20071023Monsanto to PAC 1-37.pdf

Jean Jewell, Secretary
Idaho Public Utilities Commission
Attn: Xan Allen
472 W. Washington Street
Boise, Idaho 83702
LOUIS F. RACINE "917-2005)
WILLIAM D. OLSON
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL'
JOHN B. INGELSTROMDANIEL 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'"
Dear Mrs. Jewel:
LAW OFFICES OF
RACINE OLSON NYE BUDGE & BAILEY
CHARTERED
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 20B
BOISE, IDAHO 83702TELEPHONE: [phone]
FACSIMILE: [phone]
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone] IDAHO FALLS OFFICE
www.racinelaw.net
477 SHOUP AVENUE
SUITE 203A
IDAHO FALLS, 10 83402
TELEPHONE: (208) 52B-81 0 I
FACSIMILE: (208) 528-610e
SENDER'S E-MAIL ADDRESS: rcbrgJraclnelaw.net '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
t"';'c;:"co
October 22 , 2007
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Re:PAC-O7-
Enclosed please find the original and three copies of Monsanto Company s Responses to
Rocky Mountain Power s First Set of Data Requests. Included is a CD marked "CONFIDENTIAL"
which contains that portion of Monsanto s Responses to Data Request Nos. 14 and 17, identified as
confidential , which are only being made available to Pacificorp and those staff members who
executed the Confidentiality Agreement.
RCB:sab
Enclosures
Sincerely,
'F~ RANDALL C. BUDGE
F~ECE;
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]
lUll OCT Ri,; o. chi' .1-
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ORIGiNAL
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-O7-
MONSANTO COMPANY'S RESPONSES TO
ROCKY MOUNT AIN POWER'S FIRST SET OF DATA REQUESTS
Pursuant to Rule 228 of the Idaho Public Utilities Commission Rules of Procedure
Monsanto Company ("Monsanto ), by and through its counsel, submits the attached Responses
to Rocky Mountain Power s First Set of Data Requests dated October 9, 2007.
Daniel R. Schettler. Please provide documentation or citation to an agreement
with the Company that Monsanto relies upon in support of its contention that future price
increases from Rocky Mountain Power would be based on increases in its operating costs
incurred after January 1 , 2007.
RESPONSE:As a result of Monsanto s rate increase effective January 1 , 2007
PacifiCorp stated that "the proposed revenue increase would allow PacifiCorp the opportunity to
earn a fair rate of return in its Idaho jurisdiction." Case No. PAC-064-, Larsen Direct, p. 8.
Mr. Larsen further stated that the terms and conditions of the 2006 Stipulation produce "rates
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS-
that are just and reasonable . Larsen Direct, page 11. Consequently, since Monsanto s "just and
reasonable" rates allowed the Company the opportunity to earn a fair rate of return as of January
, 2007, the witness drew the reasonable conclusion that only cost increases after this time period
would affect future price increases.
Daniel R. Schettler. Please define the terms reliable, predictable and affordable as
those terms appear on page 16 of your pre filed direct testimony.
RESPONSE: These are commonly defined terms and self-explanatory as used in Mr.
Schettler s testimony. Normal meanings are ascribed to these terms. Specifically, "reliable
predictable and affordable" means that Monsanto has confidence that PacifiCorp will provide
power under the terms of the 2007 Agreement, together with Monsanto being able to reasonably
anticipate price increases and to effectively compete in its markets.
Daniel R. Schettler. Please identify all facts relied upon by you for your assertion
on page 15 of your prefiled direct testimony that the Company was not negotiating in good faith
with respect to the contract negotiations for the 2007 contract.
