20070706Monsanto to PAC 2,1-65.pdf

LAW OFFICES OF
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
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 8: BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 139 I
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE (208) 232-6 109
www.racinelaw.net
SENDER'S E-MAIL ADDRESS: rcb(1j)racinelaw.net
July 2, 2007
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83702
Re:PAC-O7-
Dear Mrs. Jewel:
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702
TELEPHONE: [phone] IFACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 203A
10AHO FALLS, ID 93402
TELEPHONE: [phone]
FACSIMILE: [phone]
'ALSO MEMBER WY "' IL BARS
"ALSO MEMBER UT BAR
"'ALSO MEMBER CO BAR
tALSO MEMBER D. C. BAR
ttALSO MEMBER MO BAR;ALSO MEMBER IL BAR
;;ALSO MEMBER WA BAR
Idaho Pu~lic Utilities Commission
Office of the Secretary
RECEIVED
JUL 5 - 2007
Boise, Idaho
Enclosed for filing please find the original and three copies of Monsanto Company s Second
Data Requests to Rocky Mountain Power.
Thank you for your assistance.
Sincerely,
~BUDGE
RCB:rr
Enclosures
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]
Idaho Public Utilities Commission
Office of the Secretary
RECEIVED
JUL 5 - 2007
Boise, Idaho
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, P AC-E- 7-
MONSANTO COMPANY'S SECOND DATA REQUESTS
TO ROCKY MOUNTAIN POWER
MONSANTO COMPANY, by and through their attorneys, hereby submits this Second Data
Request to Rocky Mountain Power, pursuant to Rule 225 ofthe Idaho Public Utility Commission
Rules of Procedure, IDAP A 31.01.01 , as follows:
Monsanto 2-Referring to the testimony of Mr. Walje at page 6, please provide the
basis for determining that an 80%/20% share of health insurance premium costs is the appropriate
sharing. Please provide copies of all studies, backup material, surveys, etc., relied upon.
Monsanto 2-2: What percentage of health care premiums is assumed to be paid by
employees in developing the test year revenue requirement in this proceeding? If less than 20%,
what adjustment would be required to reflect the 80%120% sharing?
Monsanto 2-3: With respect to the testimony of witness Walje, page 6, please provide
the studies, analyses and surveys used to determine the appropriate change in the pension plan for
non-union employees.
Monsanto 2-Please state whether the level of pension expense included in the test
year in this proceeding corresponds to the change made effective on June 1 , 2007, and whether that
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER - 1
change has been reflected on a pro forma annualized basis for the entire test year. If it has not been
reflected on a pro forma annualized basis, what adjustment would be required to reflect the new
policy on an annualized pro forma basis?
Monsanto 2-5: Referring to pages 4 and 5 ofthe testimony of Mr. Walje, in particular
from line 23 of page 4 through line 3 of page 5, please state whether it is Rocky Mountain Power
position that if the Commission does not grant 100% of the requested rate relief that Rocky
Mountain Power company will be unable ". . . to maintain and provide safe and reliable service to
our customers at a level they both expect and deserve." Provide all supporting workpapers for your
answer.
Monsanto 2-6: Referring to page 7 ofthe testimony of Mr. Walje, lines 15 through
, please provide the studies and workpapers supporting the generation cost figures of6.5~ per kWh
for traditional gas combined-cycle turbines, 5.5~ per kWh for super critical pulverized coal plants
and 9~ per kWh for an IGCC plant.
Monsanto 2-7: Referring to page 8 ofthe testimony of Mr. Walje, lines 14 through
, please provide the year-by-year detail for the expected $16 billion capital expenditures, with a
breakdown by function and identifying costs associated with major projects. Also indicate where
the information contained in your response is reflected in the Company s most recent Integrated
Resource Plan.
Monsanto 2-Referring to the testimony of Mr. Walje at page 11 , line 19 through
page 12, line 2, please state the policy guidelines and tests applied by Rocky Mountain Power
Company to determine which post- December 31 , 2006 investments and costs should be included in
the test year in this proceeding.
Monsanto 2-With respect to the testimony of Mr. Walje at page 11 , line 18 through
page 12, line 2, please explain and quantify what revenues for growth in usage by existing customers
and revenues from new customers has been included for post-December 31 2006 changes. Ifnone
was included, please explain in detail why not.
Monsanto 2-10:Referring to page 13 , lines 4 through 18, of the testimony of Mr.
