20070725PAC to Monsanto 2-1 to 2-65.pdf

~~~:OUNTAJN 20 I South Main. Suite 2300
Salt Lake City. Utah 84111
~ ,, ';.."
July 24, 2007
Randall C. Budge
RACINE, OLSON, NYE, BUDGE &
BAlLEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
RE:PAC-07-
Monsanto Data Request Set 2 (1-65)
Please find enclosed PacifiCorp s responses to Monsanto Data Requests 2.1 - 2.65.
Provided on the enclosed CD are Attachments Monsanto 2., 2.10 a, 2., 2., 2.19
20 -(a-b), 2.21 b, 2.24, 2.27 -(a-b), 2.29 -(a-b), 2.31-(a-b), 2.32, 2.33 -(a-b), 2.35 -(a-
c), 2.36 -(a-d), 2.41 -(a-c), 2.53 -(a-d), 2.54 -(a, c), 2.58 and 2.65. Provided on the
enclosed Confidential CD are Attachments Monsanto 2.12 -(a-b), 2.16, 2.21 a and 2.40.
Responses to Monsanto Data Requests 2., 2.14, 2.44, 2.49, 2., 2., 2., 2.59 and
61 are in process and will be provided upon completion.
If you have any questions, please feel free to call me at [phone].
Sincerely,
f)lh~/h-t/
Brian Dickman, Manager
Regulation
Enclosures
Cc: James R. Smith
Maurice Brubaker
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the testimony of Mr. Walje at page 6, please provide the basis for
determining that an 80%/20% share of health insurance premium costs is the
appropriate sharing. Please provide copies of all studies, backup material
surveys, etc., relied upon.
Response to Monsanto Data Request 2.
See Wilson direct testimony beginning with page 20 line 16.
(Erich D. Wilson is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.3
Monsanto Data Request 2.
With respect to the testimony of witness Walje, page 6, please provide the studies,
analyses and surveys used to determine the appropriate change in the pension planfor non-union employees.
Response to Monsanto Data Request 2.
See Wilson direct testimony beginning with page 17 line 20 through page 18 line
9. Also, reference Exhibit No. 26 (referred to on page 17 line 23).
(Erich D. Wilson is expected to sponsor this response at hearing.
P A C- E-07 -OS/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.4
Monsanto Data Request 2.
Please state whether the level of pension expense included in the test year in this
proceeding corresponds to the change made effective on June 1 , 2007, and
whether that change has been reflected on a pro forma annualized basis for the
entire test year. If it has not been reflected on a pro forma annualized basis, what
adjustment would be required to reflect the new policy on an annualized pro
forma basis?
Response to Monsanto Data Request 2.
The pension expense included in the test year has been adjusted to that expected
in calendar year 2007, which includes the change made effective June 1 2007.
This is consistent with all other pro forma adjustments included in the case such
as wages, plant additions and net power costs. Annualized calendar year 2007
pension expense would require an actuarial study and is not available.
(Steven R. McDougal is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to pages 4 and 5 of the testimony of Mr. Walje, in particular from line
23 of page 4 through line 3 of page 5, please state whether it is Rocky Mountain
Power s position that if the Commission does not grant 100% of the requested
rate relief that Rocky Mountain Power company will be unable . . . to maintain
and provide safe and reliable service to our customers at a level they both expect
and deserve." Provide all supporting workpapers for your answer.
Response to Monsanto Data Request 2.
It is Rocky Mountain Power s position that recovering less than the prudent
expenses included in the rate case test year weakens the company s ability to
maintain and provide safe and reliable service.
(A. Richard Walje is expected to sponsor this response at hearing.
P AC- E-O7 -OS/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to page 7 of the testimony of Mr. Walje, lines 15 through 22, please
provide the studies and workpapers supporting the generation cost figures of 6.
per kWh for traditional gas combined-cycle turbines, 5.s~ per kWh for super
critical pulverized coal plants and 9~ per kWh for an IGCC plant.
Response to Monsanto Data Request 2.
PacifiCorp s current published levelized rate for a 35 year QF contract in Idaho
beginning in 2007 is 6.6 ~ per kWh. This rate is calculated based on the costs for
a gas-fired combined-cycle turbine. Please see Attachment Monsanto 2.6 for
additional detail regarding the cost of a super critical pulverized coal plant and an
IGCC plant. The costs provided in the attachment represent preliminary estimates
of future resource costs at the time the analysis was completed.
(It has not been determined who will sponsor this response at hearing.
IDAHO
P A C- E-O7 -
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.
ON THE ENCLOSED CD
P AC- E-07 -O5/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to page 8 ofthe testimony of Mr. Walje, lines 14 through 17, please
provide the year-by-year detail for the expected $16 billion capital expenditures
with a breakdown by function and identifying costs associated with major
projects. Also indicate where the information contained in your response is
reflected in the Company s most recent Integrated Resource Plan.
Response to Monsanto Data Request 2.
The requested year-by-year detail from the PacifiCorp 2006 lO-year plan for the
expected $16 billion capital expenditures is extremely confidential, price and
transaction sensitive, and commercially proprietary. The information will be
made available for review at the company s offices but cannot be copied and
cannot be removed from the company s premises. Please contact Brian Dickman
at 801-220-4975 to make arrangements to review these documents.
The 2006 10-year plan was completed while the Integrated Resource Plan
was still in progress. A highly confidential worksheet is available recapping
capital expenditure differences between the 2006 10-year plan and the final
Integrated Resource Plan filed; the difference between the two is due primarily to
additional transmission and renewable resource investments included in the recent
Integrated Resource Plan but not in the $16 billion 10-year plan capital
expenditures.
