20071009PAC to Agrium 1-6.pdf

John R. Hammond, Jr., ISB No. 5470
FISHER PUSCH & ALDERMAN LLP
U S Bank Plaza, 5th Floor
101 South Capitol Boulevard
O. Box 1308
Boise, Idaho 83701
[phone]
[phone] facsimile
irh~fua-law.com.com
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UTILfYIES. COMMISSiCi'
Justin Lee Brown
Pro Hac Vice Admission Pending
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
Fax: [phone]
Email: iustin.brown~pacificorp.com
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL OF CHANGES TO
ITS ELECTRIC SERVICE SCHEDULES
CASE NO. P AC-O7-
DATA REQUESTS
ROCKY MOUNTAIN POWER'
FIRST SET OF DATA REQUESTS TO AGRIUM, INc.
Pursuant to Rules 222 and 225 of the Idaho Public Utilities Commission Rules of
Procedure, Rocky Mountain Power, a division of PacifiCorp (herein
, "
Rocky Mountain
Power" or "Company ), by and through its counsel, herein submits its first set of data
requests to Agrium, Inc. ("Agrium ) and requests that Agrium respond, in writing, within
fourteen (14) days after service hereof, to the following data requests:
ROCKY MOUNTAIN POWER'S FIRST Page
SET OF DATA REQUESTS TO AGRIUM
DEFINITIONS AND INSTRUCTIONS
The following definitions and instructions apply to each of the requests for production
set forth herein and are deemed to be incorporated therein.
(1)Document" and "documentation" should be interpreted as broadly as
possible to include, but not be limited to, the original or any copy, regardless of origin or
location, of any book, pamphlet, periodical publication, letter, scrapbook, diary, calendar
canceled check, photograph, form, memorandum, schedule, tax return, telegram, telex
report, record, order or notice of governmental action of any kind, study, minutes, logs
graph, index, tape, disc, internal operating manual, data sheet or data processing card, or any
other written, recorded, transcribed, punched, taped, filmed, graphic or retrievable matter or
data of any kind, however produced or reproduced, to which you have or have had access.
This definition is intended to include, but not be limited to, all documents which have been
created and/or which reside in any type of electronic format and is to be construed in its most
comprehensive sense as contemplated by the Idaho Rules of Civil Procedure.
(2)You" shall mean the Agrium; any merged or consolidated predecessor or
predecessors in interest; parente s), subsidiaries and affiliates, past and present; and the
employees, officers, directors, agents, consultants, attorneys and all persons acting under
contractual arrangement with or acting or purporting to act on behalf of Agrium.
(3)Person or Entity" should be interpreted to denote, unless otherwise
specified, any natural person, firm, corporation, association, group, individual or organization
of any type whatsoever.
ROCKY MOUNTAIN POWER'S FIRST Page 2
SET OF DATA REQUESTS TO AGRIUM
(4)Any request to identify" or "provide should be interpreted to mean:
With respect to a natural person, that person s full name, title, job
description, and business and home address. Where the identification pertains to a past
period, as to each person identified who is still in your employ, or the employment of the
group with which such person is identified in response to any requests, provided, in addition
that person s title and job description as of the time of such past period. Where the person is
no longer in your employ or the employment of the group with which such person is
identified in response to any request, provide that person s affiliate, position, home and
business address, if known, or if not known, such person s last known affiliation, position
home and business address, or portions thereof as may be known.
With respect to an entity other than a natural person, that entity s name
business, type of entity, present status and present or last known address.
With respect to a document, that document's title, date, author (and, if
different, the signer), addresses, recipients, or other persons who assisted in the preparation
subject matter or general nature, and any amendments thereto, present location and
custodian, whether or not such document is in the respondent's possession, custody or
control and whether or not the document is claimed to be privileged. The final version and
each draft of each document should be identified and produced separately. Each original and
each non-identical copy (bearing marks or notations not found on the original) of each final
version and draft of each document should be identified and produced separately.
