20100715PAC Partial to Monsanto 3 (1-41).pdf

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July 14,2010
Randall C. Budge
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHATERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
RE: ID P AC-E-1 0-07
Monsanto Data Request Set 3 (1-41)
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iftm JUl '5 At1 9: 2 ,
201 South Main Suite 2300
Salt Lake City. Utah 84111
Please find enclosed Rocky Mountan Power's responses to Monsanto Data Requests 3.5-3.6,
3.14-3.17,3.19-3.23, and 3.25-2.28. Provided on the enclosed Confdential CD are Confdential
Attchments Monsanto 3.14,3.15,3.16,3.17,3.19,3.20,3.22,3.25,3.26, and 3.27. Confdential
Attchments are Confdential and ar provided to pares tht have signed a protective order in
ths docket.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J T.¿d tv~ I'~
J. Ted Weston
Manger, 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
Michal C. Creamer
Eric L. Olsen
Jea Jewell
Ben Oto
P AC-E-1 0-07/Rocky Mountain Power
July 14,2010
Monsanto Data Request 3.5
Monsanto Data Request 3.5
Please provide a copy of the Biomass non-generation agreement for the test year
and the supporting economic analysis.
Response to Monsanto Data Request 3.5
Please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the agreement. The Company considers the requested economic analysis
information to be of utmost commercial sensitivity and highy confidential.
Please contact Greg Duvall at 503-813-7069 to discuss arangements for review
onsite.
Recordholder:
Sponsor:
Jim Schroeder / Rick Lin
Hui Shu
PAC-E-10-07/Rocky Mountain Power
July 14,2010
Monsanto Data Request 3.6
Monsanto Data Request 3.6
Please provide a copy of the Cowlitz Swift contract p65787.
Response to Monsanto Data Request 3.6
Please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract.
Recordholder:
Sponsor:
Jim Schroeder
Hui Shu
PAC-E- 1 0-07/Rocky Mountain Power
July 14,2010
Monsanto Data Request 3.14
Monsanto Data Request 3.14
Please provide a copy of the NVE LTF sales contract, the economic analysis and
workpapers supporting the transaction and all correspondence to management
regarding the decision to enter the transaction.
Response to Monsanto Data Request 3.14
To the extent this request seeks all correspondence to management regardig the
decision to enter the transaction, PacifiCorp objects to ths request on the grounds
that itis overly broad and unduly burdensome. Without waivig ths objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contrct and Confdential Attachment Monsanto 3.14 for redacted
documentation supportg the transaction. Confdential inormation is provided
subject to the terms and conditions of the protective order in ths proceeding.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
P AC-E- 1 0-07/Rocky Mountain Power
July 14,2010
Monsanto Data Request 3.15
Monsanto Data Request 3.15
Please provide a copy of the Pacific Ga and Electrc L TF sales contract, the
economic analysis and workpapers supporting the transaction and all
correspondence to management regarding the decision to enter the trsaction.
Response to Monsanto Data Request 3.15
To the extent ths request seeks all correspondence to mangement regarding the
decision to enter the transaction, PacifiCorp objects to ths request on the grounds
that it is overly broad and unduly burdensome. Without waivig ths objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract and Confdential Attchment Monsanto 3.15 for redacted
documentation supporting the transaction. Confdential.inormation is provided
subject to the terms and conditions of the protective order in ths proceedig.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
PAC-E- 1 0-07/Rocky Mountan Power
July 14,2010
Monsanto Data Request 3. I 6
Monsanto Data Request 3.16
Please provide a copy of the SCE L TF sales contract, the economic analysis and
workpapers supporting the transaction and all correspondence to management
regarding the decision to enter the tranaction.
Response to Monsanto Data Request 3.16
To the extent this request seeks all correspondence to management regarding the
decision to enter the transaction, PacifiCorp objects to ths request on the grounds
that it is overly broad and unduly burdensome. Without waivig ths objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract and Confidential Attchment Monsanto 3.16 for redated
documentation supporting the tranaction. Confdential inormation is provided
subject to the terms and conditions of the protective order in ths proceeding.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
PAC-E-10-07/Rocky Mountain Power
July 14,2010
Monsanto Data Request 3.17
Monsanto Data Request 3.17
Please provide a copy of the SDG&E L TF sales contract, the economic analysis
and workpapers supporting the transaction and all correspondence to management
regarding the decision to enter the transaction.
