20100617Monsanto 2 (1-74) to PAC.pdf

Mrs. Jean Jewell, Secreta
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
W. MARCUS W. NYE
RANDALL 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.
LANE V. ERICKSON
FREDERICK J. HAHN, III
DAVID E. ALEXANDER
PATRICK N. GEORGE
SCOTT J. SMITH
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN
CANDICE M. MCHUGH
CAROL T1PPI VOLYN
BRENT L. WHITING
JONATHON S. BYINGTON
DAVE BAGLEY
THOMAS J. BUDGE
JONATHAN M. VOLYN
MARK A. SHAFFER
JASON E. FLAIG
Dear Jean:
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
Boise: OFFICE
to t SOUTH CAPITOL
BOULEVARD, SUITE.208
BOISE, IDAHO 83702TELEPHONE: [phone]
FACSIMILE: [phone]
TELEPHONE [phone]FACSIMILE [phone] IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 107
POST OFFICE BOX 50698
IDAHO FALLS, ID 83405
TELEPHONE:. [phone]
FACSIMILE: (20S) 528-6109
ww.racinelaw.net
ALL OFFICES TOLL FREE
(877) 232-8 I 01
SENDER'S E-MAIL ADDRESS:rcb\!racinelaw.net
L.OUIS F. RACINE (1917.2005)
WILLIAMD. OLSON, OF COUNSEL
June 15,2010
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Re:
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PAC-E-10-07
Enclosed for filing please find the original and nine copies of Monsanto Company's Second
Data Requests to Rocky Mountain Power. Than you for your assistance.
RCB:rr
Enclosures
cc: Service List
~
. BUDGE
.
Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAlLEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-139 I
Telephone: [phone]
Fax: [phone]
rcb(qracinelaw.net
,,-RE",,l=;:_D
zuin JUN' 1 AM 8: 09
Attorneys for Intervenor Monsanto Company
BEFORE TH IDAHO PUBLIC UTITIES COMMSSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR APPROVAL )
OF CHANGES TO ITS ELECTRIC SERVICE )
SCHEDULES AND A PRICE INCREASE OF )
$27.7 MILLION, OR APPROXIMATELY )13.7 PERCENT )
)
Case No. PAC-E-io-07
MONSANO COMPAN'S SECOND DATA REQUESTS
TO ROCKY MOUNAI POWER
MONSANTO COMPANY, by and though their attorneys, hereby submits ths Second
Data Request to Rocky Mountan Power, pursuant to Rule 225 of the Idaho Public Utilty
Commission's Rules of Procedure, IDAPA 31.01.01, as follows:
Monsato 2.1: Please provide workpapers that show the source and calculations pertining to the
Company's NPC study(s), including the net power cost report in Excel, the GRID project and
access to the NPC modeL.
Furher, it should be noted that all requests for spreadsheets or any other documentation which
includes numerical calculations should be provided in a working format with all cells and
formula intact. Ths is a continuig request for all discovery requests.
Monsanto 2.2: Please provide a copy of all PacifiCorp discovery responses and attchments
from Case No. PAC-E-07-05 related to NPC that were provided in response to discovery from
Monsanto and Sta.
Monsanto 2.3: Please provide a working copy ofthe entire NPC study that shows the authorized
MONSANO'S SECOND DATA REQUESTS TO ROCKY MOUNAI POWER-l
NPC from Case No. PAC-E-08-07.
Monsanto 2.4: Please provide a copy of the Idaho Commission Order for Case No. PAC-E-08-
07.
Monsanto 2.5: Does the Company agree to allow Monsanto to use discovery responses for the
following cases: Washington Docket No. UE-090205, Wyoming PSC Docket Nos. 20000-352-
ER-09, 20000-342-EA-09, 20000-341-EP-09 and 20000-333-ER-08?
Monsanto 2.6: Please provide the calculation and supporting workpapers for the $16.5 millon
increase for wheeling expense.
Monsanto 2.7: Please explain how STF transmission capability and expense were modeled in
GRID and provide all supporting workpapers.
Monsanto 2.8: Please provide the workpapers that calculated planed and unplaned forced
outage rates used in GRID including all back-up data showing each outage and duration
considered in the time period plus NERC cause code, tye of event duration, energy lost, etc.
