20150421PAC to Monsanto Supplemental 1.11.pdf

ROCKY MOUNTAINmn*.201 South Main, Suite 2300
Salt Lake City, Utah 84ll I
?tiinPP21 Pi4 l:il5
April2o,2ot5 ;-i[tli: 'l .: ' ,,,,,].'
Randy Budge
Kevin Higgins
Brad Mullins
Monsanto
[e-mail] (C)
khi [e-mail] (C)
brmullins@mwanalytics. com (C)
RE: ID PAC-E-14-10
Monsanto Set I (l-30)
Please find enclosed Rocky Mountain Power's I't Supplemental Response to Monsanto I't Set
Data Request l.l 1. Provided on the enclosed Confidential CD is Confidential Attachment
Monsanto 1.1 I I't Supplemental. Confidential information is provided subject to the terms and
conditions of the protective agreement between Rocky Mountain Power and Monsanto in this
proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J:i(d, {t rr fir,x
J. Ted Weston
Manager, Regulation
Enclosures
C.c. : Ronald L. Williams/PIIC [e-mail] (C)
Jean Jewell/IPUC [e-mail]. gov (C)
Neil Price/IPUC Neil. [e-mail]. qov (C)
PAC-E- I 4- 1 O/Rocky Mountain Power
April20, 2015
Monsanto Data Request 1.11 - l't Supplemental Response
Monsanto Data Request l.Ll
Please provide all accounting work papers used to develop the journal entries
associated with booking the $194 million regulatory assets associated with the
Deer Creek Mine closure, as described on page 70 of its 201410-K.
l't Supplemental Response to Monsanto Data Request 1.11
In further response and as a supplement to the Company's original response to
DR 1 . I I , the Company hereby provides a redacted version of the workpapers as
Confidential Attachment Monsanto 1.11 l't Supplemental. The enclosed work
papers relate to referenced joumal entries and were originally withheld because
the documents are both privileged (as correspondence between our accountants
and our lawyers) and work product (as providing information requested by
counsel). However, in an effort to provide complete disclosure without waiving
any attorney-client privilege or work product protection, each of which is
expressly reserved, the Company has redacted portions to protect attorney client
privilege and attomey work product. This disclosure is made without prejudice to
the Company's right to object to the disclosure or production of any of the
redacted information, and does so in an attempt in good faith to produce
requested, non-privileged information.
Confidential information is provided subject to the terms and conditions of the
protective agreement between Rocky Mountain Power and Monsanto in this
proceeding.
Responder: Doug Stuver
Witness: Doug Stuver