20100617IIPA 1-53 to PAC.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTEREDW. 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
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
LANE V. ERICKSON
DAVID E. ALEXANDER
PATRICK N. GEORGE
SCOTT J. SMITH
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN
BRENT L. WHITING
JONATHON S. BYINGTON
DAVE BAGLEY
CAROL T1PPI VOLYN
THOMAS J. BUDGE
CANDICE M. MCHUGH
JONATHAN M. VOLYN
MARK A. SHAFFER
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. PACE-E-IO-07
Dear Ms. Jewell:
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
ww.racinelaw.net
SENDER'S E-MAIL ADDREss:elo\Qracinelaw.net
June 15,2010
BOISE OFFICE
t01 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702
TELEPHONE: [phone]FACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUESUITE 203A
IDAHO FALLS, ID 83402
TELEPHONE: (208) 528"'6101
FACSIMILE: (208) 528-6'109
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE tOSA
COEUR D'ALENE, ID 83814TELEPHONE: [phone]
ALL OFFICES TOLL FREE
[phone]
LOUIS F. RACINE (1917-2005)
D. OLSON. OF COUNSEL~~~
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Enclosed for fiing in the captioned matter, please find the original and thee copies of Idaho
Irrigation Pumpers Association, Inc. 's First Data Requests to Rocky Mountain Power Company.
ELO:rg
Enclosures
cc: Service List
li
Eric L. Olsen ISB# 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
o
2010 JUNI7 Al1 8: 08
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR )
APPROVAL OF CHANGES TO ITS )
ELECTRIC SERVICE SCHEDULE AND A )
PRICE INCREASE OF $27.7 MILLION OR )
APPROXIMATELY 13.7 PERCENT )
)
)
CASE NO. PAC-E-I0-07
IDAHO IRRGATION PUMPERS
ASSOCIATION, INC.'S FIRST
DATA REQUEST TO
PACIFICORP
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC'S FIRST DATE REQUESTS
TO ROCKY MOUNTAIN POWER COMPANY
IDAHO IRRGATION PUMPERS ASSOCIATION, INC. ("IIPA"), by and
through its attorneys, hereby submits this First Data Requests to Rocky Mountain Power
Company ("RMPC"), pursuant to Rule 225 of the Idaho Public Utility Commission's
Rules of Procedure, IDAPA 31.01.01, as follows:
1. Please answer the following with respect to information contained on McDougal's
Exhibit 2, Tab 10 entitled "Allocation Factors":
A. On pages 10.13 though 10.18, are these actual generation level energy and
demand values recorded for each jursdiction during each of the months
specified? If not, please provide the actual values.
B. Do the demand values on page 10.13 for Idaho include Monsanto load that has
been interrpted?
C. Are the values/adjustments on page 10.13 through 10.18 simply weather related
adjustments? If these adjustments are more than simply weather related
adjustments, please provide a breakdown of these values that relate to weather
adjustments and those that relate to other adjustments (please provide specific
detail for each "other" adjustment).
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 1
D. Are the demand and energy values on pages 10.13 though 10.18 the ones used to
form the basis for such system allocators as SC and SE?
E. For each ofthe adjustments listed on pages 10.13 and 10.14, how are these
adjustments reflected by rate schedules or special contract customer consumptions
in each month?
F. Please provide an electronic as well as hard copy of all workpapers that support
the calculations on Tab 10.
G. Please provide an electronic copy of all workpapers and/or calculations that
support the adjustments to actual values for both demand and energy for each
jursdiction listed in Tab 10.
2. Please answer the following with respect to information contained on Paice's Exhibit
49, Tab 5 "Cost of Service Allocation Factors":
A. Are the times of the system peaks listed on page 6 the same as the actual
coincident system peaks during each of those months?
B. Are the times listed on page 6 on Pacific or Mountain time?
C. How do the total jurisdictional values for each month on page 6 relate to the Idaho
values on McDougal's Exhibit 2, Tab 1O?