RESPONSE: One of the reasons cited by PacifiCorp for the proposed $11.7 million
increase to Monsanto in this case was that the "$6.8 million increase the customer agreed to in
Case No. P AC-06-04 recovered less than half of the $14.3 million dollar shortfall the
Company s cost of service showed at that time.Direct Testimony of Mark Tucker, p. 7
emphasis added. The facts though show PacifiCorp testified in its request for approval of the
2007 contract that the proposed rates were "just and reasonable" and that "the proposed revenue
increase would allow PacifiCorp the opportunity to earn a fair rate of return in its Idaho
jurisdiction." The Commission s approval of the 2007 contract further confirms that the new
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS - 2
effective rates were "fair, just and reasonable and in the public interest." Case No. P AC-06-
, Order No. 30199 , p. 9 Furthermore, the Order states that in Commission Staffs view "the
give and take involved in the proposed 2006 Settlement is unusual in that the three customer
classes whose rates are farthest below cost of service have agreed to substantial rate increases
and the Company appears to forego advocating for all that it could"Order No. 30199, p. 4
emphasis added. Thus, the facts are clear that PacifiCorp claimed the 2007 rates were "just and
reasonable" during the negotiations and subsequent application to the Commission, only to turn
around and seek recovery of the additional $7.5 million ($14.3 million less $6.8 million) in this
case. Had PacifiCorp negotiated the 2007 contract in good faith, it would not be trying to now
recover costs of serving Monsanto incurred prior to the effective data of the 2007 contract.
James Smith. Please identify all phosphorus producers that you are aware of that
use non-electric furnaces.
RESPONSE: The witness is not aware of any technology or operation that would allow
one to produce "Phosphorus" (P4) without electric furnaces.
James Smith. Please provide copies of all documentation relied upon or that
reasonably relates to your contention on page 18 of your prefiled direct testimony that Monsanto
is committed to spending millions of dollars on projects at the Soda Springs plant.
RESPONSE: Monsanto objects to this data request on the grounds that the specific
nature of the documents requested would require disclosure of future capital expenditures
budget and planning information that is proprietary and confidential to Monsanto s business and
competitive interests, irrelevant to the issues presented in this case and not likely to lead to
relevant discoverable information.
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS - 3
James Smith. Please confirm that the reference of 21.4% on line 1 , page 20 of
your prefiled direct testimony is a typographical error that should read 24.1 %.
RESPONSE: Yes, this was a typographical error and should read 24.1 %
J ames Smith. Please identify all facts and documentation relied upon by you for
your assertion on page 16 of your prefiled direct testimony that Monsanto believed that its rate
increase for 2007 rates effectively brought Monsanto to a rate that was "fair, just and reasonable
at or near true cost of service and fairly valuing interruptibility.
RESPONSE: See Monsanto Response to Data Request No.1 and No.3 above.
James Smith.Please provide copies of all notes, presentations, or other
documentation used, referred to, or relied upon in Monsanto s meeting with community leaders
and suppliers as alleged on page 22 of your prefiled direct testimony. Please also identify who
Monsanto met with, where and when the meetings occurred.
RESPONSE: No notes, presentations or documents were used, referred to or relied
upon, other than the Application and other documents which are part of the filing and record in
this proceeding. The exact time and location of each meeting is unknown and no notes or
records were taken. Generally, communications were by phone or in person in Soda Springs or
at the plant responding to inquiries from public officials, suppliers, employees and other citizens
that had read news articles in the Caribou County Sun based upon information provided by
PacifiCorp or the Commission and were expressing concern of the magnitude of the proposed
increase to Monsanto s rates and the impact such an increase might have on the future viability
of the plant. From memory the witness had communications with the following persons:
Vaughn Rasmussen, PacifiCorp/Bear Lake County Commissioner
Mitch Hart, Soda Springs City Council
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS - 4
Boyce Barnes, BJ Barnes Trucking
Rod Eike, SGL Carbon
Earl Somsen, Caribou County Commissioner
Clayton Krall, Washington Group International
F erril Beins, Mark III
Kevin Keller, PPS
Nancy Keller, PPS
Wayne Perkins, Perks Electric
Randy Czikal, Oxbow Carbon
Jon Goode, Agrium Inc. and the Hospital Board
Troy Nielsen, Heritage Safe
Wade Clark, Alexander Company
Terry Andersen, Sander s Furniture
Robert Moyle, AR W Engineers
Lorrin Rasmussen, Atlas Mechanical
Casey Standley, Ferguson
Molly Stein, School Superintendent
Linda Lee, Soda Springs City Counsel
Mark Dooley, School board trustee
Jim Stoor, School board trustee
Mark Steel, Caribou County Sun
Randy Griffith, Chemical Lime
Kathryn E. Iverson. Please identify all circumstances that you are aware of where
Monsanto would not comply with a curtailment request from Rocky Mountain Power?
RESPONSE: It is the witness s understanding that if Rocky Mountain Power were to
request curtailments that are above and beyond those specified in the contract, Monsanto would
not be obligated to comply with the request unless additional arrangements had been agreed to
by the parties.
