20090401Monsanto 1-17 to PAC.pdf

LAW OFFICES OF
W. MARCUS W. NYE
RANOALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT o. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
DAVID E. ALEXANDER
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
JONATHAN M. VOLYN
MARK A. SHAFFER
RACINE OLSON NYE BUDGE & BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
BOISE OFFICE
t01 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE. IDAHO 83702
TELEPHONE: [phone]FACSIMILE: [phone]
ww.racinelaw.net
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 2034
IDAHO FALLS, ID 83402
TELEPHONE: [phone]FACSIMILE: [phone]
TELEPHONE [phone]
FACSIMILE [phone]
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE 106ACOEUR D'ALENE, ID 83814
TELEPHONE: [phone]
SENDER'S E-MAIL ADDRESS:rcb(éracinelaw.net
ALL OFFICES TOLL FREE
[phone]
LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON. OF COUNSEL.
March 30, 2U09 r-c;=~:t-":;
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Mrs. Jean Jewell, Secretar
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
q:oco
Re: PAC-E-08-08
Dear Jean:
Enclosed for filing please find the original and nine copies of Monsanto Company's First
Data Requests to Rocky Mountain Power. Than you for your assistance.
~d~
RANDALL C. BUDGE
RCB:rr
Enclosures
cc: Service List
Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
rcb (tracinelaw. net
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20D9 APR - J ~M 8"(,./ .09
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR APPROVAL)
OF AN ENERGY COST ADJUSTMENT )MECHANISM )
)
)
Case No. PAC-E-08-08
FIRST DATA REQUESTS OF MONSANTO COMPAN
TO ROCKY MOUNTAIN POWER
MONSANTO COMPANY, by and through its attorneys, hereby submits this First Data
Requests to Rocky Mountain Power, pursuant to Rule 225 ofthe Idaho Public Utility
Commission's Rules of Procedure, IDAPA 31.01.01, as follows:
1.1 Please provide an electronic copy of production responses provided to other paries.
1.2 Please provide an electronic version of Exhibit 2, in Excel compatible format with all
formulas intact.
1.3 Please provide an electronic version of all workpapers supporting Exhibit 2, in Excel
compatible format with all formulas intact.
1.4 How does RM propose to allocate cost responsibility to customer classes for recovery of
ECAM-related costs?
MONSANO COMPAN'S FIRST DATA REQUESTS TO ROCKY MOUNTAI POWER - 1
1.5 What rate design is RMP proposing for ECAM-related charges? Does RMP believe this
charge should be differentiated by customer voltage level? If not, please explain.
1.6 Does PacifiCorp have a balancing account for its Energy Charge Adjustment Clause in
Californa?
( a) If not, please explain why there is no balancing account for this mechansm.
(b) If yes, does the account ear a return or interest on the balance?
(c) If the answer to "b" is yes, please identify the rate and basis for setting the rate.
1.7 With reference to RMP's filing in Utah PSC Docket No. 08-035-38 and RMP's Response
to UAE 2.1 through 2.3 in that docket please answer the following:
(a) D~es Mr. Duvall agree that when the Company's forward price curve was updated
to December 31,2008, PacifiCorp's projected fuel bur expense for its gas-fired unts decreased
by approximately $77 milion whereas net power cost decreased by only $5.9 milion?
(b) If Mr. Duvall disagrees with this characterzation, please explain the basis for the
disagreement.
(c) Does Mr. Duvall agree that PacifiCorp's cost of gas swaps increased from
approximately $80 milion to $155 milion when the forward price curve was updated?
(d) If Mr. Duvall disagrees with this characterization, please explain the basis for the
disagreement.
(e) Does Mr. Duvall agree that the cost of gas swaps in the GRID model reflects the
cost ofthe hedging positions taken by PacifiCorp?
(f) If Mr. Duvall disagrees with this characterization, please explain the basis for the
disagreement.
(g) Does Mr. Duvall believe that the $5.9 milion drop in net power cost when
forward price curves were updated from November 2, 2008 to December 31, 2008 is an indicator
of signficant net power cost volatility?
1.8 Please provide a copy of the guidelines PacifiCorp uses to manage its hedging policy for
net power costs.
1.9 As of December 31; 2008 please state:
MONSANO COMPAN'S FIRST DATA REQUESTS TO ROCKY MOUNTAI POWER - 2
(a) what percentage of PacifiCorp's projected 2009 fuel cost for its gas-fired units
was subject to fixed price contracts or otherise hedged?
