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Home My WebLink About20070719Monsanto to PAC 3-1 to 3-7.pdfLOUIS F. RACINE (1917-2005) WILLIAM D. OLSON W. MARCUS W. NYE RANDALL C. BUDGE JOHN A. BAILEY, JR. JOHN R. GOODELL' JOHN B. INGELSTROM DANIEL C. GREEN" BRENT O. ROCHE KIRK B. HADLEY FRED J. LEWIS MITCHELL W. BROWN ERIC L. OLSEN CONRAD J. AIKEN'" RICHARD A. HEARN, M. DAVID E. ALEXANDERtt LANE V. ERICKSON" PATRICK N. GEORGE" SCOTT J. SMITH STEPHEN J. MUHONEN BRENT L. WHITING JUSTIN R. ELLIS JOSHUA D. JOHNSON:j: JONATHON S. BYINGTON DAVE BAGLEY CAROL TIPPI VOLYN:j::j: THOMAS J. BUDGE CANDICE M. MCHUGH'" LAW OFFICES OF RACINE OLSON NYE BUDGE Be BAILEY CHARTERED BOISE OFFICE 101 SOUTH CAPITOL BOULEVARD, SUITE 208 BOISE, IDAHO 83702 TELEPHONE, (208) 39S.0011FACSIMILE' (208) 433-0167 201 EAST CENTER STREET POST OFFICE BOX 1391 POCATELLO, IDAHO 83204-1391 TELEPHONE (208) 232-6101 FACSIMILE (208) 232-6109 IDAHO FALLS OFFICE www.racinelaw.net 477 SHOUP AVENUE SUITE 203A IDAHO FALLS, ID 83402 TELEPHONE' (208) S28-6101FACSIMILE, (208) S28-6109 SENDER'S E-MAIL ADDRESS, rcb(IDracinelaw.net 'ALSO MEMBER WY & IL BARS "ALSO MEMBER UT BAR "'ALSO MEMBER CO BAR tALSO MEMBER D. C. BAR ttALSO MEMBER MO BAR :j:ALSO MEMBER IL BAR ~:j:ALSO ME!,,~ER WA BAR July 17, 2007 ::;.. Jean Jewell , Secretary Idaho Public Utilities Commission 472 W. Washington Street Boise, Idaho 83702 Dear Mrs. Jewel: Re:PA C- Enclosed for filing please find the original and three copies of Monsanto Company s Third Data Requests to Rocky Mountain Power. Thank you for your assistance. RCB:rr Enclosurescc: Service List (via e-mail) 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 , '' ;-' ,.: '' ,.' " Attorneys for Intervenor Monsanto Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR APPROVAL) OF CHANGES TO ITS ELECTRIC SERVICESCHEDULES Case No. PAC- MONSANTO COMPANY'S THIRD DATA REQUESTS TO ROCKY MOUNTAIN POWER MONSANTO COMPANY, by and through their attorneys, hereby submits this Third Data Request to Rocky Mountain Power, pursuant to Rule 225 ofthe Idaho Public Utility Commission s Rules of Procedure, IDAPA 31.01.01 , as follows: Monsanto 3-With respect to Mr. Widmer s supplemental direct testimony and Exhibit No. 42, please provide: A listing of all assumptions used in each model; Complete executable copy of each model in native format with all formulas intact; All work papers and supporting documentation for the forward price curves; and All other workpapers supporting the modeling and calculations of the value of interruptible power. Monsanto 3-2: Concerning Mr. Widmer s supplemental direct testimony and Exhibit No. 42, if not provided in response to other data requests, please provide for the "Front Office Model" the following: The generating units evaluated to calculate the value of operating reserves, the MONSANTO COMPANY'S THIRD DATA REQUEST FOR ROCKY MOUNTAIN POWER- Monsanto number of megawatt of reserves evaluated on each unit, the incremental cost for each unit and the market price. The name and incremental cost ofthe unites) selected as the unites) "in-the- money All assumptions used in determining the incremental cost of each unit evaluated including heat rates, gas prices and variable operating and maintenance expenses; The source of the market prices used in the valuation of operating reserves and the date the market price forecast was prepared; The hours (per day, per month and per year) and loads of Monsanto modeled in the valuation of operating reserves; The market price values for each hour in the year, with the particular 800 "most expensive" hours identified; The source of the market price values used in the valuation of the economic curtailment and the date the market price forecast was prepared; The derivation of the "annual average on peak market price" used for the system integrity valuation, with workpapers to show the values for each hour of each day; A description and explanation of any adjustment made in the Front Office Model for "lost revenues ; and A description, derivation, and explanation of any discount rate used in the Front Office Model. Ifthe Front Office Model was in fact used to establish the Existing Contract value of$12.4M shown in Exhibit No. 42, page 1 , please describe why the value decreased to $10.8M in 2008 and to $8.7M in 2009 and provide all supporting information. Please describe in detail how the $12.4M value in 2007 for the Existing Contract shown in Exhibit No. 42, page 1 was established, how the Front Office Model and GRID Model were utilized to establish this value and provide all supporting work papers. Concerning Mr. Widmer s supplemental direct testimony and Exhibit No. MONSANTO COMPANY'S THIRD DATA REQUEST FOR ROCKY MOUNT A1N POWER - 2 , if not provided in response to other data requests, please provide the following information with respect to the "Grid Model" evaluation: Complete copies of both Grid model runs used in the evaluation; A detailed listing of all assumptions; A copy of all standard output reports; Work papers deriving the value of the interruptible product; and A detailed explanation of how the Monsanto curtailment products are modeled in the second Grid model run. Monsanto 3-For the existing contract the Front Office Model and the GRID Model, for each year, please separately identify the values attributed to Monsanto s operating reserves economic curtailment and system integrity features. Monsanto 3-Please explain why from 2008 to 2009 the valuation of the interruptible products decreases under the Front Office Model and increases under the GRID Model and provide all supporting work papers and detail. Monsanto 3-6: PacifiCorp Pricing and Regulatory Operations Director William Griffith is quoted in the July 9, 2007 Power Week West publication with respect to the Wyoming general rate case filed June 19 2007, as stating that Wyoming industrial customers, primarily mining and other extractive industries, have told PacifiCorp they expect to add 1 000 MW of new load, of which 560 MW is expected to accrue over the next five years. Further, that the Company proposes that new large customers be priced for firm service using the same avoided costs methodology that the Wyoming Public Service Commission recently approved for new, large power generation qualifying facilities so that prices charged for new customers will be set based on the same method used to set prices paid to the new large QFs; and, that the "benefits ofthis proposal are that it will provide better price signals for new customers about the cost of serving them, and it will reduce future price impacts on our current Wyoming customers." Also, that " more accurate price signal is needed to help ensure that these anticipated new large load customers are making the most economically fuel efficient choice when obtaining new service for their new facilities." Please state: The number, size and total new load of industrial customers added in the MONSANTO COMPANY'S THIRD DATA REQUEST FOR ROCKY MOUNTAlN POWER - 3 Company s service area in Idaho in each of the last five years and the projected amounts in the next three years; Does the Company propose that new large customers in Idaho be priced for firm service using the same avoided costs methodology that the Idaho Public Utilities Commission has approved for QFs? Ifnot, please explain why. With respect to the Company s proposed rate increase in Wyoming, please indicate the percentage increase in rates the Company proposes for each customer class. Monsanto The July 9, 2007 publication of Power Week West also quotes PacifiCorp spokesman Jeff H ymus as stating that "based on actual and proj ected costs from December 31 2006, through August 31 , 2008, the Company will have invested $153 000 000 in generation transmission and distribution to serve Wyoming customers. a. Please indicate the amount the Company will have invested in Idaho in each year 2006 through 2008 in generation, transmission and distribution to serve Idaho customers. b. Break the amount invested into each category: generation, transmission and distribution; c. With respect to your answer to the previous question, indicate how much of said investments occurred in Idaho and the location ofthe balance of said investments. DATED this 17th day of July, 2007. RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED t.~ RANDALL C. BUDGE MONSANTO COMPANY'S THIRD DATA REQUEST FOR ROCKY MOUNTAlN POWER - 4 CERTIFICATE OF MAILING I HEREBY CERTIFY that on this 17th day of July, 2007, 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 3) Idaho Public Utilities Commission O. Box 83720 Boise, ID 83720-0074 E-mail: jjewell(g)puc.state.id.S. Mail Brian Dickman Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake City, Utah 84111 brian. di ckman~pacifi corp. com Mail Dean Brockbank Justin Brown Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake city, Utah 84111 dean. brockbank~pacifi corp. com Justin. brown~paci ficorp. com Mail Data Request Response Center PacifiCorp 825 NE Multnomah, Suite 2000 Portland, Oregon 97232 Fax: 503-813-6060 datarequest~pacificorp. com Mail MONSANTO COMPANY'S THIRD DATA REQUEST FOR ROCKY MOUNTAIN POWER - 5 Maurice Brubaker Katie Iverson Brubaker & Associates, Inc. 1215 Fern Ridge Parkway, Suite 208 St. Louis, MO 63141 m brubak er(ll),consul t b ai. com kiverson~consul tbai. com Mail James R. Smith Monsanto Company O. Box 816 Soda Springs, Idaho 83276 iim.r .smith~monsanto. com Mail Eric L. Olsen Racine, Olson, Nye, Budge & Bailey O. Box 1391 Pocatello, Idaho 83204-1391 elo(zv,racinelaw.net Tim Buller Agrium, Inc. 3010 Conda road Soda Springs, Idaho 83276 tbuller~agrium.com Mail J!~K $;if4 MONSANTO COMPANY'S THIRD DATA REQUEST FOR ROCKY MOUNT A1N POWER - 6