HomeMy WebLinkAbout20100830PAC to Monsanto 10 (1-27).pdf~. ROCKY MOUNTAIN
POWER. A DMSION OF PAACORP
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RECEIVED
20 I South Main. Sulte 2300
Salt Lake City. Utah 84111
ZOIOAUG 30AH 10:40
IDAHO PU.~.l !Tll 1,1~:Q ('c'~.:'t'
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August 27, 2010
Radal 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 10 (1-27)
Please find enclosed Rocky Mounta Power's responses to Monsanto Data Requests 10.1-10.27.
Provided on the enclosed CD are Attchments Monsanto 10.10, 10.16 -(1-8), 10.21, and 10.24-
(1-6). Provided on the enclosed Confdential CD are Confdential Attchments Monsanto 10.13,
10.22, and 10.26. The Confdential Atthments are Confdential and are provided to pares that
have signed a protective order in ths docket.
If you have any questions, please feel free to call me at (801) 220-2963.
Sincerely,.: T..~ Ú/~/~
J. Ted Weston
Manger, Regulation
Enclosure:
C.c: James R. Smith
Richad Anderson
George C. Carer, III
Denns Peseau
Gaeth R. Kajander
Maurce Brubaker
Bnan Colli
Michal Gorman
Kath Iversn
Mark Widmer
Enc L. Olsen
Jea Jewell
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l'PAC-E-1 0-07/Rocky Mountain Power
August 27, 2010
Monsanto Data Request 10.1
Monsanto Data Request 10.1
Questions Directed to Steven R. McDougal
Reference page 10.13: Please identify how much of the Idaho monthly "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.
Response to Monsanto Data Request 10.1
Monsanto's contribution to coincident peak is not identifiable because "Metered
Loads (CP)" are developed from the hourly loads and the hourly load is
developed at the jurisdictional leveL.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
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August 27,2010
Monsanto Data Request 10.2
Monsanto Data Request 10.2
Questions Directed to Steven R. McDougal
Reference page 10.13: Please identify how much of the monthly "Adjustments
for Curilments, Buy- Throughs and Load No Longer Served (Reductions to
Load)" are for Monsanto. Is the entire amount related to serving Monsanto? If
not, what other loads are considered par of those reductions? Please provide all
supporting workpapers detailng both the Monsanto amount and any other load
amount, including a narative description of how those amoUnts were derived.
Response to Monsanto Data Request 10.2
On page 10.13 of the filing, none of the CP adjustments arerelated to Monsanto.
The adjustments are for the Idaho Irrgation Load Control Program and are
derived based on the expected program paricipation at the time of the system
coincident peaks during 2010.
Recordholder:
Sponsor:
Steve McDougal
Steve McDougal
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PAC-E-10-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.3
Monsanto Data Request 10.3
Questions Directed to Steven R. McDougal
Reference page 10.13. Are the monthly coincident peak dates and times shown
there determined through estimated hourly load data? Please provide all
supporting workpapers detailng how those coincident peak dates and times were
established.
Response to Monsanto Data Request 10.3
Yes, the dates and times are identifieg by developing hourly loads for each
jursdiction, suming the hourly loads, then identifying the date and hour of the
coincident peak. Please refer to the testimony of Dr. Eelkema for more details on
the hourly forecast. Hourly loads were developed using proprieta software and
exporting the model to Excel is excessively time consuming. The model can be
viewed at the Company's Portland offces.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
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PAC-E-l 0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request lOA
Monsanto Data Request 10.4
Questions Directed to Steven R. McDougal
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 January 2010 CP on the
25th at 19:00, while the Exhibit 48 shows a Januar 2010 CP on the 27 at 9:00.
Please explain the differences for each month.
Response to Monsanto Data Request 10.4
Please refer to the Company's response to Monsanto Data Request 7.3.
Recordholder:
Sponsor:
Steve McDougal/Craig Paice
Steve McDougal/Craig Paice
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PAC-E-l 0-07/Rocky Mountain Power
August 27, 2010
Monsanto Data Request 10.5
Monsanto Data Request 10.5
Questions Directed to Steven R. McDougal
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 of Idaho.
Response to Monsanto Data Request 10$,
Please refer to the Company's responses to IIP A Data Request 8 and Monsanto
Data Request 7.3. As explained in these responses class and jurisdictional loads
were prepared using different data sources. As such, class loads do not directly
flow into the jursdictional loads. A comparson of these two load types would
not provide meaningfu data.