Monsanto 2.9: Please provide the heat rate cures for each resource and the spreadsheets that
show the derivation of the heat rate cures.
Monsanto 2.10: Please provide the workpapers and documentation supporting the inputs in the
Other Cost file used in GRID, including all spreadsheets used to compute any of the line items in
the file including test year wheeling expense.
Monsanto 2.11: Please provide workpapers and documentation supporting the Energy Cost fie
in GRID, including all spreadsheets used to compute any of the line items in the fie.
Monsanto 2.12: Please provide workpapers and documentation supporting the Demand file in
GRID, including all spreadsheets used to compute any of the line items in the file.
Monsanto 2.13: Please identify the time periods used to calculate outage rates and other inputs
included in the GRID modeL.
Monsanto 2.14: Please provide a list and explanation of all modeling or logic
changes/enhancements to the GRID model that have been implemented since Case No. E-08-07.
Monsanto 2.15: Please provide all documents, workpapers or other information relied upon by
the Company in the development of market caps used in GRID.
Monsanto 2.16: Please provide the date and forward price cure (HLH, LLH, flat) used in GRID
for the test year and years 2011, 2012 and 2013.
MONSANO'S SECOND DATA REQUESTS TO ROCK MOUNAI POWER - 2
Monsanto 2.17: Did the Company use monthly screens or daily screens as was agreed to in
Wyoming Docket No.20000-352-ER-09 to model thermal plant dispatch? Ifnot, please explain
why not.
Monsanto 2.18: Please provide workpapers for any screens applied to correct uneconomic
commitment and dispatch of resources in the GRID modeL.
Monsanto 2.19: Please provide a plant breakdown of the 0.1 milion MWh hydro generation
decline referred to in Dr. Shu's testimony as compared to the amount included in the Company's
last filing.
Monsanto 2.20: Please explain the methodology used to calculate the $6.50 per MWH wind
integration cost used in GRID and whether that methodology includes an offset for changes in
retail load. Please provide the calculation, supporting workpapers and a sumar of
assumptions.
Monsanto 2.21: Please provide reasonable advance notice to Mr. Widmer of all IRP public
meetings on the Company's new wind integration cost study.
Monsanto 2.22: Please explain how the Company modeled Bridger Coal overburden strpping
costs and provide the supporting workpapers.
Monsanto 2.23: Please provide the calculation and supporting workpapers for the gas star-up
costs included in GRID.
Monsanto 2.24: Please provide the GRI transmission topology for Case No. E-08-07.
Monsanto 2.25: Please provide the GRID transmission topology for the curent filing plus an
explanation of all differences that have been made to the topology since the last filing, including
supporting documentation for the changes.
Monsanto 2.26: Please provide the latest status of the Condit hydro decommissioning including
the expected decommissioning date.
Monsanto 2.27: Please provide a list of thermal plant upgrades for the period 2004 though
December 3 i, 2010 including in-service dates and capacity changes.
Monsanto 2.28: Does the Company's market cap adjustment include any normalizing
adjustments for expected changes in wholesale market sizes to reflect new transmission capacity?
If not, please explain why not.
Monsanto 2.29: Does the Company's market cap adjustment include any normalizing
adjustments to wholesale market sizes to reflect increased thermal capacity durng the modeling
period? If not, please explain why not.
MONSANO'S SECOND DATA REQUESTS TO ROCK MOUNAIN POWER - 3
Monsanto 2.30: Please identify and quantify how the impact of reduced reliance of additional
purchases of transmission from third paries has been reflected in NPC. Please provide a
sumar of the comparable transmission capacity and associated expense that was included in
NPC in Case No. PAC-E -08-07.
Monsanto 2.31: Please provide the normalization term for each of the hydro resources included
in NPC.
Monsanto 2.32: Dr. Shu indicated that the Company will update its filing in rebutt testimony
for material changes in NPC. Please define material changes. Does the Company plan to update
the fiing to include actual STF transactions during the test year?
Monsanto 2.33: Please provide an explanation and provide supporting workpapers of each
material change to the filed NPC concurent with the time the Company becomes aware of such
changes.
Monsanto 2.34: Has the Idaho Commission previously approved of the Company's plan to make
the tyes of updates it proposes to make in rebuttal testimony? If yes, please provide the
associated commission order supporting such updates.