10.Kathryn E. Iverson. You testify that the Company should value Monsanto
curtailment based upon the long-run avoided costs. Can Monsanto guarantee that the Soda
Springs plant will remain in operation for the next 15 , 20, 30 or 35 years? If not, how can the
Company reasonably plan on Monsanto s curtailment as a long-term resource?
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS - 5
RESPONSE: In economic terms, long-run costs are those that recognize that all factors
of production (i., capital facilities, fuel, etc.) can be varied. The avoided costs used in the
witness s analysis are based on those costs found in the Company s 2007 IRP which are first-
year real levelized costs which represent the costs associated with deferral of a plant for one
year.In contrast, the first year revenue requirement of a plant coming on-line would be
substantially higher under traditional utility accounting as the revenue requirement would be
based on a return applied to the full undepreciated cost of the facility. Thus, first-year real
levelized costs do not assume 15 , 20, 30 or 35 years of operation. Even so, it is the witness
understanding that Monsanto s intent is to remain in operation given a reasonable and stable cost
of energy. Further, Monsanto has been a customer for more than 50 years pursuant to special
contracts all of which provided for load interruptions and it is the witness s understanding that
Monsanto contemplates continuing to be a long-term interruptible customer in the future.
11.Kathryn E. Iverson. Please confirm whether the amount used for the SO2 sales
adjustment illustrated in Exhibit 210 (KEI-6), and proposed by Monsanto witness Mr. Gorman
included a rate base offset component?
RESPONSE: Yes, the amount used for the SO2 sales adjustment included a rate base
offset component. See Exhibit 215 (MPG-
12.Kathryn E. Iverson.Please provide copIes of all work papers, analyses
documents , calculations, and other material relied upon or that you anticipate relying upon in
support of your Exhibit 208 (KEI-4), Adjustments in Load to Align with JAM Study.
RESPONSE: Please see the attached Excel spreadsheets: "Exhibit 206, 207, 208. xis
and "Table 3 Idaho COS (9.6 with Alignment).xls
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS - 6
13.Kathryn E. Iverson.Please provide copies of all work papers, analyses
documents, calculations, and other material relied upon or that you anticipate relying upon in
support of your Exhibit 209 (KEI-5), Allocation of Revenue Reduction as a Result of the Rate
Mitigation Cap.
RESPONSE:See the attached Excel spreadsheets "Exhibit 209.xls" and "Exhibit
210.xls
14.Kathryn E. Iverson.Please provide copIes of all work papers, analyses
documents, calculations, and other material relied upon or that you anticipate relying upon in
support of your Exhibit 211 (KEI- 7) - Exhibit 213 (KEI-9), regarding valuation of Monsanto
interruptibility.
RESPONSE: Please see the attached Excel spreadsheets: "Exhibit 211 , 212.xls" and
Exhibit 213 REDACTED.xls . Also, see Attachment 14 for reference on paper footnoted on
page 40 of the witness s Direct Testimony. In addition, the following workpaper is provided as a
confidential attachment. This information is confidential and is provided subject to the terms
and conditions of the protective order in this proceeding: "Exhibit 213 CONFIDENTIALxls.
15.Kathryn E. Iverson. Please identify all characteristics that you rely upon
support of your contention that the Company treats the Monsanto load curtailment like a
combustion turbine.
RESPONSE: See pages 24 and 25 of the witness s direct testimony for a discussion of
the characteristics.The notable characteristics include:(1) Addition of peaking capacity
increases overall reliability of Rocky Mountain Power to meet its customers ' demands.
Interruptible load defers capacity and so enables the Company to meet customer demand in
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS - 7
reliable manner. (2) Generation from peaking resources is able to displace high cost wholesale
purchases. Interruptible load similarly is able to displace wholesale purchases. (3) Peaking
resources have planned maintenance outages and forced outages. Monsanto works with Rocky
Mountain Power to coordinate its planned maintenance to provide the greatest benefit for the
system.(4)Peaking resources are available throughout the year, except for planned
maintenance and forced outages. Interruptible load is also available throughout the year.
16.Kathryn E. Iverson. Please identify all characteristics that you are aware of that
distinguish the Company s treatment of Monsanto s load curtailment from its use of a
combustion turbine.
