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Home My WebLink About20070801PAC to Monsanto 2-14, 44, 49-51, 55, 59, 61.pdf~ ~~~oo ~OUNT AIN 201 South Main, Suite 2300 Salt Lake City. Utah 84111 InO) Q. .- v July 31 , 2007 Randall C. Budge RACINE, OLSON, NYE, BUDGE & BAILEY, 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., 2.44, 2.49 59 and 2.61. Provided on the enclosed CD are Attachments Monsanto 2.44 -(a-b), 2.49, 2.50 (cl , c2, dl , d2) and 2.55. Provided on the enclosed Confidential CD are Confidential Attacqrnents Monsanto 2.14 -(1,.2) and 2.51 -(1-2). The response to Monsanto 2.2 is in procesS and will be provided upon completion. If you have any questions, please feel free to call me at (801) 220-4975. Sincerely,~~IcJ:~tp.I\. Brian Dickman, Manager Regulation Enclosures Cc: James R. Smith Maurice Brubaker Richard Anderson PAC-07-05/Rocky Mountain Power July 31 , 2007 Monsanto 2nd Set Data Request 2. Monsanto Data Request 2. With respect to the page 14 of the testimony ofMr. Walje, lines 11 through 18, please provide a copy of the J.D. Power & Associates study and the previous studies against which the improved performance was measured. Response to Monsanto Data Request 2. J. D. Power & Associates studies are provided as Confidential Attachment Monsanto 2.14 -Ion the enclosed CD. This information is proprietary and is provided subject to the terms and conditions of the protective order in this proceeding. A summary sheet provided by J.D. Power & Associates from the 2007 study is provided as Confidential Attachment Monsanto 2.14 -2; it shows Rocky Mountain Power s 9th place west region ranking. The company began purchasing the J.D. Power business study in 2006; the 2006 and 2007 studies are provided; previous studies are not available. (It has not been determined who will sponsor this response at hearing. IDAHO P AC-O7- ROCKY MOUNTAIN POWER MONSANTO DATA REQUESTS SET 2 (1-65) CONFIDENTIAL ATTACHMENT MONSANTO 2.14 -(1- ON THE ENCLOSED CONFIDENTIAL CD PAC-07-05/Rocky Mountain Power July 31, 2007 Monsanto 2nd Set Data Request 2.44 Monsanto Data Request 2. Referring to page 13 of the testimony of Mr. Widmer, concerning reserve requirements, please provide for each month of calendar year 2006 the operating reserve (regulating and contingency stated separately) requirement and the actual reserves being carried on the system, at the time of each monthly peak. Also identify the megawatts by unit and contract (including non-firm load) where each type of reserve was actually carried. Response to Monsanto Data Request 2. The Company s hourly reserve information that is available are provided as Attachments Monsanto 2.44a and 2.44b on the enclosed CD. Hourly reserves through November 15 2006 are provided on Attachment Monsanto 2.44a. Hourly reserve data for the remainder of calendar year 2006 is provided on Attachment Monsanto 2.44b. Data is provided for spinning reserves non-spinning reserves, and regulating reserves. Note: As of November 15,2006, reserve data is maintained in a different system than the data provided in Attachment Monsanto 2.44a and is in a different format. (Mark T. Widmer is expected to sponsor this response at hearing. IDAHO P A C- E-07 - ROCKY MOUNTAIN POWER MONSANTO DATA REQUESTS SET 2 (1-65) TT ACHMENT MONSANTO 2.44 -(a- ON THE ENCLOSED CD PAC-07-05/Rocky Mountain Power July 31 , 2007 Monsanto 2nd Set Data Request 2.49 Monsanto Data Request 2. Please provide the information requested in the previous question (No. 2-48) for each month of 2006. Response to Monsanto Data Requesf2. PacifiCorp objects to this question on the grounds that it is unduly burdensome. Moreover, the Company has not prepared the requested information for peak. Notwithstanding the objection, provided as Attachment Monsanto 2.49 on the enclosed CD is a copy of actual net power costs for 2006. The average energy information can be developed from this information. (Mark T. Widmer is expected to sponsor this response at hearing. IDAHO PAC-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 31 , 2007 Monsanto 2nd Set Data Request 2. Monsanto Data Request 2. For each hour of calendar year 2005, calendar year 2006, and calendar year 2007 to date, please provide the following information (In $/Mwh) both for the entire system and for the East System.a. The market value of energy;b. The incremental cost associated with the most expensive resource dispatched; The purchase price for the most expensive short-term resource purchased; and The revenues received from the short-term sale that provided the highest per unit revenue. Response to Monsanto Data Request 2. a. Hourly prices from PowerDex, a price index supplier, for the period January 1 2005 through June 28, 2007 are proprietary and will be made available for review at the company s offices. Mid-Columbia prices are representative of the market value of energy in the west system and Four Comers prices are representative of the market value of energy in the east system. This data is proprietary and Highly Confidential and cannot be copied nor distributed. Please contact Brian Dickman at 801-220-4975 to make arrangements to review. b. Due to the complexity of the operating requirements on PacifiCorp s system PacifiCorp does not calculate incremental cost associated with the most expensive resource dispatched each hour. These complexities include system operating reserve requirements, regulating margin, load following and other resource contingencies. Multiple generating units of variable fuel types and contracts including hydro generation, are dispatched to manage system requirements. c. The attached