20100716Monsanto 6 (1-16) to PAC.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE & BAILEY
CHARTEREDW. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT O. ROCHE
KI RK B. HADLEY
FRED J. LEWIS
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
LANE V. ERICKSON
FREDERICK J. HAHN, III
DAVID E. ALEXANDER
PATRICK N. GEORGE
SCOTT J. SMITH
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN
CANDICE M. MCHUGH
CAROL TIPPI VOLYN
BRENT L. WHITING
JONATHON S. BYINGTON
DAVE BAGLEY
THOMAS J. BUDGE
JONATHAN M. VOLYN
MARK A. SHAFFER
JASON E. FLAIG
Mrs. Jean Jewell, Secretar
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Re: PAC-E-10-07
Dear Jean:
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
ww.racinelaw.net
SENDER'S E-MAIL ADDREss:rcb(§racinelaw.net
July 14,2010
BOISE OFFICE
to 1 SOUTH CAPITOL
BOULEVARD, SUITE 20a
BOISE~ IDAHO 83702
TELEPHONE:. (208) 39!5~OOt IFACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUESUITE 107
POST OFFICE BOX 50698IDAHO FALLS, ID 83405
TELEPHONE: [phone]
FACSIMILE: (208) S28~6t09
ALL OFFICES TOLL FREE
(877) 232-81 01
LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON, OF COUNSEL
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Enclosed for filing please find the original and nine copies of Monsanto Company's Sixth
Data Requests to Rocky Mountain Power. Than you for your assistace.
RCB:rr
Enclosures
cc: Service List
RECE Er1
Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
rcb(fracinelaw.net
2010 JUL 16 AM 8: 03
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR APPROVAL)
OF CHAGES TO ITS ELECTRIC SERVICE )
SCHEDULES AND A PRICE INCREASE OF )
$27.7 MILLION, OR APPROXIMATELY )13.7 PERCENT )
)
Case No. PAC-E-l0-07
MONSANO COMPAN'S SIX DATA REQUESTS
TO ROCKY MOUNAI POWER
MONSANTO COMPANY, by and though their attorneys, hereby submits this Sixth
Data Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utility
Commission's Rules of Procedure, IDAPA 31.01.01, as follows:
Monsanto 6.1: Please provide the most curent Populus to Terminal transmission project NPC
analyses used to justify the project and a list of all modeling assumptions including but not
limited to wholesales market sizes. In addition, please provide the hourly coal generation and
wholesale sales by market with and without the project for the first two years of the studies.
Monsanto 6.2: Please provide the NPC analyses used to develop the information shown in
Confidential Attchment Monsanto 1.11-1, Table 8 and provide a list of all modeling
assumptions including but not limited to wholesale market sizes. In addition, please provide the
hourly coal generation and wholesale sales by market with and without the project for the first
two years of the studies.
Monsanto 6.3: Please provide the economic and NPC analyses, plus the hourly coal generation
and wholesale sales without and without the following tubine upgrades:
MONSANO'S SIX DATA REQUESTS TO ROCKY MOUNAI POWER - i
a. Hunter unit 1 high pressure
b. Huntington unit 1 HP/IP/LP turbine sections replacements
c. Bridger unit 1 HP/IP turbine sections replacements
Monsanto 6.4: On pages three and four of Mr. Gerrard's testimony he states that installation of
new transmission capacity wil ensure the system can sustain transmission outages nort of the
Terminal substation without curailing loads, generation or impacting PacifiCorp's East Control
Area and neighboring transmission balancing authority areas. Please provide the amount of
additional energy that would have been generated by the coal plants without the referenced
generation curailments for the four year period used to normalize thermal generation.
Monsanto 6.5: On pages three and four of Mr. Gerrard's testimony he stated that the installation
of the Populus to Terminal transmission line will improve the Company's abilty to perform
maintenance on transmission facilities between Populus and Terminal by having alternative paths
that allow facilities to be taken off-line and maintained. Please provide the incremental amount
of energy that would have been generated by the coal plants above the amounts provided in the
prior request, if the alternative transmission paths were available durng the four year period used
to normalize thermal generation.
