The URL can be used to link to this page

Home My WebLink About20070815Monsanto to PAC 6-1 to 6-19.pdfLAW OFFICES OF RACINE OLSON NYE BUDGE 8: BAILEY CHARTERED 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"" Jean Jewell, Secretary Idaho Public Utilities Commission 472 W. Washington Street Boise, Idaho 83702 Re:PAC-O7- Dear Mrs. Jewel: 201 EAST CENTER STREET POST OFFICE BOX 1391 POCATELLO, IDAHO 83204-1391 TELEPHONE (208) 232-6101FACSIMILE (208) 232-6109 www.racinelaw.net SENDER'S E-MAIL ADDRESS: rcbiQ\racinelaw.net August 13 , 2007 c::: BOISE OFFICE 101 SOUTH CAPITOL BOULEVARD. SUITE 208 BOISE. IDAHO 83702TELEPHONE: (208) 395-0011 FACSIMILE: (208) 433-0167 IDAHO FALLS OFFICE 477 SHOUP AVENUE SUITE 203A IDAHO FALLS. ID 83402 TELEPHONE: (208) 528-6101FACSIMILE: (208) 528-6109 "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 r--J E:::i ---' ;:0 --~ Enclosed for filing please find the original and three copies of Monsanto Company s Sixth Data Requests to Rocky Mountain Power. Thank you for your assistance. RCB:sab Enclosurescc: Service List (via e-mail) RANDAL~ C. 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 od: ,._ znu-I e: 0 c: UTi , f"\f-1'--"". 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 SIXTH DATA REQUESTS TO ROCKY MOUNTAIN POWER MONSANTO COMPANY, by and through their attorneys, hereby submits this Sixth Data Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utility Commission s Rules of Procedure, IDAPA 31.01.01 , as follows: Monsanto 6-1: Referencing Exhibit No. 27, is this single page the complete and entire Hewitt Associates report? If not, then please provide the entire report. Monsanto 6-2: Please provide the workpapers supporting the amounts shown on line 10 of Page 21 of Mr. Wilson s direct testimony. Upon what sharing were those levels of expenses based? Monsanto 6-3: Referencing the response to Monsanto Data Request 2., the question asked for the studies, analyses and surveys used to determine the appropriate change in the pension plan for non-union employees. The response refers to Wilson direct testimony as well as Exhibit No. 26.a. Does Exhibit 26 represent the full extent of the Company s basis for its determination of the change in the pension plan? If not, then please provide the studies, analysis and surveys also used to determine the change in the pension plan. MONSANTO COMPANY'S SIXTH DATA REQUEST FOR ROCKY MOUNTAIN POWER- b. For Exhibit No. 26, is this single page the complete and entire Hewitt Associates report? If not, then please provide the entire report. c. For Exhibit No. 26, was this single page provided in any presentation or meeting? If so, please provide a copy of the complete presentation and notes made by parties in attendance. Monsanto 6-4: Please provide the workpapers supporting the $54.7 million budgeted pension expense as shown on line 10 of page 18 of Mr. Wilson s direct testimony. Monsanto 6-5: Please provide the workpapers supporting the $49.6 million projected pension expense as shown on line 12 of page 18 of Mr. Wilson s direct testimony. Monsanto 6-6: Reference the Company s response to Monsanto Data Request 2.19. The response states that the MEHC cross-charges began in April 2006, but the attachment claims the cross-charges commenced on March 1 , 2006. Which is the correct date? Monsanto 6-7: Please provide a projection of the pension trust cash contributions for the next five years. If five years' projection are not available , then provide as many years as is available. Monsanto 6-8: Follow-up to the Company s response to Monsanto Data Request No. 2.63: Please explain how the costs associated with the Company s long term incentive plan have been removed from the 2006 unadjusted data and how much that adjustment is in the present general rate case. For example, where is this adjustment made in Tab 4 (O&M Adjustments) of Exhibit 11 ? Monsanto 6-9: Follow-up to the Company s response to Monsanto Data Request No. 2.61:a. Mr. Wilson states that the $27.5 million "is derived by taking the target incentive opportunity of each employee times their current base wage." Could this be restated as saying the target incentive opportunity is multiplied times the current base wage? If not, please explain. b. Is the "target incentive opportunity" a percentage of each employee s base wage? If not, please explain. c. Page 3, line 13 , Mr. Wilson states that , " We then separate the total cash compensation portion into two elements: 1) base salary, and 2) an "at risk" or incentive element." Is the "at risk" or incentive element as a percentage of each employee s base wage the same for all employees? If not, how is the separation performed? MONSANTO COMPANY'S SIXTH DATA REQUEST FOR ROCKY MOUNTAIN POWER - 2 d. Please explain the current algorithm for determining the amount of each employee s incentive award used in the development of the $27.5 million; e., 60% based on individual employee achievement, 25% based on business unit, etc.e. Please provide a breakdown of the incentive award percentages and eligible wages used in the development of the $27.5 million. For example, Group A: wages average $x, with a target incentive