20070720PAC to Monsanto Set 1, 1-20.pdf

~~;~OUNTAIN 20 I South Main, Suite 2300
Salt Lake City, Utah 84111
, ,' ' ,-
July 13, 2007
Randall C. Budge
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201E. Center
Pocatello, Idaho 83204-1391
RE:PAC-07-
Monsanto Data Request Set 1 (1-20)
Please find enclosed PacifiCorp s responses to Monsanto Data Requests 1.1 - 1.20.
Provided on the enclosed CD are Attachments Monsanto 1.1, 1.2 a, 1.4 -(a-b), 1.5 , 1.6-
(a-d), 1.7, 1.8 -(a-k), 1.10 -(a-j), 1.12 -(a-c), 1.13 -(a-b), 1.14 -(a-b), 1.17 -(1-2), 1.18
and 1.20. Provided on the enclosed Confidential CD are Attachments Monsanto 1.2 b
and 1.8
If you have any questions, please feel free to call me at [phone].
Sincerely,
~~ l)(
~( p. () .
Brian Dickman, Manager
Regulation
Enclosures
Cc: James R. Smith
Katie Iverson
P AC-07 -05/Rocky M~)Untain Power
July 13, 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.
Please provide a copy of all data requests received from Commission Staff and
other parties. Please consider this to be continuing request and supplement your
response as additional requests are received.
Response to Monsanto 1st Set Data Request 1.1
See Attachment Monsanto 1.1 on the enclosed CD.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENT MONSANTO 1.
ON THE ENCLOSED CD
PAC-E-O7-05/Rocky Mountain Power
July 13 , 2007
Monsanto 1 st Set Data Request 1.2
Monsanto 1st Set Data Request 1.2
Please provide a copy of your responses to the data requests from Commission
Staff and other parties. Please consider this to be continuing request and
supplement your response as additional responses are received.
Response to Monsanto 1st Set Data Request 1.
See Attachment Monsanto 1.2 a on the enclosed CD for non-confidential
responses submitted by the company. Confidential responses are provided in
Confidential Attachment Monsanto 1.2 b, on the enclosed confidential CD
subject to the terms and conditions of the protective agreement in this proceeding.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENT MONSANTO 1.
0 N THE EN CLOSED CD
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
CONFIDENTIAL ATTACHMENT
MONSANTO 1.2 b
CONFIDENTIAL (LEVEL YELLOW)
ON THE ENCLOSED CONFIDENTIAL CD
P AC- E-07 -05/Rocky Mountain Power
July 13 , 2007
Monsanto 1 st Set Data Request 1.3
Monsanto 1st Set Data Request 1.
Please provide a copy of your responses to requests conveyed to Rocky Mountain
Power other than through formal data requests from Commission Staff and other
parties. Please consider this to be continuing request and supplement your
response as additional responses as provided.
Response to Monsanto 1st Set Data Request 1.3
All responses provided to parties in this proceeding to date are provided in
response to Monsanto Data Request 1.2. The company will supplement this
response as additional responses are provided.
P AC-07 -05/Rocky Mountain P~wer
July 13 , 2007
Monsanto 1 st Set Data Request 1.4
Monsanto 1st Set Data Request 1.
Please provide a copy of the workpapers supporting the testimony of witness
Richard Walje. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.4
See Attachments Monsanto l.4a and l.4b on the enclosed CD. There are no
additional workpapers, but the Company is providing supporting data for Mr.
Walje s testimony in response to Monsanto 2-1 through 2-14.
(A. Richard Walje is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENTS MONSANTO 1.4a & 1.
ON THE EN CLOSED CD
P AC-07-05/Rocky Mountain Power
July 13 , 2007
Monsanto 1 st Set Data R-equest 1.
Monsanto 1st Set Data Request 1.
Please provide a copy of the workpapers supporting the testimony of witness
Samuel Hadaway. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.5
See Attachment Monsanto 1.5 on the enclosed CD.