(It has not been determined who will sponsor this response at hearing.
P AC-07 -05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data R-equest 2.
Monsanto Data Request 2.
Referring to the testimony of Mr. Walje at page 11, line 19 through page 12, line
2, please state the policy guidelines and tests applied by Rocky Mountain Power
Company to determine which post-December 31 , 2006 investments and costs
should be included in the test year in this proceeding.
Response to Monsanto Data Request 2.
The guideline followed by the company regarding post-December 31 , 2006
investments in the test year was to include distinctly identified major capital
projects greater than $2 million. This $2 million threshold allows the company to
include as part of rate base approximately 70% of total capital additions scheduled
to go into service by December 31 , 2007. Capital additions for calendar year
2007 total $1 155,781 719 and are included in rate base in the direct testimony of
Steven R. McDougal, Exhibit 11 , page 8.
The company has also included some incremental costs of doing business, and
known and measurable benefits that flow through to customers. For further
explanation please refer to the direct testimony of Steven R. McDougal, page 10
line 13; and Exhibit 11 , tabs 3 through 8.
(Steven R. McDougal is expected to sponsor this response at hearing.
P AC-E-"07 -O5/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
With respect to the testimony of Mr. Walje at page 11 , line 18 through page 12
line 2, please explain and quantify what revenues for growth in usage by existing
customers and revenues from new customers has been included for post-
December 31, 2006 changes. If none was included, please explain in detail why
not.
Response to Monsanto Data Request 2.
No adjustments were made to revenues to project future growth from new or
existing customers. This case was filed using an historic test year. As such, all
revenues and loads are for the normalized 12 months ended December 31 , 2006
adjusted for known tariff changes through December 31 , 2007.
(Steven R. McDougal is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to page 13 , lines 4 through 18, of the testimony of Mr. Walje, please
provide the "before" and "after" metrics for each area where Rocky Mountain
Power company claims that improvements have been made, and provide a
quantification of the savings in cost as a result of each. In addition, please state
the amount of cost reduction reflected in the Company s test year in this case, and
identify the specific adjustments where these savings are reflected.
Response to Monsanto Data Request 2.
a. See Attachment Monsanto 2.1 Oa on the enclosed CD.
b. Specific adjustments where these savings in cost are reflected cannot be
explicitly identified and tied to the savings listed under part a. A majority of these
cost reduction savings are reflected in reduced costs during the twelve months
ended December 2006. However, various regulatory adjustments incorporate into
results of operations additional cost savings; these adjustments are shown and
explained in the direct testimony of Steven R. McDougal, Exhibit 11 , tabs 3
through 8.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
PAC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.10 a
ON THE ENCLOSED CD
P AC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
With respect to the testimony of Mr. Walje at page 13, line 19 through page 14
line 3 , please identify each commitment and provide the "before" and "after
metrics that demonstrate these improvements.
Response to Monsanto Data Request 2.
These lines in the testimony are supported by the TQS and J.D. Power customer
satisfaction research results which are provided in response to Monsanto requests
2.12 2.13 , and 2.14. The particular commitments identified are associated with
the Service Standards Program, which includes both the Customer Service
Guarantee Program and the Performance Standards Program. This was
implemented at the time of the merger with ScottishPower and provides
performance results against which the company evaluates. Particularly, the
Customer Guarantee Program addresses individual customer interactions, such as
restoration of power during routine performance. The Performance Standards
Program addresses system-level (i.e. state) performance targets the company
evaluates against, such as customer average outage duration for a year (also
excluding "major events
(A. Richard Walje is expected to sponsor this response at hearing.
PAC-t)7-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
With respect to page 14 of the testimony of Mr. Walje, lines 3 through 9, please
provide a copy of each of the TQS research reports.
Response to Monsanto Data Request 2.
The "2005 TQS National Report" is provided as Confidential Attachment
Monsanto 2.12a on the enclosed Confidential CD. The "2006 TQS National
Report" is provided as Confidential Attachment Monsanto 2.12b on the enclosed
Confidential CD. The TQS reports contain confidential information and are
provided subject to the terms and conditions of the protective order in this
proceeding.
Note that in the 2005 TQS Report, Rocky Mountain Power is not shown
separately from PacifiCorp; the relevant information is on page 35. In the 2006
TQS Report, Rocky Mountain Power is shown separately; page 28 shows Rocky
Mountain Power having 93.5% "very satisfied" customers.
(It has not been determined who will sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
CONFIDENTIAL A TT ACHMENT
MONSANTO 2.12 -(a-
ON THE ENCLOSED CONFIDENTIAL CD
PAC-07-0SlRocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
With respect to page 14 of the testimony of Mr. Walje, please provide the 2007
TQS research report when it becomes available.
Response to Monsanto Data Request 2.
The full TQS report expected to be published in the month of August 2007. A
specific date has not been announced. See "TQS-RMP results 2003 - 2007
provided as Attachment Monsanto 2.13, which shows Rocky Mountain Power
with 88% "very satisfied" customers in 2007.
(It has not been determined who will sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.
ON THE ENCLOSED CD
PAC-07-0S/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the testimony of Mr. McDougal, beginning at line 12, please provide
the following growth statistics for the last 10 years, and as forecasted for the next
10 years, in total and by jurisdiction.a. Annual summer peak megawatt demand, and winter peak megawatt
demand and annual megawatthour sales;
Annual megawatt change and percentage change in summer peak demand
each year;
Annual megawatt change and percentage change in winter peak demand
each year; and
Annual megawatthour change and percentage change in energy sales each
year.
Response to Monsanto Data Request 2.
