20100629PAC to Monsanto 2 (1-74).pdf

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",ROCKY MOUNTAIN
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201 South Main, Suite 2300
Salt Lake City, Utah 84111
June 28, 2010
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UTiLITIES do1ú:'l¡ŠSIO:~
Randall C. Budge
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHATERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
RE: ID PAC-E-1O-07
Monsanto Data Request Set 2 (1-74)
Please find enclosed Rocky Mountain Power's responses to Monsanto Data Requests 2.1-2.2,
2.4-2.5,2.13-2.14,2.17,2.20-2.22,2.26,2.28-2.29, 2.36-2.37, 2.39, 2.41, 2.43, 2.52, 2.54, 2.58,
2.62,2.66-2.67, and 2.69-2.70. The remainig responses will be provided separtely. Provided
on the enclosed CD are Attchments Monsanto 2.2 -1, 2.4 -1, 2.4 -2, 2.20, 2.36, and 2.37.
Provided on the enclosed Confidential CD are Confdential Attachments Monsanto 2.2 -2, 2.22,
2.41,2.43 -1,2.43 -2,2.62,2.66, and 2.69. Confidential Attchments are Confdential and are
provided to paries that have signed a protective order in this docket.
Ifyo.u have any questions, please feel free to call me at [phone].
Sincerely,
J. H~ 1u~1ø
J. Ted Weston
Manager, Reguation
Enclosure:
C.c: James R. Smith
Richad Anderson
George C. Carer, III
Denns Peseau
Gareth R. Kajander
Maurce Brubaker
Brian Collin
Michal Gorman
Kath Iverson
Mark Widmer
Michael Stak
Michal C. Creamer
Eric L. Olsen
Jea Jewell
PAC-E-10-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.1
Monsanto Data Request 2.1
Please provide workpapers that show the source and calculations pertaining to the
Company's NPC study(s), including the net power cost report in Excel, the GRID
project and access to the NPC modeL.
Furer, 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. This is a continuing request for
all discovery requests.
Response to Monsanto Data Request 2.1
The requested information has been provided to Monsanto's consultants, Mr.
Widmer and Mr. Collins on June 17,2010 for delivery on June 18,2010 along
with the access to the Company's GRID model that calculated the net power costs
in the curent proceeding.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-1 0-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.2
Monsanto Data Request 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 Staff.
Response to Monsanto Data Request 2.2
Please refer to Attchment Monsanto 2.2 -1 for non-confdential responses and
attchments. Please refer to Confdential Attchment Monsanto 2.2 -2 for
confdential attchments. Confdential inormation is provided subject to the
terms and conditions of the protective agreement in ths proceeding.
Recordholder: N/ A
Sponsor: N/A
PAC-E-l 0-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.4
Monsanto Data Request 2.4
Please provide a copy of the Idaho Commssion Order for Case No. PAC-E-08-
07.
Response to Monsanto Data Request 2.4
Please refer to Attachments Monsanto 2.4 -1 and 2.4 -2. .
Recordholder:
Sponsor:
Ted Weston
N/A
PAC-E-10-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.5
Monsanto Data Request 2.5
Does the Company agree to allow Monsanto to use discovery responses for the
following cases: Washigton 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?
Response to Monsanto Data Request 2.5
Monsanto may use the Company's responses provided to Monsanto's consultat
in the following cases: Washigton 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, subject to the Company's reservation of all evidentiar objections.
Use of the Company's confidential data provided in the above-referenced dockets
will be subject to maintaning the confdentiality of such data on the terms and
conditions of the protective orders and confidentiality agreements in those
dockets. Use of confdential responses from other proceedings is also subject to
the terms and conditions of the protective agreement in ths docket.
Recordholder: N/ A
Sponsor: N/ A
P AC-E-I 0-07/Rocky Mountain Power
June 28,2010
Monsanto Data Request 2.13
Monsanto Data Request 2.13
Please identify the time periods used to calculate outae rates and other inputs
included in the GRI modeL.
Response to Monsanto Data Request 2.13
The time period is the 48 months ended December 2009.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-1 0-07/Rocky Mountan Power
June 28, 2010
Monsanto Data Request 2.14
Monsanto Data Request 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.
Response to Monsanto Data Request 2.14
As stated in Dr. Shu's testimony, the Company uses the same version of GRI as
used in Case No. PAC-E-08-07.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-10-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.17
Monsanto Data Request Z.17
Did the Company use monthly screens or daily screens as was agreed to in
Wyomig Docket No.20000-352-ER-09 to model thermal plant dispatch? Ifnot,
please explain why not.
Response to Monsanto Data Request 2.17
The Company used daily screens.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-1 0-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.20
Monsanto Data Request 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.