(Samuel C. Hadaway is expected to sponsor this response at hearing.
IDAHO
P A C- E-07 -
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENT MONSANTO 1.
ON THE ENCLOSED CD
P AC- E-07 -05/Rocky Mountain Power
July 13 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.
Please provide a copy of the workpapers supporting the testimony of witness
Bruce Williams. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.6
Please see Attachments Monsanto 1.6 a-d on the enclosed CD.
(Bruce N. Williams is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENTS MONSANTO
6 a through 1.6 d
ON THE ENCLOSED CD
P AC-07 -05/R~cky Mountain Power
July 13, 2007
Monsanto 1st Set Data Request 1.
Monsanto 1st Set Data Request 1.7
Please provide a copy of the workpapers supporting the testimony of witness
Steven McDougal. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.
The revenue requirement workpapers supporting the direct testimony of Steven R.
McDougal are provided as Exhibits 11 , 12 and 13 , already provided with the
filing. Attached are executable copies of Exhibit 13, the JAM model, and the
RAM model. They are all provided on the enclosed CD as Attachment Monsanto
1.7. The JAM and RAM models can be run for both Rolled-In and Revised
Protocol methodologies.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENT MONSANTO 1.
ON THE ENCLOSED CD
P AC- E-07 -OS/Rocky Mountain Power
July 13 , 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.
Please provide a copy of the workpapers supporting the testimony of witness
Mark Widmer. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.8
The requested information is provided as non-confidential Attachments Monsanto
8a through 1.8k and Confidential Attachment Monsanto 1.8L on the enclosed
CDs. Company forecasts of market prices are confidential and are provided as
Confidential Attachment Monsanto 1.8L subject to the terms and conditions of the
protective agreement in this proceeding.
(Mark T. Widmer is expected to sponsor this response at hearing.
IDAHO
PAC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENTS MONSANTO
8 a through 1.8 k
0 N THE EN CLOSED CD
IDAHO
P A C- E-07 -
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
CONFIDENTIAL ATTACHMENT
MONSANTO 1.8 I
CONFIDENTIAL (LEVEL YELLOW)
ON THE ENCLOSED CONFIDENTIAL CD
PAC-07-05/Rocky Mountain Power
July 13, 2007
Monsanto 1st Set Data Request 1.
Monsanto 1st Set Data Request 1.9
Please provide a copy of the workpapers supporting the testimony of witness
William Fehrman. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.9
Mr. Fehrman s testimony was filed in support of the company s new supply-side
resources and relies on the Integrated Resource Plan, Requests for Proposals, and
other analyses provided in response to IPUC Staff Audit Request 67 in this
proceeding. The response to IPUC 67 includes citations to the 2003, 2004, and
2007 IRPs, copies of RFP 2003A and RFP 2003B, final reports on RFP 2003A
and RFP 2003B, and additional supporting documents for Lake Side and the new
wind resources. A copy of the response to IPUC 67 is included in the company
response to Monsanto 1.2 in this set. Supporting documents for the Blundell
Bottoming Cycle will be provided in response to Monsanto request 2.32.
Following is a clarification of Mr. Ferhman s testimony regarding operation and
maintenance costs for the Lake Side (page 8, line 14) and Leaning Juniper 1 (page
, line 5) resour~es. The dollar amounts referenced in the filed testimony are the
incremental O&M costs above 2006 historical levels. The total 2007 O&M cost
for all resources supported by Mr. Fehrman is detailed on Page 4.10.1 of
Company witness Steven McDougal's Exhibit No. 11.
(William J. Fehrman and Steven R. McDougal are expected to sponsor this
response at hearing.
P AC-07-oS/Rocky Mountain Power
July 13, 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.10
Please provide a copy of the workpapers supporting the testimony of witness
Douglas Bennion. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.10
See the following attachments on the enclosed CD:
Attachment Monsanto 1. lOa (Transmission System Planning 5-year Study Guide
2006)
Attachment Monsanto 1.10b (Asset replacements)
Attachment Monsanto 1.10c (5-year study)
Attachment Monsanto 1.10d (Greg Abel RMP Customer & Community
Conference - 2007)
Attachment Monsanto 1.10e (Idaho Service Quality Review 4/1/2006-6/30/2006
Report)
Attachment Monsanto 1.10f(Idaho New Connects)
Attachment Monsanto 1. 109 (Line and Feeder Design Criteria)
Attachment Monsanto 1.10h (Planning Standards for Voltage)
Attachment Monsanto 1.10i (Sample Costs Comparison of Large Material Items)
Attachment Monsanto 1.10j (RMP Dee 2006 statistics)
(Douglas N. Bennion is expected to sponsor this response at hearing.
IDAHO
P A C- E-07 -
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENTS MONSANTO
10 a through 1.10 j
ON THE ENCLOSED CD
P AC-07 -OS/Rocky Mountain Power
July 13, 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.
Please provide a copy of the workpapers supporting the testimony of witness
Erich Wilson. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.11
There are no additional workpapers.
(Erich D. Wilson is expected to sponsor this response at hearing.
PAC-07-0S/Rocky Mountain Power
July 13, 2007
Monsanto 1st Set Data Request 1.
Monsanto 1st Set Data Request 1.
Please provide a copy of the workpapers supporting the testimony of witness
Mark Tucker. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.
Attachment Monsanto 1.12a on the enclosed CD is the Cost of Service model
used in this case. This is the source for Exhibits 28 and 29, and for Tabs 4 and 5
of Exhibit 30.
Attachment Monsanto 1.12b on the enclosed CD shows the calculation of the
functional factors used in the cost of service study. This is the source of Exhibit
30, Tab 3.
Attachment Monsanto 1.12c on the enclosed CD is the source document for
Exhibit 30, Tab 1.
Exhibit 30, Tab 2 - Functionalized Results of Operations comes from the
Jurisdictional Allocation Model which is being provided as an attachment to
Monsanto 1-
(Mark E. Tucker is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENTS MONSANTO
12 a through 1.12 c
ON THE ENCLOSED CD
P AC-E-O7-0S/Rocky Mountain Power
July 13, 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.
Please provide a copy of the workpapers supporting the testimony of witness
William Griffith. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.13
Attachment Monsanto 1.13a on the enclosed CD contains the data and
calculations used in developing Exhibits 31 , 34 and 35. This file also shows the
calculation of the new rates shown in Exhibits 32 and 33.
Attachment Monsanto 1.13 b on the enclosed CD contains the data used to
calculate the percentage change in Rocky Mountain Power rates compared to the
Consumer Price Index as described in Mr. Griffith's testimony.
(William R. Griffith is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENTS MONSANTO
13 a through 1.13 b
ON THE ENCLOSED CD
PAC-07-0S/Rocky Mountain Power
July 13, 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.
Please provide a copy of the workpapers supporting the testimony of witness
Carole Rockney. To the extent that the workpapers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Monsanto 1st Set Data Request 1.14
See Attachments Monsanto 1.14a and 1.14b on the enclosed CD.
(Carole A. Rockney is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENTS MONSANTO
14 a through 1.14 b
ON THE EN CLOSED CD
P AC- E-,O7 -OSlRocky Mountain Power
July 13 2007
Monsanto 1st Set Data Request 1.
Monsanto 1st Set Data Request 1.
If not included in the responses to other data requests, please provide the
jurisdictional allocation models in executable native format with all formulas
intact. Please include the allocations for both the Rolled-In and the Revised
Protocol.
Response to Monsanto 1st Set Data Request 1.15
The jurisdictional allocation models in executable format with all formulas intact
are provided as Attachment Monsanto 1.7. Both the JAM and RAM models can
be run for both the Rolled-In and Revised Protocol methodologies.
(Steven R. McDougal is expected to sponsor this response at hearing.
P AC- E-07 -OS/Rocky Mountain Power
July 13 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.16
If not included in the responses to other data requests, please provide the class
cost of service allocation model in executable native format with all formulas
intact. Please include the allocations for both the Rolled-In and the Revised
Protocol.
Response to Monsanto 1st Set Data Request 1.16
The Idaho Cost of Service model is included as Attachment Monsanto 1.12a.
This model uses MSP Revised Protocol allocations. Separate cost of service
allocations for Rolled-In are no longer calculated in any of the company
jurisdictions.
(Mark E. Tucker is expected to sponsor this response at hearing.
P AC-07 -05/Rocky Mountain Power
July 13, 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.17
Please provide Monsanto s actual hourly load data for the test year and all
adjustments made to that actual hourly load data for purposes of:a, The jurisdictional allocationsb. The class cost of service allocations
Response to Monsanto 1st Set Data Request 1.17
Monsanto s actual hourly load data for the 12 months ended December 31 , 2006
is provided as Attachment Monsanto 1.17 -Ion the enclosed CD.
a. Adjustments made to Monsanto s actual hourly load for Coincident Peak and
Energy Factor adjustments is provided as Attachment Monsanto 1.17 -2 on the
enclosed CD.
b. The Total Curtailment MWh Adjustment and Total Curtailment MW
Adjustment figures shown in Attachment Monsanto 1.17 -2 are used in the
cost of service study to develop energy- and demand-related allocation
factors. The cost of service model is included as Attachment Monsanto 1.12a.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENTS MONSANTO
17 -1 through 1.17 -
ON THE ENCLOSED CD
PAC-Q7-05/Rocky M~untain Power
July 13, 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.18
If not provided in response to other data requests, please provide all workpapers
and supporting data showing the derivation of each external allocation factor for
both the Rolled-In and Revised Protocol versions of the jurisdictional allocation
models.
Response to Monsanto 1st Set Data Request 1.18
The derivation of each external allocation factor for the Revised Protocol version
ofthe jurisdictional models is provided as hard copy in the direct testimony of
Steven R. McDougal, Exhibit 11 , tab 10. An electronic copy is provided as
Attachment Monsanto 1.7 "JAM-Idaho GRC-Dec2006.xls " tab "Factors.
The derivation of each external allocation factor for the Rolled-In version of the
jurisdictional models is provided as Attachment Monsanto 1.18 on the enclosed
CD. An electronic copy is provided as Attachment Monsanto 1.7 "JAM-Idaho
GRC-Dec2006.xls tab "Factors.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
P A C- E-07 -
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENT MONSANTO 1.
ON THE ENCLOSED CD
P AC-07 -()5/R-ocky Mountain Power
July 13 2007
Monsanto 1 st Set Data Request 1.
Monsanto 1st Set Data Request 1.19
If not provided in response to other data requests, please provide all workpapers
and supporting data showing the derivation of each external allocation factor for
both the Rolled-In and Revised Protocol versions ofthe class cost of service
allocation models.
Response to Monsanto 1st Set Data Request 1.19
The derivation of external allocation factors used in the cost of service model is
provided as Attachment Monsanto 1.12b. All other allocation factors are
calculated within the Cost of Service model.
(Mark E. Tucker is expected to sponsor this response at hearing.
PAC-07-0S/Rocky Mountain Power
July 13, 2007
Monsanto 1st Set Data Request 1.
Monsanto 1st Set Data Request 1.20
If not provided in response to other data requests, please provide the filed exhibits
in executable native format with all formulas intact, where available.
Response to Monsanto 1st Set Data Request 1.20
Please see Attachment Monsanto 1.20 on the enclosed CD.
(Samuel C. Hadaway, Bruce N. Williams, Steven R. McDougal, Mark T.
Widmer, William J. Fehrman, Erich D. Wilson, Mark E. Tucker, William R.
Griffith, and Carole A. Rockney will sponsor this response at hearing.
IDAHO
P A C- E-07 -
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 1 (1-20)
ATTACHMENT MONSANTO 1.
ON THE ENCLOSED CD