20100621PAC to Monsanto 1 (1-32).pdf

~~Y!~~o~OUNTAIN RECEt\/
201 South Main, Suite 2300
Salt Lake City, Uth 84111
inm JON 2\ AM
9: 29
June 15,2010
Randall C. Budge
RACIN, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E, Center
Pocatello, Idaho 83204-1391
RE: ID PAC-E-1O-07
Monsanto Data Request Set 1 (1-32)
Please find enclosed Rocky Mountain Power's responses to Monsanto Data Requests 1.1 - 1.32,
excluding 1.4, 1.21 and 1,27-1.32, which will be provided separately upon completion. Provided
on the enclosed CD are Attachments Monsanto 1.5, 1.7 -1,1.13,1.17,1.18, and 1.19. Certain
responses contan confdential information; confdential information will be provided
subsequently, soon after Rocky Mountain Power receives a protective agreement from Monsto
regarding use of the company's confdential inormation in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J1ú(WtØ'Ý~
J. Ted Weston
Manager, Reguation
PAC-E-10-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.1
Monsanto Data Request 1.1
Please provide a copy of all data requests received from Commssion Staff and
other paries. Please consider ths to be a contiuig request and supplement your
response as additional requests are received.
Response to Monsanto Data Request 1.1
To date ths is the only set of data requests in ths case. As an intervenig par
in ths case Monsanto will be provided copies of all data requests and the
responses to those requests.
Recordholder: N/ A
Sponsor: N/A
PAC-E-1O-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.2
Monsanto Data Request 1.2
Please provide a copy of your responses to the data requests from Commssion
Staff and other paries. Please consider ths to be a continuing request and
supplement your response as additional requests are received.
Response to Monsanto Data Request 1.2
To date this is the only set of data requests in this case. As an intervening par
in this case Monsanto wil be provided copies of all data requests and responses.
Recordholder: N/ A
Sponsor: N/A
P AC-E-1 0-07/Rocky Mountain Power
June 15,2010
Monsanto Data Request 1.3
Monsanto Data Request 1.3
Please provide a copy of your responses to requests conveyed to Rocky Mountan
Power other than though formal data requests from Commssion Staf and other
pares. Please consider this to be a continuing request and supplement your
response as additional requests are received.
Response to Monsanto Data Request 1.3
To date this is the only set of data requests in ths cae. As an intervening par
in ths case Monsanto will be provided copies of all data responses.
Recordholder: N/ A
Sponsor: N/A
PAC-E-10-071R0cky Mountan Power
June 15,2010
Monsanto Data Request 1.5
Monsanto Data Request 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 il executable native format with all formula intact.
Response to Monsanto Data Request 1.5
Please refer to Attchments Monsanto 1.5 and 1.19 for copy of workpapers and
revenue requirement models.
Record holder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
P AC-E-1 0-071R0cky Mountan Power
June 15,2010
Monsanto Data Request 1.6
Monsanto Data Request 1.6
Please provide a copy of the workpapers supporting the testimony of Bruce N.
Wiliams. To the extent tht the workpapers include any spreadsheets or models,
please provide in executable native format with all formula intact.
Response to Monsanto Data Request 1.6
Mr. Bruce N. Wiliam's workpapers are provided as Confdential Attchments
Monsanto 1.6 -1 through 1.6 -3. Confdential inormation is provided subject to
the terms and conditions of the protective agreement in ths proceedig.
Recordholder:
Sponsor:
Bruce N. Willams
Bruce N. Wiliams
P AC-E-l 0-071R0cky Mountan Power
June 15,2010
Monsanto Data Request 1.7
Monsanto Data Request 1.7
Please provide a copy. of the workpapers supporting the testimony of Samuel C.
Hadaway. To the extent tht the workpapers include any spreadsheets or models,
please provide in executable native format with all formula intact.
Response to Monsanto Data Request 1.7
Please refer to Attchment Monsanto 1.7 -1 for the non-confdential workpapers
of Samuel C. Hadaway and Confdential Attchment Monsanto 1.7 -2 for
confdential workpapers. Dr. Hadaway's spreadsheets with formula were
provided on a CD as par of the rate filing request. Confdential inormation is
provided subject to the terms and conditions of the protective agreement in this
proceeding.
