20100811Monsanto 10 (1-27) to PAC.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTEREDW. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT O. ROCHE
KIRK 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 T1PPI 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 Utilties Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Re: PAC-E-IO-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(§radnelaw.net
August 9,2010
BOISE OFFICE
iOt SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702
TELEPHONE: [phone]'
FACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 107
POST OFFICE BOX 50698
IDAHO FALLS, ID 83405TELEPHONE: [phone]
FACSIMILE: [phone]
ALL OFFICES TOLL FREE
[phone]
LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON. OF COUNSEL
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Enclosed for fiing please find the original and thee copies of Monsanto Company's Tenth
Data Requests to Rocky Mountain Power. Than you for your assistance.
RCB:rr
Enclosures
cc: Service List
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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
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Attorneys for Intervenor Monsanto Company
BEFORE TH IDAHO PUBLIC UTITIES 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-10-07
MONSANO COMPAN'S TENTH DATA REQUESTS
TO ROCKY MOUNAI POWER
MONSANTO COMPANY, by and though their attorneys, hereby submits ths Tenth
Data Request to Rocky Mountain Power, pursuat to Rile 225 of the Idaho Public Utilty
Commission's Rules of Procedure, IDAPA 31.01.01, as follows:
Questions Dirted to Steven R. McDougal
Monsanto 10.1. Reference page 10.13: Please identify how much of the Idaho monthy
"Metered Loads (CP)" are for Monsanto. Please provide all supporting workpapers detailing the
Monsanto amount including a narative description of how that amount was derived.
Monsanto 10.2. Reference page 10.13: Please identify how much of the monthly
"Adjustments for Curlments, Buy-Thoughs and Load No Longer Served (Reductions to
Load)" are for Monsanto. Is the entire amount related to serving Monsanto? Ifnot, what other
loads are considered par of those reductions? Please provide all supporting workpapers
detaling both the Monsanto amount and any other load amount, including a narative description
of how those amounts were derived.
MONSANO'S TENT DATA REQUESTS TO ROCKY MOUNAI POWER - i
Monsanto 10.3. Reference page 10.13. Are the monthly coincident peak dates and times
shown there determined though estimated hourly load data? Please provide all supporting
workpapers detailing how those coincident peak dates and times were established.
Monsanto lOA. Reference page 10.13. Why are the monthly coincident peak dates and times
so different from the monthly coincident peak dates and times shown in Exhibit No. 49, Tab 5,
page 6? For example, the JAM study shows a Januar 2010 CP on the 25th at 19:00, while the
Exhbit 48 shows a Januar 2010 CP on the 27 at 9:00. Please explain the differences for each
month.
Monsanto 10.5. Please compare the Idaho monthly coincident peaks used in the JAM model to
the monthly coincident peaks used in the Idaho class cost of service model and explain the basis
of the difference and the impact on the state ofIdaho.
Monsanto 10.6. Reference page 10.14. Please identify how much of the Idaho monthy
"Metered Loads (MWH)" are for Monsanto. Please provide all supporting workpapers detailng
the Monsanto amount.
Monsanto 10.7. Reference page 10.14: Please explain why there are no "Adjustments for
Curailments, Buy- Throughs and Load No Longer Served (Reductions to Load)" for Idaho,
paricularly since there were adjustments made to the coincident peak demands shown on page
10.13. How can an adjustment be made to a coincident peak that is based on hourly loads, and
there be no similar MWH adjustment?
Monsanto 10.8. Please explain how all curailments and interrptions to Monsanto, and buy-
throughs by Monsanto, were handled in the determination of the Idaho coincident peaks and
metered MWH loads used in the JAM study. Please provide all supporting workpapers detaling
those estimated curlments, interrptions and buy-thoughs.
Monsanto 10.9. Please provide a ru of the JAM study with the Monsanto load treated as a
separate jursdiction. (Note: The Company provided a similar JAM study in Docket No. PAC-
E-07-05 by using the colum designated as "Montana" for Monsanto.)
Questions Directed to C. Craig Paice
Monsanto 10.10. Please explain in more detail how the coincident peaks for Monsanto were
generated for use in the Idaho class cost of service study. For example, the confdential
attchment to Monsanto Data Request 1-21 shows hourly data as "3 Year Avg (2006-2008) Tied
to 2010 Forecasted Energy" and "Factors Needed to Adjust Monsanto 3 Yr Avg kWh to
Forecasted kWh," but there is no detail of how the thee-year average was either created, or how
it was tied to the 2010 forecasted energy. Exactly how were these hourly loads determined and
how do they relate to the loads in 2009? And for what use were the monthly adjustment factors
employed?
