20110105Staff to Monsanto 19 (1-2).pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
RECEIV n
zon JriN -5 PM l: 55
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. PAC-E-IO-07
(ECONOMIC VALUATION OF
MONSANTO INTERRUPTIBLE
PRODUCTS)
COMMISSION STAFF'S
RESPONSE TO MONSANTO'S
FIRST DATA REQUESTS TO
STAFF
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbury, Deputy Attorney General,ptovides the following documents and information
in response to Monsanto's First Set of Discov.~ry Reqllests to Staff dated January 4, 2011.
STAFF'S RESPONSE TO MONSANTO'S .1
FIRST DATA REQUEST 1 JANUARY 5, 2011
Request No. 19.1: Please provide a copy of aU workpapers supporting the testimony
and exhibits of Keith Hessing. To the extent that the workpapers include any spreadsheets
or models, please provide in executable native format with all formulae intact.
Answer: The requested workpapers are on the attached Confidential CD.
Request No. 19.2: Please provide all support and documentation for the witness's
statement that interruptions for a "double contingency" event can only be "up to 95 MW."
Answer: This is his understading from reading Section 3 of Exhibit A to the Electric
Service Agreement between PacifiCorp and Monsanto dated November 5, 2007 that was
approved by the Commission in Case No. PAC-E:'07-05, Order No. 30482.
DATED at Boise, Idaho, this s'fday of January 2011.
Scott Woodbury
Reputy Attorney General
Technical Staff: Keith Hessing
i:umisc:prodreqlpacelO.7swkh prod response 1 to Monsanto
STAFF'S RESPONSE TO MONSANTO'S
FIRST DATA REQUEST 2 JANUARY 5, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF JANUARY 2011,
SERVED THE FOREGOING COMMISSION STAFF'S RESPONSE TO
MONSANTO'S FIRST DATA REQUESTS TO STAFF, IN CASE NO. PAC-E-1O-07
(ECONOMIC V ALUA TION OF MONSANTO INTERRUPTIBLE PRODUCTS), BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.weston(fpacificorp.com
PAUL J HICKEY
HICKEY & EVANS LLP
1800 CARY AVE., SUITE 700
PO BOX 467
CHEYENNE WY 82003
E-MAIL: phickey(fhickeyevans.com
E-MAIL: ONLY
MAR C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: mark.moench(fpacificorp.com
danel.solander(fpacificorp.com
E-MAIL: ONLY
DATA REQUEST RESPONSE CENTER
PACIFICORP
E-MAIL: dataeguest(fpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(fracinelaw.net
E-MAIL: ONLY
KATIE IVERSON
BRUBAKER & ASSOCIATES
E-MAIL: kiverson(fconsultbai.com
E-MAIL: ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smith(fmonsanto.com
,b~
SECRETA.
CERTIFICATE OF SERVICE