Walje, please provide the "before" and "after" metrics for each area where Rocky Mountain Power
company claims that improvements have been made, and provide a quantification of the savings in
cost as a result of each. In addition, please state the amount of cost reduction reflected in the
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER - 2
Company s test year in this case, and identify the specific adjustments where these savings are
reflected.
Monsanto 2-11:With respect to the testimony of Mr. Waljeatpage 13, line 19 through
page 14, line 3 , please identify each commitment and provide the "before" and "after" metrics that
demonstrate these improvements.
Monsanto 2-12:With respectto page 14 ofthe testimony ofMr. Walj e, lines 3 through
, please provide a copy of each of the TQS research reports.
Monsanto 2-13: With respect to page 14 of the testimony of Mr. Walje, please provide
the 2007 TQS research report when it becomes available.
Monsanto 2-14: With respect to the page 14 ofthe testimony of Mr. Walje, lines 11
through 18, please provide a copy ofthe J.D. Power & Associates study and the previous studies
against which the improved performance was measured.
Monsanto 2-15: Referring to the testimony of Mr. McDougal, beginning at line 12
please provide the following growth statistics for the last 10 years, and as forecasted for the next 10
years, in total and by jurisdiction.a. Annual summer peak megawatt demand, and winter peak megawatt demand and
annual megawatthour sales;
Annual megawatt change and percentage change in summer peak demand each year;
Annual megawatt change and percentage change in winter peak demand each year;
and
Annual megawatthour change and percentage change in energy sales each year.
Monsanto 2-16: Referring to page 12 ofthe testimony of Mr. McDougal, beginning
at line 17, please provide for each ofthe years 2000 through 2006, and as projected for each ofthe
years 2007 through 2015 , the number ofSO2 allowances sold and the revenues per allowance, and
in total. In addition, please provide for each year the beginning of year balance, the number
acquired, the number sold and the end of year balance.
Monsanto 2-17: Referring to page 18 of the testimony of Mr. McDougal, lines 9
through 15, please state the amount ofIdaho test year cost proposed in Rocky Mountain Power
filing, and what that amount would be if the Company utilized the FAS87 amount.
Monsanto 2-18: Referring to the testimony of Mr. McDougal at page 19, lines 2
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER - 3
through 20, please provide the basis for the three-year amortization proposal. Include any applicable
precedent relied upon for a three-year amortization period. Also, please state the test year cost and
the amount of the adjustment if the amortization period were five years and if the amortization
period were 10 years.
Monsanto 2-19: Referring to the testimony of Mr. McDougal at page 20, lines 25
through 30, please provide the basis for and detail of the $7.3 million expected on-going level of
annual charges from MEHC.
Monsanto 2-20: Referring to the testimony of witness Fehrman, at page 8, concerning
the Lake Side plant, please provide the annualized first year non-fuel revenue requirement on both
a total company and an Idaho jurisdictional basis, and the amount proposed to be included in revenue
requirements in this case on both a total company and an Idaho jurisdictional basis.
Monsanto 2-21:Referring to the testimony of Mr. Fehrman at pages 9 and 10
concerning the acquisition of natural gas, please provide a copy of the Company s risk management
policy and its implementation plan for acquiring natural gas and purchased power, and demonstrate
how the acquisition plan is consistent with the risk management policy.
concerning the acquisition of natural gas, please identify each natural gas transaction as to:
Monsanto 2-22:Referring to pages 9 and 10 of the testimony of Mr. Fehrman
Date of contract;
Nature of produce, i., physical gas, futures contract, call option, put, swap, etc.
Purchase or sale;
The quantity of bas;
The delivery point;
The delivery period;
The price or price basis;
Counterparty; and
Reason for transaction.
Monsanto 2-23:Referring to page 10 of the testimony of Mr. Fehrman, lines 6 through
, please provide the basis for the statement that over time hedging will ". . . always produce the
lowest possible cost."
Monsanto 2-24:Referring to pages 9 and 1 0 of the testimony of Mr. Fehrman, please
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER - 4
provide the dispatch prices that are used in the test year for each natural gas unit and explain how
those prices are determined.
Monsanto 2-25: Referring to the testimony of Mr. Fehrman, at page 10, line 19 through
page 11 , line 5, please provide the assumed per kW cost of the 1 400 megawatts of renewable
resources that were identified as a part of a least-cost portfolio, and the per kW cost of each of the
wind resources proposed to be included in the revenue requirement in this proceeding. Please
separately identify generation and transmission costs.
