20090106PAC to Monsanto 1-6.pdf

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RECEiVEDi 20 I South Main. Suite 2300
Salt lake City. Utah 84111
20U) JAN -6 PM 12: 50
December 16, 2008
Randall C. Budge
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204~1391
RE: ID PAC-E~08~07
Monsanto Data Request Set 1 (1-6)
Please find enclosed PacifiCorp's responses to Monsanto Data Requests i.1 - 1.6. Provided on
the enclosed CD are Attachments Monsanto 1.1 ~1, 1.2, 1.3, 1.4 -(a~(1-2),b), and 1.5. Provided
on the enclosed Confidential CD is Confidential Attchment Monsanto 1.1 ~2. The Confidential
Attchment is being provided to paries who have signed a confidentiality agreement pursuant to
the protective order in this case.
If you have any questions, please feel free to call me at (80l) 220~2963.
Sincerely,
1m \rM~Y()
Ted Weston ~
Manager, Regulation
Enclosures
Cc:
PAC~E.08~07/Rocky Mountain Power
December i 6, 2008
Monsanto Data Request i.l
Monsanto Data Request 1.1
Please provide a copy of all exhibits in electronic format with all formulae intact.
Response to Monsanto Data Request 1.1
Please refer to Attachment Monsanto 1. i ~ i for all non~confidential exhibits and
Confidential Attachment Monsanto i. i -2 for all confidential exhibits.
Confidential information is provided subject to the terms and conditions of the
protective order in this proceeding.
IDAHO
P AC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUEST (1-6)
ATTACHMENT MONSANTO 1.1 -1
ON THE ENCLOSED CD
IDAHO
PAC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUEST (1-6)
CONFIDENTIAL (LEVEL YELLOW)
ATTACHMENT MONSANTO 1.1-2
ON THE ENCLOSED CONFIDENTIAL CD
PAC-E-08~07/Rocky Mountain Power
December 16,2008
Monsanto Data Request 1.2
Monsanto Data Request 1.2
Please provide a copy of all workpapers supporting the jurisdictional cost study
fied by Mr. Brian S. Dickman.
Response to Monsanto Data Request 1.2
Please refer to Attachment Monsanto i .2.
IDAHO
P AC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUEST (1-6)
ATTACHMENT MONSANTO 1.2
ON THE ENCLOSED CD
PAC-E~08-07/Rocky Mountain Power
December i 6, 2008
Monsanto Data Request 1.3
Monsanto Data Request 1.3
Please provide a copy of all workpapers supporting the Idaho class cost of service
study fied by Mark E. Tucker.
Response to Monsanto Data Request 1.3
The main workpapers used in preparing the class cost of service study are
provided in the folder titled Attachment Monsanto i .3. This includes the working
cost of service model, as well as important input data including load research
data, substation peak data, customers per transformer data, and meter and service
drop cost data. Other important input data is included in the workpapers and
exhibits of Company witnesses Mr. Dickman and Mr. Zimmerman. For
workpapers related to Monsanto's demand and energy calculations, please refer to
the Company's response to Monsanto Data Request i.4.
IDAHO
PAC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUEST (1-6)
ATTACHMENT MONSANTO 1.3
ON THE ENCLOSED CD
PAC-E-Og-07/Rocky Mountain Power
December 16, 2008
Monsanto Data RequestlA
Monsanto Data Request 1.4
Referencing the loads used in the Idaho class cost of service of study:
a. Please provide all workpapers supporting the coincident peak demands for
Monsanto, including the actual peak demands and any adjustments made to
the demands as aresult of Monsanto being curtailed or interrupted; and
b. Please provide all workpapers supporting the energy used by Monsanto during
the test period, including the actual energy used and any adjustments made as
a result of Monsanto being curtailed or interrpted.
Response to Monsanto Data Request 1.4
a. Please refer to Attachment Monsanto l.4a - 1, which shows Monsanto's actual
metered load at the hour of coincident peak each month. These amounts are
entered into the cost of service model, and then modified by the amounts
shown in Attachment Monsanto l.4a -2. The totals in Column F are the
curtailment adjustment, which is added to the metered loads. The totals in
Column H are the buy through adjustment, which is subtracted from the
metered loads. In the cost of service model, this can be seen on the tab titled
Demand Factors, lines 143 and 144. These amounts are entered into the
model at the sales level, and then are grossed up to the input level on lines 93
and 94. The end result is Monsanto's load is shown as ifit were served as a
full retail customer without curtailment or buy though.
b. Please refer to Attachment Monsanto i Ab, which shows amounts biled to
Monsanto for usage during 2007. Line 13 shows firm and interruptible energy
used each month. This amount does not include any buy through energy used.
These monthly amounts are added to the curtailed MWh for each month,
shown in Attachment Monsanto l.4a -2, column Q. The resulting sum is
entered into the cost of service model on line 147 of the sheet Energy Factor.
Since the base data used for energy does not include buy through energy, no
adjustment is made.
IDAHO
PAC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUEST (1-6)
ATTACHMENT MONSANTO 1.4 -(A -(1-2),B)
ON THE ENCLOSED CD
P AC-E-08~07/Rocky Mountain Power
December 16,2008
Monsanto Data Request 1.5
Monsanto Data Request I.S
Please provide all interruptions and curtailments made to Monsanto's load for the
years 2007 and 2008 (to date), detailing hours, amount and type of curtailment.
Response to Monsanto Data Request I.S
Please refer to Attachment Monsanto 1.5.
IDAHO
PAC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
MONSANTO DATA REQUEST (1-6)
ATTACHMENT MONSANTO 1.5
ON THE ENCLOSED CD
PAC-E-08-07/Rocky Mountain Power
December 16, 2008
Monsanto Data Request 1.6
Monsanto Data Request 1.6
Please confirm or deny that it is the Company's proposal to seek a lower rate of
return in the class cost of service study in order to recognize the rate mitigation
cap. If denied, then please explain.
Response to Monsanto Data Request 1.6
Confirmed. The rate mitigation cap results in a lower revenue requirement and a
lower requested increase, which results in a lower target rate of return as
calculated in the class cost of service study. This is consistent with prior practice
in Idaho.