D. With respect to the data listed on pages 7 and 12, which data came from the
Company's load research data and which data came from census data? Iffrom
load research data, over what timeframe was the data collected? If the data came
from load research data, but was adjusted, please provide an electronic copy of all
workpapers and/or calculations that support the adjustments to actual values.
E. With respect to the data listed on page 13, which data came from the Company's
load research data and which data came from biling data? If the data came from
biliing data, but was adjusted, please provide an electronic copy of all
workpapers and/or calculations that support the adjustments to actual values.
F. What was the level of curtilment/interrption for each customer class or
Monsanto durng the times of each of the monthly peaks listed on page 7? (Please
specify at input leveL.)
G. Is there any weather normalization of the Distribution Peak data on page 12 or the
Non-Coincident Peak data on page 13? If this data is weather normalized, please
provide an electronic as well as hard copy of all workpapers used to support this
normalization.
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNTAI POWER COMPAN 2
3. With respect to the Company's Load Research data, please provide for each sample
customer with valid data that was sampled between Januar 2007 and the most recent
month available the following:
A. Customer identification number;
B. Customer rate schedule;
C. Strata to which it belongs and weighting factors of each strata;
D. Raw hourly usage data (i.e., unadjusted, simply the data originally gathered for
each sample);
E. Raw hourly usage data modified to reflect losses;
F. On an hourly basis, any additional calibrations that are applied to the Load
Research data before it is applied to develop the allocation factors used in the
Company's cost of service study in this case.
G. Please provide copies of the formulas (and data) used to expand the Load
Research data up to the population as a whole as used in the class cost of service
study in this case. This information should include number of customers in the
population of each class.
4. Previously the Company developed hourly calibrations that calibrated the Load
Research data such that the sumation of the (population expanded) Load Research
data and the Census data equaled the Company's "Operations Stat" or border loads.
The Company may no longer be applying these calibrations to the Load Research
data, but the data is stil of interest. On an hourly basis from Janua 2007 through
the most recent month available, please provide:
A. The "Operations Stat" or border load for the Idaho Jurisdiction;
B. The summation of the (population expanded) Load Research data and the Census
data that would reflect what the Company measured or estimated as its internal
customer load for each rate schedule or customer group;
C. The hourly load for each rate schedule or special contract customer that is
measured or calculated on a census basis as opposed to using load research data;
D. Any other load that is contained in "a" above but is not addressed in "c" above
(please specify the type of load); and
E. Any information such as difference in measurng techniques or timing of the data
that needs to be addressed when comparng the above data.
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 3
5. Please provide for each month from Januar 2007 forward a copy of the results of all
checks that the Company makes regarding how well the load research data reflects
the actual population usage.
6. For the Irrgation load research samples, what is the range (kW or kWh) cut-off for
each stratum?
7. This fiing used weather-normalized data for developing allocation factors in the
jursdictional allocations and presumably the class cost-of-service study. For each
rate schedule, please provide all workpapers as well as a description of the flow
(manipulation) of data from historic load research or consensus data to projected test
year energy, coincident demands, and non-coincident demands. Please supply this
data in Excel format.
8. On Exhibit 2, page 10.13 there is a different coincident peak value for Idaho (406) for
Januar 2010 than the value used on Exhibit 49 pages 6 and 7. Please provide all
data, equations, and assumptions usea to develop the figure on both Exhibit 2 and
Exhibit 49. Please supply this data in Excel format. Explain how, if at all, the
jursdictional data from Exhibit 49 (pages 6 and 7) flows through or is incorporated in
Exhibit 2 Tab 10.
9. Please provide in electronic format for the period Januar 1,2007 through the most
recent month available hourly data similar to that provided in CCS Request 11 in
P AC-E-05-0 1.
