20090413PAC to Monsanto 1-17.pdf

,~ROCKY MOUNTAIN
POWER
A DISION Of PAClACORP
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Apnl 10, 2009
Radal C. Budge
RACIN, OLSON, NYE, BUDGE &
BAILEY, C~TERED
P.O. Box 1391; 201 E. Center
Pocatello, Idao 83204-1391
RE: ID PAC-E-08-08
Monsanto Data Request Set 1 (1-17)
201 South Main. Suite 2300
Salt Lake City. Utah 84111
Please find enclosed PacifiCorp's responses to Monsanto Data Requests 1.1 - 1.17. Provided on
the enclosed CD are Attchments Monsanto 1.1 -1, 1.2, 1.10, 1.12b, 1.13, and 1.16. Provided on
the enclosed Confidential CD are Confdential Attachments Monsanto 1.1 -2 and 1.12 -(a&c).
The Confidential Attachments are being provided to paries who have signed a confdentiality
agreement pursuat to the protective order in ths case.
If you have any questions, please feel free to call me at [phone].
Sincerely,
~ d C1¿il ! ~
Ted Weston
Manager, Regulation
Enclosures
Cc: Tony YanelllIIPA
Eric OlsenlIIPA
Katie Iverson
Jean JewelllIPUC
Scott Woodbur/IPUC
.PAC-E-Q8-08/Rocky Mountain Power
April 10,2009
Monsanto Data Request 1.1
Monsanto Data Request 1.1
Please provide an electronic copy of production responses provided to other
paries.
Response to Monsanto Data Request 1.1
Please refer to Attachment Monsanto 1.1 -1 for responses and non confidential
attachments. Please refer to Confidential Attachment Monsanto 1.1 -2 for
confidential attachments. Confidential information is provided subject to the
terms and conditions of the protective order in this proceeding.
Going forward, Monsanto wil be copied on all responses in this docket as they
are completed.
.
IDAHO
PAC-E-08-08
ROCKY MOUNTAIN POWER
MONSANTO 1ST SET DATA REQUEST (1-17)
ATTACHMENT MONSANTO 1.1 -1
ON THE ENCLOSED CD
IDAHO
PAC-E-08-08
ROCKY MOUNTAIN POWER
MONSANTO 1ST SET DATA REQUEST (1-17)
CONFIDENTIAL (LEVEL YELLOW)
ATTACHMENT MONSANTO 1.1 -2
ON THE ENCLOSED CONFIDENTIAL CD
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.2
Monsanto Data Request 1.2
Please provide an electronic version of Exhibit 2, in Excel compatible format with
all formulas intact.
Response to Monsanto Data Request 1.2
Please refer to Attachment Monsanto 1.2.
IDAHO
PAC-E-08-08
ROCKY MOUNTAIN POWER
MONSANTO 1ST SET DATA REQUEST (1-17)
ATTACHMENT MONSANTO 1.2
ON THE ENCLOSED CD
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.3
Monsanto Data Request 1.3
Please provide an electronic version of all workpapers supporting Exhibit 2, in
Excel compatible format with all formulas intact.
Response to Monsanto Data Request 1.3
Please refer to the Company's response to Monsanto Data Request 1.2;
specifically Attachment Monsanto 1.2. As noted on the attachment, all numbers
were for ilustrative purposes, there are no supporting workpapers.
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.4
Monsanto Data Request 1.4
How does RMP propose to allocate cost responsibilty to customer classes for
recovery of ECAM-related costs?
Response to Monsanto Data Request 1.4
Please refer to Mr. Duvall's direct testimony on page 7 lines 19 through 23, page
8 lines 1 through 8 and page 9 lines 1 though 4.
PAC-E-08-08/Rocky Mountain Power
April 10,2009
Monsanto Data Request 1.5
Monsanto Data Request 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.
Response to Monsanto Data Request 1.5
Please refer to page 9, lines 1 through 4 ofMr. Duvall's testimony.
The Company does not believe the ECAM rate should be differentiated by
customer voltage leveL. The ECAM is a deferral of net power costs, generation
related expenses should be allocated the same for all customer classes.
P AC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.6
Monsanto Data Request 1.6
Does PacifiCorp have a balancing account for its Energy Charge Adjustment
Clause in California?
(a) If not, please explain why there is no balancing account for this mechanism.
(b) If yes, does the account ear a retur or interest on the balance?
(c) If the answer to "b" is yes, please identify the rate and basis for setting the
rate.
Response to Monsanto Data Request 1.6
Yes, please refer to the Company's response to IPUC Production Data Request 3.
(a) nla
(b) Yes
(c) The ECAC Balancing Account has monthly accruals with the interest rate
equal to 1/12 of the interest rate on Commercial Paper for the previous month
as published in the Federal Reserve Statistical Release, H.15.
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.7
Monsanto Data Request 1.7
With reference to RMP's filing in Utah PSC Docket No. 08-035-38 and RMP's
Response to UAE 2.1 though 2.3 in that docket please answer the following:
(a) Does 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 units decreased by approximately $77 milion whereas net power
cost decreased by only $5.9 millon?
