20110609Monsanto 1-24 to PAC.pdf

W. 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
FREDERICK J. HAHN, III
PATRICK N. GEORGE
SCOTT J. SMITH
DAVID E. ALEXANDER
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN
CANDICE M. MCHUGH
CAROL TIPPI VOLYN
JONATHON S. BYINGTON
JONATHAN M. VOLYN
BRENT L. WHITING
DAVE BAGLEY
THOMAS J. BUDGE
JASON E. FLAIG
FERRELL S. RYAN, III
AARON A. CRARY
JOHN J. BULGER
BRETT R CAHOON
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD~ SUITE 300
BOISE, IDAHO 83702
TELEPHONE: [phone]FACSIMILE: [phone]
TELEPHONE [phone]
FACSIMILE [phone] IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 107
POST OFFICE BOX 50698
IDAHO FALLS, ID 83405
TELEPHONE: [phone]
FACSIMILE: [phone]
ww.racinelaw.net
ALL OFFICES TOLL FREE
[phone]SENDER'S E-MAIL ADDRESS:rcb(§racinelaw.net
LOUIS F. RACINE (1917-2005)WILLIAM D. OLSON. OF COUNSEL.
June 7, 2011 ,.c=~-
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Jean D. Jewell, Secretar
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Dear Mrs. Jewell
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Re: Case No. PAC-E-1l-12
Please find enclosed for fiing the original and three copies of Monsanto Company's First
Data Requests to Rocky Mountain Power.
Than you for your assistance.
'ncerely,
L~DGE
RCB:rr
Enclosures
cc: Service List (w/encls.)
Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
l? I: Cit:! Ilr:D
2t?IIJfIPI ';.Urr "'9
AI1 8: 22
Attorneys for Interenor 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 SERVICE ) Case No. PAC-E-l1-12
SCHEDULES AND A PRICE INCREASE OF $32.7 )
MILLION, OR APPROXIMATELY 15.0 PERCENT )
)
MONSANTO COMPANY'S FIRST DATA REQUESTS
TO ROCKY MOUNTAIN POWER
MONSANTO COMPANY, by and through their attorneys, hereby submits this First Data
Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utility
Commission's Rules of Procedure, IDAPA 31.01.01, as follows:
Monsanto 1: Please provide a copy of all data requests received from Commission Staff and
other paries. Please consider this to be a continuing request and supplement your response as
additional requests are received.
Monsanto 2: Please provide a copy of your responses to the data requests from Commission
Staff and other parties. Please consider this to be a continuing request and supplement your
response as additional requests are received.
Monsanto 3: Please provide a copy of your responses to requests conveyed to Rocky Mountain
Power other than though formal data requests from Commission Staff and other paries. Please
consider this to be a continuing request and supplement your response as additional requests are
received.
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 1
Monsanto 4: Please provide a copy of the workpapers supporting the testimony of A. Richard
Walje. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 5: Please provide a copy of the workpapers supporting the testimony of Steven R.
McDougaL. To the extent that the workpapers include any spreadsheets or models, please
provide in executable native format with all formula intact.
Monsanto 6: Please provide a copy of the workpapers supporting the testimony of Bruce N.
Wiliams. To the extent that the workpapers include any spreadsheets or models, please provide
in executable native format with all formula intact.
Monsanto 7: Please provide a copy of the workpapers supporting the testimony of Samuel C.
Hadaway. To the extent that the workpapers include any spreadsheets or models, please provide
in executable native format with all formula intact.
Monsanto 8: Please provide a copy of the workpapers supporting the testimony of Cathy S.
Woollums. To the extent that the workpaper include any spreadsheets or models, please
provide in executable native format with all formula intact.
Monsanto 9: Please provide a copy of the workpapers supporting the testimony of Erich D.
Wilson. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 10: Please provide a copy of the workpapers supporting the testimony of Chad A.
Teply. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 11: Please provide a copy of the workpapers supporting the testimony of Barbara A.
Coughin. To the extent that the workpapers include any spreadsheets or models, please provide
in executable native format with all formula intact.
Monsanto 12: Please provide a copy of the workpapers supporting the testimony of Darell T.
Gerrard. To the extent that the workpapers include any spreadsheets or models, please provide
in executable native format with all formula intact.
Monsanto 13: Please provide a copy of the workpapers supporting the testimony of Paul H.
Clements. To the extent that the workpapers include any spreadsheets or models, please provide
in executable native format with all formula intact.
Monsanto 14: Please provide a copy of the workpapers supporting the testimony of Gregory N.
Duvall. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER. 2
Monsanto 15: Please provide a copy of the workpapers supporting the testimony of Cindy A.
Crane. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 16: Please provide a copy of the workpapers supporting the testimony of C. Craig
Paice. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 17: Please provide a copy of the workpapers supporting the testimony of Wiliam R.
Griffith. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 18: If not included in the responses to other data requests, please provide the
jursdictional allocation models in executable native format with all formulas intact.
Monsanto 19: If not included in the responses to other data requests, please provide the class
cost of serice allocation model in executable native format with all formulas intact.
Monsanto 20: Please provide Monsanto's actual hourly load data for the test year and all
adjustments made to that actual hourly load data for purposes of:
a. The jursdictional allocations
b. The class cost of servce allocations.
Monsanto 21: Provide the twelve monthly coincident peaks used in the jurisdictional cost of
service study for Monsanto.
Monsanto 22: If not provided in response to other data requests, please provide all workpapers
and supporting data showing the dervation of each external allocation factor.
Monsanto 23: If not provided in response to other data requests, please provide all workpapers
and supporting data showing the derivation of each exteral allocation factor for the class cost of
serice allocation modeL.
Monsanto 24: If not provided in response to other data requests, please provide the pre-filed
exhibits in executable native format with all formulas intact, where available.
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER. 3
l~DATED this i day of June, 2011.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By ~t-fJ
RANDALL C. BuD
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER. 4
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 1 l~ay of June, 2011, I sered a tre, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretar (original and 3)
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
E-mail: jjewellêpuc.state.id.us U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
ted. weston(ßpacificorp.com
E-Mail
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
daniel.solander(ßpacificorp.com
E-Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Fax: [phone]
datareguest(ßpacificorp.com E-Mail
Maurce Brubaker
Katie Iverson
Brubaker & Associates, Inc.
1215 Fern Ridge Parkway, Suite 208
St. Louis, MO 63141
mbrubaker(ßconsultbai.com
kiverson(ßconsultbai.com
E-Mail
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
jim.r.smith(ßmonsanto.com E-Mail
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER. 5
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
P.O. Box 1391
Pocatello, Idaho 83204-1391
elo(ßracinelaw.net
Gary Kajander
Manager, Energy Procurement
Monsanto Company
800 N. Lindbergh Blvd., Z C2NF
St. Louis, Missouri 63167
Gar.r.kajander(ßmonsanto.com
Rick Anderson
Energy Strategies, LLC
215 S. State Street, #100
Salt Lake City, Utah 84111-2322
randerson(ßenergystrat.com
E-Mail
E-Mail
E-Mail
~~-~
RANDALL C. BUDGE
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER. 6