20070627Monsanto to PAC 1-1 to 1-20.pdf

LAW OFFICES OF
LOUIS F. RACINE (1917-2006)
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
KIRK 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".
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 63204-1391
TELEPHONE [phone]
FACSIMILE [phone]
www.racinelaw.net
SENDER'S E-MAIL ADDRESS: rcb(g)racinelaw.net
June 25, 2007
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83702
Re:PA C-
Dear Mrs. Jewel:
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702TELEPHONE: [phone]
FACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUESUITE 203A
IDAHO FALLS, ID 83402
TELEPHONE: [phone]FACSIMILE: [phone]
.ALSO MEMBER WY" IL BARSuALSO MEMBER UT BAR
.uALSO MEMBER CO BAR
tALSO MEMBER D. C. BAR
ttALSO MEMBER MO BAR
*ALSO MEMBER IL BAR
**ALSO MEMBER WA BAR
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Enclosed for filing please fmd the original and three copies of Monsanto Company s First
Data Requests to Rocky Mountain Power.
Thank you for your assistance.
RCB:rr
Enclosures
Sincerely,
1Uc.
Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
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Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR APPROVAL)
OF CHANGES TO ITS ELECTRIC SERVICESCHEDULES Case No. PAC-
MONSANTO COMPANY'S FIRST DATA REQUEST
TO ROCKY MOUNTAIN POWER
MONSANTO COMPANY by and through their attorneys, hereby submits this First Data
Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utility Commission
Rules of Procedure, IDAPA 31.01.01 , as follows:
Monsanto 1-1: Please provide a copy of all data requests received from Commission
Staff and other parties. Please consider this to be continuing request and supplement your response
as additional requests are received.
Monsanto 1-2: Please provide a copy of your responses to the data requests from
Commission Staff and other parties. Please consider this to be continuing request and supplement
your response as additional responses are received.
Monsanto 1-Please provide a copy of your responses to requests conveyed to
Rocky Mountain Power other than through formal data requests from Commission Staff and other
parties. Please consider this to be continuing request and supplement your response as additional
responses as provided.
Monsanto 1-Please provide a copy ofthe workpapers supporting the testimony of
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER-
witness Richard Walje. To the extent that the workpapers include any spreadsheets or models
please provide in executable native format with all formulas intact.
Monsanto 1-5: Please provide a copy ofthe workpapers supporting the testimony of
witness Samuel Hadaway. To the extent that the workpapers include any spreadsheets or models
please provide in executable native format with all formulas intact.
Monsanto 1-6: Please provide a copy ofthe workpapers supporting the testimony of
witness Bruce Williams. To the extent that the workpapers include any spreadsheets or models
please provide in executable native format with all formulas intact.
Monsanto Please provide a copy ofthe workpapers supporting the testimony of
witness Steven McDougal. To the extent that the workpapers include any spreadsheets or models
please provide in executable native format with all formulas intact.
Monsanto 1-8: Please provide a copy of the workpapers supporting the testimony of
witness Mark Widmer. To the extent that the workpapers include any spreadsheets or models, please
provide in executable native format with all formulas intact.
Monsanto 1-9: Please provide a copy ofthe workpapers supporting the testimony of
witness William Fehrman. To the extent that the workpapers include any spreadsheets or models
please provide in executable native format with all formulas intact.
Monsanto 1-10: Please provide a copy of the workpapers supporting the testimony of
witness Douglas Bennion. To the extent that the workpapers include any spreadsheets or models
please provide in executable native format with all formulas intact.
Monsanto 1-11: Please provide a copy of the workpapers supporting the testimony of
witness Erich Wilson. To the extent that the workpapers include any spreadsheets or models, please
provide in executable native format with all formulas intact.
Monsanto 1-12: Please provide a copy ofthe workpapers supporting the testimony of
witness Mark Tucker. To the extent that the workpapers include any spreadsheets or models, please
provide in executable native format with all formulas intact.
Monsanto 1-13: Please provide a copy of the workpapers supporting the testimony of
witness William Griffith. To the extent that the workpapers include any spreadsheets or models
please provide in executable native format with all formulas intact.
Monsanto 1-14: Please provide a copy ofthe workpapers supporting the testimony of
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 2
witness Carole Rockney. To the extent that the workpapers include any spreadsheets or models
please provide in executable native format with all formulas intact.
Monsanto 1-15:If not included in the responses to other data requests, please provide
the jurisdictional allocation models in executable native format with all formulas intact. Please
include the allocations for both the Rolled-In and the Revised Protocol.
Monsanto 1-16:If not included in the responses to other data requests, please provide
the class cost of service allocation model in executable native format with all formulas intact. Please
include the allocations for both the Rolled-In and the Revised Protocol.
Monsanto 1-17: Please provide Monsanto s actual hourly load data for the test year and
all adjustments made to that actual hourly load data for purposes of:
The jurisdictional allocations
The class cost of service allocations
Monsanto 1-18: If not provided in response to other data requests, please provide all
workpapers and supporting data showing the derivation of each external allocation factor for both
the Rolled-In and Revised Protocol versions of the jurisdictional allocation models.
Monsanto 1-19: If not provided in response to other data requests, please provide all
workpapers and supporting data showing the derivation of each external allocation factor for both
the Rolled-In and Revised Protocol versions of the class cost of service allocation models.
Monsanto 1-20: If not provided in response to other data requests, please provide the
filed exhibits in executable native format with all formulas intact, where available.
DATED this 25th day of June, 2007.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By ~ti db J ~
RANDALL C. B
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNT AlN POWER - 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 25th day of June, 2007, 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 3)
Idaho Public Utilities Commission
O. Box 83720
Boise, ID 83720-0074
E-mail: jjewell~puc.state.id.S. Mail
Brian Dickman
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
brian. dickman(fPpacifi corp. com
Mail
Dean Brockbank
Justin Brown
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
dean. brockbank(fPpacificorp. com
Justin. brown(fPpacifi corp. com
Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Fax: [phone]
datareq uest(fPpaci fi corp. com Mail
Maurice Brubaker
Brubaker & Associates, Inc.
1215 Fern Ridge Parkway, Suite 208
St. Louis, MO 63141
m brubaker~consul tbai. com Mail
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
O. Box 1391
Pocatello, Idaho 83204-1391
elo~racinelaw .net
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNT AlN POWER - 4
Tim Buller
Agrium, Inc.
3010 Conda road
Soda Springs, Idaho 83276
tbuller~agrium.com
Mail
iAnJ hA!
RANDALL C B
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAlN POWER - 5