A page reference is not given in this question. For purposes of this response, the
company assumes the question intended to reference page 7. See Attachment
Monsanto 2.15 on the enclosed CD.
(It has not been determined who will sponsor this response at hearing.
ID AH
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.
ON THE ENCLOSED CD
PAC-O7-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to page 12 of the testimony of Mr. McDougal, beginning at line 17,
please provide for each of the years 2000 through 2006, and as projected for each
of the years 2007 through 2015 , the number ofSO2 allowances sold and the
revenues per allowance, and in total. In addition, please provide for each year the
beginning of year balance, the number acquired, the number sold and the end of
year balance.
Response to Monsanto Data Request 2.
Please see Confidential Attachment Monsanto 2.16 for the data requested above.
This information is confidential and is provided subject to the terms and
conditions of the protective order in this proceeding.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
CO NFID ENTIAL A TT A CHMENT
MONSANTO 2.
ON THE ENCLOSED CONFIDENTIAL CD
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to page 18 of the testimony of Mr. McDougal, lines 9 through 15
please state the amount of Idaho test year cost proposed in Rocky Mountain
Power s filing, and what that amount would be if the Company utilized the
F AS87 amount.
Response to Monsanto Data Request 2.
Idaho portion of pension O&M expense in filing
Idaho portion of pension O&M expense under F AS 87
$3,055 326
055,239
Please refer to Adjustment 4.14 in Mr. McDougal's Exhibit 11 to see the pro
forma adjustment made to arrive at cash-basis pension cost for inclusion in
revenue requirement in the case.
(Steven R. McDougal is expected to sponsor this response at hearing.
P AC-07-0s/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the testimony of Mr. McDougal at page 19, lines 2 through 20, please
provide the basis for the three-year amortization proposal. Include any applicable
precedent relied upon for a three-year amortization period. Also, please state the
test year cost and the amount of the adjustment if the amortization period were
five years and if the amortization period were 10 years.
Response to Monsanto Data Request 2.
The company is proposing a three-year amortization of severance costs in its
general rate case filing based on the Commission s approval of the company
deferred accounting application in Case No. P AC-06-11. Order No. 30225
states, "the Company is authorized to defer the costs of the MEHC Transition in
Account 182.3 Other Regulatory Assets as set forth above and amortize the
balance to Account 930.2 Miscellaneous General Expenses over a three-year
period.
A three-year amortization allows the company to match the severance costs with
the resulting benefits, or reduction in costs, resulting from the transition program
over a reasonable period of time.
Change in Control Severance Deferral 39,522 007
Annual Amortization:
Three-year period
Five-year period
Ten-year period
174 002
904 401
952 201
(Steven R. McDougal is expected to sponsor this response at hearing.
P AC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the testimony of Mr. McDougal at page 20, lines 25 through 30,
please provide the basis for and detail of the $7.3 million expected on-going level
of annual charges from MEHC.
Response to Monsanto Data Request 2.
The basis for the $7.3 million annual charges from MEHC is the state
commitments agreed to during the acquisition of PacifiCorp by MEHC. Idaho
commitment 128 states:
a) MEHC and PacifiCorp will hold customers harmless for increases in costs
retained by PacifiCorp that were previously assigned to affiliates relating to
management fees...
b) This commitment is offsetable to the extent PacifiCorp demonstrates to the
Commission s satisfaction, in the context of a general rate casethe following:
i) Corporate allocations from MEHC to PacifiCorp included in PacifiCorp s rates
are less than $7.3 million.
Please see Attachment Monsanto 2.19 on the enclosed CD for the detail of the
April-December 2006 MEHC cross-charges of $5.475 million, which is 75% of
the annual level. MEHC cross-charges began in April 2006.
(Steven R. McDougal is expected to sponsor this response at hearing.
ID All 0
PAC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.
ON THE ENCLOSED CD
PAC-1)7-051R0cky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the testimony of witness Fehrman, at page 8, concerning the Lake
Side plant, please provide the annualized first year non-fuel revenue requirement
on both a total company and an Idaho jurisdictional basis, and the amount
proposed to be included in revenue requirements in this case on both a total
company and an Idaho jurisdictional basis.
Response to Monsanto Data Request 2.
The annualized first year non-fuel revenue requirement for both total company
and Idaho jurisdiction is provided as Attachment Monsanto 2.20a on the enclosed
CD. The amount included in the case for total company and Idaho is provided in
Attachment Monsanto 2.20b on the enclosed CD.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.20 -(a-
ON THE EN CLOSED CD
PAC-E..o7-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the testimony of Mr. Fehrman at pages 9 and 10, concerning the
acquisition of natural gas, a). please provide a copy of the Company s risk
management policy and b). its implementation plan for acquiring natural gas and
purchased power, and c). demonstrate how the acquisition plan is consistent with
the risk management policy.
Response to Monsanto Data Request 2.
a. The Risk Management Policy is provided as Confidential Attachment
Monsanto 2.21 a. This document contains confidential information and is
provided subject to the terms and conditions of the protective order in this
proceeding.
b. The attached presentation (slide numbers 19 through 31), given at the
December 18 , 2006 Idaho Quarterly Meeting, describes PacifiCorp s plan for
acquiring natural gas. It is provided as Attachment Monsanto 2.21 b.
c. PacifiCorp s natural gas acquisition plan is consistent with the Risk
Management Policy in that the gas acquisition plan implements the Risk
Management Policy s directives with regard to limiting natural gas price risk.
