20100624PAC (more) to Monsanto 1 (1-32).pdf

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201 South Main. Suite 2300
Salt Lake City. Utah 84111
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June 23, 2010
Radall C. Budge
RACIN, OLSON, NYE, BUDGE &
BAILEY, CHATERED
P.O. Box 1391; 201 E. Center
Pocatellö,Idah083204-1391
RE: ID pAC-E-IO-07
Monsanto Data Request Set 1 (1-32)
Please find enclosed Rocky Mountain Power's responses to Monsanto Data Requests 1.4, 1.21,
1.27-1.29 and 1.31. Provided on the enclosed Confidential CD are Confdential Attchments
Monsanto 1.21 -(a-b), 1.27, and 1.29. Confdential Attchments are Confdential and are
provided to paries that have signed a protective order in ths docket.
If you have any questions, please feel free to call me at [phone].
Sincerely,
... T 't ~ MJ~Jli)il/~
J. Ted Weston
Manger, Reguation
Enclosure:
C.c.:
James R. Smith
Richad Anderson
George C. Carer, III
Denns Peseau
Garth R. Kajander
Maurce Btubaker
Bnan Collin
Michael Gorman
Kath Iverson
Mar Widmer
Michal Stak
Michael C. Creaer
Enc L. Olsen
Jea Jewell
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..,PAC-E-IO-07/Rocky Mountain Power
June 23,2010
Monsanto Data Request 1.4
Monsanto Data Request 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.
Response to Monsanto Data Request 1.4
There are no workpapers associated with the testimony of A. Richard Walje.
Recordholder:
Sponsor:
A. Richard Walje
A. Richard Walje
P AC-E-1 0-07/Rocky Mountain Power
June 23, 2010
Monsanto Data Request 1.21
Monsanto Data Request 1.21
Please provide Monsanto's actual hourly load data for the test year and all
adjustments made to that actul hourly load data for purposes of:
a. Thejurisdictional allocations
b. The class cost of service allocations.
Response to Monsanto Data Request 1.21
Due to Monsanto's unusual operating conditions during 2009 the Company
normalized Monsanto load for the test period based on a three-year average of
2006-2008 historical data. Please refer to Mr. PeterC. Eelkema's testimony for
additional information on development of the system loads.
a. The Company has not developed forecast hourly loads for Monsanto for
purposes of jurisdictional allocation. Notwithstanding, please refer to
Confidential Attachment Monsanto 1.21 a for the adjustment made to Idaho
load to .account for Monsanto's interrptions in the jurisdictional allocation
factors. This information is confidential and is provided subject to the terms
and conditions of the protective agreement in this proceeding. This
adjustment to Idaho load was made on page 10.14 of Exhibit 2.
b. Please refer to Confidential Attachment.Monsanto 1.21 b for the class cost of
service allocations. This info~~~ion is confidential and is provided subject to
the terms and conditions of the protective agreement in this proceeding. The
hourly load data used for the forecast test year is based on a three-year
average of Monsanto's histoncal usage during the years 2006-2008. Due to
outages and curtailments which occurred in 2009, the Company determined
that ths thee-year average data would be more representative of normal test
year operations.
Recordholder:
Sponsor:
Steven R. McDougal ~d C. Craig Paice
Steven R. McDougal and C. Craig Paice
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PAC-E-10-07/Rocky Mountain Power
June 23, 2010
Monsanto Data Request 1.27
Monsanto Data Request 1.27
Please provide a copy of the most recent contract Rocky Mountain Power has
with Nucor, including the interrptiHility provisions, as well as Nucor's
interrption history for the years 200,1 through 2009, inclusive.
Response to Monsanto Data Request 1.27
Rocky Mountain Power's customer information protection policy prohibits
providing customer information without the customer's prior consent. The
Company has contacted Nucor and received their consent to provide a copy of the
electric service agreement, but Nucor did not consent to disclosing details
regarding its interrption history.
Please refer to Confdential Attachment Monsanto 1.27. Confidential information
is provided subject to the terms and conditions of the protective agreement in this
proceeding.
Recordholder:
Sponsor:
Jim Schroeder / Tom Beck
Gregory N. Duvall
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PAC-E-10-07/Rocky Mountain Power
June 23, 2010
Monsanto Data Request 1.28
Monsanto Data Request 1.28
Please explain how Nucor' s interrptible load has been treated for purposes of the
jurisdictional allocation model and provide Nucor's twelve monthly coincident
peaks included in the Utah jurisdiction of the JAM study used in this filing.
Response to Monsanto Data Request 1.28
Nucor's interruptible load is treated similar to Monsanto's load for the purposes
of jurisdictional allocation, i.e. the Utah monthly jurisdictional peak and energy
amounts are reflected as ifNucor curilment does not occur. The loads in this
case are normalized for calendar year 2010, Nucor's monthly coincident peaks
were not needed to calculate the jursdictional allocation factors or for class cost
of service purposes, therefore they were not developed for this case.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R.. McDougal
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. PAC-E-1 0-07/Rocky Mountain Power
June 23, 2010
Monsanto Data Request 1.29
Monsanto Data Request 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.
Response to Monsanto Data Request 1.29
Rocky Mountain Power's customer information protection policy prohibits
providing customer information without the customer's prior consent. The
Company has contacted Nucor and received their authorization to provide this
information under protection of the confidentiality agreement.
(i) The loads in Uta Docket No. 09-035-23 were forecasted, not actual; the
Company does not forecast monthly coincident peaks on an individual
customer basis.
(ii) Class coincident peaks used in the Utah cost of service study, Docket 09-
035-23, are provided as Confidential Attchment Monsanto 1.29. Nucor's
coincident peak information is identified as Customer C in this attachment.
Confidential information is provided subject to the terms and conditions of
the protective order in this proceeding.
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Recordholder:
Sponsor:
Steven R. McDougal and C. Craig Paice
Steven R. McDougal and C. Craig Paice
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PAC-E-10-07/Rocky Mountain Power
June 23,2010
Monsanto Data Request 1.31
Monsanto Data Request 1.31
Please explain how Magcorp's interrptible load has been treated for puroses of
the jurisdictional allocation model, and provide Magcorp's twelve monthly
coincident peaks included in the Uta jurisdiction of the JAM study.
Response to Monsanto Data Request 1.31
For puroses of jurisdictional allocations the economic curailment portion of
Magcorp's contract is reflected in the jursdictional load as it is expected to occur,
i.e. expected reductions in Magcorp load for economic curtailment are reflected in
Utah jurisdictional load. Interrptions for operating reserves are not reflected in
Utah jurisdictional load, i.e. as if interrptions for operating reserves do not occur.
The loads in this case are forecasted for calendar year 2010; however, the
Company does not forecast monthly coincident peaks on an individual customer
basis.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
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