files (Attachments Monsanto 2.50 c1 and c2 on the enclosed CD) contain hourly prices for the most expensive short-term resource purchased for the entire system and for the east system. Attachments Monsanto 2.50 cl is for the entire system; Attachment Monsanto 2.50 c2 is for the east system. d. The attached files (Attachment Monsanto 2.50 dl and d2 on the enclosed CD) contain hourly revenues received from the short-term sale with the highest price for the entire system and for the east system. Attachment Monsanto 2.50 dl is for the entire system; Attachment Monsanto 2.50 d2 is for the east system. (Mark T. Widmer is expected to sponsor this response at hearing. IDAHO P A C- E-07 - ROCKY MOUNTAIN POWER MONSANTO DATA REQUESTS SET 2 (1-65) TT A CHMENT MONSANTO 2.50(cl, c2, dl, d2) ON THE ENCLOSED CD PAC-07-05/Rocky Mountain Power July 31 , 2007 Monsanto 2nd Set Data Request 2. Monsanto Data Request 2. Please provide a copy of all communications between: (a) Rocky Mountain Power Company, its predecessor company, and any affiliates; and (b) Bond rating agencies, concerning regulatory issues, price levels for retail service, regulatory commission policies, regulatory climate, presence or absence of adjustment clauses for fuel and purchased power, and related issues for the period beginning one year before the acquisition by MEHC was final, through the most recent communication. Please include all drafts of commentaries, all mark-ups exchanged and all comments with respect to rating agency reports. Response to Monsanto Data Request 2. To the extent this request seeks "all" communications between Rocky Mountain Power, its predecessor company, its affiliates and bond rating agencies, Rocky Mountain Power objects to this question on the grounds that it is overly broad, unduly burdensome and not likely to lead to any meaningful discovery. Notwithstanding this objection, provided as Confidential Attachment Monsanto 2.51 -Ion the enclosed Confidential CD are communications between PacifiCorp and bond rating agencies for the period beginning one year before the acquisition by MEHC was final, through the most recent communication. Provided as Confidential Attachment Monsanto 2.51 -2 on the enclosed Confidential CD are communications between MEHC and bond rating agencies, to the extent relevant to PacifiCorp. These rating agency communications are confidential and are provided subject to the terms and conditions of the protective order in this proceeding. (Bruce N. Williams is expected to sponsor this response at hearing. IDAHO P AC-07- ROCKY MOUNTAIN POWER MONSANTO DATA REQUESTS SET 2 (1-65) CONFIDENTIAL ATTACHMENT MONSANTO 2.51 -(1- ON THE ENCLOSED CONFIDENTIAL CD P AC- E-07 -05/Rocky Mountain Power July 31, 2007 Monsanto 2nd Set Data Request 2. Monsanto Data Request 2. Referring to page 8.2 ofMr. McDougal's Exhibit No. 11 , for each "Steam Production" project (other than the Huntington Scrubber), for the Hermiston combustion turbine rotor replacement and for each transmission project, please:a. Identify the reason for the expenditure;b. State whether the capital expenditure will reduce expenses, and if so quantify the reduction and explain how much of the reduction is included in the test year in this proceeding; and Please explain whether the project will lead to increased capacity to serve retail customers or to sell in the wholesale market, and if so quantify the extent of additional capacity and energy, the amount of potential net revenue, and the amount included in the test year in this proceeding. Response to Monsanto Data Request 2. Please see Attachment Monsanto 2.55 on the enclosed CD. In particular, please refer to Tab "Jan06 - Dec06 Cap Add Detail" for the data requested above. (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) TT A CHMENT MONSANTO 2. ON THE ENCLOSED CD PAC-07-05/Rocky Mountain Power July 31 , 2007 Monsanto 2nd Set Data Request 2. Monsanto Data Request 2. With respect to page 8.8.4 of Mr. McDougal's Exhibit No. 11 , for each "steam production" project (other than Blundell Bottoming Cycle) and for each transmission" project, please:a. Identify the reason for the expenditure;b. State whether the capital expenditure will reduce expenses, and if so quantify the reduction and explain how much of the reduction is included in the test year in this proceeding; and Please explain whether the project will lead to increased capacity to serve retail customers or to sell in the wholesale market, and if so quantify the extent of additional capacity and energy, the amount of potential net revenue, and the amount included in the test year in this proceeding. Response to Monsanto Data Request 2. Please refer to Attachment Monsanto 2.55; in particular please refer to Tab Jan07 - Dec07 Cap Add Detail" for the data requested above. (Steven R. McDougal is expected to sponsor this response at hearing. PAC-07-05/Rocky Mountain Power July 31 , 2007 Monsanto 2nd Set Data Request 2. Monsanto Data Request 2. With reference to the direct testimony of Erich Wilson, page 6, please provide all workpaper studies and analyses that detail the $27.5 million company incentive compensation as reduced from the $33.9 million included in the 2006 unadjusted data. Response to Monsanto Data Request 2. There are no workpapers or specific studies related to the quantification of the $27.5 million. This amount is derived by taking the target incentive opportunity of each employee times their current base wage. The target incentive is established as outlined beginning on page 3 line 13 through page 4 line 12. (Erich D. Wilson is expected to sponsor this response at hearing.