Monsanto 2-26:Referring to the testimony of Mr. Fehrman at page 13 , lines 14 through
, please provide a copy of all information concerning the Leaning Juniper 1 project that is
referenced.
Monsanto 2-27:Concerning page 14 of the testimony of Mr. Fehrman, lines 1 through
, please provide the annualized first year non-fuel revenue requirement on both a total company
and an Idaho jurisdictional basis for the Leaning Juniper 1 facility, and the amounts proposed to be
included in the test year in this proceeding, on both a total company and an Idaho jurisdictional
basis.
Monsanto 2-28:Referring to the testimony of Mr. Fehrman at page 16, lines 15 to 21
please provide a copy of all information concerning the Marengo project that is referenced.
Monsanto 2-29:Concerning page 16-17 of the testimony of Mr. Fehrman, please
provide the annualized first year non-fuel revenue requirement on both a total company and an Idaho
jurisdictional basis for the Marengo facility, and the amounts proposed to be included in the test year
in this proceeding, on both a total company and an Idaho jurisdictional basis.
Monsanto 2-30:Referring to the testimony of Mr. Fehrman at page 19, lines 14 to 20
please provide a copy of all information concerning the Goodnoe Hills project that is referenced.
Monsanto 2-31:Concerning pages 19 and 20 ofthetestimony of Mr. Fehrman, please
provide the annualized first year non- fuel revenue requirement on both a total company and an Idaho
jurisdictional basis for the Goodnoe Hills facility, and the amounts proposed to be included in the
test year in this proceedings, on both a total company and an Idaho jurisdictional basis.
Monsanto 2-32:Referring to the testimony of Mr. Fehrman at page 22, lines 8 to 12
please provide a copy of all information concerning the Blundell Bottoming Cycle resource project
that is referenced.
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER - 5
Monsanto 2-33: Concerning page 22 of the testimony ofMr. Fehrman, please provide
the annualized first year non-fuel and fuel revenue requirement on both a total company and an Idaho
jurisdictional basis for the Blundell Bottoming Cycle resource, and the amounts proposed to be
included in the test year in this proceeding, on both a total company and an Idaho jurisdictional
basis.
Monsanto 2-34: Referring to Table 1 at page 3 of the testimony of witness Widmer
please provide the detailed workpapers that illustrate how Rocky Mountain Power Company has
identified the various components of the increase in claimed revenue requirement, both for the total
system and for the Idaho jurisdiction.
Monsanto 2-35: Referring to Table 1 at page 3 , please provide a copy of all "Expired
Purchase Contracts" as noted as Adjustment Item No.5 in the table.
Monsanto 2-36: Referring to Table 1 at page 3, please provide a copy of all "Expired
Sales Contracts" as noted as Adjustment Item No.6 in the table.
Monsanto 2-37: Does the "growth" component in the table at page 3 of Mr. Widmer
testimony recognize a difference in the rate of growth in Idaho and the rate of growth in the system
in determining the amount of dollars associated with load growth attributed to the Idaho jurisdiction?
Plase explain and provide your workpapers. If it does not distinguish differences in the rate of
growth, please explain why Rocky Mountain Power Company has chosen not to recognize the
difference in preparing this table.
Monsanto 2-38: With respect to Mr. Widmer s testimony at page 3, lines 13-, please
provide a numerical value of load growth for the Idaho jurisdiction contained in this filing as
compared to the Idaho load contained in the Company s filing in Case No. PAC-06-04.
Monsanto 2-39: Referring to page 4, lines 6-8 of Mr. Widmer s testimony, plese
provide details as to what "market prices" the Company has utilized in this filing.
Monsanto 2-40: Referring to page 4, lines 6-8 of Mr. Widmer s testimony, please
provide a detail breakout ofthe "cost increases or decreases" associated with the Company s natural
gas hedges.
Monsanto 2-41: Referring to page 5, lines 19-, of Mr. Widmer s testimony, please
provide an explanation and numerical calculation of how the Company s QF purchases have affected
overall net power costs. Has the avoided cost value posted by the Company in 2006 and up through
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER - 6
current 2007 been generally increasing, decreasing or remaining stable?
Monsanto 2-42:Referring to Exhibit No. 14, page 5, of Mr. Widmer s testimony,
please provide workpapers supporting the derivation ofthe calculations of "Mark to Market" values.