(b) What percentage ofPacifiCorp's 2010 fuel cost for its gas-fired unts was subject to
fixed price contracts or otherwise hedged?
(c) What percentage of PacifiCorp's 2011 fuel cost for its gas-fired units was subject to
fixed price contracts of otherwise hedged?
1.10 For each ofPacifiCorp's gas-fired generating facilities, please indicate:
(a) What procurement arangement(s) are curently in place for the gas used at the facility
(b) If more than one procurement arrangement is in place, please indicate the proportion
of gas procured under each arangement.
(c) For each contractual procurement arangement, please identify the duration of the
contract and any changes in the volumes or price that are in place for the duration of the contract.
1. 11 As of December 31, 2008 please state:
(a) what percentage of PacifiCorp's 2009 projected fuel cost for its coal-fired units was
exposed to spot market prices?
(b) What percentage ofPacifiCorp's 2010 fuel cost for its coal-fired units was exposed to
spot market prices?
(c) What percentage ofPacifiCorp's 2011 fuel cost for its coal-fired units was exposed to
spot market prices?
1.12 For each ofPacifiCorp's coal-fired generating facilities, please indicate:
(a) What procurement arangement(s) are currently in place for the coal used at the
facility?
(b) If more than one procurement arangement is in place, please indicate the proportion
of coal procured under each arangement.
(c) For each contractual procurement arangement, please identify the duration of the
contract and any changes in the volumes or price that are in place for the duration of the contract.
1.13 Does PacifiCorp have any coal supply contracts expiring in 2009. 2010 or 20ll? If yes,
please describe and indicate the portion of the Company's coal supply requirements that
this represents.
MONSANO COMPAN'S FIRST DATA REQUESTS TO ROCKY MOUNAIN POWER - 3
1.14 What is the definition of "short-ter firm purchases" and "long-ter firm purchases"as
used by PacifiCorp in GRI?
1.15 With reference to RMP's filing in Utah PSC Docket No. 08-035-38, Exhibit GND-ISS,
p. 2, please state:
(a) What percentage of the 270,326,836 MW oflong-term firm purchases is subject to
price varability during 2009?
(b) What percentage of these MW is subject to price varability greater than 5%?
( c) What percentage of these MWH is associated with contracts that expire during 2009?
(d) What percentage of these MW is associated with contracts that expire during 2010?
( e) What percentage of these MW is associated with contracts that expire during 201 1 ?
1.16 Please answer the following:
(a) PacifiCorp's total company actual net power costs for each calendar year from 1999
through 2008.
(b) PacifiCorp's "Total Company Adjusted Actual NPC" (as this term is used in Exhibit
No.2, p. 1) for each calendar year from 1999 through 2008.
(c) PacifiCorp's total Company "Actual Retail Load" (as this ter is used in Exhibit No.
2, p. 1) for each calendar year from 1999 through 2008.
(d) PacifiCorp's "Actual NPC ($/MWh)" (as this term is used in Exhbit No.2, p. 1) for
each calendar year from 1999 through 2008.
1.17 From Januar 1, 1998 to the present, please identify each instance in which PacifiCorp's
net power cost has been approved by one of its six state jurisdictions. For each approval,
please provide:
(a) state;
(b) docket number;
(c) NPC test period;
(d) final approved NPC on a total company basis;
MONSANO COMPAN'S FIRT DATA REQUESTS TO ROCKY MOUNTAI POWER - 4
( e) total company retail load; and (f) effective date of approved rates.
DATED this 30th day of March, 2009.
RACINE, OLSON, NYE,BUDGE &
BAILEY, CHARTERED
~c,~By
RANDALL C. BUDGE
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 30th day of March, 2009, I served a tre, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, il 83720-0074
E-mail: jj ewell (£puc. state.id.us U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: ted.westonCfacificorp.com U.S. Mail
Daniel Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
E-mail: Daniel.solanderCfacificorp.com
U.S. Mail
MONSANO COMPAN'S FIRT DATA REQUESTS TO ROCKY MOUNTAIN POWER - 5
..
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise,Idaho 83720-0074
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
P.O. Box 1391
Pocatello, Idaho 83204-1391
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
Data Request Response Center
PacifiCorp
825 NE Multnomah St., Ste 2000
Portland, Oregon 97232
datareguest(?acificorp.com
U.s. Mail
Hand Delivery
U.s. Mail
Email
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RANDALL C. BUDGE
MONSANO COMPAN'S FIRST DATA REQUESTS TO ROCKY MOUNTAI POWER - 6