RecordhoIder:
Sponsor:
Samuel C. Hadaway
Samuel C. Hadway
PAC-E-10-071R0cky Mountain PowerJune 15,2010 .
Monsanto Data Request 1.8
Monsanto Data Request 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.
Response to Monsanto Data Request 1.8
There are no workpapers supportng the testimony of Stefan A. Bird.
Recordholder:
Sponsor:
Stefan A. Bird
Stefan A. Bird
P AC-E-1 0-07/Rocky Mountan Power
June 15,2010
Monsanto Data Request 1.9
Monsanto Data Request 1.9
Please provide a copy of the workpapers supporting the testiony 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.
Response to Monsanto Data Request 1.9
Please refer to Confidential Attchment Monsanto 1.9. Confdential information
is provided subject to the terms and conditions of the protective agreement inthis
proceeding.
Recordholder:
Sponsor:
Mark R. Tallman
Mark R. Tallman
PAC-E-10-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.10
Monsanto Data Request 1.10
Please provide a copy of the workpapers supporting the testiony 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.
Response to Monsanto Data Request 1.10
The testimony of Chad A. Teply is not supported with any specific workpapers,
spreadsheets, or models. A detaled listing of the capital projects to which the
testimony refers is provided in Mr. Steven R. McDougal's Exhbit No.2, page
.8.6.2.
Recordholder:
Sponsor:
Chad A. Teply / Steven R. McDougal
Chad A. Teply
PAC-E-10-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.11
Monsanto Data Request 1.11
Please provide a copy of the workpapers supporting the testimony of John A.
Cupparo. To the extent that the workpapersinclude any spreadsheets or models,
please provide in executable native format with all formula intact.
Response to Monsanto Data Request 1.11
Please refer to Confdential Attchments Monsanto 1.11 -1 and 1.11 -2.
Confdential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:
Sponsor:
John A. Cupparo
John A. Cupparo
PAC-E-10-07/Rocky Mountain Power
June 15,2010
Monsanto Data Request 1.12
Monsanto Data Request 1.12
Please provide a copy of the workpapers supportg the testiony of Darell T.
Gerrard. To the extent tht the workpapers include any spreadsheets or models,
please provide in executable native format with all formula intact.
Response to Monsanto Data Request 1.12
Please refer to Confdential Atthments Monsanto 1.11 -1 and 1.11 -2.
Confidential Information is provided pursuat to the protective agreement in ths
case.
Recordholder:
Sponsor:
Darell T. Gerrard.
Darell T. Gerrard.
PAC-E-1O-071R0cky Mountai Power
June 15,2010
Monsanto Data Request 1.13
Monsanto Data Request 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.
Response to Monsanto Data Request 1.13
Please refer to Attchment Monsanto 1.13. Some of these files are downoaded
fromthe weather normalization model (MetrxND). The model itself is a
proprieta softare product from ITRON that canot be provided.
Recordholder:
Sponsor:
Peter C. Eelkema
Peter C. Eelkema
PAC-E-10-07/Rocky Mountain Power
June 15,2010
Monsanto Data Request 1.14
Monsanto Data Request 1.14
Please provide a copy of the workpapers supportg 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 intat.
Re~ponse.to Monsanto Data Request 1.14
The net power cost sponsored by Dr. Shu is calculated using the Company's
GRID model that is a web-based application. In order to provide access to the
mode_th Company would need the followig information from the person who
wil access the model: name, business address, email address and signatue page
of the protective agreement in the curent proceeding.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-I0-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.15
Monsanto Data Request 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.
Response to Monsanto Data Request 1.15
Please refer to Confdential Attchment Monsanto 1.15. Confdential information
is provided subject to the terms and conditions of the protective agreement in this
proceeding.
Recordholder:
Sponsor:
Brian Durg
Cindy A. Crane
PAC-E-1O-071R0cky Mountan Power
June 15,2010
Monsanto Data Request 1.16
Monsanto Data Request 1.16
Please provide a copy of the workpapers supporting the testiony 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.
Response to Monsanto Data Request 1.16
The workpapers supporting the testimony of Ryan R. Fuller are provided as
Exhbits 41-46.
Recordholder:
Sponsor:
Ryan R. Fuller
Ryan R. Fuller
PAC-E-10-071R0cky Mountan Power
June 15,2010
Monsanto Data Request 1.17
Monsanto Data Request 1.17
Please provide a copy of the workpapers supporting the testimony of C. Craig
Paice. To the extent that the workpapers include any spreadsheets or models,
please provide in executable native format with all formula intact.
