20100604Monsanto 1 (1-32) to PAC.pdf

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RECEiVED
iOID JUH -It AM 8:11
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]
IDAHO
UTlLlTl2S
Attorneys for Intervenor Monsanto Company
BEFORE TH IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR APPROVAL )
OF CHANGES TO ITS ELECTRIC SERVICE ) Case No. PAC-E-10-07
SCHEDULES AND A PRICE INCREASE OF $27.7 )
MILLION, OR APPROXIMATELY 13.7 PERCENT )
)
MONSANO COMPAN'S FIRST DATA REQUESTS
TO ROCKY MOUNAI POWER
MONSANTO COMPANY, by and though their attorneys, hereby submits this First Data
Request to Rocky Mountan Power, pursuat to Rule 225 of the Idaho Public Utility
Commission's Rules of Procedure, IDAPA 31.01.01, as follows:
Monsanto 1-1: Please provide a copy of all data requests received from Commission Staf and
other paries. Please consider this to be a continuing request and supplement your response as
additional requests are received.
Monsanto 1-2: Please provide a copy of your responses to the data requests from Commission
Staff and other paries. Please consider ths to be a continuing request and supplement your
response as additional requests are received.
Monsanto 1-3: Please provide a copy of your responses to requests conveyed to Rocky
Mountan Power other than though formal data requests from Commission Staff and other
paries. Please consider this to be a continuing request and supplement your response as
additional requests are received.
MONSANTO COMPANYS FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER-1
..
Monsanto 1-4: Please provide a copy of the workpapers supporting the testimony of A. Richard
Walje. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 1-5: Please provide a copy of the workpapers supporting the testimony of Steven R.
McDougaL. To the extent that the workpapers include any spreadsheets or models, please
provide in executable native format with all formula intact.
Monsanto 1-6: Please provide a copy of the workpapers supporting the testimony of Bruce N.
Wiliams. To the extent that the workpapers include any spreadsheets or models, please provide
in executable native format with all formula intact.
Monsanto 1-7: Please provide a copy of the workpapers supporting the testimony of Samuel C.
Hadaway. To the extent that the workpapers include any spreadsheets or models, please provide
in executable native format with all formula intact.
Monsanto 1-8: Please provide a copy of the workpapers supporting the testimony of Stefan A.
Bird. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 1-9: Please provide a copy of the workpapers supporting the testimony of Mark R.
Tallman. To the extent that the workpapers include any spreadsheets or models, please provide
in executable native format with all formula intact.
Monsanto 1-10: Please provide a copy of the workpapers supporting the testimony of Chad A.
Teply. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 1-11: Please provide a copy of the workpapers supporting the testimony of John A.
Cupparo. To the extent that the workpapers include any spreadsheets or models, please provide
in executable native format with all formula intact.
Monsanto 1-12: Please provide a copy of the workpapers supporting the testimony of Darell T.
Gerrard. To the extent that the workpapers include any spreadsheets or models, please provide
in executable native format with all formula intact.
Monsanto 1-13: Please provide a copy of the workpapers supporting the testimony of Dr. Peter
C. Eelkema. To the extent that the workpapers include any spreadsheets or models, please
provide in executable native format with all formula intact.
Monsanto 1-14: Please provide a copy of the workpapers supporting the testimony of Dr. Hui
Shu. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 2
Monsanto 1-15: Please provide a copy of the workpapers supporting the testimony of Cindy A.
Crane. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 1-16: Please provide a copy of the workpapers supporting the testimony of Ryan R.
Fuller. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 1-17: Please provide a copy of the workpapers supporting the testimony ofC. Craig
Paice. To the extent that the workpapers include any spreadsheets or models, please provide in
executable native format with all formula intact.
Monsanto 1-18: Please provide a copy of the workpapers supporting the testimony of Wiliam
R. Griffith. To the extent that the workpapers include any spreadsheets or models, please
provide in executable native format with all formula intact.
Monsanto 1-19: If not included in the responses to other data requests, please provide the
jursdictional allocation models in executable native format with all formulas intact. Please
include the allocations for both the Rolled-In and the Revised Protocol.