(b) If Mr. Duvall disagrees with this characterization, please explain the basis for
the disagreement.
(c) Does Mr. Duvall agree that PacifiCorp's cost of gas swaps increased from
approximately $80 millon to $155 milion when the forward price cure 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 of the 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 significant net power cost volatilty?
Response to Monsanto Data Request 1.7
(a) No. The total fuel burn expenses for gas-fired units decreased by about
$700,000, which includes both the physical transactions that are used to
acquire the natural gas requirement and financial transactions, or swaps, that
are used to hedge market price risk.
(b) Please refer to the Company's response to subpar (a) above.
(c) No. The change in the settlement payments under the gas swaps changed by
the amount indicated. The increase in settlement payments under the gas
swaps were offset by lower physical gas costs, changes in the settlement
payments under electric swaps, and increased value of existing wholesale
sales.
P AC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.7
(d) Please refer to the Company's response to subpar (c) above.
(e) No. The Company does not "take positions" with gas swaps; rather, gas
swaps are used to hedge against the volatilty and risk of market based gas
prices. As indicated in subpar (a) of this question, for the three-month period
between September 30, 2008 and December 31, 2008, this market volatility
resulted in a swing of over $75 millon dollars in the cost of delivered gas.
Changes of similar magnitudes but opposite direction occurred in the first two
quarers of 2008. The gas swaps shown in GRID represent settlement amounts
associated with the swaps.
(f) Please refer to the Company's response to subpar (e) above.
(g) The $5.9 milion drop in net power costs when market prices for gas and
electricity changed as they did between September 30, 2008 and December
31, 2008 is an indicator that the Company is nearly fully hedged on both the
gas and electric side. Without an ECAM, the Company rates are based on the
results of a Commission ordered normalized power cost study, which endorses
a policy that net power costs in rates should be maintain at a stable level,
regardless how the market wil change. With an ECAM, the Company could
implement policy direction from the Commission concerning the appropriate
level of exposure to increases and decreases in market costs.
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.8
Monsanto Data Request 1.8
Please provide a copy of the guidelines PacifiCorp uses to manage its hedging
policy for net power costs.
Response to Monsanto Data Request 1.8
Please refer to the Company's response to IPUC Production Data Request 4;
specifically Confidential Attchment IPUC _Production 4 -2.
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.9
Monsanto Data Request 1.9
As of December 31, 2008 please state:
(a) What percentage ofPacifiCorp's projected 2009 fuel cost for its gas-fired
units was subject to fixed price contracts or otherwise hedged?
(b) What percentage ofPacifiCorp's 2010 fuel cost for its gas-fired units was
subject to fixed price contracts or otherwise hedged?
(c) What percentage ofPacifiCorp's 2011 fuel cost for its gas-fired units was
subject to fixed price contracts of otherwise hedged?
Response to Monsanto Data Request 1.9
(a) 94%
(b) 85%
(c) 69%
P AC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.10
Monsanto Data Request 1.10
For each of PacifiCorp's gas-fired generating facilties, please indicate:
(a) What procurement arrangement(s) are curently in place for the gas used at the
facility
(b) If more than one procurement arangement is in place, please indicate the
proportion of gas procured under each arangement.
(c) For each contractual procurement arrangement, please identify the
duration of
the contract and any changes in the volumes or price that are in place for the
duration ofthe contract.
Response to Monsanto Data Request 1.10
Please refer to Attachment Monsanto 1.10. Please note that Quantity is expressed
in MMBtu per month and, where Average Unit Price equals 0, the transaction
price is based on a floating index price. Column P of the spreadsheet has PODs;
"HRM" identifies Hermiston related transactions. There are no forward physical
Sumas purchases for Chehalis. East Side gas is not identified as plant specific.
IDAHO
PAC-E-08-08
ROCKY MOUNTAIN POWER
MONSANTO 1ST SET DATA REQUEST (1-17)
ATTACHMENT MONSANTO 1.10
ON THE ENCLOSED CD
PAC-E-08-08/Rocky Mountain Power
April 10,2009
Monsanto Data Request 1.11
Monsanto Data Request 1.11
As of December 31, 2008 please state:
(a) What percentage ofPacifiCorp'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?
Response to Monsanto Data Request 1.11
The percentage of delivered coal supplies tied to spot market pricing as of
December 31, 2008 is as follows:
(a) 2009: 0.74%
(b) 2010 : 8.74%
(c) 2011 : 14.06%
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.12
Monsanto Data Request 1.12
For each ofPacifiCorp's coal-fired generating facilties, please indicate:
(a) What procurement arrangement(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.
Response to Monsanto Data Request 1.12
(a) Please refer to Confidential Attachment Monsanto 1.12a&c.
(b) Please refer to Attachment Monsanto 1.12b.
(c) Please refer to Confidential Attachment Monsanto 1.12a&c.
This confidential information is provided subject to the terms and conditions of
the protective order in this proceeding.