MONSANO'S TENT DATA REQUESTS TO ROCK MOUNAI POWER - 2
Monsanto 10.11. Please confirm that that all curailments, interrptions and buy-throughs are
included in the "HourlyData" shown in Attach Monsanto 1-21b.CONF. Please state how much
those curailments, etc have impacted both the coincident peaks and energy usage and provide all
supporting workpapers detailng those amounts.
Monsanto 10.12. Please reference the spreadsheet "Attach Monsanto 1.18" attached to RMP's
response to Monsanto Request No. 1-18. On the sheet "Energy-2010" the energy sales for
Monsanto are simply the following hard-wired numbers:
Jan-10 126,100,000
Feb-10 107,000,000
Mar-10 113,000,000
Apr-10 113,000,000
May-10 113,000,000
Jun-10 113,000,000
Jul-10 113,000,000
Aug-10 113,000,000
Sep-10 113,000,000
Oct-10 113,000,000
Nov-10 113,000,000
Dec-10 113,000,000
What is the source of these energy amounts? Do they reflect Monsanto energy usage before or
afer any adjustment for curilment, interrptions or buy-through? Why are all the months
March through December set at exactly 113,000 MWH?
Monsanto 10.13. Please reference the spreadsheet "Attach Monsanto 1.18" attached to RMP's
response to Monsanto Request No. 1-18, and in paricu1ar the sheet entitled, "Monsanto Curl".
Please provide a narative description of how each of those hard-wired numbers are developed,
and provide all supporting workpapers used in the development of those hard-wired numbers. In
paricu1ar, please explain why the interrption MWH amounts are added to the monthy energy
amounts shown in Monsanto 10.9 to arve at Monsanto's energy sales?
Monsanto 10.14. Please explain how any curilments or interrptions to Monsanto, or buy-
throughs by Monsanto, were handled in the determination of the Monsanto coincident peaks and
energy loads used in the Idaho class cost of service study.
Monsanto 10.15. Please compare the Idaho monthly coincident peaks used in the JAM model to
the monthly coincident peaks used in the Idaho class cost of service modeL. To the extent any
monthly coincident peak is different by more than 2%, please explain the basis of the difference
and the impact on the state of Idaho.
MONSANO'S TENTH DATA REQUESTS TO ROCKY MOUNAI POWER - 3
Questions Directed to Dr. Samuel Hadaway
Monsanto 10.16. Please provide copies of all credit reports published by Standard & Poor's
(S&P), Moody's and Fitch Ratings for RMP, MidAmerican Energy Holdings Company and all of
its affliates reviewed by Dr. Hadaway.
Monsanto 10.17. Please provide complete copies of all utility industry analyst reports, or
assessments on the electric utility industr, reviewed by Dr. Hadaway.
Monsanto 10.18. Please provide complete copies of all comments, reports, etc., of how the
curent capital market and economy have impacted the electrc utility industr and its growt
outlook.
Questions Directed to Mr. Bruce Wilams
Monsanto 10.19. On an electronic spreadsheet with all formu1as intact, please provide a copy of
all exhibits, analyses and workpapers used in support of Mr. Wiliams' direct testimony.
Monsanto 10.20. Referrng to page 2 of Mr. Willams' direct testimony, on an electronic
spreadsheet with all formu1as intact, please provide the balance of the long-term debt, preferred
stock, and common equity used to derive the weight of each tye of capita as shown in the table
on lines 19 through 22.
Monsanto 10.21. On an electronic spreadsheet with all formu1as intact, please provide the
monthly average balances for constrction work in progress and short-term debt for the most
recent 13-month period and for the five-quaer ends used to derive the proposed capital
strctue.
Monsanto 10.22. Referrng to page 5 of Mr. Wiliams' direct testimony, please provide the
amount of debt, equity and preferred stock for each of the five quarers used to derive the
Company's proposed capital strcture. Also, please break down the equity amount for each
quarer based on the retained earings, equity contributions (paid-in capital) and other
comprehensive income.
