20070917PAC to Monsanto 9-6, 9-7.pdf

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September 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 9 (1-13)
Please find enclosed Rocky Mountain Power s Response to Monsanto Data Request 9.
and 9.7. Provided on the enclosed CD are Attachments Monsanto 9.6 and 9.7 c.
If you have any questions, please feel free to call me at [phone].
Sincerely,
)j/~~/
Brian Dickman, Manager
Regulation
Enclosures
Cc:James R. SmithIMonsanto
Maurice Brubaker/Monsanto
Richard Anderson/Energy Strategies
Jean JewelllIPUC
Eric Olsen/lIP A
Tony Y ankellIIP A
Conley Ward/Agrium
Dennis Peseaul Agrium
Brad Purdy/CAP AI
Timothy Shurtz
P AC-07-05/Rocky Mountain Power
September 14, 2007
Monsanto 9th Set Data Request 9.
Monsanto Data Request 9.
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-
clearly shows that Monsanto was purchasing buy-through (i., replacement)
energy during those coincident peaks as follows:
9/5/2006: 4 hours ~ 67
11129/2006: 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
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.
c. If confirmed, please provide a corrected version of Exhibit 29.
Response to Monsanto Data Request 9.
a. The question refers to the cost of service study which is Exhibit 30. In the
cost of service study, service to Monsanto is treated as firm retail service. To
accomplish this, any curtailments are added back to their metered demand and
energy totals. In addition, any buy-through or replacement energy and kW is
subtracted because these are treated as purchased power.
Rocky Mountain Power agrees that the metered coincident peak
loads of Monsanto for the months of September, November, and December
include 67 MW of buy-through kW in Exhibit 30. The buy-through kW
amounts should be deducted from the metered loads before the addition of the
curtailed kW. This deduction did not occur in September, November and
December, and Rocky Mountain Power acknowledges that it should have.
b. Not applicable.
P AC- E-07 -05/Rocky Mountain Power
September 2007
Monsanto 9th Set Data Request 9.
c. A revised Exhibit 30 is provided as Attach Monsanto 9.6. This version of the
cost of service model also incorporates the net power cost adjustment that was
provided in response to Monsanto 7.
(Mark E. Tucker prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 9 (1-13)
ATTACHMENT MONSANTO 9.
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
September 14, 2007
Monsanto 9th Set Data Request 9.
Monsanto Data Request 9.
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
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 s hourly loads before the replacement energy has been
removed.. For any hour in which Monsanto s MWH load is greater 185 000
MWH, please identify and explain how Monsanto s loads could reach this
amount.
e. If confirmed, please provide a corrected version of Exhibit 29 with
Monsanto s energy loads corrected.
Response to Monsanto Data Request 9.
a. The data is interval data for the total load to Monsanto for calendar year 2006.
760 hours.
b. The data includes all energy delivered to Monsanto for calendar year 2006.
c. The question refers to the cost of service study which is Exhibit 30.
Monsanto s energy in the cost of service study is not derived from the data
shown in Attachment Monsanto 1.17-1. It is taken from the firm and
interruptible energy shown in Monsanto s monthly bills during the test period
in order to match energy to revenues in the test period. Curtailed or
interrupted energy is added back to the billed totals. The monthly amounts for
each category are shown in Attach Monsanto 9.7c. The monthly and annual
totals shown in this attachment correspond to the MWh by Month at Sales
totals shown in Exhibit 30, Tab 5, Page 16. The annual total is 1 395 545
MWh. Replacement. or buy-through energy is excluded from this calculation
and therefore does not need to be adjusted out. Monsanto s energy totals are
accurate as shown in Exhibit 30 and do not need to be adjusted.
d. Please refer to response to part c above.
e. No correction to Monsanto s energy totals is necessary.
P AC-07-05/Rocky Mountain Power
September 2007
Monsanto 9th Set Data Request 9.
(Mark E. Tucker prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUESTS SET 9 (1-13)
ATTACHMENT MONSANTO 9.7 c
ON THE ENCLOSED CD