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Home My WebLink About20050531Monsanto 3rd data request PAC.pdf: :::- ', " - i \ j:" :' \::. L r..! 't '- '1....., ...., Randall C. Budge, ISB No. 1949 RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 _., L.... zoos r'i?: Y 31 At"' 1= 25 ID/\HO PUBLIC : ! T't 1-'- ' ,..., ,),H,JIC'It"'UliLI! L L..lfjj..) Ivr~ 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 SCHEDULES Case No. P AC-O5- MONSANTO COMPANY'S THIRD DATA REQUEST TO P ACIFICORP MONSANTO COMPANY, by and through their attorneys, hereby submits this Second Data Request to Pacificorp, pursuant to Rule 225 of the Idaho Public Utility Commission s Rules of Procedure, IDAP A 31.01.01 , as follows: MONSANTO DATA REQUEST NO. It. Regarding PacifiCorp s Response to IPUC Production Request 55 as to the current valuation of Monsanto Operating Reserves: Please explain the overall methodology employed by PacifiCorp to arrive at its current valuation of Monsanto Operating Reserves. What is the source of the Mona HLH ("Mona 6x 16") prices and Mona LLH ("Mona 6x8+24") prices? How often are these prices updated and by whom? Please explain the calculation for the "Mona MSu - HLH" price, and provide an example of the details of the calculation for one of the months shown (e. January 2007). What is the discount rate used in the present value calculations? Provide the equation used for the determination of the discount factors DF" MONSANTO DATA REQUEST NO. 12.Regarding PacifiCorp s Response to IPUC Production Request 55 as to the current valuation of Monsanto Operating Reserves: What is "mgetrate" and how is it used in the current valuation? Please explain why the reserve value is the difference between the Mona Msu - HLH price and marginal cost. Upon what number of hours a year of curtailment is this valuation based? Please fully explain your answer. In IPUC Case No. PAC-01-, PacifiCorp adjusted its valuation of Operating Revenues to account for revenues lost due to curtailment (see Final Order No. 29157 , page 9). Please explain whether PacifiCorp s current valuation likewise has been adjusted to account for revenues lost due to curtailment, and if so identify the amount of such adjustment and how this adjustment is perfonned in Confidential Attachment IPUC 55. MONSANTO DATA REQUEST NO. 13. Accordingto the Response to IPUC Production Request 55, PacifiCorp currently values Monsanto s Operating Reserves at $1.93 per kW-month for 95 MW, resulting in an annual value of$2.2 million ($1.93 x 000 kW per month x 12 months per year). In September 2002 in IPUC Case No. PAC-01-, PacifiCorp claimed that operating reserves for 95 MW and 288 hours of curtailment per year were valued at $4.4 million per year, once the "lost revenue adjustment proposed by PacifiCorp was eliminated per the Commission s finding. Please explain all underlying factors and cost considerations as to why PacifiCorp s current valuation is substantially below the valuation made by the Company in 2002. MONSANTO DATA REQUEST NO. 14.Regarding PacifiCorp s Response to IPUC Production Request 55 as to the current valuation of Monsanto Economic Curtailment: Please explain the overall methodology employed by PacifiCorp to arrive at its current valuation of Monsanto Economic Curtailment. Please provide the source of the Retail Rate $/MWH. Is the Retail Rate also the "strike price" of this valuation? Please explain the source of "PV 7x 16" and provide an example of the details of the calculation for one of the months shown (e., January 2007). Does this represent a flat rate for 7 days per week, 16 hours per day? How often is this updated and by whom? Please explain the source of "Mona Basis 7x16" and provide an example of the details of the calculation for one of the months shown (e., January 2007). How often is this updated and by whom? Why did PacifiCorp select the PV 7x16 price plus the Mona Basis, as adjusted by the Scalar, as the relevant market cost on which to value Monsanto economic curtailment? Please fully explain your answer. MONSANTO DATA REQUEST NO. 15.Regarding PacifiCorp s Response to IPUC Production Request 55 as to the current valuation of Monsanto Economic Curtailment: What does "Vols" stand for? Please explain the meaning of "Super Peak V ols , and provide an example of the details of the calculation for one of the months shown (e., January 2007). Please explain the meaning of "Scalar (Super peak average)", and provide an example of the details of the calculation for one of the months shown (e., January 2007). Please explain the meaning of "Intrinsic . Since Intrinsic is based upon reducing the "Market Cost" by the "Retail Rate , please confirm or deny that PacifiCorp is adjusting the economic curtailment valuation to account for revenues lost due to curtailment. Please explain "undiscountedoption" as used in determining the "Option Premium Value $/MWH". If this is a macro , please provide all supporting formulae in order to understand the steps involved. MONSANTO DATA REQUEST NO. 16.Regarding PacifiCorp s Response to IPUC Production Request 55 as to the current valuation of Monsanto Economic Curtailm en What is "QuoteDT" and how is this used in the valuation? What is "Option Delta" and how is this used in the valuation? Please explain the impact of the "expir" on the PacifiCorp s current valuation. For example, if the January 2007 "expir" amount was 0., rather than 1.769 and all other months were correspondingly lowered as well, how would this affect the valuation and specifically the "Option Delta MONSANTO DATA REQUEST NO. 