opportunity ofy%; Group B: and so forth. Monsanto 6-10: Please provide a copy of the Company s Annual Incentive Plan referenced on line 13 of page 5 of Mr. Wilson s direct testimony, and used as the basis for developing the $27. million. Monsanto 6-11: Other than the Annual Incentive Plan, what other alternative incentive plans are available to Company employees? Are the costs of any of these alternative incentive plans included in the $27.5 million? Monsanto 6"12: If not identified in Monsanto 6-12 or 6-13 above, what is the Plan Term of the incentive planes) used in the development of the $27.5 million? Monsanto 6-13: Please clarify Mr. Wilson s testimony at lines 15-20 on page 6 of his direct testimony. Mr. Wilson states that the incentive compensation design provides for an upside opportunity for individual employees whose performance surpasses acceptable levels. He also states the overall company payout is limited to the target incentive level. Does this mean that if individuals receive above their target incentive, there must be a corresponding reduction in some other employees' incentive in order for the Company to payout only the overall target incentive level? Monsanto 6-14: Reference the $33.9 million Incentive expense (12 months ended December 2006) as shown on Page 4.5.2 ofMr. McDougal's Exhibit No. 11: Incentive Plan? How much of the $33.9 million was related to the Company s Annual b. How much of the $33.9 million was related to the incentive plan for selected officers and key personnel that incorporates achievement of corporate financial performance as one of its critical elements. How much of the $33.0 million was related to other incentive plans? Is all of the $33.9 million related to non-union employees? MONSANTO COMPANY'S SIXTH DATA REQUEST FOR ROCKY MOUNTAIN POWER - 3 e. What was the target incentive level for 2006? Did the Company payout more or less than its target incentive level in 2006?f. Has the Company ever paid out less than its target incentive level in aggregate? If so, when? Monsanto 6-15: Follow-up to Monsanto Data Request 2.2, please fully explain why the difference of $842 082 is multiplied by 0.7435. Monsanto 6-16: In Case No. PAC-06-, the Company sought authority to capitalize costs associated with conversion of software to an accounting calendar year, and that these costs will fall between $500 000 and $1 million. Is the Company seeking recovery ofthose costs in this general rate case? If so, please identify the amount and the page reference in Mr. McDougal' Exhibit 11. If not, show where these costs have been removed from the unadjusted results. Monsanto 6-17: Reference Page 4.17 though 4.17.2 ofMr. McDougal's Exhibit 11: Please provide supporting workpapers for the $39 557 830 CIC Severance. related SERP. Please provide supporting workpapers for the $3 925 013 CIC Severance- Please provide supporting workpapers for the $461 871 CY 2005 deferral. d. Please provide supporting workpapers for the $5 467 764 back-filled and non-regulated employees. e. Please provide supporting workpapers for the $1 045 057 additions 12/31/2006 through 3/9/2007. Monsanto 6-18: Has the basic algorithm of the Company s incentive compensation plan changed since 2006, or since the last Idaho general rate case? If so, please explain. Monsanto 6-19: Reference Exhibit 24 and 25, have any of the employees listed on these exhibits been retained by the Company as an outside consultant? If so, please identify and provide the amount of fees paid to such outside consultants. Have any other of these fees been included in this rate case? MONSANTO COMPANY'S SIXTH DATA REQUEST FOR ROCKY MOUNTAIN POWER - 4 DATED this 13th day of August, 2007. RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED ~ - ~~AL~B~ MONSANTO COMPANY'S SIXTH DATA REQUEST FOR ROCKY MOUNTAIN POWER - 5 CERTIFICATE OF MAILING I HEREBY CERTIFY that on this 13th day of August, 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.u.S. Mail Brian Dickman Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake City, Utah 84111 brian. dickman~pacificorp. com Mail Dean Brockbank Justin Brown Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake city, Utah 84111 dean. brockbank(fYpacificorp.com Justin. brown(fYpacificorp.com Mail Data Request Response Center PacifiCorp 825 NE Multnomah, Suite 2000 Portland, Oregon 97232 Fax: 503-813-6060 datarequest~pac if! corp. co m Mail Maurice Brubaker Katie Iverson Brubaker & Associates, Inc. 1215 Fern Ridge Parkway, Suite 208 St. Louis, MO 63141 m brubak er~consu I tbai. co m ki verson~consultbai. com Mail MONSANTO COMPANY'S SIXTH DATA REQUEST FOR ROCKY MOUNTAIN POWER - 6 James R. Smith Monsanto Company O. Box 816 Soda Springs, Idaho 83276 iim.smith~monsanto.com 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 Conley E. Ward Michael C. Creamer Givens Pursley LLP 601 W. Bannock Street O. Box 2720 Boise, ID 83701-2720 cew~givenspursley.com Dennis E. Peseau, Ph. Utility Resources, Inc. 1500 Liberty Street S., Ste. 250 Salem, OR 97302 dpeseau~excite.com &v- Mail Mail Mail Mail Mail ---./ RANDALL C. B DGE MONSANTO COMPANY'S SIXTH DATA REQUEST FOR ROCKY MOUNTAIN POWER - 7