With respect to a physical facility, the location of the facility, the
intended purpose of the facility, the actual use of such facility, the operating dates of the
facility, the installation date of the facility, the date utilization of the facility terminated if
ROCKY MOUNTAIN POWER'S FIRST Page 3
SET OF DATA REQUESTS TO AGRIUM
applicable, and whether the facility is subject to the jurisdiction of the Federal Energy
Regulatory Commission, the Idaho Public Utilities Commission, or any other regulatory
body.
(5)Communication should be interpreted to include, but not be limited to, all
forms of communication, whether written, printed, oral, pictorial, electronic or otherwise
including testimony or sworn statement, or any means or type whatsoever.
(6)Relating To" or "Related To means pertaining to, presenting, discussing,
commenting on, analyzing, or mentioning in any way.
(7)The term and" and "should be construed either disjunctively or
conjunctively whenever appropriate in order to bring within the scope of each request any
information or document which might otherwise be considered to be beyond its scope.
(8)The singular form of a word should be interpreted as plural, and the plural
form of a word should be interpreted as singular, whenever appropriate in order to bring
within the scope of each request any information or document which might otherwise be
considered to be beyond its scope.
DATA REQUESTS
Dennis Peseau.Please provide all work papers and calculations used in
developing the alternate demand cost allocations you propose (1 CP, 3 CP and "3 Sum-
Win ) and the resultant cost of service results of each proposal.
Dennis Peseau. Are the alternate demand cost allocations you propose in this
case (1 CP, 3 CP and "3 Sum-1 Win ), allocation proposals you have recommended in other
cases where you have filed pre filed written testimony? If yes, please identify each proceeding
and provide a description of the comments that were filed in response to your testimony
ROCKY MOUNTAIN POWER'S FIRST Page 4
SET OF DATA REQUESTS TO AGRIUM
received from each respective state s commission? If no, what other allocation methods have
you proposed in other states? Also, please provide copies of testimony supporting other
allocation methods you have sponsored in other states, if any.
Dennis Peseau. At pages 5-6 of your prefiled direct testimony, you state that
the company has included the increased costs associated with 2007 load growth but not the
increased revenues, resulting in a mismatch. Please specifically identify the costs increases
associated with 2007 load growth included the company s filing. Assuming that your
adjustment is designed to include all increased revenues associated with 2007 load growth
do you agree that your adjustment must include all increased expenses associated with 2007
load growth to avoid a mismatch?
Dennis Peseau. Please provide work papers and any other supporting
documentation for Exhibit 405.
Dennis Peseau. Please identify all Idaho Public Utilities Commission orders
that you are aware of that have not allowed known and measurable adjustments when setting
utility rates.
Dennis Peseau. Please confirm whether you agree that Idaho law permits
known and measurable adjustments when setting utility rates. Please explain your answer.
ROCKY MOUNTAIN POWER'S FIRST Page 5
SET OF DATA REQUESTS TO AGRIUM
Please produce any and all documents that Agrium expects or reasonably
anticipates introducing into evidence at hearing in the above-captioned docket.
DATED this 9th day of October 2007.