Monsanto 1-20: If not included in the responses to other data requests, please provide the class
cost of service allocation model in executable native format with all formulas intact. Please
include the allocations for both the Rolled-In and the Revised Protocol.
Monsanto 1-21: Please provide Monsanto's actual hourly load data for the test year and all
adjustments made to that actual hourly load data for puroses of:
a. The jursdictional allocations
b. The class cost of service allocations.
Monsanto 1-22: If not provided in response to other data requests, please provide all
workpapers and supporting data showing the derivation of each external allocation factor for
both the Rolled-In and Revised Protocol versions of the jursdictional allocation models.
Monsanto 1-23: If not provided in response to other data requests, please provide all
workpapers and supporting data showing the derivation of each external allocation factor for
both the Rolled-In and Revised Protocol versions of the class cost of service allocation models.
Monsanto 1-24: Please provide a history of all curilments and/or interrptions made to
Monsanto for the years 2001 though 2009, inclusive. Please detail the time and date of the
curailment or interrption, the amount and reason (economic curailment, operating reserves,
system integrity, etc.).
Monsanto 1-25: If not provided in response to other data requests, please provide the pre-fied
exhibits in executable native format with all formulas intact, where available.
MONSANTO COMPANYS FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 3
Monsanto 1-26: Please fully explain the basis upon which Rocky Mountain Power determines
that Monsanto's entire load (both the firm 9 MW and the interrptible load) should be treated as
firm in this filing for the allocation of jurisdictional costs.
Monsanto 1-27: Please provide a copy of the most recent contract Rocky Mountain Power has
with Nucor, including the interrptibility provisions, as well as Nucor's interrption history for
the years 2001 though 2009, inclusive.
Monsanto 1-28: Please explain how Nucor's interrptible load has been treated for puroses of
the jursdictional allocation model and provide Nucor's twelve monthly coincident peaks
included in the Utah jurisdiction of the JAM study used in this fiing.
Monsanto 1-29: For Docket No. 09-035-23 before the Utah Public Service Commission, please
provide Nucor's twelve monthly coincident peaks used in the jursdictional and class cost of
service studies.
Monsanto 1-30: Please provide a copy of the most recent interrptible contract Rocky
Mountai Power has with Magcorp, including the interrptibiliy provisions, as well as
Magcorp's interrption history for the years 2001 through 2009, inclusive.
Monsanto 1-31: Please explain how Magcorp's interrptible load has been treated for puroses
of the jursdictional allocation model, and provide Magcorp's twelve monthly coincident peaks
included in the Utah jurisdiction of the JAM study.
Monsanto 1-32: For Docket No. 09-035-23 before the Uta Public Service Commission, please
provide Magcorp's twelve monthly coincident peaks used in the jurisdictional and class cost of
service studies.
~DATED this ~ day of June, 2010.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By ìi ~'~
RADALL C. BUDGE
MONSANTO COMPANYS FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 4
CERTIFICATE OF MAING
vdI HEREBY CERTIFY that on this -l day of June, 2010, 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, Secreta (original and 3)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail: jjewell~puc.state.id.us U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Uta 84111
ted. weston(ßpacificorp.com
E-Mail
Danel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
daniel.solander(ßpacificorp.com
E-Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Fax: [phone]
dataequest(ßpacificorp.com E-Mail
Maurce Brubaker
Katie Iverson
Brubaker & Associates, Inc.
1215 Fern Ridge Parkway, Suite 208
St. Louis, MO 63141
mbrubaker(ßconsultbai.com
kiverson(ßconsultbai.com
E-Mail
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
jim.r.smith§monsanto.com E-Mail
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 5
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
P.O. Box 1391
Pocatello, Idaho 83204-1391
elotßacinelaw.net
Gar Kajander
Manager, Energy Procurement
Monsanto Company
800 N. Lindbergh Blvd., Z C2NF
St. Louis, Missour 63167
Gar.r.kajander(ßmonsanto.com
Rick Anderson
Energy Strategies, LLC
215 S. State Street, #100
Salt Lake City, Utah 84111-2322
randerson(ßenergystrat.com
E-Mail
E-Mail
E-Mail
~~,~RANDALL C. BUDGE
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - 6