Response to Monsanto Data Request 2.20
The $6.50/MWh is not a calculated number, but rather the amount set by the
Idaho Public Utilities Commission in Order No. 31021, which is provided as
Attchment Monsanto 2.20.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-1 0-07/Rocky Mounta Power
June 28,2010
Monsanto Data Request 2.21
Monsanto Data Request 2.21
Please provide reasonable advance notice to Mr. Widmer of all IR public
meetings on the Company's new wind integration cost study.
Response to Monsanto Data Request 2.21
Mr. Widmer is already on the parcipant list to receive notices.
Recordholder:
Sponsor:
Pete Waren
N/A
P AC-E-1 0-07/Rocky Mountan Power
June 28, 2010
Monsanto Data Request 2.22
Monsanto Data Request 2.22
Please explain how the Company modeled Bridger Coal overburden strpping
costs and provide the supporting workpapers.
Response to Monsanto Data Request 2.22
In Case No. P AC-E-09-08 the Company fied an accounting application with the
Idaho Public Utilties Commssion requesting authority to ignore the Financial
Accounting Stadads Board Emerging Issues Task Force issued EITF No. 04-6,
Accounting for Strpping Costs Incured durg Production in the Minig
Industry. EITF No. 04-6 requies that strpping costs incured durg the
production phase of a surface mine become varable production costs that should
be included in the costs of the inventory produced and recognzed durng the
period that the stripping costs are incured. The Commssion issued Order No.
30987 approving the Company's request to defer strpping costs and match
. amortization of those costs with coal extracted from the mine. In Case No. P AC-
E-10-07 the Company adjusted Bridger Coal production costs to remove the
effects ofEITF 04-6. The supporting workpapers are in found in Confdential
Attachment Monsanto 2.22. Confdential inormation is provided subject to the
terms and conditions of the protective agreement in ths proceeding.
Recordholder:
Sponsor:
Brian T. Durng
Cindy A. Crae
PAC-E-10-07/Rocky Mountai Power
June 28, 2010
Monsanto Data Request 2.26
Monsanto Data Request 2.26
Please provide the latest statu of the Condit hydro decommissionig including
the expected decommssionig date.
Response to Monsanto Data Request 2.26
Decommissionig is curently scheduled for the fall of201 1. PacifiCorp has not
received all permits necessar for decommissionig the Condit Hydroelectric
project. Stil to be acquired are a Washington Deparent of Ecology 401 Clean
Water Certificate, a Washington Deparent of Ecology National Pollutat
Discharge Elimation System (NDES) Permt under Section 402 of the Clean
Water Act, authorization from the United States Ary Corps of Engineers under
Section 404 of the Clean Water Act and under Section 1 Oof the Rivers and
Harbors Act, and a Federal Energy Reguatory Commission Surender Order.
PacifiCorp maintans that other state and county permts are not required as they
are pre-emptedby the Commission.
Recordholder:
Sponsor:
Todd M. Olson
Chad A. Teply
PAC-E-10-07/Ròcky Mountain Power
June 28,2010
Monsanto Data Request 2.28
Monsanto Data Request 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.
Response to Monsanto Data Request 2.28
No. The new transmission capacity included in the filing does not increase access
to or the size of wholesale markets.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-1O-07/Rocky Mountan Power
June 28, 2010
Monsanto Data Request 2.29
Monsanto Data Request 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.
Response to Monsanto Data Request 2.29
No. The Company does not believe increased thermal capacity would increase
wholesale market sizes.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-10-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.36
Monsanto Data Request 2.36
Please provide the calculation and supporting workpapers for the Company's Bear
River median hydro normalization.
Response to Monsanto Data Request 2.36
Please refer to Attchment Monsanto 2.36.
Recordholder:
Sponsor:
Mark Smith
Hui Shu
PAC-E-10-07/Rocky Mountain Power
June 28,2010
Monsanto Data Request 2.37
Monsanto Data Request 2.37
Please provide the order on avoided costs for Case No. P AC-E-09-07.
Response to Monsanto Data Request 2.37
Please refer to Attachment Monsanto 2.3 7.
Recordholder:
Sponsor:
Ted Weston
N/A
P AC-E-1 0-07/Rocky Mountain Power
June 28,2010
Monsanto Data Request 2.39
Monsanto Data Request 2.39
Please provide the 2011 IRP updated wind integration studies and supporting
documentation when they are completed.
Response to Monsanto Data Request 2.39
Once completed, the wind integration documentation will be posted on the
Company's website at ww.pacificorp.com. Select "Energy Sources" then
"Integrated Resource Plan." Mr. Widmer is already on the paricipant list to
receive notices.
Recordholder:
Sponsor:
Pete Waren
N/A
P AC-E-1 0-07/Rocky Mountan PowerJune 28, 2010 .