Response to Monsanto Data Request 3.17
To the extent this request seeks all correspondence to management regarding the
decision to enter the transaction, PacifiCorp objects to this request on the grounds
that it is overly broad and unduly burdensome. Without waiving this objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract and Confidential Attachment Monsanto 3.17 for redacted
documentation supporting the transaction. Confidential information is provided
subject to the terms and conditions of the protective order in this proceeding.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
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PAC-E-10-07/Rocky Mountain Power
July 14,2010
Monsanto Data Request 3.17
Monsanto Data Request 3.17
Please provide a copy of the SDG&E L TF sales contract, the economic analysis
and workpapers supporting the transaction and all correspondence to management
regarding the decision to enter the transaction.
Response to Monsanto Data Request 3.17
To the extent this request seeks all correspondence to management regarding the
decision to enter the transaction, PacifiCorp objects to this request on the grounds
that it is overly broad and unduly burdensome. Without waiving this objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract and Confidential Attachment Monsanto 3.17 for redacted
documentation supporting the transaction. Confidential information is provided
subject to the terms and conditions of the protective order in this proceeding.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
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¡1'1
PAC-E-10-07/Rocky Mountain Power
July 14,2010
Monsanto Data Request 3.19
Monsanto Data Request 3.19
Please provide a copy of the BP A L TF reserves purchase contract, the economic
analysis and workpapers supporting the transaction and all correspondence to
management regarding the decision to enter the transaction.
Response to Monsanto Data Request 3.19
To the extent this request seeks all correspondence to management regarding the
decision to enter the transaction, PacifCorp objects to this request on the grounds
that it is overly broad and unduly burdensome. Without waiving this objection,
please refer to Confidential Attchment Monsanto 3.19. Confidential information
is provided subject to the terms and conditions of the protective order in this
proceeding. PacifiCorp operates two wind generation resources in BPA's contral
area, Leaning Juniper and Goodnoe Hils. BP A provides reserves for those two
resources pursuant to PacifiCorp's general service agreement with BPA and the
associated OATT rates.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
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PAC-E-10-07/Rocky Mountain Power
July 14,2010
Monsanto Data Request 3.20
Please provide a copy of Kennecott Generation Incentive contract p491303-4, the
economic analysis and workpapers supporting the transaction, the calculation and
supporting workpapers and all correspondence to management regarding the
decision to enter the transaction.
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Monsanto Data Request 3.20
Response to Monsanto Data Request 3.20
To the extent this request seeks all correspondence to management regarding the
decision to enter the transaction, PacifiCorp objects to this request on the grounds
that it is overly broad and unduly burdensome. Without waiving this objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract and Confidential Attchment Monsanto 3.20 for redacted
documentation supporting the transaction. Confidential information is provided
subject to the terms and conditions of the protective order in this proceeding.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
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P AC-E-1 0-07/Rocky Mountain Power
July 14, 2010
Monsanto Data Request 3 .21
Monsanto Data Request 3.21
Please provide a copy ofLADWP contract p491303-4, the economic analysis and
workpapers supporting the transaction and all correspondence to management
regarding the decision to enter the transaction.
Response to Monsanto Data Request 3.21
To the extent this request seeks all correspondence to management regarding the
decision to enter the transaction, PacifiCorp objects to this request on the grounds
that it is overly broad and unduly burdensome. Without waiving this objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract. Additional documentation supporting the transactions are
considered by the Company to be of utmost commercial sensitivity and highly
confidential. Please contact Greg Duvall at 503-813-7069 to discuss
arangements for review onsite.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
P AC-E-1 0-07/Rocky Mountain Power
July 14, 2010
Monsanto Data Request 3.22
Monsanto Data Request 3.22
Please provide a copy of the Top of World wind project purchase power contract,
the economic analysis and workpapers supporting the transaction and all
correspondence to management regarding the decision to enter the transaction.