Monsanto 10.23. On page 10 of Mr. Wiliams' direct testimony, he states that S&P imputed
$395 milion debt and related interest expense. Please provide all workpapers and/or credit
reports supporting this testimony. Also, provide an estimate of the related imputed interest and
amortization expense associated with this off-balance sheet debt.
Monsanto 10.24. Referrng to page 10 of Mr. Wiliams' direct testimony, please provide a copy
of all credit reports issued by the major credit rating agencies that discuss RMP's off-balance
sheet debt and its impact on the Company's credit metric financial ratios.
MONSAO'S TENm DATA REQUESTS TO ROCKY MOUNAIN POWER - 4
Monsanto 10.25. Please estimate RMP's jursdictional credit metric financial ratios using
S&P's methodology based on RMP's current and proposed rates. Also, please provide all
workpapers on electronic spreadsheets with all formulas intact used to respond to this inquiry.
Monsanto 10.26. Please provide a copy ofRMP's five-year budget for: capital expenditues,
capital fuding, and total capital requirements.
Monsanto 10.27. Please provide a description of the economic strength of RMP' s service
terrtory considered by Mr. Wiliams and/or RMP in deriving capital budgets, revenue and
financial projections, and other planing puroses.
DATED this 9th day of August, 2010.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By~r~RADALL C. DGE~~
MONSAO'S TENT DATA REQUESTS TO ROCK MOUNAI POWE - 5
CERTICATE OF MALING
I HEREBY CERTIFY that on this 9th day of August, 2010, I served a tre, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretar (original and3)
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
E-mail: jjewell(gpuc.state.id.us U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: ted.westonCßacificorp.com E-Mail
Paul J. Hickey
Hickey & Evans, LLP
1800 CareyAve., Ste 700
PO Box 467
Cheyenne, WY 82003
E-mail: phickey(fhickevvans.com E-Mail
Mark C. Moench
Daniel Solander
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, Uta 84111
E-mail: mark.moenchCßacificorp.com
daniel.solander(fpacificorp.com
E-Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
E-mail: datarequest(fpacificorp.com
E-Mail
Scott Woodbur
Deputy Attorney General
Idaho Public Utilities Commission
P. O. Box 83720
Boise, Idaho 83720-0074 E-Mail
MONSANO'S TENT DATA REQUESTS TO ROCK MOUNAI POWER - (j
E-mail: scott. woodbur(ßuc.idaho. gov
Katie Iverson
Brubaker & Associates
17244 W. Cordova Cour
Surrise, Arizona 85387
E-mail: kiverson(fconsultbai.com
E-Mail
James R. Smith
Monsanto Company
P. O. Box 816
Soda Springs, Idaho 83276
E-mail: jim.r.smith(fmonsanto.com
E-Mail
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
P.O. Box 1391
Pocatello, Idaho 83204-1391
E-mail: elo(fracinelaw.net
E-Mail
Anthony Yane i
29814 Lake Road
Bay Vilage, Ohio 44140
E-mail: tony(fyankel.net
E-Mail
Michael C. Creamer
Kelsey J. Nunez
Givens Pursley LLP
P.O. Box 2720
Boise, Idaho 83701-2720
E-mail: mcc(fgivenspursley.com
kelseynunez(fgivenspursley.com
E-Mail
Tim Bu11er
Jason Hars
Agrum, Inc.
3010 Conda Road
Soda Springs, Idaho 83276
E-mail: tbuller(fagrium.com
jahars(fagrium.com
E-mail
MONSANO'S TENT DATA REQUESTS TO ROCK MOUNAI POWER. 7
Benjamin J. Otto
Idaho Conservation League
P. O. Box 844
Boise, Idaho 83702
E-mail: botto(fidahoconservation.org
E-Mail
Melinda J. Davison
Davison Van Cleve, P.C.
333 SW Taylor, Suite 400
Portland, Oregon 97204
E-mail: mjd(fdvclaw.com
E-Mail
Ronald L. Wiliams
Wiliams Bradbur, P.C.
1015 W. Hays Street
Boise, Idaho 83702
E-mail: ron(fwiliamsbradbur.com
E-Mail
Brad M. Purdy
Attorney at Law
2019N. 17th Street
Boise, Idaho 83702
E-mail: bmpurdy(fhotmail.com
E-Mail
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MONSANO'S TENTH DATA REQUESTS TO ROCKY MOUNAIN POWER - 8