESUITE 203A IDAHO FALLS, ID 83402 TELEPHONE, (208) 528-6101FACSIMILE, (206) 528-6109 SENDER'S E-MAIL ADDRESS: rcb(gJracinelaw.net 'ALSO MEMBER WY .. IL BARS "ALSO MEMBER UT BAR "'ALSO MEMBER CO BAR tALSO MEMBER D. C. BAR ttALSO MEMBER MO BAR ojoALSO MEMBER IL BAR **ALSO MEMBER WA BAR June 21 , 2007 ;:,.-. -, -'..())- .. Dean Brockbank Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake city, Utah 84111 dean. brockbank~JJaci ficorp. com Dear Dean and Brian: Re:Idaho Public Utilities Commission Rocky Mountain Power Case No. PAC-O7- Attached please find a copy ofthe Petition for Leave to Intervene which we re filing today on behalf of Monsanto Company. You will note the Petition requests that copies of all pleadings and production requests and responses be served upon myself, Katie Iverson and Jim Smith. While I believe the Commission Rules require service upon two representatives, as a courtesy an extra copy has been provided to our consultant in the past per our request. Should this pose any concern, we be happy to pay any additional costs associated with this. June 21 , 2007 Page 2 Dean, I'd suggest that we get the same Confidentiality Agreement in place that we ve used in the past. If you would like to provide that electronically, I will sign the same and also circulate it to our folks for their signatures. From a preliminary review, it appears that the Application did not address or attempt to value in any way the Monsanto credit resulting from the 1000 hours of curtailment options under the Special Contract. To that extent, the Application appears deficient and does not comply with the Commission s mandate in theP AC-06-09 Order dated December 18, 2006, wheretheComrnission stated at page 9: Included in the Agreement are three interruptible provisions that provide operational benefits to PacifiCorp. The products offered also provide Monsanto with a means of controlling its net energy price. We find the products to be priced at a level commensurate with the value they represent today. . . . The Commission also recognized that the value of interruptible products furnished by Monsanto as well as Monsanto cost of service will be important considerations in establishing the net rate to Monsanto in the future. Consequently, we expect the parties to address interruptible product valuation in the context of a general case when Monsanto s cost of service is determined. Quite obviously, pursuant to this Order and otherwise, it is the Company s responsibility " address interruptible product valuation" as a part of its original filing. Otherwise, neither Monsanto the Staff or other intervenors will be able to address and respond to this significant issue in a timely and appropriate manner. Nor is it acceptable to see the Company s filing on this important issue for the first time on rebuttal. Accordingly, we respectfully request that the Company immediately amend its Application to address interruptibility product valuation for both Monsanto and the Irrigators. If the Company is unwilling to do so, we will have no alternative but to bring this issue before the Commission by formal motion. RCB:rr Attachmentscc: Idaho Public Utilities Commission Randy Lobb, Commission Staff Monsanto Company: L C. BUDGE June 21 , 2007 Page 3 Gary Kajander James R. Smith Katie Iverson