17.According to the Response to IPUC Production Request 55, PacifiCorp currently values Monsanto s economic curtailment at $3.26 per kW-month for 67 MW, resulting in an annual value of$2.6 million ($3.26 x 000 kW per month x 12 months per year). In September 2092 in IPUC Case No. PAC-01-, PacifiCorp claimed that economic curtailment for 67 MW and 500 hours of curtailment per year were valued at $4.6 million per year, once the "lost revenue adjustment proposed by PacifiCorp was eliminated per the Commission s finding. Please explain all underlying factors and cost considerations as to why PacifiCorp s current valuation is substantially below the valuation made by the Company in 2002. MONSANTO DATA REQUEST NO. 18.In Final Order 29157 , the Commission found "it reasonable to eliminate the "lost revenue" adjustment proposed by PacifiCorp in its rebuttal." Please explain whether PacifiCorp continues to adjust its current valuation of Monsanto s ancillary services for "lost revenues , and if so, provide the reasoning for such an adjustment. MONSANTO DATA REQUEST NO. 19.Page 3 of the testimony ofMr. Watters references PacifiCorp s 2003 IRP: Please identify where Monsanto s contract for ancillary services is located Table C., C.2 or C.3 of the 2003 IRP. MONSANTO DATA REQUEST NO. 20.Please provide the total variable costs ($), total generation output (MWH) and unit costs ($ per MWH) associated with purchasing energy from the West Valley Project for each month in 2003, 2004 and 2005 (to date). MONSANTO DATA REQUEST NO. 2t.With respect to the West Valley Lease, please provide a detailed description of the lease costs, including purchase and termination options in three- and six-year windows and the costs associated with purchasing generation. MONSANTO DATA REQUEST NO. 22.Page 6 of the testimony of Mr. Watters references "the volatility of the power markets in recent years . Please describe in more specificity this volatility, as well as PacifiCorp s expectation of volatility over the rest of the decade. MONSANTO DATA REQUEST NO. 23.Please provide the three proposals in response to RFP 2004- X, and any report or summary generated by Lands Energy Inc. as to the three proposals and the narrowing to the 150 MW market alternative. MONSANTO DATA REQUEST NO. 24.Please provide all reports documents, workpapers or studies prepared by PacifiCorp, or on its behalf, regarding the Company s decision to rescind the first termination option of the West Valley Lease. MONSANTO DATA REQUEST NO. 25.Please provide all supporting workpapers for Exhibit No. 12 in sufficient detail that all benefits, costs and energy amounts are fully explained and documented. MONSANTO DATA REQUEST NO. 26.Please provide the total variable costs ($), total generation output (MWH) and unit costs ($ per MWH) associated with producing energy from the Gadsby Project for each month in 2003 2004 and 2005 (to date) . MONSANTO DATA REQUEST NO. 27.Page 11 of the testimony of Mr. Watters states that the Gadsby Project "gas turbines can provide ancillary services in the form of operating reserves." What value does PacifiCorp attribute to these operating reserves provided by the Gadsby Project? Please provide all supporting workpapers studies and analyses used in the valuation. MONSANTO DATA REQUEST NO. 28.Please provide the projected total variable costs ($), total generation output (MWH) and unit costs ($ per MWH) associated with producing energy from the Currant Creek Project for each month in 2005, 2006 and 2007. MONSANTO DATA REQUEST NO. 29.Please provide all workpapers analysis and studies supporting the lease payments for West Valley as described on page 5 of Mr. Watters' testimony. MONSANTO DATA REQUEST NO. 30.Please provide all workpapers analysis and studies supporting the cost of the Gadsby Project as described on page 11 of Mr. Watters' testimony. MONSANTO DATA REQUEST NO. 3t.Please provide all workpapers analysis and studies supporting the cost of the Currant Creek Phase One and Phase Two as described on page 14 ofMr. Watters' testimony. DATED this 26th day of May, 2005. RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED RANDALL C. BUDGE CER TIFI CA TE OF MAILING I HEREBY CERTIFY that on this 26th day of May, 2005 , I served a true, correct and complete copy of the foregoing document, to each of the following, via the method so indi cated: Jean D. Jewell, Secretary (original and 7) Idaho Public Utilities Commission O. Box 83720 Boise, ID 83720-0074 E-mail: jjewell~puc.state.id.S. Mail John Stewart PacifiCorp 201 South Main, Suite 2300 Salt Lake City, Utah 84140-0023 j ohn. stewart2~pacificorp. com S. Mail Data Request Response Center PacifiCorp 825 N. E. Multnomah, #800 Portland, OR 97232 datarequest~paci fi corp. com Electronically James M. Van Nostrand Stoel Rives LLP 900 SW Fifth A v., Suite 2600 Portland, Oregon 97204 jm vanno 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 Anthony Yankel 29814 Lake Road Bay Village, OH 44140 tony~yankel.net Conley Ward Attorney for Agrium Givens Pursley LLP O. Box 2720 Boise, ID 83701-2720 cew~givenspursley.com Dennis Peseau Utility Resources, Inc. 1500 Liberty St. SE, Suite 250 Salem, OR 97302 dpeseau~exci te. com R. Scott Pasley J .R. Simplot Company O. Box 27 Boise, Idaho 83707 spasley~simplot. com David Hawk J .R. Simplot Company O. Box 27 Boise, Idaho 83707 dhawk~simplot.com Timothy J. Shurtz 411 S. Main Firth , Idaho 83236 tim~idahosupreme. com Brad M. Purdy Attorney at Law 2019 N. 17th Street Boise, Idaho 83702 bmpurdy~hotmail. com S. Mail S. Mail S. Mail S. Mail S. Mail S. Mail S. Mail OL