RESPONSE: Unlike a combustion turbine that is added to the Company s rate base and
depreciated over time, Rocky Mountain Power values interruptible load on the basis of wholesale
prices either avoided, or in the case of operating reserves, the additional profits.
17.Kathryn E. Iverson.Please provide copies of all work papers, analyses
documents, and other material relied upon or that you anticipate relying upon in support
(including electronic files with active formulas) of your Monsanto curtailment recommendation.
RESPONSE:Please see the attached Excel spreadsheets:GRID Reserves EC
09.xls" and "Exhibit 213 REDACTED.xls" Note that in Monsanto s GRID model runs, we
could not match Rocky Mountain Power s costs for the year 2008, however, we were able to
match the amounts for year 2009.The following workpaper is provided as a confidential
attachment. This information is confidential and is provided subject to the terms and conditions
of the protective order in this proceeding: "CONFIDENTIAL WP on Operating Reserves.pdf'
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS - 8
18.Kathryn E. Iverson. Given the Company s current generation portfolio, should
Monsanto be paid any more for providing power through curtailing its load than the cost the
Company would incur by providing that same power by utilizing its current generation portfolio?
RESPONSE: According to page 68 of the 2007 IRP
, "
In 2007 PacifiCorp owns, or has
interest in resources with a system peak capacity of 12 131 megawatts." As an interruptible
customer, Monsanto is included in the interruptible load comprising 1.9% of the total 12 131
MW capacity and so should be considered an integral part of PacifiCorp s current generation
portfolio. Since Monsanto s interruptible rate is set in a general rate case, there is no "payment"
for power. Ms. Iverson s treatment of the valuation of Monsanto s interruptibility is found in
Section V of her Direct Testimony.
19.Kathryn E. Iverson.Please explain, in your OpInIOn, the difference, if any,
between a firm WSPP Schedule C market purchase of power, power generated by a Company
owned resource, and power supplied by Monsanto by curtailing load.
RESPONSE: The question is unclear as to what type of difference (cost, reliability,
quality, length of contract, availability, etc.) is sought. WSPP Schedule C market purchases of
power are typically short-term and terms are negotiated between parties. Power generated by a
Company owned resource may be unavailable due to maintenance or forced outage, and its
variable cost may fluctuate due to rising fuel costs. In contrast, the cost for curtailment of
Monsanto load is a sunk cost as the result of the 2007 contract.
20.Kathryn E. Iverson.Please provide any analysis or work papers supporting
Monsanto s claim that an aero-derivative simple cycle combustion turbine is the most cost
effective method to provide operation reserves.
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS - 9
RESPONSE: Combustion turbines typically have the lowest capital cost to install and
the shortest construction time frame, and when units can start and reach full load in less than 10
minutes, can provide ancillary services in the form of operating reserves.F or details
alternative resource costs, see PacifiCorp s 2007 IRP.
21.Kathryn E. Iverson. Please provide a list comparing the number of hours an aero-
derivative simple cycle combustion turbine is available to operate in a typical year to the total
number of hours Monsanto is willing to curtail all three furnaces in a typical year.
RESPONSE: This question seeks to compare "availability" to "hours of operation
which is an inconsistent comparison. However, it should be noted that except for periods of
planned maintenance or forced outage, a SCCT is available all hours of the year, and is expected
to be run during heavy load hours. Monsanto s curtailment is also available all hours of the year
and can be called upon in conformity to the 2007 contract.
22.Kathryn E. Iverson.Please provide the benefit to customers for Monsanto
receiving credit for "avoiding capacity" if the Company already owns sufficient capacity to meet
load and operating reserve requirements.
RESPONSE: See Response to Data Request 18. Monsanto is considered a resource
within PacifiCorp s current generation portfolio and as such, the value of its interruptibility
should continue to be reflected in Monsanto s interruptible rates. Interruptible loads defer the
need for additional peaking resources even during times the utility may be in load/resource
balance. Furthermore, this data request begs the obvious question: ifthe Company already owns
sufficient capacity to meet load and operating reserve requirements, then why is it seeking to add
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS -
some $38 million of production rate base to the Idaho jurisdiction?Consequently, the
hypothetical posited in this request is not valid in light of these capacity additions.
23.Kathryn E. Iverson.Please provide the benefit to customers for Monsanto
receiving credit for "avoiding capacity" if the Company can obtain the same type of capacity and
energy product through the market at costs that are less than those incurred by building and
operating new capacity.
