20050701Comments and Objections.pdf

EC~EIVED LZJ
Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
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Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ACIFICORP DBA UTAH POWER & LIGHT
COMP ANY FOR APPROVAL OF CHANGES
TO ITS ELECTRIC SERVICE SCHEDULE
Case No. PAC-O5-
COMMENTS AND OBJECTIONS OF MONSANTO COMPANY
Comes now Intervenor Monsanto Company ("Monsanto ), through counsel, and submits
the following comments and objections regarding the proposed settlement Stipulation submitted
to the Commission for approval. This is intended to set forth Monsanto s position with respect
to the settlement of this case and to provide Monsanto s requested changes to the proposed
Stipulation. Monsanto s current rates are not directly impacted by this case because they are set
through December 31 , 2006 by contract approved by the Commission. Notwithstanding,
Monsanto has a direct and substantial interest in this case as P acifi Corp s largest customer and
because the cost of service study, allocation methods, and test year, adopted for other customers
may impact future rate proceedings affecting Monsanto s subsequent contracts and rates.
First, Monsanto makes clear it has no objection to the proposed $5.75 million "black
box" settlement spread uniformly to tariff customers and other relevant provisions so long as
they address issues actually presented by PacifiCorp s filing, are fair, just and reasonable to all
parties, do not prejudice or impair the rights and interests of any individual party and are
unanimously agreed to. However, as the Commission noted in its Notice regarding this proposed
stipulation, Monsanto specifically objects to ~9 of the Stipulation, a provision that addresses
COMMENTS AND OBJECTIONS OF MONSANTO COMPANY - 1
special contract customers and how their rates may be changed. Consequently, Monsanto
comments on its objection to the proposed Stipulation focus primarily on ~9, to wit:
Staff and the Company agree that all of the Company s Idaho customers should
be served under the tariff standard. In any future proceedings involving Company
customers seeking electric service under a special contract, Staff will support the
position that any service contract should be pursuant to the tariff standard rather
than the contract standard. Other Parties to the Stipulation that participate in such
proceedings shall support or not oppose this position. The Commission is not
bound by any agreement of the Parties on this issue in any such proceedings
PacifiCorp s ~9 is a purposeful attempt to get Staff and all other parties to support tariff
rates and reject contract rates for Monsanto. This paragraph without question should be deleted.
This provision is extremely objectionable and highly inflammatory, purports to settle an issue
never raised or presented in PacifiCorp s filing or by any other party in this case, is entirely
irrelevant to the settlement and premature for discussion of Monsanto s subsequent contract.
Monsanto urges the Commission and other parties to support removal of paragraph 9, as well as
the other minor changes suggested by Monsanto. The reasons are summed up as follows:
(1) Whether Monsanto should be served under contract or tariff rates in future
proceedings is not an issue presented in this case, and is not a part ofPacifiCorp s filing.
Accordingly, it is improper and violates due process to address and include in a settlement
Stipulation an issue never presented by the Applicant PacifiCorp to the Commission for
determination. This is particularly onerous where the only party impacted by the provision
objects.
Monsanto has continuously received electric service via special contract rates since 1951
some 54 years. PacifiCorp does not have any tariff rates in Idaho applicable to large industrial
users. The last industrial tariff Schedule No. 13 was eliminated in 1990 when PacifiCorp Sr.
Vice President John A. Bohling wrote the Commission stating:
Utah Power would prefer to see the schedule eliminated and hereby
makes that request to the commission. Schedule No. 13 for large
industrial services has never been used by any customer. Currently
there are no customers on it and in the future any customers who
would qualify, having loads over 15 000 KW, would be provided
for under a special contract.
COMMENTS AND OBJECTIONS OF MONSANTO COMPANY - 2
This case presents neither the time or place to consider eliminating special contract rates or
establishing new industrial tariffs. Such issues involve many factors and warrant thorough
analysis and a full opportunity for debate, neither of which are appropriate at this time.
