20150325Monsanto 1-30 to PAC.pdf

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RACI N E
OLSON
NYE
BUDGE
BAILEY
201 E. Center St.
P.o. Box 1391 ,-r i: .,:.- r.;, RANDALL C. BUDGE
o 208.232.6101
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March 23,2015
Jean Jewel!, Secretary
ldaho Public Utilities Commission
472 W . Washington Street
Boise, ldaho 83702
Re: PAC-E-14-10
Dear Jean:
Enclosed for filing please find the original and three (3) copies of
Monsanto Company's First Data Requests to Rocky Mountain Power.
Thank you for your assistance.
Sincerely,
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RANDALL C. BUDGE
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Enclosurescc: Service List (via e-mail)
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Intervenor Monsanto Company
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
APPROVAL OF A TRANSACTION TO
CLOSE DEER CREEK MINE AND FOR A
DEFERRED ACCOUNTING ORDER
Case No. PAC-E-14-10
MONSANTO COMPANY'S FIRST DATA REOUEST
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 1-1: Please provide the Company's responses to data requests submitted by the
Industrial Customers of Northwest Utilities ("ICNU") in Docket No UM lTl2before the Oregon
Public Utilities Commission. Specifically, please provide the responses to ICNU discovery sets
1,2,3 and 4.
Monsanto 1-2: Please provide electronic copies of all confidential and non-confidential
documents filed by the Company in this proceeding, including the Application, testimony,
exhibits, and workpapers. Please provide all tables, exhibits and workpapers in Excel format with
links to, and including, all supporting source documents.
Monsanto L-3: Please provide any and all economic analyses performed in the last five
years by the Company that evaluated whether to close the Deer Creek Mine.
f,r8
MONSANTO COMPANY'S FIRST DATA REQUEST TO ROCKY MOI_INTAIN POWER - 1
Monsanto L-4: Please provide any and all economic analyses performed by the Company
in support of its decision to close the Deer Creek Mine in 2015.
Monsanto 1-5: Please provide any presentation materials that have been provided to the
Staff of the Idaho Public Utilities Commission in connection with the Application.
Monsanto 1-6: Please provide copies of any confidential presentation materials that have
been provided to the Oregon Public Utility Commission or its Staff in Docket No UM 1712.
Monsanto 1-7: Please speciff the exact date that mining production concluded at the
Deer Creek Mine.
Monsanto 1-8: Please state the exact date that the Company made its decision to close
the Deer Creek Mine.
Monsanto L-9: Please state the exact date on which the Company booked the $194
million regulatory asset associated with the Deer Creek Mine closure, as described on page 70 of
the Company's 2014 10-K.
Monsanto 1-10: Please provide all of the SAP journal entries associated with booking
the $194 million regulatory assets associated with the Deer Creek Mine closure, as described on
page70 of the Company's 2014 10-K.
Monsanto 1-11: Please provide all accounting workpapers used to develop the journal
entries associated with booking the $194 million regulatory assets associated with the Deer
Creek Mine closure, as described on page7} of its 2014 10-K.
Monsanto 1-12: Please specify the exact date on which the retiree medical settlement
was executed, as well as a copy of the settlement document.
Monsanto 1-13: Please state the year in which the Deer Creek Mine was acquired by
PacifiCorp.
Monsanto 1-14: Please state the gross plant associated with the Deer Creek Mine as of
the date that the Company made its decision to close the plant.
Monsanto 1-15: Please state the net plant associated with the Deer Creek Mine as of the
date that the Company made its decision to close the plant.
Monsanto L-16: Please state the gross plant associated with the Deer Creek Mine
included in the Company's most recent general rate case, Docket No. PAC-E-ll-t2.
Monsanto 1-17: Please state the net plant associated with the Deer Creek Mine included
in the Company's most recent general rate case, Docket No. PAC-E-ll-Lz.
