20070913Monsanto to PAC 9-1 to 9-13.pdf

LOUIS 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~
JONATHON S. BYINGTON
DAVE BAGLEY
CAROL TIPPI VOLYN~~
THOMAS J. BUDGE
CANDICE M. MCHUGH'"
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
BOISE OFFICE
101 SOUTH CAPITOL-
BOUL-EVARD, SUITE 208BOISE, IDAHO 83702
TEL-EPHONE, [phone]
FACSIMIL-E, (208) 433'0167
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone] IDAHO FALLS OFFICE
www.racinelaw.net
477 SHOUP AVENUE
SUITE 203A
10AHO FAL-L-S, ID 83402
TEL-EPHONE, [phone]FAC5IMIL-E' [phone]
SENDER'S E-MAIL ADDRESS: rcb(Q:iracinelaw.net 'AL-SO MEMBER WY .. IL- BARSHAL-SO MEMBER UT BAR
u'AL-SO MEMBER CO BAR
tAL-SO MEMBER D. C. BAR
ttAL-50 MEMBER MO BAR.AL-SO MEMBER IL- BAR
..AL-50 MEMBER WA BAR
September 10, 2007
L..,r--..Jc:o
.....
Jean Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
=ic:
Z::
~~~~~~:~;:::;:(';';.
:t::"
....,,-
Dear Mrs. Jewel:
(/)
fTl ;'J
c...:'
('")
Re:PA C-
c/)
::':)
(1)
- .
Enclosed for filing please find the original and three copies of Monsanto Company s Ninth
Data Requests to Rocky Mountain Power.
Thank you for your assistance.
RCB:sab
Enclosurescc: Service List (via e-mail)
R E C E j \'
Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
7D07 ~L-
' "
' npwLI J rill C'
UTjL (fr~~(j iSEW);
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 NINTH DATA REQUESTS
TO ROCKY MOUNTAIN POWER
MONSANTO COMPANY, by and through their attorneys, hereby submits this Ninth
Data Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utility
Commission s Rules of Procedure, IDAPA 31.01.01 , as follows:
Monsanto 9-1: Referring to the direct testimony of RMP witness, Erich Wilson at 19, please
identify the amount of pension cash contributions and F AS 87 pension expense on a total
company and Idaho basis recorded over the last five years , and projected over the next five years,
Monsanto 9-2: Please provide all support for Mr, Wilson s contention at page 20 of his
testimony that "over the long run, the accrued pension expense will equal the total pension cash
contributions; however, in a given year, the cash contribution maybe significantly different than
the accrued expense
Monsanto 9-3: At page 16 of Mr. Wilson s Testimony, please state the impact on the
company s on-going annual pension expense caused by its decision to freezing its defined
benefit pension plan and switch to a cash basis pension plan as of May 31 , 2007. Also, please
identify the amount of pension trust assets and the plan benefit obligation as of May 31 , 2007.
Finally, state whether the current pension trust balance is adequate to fund the new benefit plan
obligation.
MONSANTO COMPANY'S NINTH DATA REQUEST FOR ROCKY MOUNTAIN POWER-
Monsanto 9-4: Please estimate the amount of total company and Idaho allocated retirement plan
cost using the cash basis formula set forth in Mr. Wilson s testimony, pages 16 and 17 , and the
change to the company s 401k expense created by this proposed change. Please compare these
on-going retirement costs to the amount of retirement plan and 401k expenses included in the
company s filing in this case.
Monsanto 9-5: Please provide a history of all curtailments and/or interruptions made to
Monsanto for the years 2001 through 2005, inclusive. Please detail the time and date of the
curtailment or interruption, the amount and reason (economic curtailment, operating reserves
system integrity, etc.
Monsanto 9-6: Reference Exhibit 29, Tab 5, Page 7 (Idaho Cost of Service Study). For the
coincident peaks in September, November and December for Monsanto, the cost study uses the
following data (kW at sales):
September: 166 800 + 67 000 = 233 800
November: 167 690 + 67 000 = 234 690
December: 172 582 + 67 000 = 239 582
However, the information provided in response to Attachment Monsanto 1.17-2 clearly shows
that Monsanto was purchasing buy-through (i., replacement) energy during those coincident
peaks as follows:
9/5/2006: 4 hours ~ 67
11/29/2006: 5 hours ~ 67
12/18/2006: 8 hours ~ 67
Furthermore, the "Monsanto Adjustment" tab of Attachment Monsanto 1.17.2 also shows the
buy-through MW for these three months, as well as Page 10.12 of Mr. McDougal's Exhibit 11.
Mr. McDougal has removed the buy-through load from both the monthly energy loads, as well as
the appropriate monthly coincident peaks.a. Please confirm or deny that Monsanto coincident peaks for the months of
September, November and December are overstated by 67 MW (at sales) in Exhibit 29 as a
result of double-counting the buy-through kW.
b. If denied, please explain how Monsanto s loads could physically reach a
maximum load of close to 240 MW and/or how those loads correctly reflect Monsanto s loads
when the JAM model has reduced the metered loads by the buy-through MW.