10. Please provide in electronic format for the period Januar 1, 2007 though the most
recent month available, hourly Salt Lake City temperature data or other relevant data
that the Company uses to make weather normalization adjustments.
11. Please provide in electronic format a listing of the date, time, and estimated
magnitude of all actual hourly curtailments/interrptions that occured during 2008
through the most recent month available in Idaho separated by rate schedule or
special contract customer. If outright curailments/interrptions are treated differently
than "buy-throughs", please state each separately.
12. Please provide in electronic format a listing of the date, time, and estimated
magnitude of all actual hourly curtailments/interrptions that occured during 2008
through the most recent month available in each of the other jursdictions. If outright
curailments/interrptions are treated differently than "buy-thoughs", please state
each separately.
13. Please provide a copy or copies of the Company's Jurisdictional Allocation Model (in
a maner similar to that of Exhibit 2 Tabs 1, 2 and 10) stating the Idaho Jursdiction
without Monsanto and the Monsanto load as two separate jursdictions.
IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 4
14. Do the values in Exhibit 2, Tab 10, reflect Idaho demand and energy requirements by
assuming that there are no curtailments/interrptions to Monsanto? If
curailments/interrptions are assumed, what is the energy and demand impact of
each for each month of the test year?
15. Do the values in Exhibit 49, Tab 5, reflect Idaho demand and energy requirements by
assuming that there are no curailments/interrptions to Monsanto? If
curtailments/interrptions are assumed, what is the energy and demand impact of
each for each month of the test year?
16. With respect to Exhibit 49, Tab 5, page 7, please answer the following:
A. Are all of these values actual? If not, please provide and explanation of how they
were normalized and the workpapers that support the normalization.
B. What level of curailment of Schedule 10 load is reflected on line 23? Is this level
of curailment the same as occured in 2008 and 2009 or is expected to be
incurred in 201O?
C. What is the level of curilment that is reflected in each month on line 26 for the
Irrgation load?
17. Please explain how any revenue credits to Monsanto are addressed in this case in
relationship to Monsanto's inclusion/exclusion in/from the Idaho Jursdiction and
how Monsanto is treated in the class cost of service study.
18. For each rate schedule and special contract customer listed in Exhibit 50, for each
month of 2005 through the most recent month available, please list the amount of
energy consumed and the revenue collected.
19. For the year 2005--2009 list by FERC account the amount of Distribution plant that
is associated (allocated or directly assigned) with each jurisdiction.
20. For the year 2005--2009 list by FERC account the amount of Transmission plant that
is associated (allocated or directly assigned) with each jursdiction.
21. Beginning on page 5 line 22 of Mr. Eelkema's testimony there is a discussion
regarding the development of the company's models for sales per residential
customer:
a. Please provide in electronic format (Excel) the historical and/or projected
data/drvers used to develop the Residential modeL.
b. Was there a single model for the residential class, or a separate one for Schedule 1
and Schedule 36 customers? If only one model was ru, how was the projected
usage spread between the two rate schedules?
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO ROCKY MOUNTAI POWER COMPAN 5
c. For each of the last 20 years, what has been the actual sales per residential
customer, schedule 1 customer, and schedule 36 customer?
d. For each of the last 20 years, what has been the weather normalized sales per
residential customer, schedule 1 customer, and schedule 36 customer?
f. For each of the last 20 years, what has been the calculated/utilized HDD and CDD
data used by the Company for the Idaho jursdiction?
g. What are the test year weather normalized sales per residential customer, schedule
1 customer, and schedule 36 customer?
h. What does the company consider normal anual HDD and CDD values for its
Idaho service terrtory?