Monsanto 2.35: Please provide the workpapers used to calculate reduced hydro generation for
the motoring and effciency losses as discussed in Dr. Shu's testimony.
Monsanto 2.36: Please provide the calculation and supporting workpapers for the Company's
Bear River median hydro normalization.
Monsanto 2.37: Please provide the order on avoided costs for Case No. PAC-E-09-07.
Monsanto 2.38: Please provide the2008 IRP wind integration studies and supporting workpapers
referenced in Dr. Shu's testimony.
Monsanto 2.39: Please provide the 2011 IRP updated wind integration studies and supporting
documentation when they are completed.
Monsanto 2.40: Please provide a table showing the actual generation of each PacifiCorp coal,
gas and hydro unit modeled in GRID for each month of the period 2005 to the present. Please
provide the information electronically in excel spreadsheets.
Monsanto 2.41: Please provide the hourly generator logs for each wind, coal, gas and hydro
plant modeled in GRID for the four year period used to model outage rates and other inputs used
in GRID ("the Four Year Period"). Note that in cases where the Company does not possess unt
specific data for its share of a resource such as Bridger, please provide unt specific data for its
share of a resource as a whole including the output of other owners.
MONSANO'S SECOND DATA REQUESTS TO ROCK MOUNTAI POWER - 4
Monsanto 2.42: For the Four Year Period, please provide the hourly logs for the following
contracts/resources modeled in GRID in excel format.
a. The Mid Columbia hydro contracts
b. All SPA contracts
c. All wind resources
d. Each long-term purchase or sale contract
Monsanto 2.43: Please provide the most curent schedule for thermal and hydro generator
planed outages for 2010,2011,2012 and 2013.
Monsanto 2.44: For each transmission contract whose costs are included in GRID, please
identify the purose of the transaction, why it is used and useful in the test year, the amount of
transmission capacity or tye of transmission service it provides and where the capacity or
service is modeled in GRID.
Monsanto 2.45: Please provide all real time thermal unit operating characteristics comparable to
GRI inputs.
Monsanto 2.46: Please provide all real time hydro unt operating characteristics comparble to
GRID inputs.
Monsanto 2.47: Please provide electronic copies of all wholesale sales and purchase power
contracts and all fuel contracts modeled in GRID, a sumar list of which contracts have been
executed or changed since Case no. E-08-07 and workpapers used to develop the contracts GRID
model inputs. If the contracts have been changed, please provide a sumar of the changes.
Monsanto 2.48: Have any changes been made to the maximum capacities, minimum up or down
times or minimum unt capacities for thermal or hydro generators modeled in GRID since Case
No. PAC-E-08-07? If yes, identify each change, explain why the change was made and provide
supporting documentation, including engineering data, reports or analysis supporting the new
assumptions.
Monsanto 2.49: Provide data for the Four Year Period for all third par transmission imbalance
transactions that have been included in actual costs durng that period.
Monsanto 2.50: Please provide all non-firm transmission transactions that have been included in
actu net power costs for the Four Year Period. The data should also include non-firm
transmission acquired from PacifiCorp transmission that was not made possible as a result of
release of firm commitments from PacifiCorp Merchant. The information should be provided in
the same format as Attchment WIEC 3.27 Confidential from Wyoming Docket No. 20000-ER-
352-EP-09.
MONSANTO'S SECOND DATA REQUESTS TO ROCK MOUNAIN POWER - S
Monsanto 2.51: Please provide all STF transmission data that have been included in actual net
power costs for the Four Year Period. Please provide the information in the same format as
Attachment WIEC 1.18 from Docket No. 20000-ER-352-09.
Monsanto 2.52: Did the Company model the non-firm transmission that it uses in actual
operations? If yes, please provide the workpapers used to develop the modeling inputs. If not,
please provide the Company's justification for exclusion of these tyes of transactions.
Monsanto 2.53: Please provide the calculation and supporting documentation for sta-up fuel
costs used in this case including the star-up MMBTU and number of stas etc. Provide the
information for per unit sta costs and total star costs modeled in GRID.
Monsanto 2.54: Please provide an update of the Company's efforts to address the commitment
logic error in the GRID model, as opposed to the use of screens or other workarounds.
