20140213Monsanto 1-11 to PAC.pdf

Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
rcb@racinelaw.n"t
Attomeys for Intervenor Monsanto Company
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BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCI(Y MOUNTAIN POWER FOR
AUTHORITY TO DECREASE RATES BY
$2.8 MILLION TO RECOVER DEFERRED
NET POWER COSTS THROUGH THE
ENERGY COST ADJUSTMENT
MECHANISM
CASE NO. PAC.E.l4.OI
MONSANTO COMPANY'S FIRST DATA REQUESTS
TO ROCI(Y 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 describe all avenues and programs by which RMP sells renewable energy credits. Please
include copies of all tariffs and sales agreements currently in effect through which RMP collects
a revenue from the sale of renewable energy credits.
Monsanto 2:
Please provide copies of the long-term sales contracts that expired during the Deferral Period, as
reference by RMP Witness Dickman on page 10, line l5 through page 11, line 6, and at page 11,
lines 16 tlvotgh22.
MONSANTO'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - I
Monsanto 3:
Regarding the qualifying facilities ("QF") referenced by RMP Witness Dickman at the bottom of
page 11 of his testimony, is RMP entitled to the renewable energy credits ("REC") produced by
these QFs? Did RMP purchase fewer RECs from these QFs than in previous years because of
the increase in the "customers utilizing the QF generation to serve their own load", as Mr.
Dickman describes? Please fully explain your answer.
Monsanto 4:
Please provide copies of the purchase agreements with the qualifying facilities referenced at page
12, lines 9 through 13 of RMP Witness Dickman's testimony, including detail regarding the
purchase of any RECs from the QFs by RMP.
Monsanto 5:
Please provide the 12 months data supporting the Monsanto Balancing Account Beginning
Balance for December 2012 of $11,850,355 with all supporting workpapers (i.e., Exhibit 1 as
ordered by the Commission in Case No. PAC-E-I3-03).
Monsanto 6:
Please confirm or deny that Monsanto's ECAM deferral balance was $6,783 ,223 for the
Decernber l, 2010 through November 30,2011 ECAM deferral period as referenced on page 9
of Order No. 32597 in Case No. PAC-E-12-03. If denied, please explain.
Monsanto 7:
Please state the source, and provide all supporting workpapers for $2.4 million shown on line 7,
page 3 of Joelle Steward's testimony.
Monsanto 8:
Amortizing the $6,783,223 deferlal balance ordered in Case No. PAC-E-12-03 over three years
would be$2,261,074. Please reconcile this amount to the $2.4 million on page 3 of Joelle
Steward's testimony.
Monsanto 9:
ln Case No. PAC-E-13-03, Joelle Steward testified on page 3 at line 18, "The Company will
track the recovery of the two different deferral period amounts by proportioning the collections
consistent with each contract customers' annual amortization balance." Please provide all
studies, analysis and accounting performed by the Company through February 2014 which track
the recovery of the two different deferral period amounts. Please provide all analysis in
electronic format.
Monsanto 10:
Assuming Monsanto's future loads are consistent with 2013 loads, please provide the
Company's estimate of the expected date by which the 2011 ECAM deferral for the period of
December l, 2010 through November 30,2011 will be paid off. Please provide all workpapers.
MONSANTO'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER.2
Monsanto 11:
Assuming Monsanto's future loads are consistent with 2013 loads, please provide the
Company's estimate of the expected date by which the20l2 ECAM deferral for the period of
Decenrber l,20ll through Novenrber 30,2012 will be paid off. Please provide all workpapers.
DATED this 1lth day of February 2014.
RACINE, OLSON, }IYE, BUDGE &
BAILEY, CHARTERED
RANDALL C. BUDGE
MONSAI{TO'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER-3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this I lth day of February 2014,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
P.O. Box 83720
Boise,lD 83720-0074
E-mail: [e-mail] U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: [e-mail] E-Mail
Yvonne Hogle
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Email: Yvonne.hoele@f'acificom.com E-Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah St., Suite 2000
Portland, OR97232
Email: datarequest@f'acificorp.com E-Mail
Daniel Solander
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, Utah 84111 E-Mail
E-mail: [e-mail]
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
P. O. Box 83720
Boise,Idaho 83720-0074 E-Mail
E-mail: [e-mail]. gov
MONSANTO'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER.4
James R. Smith
Monsanto Company
P. O. Box 816
Soda Springs, Idaho 83276
E-mail: [e-mail]
Katie Iverson
Brubaker & Associates
19540 N. Wessex Drive
Surprise, Arizona 853 87
E-mail: [e-mail]
E-Mail
E-Mail
RANDALL C. BUDGE
MONSANTO'S FIRST DATA REQUESTS TO ROCKY MOTJNTAIN POWER. S