IDAHO
P AC-E-08-08
ROCKY MOUNTAIN POWER
MONSANTO 1ST SET DATA REQUEST (1-17)
CONFIDENTIAL (LEVEL YELLOW)
ATTACHMENT MONSANTO 1.12 -(A&C)
ON THE ENCLOSED CONFIDENTIAL CD
IDAHO
PAC-E-08-08
ROCKY MOUNTAIN POWER
MONSANTO 1ST SET DATA REQUEST (1-17)
ATTACHMENT MONSANTO 1.12B
ON THE ENCLOSED CD
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.13
Monsanto Data Request 1.13
Does PacifiCorp have any coal supply contracts expiring in 2009. 2010 or 2011 ?
If yes, please describe and indicate the portion of the Company's coal supply
requirements that this represents.
Response to Monsanto Data Request 1.13
Yes. Please refer to Attachment Monsanto 1.13 for a list of coal supply contracts
expiring in 2009, 2010 and 2011. Please note while the Black Butte agreement
expires in 2009, a new coal supply agreement with Black Butte begins Janua 1,
2010. Also, PacifiCorp has the option to extend the Sufco agreement for two five
year terms beyond the primar term of2010.
Besides the list of contracts provided in Attachment Monsanto 1.13, the coal
prices under two long-term contracts are reset in 2011. The Naughton Plant is
supplies under a long-term coal supply agreement with Chevron Mining. The
contract provides for periodic price reopeners. The next price reopener is
effective January 1, 2011. The Sufco coal price wil also be reset on Januar 1,
2011, pursuant to a contract reopener.
IDAHO
P AC-E-08-08
ROCKY MOUNTAIN POWER
MONSANTO 1ST SET DATA REQUEST (1-17)
ATTACHMENT MONSANTO 1.13
ON THE ENCLOSED CD
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request l.14
Monsanto Data Request 1.14
What is the definition of "short-term firm purchases" and "long-term firm
purchases"as used by PacifiCorp in GRID?
Response to Monsanto Data Request 1.14
Short-term firm purchases refer to the firm purchase contracts that are one-year or
shorter in duration. Long term firm purchases refer to firm purchase contracts
that are longer than one year in duration.
P AC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.15
Monsanto Data Request 1.15
Wìth reference to RMP's filing in Utah PSC Docket No. 08-035-38, Exhibit
GND-l SS, p. 2, please state:
(a) What percentage of the 270,326,836 MWH oflong-term firm purchases is
subject to price variabilty during 2009?
(b) What percentage of these MWH is subject to price variabilty greater than
5%?
(c) What percentage of these MWH is associated with contracts that expire durng
2009?
(d) What percentage of these MWH is associated with contracts that expire during
201O?
(e) What percentage of these MWH is associated with contracts that expire during
2011?
Response to Monsanto Data Request 1.15
The 270,326,836 referred to in the request is the total expense of
the long-term
firm purchase contracts. The Company assumes that the subsequent questions
relate to MWh of the long-term firm purchases, which is 4,831,545 MWh.
(a) Please refer to page 15 of the Exhibit GND-ISS for average prices of those
long-term firm purchase contracts. The average prices of some of the
contracts change from month to month because the MWh var by month but
the payments are levelized, or the prices of the contracts are indexed to market
prices.
(b) Please refer to (a) above.
(c) The contracts that expire in 2009 do not have MWh impact.
(d) 286,081 MWh expire in 2010.
(e) 153,792 MWh expire in 2011.
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.16
Monsanto Data Request 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 term is used in
Exhibit No.2, p. 1) for each calendar year from 1999 through 2008.
..
(d) PacifiCorp's "Actual NPC ($IMWh)" (as this term is used in Exhibit No.2, p.
1) for each calendar year from 1999 through 2008.
Response to Monsanto Data Request 1.16
(a) Please refer to Attachment to Monsanto 1.16.
(b) The information requested is not available. This line is the actual net power
costs with adjustments that reflect prior Commission decisions (ie SMUD
imputed price). The Adjusted Actual NPC is only prepared in the context of a
regulatory filing requesting for recovery ofthe deferred net power costs
during a paricular test period.
(c) Please refer to the Company's response to subpar (a) above on line labeled as
"NET SYSTEM LOAD."
(d) Please refer to the Company's response to subpar (a) above on line labeled as
"Net Power Costlet System Load."
IDAHO
PAC-E-08-08
ROCKY MOUNTAIN POWER
MONSANTO 1ST SET DATA REQUEST (1-17)
ATTACHMENT MONSANTO 1.16
ON THE ENCLOSED CD
PAC-E-08-08/Rocky Mountain Power
April 10, 2009
Monsanto Data Request 1.17
Monsanto Data Request 1.17
From January 1, 1998 to the present, please identify each instace 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;
(e) total company retail load; and
(f) effective date of approved rates.
Response to Monsanto Data Request 1.17
Please refer to the Company's response to IIPA Data Request 7 which provides
net power costs requested in PacifiCorp's jurisdictions over the last five years,
along with corresponding load. A majority of the Company's rate cases since
1998 have been settled. In these cases, there have not been approved NPCs. In
other cases during this period, Commissions have made findings on NPC without
stating final approved NPC.
Due to changes in the Company's resource mix and implementation of
hedging
strategies and procurement policies as well as changes to the electrc, gas, and
coal markets comparng net power cost over an eleven year period would provide
little if any relevant information.