(William J. Fehrman is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
CO NFID ENTIAL A TT A CHMENT
MONSANTO 2.21 a
ON THE ENCLOSED CONFIDENTIAL CD
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
TT A CHMENT MO NSANTO 2.21 b
ON THE EN CLOSED CD
P AC- E-07 -Os/Rocky Mountain Power
July 24, 2007
Monsanto 2nd 'Set Data Request 2.
Monsanto Data Request 2.
Referringto pages 9 and 10 of the testimony of Mr. Fehrman, concerning the
acquisition of natural gas, please identify each natural gas transaction as to:a. Date of contract;b. Nature of produce, Le., physical gas, futures contract, call option, put,
swap, etc.
Purchase or sale;
The quantity of gas;
The delivery point;
The delivery period;
The price or price basis;
Counterparty; and
Reason for transaction.
Response to Monsanto Data Request 2.
The natural gas transaction information requested is extremely confidential
price and transaction sensitive, and commercially proprietary. Disclosure of this
material may give an undue advantage to competitors and therefore requires the
highest level of confidential treatment. The information, with the exception of
counterparty identities, will be made available for review at the company
offices. Please contact Brian Dickman at 801-220-4975 to make arrangements.
This information cannot be copied and cannot be removed from the company
premIses.
L Each transaction is executed in order to effectively, efficiently, and
economically manage that portion of reliability and price risk associated
PacifiCorp s natural gas requirements for generation and tolling agreements as
well as the natural gas price component of natural gas index-priced electricity
purchases.
(William J. Fehrman is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.23
Monsanto Data Request 2.
Referring to page 10 of the testimony of Mr. Fehrman, lines 6 through 11 , please
provide the basis for the statement that over time hedging will ". . . always
produce the lowest possible cost."
Response to Monsanto Data Request 2.
This question misstates Mr. Fehrman s testimony. Mr. Fehrman stated in
response to the question "Does hedging always produce the lowest possible cost?"
the following response. "On average over the long term, it should. But in any
particular period there will inevitably be periods when market prices are lower
than the Company s hedged costs and periods when market prices are higher than
hedged costs, as was the case in Case No. P AC-06-04 where the Company
hedged costs provided significant value to customers. The benefit of this approach
is that customers will be protected against significant volatility." Over time
hedging will not always produce the lowest possible cost. Generally, hedging
protects against increased costs that may result from unfavorable market price
movements such as those experienced during the 2000 / 2001 California energy
cnSlS.
(William J. Fehrman is expected to sponsor this response at hearing.
P AC-07 -Os/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to pages 9 and 10 of the testimony of Mr. Fehrman, please provide the
dispatch prices that are used in the test year for each natural gas unit and explain
how those prices are determined.
Response to Monsanto Data Request 2.
The dispatch prices used in the company s GRID model are provided as
Attachment Monsanto 2.24 on the enclosed CD.
The dispatch price is the heat rate multiplied by the fuel cost. Gas prices are from
the company s December 31 , 2006 Official Forward Price Forecast for the
January to March 2007 portion of the normalized test year and the company
March 31 , 2007 Official Forward Price Forecast for the April to December 2007
portion of the normalized test year. Market prices are developed from broker
quote information available on December 31 , 2006 and March 31 , 2007.
(Mark T. Widmer is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data R~quest 2.
Monsanto Data Request 2.
Referring to the testimony of Mr. Fehrman, at page 10, line 19 through page 11
line 5, please provide the assumed per kW cost of the 1,400 megawatts of
renewable resources that were identified as a part of a least-cost portfolio, and the
per k W cost of each of the wind resources proposed to be included in the revenue
requirement in this proceeding. Please separately identify generation and
transmission costs.
Response to Monsanto Data Request 2.
a. For IRP portfolio modeling purposes, the cost per kW varies by region in
which the renewable proxy resources are located, as shown in the table below.
Southeast Washin
North Central Ore on
Southeast Wyoming
Per-kW Cost
2006 dollars
480
687
586
Region
In addition to an initial capital cost component, these figures account for the
stream of fixed operations & maintenance costs, renewable production tax
credits, renewable energy credits (green tags), system integration costs, and in
the case of southeast Wyoming resources, incremental transmission costs. In
addition, the North Central Oregon resource includes transmission wheeling
costs.
b. Please refer to the following table. There was no incremental firm
transmission added in this case for these resources.
Additional Capital
Resource Capacity Investment $/kW
Goodnoe Hills 94MW $ 196,572,406 $ 2 091
Leaning Juniper 100.5 MW $ 175 434 259 $ 1 746
Marengo 140.4 MW $ 258 541 351
$ '
841
(William J. Fehrman and Steven R. McDougal are expected to sponsor this
response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data R.equest 2.26
Monsanto Data Request 2.
Referring to the testimony of Mr. Fehrman at page 13, lines 14 through 22, please
provide a copy of all information concerning the Leaning Juniper 1 project that is
referenced.
Response to Monsanto Data Request 2.
Please refer to IPUC Production Data Request 9, a copy of which is provided
separately.
(William J. Fehrman is expected to sponsor this response at hearing.
PAC-O7-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Concerning page 14 of the testimony of Mr. Fehrman, lines 1 through 11 , please
provide the annualized first year non-fuel revenue requirement on both a total
company and an Idaho jurisdictional basis for the Leaning Juniper 1 facility, and
the amounts proposed to be included in the test year in this proceeding, on both a
total company and an Idaho jurisdictional basis.
Response to Monsanto Data Request 2.