RESPONSE: Unlike the purchase of energy from the wholesale market during heavy
load hours, PacifiCorp has never demonstrated that it can buy operating reserves from the
market. To the contrary, PacifiCorp testified in Case No. PAC-01-16 that in the case of
operating reserves, the Company prices the product based on "not holding them on our own
facilities.Rebuttal Testimony of Stan Watters, page 2 , line 16. Consequently, this question
pre-supposes that a market exists for the services provided by Monsanto s interruptibility, when
in reality, no such market exists. Furthermore, PacifiCorp s continued building and operating of
new capacity also substantiates that these services are not available in the market. For example
PacifiCorp brought on-line the 120 MW peaking resource Gadsby in 2002 at a cost of $75
million. This resource provides ancillary services in the form of operating reserves.
24.Kathryn E. Iverson.Please explain how customers benefit from retaining
interruptible contracts at costs that are higher than those incurred by the customers to obtain the
same products elsewhere.
RESPONSE: See Response to Data Request 23.
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS -
25.Michael Gorman.Please confirm whether you agree with the Idaho Public
Utilities Commission Staffs adjustment related to the Company s 2007 plant additions? If not
please explain why.
RESPONSE:Mr. Gorman has not yet completed his reVIew of the Staff s filing.
However, his position on 2007 plant additions is described in his Volume 1 direct testimony at
12-14.
26.Michael Gorman.Please confirm whether you agree that Idaho law permits
known and measurable adjustments when setting utility rates. Please explain your answer.
RESPONSE: Monsanto objects to this data request on the grounds that it calls for legal
conclusions and analyses that are beyond the scope of proper discovery. Without waiving this
objection, Monsanto responds that it is Mr. Gorman s understanding that Idaho law allows for
known and measurable changes to cost of service including cost increases and decreases.
27.Michael Gorman. Exhibit 220 (MPG- 7) reverses the 2007 plant additions and
accumulated deferred income taxes from McDougal Exhibit 11 page 8., but does not reverse the
schedule M or deferred income tax adjustments associated with the same plant on page 8.
Please explain why you did not include these tax items in your adjustment?
RESPONSE: Mr. Gorman agrees that the deferred income tax related to the 2007 plant
additions should also be removed from the final revenue requirement if Mr. Gorman s 2007 plant
addition adjustment is approved.
28.Michael Gorman.Please confirm whether you agree with the Idaho Public
Utilities Commission Staff s position to disallow only those severance costs that exceed the
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS -
amount of the lower of the actual amount paid or the savings realized. If you do not, please
explain your response.
RESPONSE: Mr. Gorman s position concerning severance costs is described in his
direct testimony at 5-8. Mr. Gorman does not agree that costs incurred before RMP requested
authority to defer severance costs should be included in the deferral balance and subject to
recovery in a rate case.
29.Michael Gorman. Please provide copies of all work papers, analyses, documents
and other material relied upon or that you anticipate relying upon in support (including electronic
files with active formulas) of your return on equity recommendations.
RESPONSE: Please see Attachment 29 which contains Mr. Gorman s workpapers.
30.What is the maximum number of hours Monsanto is willing to curtail each year?
Please provide how many furnaces will be curtailed for the number of hours provided.
RESPONSE: See the Direct Testimony of Dan Schettler at page 12, line 17
31.What is the maximum number of consecutive hours Monsanto is willing to curtail
three furnaces? Two furnaces? One furnace?
RESPONSE: See the Direct Testimony of Dan Schettler at page 12, line 17.
32.For each of Monsanto s three furnaces , please provide the market value of the
product produced by the furnace in a typical hour of operation.
RESPONSE: Monsanto objects to this data request on the grounds that the information
is irrelevant to the issues presented, will not likely lead to any relevant or admissible evidence
relating to Rocky Mountain Power s application for an increase in rates , and is proprietary and
confidential information.
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS -
33.Please provide details regarding the ability of Monsanto s furnaces to operate at
different levels. For comparison purposes, please provide ramp rates, minimum run times, and
other data similar to that which is available for a combustion turbine.
RESPONSE: The 2007 Electric Service Agreement between Monsanto and PacifiCorp
addresses the availability and hours of interruption associated with the three furnaces. Each
furnace is able to operate in compliance with the requirements specified in the Electric Service
Agreement.