(2) Paragraph 9 of the Stipulation is an improper and unlawful collateral attack on the
Commission s Order No. 29517 in the Monsanto rate case, Docket No. P AC-01-16 approving
Monsanto s special contract, an Order that was never appealed by PacifiCorp. The Commission
specifically rejected PacifiCorp s request for a tariff standard stating as follows:
The Commission finds the tariff standard proposed by the Company to be
unreasonable.The Commission finds that the contract, apart from authorized re-
openers, should be subject to the public interest contract standard as set forth in
the Agricultural Products case Agricultural Products v. Utah Power Light Co.,
98 Idaho 23, 557 P.2d 617 (1976). Under this doctrine, approved contract rates
cannot be changed during the contract term unless we find that a change in rates is
necessary to prevent an adverse affect on the public interest." Final Order No.
29157 , p. 15, (emphasis added).
(3) Since ~9 seeks to prejudge treatment of Monsanto in subsequent contracts, it further
expressly violates the Stipulation and Commission s Order No. 29708 issued on November 5
2004 in the MSP case relating to inter-jurisdictional issues affecting PacifiCorp, Docket No.
P AC-02-3. While the MSP Stipulation and Agreement claims that Monsanto current rates
would not be affected by any rate change in the 2005 general rate proceeding, PacifiCorp has
circumvented the MSP Stipulation by inclusion of~9 which prejudges Monsanto subsequent
rates will be tariff-based. The Stipulation and Agreement provided in ~2( d) as follows:
PacifiCorp s largest Idaho customer, Monsanto, is currently served under
a Special Contract. The current contract expires December 31 2006. Monsanto
current rates are established by contract and, therefore, not affected by this
Stipulation, by the surcharge related to Docket P AC-03-, or by any rate change
established in the anticipated general rate proceeding in calendar year 2005.
(emphasis added)
Additionally, paragraph 6(b) provided:
F or purposes of establishing Monsanto s cost of service for subsequent Special
Contracts, the Company s Idaho revenue requirement will be calculated consistent
with the Rate Mitigation Mechanism described in subsection (a) above. This
COMMENTS AND OBJECTIONS OF MONSANTO COMPANY - 3
Stipulation does not preiudge how or over what timeframe Monsanto s cost of
service will be established and no parties waive any arguments with respect
thereto." (emphasis added).
By prejudging in this general rate proceeding that Monsanto will have no subsequent
Special Contract (as evidenced by agreeing that all Idaho customers should be served under the
tariff standard), PacifiCorp has gone beyond the issues of the present general rate case. The very
purpose intended by PacifiCorp in ~9 is to obligate Staff and the other parties to prejudge how
Monsanto s rates would be established in the future.
(4) Paragraph 9 is irrelevant to this case and unnecessary for the purposes of the
Stipulation and settling all issues properly presented by PacifiCorp in its filings. The
elimination of~9 will not diminish or detract from the other provisions of the settlement, namely
the revenue increase or rate spread. "Blackbox" settlements often involve compromises between
the various parties to a case. Monsanto did not question the amount or allocation of the proposed
settlement values that impact the other customers. It, therefore, is simply not proper business
protocol for other customers to agree to unsupported positions which adversely affect only
Monsanto.
(5) The Stipulation already identifies in ~8 the issue relating to the treatment of including
or excluding Monsanto as a Special Contract customer in the Idaho Class Cost of Service Study
and provides that such issues will be addressed in the next general rate case to be filed in 2006.
PacifiCorp s only real motive for adding the unnecessary ~9 is to leverage the other parties
pressure the Commission and try to position itself more favorably for purposes of future contract
negotiations and rate proceedings affecting Monsanto s subsequent contracts and rates. It is an
unabashed strategic move that has no purpose other than to garner future leverage.
To demonstrate Monsanto s good faith attempt to address these issues, Monsanto
presented to parties a "redline" revised draft of the proposed Stipulation reflecting changes
requested by Monsanto which would enable it to be a signatory party. This "redline" is attached
to Monsanto s comments for the Commission s information. Minor changes are made to ~8 to
accurately characterize the issue relating to the treatment of including or excluding Monsanto in
the Idaho Class Cost of Service Study.
Monsanto is happy to join in the proposed Stipulation with the requested changes as
COMMENTS AND OBJECTIONS OF MONSANTO COMPANY - 4
shown in our redline. If these changes are not made however, then Monsanto strenuously
opposes the settlement and urges the Commission to strike ~9 in its entirety.
