20190109PAC to Monsanto 29-34.pdf

ROCKY MOUNTAIN
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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
January 8,2019
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE & BUDGE, CHARTERED
P.O. Box l39l:'201E. Center
Pocatello, Idaho 83204-1391
rcbg)racinelaw. net (C)
tib(rDracinelaw.net (CXW)
RE: ID PAC-E-18-08
Monsanto 2nd Set Data Request (29-34)
Please find enclosed Rocky Mountain Power's Response to Monsanto 2od Set Data Request 32.
Also provided are Attachments Monsanto 32-1, 32-2, 32-4, and 32-5 . Provided on the
Confidential CD is Confidential Attachment Monsanto 32-3.
Confidential information is provided subject to the non-disclosure agreement between Monsanto
and PacifiCorp.
Sincerely,
-1sl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Diane HaniadIPUC diane.holt(@puc.idaho.qov (C)
Edward Jewell/IPUC Edward. ieweU(aDusJdaha.cav
Ronald L. Williams/?IlC ron@.wil li amsbradburv. com (C)
Brad MullinslPIIC [e-mail] (e-mail only)
Jim Duke/PIIC i duke(didahoan.com
Kyle Williams/PtrC w i I I i amsk(gbyui. edu
Val Steiner/PIIC val. steiner(Eagrium.com
Maurice Brubaker/Ivlonsanto mbrubaker(E consultbai. com (C)
Ben Otto/ICL botto(didahoconservation.org (C)
Eric Olsen/IIPA elo(Eechohawk.com (C)
Dr. Lance Kaufinan/IIPA [e-mail] (C)
Anthony YankeVIIPA tony(Dyankel.net (C)
Matthew Gerhart/Sierra Club matt. eerhart(d,si erracl ub. ore
Ana Boyd/Sierra Club ana. boyd@ sienaclub.ore
PAC-E-I8-08 / Rocky Mountain Power
January 8,2019
Monsanto 2'd Set Data Request 32
Monsanto Data Request 32
Referring to the file provided as "Attach Monsanto l4-3 - 2018-2020 Estimated
Additions.xlsx," please answer the following:
(a) Please provide all studies, work papers, documents, etc. that support the level
of wind additions, totaling $1.136 billion over 2018-2020.
(b) Please provide all studies, work papers, documents, etc. that support the level
of wind retirements, totaling $ I .278 billion over 201 8-2020.
(c) Please provide all studies, work papers, documents, etc. that support the level
of transmission additions, totaling $1.294 billion over 2018-2020 for the wind
facilities.
Response to Monsanto Data Request 32
PacifiCorp objects to this request as overbroad, vague and not reasonably
calculated to lead to the discovery of admissible evidence. Without waiving these
objections, the Company provides the following:
(a) Please refer to Attachment Monsanto 32-1 which is the file provided to Mr.
John Spanos to support the wind plant additions. For additional information
regarding these wind plant additions the Company is providing IPUC Data
Response 30 from Docket PAC-E-17-06, as Attachment Monsanto 32-2, as
noted in this response the requested documents are considered to be highly
confidential and commercially sensitive. Please contact Ted Weston at (801)
220-2963 to make arrangements to review the documents.
(b) Please refer to Confidential Attachment Monsanto 32-3 which provides
information supporting the estimated wind retirements.
(c) Please refer to Attachment Monsanto 32-4 whrch is the file provided to Mr.
John Spanos to develop the Company's Depreciation Study. For additional
information regarding future transmission additions the Company is providing
IPUC Data Request 27, from Docket PAC-E-17-07, as Attachment Monsanto
32-5.The requested documents are considered to be highly confidential and
commercially sensitive. Please contact Ted Weston at [phone] to
make arrangements to review the documents.
Confidential information is provided subject to the non-disclosure agreement
(NDA) between Monsanto and PacifiCorp.
Recordholder: Tim Hemstreet / Kent Ipson / Rick Vail
Sponsor: To Be Determined