Respectfully submitted
ROCKY MOUNTAIN POWER
R. Hammond, Jr., ISB No. 5470
FI ER PUSCH & ALDERMAN LLP
S Bank Plaza, 5th Floor
101 South Capitol Boulevard
O. Box 1308
Boise, Idaho 83701
[phone]
[phone] facsimile
irh~fpa-law .com
-and-
Justin Lee Brown
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
Fax: [phone]
Email: iustin.brown~pacificorp.com
ROCKY MOUNTAIN POWER'S FIRST Page 6
SET OF DATA REQUESTS TO AGRIUM
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 9th day of October, 2007, a true and correct copy of
the foregoing document was served by first-class mail, postage prepaid, and addressed to; by
fax transmission to; by overnight delivery to; or by personally delivering to or leaving with a
person in charge of the office as indicated below:
Jean Jewell, Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
Email: iean.iewell(Q),puc.idaho.gov
) U.S. Mail
) Facsimile
) Overnight Delivery
(,XI Hand Delivery
) Email
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
P. O. Box 83720
Boise, ill 83720-0074
neil. pricecq~puc.idaho. gov
) U.S. Mail
) Facsimile
) Overnight Delivery
(X) Hand Delivery
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Data Request Response Center
PacifiCorp
825 N. E. Multnomah, Suite 2000
Portland, OR 97232
e-mail: datarequest~pacificorp.com
) U.S. Mail
) Facsimile
) Overnight Delivery
) Hand Delivery
(XI Email
) u.S. Mail
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Hand Delivery
) Email
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, ill 83720-0074
scott. woodburv~puc. idaho. gov
Attorney for Commission Staff
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, ill 83276
E-mail: iim.smith~monsanto.com
) U.S. Mail
( ) Facsimile
) Overnight Delivery
) Hand Delivery
J/\1 Emai1 Only
ROCKY MOUNTAIN POWER'S FIRST Page 7
SET OF DATA REQUESTS TO AGRIUM
Randall C. Budge
Racine, Olson, Nye, Budge
& Bailey, Chtd.
O. Box 1391
Pocatello, Idaho 83204- 1391
Email: rcb~racinelaw.net
Attorneys for Monsanto Company
) U.S. Mail
) Facsimile
( ) Overnight Delivery
( J Hand Deli very
(X Email
Maurice Brubaker
Katie Iverson
Brubaker & Associates
17244 W. Cordova Court
Surprise, AZ 85387
Email: mbrubaker~consu1tbai.com
ki verson(2V,consultbai.com
Consultant for Monsanto Company
( J u.S. Mail
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Eric L. Olsen
Racine, Olson, Nye, Budge
& Bailey, Chtd.
201 E. Center
O. Box 1391
Pocatello, Idaho 83204-1391
Email: elo((i)xacine1aw.net
Attorneys for Idaho Irrigation Pumpers Association, Inc.
( J U.S. Mail
( J Facsimile
J Overnight Delivery
~ J, Hand Delivery
'D\J Email
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
E-mail: tony~!yanke I.net
Consultant for Idaho Irrigation Pumpers
Association, Inc.
( J u.S. Mail
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Email
Idaho Irrigation Pumpers
Association, Inc.
c/o Lynn Tominaga
O. Box 2624
Boise, ill 83701-2624
E-mail: Ivnn tominaga(alhotmai 1.com
( J U.S. Mail
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Email
Tim Buller
Agrium, Inc.
3010 Conda Road
Soda Springs, Idaho 83276
E-mail: tbuller((l!agrium.com
J U.S. Mail
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Email
ROCKY MOUNTAIN POWER'S FIRST Page 8
SET OF DATA REQUESTS TO AGRIUM
Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
608 W. Bannock Street
P. O. Box 2720
Boise, ill 83701-2720
E-mail: cew((u,givenspurslev.com
Attorneys for Agrium, Inc.
( J u.S. Mail
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Email
Dennis Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S, Ste. 250
Salem, OR 97302
E-mail: dpeseau~excite.com
Consultant for Agrium, Inc.
( J u.S. Mail
) Facsimile
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Email
Brad M. Purdy
Attorney at Law
20l9 N. 17th Street
Boise, ill 83702
Email: bmpurdy~hotmail.com
Attorneys for Community Action
Partnership Association of Idaho
( J u.S. Mail
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(X! Email
Kevin B. Homer, Esq.
1565 South Boulevard
Idaho Falls, ill 83404
Email: kbh~khomerlaw.com
Attorney for Timothy Shurtz
Tim Shurtz
411 S. Main
Firth, Idaho 83236
Email: tim((i~idahosupreme.com
( J U.S. Mail
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ROCKY MOUNTAIN POWER'S FIRST Page 9
SET OF DATA REQUESTS TO AGRIUM