The annualized first year non-fuel revenue requirement for both total company
and Idaho jurisdiction is provided as Attachment Monsanto 2.27a on the enclosed
CD. The amount included in the case for total company and Idaho is Attachment
Monsanto 2.27b on the enclosed CD. Some numbers in Attachment Monsanto
27b differ slightly from Mr. McDougal's Exhibit 13. Exhibit 13 will be
corrected at hearing; this has no impact on revenue requirement in the case.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
PAC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.27 -(a-
ON THE ENCLOSED CD
P AC-07 -O5/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the testimony of Mr. Fehrman at page 16, lines 15 to 21 , please
provide a copy of all information concerning the Marengo project that is
referenced.
Response to Monsanto Data Request 2.
Please refer to IPUC Production Data Request 9, a copy of which is provided
separately.
(William J. Fehrman is expected to sponsor this response at hearing.
PAC-O7-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Concerning page 16-17 of the testimony of Mr. Fehrman, please provide the
annualized first year non-fuel revenue requirement on both a total company and
an Idaho jurisdictional basis for the Marengo facility, and the amounts proposed
to be included in the test year in this proceeding, on both a total company and an
Idaho jurisdictional basis.
Response to Monsanto Data Request 2.
The annualized first year non-fuel revenue requirement for both total company
and Idaho jurisdiction is provided as Attachment Monsanto 2.29a on the enclosed
CD. The amount included in the case for total company and Idaho is Attachment
Monsanto 2.29b on the enclosed CD.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQ UES TS SET 2 (1-65)
TT ACHMENT MONSANTO 2.29 -(a-
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
July 24, 2007
Mon~anto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the testimony of Mr. Fehrman at page 19, lines 14 to 20, please
provide a copy of all information concerning the Goodnoe Hills project that is
referenced.
Response to Monsanto Data Request 2.
Please refer to IPUC Production Data Request 9, a copy of which is provided
separately.
(William J. Fehrman is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.31
Monsanto Data Request 2.
Concerning pages 19 and 20 of the testimony of Mr. Fehrman, please provide the
annualized first year non-fuel revenue requirement on both a total ~ompany and
an Idaho jurisdictional basis for the Goodnoe Hills facility, and the amounts
proposed to be included in the test year in this proceedings, on both a total
company and an Idaho jurisdictional basis.
Response to Monsanto Data Request 2.
The annualized first year non-fuel revenue requirement for both total company
and Idaho jurisdiction is provided as Attachment Monsanto 2.31a on the enclosed
CD. The amount included in the case for total company and Idaho is Attachment
Monsanto 2.31 b on the enclosed CD.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
P A C- E-07 -
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.31-(a-
ON THE ENCLOSED CD
P AC-07 -05/Rocky Mountain Power
July 24, 2007
Mon-santo 2nd 'Set Data Request 2.32
Monsanto Data Request 2.
Referring to the testimony of Mr. Fehrman at page 22, lines 8 to 12, please
provide a copy of all information concerning the Blundell Bottoming Cycle
resource project that is referenced.
Response to Monsanto Data Request 2.
Please see Attachment Monsanto 2.32 on the enclosed CD for the requested data.
(William J. Fehrman is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.
ON THE ENCLOSED CD
P AC-07 -OSlRocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.33
Monsanto Data Request 2.
Concerning page 22 of the testimony of Mr. Fehrman, please provide the
annualized first year non-fuel and fuel revenue requirement on both a total
company and an Idaho jurisdictional basis for the Blundell Bottoming Cycle
resource, and the amounts proposed to be included in the test year in this
proceeding, on both a total company and an Idaho jurisdictional basis.
Response to Monsanto Data Request 2.
The annualized first year non-fuel revenue requirement for both total company
and Idaho jurisdiction is provided as Attachment Monsanto 2.33a on the enclosed
CD. The amount included in the case for total company and Idaho is Attachment
Monsanto 2.33b on the enclosed CD.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.33 -(a-
ON THE ENCLOSED CD
, PAC-O7-0S/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.34
Monsanto Data Request 2.
Referring to Table 1 at page 3 of the testimony of witness Widmer, please provide
the detailed workpapers that illustrate how Rocky Mountain Power Company has
identified the various components of the increase in claimed revenue requirement
both for the total system and for the Idaho jurisdiction.
Response to Monsanto Data Request 2.
Please see the company s response to Monsanto data request 1.8. The requested
information was provided as Attachments Monsanto 1.8c and 1.8f.
(Mark T. Widmer is expected to sponsor this response at hearing.
P AC-07 -'Os/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.35
Monsanto Data Request 2.
Referring to Table I at page 3, please provide a copy of all "Expired Purchase
Contracts" as noted as Adjustment Item No.5 in the table.
Response to Monsanto Data Request 2.3'5
The requested contracts are:
Duke HLH
Duke
TransAlta
The requested information is provided as Attachments Monsanto 2.35a through
3Sc.
(Mark T. Widmer is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.35 -(a-c)
ON THE ENCLOSED CD
PAC-07-0S/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.36
Monsanto Data Request 2.
Referring to Table 1 at page 3, please provide a copy of all "Expired Sales
Contracts" as noted as Adjustment Item No.6 in the table.
Response to Monsanto Data Request 2.
The requested contracts are:
BP A Flathead Sale
Flathead & ENI Sale
Southern California Edison (SCE)
The requested information is provided as Attachments Monsanto 2.36a through
2.36d.
(Mark T. Widmer is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.36 -(a-
ON THE ENCLOSED CD
P AC-O7 -05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.37
Monsanto Data Request 2.
(a) Does the "growth" component in the table at page 3 of Mr. Widmer
testimony recognize a difference in the rate of growth in Idaho and the rate of
growth in the system in determining the amount of dollars associated with load
growth attributed to the Idaho jurisdiction? (b) Please explain and provide your
workpapers. If it does not distinguish differences in the rate of growth, please
explain why Rocky Mountain Power Company has chosen not to recognize the
difference in preparing this table.
