20150706Monsanto 1-14 to PAC.PDF

il RACI N E
OLSON
NYE
BUDGE
BAILEY
2O1 E. Center St.
P.O. Box 1391
Pocatello, lD 83204
o 208.232.6101
F 208.232.6109
racinelaw.net
RANDALL C. BUDGE
[e-mail]
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July 2,2015
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 83720-007 4
iean.jewell @ puc.state.id. us
Re: IPUC Case No. PAC-E-I5-09
Dear Ms. Jewell:
Senf Via Email & U.S. Mail
Enclosed for filing please find the original and three (3) copies of
Monsanto Company's Frrsf Data Requesfs fo Rocky Mountain Power.
Thank you for your assistance.
Sincerely,
/]|*ilut r",-Fufr
V
RANDALL C. BUDGE
RCB:ts
Enclosurescc: Seruice List (via e-mail)
I

MONSANTO COMPANY’S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 1
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]
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER TO MODIFY ) THE ENERGY COST ADJUSTMENT ) Case No. PAC-E-15-09 MECHANISM AND INCREASE RATES BY $10.2 ) MILLION, OR APPROXIMATELY 3.9 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 parties. 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 through formal 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 COMPANY’S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 2
Monsanto 4: Please provide a copy of the workpapers supporting the testimony of Joelle R. Steward. 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 Michael G. Wilding. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formula intact. Monsanto 6: Reference page Table 2 on page 13 of Mr. Wilding’s testimony. Please provide
the same information for the years 2010, 2011, 2012 and 2014. Monsanto 7: Reference page Table 2 on page 13 of Mr. Wilding’s testimony. Please provide the fuel or purchased power costs (or sales price in the case of Total Wholesale Sales) that
correspond to the GWh shown in the table. Please provide this information for the years 2009,
2010, 2011, 2012, 2013 and 2014. Monsanto 8: Please provide copies of the five expired long-term sales contracts described at page 7, lines 2-4 of Mr. Wilding’s testimony.
Monsanto 9: To the extent not already provided, please provide a copy of the Annual Results of Operations NPC 2015 report. Monsanto 10: To the extent not already provided, please provide all workpapers and documents
supporting the contractual coal price increases, new coal contracts, and increased mine operating
costs at the Bridger mine as discussed at page 7, lines 6-8 of Mr. Wilding’s testimony. Monsanto 11: Please provide the 90%/10% NPC differential sharing amounts under the ECAM for each of the past 5 years.
Monsanto 12: 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 13: Reference page 9 of Mr. Wilding’s testimony at line 2. Please describe and
provide all analysis proformed by or for the Company as to the “temporary adder” to include in the ECAM to allow for the recovery of the amortization of the remaining book value of Deer Creek Mine.
Monsanto 14: 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
DATED this 2nd day of July, 2015.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED

By
RANDALL C. BUDGE

MONSANTO COMPANY’S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 4
CERTIFICATE OF MAILING I HEREBY CERTIFY that on this 2nd day of July, 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 and 3) Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074 E-Mail & U.S. Mail E-mail: [e-mail] Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300 Salt Lake City, Utah 84111 E-Mail [e-mail]
Yvonne R. Hogle
Rocky Mountain Power 201 South Main, Suite 2400 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] E-Mail Maurice Brubaker Katie Iverson
Brubaker & Associates, Inc.
1215 Fern Ridge Parkway, Suite 208 St. Louis, MO 63141 [e-mail] E-Mail [e-mail]

James R. Smith Monsanto Company P.O. Box 816 Soda Springs, Idaho 83276
[e-mail] E-Mail

MONSANTO COMPANY’S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 5
RANDALL C. BUDGE