22. Beginning on page 6 line 8 of Mr. Eelkema's testimony there is a discussion
regarding the development ofthe company's models for sales per "other" customer
classes:
a. Please provide in electronic format (Excel) the historical and/or projected
data/drivers used to develop the Irrgation model used in this case.
b. Please provide all workpapers that support the weather or other normalizing
adjustment to monthly Irrgation revenues in this case.
c. For each of the last 20 years, what has been the actual monthly sales per Irrgation
customer?
d. Please provide all workpapers that support the monthly weather normalizing
adjustment to the Irrgation monthly demands in this case.
e. For each of the last 20 years, what has been the monthly weather normalized sales
per Irrigation customer?
f. For each of the last 20 years, what has been the calculated/utilized monthly
precipitation data available to and/or used by the Company for the Idaho
jursdiction?
g. What does the company consider normal monthly precipitation values for its
Idaho service terrtory?
h. What are the test year weather normalized sales per Irrigation customer?
23. Regarding the Irrgation Load Control Program credit addressed on Exhibit 2, Tab
4, page 4.5x, please answer the following:
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 6
a. The revenue credit listed is $7,324,489. In the company's Nov. 14,2009 review
of the Idaho Irrgation Load Control Program for 2009 the credit was listed as
$7,246,583. Please provide a table similar to Table Eighteen in the Nov. 14,2009
report that reflects the expected participation for 2010.
b. Is this credit allocated within the class cost of service study on a demand or
energy basis?
c. Are these costs allocated to Monsanto?
d. Are any similar credits to Monsanto allocated to the Idaho Irrgation customers,
and if so, what is the dollar amount and the basis for the allocation?
24. On page 9 beginning on line 12 ofMr. Shu's testimony, it is indicated that the
NPC model uses hourly loads as some of the inputs. In Excel format:
a. Please provide the hourly system retail load data that was used in the NPC model
that was used in this case.
b. Please provide the hourly system retail load data that was used/adjusted for uses
in the NPC model to develop the data in "a" above.
c. Please provide the hourly Idaho retail load data that was used in the NPC model
that was used in this case.
d. Please provide the hourly Idaho Irrgation retail load data that was used in the
NPC model that was used in this case.
e. Please provide the hourly market price data that was used in the NPC model that
was used in this case.
25. Please provide electronically a listing of all dates, times, and expected magnitude of
all dispatched and scheduled day curtailments when Idaho irrgation load was
curtailed under Schedule 72A since Januar 2007.
26. Please provide a biling sumar for the Irrigation customers for each month since
Januar 2003 showing; total revenue, KWh, revenue based on energy, biling
demand, revenue based upon billng demand, customers biled, and revenue based
upon customers biled. Please provide similar information for the test year as well.
27. For each hour since Januar 1 2007 to the most recent data available please
provide the following information in $/Mwh for both the entire system and for the
East System:
a. The market value of energy;
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIRT DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 7
b. The incremental cost associated with the most expensive resource dispatched;
c. The purchase price for the most expensive short-term resource purchased; and
d. The revenue received from the most expensive sale made.
28. For each month since Januar 2007, please supply the level (as well as mechanism
such as mils per kWh etc.) of the BP A credit that was applied to each rate schedule.
29. Does the Company weather normalization summer usage of Schedule 36 customers?
30. Please provide a history of all curailments and/or interrptions made to Monsanto
for the period Januar 1, 2006 through the present. Please detail the time and date of
the curtailment or interrption, the amount and reason (economic curtilment,
operating reserves, system integrity, etc.).
31. Please provide the following for each Morgan Stanley contract that is included in the
Company's Net Power Cost model:
a. Please provide a copy of each contract?
b. In the Net Power Cost model, what was the energy and dollars associated with
each month of the test year.
c. Since Januar 1,2007, what has been the dates, hours, MW, and $/MWH of all
purchases through each of these contracts?
32. Regarding the values on page 10.13 of Company Exhibit 2, please answer the
following:
a. Are the "Metered Loads" at the top of the page actual (unaltered in any way)
values for each jursdiction at the time of the monthly system energy in 2009?
b. What is the specific basis for the first set of adjustments to the Utah energy load?
c. Why are there no adjustments in the first set ofadjustrents (decreases) to the
Idaho energy load?
d. Why are there values each month for both Idaho and Utah shown for the second
set of adjustments which is suppose to include the "normalization ofIrrgation
and Monsanto"?