Response to Monsanto Data Request 2.
(a) Yes.
(b) Please see the company s response to Monsanto Data Request 1.8. The
allocation factors used in Table 1 were provided as part of Attachment
Monsanto 1.8c. As shown in Attachment Monsanto 1.8c, Idaho
approximate share of the load growth was developed by multiplying the
system cost of the load change by an Idaho NPC weighted allocation factor.
The NPC weighted allocation factor is a composite ofSG, SE SSGC, SSECH
and SSECT allocation factors weighted by their corresponding NPC dollars.
(Mark T. Widmer is expected to sponsor this response at hearing.
P AC- E-07 -Os/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
With respect to Mr. Widmer s testimony at page 3, lines 13-, please provide a
numerical value of load growth for the Idaho jurisdiction contained in this filing
as compared to the Idaho load contained in the Company s filing in Case No.
P AC-06-04.
Response to Monsanto Data Request 2.
Idaho weather normalized loads grew by 96 276 MWH (2.7%) between the
current case and Case No. P AC-06-04.
(Mark T. Widmer is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.39
Monsanto Data Request 2.
Referring to page 4, lines 6-8 of Mr. Widmer s testimony, please provide details
as to what "market prices" the Company has utilized in this filing.
Response to Monsanto Data Request 2.
Please see Mr. Widmer s testimony, Page 19 lines 3 through 18 for a discussion
of the market prices utilized by the company in this filing.
Please see the company s response to Monsanto Data Request 1.8 L for the
market prices used in GRID.
(Mark T. Widmer is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to page 4, lines 6-8 of Mr. Widmer s testimony, please provide a detail
breakout of the "cost increases or decreases" associated with the Company
natural gas hedges.
Response to Monsanto Data Request 2.
After the filing of the case the Company detected an error in the normalized gas
swap valuation. Some of the gas trades that were coded in the data extractions as
gas buys were in fact gas sales. The Company has since revised the gas swap
calculation to correct this issue.
Provided as Confidential Attachment Monsanto 2.40 on the enclosed CD is a
breakout of the natural gas hedge costs (mark-to-market and gas swaps) as filed in
this case and the natural gas hedges as corrected. This information is confidential
and is provided subject to the terms and conditions of the protective order in this
proceeding.
The Company intends to submit revised power costs in rebuttal testimony.
(Mark T. Widmer is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
CONFIDENTIAL A TT ACHMENT
MONSANTO 2.
ON THE ENCLOSED CONFIDENTIAL CD
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.41
Monsanto Data Request 2.
(a) Referring to page 5, lines 19-, of Mr. Widmer s testimony, please provide
an explanation and numerical calculation of how the Company s QF purchases
have affected overall net power costs. (b) Has the avoided cost value posted by
the Company in 2006 and up through current 2007 been generally increasing,
decreasing or remaining stable?
Response to Monsanto Data Request 2.
(a) Net power costs associated with QF resources have declined from $195
million in the prior case to $161 million in the current case. Average cost of
QF resources has declined from $76 to $65/MWH. The requested workpapers
are provided as Attachment Monsanto 2.41a on the enclosed CD.
(b) Avoided costs for natural gas indexed resources have declined from $57.33
/MWH in 2006 to $51.06 /MWH in 2007. Avoided costs for all other QF
resources have remained unchanged at the avoided costs levels ordered by the
Commission in December 2004. Copies of the Idaho Commission orders are
provided as Attachments Monsanto 2.41b and 2.41c on the enclosed CD.
(Mark T. Widmer is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.41-(a-c)
ON THE ENCLOSED CD
PAC-O7-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.42
Monsanto Data Request 2.
(a) Referring to Exhibit No. 14, page 5, of Mr. Widmer s testimony, please
provide workpapers supporting the derivation of the calculations of "Mark to
Market" values. Please provide supporting documentation in Excel with formulas
intact. (b) Please confirm that such calculations are performed within the GRID
model or post-Model calculations.
Response to Monsanto Data Request 2.
(a) Please see the Company s response to Monsanto Data Request 2.40.
(b) The "Mark to Market" calculation is performed outside of the GRID model.
The results of this calculation are included as an input into GRID.
(Mark T. Widmer is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.43
Monsanto Data Request 2.
(a) Referring to Exhibit No. 14, page 5, of Mr. Widmer s testimony, please
provide workpapers supporting the derivation of the calculations of "Gas 'Swaps
values. Please provide supporting documentation in Excel with formulas intact.
(b) Please confirm that such calculations are performed within the GRID model or
post-Model calculations.
Response to Monsanto Data Request 2.
(a) Please see the Company s response to Monsanto Data Request 2.40.
(b) The "Gas Swaps" calculation is performed outside of the GRID model. The
results of this calculation are included as an input into GRID.
(Mark T. Widmer is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.45
Monsanto Data Request 2.
Concerning the testimony of Mr. Widmer, please state Rocky Mountain Power
company s "planning reserve" margin targets, in megawatts and percent of annual
firm peak demand.
Response to Monsanto Data Request 2.
The Company s planning reserve margin is 12% of annual firm peak demand.
(Mark T. Widmer is expected to sponsor this response at hearing.
P AC-O7-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.46
Monsanto Data Request 2.
(a) Referring to page 18 of the testimony of Mr. Widmer, beginning at line 20
please provide the price curves at each of the four market points that were used in
the test year GRID model dispatch. (b) Also, please provide the import and
export limits for each market, for each month of the test year.
Response to Monsanto Data Request 2.
