20180424Monsanto 1-4 to PAC.pdf

Randall C. Budge,ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NTE & BUDGE, CHARTERED
P.O. Box l39l;201E. Center
Pocatello, Idaho 832M-1391
Telephone: Q08) 232-6101
Fax: [phone]
[e-mail]
[e-mail]
Auorneys for Intervenor Monsanto Company
REC EIVED
20lB APR 2h Pt{ h: 07
l; i i:.;i i:U3LlC
I l- I,'tr: ;i ;-lC-i,it {tSSl0N
IN THE MATTER OF APPLICATION
OF ROCKY MOUNTAIN POWER
REQUESTING APPROVAL OF $7.8
MILLION NET POWER COST DEFERRAL
WITH NO CHAI\GE TO RATES
CASE NO. PAC.E.18.O1
MONSANTO COMPAIIY'S FIRST
sET OF DATA REQUESTS TO
ROCKY MOI]NTAIN POWER
MONSANTO COMPANY, by and through their attorneys, hereby submits this First Data
Request to Rocky Mountain Power, pursuant to Rule 225 of the tdaho Public Utility Commission=s
Rules of Procedure, IDAPA 31.01.01, as follows:
Request No. 1: Please provide copies of responses to all data requests (whether formal or
informal) that have been supplied to date and continue to do so when additional information is
supplied to other parties. To the extent applicable, please provide executable versions in native
format with all formula intact, and include workpapers.
Request No.2: In the previous ECAM filing, Case No. PAC-E-17-02, RMP presented
the results of calculated ECAM rates under two scenarios: (i) without making a contribution to
the depreciation balance (Exhibit No. 3), and (ii) under the alternative rate plan which provided
$4 million towards the amortization of the deferred depreciation balance (Exhibit No. 5). Please
provide similar exhibits for this ECAM filing under the two scenarios, that is, with and without
making a S4 million contribution to the depreciation balance.
Request No. 3: [n the previous ECAM filing, Case No. PAC-E-17-02, RMP offered an
"alternative rate plan", however, it appears in this filing that RMP is not offering an
"alternative", but instead desires to maintain last year's "alternative rate plan" in place for
MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY
MOUNTAIN POWER. 1
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
another year. [s it RMP's belief that the 2017 "alternative rate plan" agreed to by the parties and
ordered by Commission was for more than a single year? Please fully explain your response.
Request No.4: Please provide all workpapers identiffing the incremental changes to the
Commission approved depreciation deferral from January 2014 through December 2018 (as
estimated) showing amounts debited and credited to the balance. Please provide workpapers in
Excel format with formulae intact.
DATED this 24th day of April, 2018.
RACINE, OLSON, NYE
& BUDGE, CHARTERED
By:
MONSAI\TO COMPANIY',S FIRST SET OF DATA REQT ESTS TO ROCKY
MOUNTAIN POWER - 2
D,,lra B,/bD"
RANDALL C. BUDGff'
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 24th day of April,2Ol8,I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Diane Hanian, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail: diane.holt@puc. idaho. gov U.S. Mail + Email
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
Email : ted. weston@fracifi com.com E-Mail
Yvonne R. Hogle,
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
salt Lake city, Utah 84116
Telephone: [phone]
Email: yvonne.ho gle@naci fi corp. com E-Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
datarequest@paci fi corp. com E-Mail
Brubaker & Associates
16690 Swingley Ridge Rd #140
Chesterfield, MO 63017
[e-mail]
[e-mail]
E-Mail
MONSAI\TO COMPANY',S FrRST SET OF DATA REQUESTS TO ROCKY
MOTJNTAIN POWER. 3
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RANDALL C. BUDGE
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