33. Regarding the values on page 10.13 of Company Exhibit 2, please answer the
following:
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIRT DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 8
a. What were the specific equations used to calculate the Metered Loads at the top of
the page for each state? Please present information by rate schedule or customer
class.
b. For each month since Januar 2006, what was the actual time of the system
coincident peak and each jurisdictions contribution to the coincident peak?
34. Regarding the DSM programs on page 4.15 of Company Exhibit 2, please provide for
each state the most recent study/assessment of each program involved.
35. On July 11,2007 Quantec provided a report to the Company entitled "Assessment of
Long-Term, System-Wide Potential for Demand-Side and Other Supplemental
Resources". Please provide a copy of any Company assessments of that report as
well as any other similar (topic wise) reports that have been developed since.
36. Please provide a copy of the Company's jursdictional allocation mode1(s) and its
class cost of service study in Excel format with all formula's intact.
37. For each month for which the Company does not have load research data for the
Irrgation class, please explain how the monthly system coincident peak used on
Exhibit 49, Tab 5, page 7 and the monthly Distribution peaks used on Exhibit 49, Tab
5, page 12 are derived. Please provide the raw data used to establish these non-load
research based data.
38. Please explain the methodology and provide the underlying data used to develop the
non-coincident peak data used on Exhibit 49, Tab 5, page 13 for all rate schedules.
39. With respect to the distribution peak data listed on Exhibit 49, Tab 5, page 12, please
provide the following:
a. The loss factors that are applied to each rates schedule listed;
b. The hourly distribution value for each hour for 2005-09 in electronic format;
c. The estimated hourly impact upon the distributions values listed in "b" above, due
to the impact of the Irrigation load management programs.
40. With respect to the data used to establish the Substation Peaks weighting factors on
the top of page 11 of Tab 5 of Exhibit 49, please provide the following;
a. The name of each substation used in the analysis;
b. The MW of peak recorded at each substation;
c. The time and date of the peak of each substation;
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNTAI POWER COMPAN 9
d. The original cost of the substation or any cost value that is available on the
Company's property records; and
e. A list of all substations not included in the analysis and the reason for the non-
inclusion.
41. Please provide a listing by size the number of the line transformers that are presently
used in the field to service customers. If available, please list the customer type (Res,
Corn., lIT., Ind., other) that is served.
42. Please provide a listing by size the number of single phase line transformers that are
grouped for a single customer that are presently used in the field to service 3-phase
customers.
43. What size range of line transformers are normally used to serve residential load?
44. For new line transformers that have been ordered by the Company over the last few
years (for any of the jursdictions), please provide a typical price for each size and
type of line transformers. This data is being requested in relationship to the typical
sizes and types of line transformers listed in '"41" above and need only reflect these
types of line transformers.
45. Please provide a copy of all loss studies that were developed and presently being used
for each of the Company's jursdictions.
46. Please list all benefits reflected in the Company's case for the system as a whole of
the Idaho Irrgation Load Control Program. Please quantify these benefits by
rerunnng the Company's Net Power Cost Model and other appropriate models
without the Idaho Irrgation Load Control Program.
47. Please list all benefits reflected in the Company's case for the Idaho jursdiction of
the Idaho Irrgation Load Control Program. Please quantify these benefits by
reruing the Company's Net Power Cost Model, Jurisdictional Allocation Model,
and other appropriate models without the Idaho Irrgation Load Control Program.
48. Please list all benefits reflected in the Company's case for the Idaho Irrgation
Schedule 10 of the Idaho Irrgation Load Control Program. Please quantify these
benefits by reruing the Company's Net Power Cost Model, Jursdictional
Allocation Model, Class Cost-of-Service Model, and other appropriate models
without the Idaho Irrgation Load Control Program.