DATED this 30th day of June, 2005.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
RANDALL C. BUDGE
COMMENTS AND OBJECTIONS OF MONSANTO COMPANY - 5
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 30th day of June, 2005 , 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
O. Box 83720
Boise, ID 83720-0074
E-mail: jjewell~puc.state.id.Overnight Mail
John Stewart
P acifi Corp
201 South Main, Suite 2300
Salt Lake City, Utah 84140-0023
j 000. stewart2~pacificorp. com
S. Mail
Data Request Response Center
PacifiCorp
825 N. E. Multnomah, #800
Portland, Oregon 97232
datarequest~pacificorp. com Electronically
James M. Van Nostrand
Stoel Rives LLP
900 SW Fifth A v., Suite 2600
Portland, Oregon 97204
j mvanno strand~stoelri ves. com
S. Mail
Scott Woodbury
Kira Pfisterer
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
scottwoodbury~puc.idaho. gov
kirapfisterer~puc. idaho. gov
S. Mail
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
O. Box 1391
Pocatello, Idaho 83204-1391
elo~racinelaw .net
S. Mail
COMMENTS AND OBJECTIONS OF MONSANTO COMPANY - 6
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
tony~yankel.net
S. Mail
Conley Ward
Attorney for Agrium
Givens Pursley LLP
O. Box 2720
Boise, ID 83701-2720
cew~givenspursley.com
S. Mail
Dennis Peseau
Utility Resources, Inc.
1500 Liberty St. SE, Suite 250
Salem, OR 97302
dpeseau~excite.com
S. Mail
R. Scott Pasley
J .R. Simplot Company
O. Box 27
Boise, Idaho 83707
spasley~simplot.com
S. Mail
David Hawk
J .R. Simplot Company
O. Box 27
Boise, Idaho 83707
dhawk~simplot.com
S. Mail
Timothy J. Shurtz
411 S. Main
Firth , Idaho 83236
tim~idahosupreme.com
S. Mail
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
bmpurdy~hotmail.com
S. Mail
RANDALL C. BUDGE
COMMENTS AND OBJECTIONS OF MONSANTO COMPANY - 7
MONSANTO "RED-LINED" 6-06 (rcb)
James M. Van Nostrand
James F. Fell
STOEL RIVES LLP
900 SW Fifth Avenue, Suite 2600
Portland, OR 97204
Telephone: [phone]
Fax: [phone]
Email: imvannostrand~stoel.com
ffell~stoel. com
Lisa Nordstrom
PacifiCorp Office of the General Counsel
825 NE Multnomah Street, Suite 1800
Portland, OR 97232
Telephone: [phone]
Fax: [phone]
Email: lisa.nordstrom~pacificorp. com
Bar Number: 5733
Attorneys for PacifiCorp dba Utah
Power & Light Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF PACIFICORP DBA
UTAHPOWER&LIGHTCOMPANY )
FOR AUTHORITY TO INCREASE ITS
RATES FOR ELECTRIC SERVICE
TO ELECTRIC CUSTOMERS IN THE STATE OF IDAHO
CASE NO. PAC-O5-
STIPULATION
This stipulation ("Stipulation ) is entered into by and among PacifiCorp, doing business
as Utah Power & Light Company ("PacifiCorp" or the "Company ), the Idaho Public Utilities
Commission Staff ("Staff'), the Idaho Irrigation Pumpers Association, Inc. ("IIP
),
Agrium
I Inc. ("Agrium
),
R. Simp lot Company ("SimploC'!,
' ,,
1\::I?~S~~~Oc;~l~r~I1Y
-- ,,' ,.. "" " , " " " ,
STIPULATION - Page
Portlnd3-1517347.90020017-00072
, ,
i Deleted: "
'" ... "
Mol1santo Community Action Partnership Association of Idaho ("CAPAI") and Timothy
Shurtz ("Shurtz ) (collectively referred to as the "Parties
I. INTRODUCTION
The terms and conditions of this Stipulation are set forth herein. The Parties
agree that this Stipulation represents a fair, just and reasonable compromise of the issues raised
in this proceeding and that this Stipulation is in the public interest. The Parties, therefore
recommend that the Public Utilities Commission ("Commission ) approve the Stipulation and all
of its terms and conditions. Reference IDAPA 31.01.01.272 274.