Monsanto 2.55: Please provide hourly spin and non-spin reserve and regulating margin
requirements (not available reserves) on the Company's generation system for the period
November 16,2006 to the most recent month available by plant.
Monsanto 2.56: Please provide hourly spin and non-spin reserve and regulating margin
requirements available on the Company's generation system for the period November 16,2006 to
the most recent month available by plant.
Monsanto 2.57: Please provide a sumar of all assumptions used in the Company's REC sales
calculation, a copy of the calculation including all supporting workpapers.
Monsanto 2.58 Please provide a sumar of the 2009 RECs that shows the amounts generated
by generated by plant, the amount sold by plant/contract, the sales price, the amount ofRECs
required to be baned and the amount of RECs available for sale that were not sold.
Monsanto 2.59: Please provide the actual cost of wind integration per MWh for the most recent
12 month period that the information is available or any other period that the Company has
performed the calculation. If the requested information is not available, please explain why it is
not available.
Monsanto 2.60: Please provide actual STF transaction detail included in GRID, in the same
format as Confdential Attachment WIEC 1.42 from Wyoming Docket No. 2000-352-ER-09. In
addition, please update the format from Attachment WIEC 1.42 to include colums that show the
bid and ask prices for the representative market on the day each transaction was executed.
Monsanto 2.61: Please provide actu STF transaction detail for the Four Year Period in the
same format as the prior request. A separate fie should be provided for each of the four years.
MONSANO'S SECOND DATA REQUESTS TO ROCK MOUNTAIN POWER - 6
Monsanto 2.62: Please provide the Offcial Forward Price Cure wholesale market prices for
Mead for the test year by month on a flat, HLH, LLH and hourly basis.
Monsanto 2.63: Has the Company made a FERC fiing to establish a wind integration tarff for
thrd par wind generators located within a PacifiCorp control area?
Monsanto 2.64: Please explain any changes the Company has made to wind integration cost
modeling methodology for third par wind developers located in the Company's control area
since Wyoming Docket No. 20000-ER-352-EP-09.
Monsanto 2.65: Please provide the approximate date that PacifiCorp became aware that there is
a cost associated with integrating wind generation located in its control area.
Monsanto 2.66: Please provide the actual monthly Cal iso wheeling and service fees for 2008,
2009 and 2010 to date.
Monsanto 2.67: Please provide a monthly breakdown of coal plant generation for peak, off-peak
and graveyard periods for each year of the Four Year Period used in ths filing. All information
should be provided on a PacifiCorp basis.
Monsanto 2.68: Please provide a monthly sumar thermal plant backed down for reserves
including reserves for wind integration for each year of the Four Year Period used in ths filing.
Monsanto 2.69: Please provide the Regulatory Fuel Budget and any other workpapers used in
developing fuel cost inputs for GRID.
Monsanto 2.70: Please provide a copy of the alternative coal supply analysis performed for the
Naughton plant.
Monsanto 2.71: Please provide a history of Biomass non-generation agreements executed by the
Company from 2000 though the most curent period available.
Monsanto 2.72: Please describe the Company's modeling for the Black Hils CT contract and
provide the calculation of GRID inputs and supporting documentation.
Monsanto 2.73: Please provide the Company's definition and calculation of the Mona market
size including all supporting workpapers.
Monsanto 2.74: Please describe how the Company decides whether it will exercise its option to
tae energy under the APS Supplemental Other contract.
MONSANO'S SECOND DATA REQUESTS TO ROCKY MOUNAI POWER-7
DATED this 1- fI~ day of June, 2010.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By~t'~
RADALL C. BUDGE
MONSATO'S SECOND DATA REQUESTS TO ROCKY MOUNAI POWER - 8
CERTIFCATE OF MALING
I HEREBY CERTIFY that on ths I J l~ay of June, 2010, I served a true, correct
and complete copy of the foregoing docume;i, to each of the followig, via the method so
indicated:
Jean D. Jewell, Secretar (original and 7)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail: jjewellêpuc.state.id.us U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: ted.westonCfpacificorp.com E-Mail
Daniel Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
E-mail: Danel.solanderCfpacificorp.com
E-Mail
~t~~
RADALL C. BUDGE -
MONSANO'S SECOND DATA REQUESTS TO ROCKY MOUNAI POWER - 9