(a) Please see the Company s response to Monsanto Data Request 1.8. Monthly
market prices were provided as Attachment Monsanto 1.8 L.
(b) The import (purchase) and export (sales) levels are defined within GRID by
transmission constraints from the market to load centers. In addition, market sales
are limited during graveyard hours to the historical levels experienced during
2006.
Please see the Company s response to Monsanto Data Request 1.8. The work
papers for the market sale limits were provided as Attachment Monsanto 1.8k.
(Mark T. Widmer is expected to sponsor this response at hearing.
PAC-07-0S/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.47
Monsanto Data Request 2.
Please provide the forecast and the supporting workpapers referenced at page 19
lines 4 through 18 of the testimony of Mr. Widmer.
Response to Monsanto Data Request 2.
Please see the Company s response to Monsanto Data Request 1.8. The forecast
market prices and supporting workpapers were provided as Attachment Monsanto
8 L.
(Mark T. Widmer is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Reque~t 2.48
Monsanto Data Request 2.
Mr. Widmer s Exhibit No. 15 shows monthly average megawatts, and his Exhibit
No. 16 shows peak megwatts for summer and winter. Please provide the same
information that is shown on Exhibit No. 16 for each of the months shown on
Exhibit No. 15 and separately identify firm and non-firm load.
Response to Monsanto Data Request 2.
Please see the Company s response to Monsanto Data Request 1.8. The requested
information was provided as Attachment Monsanto 1.8e.
(Mark T. Widmer is expected to sponsor this response at hearing.
P AC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd 'Set Data Request 2.
Monsanto Data Request 2:52
Please explain the purpose of Mr. McDougal's Exhibit No. 13, state where and
how the numbers in that exhibit are used in the filing and in determining the
proposed revenue requirement and revenue increase, and state where in testimony
this exhibit is explained.
Response to Monsanto Data Request 2.
The purpose of Mr. McDougal's Exhibit No 13 was to summarize on one page the
revenue requirement impact each of the new generation resources has in the
filing. The reference column on the right hand side of each page in Exhibit No. 13
refers to pages in Mr. McDougal's Exhibit No. 11 where the numbers were
included in the revenue requirement filing. ExhibitNo. 13 is described in Mr.
McDougal's testimony on page 31 lines 11 - 23 and page 32 lines 1-
(Steven R. McDougal is expected to sponsor this response at hearing.
P AC-O7 -05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.'53
Please provide the detailed workpapers supporting the development of the "net
power cost savings" shown for each project in Mr. McDougal's Exhibit No. 13.
Response to Monsanto Data Request 2.
The requested workpapers are provided as Attachment Monsanto 2.53a through
53d. The net power cost savings in Mr. McDougal's Exhibit No. 13 were
calculated stand alone studies, not incremental studies. For example, the net
power cost savings shown in Attachment Monsanto 1.8c, previously provided, are
based on incremental studies.
(Mark T. Widmer is expected to sponsor this response at hearing.
IDAHO
PAC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
TT ACHMENT MONSANTO 2.53 -(a-
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to Tabs 8.2 and 8.8.3 in Mr. McDougal's Exhibit No. 11, please
provide for each listed project:a. The month and day that the project went into service.b. The dollar amount of investment included in the December 31 , 2006 plant
in-service balance;
The dollar amount of accrual to the reserve for depreciation for this project
at December 31 , 2006;
The dollar amount of depreciation expense included for this project in the
actual 2006 operating results;
The number of months and dollar amount of adjustment to depreciation
expense proposed to be included in revenue requirements.
Response to Monsanto Data Request 2.
Attachment Monsanto 2.54a on the enclosed CD shows the 2006 additions
to plant-in-service for each project by month.
See Attachment Monsanto 2.54a which includes a December 31 , 2005
beginning balance, additions during 2006, and the December 31 , 2006
ending balance of plant-in-service.
See Attachment Monsanto 2.54c which shows the estimated depreciation
reserve balance at December 31 , 2006, based on the dollar amounts and
in-service information shown in 2.54 a and b.
See Attachment Monsanto 2.54c which shows the estimated depreciation
expense for the calendar year 2006, based on the dollar amounts and in-
service information shown in 2.54 a and b.
The number of months and dollar amount of adjustment of calendar 2006
depreciation expense included in revenue requirement is provided in
Steven R McDougal testimony, Exhibit 11 , page 6.1 (top section) and
page 6.1.1 , columns 7 and 8. Please also refer to Steven R. McDougal
direct testimony page 26, line 12 - Depreciation and Amortization
expense.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.54 -(a, c)
ON THE ENCLOSED CD
PAC-07-05lRocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
With respect to page 8.2 of Mr. McDougal's Exhibit No. 11 , please explain why
the transmission project identified as "SW Utah Load Growth Project" will
benefit Idaho customers and explain why this cost should be allocated on the
SG" factor rather than assigned to Utah.
Response to Monsanto Data Request 2.
The "SW Utah Load Growth Project" consists of converting an existing single
circuit 138 kV line to a double circuit 345 kV constructed line. This transmission
related capital addition project allows the Company greater ability to move and
transport electrical power on the electrical grid. All transmission related assets are
considered a benefit to the whole system and not just the jurisdiction in which it is
physically located. As a result, the Revised Protocol allocation methodology
allocates the cost oftransmission capital assets on the system generation (SG)
allocation code.
(Douglas N. Bennion and Steven R. McDougal are expected to sponsor this
response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.57
Monsanto Data Request 2:57
With respect to page 8.8.3 of Mr. McDougal's Exhibit No. 11 , please describe and
explain the purpose of each "mining" project and:a. State whether the project will result in reduced expenses, and if so
quantify the expense reduction and the amount included in the test year in
this proceeding; and
Whether the project will increase the ability to extract coal for use in
Rocky Mountain Power Company s generators, and if so, state how that
charge is reflected in the test year.