Please provide supporting documentation in Excel with formulas intact. Please confirm that such
calculations are performed within the GRID model or post-Model calculations.
Monsanto 2-43: Referring to Exhibit No. 14, page 5, of Mr. Widmer s testimony,
please provide workpapers supporting the derivation of the calculations of "Gas Swaps" values.
Please provide supporting documentation in Excel with formulas intact. Please confirm that such
calculations are performed within the GRID model or post-Model calculations.
Monsanto 2-44: Referring to page 13 of the testimony of Mr. Widmer, concerning
reserve requirements, please provide for each month of calendar year 2006 the operating reserve
(regulating and contingency stated separately) requirement and the actual reserves being carried on
the system, at the time of each monthly peak. Also, identify the megawatts by unit and contract
(including non-firm load) where each type of reserve was actually carried.
Monsanto 2-45:Concerning the testimony of Mr. Widmer, please state Rocky
Mountain Power company s "planning reserve" margin targets, in megawatts and percent of annual
firm peak demand.
Monsanto 2-46:Referring to page 18 ofthe testimony of Mr. Widmer, beginning at
line 20, please provide the price curves at each of the four market points that were used in the test
year GRID model dispatch. Also, please provide the import and export limits for each market, for
each month ofthe test year.
Monsanto 47:Please provide the forecast and the supporting workpapers referenced
at page 19, lines 4 through 18 of the testimony of Mr. Widmer.
Monsanto 2-48:Mr. Widmer s Exhibit No. 15 shows monthly average megawatts, and
his Exhibit No. 16 shows peak megwatts for summer and winter. Please provide the same
information that is shown on Exhibit No. 16 for each ofthe months shown on Exhibit No. 15 and
separately identify firm and non-firm load.
Monsanto 2-49:Please provide the information requested in the previous question (No.
48) for each month of 2006.
Monsanto 2-50:For each hour of calendar year 2005 , calendar year 2006, and calendar
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER - 7
year 2007 to date, please provide the following information (In $/Mwh) both for the entire system
and for the East System.
The market value of energy;
The incremental cost associated with the most expensive resource dispatched;
The purchase price for the most expensive short-term resource purchased; and
The revenues received from the short-term sale that provided the highest per unit
revenue.
Monsanto 2-51: Please provide a copy of all communications between: (a) Rocky
Mountain Power Company, its predecessor company, and any affiliates; and (b) Bond rating
agencies, concerning regulatory issues, price levels for retail service, regulatory commission policies
regulatory climate, presence or absence of adjustment clauses for fuel and purchased power, and
related issues for the period beginning one year before the acquisition by MEHC was final, through
the most recent communication. Please include all drafts of commentaries, all mark -ups exchanged
and all comments with respect to rating agency reports.
Monsanto 2-52:Please explain the purpose of Mr. McDougal's Exhibit No. 13, state
where and how the numbers in that exhibit are used in the filing and in determining the proposed
revenue requirement and revenue increase, and state where in testimony this exhibit is explained.
Monsanto 2-53:Please provide the detailed workpapers supporting the development
ofthe "net power cost savings" shown for each project in Mr. McDougal's Exhibit No. 13.
Monsanto 2-54:Referring to Tabs 8.8.2 and 8.3 in Mr. McDougal's Exhibit No. 11
please provide for each listed project:
The month and day that the project went into service.
The dollar amount of investment included in the December 31 , 2006 plant in-service
balance;
The dollar amount of accrual to the reserve for depreciation for this project at
December 31 , 2006;
The dollar amount of depreciation expense included for this project in the actual
2006 operating results;
The number of months and dollar amount of adjustment to depreciation expense
proposed to be included in revenue requirements.
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER - 8
Monsanto 2-55:Referring to page 8.8.2 of Mr. McDougal's Exhibit No. 11 , for each
Steam Production" project (other than the Huntington Scrubber), for the Hermiston combustion
turbine rotor replacement and for each transmission project, please:
Identify the reason for the expenditure;
State whether the capital expenditure will reduce expenses, and if so quantify the
reduction and explain how much of the reduction is included in the test year in this
proceeding; and
Please explain whether the project will lead to increased capacity to serve retail
customers or to sell in the wholesale market, and if so quantify the extent of
additional capacity and energy, the amount of potential net revenue, and the amount
included in the test year in this proceeding.