MONSANTO COMPANY'S FIRST DATA REQUEST TO ROCKY MOUNTAIN POWER - 2
Monsanto 1-L8: Please provide a copy of the final revenue requirement model approved
in the Company's last filed general rate case, Docket No. PAC-E-LI-I2.
Monsanto L-19: Please provide a copy of the final net power cost report approved in the
Company's most recently filed general rate proceeding.
Monsanto 1-20: Please provide the standard net power cost workpapers, including the
GRID project, used to develop the final net power cost report approved in the Company's most
recently filed general rate proceeding.
Monsanto 1-21: Please provide any and all workpapers that were relied on to develop the
cost of coal for the Huntington facility in the Company's most recently filed general rate
proceeding.
Monsanto l-222 Please state the retum on rate base included in Docket No. PAC-E- 1 1 -
l2 associated with each and every asset that will be sold, disposed, or retired as a result of the
Deer Creek Mine Closure and the associated transaction with Bowie.
Monsanto 1-23: Please state the total revenue requirement that was approved in PAC-E-
13-04.
Monsanto l-24:Please state the total number of employees that will be employed by
Energy West Mining Company following the completion of the Company's disposition of the
Deer Creek Mine.
Monsanto L-25: Please provide a list of assets and liabilities that will be possessed by
Energy West Mining Company following the completion of the Company's disposition of the
Deer Creek Mine.
Monsanto 1-26: Please provide any and all actuarial reports for the 1974 Pension Trust
that were issued between 2000 and the present.
Monsanto l-2TzPlease provide a narrative description of how the Company currently
accounts for the 1974 Pension Trust, including references to the Generally Accepted Accounting
Principles supporting its accounting.
Monsanto 1-28: Please state the asset retirement obligation amount for associated with
the Deer Creek Mine at the time of the Company's decision to dispose of that asset, as well as a
general description of how the Company accounts for asset retirement obligations.
Monsanto 1-29: Please state the total amount of loss associated with the disposal of the
Trial Mountain Mine that the Company proposed to be deferred as a result of the Transaction.
MONSANTO COMPAIryS FrRST DATA REQT.TEST TO ROCKY MOUNTAIN POWER - 3
Monsanto 1-30: Please state the total amount of rate base associated with the Trial
Mountain Mine that was included in the final revenue requirement approved in Docket No. PAC-
E-lL-12.
DATED ,1,i, &g! of Marctr, 2ots.
RACINE, OLSON, hIYE, BUDGE &
BAILEY, CHARTERED
MONSAIITO COMPAM'S FIRST DATA REQUEST TO ROCKY MOLTNTATN POWER - 4
I HEREBY CERTIFY that on thisZB day of March, 2015, 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 andT)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail: [e-mail] U.S. Mail + Email
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84l l l
E-mail: [e-mail] E-mail
Daniel Solander
Rocky Mountain Power
201 South Main, Suite 2400
Salt Lake city, Utah 841l l E-mail
E-mail : daniel. solander@f acificom. com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232Fax:[phone] E-mail
E-mail : datarequest@pacifi corp. com
Brad Mullins
333 SW Taylor Street, Suite 400
Portland, OR97204 E-mail
E-mail : brmullins@mwanalytics. com
Kevin Higgins
Energy Strategies
215 S. State St., Suite 200
Salt Lake City, Utah 84111 E-mail
E-mail : khi [e-mail]. com
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays Street
Boise,Idaho 83702 E-mail
E-mail : ron@williamsbradbury. com
MONSANTO COMPANY'S FIRST DATA REQUEST TO ROCKY MOI-INTAIN POWER - 5
Val Steiner
Agiurn Us Inc.A.[u-West Industies
E-mail: val. [e-mail]
Jim Duke
Idahoan Foods
E-mail : j duke@i dahoan. com
E-mail
E-mail
MONSANITO COMPAIIY'S FrRST DATA REQUEST TO ROCKY MOUNTATN POWER - 6