34.Please provide all facts and documentation that supports the proposition that the
market price during a double contingency event (as described in the current Monsanto
agreement) will equal or exceed $250 per MWh.
RESPONSE:First, the value for system emergency is not necessarily tied to any
particular market price, but rather to the value PacifiCorp has placed on Monsanto agreeing to be
the first off the system before other retail customers.It is an insurance policy to restore
reliability to the system without affecting other retail customers.Second, the double-
contingency language included in the 2007 Electric Service Agreement was meant only to
clarify the event, and not to limit the valuation of this particular component of Monsanto
interruptible resource. Third, in Case No. PAC-01-, PacifiCorp analyzed the value of
interrupting Monsanto s total furnace load for system integrity purposes.That entailed
Monsanto being first off the system before other retail customers. The value to PacifiCorp for
that option was $486 000 per year (162 000 kW x 12 hours x $250). Since there has been no
change in the availability of system integrity, the value of having Monsanto agree to be the first
off should remain at least as high as it was valued in 2003.
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS. 14
35.Is Monsanto willing to enter into a 30 year contract to provide curtailment
products? If yes, is Monsanto willing to agree to liquidated damages and credit requirements
similar to those required in typical power purchase supply agreement entered into by the
Company?
RESPONSE:Monsanto has always desired a long-term contract in order to have
reliable, predictable and affordable power for Soda Springs to remain viable. See Monsanto
Responses to Data Request No.2 and No.1 O.
36.Please provide all Monsanto s quantitative analysis, dating from 2003 to 2007, on
the value of its interruptibility.
RESPONSE: Monsanto objects to this data request on the grounds that these documents
are attorney-client privilege and were prepared during confidential contract negotiations in 2005
and 2006. Other than the valuations presented in Ms. Iverson s testimony, and those valuations
during the 2005-2006 contract negations, there are no quantitative analysis.
37.Please produce any and all documents that Monsanto expects or reasonably
anticipates introducing into evidence at hearing in the above-captioned docket.
RESPONSE: Monsanto intends to introduce into evidence the testimony and exhibits of
Monsanto s witnesses. Monsanto has not yet identified all documents it may seek to introduce
into evidence and reserves the right to present additional documents into evidence at the hearing.
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS -
DATED this day of October, 2007.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
For
-y/.
RANDALL C. BUDGE
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS -
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this Z- day of October, 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
Justin Brown
Brian Dickman
PacifiCorp/dba Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
bri an. di ckman~pacifi corp. com
J ustin. brown~pacificorp .com
Via Overnight Delivery
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Fax: [phone]
datareq uest~ pac i fi corp. com Mail
Maurice Brubaker
Katie Iverson
Brubaker & Associates, Inc.
1215 Fern Ridge Parkway, Suite 208
St. Louis, MO 63141
m brubaker~consultbai. com
ki verson~c6ns ul tbai. co m
Mail
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, Idaho 83276
iim.smith~monsanto.com Mail
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
O. Box 1391
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS .
Pocatello, Idaho 83204-1391
elo(fYxacinelaw.net
Mail
Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
cew~gi venspursley .com Mail
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S., Ste. 250
Salem, OR 97302
dpeseau~excite.com Mail
Katherine A.McDowell
McDowell & Rackner
520 Southwest Sixth Ave. Ste. 830
Portland, OR 97204
katherine~mcd -law .com Mail
Scott Woodbury
Neil Price
Deputy Attorneys General
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, ID 83720-0074
scott. woodbury~puc.idaho. gov
neil. price~puc. idaho. gov Via Overnight Delivery
Randall C. Budge
Racine Olson Nye Budge & Bailey
201 E. Center
O. Box 1391
Pocatello, ID 83204-1391
rc b~racinelaw .net Mail
Brad M. Purdy
Attorney at Law
2019 N. 1 ih Street
Boise, ID 83702
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS -
bmpurdy~hotmail.com Mail
Kevin B. Homer
Attorney at Law
1565 South Boulevard
Idaho Falls, ID 83404
kbh(fYkhomerlaw.com Mail
Timothy Shurtz
411 S. Main
Firth, ID 83236
tim~idahosupreme.com Mail
-- /~.
RANDALL C. BUDGE c:Y
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S FIRST DATA REQUESTS -