Monsanto 2-56:Withrespecttopage 8.8.2 of Mr. McDougal's Exhibit No. 11 , please
explain why the transmission project identified as "SW Utah Load Growth Project" will benefit
Idaho customers and explain why this cost should be allocated on the "SG" factor rather than
assigned to Utah.
Monsanto 2-57:With respect to page 8.3 of Mr. McDougal's Exhibit No. 11 , please
describe and explain the purpose of each "mining" project and:a. State whether the project will result in reduced expenses, and if so quantify the
expense reduction and the amount included in the test year in this proceeding; and
Whether the project will increase the ability to extract coal for use in Rocky
Mountain Power Company s generators, and if so, state how that charge is reflected
in the test year.
Monsanto 2-58:Concerning page 8.3 on Mr. McDougal's Exhibit No. 11 , for the
King Air B200 Turboprop" please explain the purpose of this investment, whether it is a
replacement or a new airplane, and provide copies of the studies which justified the purchase of this
airplane as opposed to alternative means and methods of transportation.
Monsanto 2-59:Withrespecttopage 8.8.4 of Mr. McDougal's Exhibit No. 11 , for each
steam production" project (other than Blundell Bottoming Cycle) and for each "transmission
project, please:
Identify the reason for the expenditure;
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER - 9
State whether the capital expenditure will reduce expenses, and if so quantify the
reduction and explain how much of the reduction is included in the test year in this
proceeding; and
Please explain whether the project will lead to increased capacity to serve retail
customers or to sell in the wholesale market, and if so quantify the extent of
additional capacity and energy, the amount of potential net revenue, and the amount
included in the test year in this proceeding.
Monsanto 2-60: Concerning page 8.5 ofMr. McDougal's Exhibit No. 11 and the
project identified as "Cinder Butte - 161-12.5 kV 2-30 MY A sub " please explain the purpose ofthis
project and state whether this project will permit Rocky Mountain Power Company to serve
additional load in Idaho, and if so quantify the amount, quantify the expected net revenues from this
additional capacity and state how much ofthose net revenues have been included in the test year in
this proceeding.
Monsanto 2-61:With reference to the direct testimony of Erich Wilson, page 6, please
provide all workpaper studies and analyses that detail the $27.5 million company incentive
compensation as reduced from the $33.9 million included in the 2006 unadjusted data.
Monsanto 2-62: Referring to the direct testimony of Erich Wilson, please provide the
target incentive level for the test period in this proceeding.
Monsanto 2-63:Referring to the direct testimony of Erich Wilson, page 8, line 14
please provide the reference to where the cost associated with the incentive plan to compensate
employees based on corporate financial performance is removed from the 2006 unadjusted data and
provide all supporting workpapers, studies and analyses which support that removal.
Monsanto 2-64:Referring to the direct testimony of Erich Wilson, Exhibit No. 22, page
Regarding Goal 1 0, please provide five-year regulatory and public policy agenda for
Rocky Mountain Power; andb. Provide the regulatory and legislative plan.
Monsanto 2-65: Referring to the direct testimony of Erich Wilson, Goal 11 , please
provide Rocky Mountain Powers ' Risk Management Plan , First Phase.
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER -
DATED this 2nd da y of July, 2007.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
RANDALL C. BUDGE
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 2nd dayofJuly, 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(illpuc.state.id.S. Mail
Brian Dickman
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
brian. di ckman~pacifi corp. com
Mail
Dean Brockbank
Justin Brown
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
dean. brockbank~J'acificorp. com
Justin. brown~JJacificorp. com
Mail
Data Request Response Center
P acifi Corp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Fax: [phone]
datarequest~JJacifi corp. com Mail
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER-
Maurice Brubaker
Katie Iverson
Brubaker & Associates, Inc.
1215 Fern Ridge Parkway, Suite 208
St. Louis, MO 63141
mbrubaker~consul tb ai. com
ki verson~consultbai. com
Mail
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, Idaho 83276
iim.r. smith~monsanto . com Mail
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
O. Box 1391
Pocatello , Idaho 83204-1391
elo~racinelaw . net
Tim Buller
Agrium, Inc.
3010 Conda road
Soda Springs, Idaho 83276
tbuller~agrium.com
Mail
d,
RANDALL C. BUDGE
MONSANTO COMPANY'S SECOND DATA REQUEST FOR ROCKY MOUNTAIN POWER -