Monsanto Data Request 2.41
Monsanto Data Request 2.41
Please provide the hourly generator logs for each wid, 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 unit specific data for its share of a resource as a whole
including the output of other owners.
Response to Monsanto Data Request 2.41
Please refer to Confdential Attchment Monsanto 2.41. Confdential inormation
is provided subject to the terms and conditions of the protective agreement in this
proceeding.
Recordholder:
Sponsor:
Tom Beck
Hui Shu
PAC-E-10-07/Rocky Mountain Power
June 28,2010
Monsanto Data Request 2.43
Monsanto Data Request 2.43
Please provide the most curent schedule for thermal and hydro generator planed
outages for 2010,2011,2012 and 2013.
Response to Monsanto Data Request 2.43
Please refer to Confdential Attachments Monsanto 2.43 -1 and 2.43 -2.
Confidential inormation is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:
Sponsor:
Alan Jackson / Ali Shafaei
Chad A. Teply
PAC-E-10-07/Rocky Mounta Power
June 28, 2010
Monsanto Data Request 2.52
Monsanto Data Request 2.52
Did the Company model the non-firm transmission that it uses in actul
operations? If yes, please provide the workpapers used to develop the modeling
inputs. Ifnot, please provide the Company's justification for exclusion of these
tyes of transactions.
Response to Monsanto Data Request 2.52
No. The Company believes that including non-fi transmission in the
normalized studies is inconsistent with the normalized ratemakg pricipaL.
Recordholder:
. Sponsor:
Hui Shu
Hui Shu
P AC-E-1 0-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.54
Monsanto Data Request 2.54
Please provide an update of the Company's efforts to address the commtment
logic error in the GRID model, as opposed to the use of screens or other
workarounds.
Response to Monsanto Data Request 2.54
The Company is investigating the use of an alternate production cost model, iOpt,
to replace GRID. Screens would not be needed with iOpt. The Company expects
to phase in implementation ofiOpt beginng in 201 1.
Recordholder:
Sponsor:
Gregory N. Duvall
Hui Shu
P AC-E-1 0-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.58
Monsanto Data Request 2.58
Please provide a sumar of the 2009 RECs that shows the amounts generated by
plant, the amount sold by plant/contract, the sales price, the amount ofRECs
required to be banked and the amount of RECs available for sale that were not
sold.
Response to Monsanto Data Request 2.58
The Company considers the requested information to be of utmost commercial
sensitivity and highy confdentiaL. Please contact Greg Duvall at 503-813-7069
to discuss arangements for review onsite.
Recordholder:
Sponsor:
Gregory N. Duvall/Bruce Grswold
Stefan Bird
PAC-E-1 0-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.62
Monsanto Data Request 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.
Response to Monsanto Data Request 2.62
Please refer to Confdential Attachment Monsanto 2.62. Confdential information
is provided subject to the terms and conditions of the protective agreement in ths
proceeding.
Recordholder:
Sponsor:
Rick Link
Hui Shu
PAC-E-10..07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.66
Monsanto Data Request 2.66
Please provide the actul monthy Cal iso wheeling and service fees for 2008,
2009 and 2010 to date.
Response to Monsanto Data Request 2.66
Please refer to Confdential Attchment Monsanto 2.66. Confdential information
is provided subject to the terms and conditions of the protective agreement in this
proceeding.
Recordholder:
Sponsor:
Tom Beck
Hui Shu
. .
P AC-E-1 0-07/Rocky Mountan Power
June 28,2010
Monsanto Data Request 2.67
Monsanto Data Request 2.67
Please provide a monthy 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.
Response to Monsanto Data Request 2.67
The Company has not performed the requested studies. Please refer to the
Company's response to Monsanto Data Request 2.41 for the hourly data.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-10-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.69
Monsanto Data Request 2.69
Please provide the Regulatory Fuel Budget and any other workpapers used in
developing fuel cost inputs for GRID.
Response to Monsanto Data Request 2.69
The Fuel Budget and workpapers are provided in Confdential Attachment
Monsanto 2.69. Confidential information is provided subject to the terms and
conditions of the protective agreement in ths proceeding.
Recordholder:
Sponsor:
Brian T. Durng
Cindy A. Crane
PAC-E-1O-07/Rocky Mountain Power
June 28, 2010
Monsanto Data Request 2.70
Monsanto Data Request 2.70
Please provide a copy of the alternative coal supply analysis performed for the
Naughton plant.
Response to Monsanto Data Request 2.70
A sumar of ths analysis has been previously supplied. Please refer to the tab
titled "Naughton Other Supply Options" in Confdential Attchment Monsanto
1.15. Due to the highy confidential natue of these documents, the Company will
make these documents available for review in the Company's Salt Lake City
offce. Please contact Ted Weston at 801-220-2963 to make arangements.
Recordholder:
Sponsor:
Brian T. Durng
Cindy A. Crane