Response to Monsanto Data Request 2.
The "Deer Creek-th North Slope & Raise" to the Blind Canyon seam is critical to
the continued extraction of coal from Company s Deer Creek/Mill Fork mine and
the "Deer Creek-Rilda Canyon Ventilation Slopes/Fan" was required by the Mine
Safety and Health Administration ("MSHA") to meet federally mandated
ventilation requirements. Neither project is expected to reduce expense.
(It has not been determined who will sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.58
Monsanto Data Request 2.
Concerning page 8.8.3 on Mr. McDougal's Exhibit No. 11 , for the "King Air
B200 Turboprop" please explain the purpose of this investment, whether it is a
replacement or a new airplane, and provide copies of the studies which justified
the purchase of this airplane as opposed to alternative means and methods of
transportation.
Response to MonsantoData Request 2.
Purpose of the investment: This expenditure is to provide for the purchase and
expected maintenance of a King Air turboprop aircraft. With the purchased
aircraft, PacifiCorp Energy and Rocky Mountain Power management and others
will have a greater ability to reach work locations and communities located over a
large geographic area including Utah, Wyoming, Idaho, Arizona, and Portland
Oregon when compared with commercial air and/or driving options. These
improvements include timeliness in accomplishing trip times, which allows for
more operational management capacity and efficiency. It also will improve the
timeliness of decision making processes from key management by their ability to
reach operational entities.
Replacement or new: The turboprop airplane, which was purchased in May 2006
is not a replacement and is new to the Company, but had been owned and used by
an external party previous to the acquisition by the Company. PacifiCorp owned
three jet aircraft in previous years but sold them under a prior management.
Studies and Cost Justification: Please see Attachment Monsanto 2.58 on the
enclosed CD for a copy of the cost justification.
(Steven R. McDougal is expected to sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.
ON THE ENCLOSED CD
P AC-D7 -05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Concerning page 8.8.5 of Mr. McDougal's Exhibit No. 11 and the project
identified as "Cinder Butte - 161-12.5 kV 2-30 MV A sub," please explain
) the purpose of this project and
) state whether this project will permit Rocky Mountain Power Company to
serve additional load in Idaho,
) and if so quantify the amount
) quantify the expected net revenues from this additional capacity
) and state how much of those net revenues have been included in the test year
in this proceeding.
Response to Monsanto Data Request 2.
) The Cinder Butte substation is designed to relieve loading on the Idaho Falls
substation and to accommodate existing and new residential and commercial load
in the immediate area. The Cinder Butte substation is a new 161 kV - 12.5 kV
substation designed to serve load exclusively in Idaho.
) Yes.
) The initial loading on the transformer is estimated to be in the range of 8 to 12
MV A, leaving 18 to 22 MV A for future growth in the area.
) Initial loading will be unloading adjacent substations, so initially the net
revenue increase will be $0.
) The Company did not include any additional revenues in the test year as a
result of this capital project.
(Douglas N. Bennion and Steven R. McDougal are expected to sponsor this
response at hearing.
PAC-07-0S/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the direct testimony of Erich Wilson, please provide the target
incentive level for the test period in this proceeding.
Response to Monsanto Data Request 2.
The target incentive level for the test period is $27.5 million as noted in the direct
testimony of Wilson on page 6 line 8 through 10.
(Erich D. Wilson is expected to sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the direct testimony of Erich Wilson, page 8, line 14, please provide
the reference to where the cost associated with the incentive plan to compensate
employees based on corporate financial performance is removed from the 2006
unadjusted data and provide all supporting workpapers, studies and analyses
which support that removal.
Response to Monsanto Data Request 2.
The reference Wilson makes (page 8 line 14) is to the Company s long term
incentive plan that is based on net income results and is a program provided to a
select group of senior managers of the company. The Company has not included
this program or any of its related expenses in its general rate case.
(Erich D. Wilson is expected to sponsor this response at hearing.
PAC-O7-05/Rocky Mountain Power
July 24, 2007
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the direct testimony of Erich Wilson, Exhibit No. 22, page 6:a. Regarding Goal 10, please provide five-year regulatory and public policy
agenda for Rocky Mountain Power; andb. Provide the regulatory and legislative plan.
Response to Monsanto Data Request 2.
PacifiCorp objects on the grounds that these documents are protected by attomey-
client privilege and were prepared in anticipation of litigation.
(It has not been determined who will sponsor this response at hearing.
PAC-07-05/Rocky Mountain Power
July 24, 2D07
Monsanto 2nd Set Data Request 2.
Monsanto Data Request 2.
Referring to the direct testimony of Erich Wilson, Goal 11 , please provide Rocky
Mountain Powers' Risk Management Plan, First Phase.
Response to Monsanto Data Request 2.
Risk management plans for the Portland Customer Contact Center and Wasatch
Customer Contact Center are provided as Attachment Monsanto 2.65.
The Company also has risk management plans for the Portland Control Center
Salt Lake Control Center, and substations. These plans are considered highly
confidential in accordance with North American Electric Reliability Corporation
(NERC) "Cyber Security" management controls. Rocky Mountain Power will
make the documents available for review in the Company s offices upon
reasonable notice, pursuant to the terms of the protective order in this case.
Please contact Brian Dickman at 801-220-4975 to make arrangements to review
these documents.
(It has not been determined who will sponsor this response at hearing.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 2 (1-65)
ATTACHMENT MONSANTO 2.
ON THE ENCLOSED CD