If confirmed, please provide a corrected version of Exhibit 29.
MONSANTO COMPANY'S NINTH DATA REQUEST FOR ROCKY MOUNTAIN POWER - 2
Monsanto 9-7: Reference Monsanto s hourly MWH of energy provided in Attachment
Monsanto 1.17-
a. Please confirm or deny that the 8 760 hours of energy shown in this
attachment are actual metered load at sales.
b. Please confirm or deny that the metered energy includes any buy-through
(i., replacement) energy.
c. The total energy shown for Monsanto in Exhibit 29 is 1 395 545 MWH.
However, the total MWH shown in Attachment Monsanto 1.17-1 is 1 360 773 MWH, Removing
the buy-through energy of 9 903 MWH and adding back in curtailment and interruption energy
of 34 948 MWH results in a total load of 1 385 818 MWH. Please confirm or deny that
Monsanto s energy load in Exhibit 29 is overstated by 9 727 MWH.
d. If denied, please explain how Monsanto s loads in Attachment Monsanto
1.17-1 have been reduced for buy-through (i., replacement) energy and provide Monsanto
hourly loads before the replacement energy has been removed.. F or any hour in which
Monsanto s MWH load is greater 185 000 MWH, please identify and explain how Monsanto
loads could reach this amount.e. If confirmed, please provide a corrected verSIOn of Exhibit 29 with
Monsanto s energy loads corrected.
Monsanto 9-8: Does the March 2007 market price forecast utilized in the GRID models used to
value the Monsanto contract for 2008 and 2009 include a price component for capacity? If yes
please quantify the capacity component. Describe in detail how any adjustment to the market
price forecast was made to account for the value of capacity.
Monsanto 9-9: In the recently released final copy of PacifiCorp s 2007 Integrated Resource
Plan, Chapter 4 (Resource Needs Assessment), page 81 , a statement is made regarding an
increase in interruptible resources for the Company. The statement, in referring to an increase in
annual capacity positions reads in part; "The slight increase in 2009 is due to . . . and an increase
in the curtailment portion of the Monsanto contract." The table following the statement, Table
, indicates an increase in interruptible capacity in 2009 of 65 MW s. Please explain the basis
of the expected change in the Monsanto contract to transpire in 2009.
Monsanto 9-10: With regard to Mr. McDougal's Exhibit 11 , page 5., under the heading of
Adjustment to Expense , please provide an explanation of what constitutes the difference
between Existing Firm Energy and Post-Merger Firm Energy.
Monsanto 9-11: With regard to Mr. McDougal's Exhibit 11 , page 5.1.1 , please explain the
difference between the entries "Fuel Consumed - Gas" and "Natural Gas Consumed"
MONSANTO COMPANY'S NINTH DATA REQUEST FOR ROCKY MOUNTAIN POWER - 3
Monsanto 9-12: With respect to Mr. McDougal's Exhibit 11 , page 5.1.1 , under the heading
Purchase Power" (Account 555), line entitled "Post Merger Firm , please provide a detail
analysis and description of how normalizing the booked cost of this entry resulted in an
approximate 165% increase in value.
Monsanto 9-13: With respect to Mr. McDougal's Exhibit 11 , page 5.1.1 , please provide a
detailed analysis and explanation of how normalizing "Natural Gas Consumed" (Account 547.1)
resulted in an approximate 115% increase in value over booked cost.
DATED this loth day of September, 2007.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
~~'~
For RANDALL C. BUDGE
MONSANTO COMPANY'S NINTH DATA REQUEST FOR ROCKY MOUNTAIN POWER.
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 10th day of September, 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~puc.state.id.S. Mail
Brian Dickman
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
brian. di ckman~pacificorp. com
Mail
Dean Brockbank
Justin Brown
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
dean. brockb ank~pacifi corp. com
Justin. brown(CV,pacifi corp. com
Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Fax: [phone]
datarequest(q),pacifi corp. com Mail
Maurice Brubaker
Katie Iverson
Brubaker & Associates, Inc,
1215 Fern Ridge Parkway, Suite 208
St. Louis, MO 63141
ill brubaker~consultbai. com
ki verson~consul tbai. com
Mail
MONSANTO COMPANY'S NINTH DATA REQUEST FOR ROCKY MOUNTAIN POWER - 5
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~racinelaw . net
Mail
Tim Buller
Agrium, Inc.
3010 Condaroad
Soda Springs, Idaho 83276
tbuller~agrium.com
Mail
Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
cew(Ci),givenspursley. com Mail
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S., Ste. 250
Salem, OR 97302
dpeseau~excite.com Mail
~c,
-Fef-RANDALL C. BUDGE
MONSANTO COMPANY'S NINTH DATA REQUEST FOR ROCKY MOUNTAIN POWER.