49. According to Company witness Shu, beginning at page 8 line 23: '"The addition of the
Populus to Terminal line increases the transmission capacity across Path C from
southeast Idaho to northern Utah by approximately 780 megawatts. The additional
transmission capacity makes it possible to better utilze the market price differentials
between the east and west sides of the Company's system, reduces reliance on
IDAHO IRRGATION PUMERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 10
additional purchases of transmission from third paries, and improves reliability."
Please reru the Company's Net Power Supply Model used in this case without the
increase of approximately 780 megawatts across Path C.
50. Company witness Bird discusses an AAC method to determine the relative
favorability of varous resource options. Please use this same ACC method to
compare the cost/value of the Idaho Irrgation Load Control Program with the
purchase of a gas fired peaker of equivalent size. This comparson can be done on
either a generic $/MW basis, or specific sized peakers can be chosen and the
appropriate reduction make to the Idaho Irrgation Load Control Program values.
51. On July 11,2007 Quantec provided a report to the Company entitled "Assessment of
Long-Term, System-Wide Potential for Demand-Side and Other Supplemental
Resources". That report on page 17 and elsewhere lists an avoided cost of papacityh
of$98 per kW-year for Rocky Mountain Power and $58 per kW-year for Pacific
Power. Are there any new values for these avoided costs? If there are, please provide
a copy of the study of analysis that contains the new values.
52. On July 11, 2007 Quantec provided a report to the Company entitled "Assessment of
Long-Term, System-Wide Potential for Demand-Side and Oter Supplemental
Resources". That report on page 22 found that there was a levelized cost for the
Residential direct load control program of$93 per kW in the Rocky Mountain service
area. Are there any new values for this levelized cost? If there are, please provide a
copy of the study of analysis that contains the new value.
53. On July 11,2007 Quantec provided a report to the Company entitled "Assessment of
Long-Term, System-Wide Potential for Demand-Side and Other Supplemental
Resources". That report on page 22 found that there was a levelized cost for the
Irrgation direct load control program of$47 per kW in the Rocky Mountain service
area. Are there any new values for this levelized cost? If there are, please provide a
copy of the study of analysis that contains the new value.
RACINE OLSON NYE BUDGE
& BAIL RTERED
IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 11
CERTIICATE OF MAING
I HEREBY CERTIFY that on this £5',l~day of June, 2010, 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, Secretar
Idaho Public Utilities Commission
P.O. Box 83720
472 WI Washington Street
Boise, Idaho 83720-0074
i i ewell(ipuc . state .id. us
Ted Weston
Idaho Regulatory Affairs Manager
201 South Main, Suite 2300
Salt Lake City, UT 8411 1
ted. weston(ipacificorp.com
Danel E. Solander
Senior Counsel
201 South Main, Suite 2300
Salt Lake City, UT 84111
daniel.solander(ipacificorp.com
Data Request Response Center
Pacificorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
datarequest(ipacificorp.com
Randall C. Budge
Racine Olson Nye Budge & Bailey Chtd.
P.O. Box 1391; 201 E. Center Street
Pocatello, Idaho 83204
rcb(iracinelaw.net
Katie Iverson
Brubaker & Associates
17244 W. Cordova Cour
Surrise, AZ 85387
kiverson(iconsultbai.com
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IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 12
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, ID 83276
Jim.r .smith(ßmonsanto.com
Michael C. Creamer
Kelsey J. Nunez
GIVENS PURSLEY LLP
601 W. Banock Street
P.O. Box 2720
Boise, ID 83701-2720
mcc(ßgivenspursley.com
KelseyNunez(ßGivensPursley.com
Tim Buller
Jason Hars
Agriur Inc.
3010 Conda Road
Soda Springs, ID 83276
TBuller(ßagrium.com
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IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 13