II. BACKGROUND
On January 15 2005, PacifiCorp filed an Application in this case, seeking
authority to increase the Company s base rates for electric service by $15.1 million annually, an
average increase of approximately 12.5%. The increase in base rates would vary by class of
customer and actual usage. The proposed increase is offset in part by the expiration of the Power
Cost/Tax Surcharge in September 2005. The revised tariff schedules reflect a net increase of
$11.4 million (9.2%) and a proposed effective date of September 16, 2005.
Petitions to intervene in this proceeding were filed by Monsanto Company, lIP A
Agrium, Simplot, CAP AI, and Shurtz. By various orders, the Commission granted these
interventions.
Following a May 4 2005 Notice of Staff Intent to Engage in Settlement
Discussions (IDAPA 31.01.01.272), representatives of the Parties met on May 16 and engaged in
initial discussions with a view toward resolving PacifiCorp' s Application in this case.
Based upon the settlement discussions among the Parties, as a compromise of the
positions in this case, and for other consideration as set forth below, the Parties agree to the
following tenns:
STIPULATION - Page 2
Portlnd3-1517347.90020017-00072
ID. TERMS OF THE STIPULATION
PacifiCorp shall be allowed to implement revised tariff schedules designed to
recover $5.75 million in additional annual revenue from base rates, representing an aggregate
base rate increase of 4.8%. Such revised tariff schedules shall become effective as of
September 16, 2005, contemporaneously with the expiration of the Power Cost/Tax Surcharge
(Schedule 93) currently appearing on customers ' bills. (Order No. 29518) All regulatory assets
and liabilities included in PacifiCorp' s filing are unadjusted and recognized for purposes of this
settlement.
The Parties agree that this revenue requirement results in a unifonn 1.7% rate
increase above current rates whether or not such current rates include Schedule 93, Power
Cost/Tax Surcharge and Schedule 94, Rate Mitigation Adjustment. The overall increase will be
reflected in base rate tariffs filed for each customer class.
This Stipulation implements the Revised Protocol jurisdictional cost allocation
methodology in Idaho. In Case No. P AC-02-, Order No. 29708, the Commission approved a
Stipulation and Agreement ("MSP Stipulation ) recommending implementation of Revised
Protocol. The MSP Stipulation included a Rate Mitigation Measure to limit the financial impact
regarding the choice of allocation methodology. Under the Rate Mitigation Measure, the impact
of implementation of Revised Protocol was limited to 101.67 percent of the rates that would have
resulted from use of the Rolled-In method. As a result of application of the Rate Mitigation
Measure, the Company s original filing in this case was reduced by $1.8 million below what it
would have been without application of the Rate Mitigation Measure. The Parties support
continued use of the Revised Protocol for future rate proceedings, consistent with the tenus and
conditions of the MSP Stipulation.
The Parties were unable to agree upon the treatment of including or excluding
Deleted: impact on the Company
Tv1onsanto in the Idaho class cost of service study. In Case No. P AC-01-16. In that ./Idahotuiffcustomers of the
-- - - - - -, - - -- --- -- - - - - - - ,- - - - .. - - -, - -
no - -
- -
- Conmrission s adoption ofa contract
standard for the Monsanto Company i
i Deleted: n
proceeding, the Commission approved a fixed price contract for Monsanto to remain in effect
through December 31, 2006, rIDding that the rates and charges under the contract would
STIPULATION - Page 3
Portlnd3-1517347.90020017-00072
reasonably reflect the Company s cost of service to Monsanto going forward.Order
No. 29157
p.
8. In its initial filing in this case, PacifiCorp s cost of service study allocated its
Idaho revenue requirement deficiency only to its Idaho tariffed customers eligible for an
Deleted: andIIPAincreaseits Idaho customers other than Monsanto. Staff, Inigators and Agrium
...
ol"p?~e
_, .- / /
this treatment, and argued that any revenue requirement deficiency associated with service to
Monsanto s fixed price contract should not be spread to the Company s remaning Idaho
customers. No cost of service study or treatment ofI\10nsanto is adopted either expressly or
Deleted: (i.the difference betweenimp)iedly by this Stipulation. Any such issues relating: to cost of service may be addressed in th~ ,' Monsanto s fixed price contract rates and
...- - - - - - - - ~ -
the cost of serving Monsanto if its cost of
service were updated) should not be
spread to the Company s remaining Idaho
customers. The cost of service issue is
not resolved in this Stipulation, and is
proposed to be
'( Deleted: a
Deleted: Staff and the Company agreeThis Stipulation will not be utilized or interpreted to deny Idaho customers of any
, .
that all of the Company s Idaho'O.u................, u,..,......... 'u ,..'u ,u........,
.., ,..... ,........... ,.. ,.......,...... ,.. , .....-......"...
..--,......,....._u...........,...
,...."..../
customers should be served under the
tariff standard. In any future proceedings
involving Company customers seeking
electric service under a special contract,
Staff will support the position that any
service contract should be pursuant to the
tariff standard rather than the contract
standard. Other Parties to the Stipulation
that participate in such proceedings shall
support or not oppose this position, The
Commission is not bound by any
agreement of the Parties on this issue in
any such proceedings.
next general rate case to be filed by the Company no later than April 29, 2006 in order that the
effective date of rates in that proceeding will coincide with the expiration of the current
Monsanto contract in December 2006.
potential benefit arising out of the proceedings in any state related to J\rIidAmerican Energy
Holding Com~ny s ac uisition ofP~ciflCo112:
Staff agrees to meet with the Company in a collaborative discussion to explore
development of alternative rate recovery mechanisms, including a power cost adjustment (PCA)
10.
mechanism or an alternative fonn of regulation (AFOR). The initial meeting to discuss the
development of such mechanisms shall occur no later than thirty (30) days after the
Commission s order with respect to this Stipulation. The purpose of these meetings is to discuss
the possibility of developing on an expedited schedule a mutually agreeable fonn of alternative
rate recovery mechanism that could be filed with the Commission for approval prior to the
Company s next general rate proceeding in Idaho, and implemented in such rate proceeding. All
Parties shall be provided with notice of these meetings and an opportunity to participate.
11.The Company agrees to meet with lIP A and other interested parties regarding the
calculation of credits under the Company s Schedule 72, the Irrigation Load Control Credit
Rider. The initial such meeting shall occur no later than August 31 , 2005. In the event the
STIPULATION - Page 4
Portlnd3-1517347.90020017-00072
parties reach agreement on such calculation, the Company shall prepare a stipulation setting forth
the agreed-upon terms and file such stipulation with the Commission no later than September 30
2005. In the event these parties do not reach agreement on such calculation, each party shall file
its proposal with respect to this issue with the Commission no later than September 30, 2005 in
order to accommodate a Commission decision that will not delay the scheduled January 15, 2006
customer notification of the credit level for the 2006 irrigation season.
12.To increase customer participation and available incentives for installation of
additional cost-effective weatherization measures, PacifiCorp will file revisions to its Low
Income Weatherization Program tariff (Schedule 21). Specific proposed program and tariff
changes will include increasing the available annual Community Action Agency incentives from
$100 000 to $150 000 annually. The Company will also propose to increase the rebate on
weatherization services available on homes with installed electric heat from the current
maximum of$I OOO per dwelling to an average annual rebate of$I 500 per dwelling. In
addition, the Company will propose to increase the administrative reimbursement provided to
Community Action Agencies from $150 per completed home to 15 percent ofPacifiCorp
rebate on installed measures with set maximums. The Company will also propose to expand its
current program incentives by offering reimbursement of 50 percent of costs associated with
additional measures installed in homes regardless of heating source, including compact
fluorescent light bulbs, replacement refrigerators and water heating measures in homes with
electric water heaters. To promote installation of efficiency measures that have become cost-
effective in the last decade, PacifiCorp will propose to offer rebates for homes in which benefits
were provided under this tariff prior to October 1, 1993, once per individual measure and up to
two times per dwelling. The Company will evaluate this tariff (Schedule 21) within two years to
determine if further revisions are warranted.
13.The Parties agree that this Stipulation represents a compromise of the positions of
the Parties in this case. Other than the above referenced positions and any testimony filed in
STIPULATION - Page 5
Portlnd3-1517347.90020017-00072
support of the approval of this Stipulation, and except to the extent necessary for a Party to
explain before the Commission its own statements and positions with respect to the Stipulation
all negotiations relating to this Stipulation shall not be admissible in evidence in this or any other
proceeding regarding this subject matter.
14.The Parties submit this Stipulation to the Commission and recommend approval
in its entirety pursuant to IDAPA 31.01.01.274. Parties shall support this Stipulation before the
Commission, and no Party shall appeal any portion of this Stipulation or Order approving the
same. If this Stipulation is challenged by any person not a party to the Stipulation, the Parties to
this Stipulation reserve the right to cross-examine witnesses and put on such case as they deem
appropriate to respond fully to the issues presented, including the right to raise issues that are
incorporated in the settlements embodied in this Stipulation. Notwithstanding this reservation of
rights, the Parties to this Stipulation agree that they will continue to support the Commission
adoption of the terms of this Stipulation.
15.In the event the Commission rejects any part or all of this Stipulation, or imposes
any additional material conditions on approval of this Stipulation, each Party reserves the right
upon written notice to the Commission and the other Parties to this proceeding, within 15 days of
the date of such action by the Commission, to withdraw from this Stipulation. In such case, no
Party shall be bound or prejudiced by the terms of this Stipulation, and each Party shall be
entitled to seek reconsideration of the Commission s order, file testimony as it chooses, cross-
examine witnesses, and do all other things necessary to put on such case as it deems appropriate.
In such case, the Parties immediately will request the prompt reconvening of a prehearing
conference for purposes of establishing a procedural schedule for the completion of the case.
The Parties agree to cooperate in development of a schedule that concludes the proceeding on the
earliest possible date, taking into account the needs of the Parties in participating in hearings and
preparing briefs. If necessary, the Company will extend the suspension period for such period as
is reasonably necessary to accommodate the revised procedural schedule.
STIPULATION - Page 6
Portlnd3-1517347.90020017-00072
16.The Parties agree that this Stipulation is in the public interest and that all of its
tenus and conditions are fair, just and reasonable.
17.No Party shall be bound, benefited or prejudiced by any position asserted in the
negotiation of this Stipulation, except to the extent expressly stated herein, nor shall this
Stipulation be construed as a waiver of the rights of any Party unless such rights are expressly
waived herein. Execution of this Stipulation shall not be deemed to constitute an
acknow ledgment by any Party of the validity or invalidity of any particular method, theory or
principle of regulation or cost recovery. No Party shall be deemed to have agreed that any
method, theory or principle of regulation or cost recovery employed in arriving at this Stipulation
is appropriate for resolving any issues in any other proceeding in the future. No findings of fact
or conclusions of law other than those stated herein shall be deemed to be implicit in this
Stipulation.
18.The obligations of the Parties under this Stipulation are subject to the
Commission s approval of this Stipulation in accordance with its tenus and conditions and upon
such approval being upheld on appeal by a court of competent jurisdiction.
Respectfully submitted this 10th day of June, 2005.
PacifiCorp Idaho Public Utilities Commission Staff
Scott D. Woodbury
Kira Dale Pfisterer
Attorneys for Idaho Public Utilities
Commission Staff
James F. Fell
James M. Van Nostrand
Stoel Rives LLP
Attorneys for PacifiCorp
STIPULATION - Page 7
Portlnd3-1517347.90020017-00072
Idaho Irrigation Pumpers Association
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chartered
Attorney for Idaho Irrigation Pumpers
Association
R. Simplot Company
R. Scott Pasley
Assistant General Counsel
Timothy Shurtz
STIPULATION -Page 8
Portlnd3-1517347.90020017-00072
Agrium, Inc.
Conley E. Ward
Givens Pursley LLP
Attorney for Agrium, Inc.
Community Action Partnership
Association of Idaho (CAP AI)
Brad M. Purdy
Attorney at Law
Monsanto Company
Randall C. Budge