20150327Monsanto 2.1-2.7 to PAC.pdf

R
RACI N E
OLSON
NYE
BUDGE
BAILEY
2Ol E. Center St.
P.O. Box 1391
Pocatello, lD 83204
o 208.232.6101
F 208.232.6109
racinelaw.net
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RANDALL C. BUDGE
[e-mail]
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March 25,2015
Jean Jewell, 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 Second Data Requests to Rocky Mountain Power.
Thank you for your assistance.
Sincerely,
ru
RCB:ts
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 l39l;201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Intervenor Monsanto Company
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 SECOND DATA RE,OUEST
TO ROCI(Y MOUNTAIN POWER
MONSANTO COMPANY, by and through their attomeys, hereby submits this Second
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 2-1: With regards to coal fuel stock balances included in rate base, please
respond to the following:
a. Please provide the amount of coal fuel stock broken down by plant/location that the
Company considers to be incorporated in current Idaho base rates and indicate the
source of the amounts.
Monsanto 2-2zPlease refer to Confidential Exhibit RMP_(DKS-l), entry entitled "Deer
Creek CWIP & PS&I."
a. Please confirm that the Deer Creek CWIP amount is currently not recovered in
Idaho rates.
b. What is the current ratemaking treatment of the Deer Creek PS&I expenditures in
Idaho?
MONSANTO COMPANY'S SECOND DATA REQUEST TO ROCKY MOUNTATN POWER - 1
Monsanto 2-3: Please refer to the EW FRF Forma Closure Sale file, the PP&E Summary
tab, provided in Attachment IPUC 4 CONF. Please confirm that Preparation Plant CWIP is not
currently recovered in Idaho rates.
Monsanto 2-4: Giver, that the Hunter Power Plants are not 100% owned by RMP:
How does the Company account in Idaho ratemaking for the portion of the Deer
Creek Mine and Mining Assets that are used for supplying the non-RMP-owned
portion of the Hunter facilities?
Are the Deer Creek Mine and Mining Assets that are included in Idaho rate base
adjusted for the portion of service from these assets that is provided to the non-
RMP-owned part of the Hunter plants? Is so, what is the amount of this adjustment
and how is it calculated? If not, why hasn't such an adjustment been made
heretofore?
Is the Fossil Rock PHFU adjusted for the portion of service from these assets that
has been held for the benefit of the non-RMP-owned part of the Hunter plants? Is
so, what is the amount of this adjustment and how is it calculated? If not, why
hasn't such an adjustment been made heretofore?
Are the depreciation and operating expenses associated with the Deer Creek Mine
and Mining Assets that are included in Idaho net power cost adjusted for the portion
of service from these assets that is provided to the non-RMP-owned part of the
Hunter plants? Is so, what is the amount of this adjustment and how is it calculated?
If not, why hasn't such an adjustment been made heretofore?
Please explain whether the Preparation Plant is used to stockpile and blend coal for
only the Hunter plant, or whether the Preparation Plant also serves the Huntington
plant. If Huntington is also served by the Preparation Plant, please approximate the
proportions of Preparation Plant coal that have supplied the Huntington, Hunter,
and any other plant for the last five years.
Monsanto 2-5: Follow-up to RMP's lst Supplemental Response to Wyoming PSC Data
Request No. 2.16.
Please fully explain the basis for the income tax regulatory asset, including a
discussion behind the history of the flow-through treatment, why that treatment
gave rise to a regulatory asset and why it is appropriate for this regulatory asset to
b.
c.
d.
e.
MONSANTO COMPAM'S SECOND DATA REQUEST TO ROCKY MOUNTAIN POWER - 2
be recovered in connection with the Transaction. Did the flow-through treatment
referenced in the Response apply in Idaho?
Monsanto 2-6: Please provide the total expense included in the most recent general rate
case test year revenue requirement (presumed to be DocketNo. PAC-E-ll-tz) for fueling the
Company's vehicle fleet, on both a total Company and an Idaho-allocated basis.
Monsanto 2-7: Please provide the per-gallon vehicle fleet fuel cost assumption used in
the Company's revenue requirement calculation in the most recent general rate case (presumed
to be Docket No. PAC-E-11-12). Please separately provide the per-gallon fuel cost assumption
for each applicable vehicle fuel type (gasoline, diesel, etc.), and the proportion that each fuel
type comprised of the total Idaho vehicle fuel revenue requirement.
DATED fin Ft?yofMarch, 2ols.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
MONSANTO COMPANY'S SECOND DATA REQUEST TO ROCKY MOLINTAIN POWER - 3
CERTIFICATE OF MAILING
Jt/t
I HEREBY CERTIFY that on this Zf ilay of March,20l5,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 7)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail : i ean j ewell@puc. idaho. gov
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail : ted.weston@nacificorp. com
Daniel Solander
Rocky Mountain Power
201 South Main, Suite 2400
Salt Lake city, Utah 84111
E-mail : daniel.solander@pacifi corp.com
Yvonne R. Hogle, Senior Counsel
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
E-mail: [e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Fax: [phone]
E-mail : datarequest@f acifi corp. com
Brad Mullins
333 SW Taylor Street, Suite 400
Portland, OR97204
E-mail : brmullins@mwanalytics. com
Kevin Higgins
Energy Strategies
215 S. State St., Suite 200
Salt Lake city, Utah 84111
E-mail : khi sgins@enerqystrat. com
U.S. Mail + Email
E-mail
E-mail
E-Mail
E-mail
E-mail
E-mail
MONSANTO COMPANY',S SECOND DATA REQUEST TO ROCKY MOTTNTAIN POWER - 4
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays Street
Boise,Idaho 83702
E-mail : [e-mail]
E-mail
RANIDALL C. BUDGE
MONSAIITO COMPAI{Y',S SECOND DATA REQUEST TO ROCKY MOLJNTAIN POWER - 5