Response to Monsanto Data Request 3.22
To the extent this request seeks all correspondence to management regarding the
decision to enter the transaction, PacifiCorp objects to this request on the grounds
that itis overly broad and unduly burdensome. Without waiving this objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract and Confidential Attachment Monsanto 3.22 for redacted
documentation supporting the transaction. Confidential information is provided
subject to the terms and conditions of the protective order in this proceeding.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
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PAC-E-10-07/Rocky Mountain Power
July 14,2010
Monsanto Data Request 3.23
Monsanto Data Request 3.23
Please provide the same information requested in the prior request for the Three
Mile Canyon Wind QF.
Response to Monsanto Data Request 3.23
To the extent this request seeks all correspondence to management regarding the
decision to enter the transaction, PacifiCorp objects to this request on the grounds
that it is overly broad and unduly burdensome. Without waiving this objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract. Additional documeIifationsupporting the transactions are
considered by the Company to be of utmost commercial sensitivity and highly
confidentiaL. Please contact Greg Duvall at 503-813-7069 to discuss
arangements for review onsite.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
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PAC-E-10-07/Rocky Mountain Power
July 14,2010
Monsanto Data Request 3.25
Monsanto Data Request 3.25
Please provide a copy of the Kennecott QF purchase power contract, the
economic analysis and workpapers supporting the tranaction and all
correspondence to management regarding the decision to enter the tranaction.
Response to Monsanto Data Request 3.25
To the extent ths request seeks all correspondence to management regarding the
decision to enter the transaction, PacifiCorp objects to ths request on the grounds
that it is overly broad and unduly burdensome. Without waiving this objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contrct and Confdential Attchment Monsanto 3.25 for documentation
supporting the transaction. Confdential inormation is provided subject to the
terms and conditions of the protective order in ths proceeding.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
P AC-E-1 0-07/Rocky Mountan Power
July 14,2010
Monsanto Data Request 3.26
Monsanto Data Request 3.26
Please provide the same information requested in the prior request for the Tesoro
QF.
Response to Monsanto Data Request 3.26
To the extent ths request seeks all correspondence to management regarding the
decision to enter the transaction, PacifiCorp objects to ths request on the grounds
that it is overly broad and unduly burdensome. Without waiving ths objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract and Confdential Attchment Monsanto 3.26 for documentation
supporting the transaction. Confdential information is provided subject to the
terms and conditions of the protective order in ths proceeding.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
PAC-E-1 0-07/Rocky Mountai Power
July 14,2010
Monsanto Data Request 3.27
Monsanto Data Request 3.27
Please provide the same inormation requested in the prior request for the US
Magnesium QF.
Response to Monsanto Data Request 3.27
To the extent ths request seeks all correspondence to management regarding the
decision to enter the transaction, Paci:fCorp objects to this request on the grounds
that it is overly broad and unduly burdensome. Without waiving ths objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contract and Confdential Atthment Monsanto 3.27 for documentation
supportg the transaction. Confdential information is provided subject to the
terms and conditions of the protective order in this proceeding.
Recordholder:
Sponsor:
Stacey Kusters
Hui Shu
PAC-E-10-07/Rocky Mounta Power
July 14,2010
Monsanto Data Request 3.28
Monsanto Data Request 3.28
Please provide a copy of the Grant Power Auction contract, the economic analysis
and workpapets supporting the transaction and all correspondence to management
regarding the decision to enter the tranaction.
Response to Monsanto Data Request 3.28
To the extent ths request seeks all correspondence to mangement regardig the
decision to enter the transaction, Paci:fCorp objects to ths request on the grounds
tht it is overly broad and unduly burdensome. Without waiving ths objection,
please refer to the Company's response to Monsanto Data Request 2.47 for a copy
of the contrct. Additiona documentation supporting the transactions are
considered by the Company 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:
Staey Kusters
Hui Shu