20100702PAC to Monsanto 2-3, 2-6, 2-15 etc.pdf

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2910 JUL -2 AM to: 22
July 1,2010
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UTILITIES COMj",lISSiON
Randall C. Budge
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 RCenter
Pocatello, Idaho 83204-13 91
RE: ID PAC-E-10-07
Monsanto Data Request Set 2 (1-74)
201 South Main, Suite 2300
Salt Lake City. Uth 84111
Please find enclosed Rocky Mountai Power's responses to Monsanto Data Requests 2.3, 2.6,
2.15,2.16,2.38, and 2.46. The remaining responses will be provided separately. Provided on
the enclosed CD are Attchments Monsanto 2.3, 2.16, and 2.46. Provided on the enclosed
Confdential CD is Confdential Attchment Monsanto 2.15. The Confdential Attachment is
Confdential and is being 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,
.: LT.td. Wg.~ !~
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 Collins
Michael Gorman
Kath Iverson
Mark Widmer
Michal Stak
Michal C. Creamer
Eric L. Olsen
Jea Jewell
j PAC-E-10-07/Rocky Mountain Power
July 1, 2010
Monsanto Data Request 2.3
Monsanto Data Request 2.3
Please provide a working copy of the entire NPC study that shows the authorized
NPC from Case No. PAC-E-08-07.
Response to Monsanto Data Request 2.3
The information requested is provided as Attchment Monsanto 2.3.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-1 0-07/Rocky Mountan Power
July 1,2010
Monsanto Data Request 2.6
Monsanto Data Request 2.6
Please provide the calculation and supporting workpapers for the $16.5 millon
increase for wheeling expense.
Response to Monsanto Data Request 2.6
Please refer to Attchment Monsanto 2.3 for the net power cost study in the
Company's rate case from Case No. PAC-E-08-07, specifically the line named
"Tota Wheeling & U. ofF. Expense." Please refer to the Company's filed
Exhbit 40 for the net power cost study in the curent proceeding, specifically the
line named "Tota Wheeling & U. ofF. Expense."
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-IO-07/Rocky Mountain Power
July 1,2010
Monsanto Data Request 2.15
Monsanto Data Request 2.15
Please provide all documents, workpapers or other information relied upon by the
Company in the development of market caps used in GRID.
Response to Monsanto Data Request 2.15
Please refer to Confdential Attchment Monsanto 2.15. The confdential
information is provided subject to the terms and conditions of the protective
agreement in ths proceeding.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-1O-07/Rocky Mountain Power
July 1,2010
Monsanto Data Request 2.16
Monsanto Data Request 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.
Response to Monsanto Data Request 2.16
The date of the forward price cure used in GRID for the test year was March 31,
2010. Please refer to Attachment Monsanto 2.16 for the data. The Company
objects to the request for forward price cures for 2011,2012 and 2013 on the
basis that the request is irrelevant, since the data for these years were not used inGRID. .
Recordholder:
Sponsor:
Rick Link
Hui Shu
P AC-E-1 0-07/Rocky Mountan Power
July 1,2010
Monsanto Data Request 2.38
Monsanto Data Request 2.38
Please provide the 2008 IRP wid integration studies and supporting workpapers
referenced in Dr. Shu's testimony.
Response to Monsanto Data Request 2.38
The Company objects to the request on the ground that it is not relevant. The
Company did not use its 2008 IR wind integration study in ths proceeding.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-1 0-07/Rocky Mountain Power
July 1,2010
Monsanto Data Request 2.46
Monsanto Data Request 2.46
Please provide all real time hydro unt operating chaacteristics comparable to
GRI inputs.
Response to Monsanto Data Request 2.46
Please refer to Attchment Monsanto 2.46, which provides some basic
information for each hydro plant. The generation from hydro unts is limited
more by stream flow and environmenta regulations than the physical limitations
of the units.
Recordholder:
Sponsor:
Peter Defazio
Hui Shu