20071018Agrium to PAC 1-7.pdf

GIVE PSLEY LLP
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G. Andrew Page
Angela M. Reed
Scott A. Tschirgi, LLM.
J. Will Varin
Coniey E. Ward
Robert B. White
Terri R. Yost
October 18 , 2007
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Via Hand Delivery
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington
O. Box 83720
Boise, ill 83720-0074
Re:
Our File:
In the Matter of the Application of Pacificorp DBA Rocky Mountain
Power for Approval of Changes to its Electric Service Schedules -
Case No.: PAC-07-
7160-
Dear Jean:
Enclosed for filing are an original and two (2) copies of Agrium s Responses to
Rocky Mountain Power s First Set of Data Requests, together with two (2) disks
containing the requested data in connection with the above entitled matter.
Thank you for your assistance in this matter.
=tn.ad~
Tina M. Adometto
Assistant to Conley Ward
/tmacc: Service List (w/enclosures)
S:\CLIENTS\7160\3\CEW to Jewell re 1st set of Data Requests.DOC
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Conley E. Ward (ISB No. 1683)
GIVENS PURSLEY LLP
601 W. Bannock Street
P. O. Box 2720
Boise, ID 83701-2720
Telephone No. [phone]
Fax No. [phone]
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Attorneys for Agrium Inc.
S:\CLlENTS\7160\3\Data RequestsDOC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF P ACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL OF CHANGES TO
ITS ELECTRIC SERVICE SCHEDULES
Case No. PAC-07-
AGRIUM'S RESPONSES TO ROCKY
MOUNTAIN POWER'S FIRST SET OF
DATA REQUESTS
Agrium hereby responds to Rocky Mountain Power s first set of data requests in the
above entitled matter. All responses were prepared by Dennis Peseau in consultation with
Agrium s Counsel, Conley Ward.
AGRIUM'S RESPONSES TO 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.
Response: The requested information is on the attached disk.
AGRlUM S RESPONSE To FIRST SET OF DATA REQUESTS-
Dennis Peseau. Are the alternate demand cost allocations you propose in this
case (1 CP, 3 CP and "3 Sum-l Win ), allocation proposals you have recommended in other
cases where you have filed prefiled written testimony? If yes, please identify each proceeding and
provide a description of the comments that were filed in response to your testimony 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.
Response: Agrium objects to this question as overbroad and unreasonably burdensome.
Without waiving this objection, Agrium states as follows: All previous Peseau testimony on
demand cost allocation has supported peak month allocators, but the exact methodology varies
by company and jurisdiction. See, for example, Idaho Case Nos. U-I006-1006, U-I006-265A
IPC-03-13. Also see Docket Nos. 91-5055 91-7079 92-1067 93-11045 01-10001 , and 03-
10001 in Nevada. Also see Formal Case No. 905 PSC District of Columbia and Case No. 8315
PSC of Maryland. The requested information can be acquired by reviewing these cases on the
internet.
AGRlUM'S RESPONSE To FIRST SET OF DATA REQUESTS - 2
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?
Response: I made no attempt to identify each and every cost increase and cost decrease
for the company s filing pertaining to 2007, other than its significant filed costs for major plant
additions, and for power cost increases for reasons stated at lines 8-, page 5 of my testimony.
To do so would require construction of a future test year, which I generally oppose.
AGRIUM'S RESPONSE To FIRST SET OF DATA REQUESTS - 3
Dennis Peseau . Please provide work papers and any other supporting
documentation for Exhibit 405.
Response : Please see the attached disk.
AGRIUM'S RESPONSE To FIRST SET OF DATA REQUESTS - 4
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.
Response: It is my understanding that known and measurable adjustments are required
to be just and reasonable. I am not aware of any Idaho Commission disallowance of known and
measurable changes that we are also determined to be just and reasonable.
AGRIUM S RESPONSE To FIRST SET OF DATA REQUESTS - 5
Dennis Peseau . Please confirm whether you agree that Idaho law permits
known and measurable adjustments when setting utility rates. Please explain your answer.
Response:The answer is yes, if the known and measurable changes are just and
reasonable.
AGRlUM'S RESPONSE To FIRST SET OF DATA REQUESTS - 6
Please produce any and all documents that Agrium expects or reasonably
anticipates introducing into evidence at hearing in the above-captioned docket.
Response: Agrium has not yet prepared such documents.
DATED this J (6 day of October, 2007.
AGRlUM'S RESPONSE To FIRST SET OF DATA REQUESTS - 7
CERTIFICATE OF SERVICE
I/)~I HEREBY CERTIFY that on thIS --li1- day of October, 2007, I caused to be served a
true and correct copy of the foregoing by the method indicated below, and addressed to the
following:
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, ID 83720-0074
US. Mail
Hand Delivered
Overnight Mail
Facsimile
Mail
Brian Dickman
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
email: brian.dickman((i;pacificorp.com
US. Mail
Hand Delivered
Overnight Mail
Facsimile
Mail
Dean Brockbank
Justin Brown
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
email: dcan.brockbank~pacificorp.com
J ustin.brown(ci;parificorp .com
S. Mail
Hand Delivered
Overnight Mail
Facsimile
Mail
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey
201 East Center, Suite A2
O. Box 1391
Pocatello, ID 83204-1391
email: rcb~racinclaw.net
US. Mail
Hand Delivered
Overnight Mail
Facsimile
Mail
James R. Smith
Monsanto Company
O. Box 816
Soda Springs , ID 83276
email: i im.r.smith(a)monsanto.com
US. Mail
Hand Delivered
Overnight Mail
Facsimile
Mail
AGRIUM'S RESPONSE To FIRST SET OF DATA REQUESTS - 8
Maurice Brubaker
Katie Iverson
Brubaker & Associates
1215 Fern Ridge Parkway, Suite 208
St. Louis, MI 63141
email: mbrubakerccvconsultbai.com
ki v erson((l)consul tbai. com
US. Mail
Hand Delivered
Overnight Mail
Facsimile
Mail
AGRIlJM'S RESPONSE To FIRST SET OF DATA REQUESTS - 9