Response to Monsanto Data Request 1.17
Please refer to Attchment Monsanto 1.17 and the JAM model provided in
Attchment Monsanto 1.19, for the workpapers supporting the testimony of C.
Craig Paice.
Recordholder:
Sponsor:
C. Craig Paice
C. CragPaice
P AC-E-1 0-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.18
Monsanto Data Request 1.18
Please provide a copy of the workpapers supporting the testimony of Willam R.
Grffth. To the extent that the workpapers include any spreadsheets or models,
please provide in executable native format with all formula intact.
Response to Monsanto Data Request 1.18
Please refer to Attchment Monsanto 1.18 for the requested information.
Recordholder:
Sponsor:
Wiliam R. Grffith
Wiliam R. Griffith
P AC-E-1 0-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.19
Monsanto Data Request 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.
Response to Monsanto Data Request 1.19
Please refer to Attchment Monsanto 1.19. The JAM model can be switched
between the Rolled-In and Revised Protocol allocation methods on the
"Varables" tab using the "Allocation Method" drop down box in cell A8.
Record holder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-10-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.20
Monsanto Data Request 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.
Response to Monsanto Data Request 1.20
Please refer to the Company's response to Monsanto Data Request 1.17.
RecordhoIder:
Sponsor:
C. Craig Paice
C. Craig Paice
PAC-E-1O-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.22
Monsanto Data Request 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.
Response to Monsanto Data Request 1.22
Please refer to the JAM model provided as Attchment Monsanto 1.19, Tab
"Factors." Please also refer to Exhbit 2, Tab 10, pages 10.1 through 1.12 for a
hard copy of the Revised Protocol method factors and derivations.
Record holder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-10-071R0cky Mountan Power
June 15,2010
Monsanto Data Request 1.23
Monsanto Data Request 1.23
If not provided in response to other data requests, please provide all workpapers
and supporting data showig the derivation of each external allocation factor for
both the Rolled-In and Revised Protocol versions of the class cost of service
allocation models.
Response to Monsanto Data Request 1.23
Data supporting derivation of external allocation factors for either the Rolled-In
or Revised Protocol allocation methodologies is included in the electronic version
of the class cost of service model provided in the Company's response to
Monsanto Data Request 1.17.
Recordholder:
Sponsor:
C. Craig Paice
C. Craig Paice
PAC-E-IO-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.24
Monsanto Data Request 1.24
Please provide a history of all curailments and/or interrptions made to Monsanto
for the years.2001 through 2009, inclusive. Please detal the time and date of the
curailment or interrption, the amount and reason (economic curlment,
operating reserves, system integrity, etc.).
Response to Monsanto Data Request 1.24
Please refer to Confdential Attchment Monsanto 1.24. Confidential information
is provided subject to the terms and conditions of the protective agreement in this
proceeding.
Recordholder:
Sponsor:
Thomas E. Beck
Gregory N. Duvall
PAC-E-10-07IRocky Mountain Power
June 15,2010
Monsanto Data Request 1.25
Monsanto Data Request 1.25
If not provided in response to other data requests, please provide the pre-fied
exhbits in executable native format with all formulas intat, where available.
Response to Monsanto Data Request 1.25
The CD provided with the Application contained each of the witness' testimony
and exhibits in executable native format where available.
Recordholder: N/ A
Sponsor: N/ A
PAC-E-10-071R0cky Mountain Power
June 15,2010
Monsanto Data Request 1.26
Monsanto Data Request 1.26
Please fully explain the .basis upon which Rocky Mounta Power determines tht
Monsanto's entire load (both the firm 9 MW and the interrptible load) should be
treated as firm in ths fiing for the allocation of jursdictional costs.
Response to Monsanto Data Request 1.26
The Company utilzed the Revised Protocol methodology for jurisdictional
allocations which was approved by the Idaho Public Utilties Commssion in Case
PAC-E-02-3, Order29708 on Febru 28,2005. Protocol Appendix D, section
Special Contracts with Ancilar Service Contract Attbutes, states: "When
interrptions of a Special Contract customer's service occur, the host
jursdiction's Load-Based Dynamic Allocation Factors and the retal service
revenue are calculated as though the interrption did not occur."
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal