20160309Comments.pdf

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TIATT;RNEYS RECEIVED
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March 9, 2016
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 83720-007 4
Re: IPUC Case No. PAC-E-16-05
Dear Ms. Jewell:
RANDALL C. BUDGE
[e-mail]
Hand Delivered
Enclosed you willfind the original and seven (7) copies ol Comments of
Monsanto Company. Please file the same with the Commission's records. lf you
have any questions, please don't hesitate to call.
Thank you.
RCB:tscc: Service List
Sincerely,
2O1 E. Center St. I
P: (2O8) 232-6101 I
P.O Box 1391 I Pocatello, lD 83204
F: (2OB) 232-6109 I racinelaw.net Offices in Boise, Pocatello, and ldaho Falls
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box l39l;201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
[e-mail]
Attomeys for Intervenor Monsanto Company
IN TIIE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER
REQUESTTNG APPROVAL OF THE $16.7
MILLION NET POWER COST DEFERRAL
AND AUTHORITY TO DECREASE RATES
BY $9.0 MILLION
REC E IVED
2OI6 HfiR
CASE NO. PAC.E.16-05
COMMENTS OF
MONSAI\TO COMPAIYY
-9 PH l: ll
i i-,uijllc: iiLrfilL{lSSl0N
BEFORE THE IDAI{O PUBLIC UTILITIES COMMISSION
INTRODUCTION
COMES NOW lntervenor Monsanto Company ("Monsanto") through counsel and
submits these Comments with respect to the February L,2016 Application of PacifiCorp, dlbla
Rocky Mountain Power ("Company') seeking authorization to decrease rates by $9.0 million to
recover deferred net power costs through the Energy Cost Adjustment Mechanism (ECAM).
Monsanto's Comments are in response to the Commission's Order No. 33467 dated February 10,
201.6, giving notice of the Application, that this matter will proceed under Modified Procedure,
authorizing interested persons to file written comments in support or opposition, and providing
rights or participation by filing a Petition to Intervene. Monsanto's Petition to Intervene was
granted by Order No. 33469.
BACKGROUND
Monsanto owns and operates phosphate mines in Caribou County, Idaho together with a
plant in Soda Springs which produces elemental phosphorus utilizing three electric furnaces.
COMMENTS OF MONSAIiITO COMPAIIY.1
Elemental phosphorus becomes the primary building block for the active ingredient glyphosate
in Roundup herbicide, the foremost weed-control agent in the world. Monsanto's Soda Springs
plant is Idaho's single largest user of electricity and the largest single user on the PacifiCorp
system with a load of approximately 180 megawatts (MW) using 1.4 million MW-hours per
year. Monsanto has continuously been a special contract customer of PacifiCorp since plant
operations began in 1951.
The Company provides electric service to Monsanto pursuant to an Electric Service
Agreement effective January 1,2016 for a2-year term ("Agreement") and Idaho Electric Service
Schedule 400. Pursuant to the Agreement, Monsanto receives firm and intemrptible power and
energy. Monsanto's intemrptible products provide the Company with up to 188 hours of
operating reserves intemrptions at 95 MW, up to 12 hours of system integrity intemrptions at
162 MW and up to 500 hours economic curtailments at 67 MW. Monsanto receives an
intemrptible credit for these intemrptions. While Monsanto's rates are fixed pursuant to the
Agreement, they remain subject to annual ECAM adjustments like all other customers.
MONSANTO COMMENTS
Monsanto has reviewed the testimony and exhibits in this case and supports the decrease
in rates. In particular, we would like to point out that as a result of the alternative payment
structure approved in the previous ECAM, Monsanto's prior deferral balance will be completely
paid off by March 31,2016 as planned. We appreciate the Company's willingness to allow
Monsanto to structure its payments on a fixed basis to ensure timely payment of the deferred
balance, as well as avoiding any over- or under-payment of the deferred balance.
We also note that the Company has determined the various back-cast adjustments in its
Application as single one-time annual events all occurring in November 2015. Since revenues
and expenses are incurred throughout the year, it would make sense that the back-cast
adjustments would likewise be handled on a monthly basis rather than assuming a single event.
This should help alleviate the interest paid by ratepayers for the deferred balance. Monsanto
does not have a specific monetary correction to make the back-cast adjustments on a monthly
basis, but would support such a recommendation by the Commission to make such correction.
COMMENTS OF MONSAI{TO COMPAI\TY - 2
RESPECTFULLY SUBMITED this 96 day of March,2016.
RACINE, OLSON,I{YE, BUDGE &
BAILEY, CHARTERED
COMMENTS OF MONSAIYTO COMPANY. 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 9th day of March,2016,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 andT)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,lD 83720-0074
E-mail : jj ewell@Fuc. state. id.us
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 841l1
E-mail: ted.weston@pacifi corp.com
Yvonne R. Hogle
Senior Counsel
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 841I I
E-mail: [e-mail]
U.S. Mail
E-Mail
E-Mail
COMMENTS OF MONSANTO COMPANY - 4