Monsanto 6.6: Please provide a copy of the 2007/2008 Company specific analyses on several
disturbance events that severely impacted generation referenced on page nine of Mr. Gerrard's
testimony and all correspondence, papers and documents regarding the conclusion of the studies.
Monsanto 6.7: On page 17 of Mr. Cupparo's testimony he states that by providing additional
transmission capacity through this transmission segment the Company has more flexibility in
locating reserves on PacifiCorp owned generation and makng full use of the Northwest Reserve
Sharng Program, which allows the Company to cover reserves requirements without having to
build additional generation.
a. Please explain the pricing methodology for reserves purchased through the Northwest
Reserve Sharing Program.
b. Please identify the amount and cost of additional reserves the Company expects to
have access to by year through the completion of the Energy Gateway transmission
project.
Monsanto 6.8: Item 18 on page 7 of Exhbit No. 36 states that "According to PacifiCorp, this
advanced conductor design wil increase transmission capacity and reduce the sag of
transmission lines as well as avoid energy losses. Please provide the yearly expected incremental
changes in energy loss factors compared to the loss factors modeled in GRID through the
completion of the Energy Gateway transmission project.
MONSAO'S SIX DATA REQUESTS TO ROCKY MOUNAI POWER -:1
Monsanto 6.9: Has the Company reflected the expected reduction in energy losses discussed in
the previous request in the Company's fiing? If yes, please identify where they were included.
Monsanto 6.10: Please provide actual wheeling expense detail for the period 2006 through
2009 and 2010 to date by month in the same level of detail as Confidential Attachment Monsanto
2.10-10.
Monsanto 6.11: Please identify all jursdictions where the Company has either agreed to or has
modeled STF transmission based on a four year average of transmission capability and expense.
Monsanto 6.12: Please provide Mona and Gonder STF sales for the period 2006 though 2009
in the same format as Confidential Attchment WIEC 1.42 from Wyoming Docket No. 20000-
353-ER-09.
Monsanto 6.13: Please provide actual STF transmission data for the first six months of2010 in
the same format as Confidential Attchment Monsanto 2.7.
Monsanto 6.14: Regarding the wind capacity factors shown in Confidential Attchment
Monsanto 2.12-3, please provide the following information.
a. The calculation of the wind capacity factors and supporting workpapers.
Monsanto 6.15: Please identify the hours classified as weekend in the EFOR calculation.
Monsanto 6.16: Please provide the Company's estimate of percentages for each category listed
in Monsanto 3.3 7.
DATED ths 14th day of July, 2010.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
~l1'1. ~,~Byf~
RANDALL C. ir~
MONSANO'S SIX DATA REQUESTS TO ROCKY MOUNAI POWER - 3
CERTIFICATE OF MAING
I HEREBY CERTIFY that on this 14th day of July, 2010, I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretar (original and 9)
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
E-mail: jjewell(Ðpuc.state.id.us U.S. Mail
Ted Weston
Rocky Mountan Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: ted.weston(iacificorp.com E-Mail
Danel Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
E-mail: Daniel.solander(fpacificorp.com
E-Mail
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
P.O. Box 1391
Pocatello, Idaho 83204-1391
E-mail: elo(fracinelaw.net
Hand Delivery
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
E-mail: tony(Ðyanel.net
E-Mail
Michael C. Creamer
Kelsey J. Nunez
Givens Pursley LLP
P.O. Box 2720
Boise, Idaho 83701-2720
E-mail: mccWgivenspursley.com
kelseynunez(fgivenspursley.com
E-Mail
MONSANTO'S SIXTH DATA REQUESTS TO ROCK MOUNAI POWER - 4
Tim Buller
Jason Haris
Agrum, Inc.
3010 Conda Road
Soda Springs, Idaho 83276
E-mail: tbuler(fagrium.com
jaharris(fagrium.com
E-mail
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MONSANTO'S slXm DATA REQUESTS TO ROCK MOUNTAI POWER - 5