Recordholder:
Sponsor:
Steve McDougal/Craig Paice
Steve McDougal ¡Craig Paice
PAC-E-I0-07/Rocky Mountain Power
August 27, 2010
Monsanto Data Request 10.6
. Monsanto Data Request 10.6
Questions Directed to Steven R. McDougal
Reference page 10.14. Please identify how much of the Idaho monthly "Metered
Loads (MWH)" are for Monsanto. Please provide all supporting workpapers
detailing the Monsanto amount.
Response to Monsanto Data Request 10.6
Please refer to Row 41 on sheet "Energy-20 1 0" of Attachment Monsanto 1.18,
which has the monthly sales (at the customer meter) which was used to develop
test year sales.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
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PAC-E-10-07/Rocky Mountain Power
August 27, 2010
Monsanto Data Request 10.7
Monsanto Data Request 10.7
Qùestions Directed to Steven R. McDougal
Reference page 10.14: Please explain why there are no "Adjustments for
Curilments, 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?
Response to Monsanto Data Request 10.7 ,
There are no "Adjustments for Curailmertts, Buy- Thoughs and Load No Longer
Served (Reductions to Load)" on page 1,0;14 for Idaho because the Irrigation
Load Control Program is an energy neutral program and the total monthly energy
for Idaho is not affected by its operation. Please refer to the Company's response
to Monsanto Data Request 10.6. .
Recordholder:
Sponsor:
Steve McDougal
Steve McDougal
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PAC-E-1 0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.8
. Monsanto Data Request 10.8
Questions Directed to Steven R. McDougal
Please explain how all curailments and interrptions to Monsanto, and buy-
thoughs 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 detailng those estimated curilments, interrptions and
buy-throughs.
Response to Monsanto Data Request 10.8
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Idaho coincident peaks and MWh loads used in the JAM study are developed
consistent with the Revised Protocol which prescribes that the jurisdictional loads
should include load for customers under special contracts with ancilar services
as though curilments do not occur. The Company's filed case relies on forecast
load for 2010 for jurisdictional cost allocation in the JAM. Jurisdictional
coincident peaks in the load forecast are already reflected as if curailments did
not occur. Forecasted MWh loads, however, initially include Monsanto
curailments, Consequently, curailments, net of anybuy-throughs, are added
back to Idaho MWh loads used in the JAM study in order to reflect the
jurisdictional MWh loads as if the curailment does not occur. Monthly detail is
shown below:
Recrdholder:
Sponsor:
Steve McDougal
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PAC-E-l 0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.9
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Monsanto Data Request 10.9
Questions Directed to Steven R. McDougal
Please provide a run 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 usingtbe colum designated as "Montana" for
Monsanto.)
Response to Monsanto Data Request 10.9
The Company has not performed the requested analysis. The Jurisdictional
Allocation Model was designed to allocate costs to states based on allocation
factors derived from jurisdictional load. By simply isolating Monsanto's load,
system-allocated costs would be broken out between all other Idaho customers
and Monsanto. The Jursdictional Allocation Model canot split Idaho situs costs
(such as current and deferred taxes, and general plant related costs) and assign the
appropriate share to Monsanto as occtirs ih the cost of service study. The
information contained in the cost of ~ervicedmodel is at a lower level of detail to
appropriately split these costs betwee~ customer classes withn Idaho.
Recordholder:
Sponsor:
Steve McDougal
Steve McDougal
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PAC-E-l 0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.10
Monsanto Data Request 10.10
Questions Directed to C. Craig Paice
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
confidential attachment to MonsantoData 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 three-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?
Response to Monsanto Data Request 10.10
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Monsanto's 3 year average is based upon a normalized year, rather than a simple
averaging of the system peaks. Each ofthe contributing years (2006-2008) was
adjusted to fit the 2009 day-of-the-week profile. Prior year data was shifted
backwards in time. For instance, July 1,2009 occured on a Wednesday. The
closest corresponding Wednesday to July 1 in the 2006 data was June 28, 2006.
So the 2006 data was shifted 3 days (+ 3 years) to align with the 2009 data. . In
2007, the closest corresponding Wednesday to July 1,2009 was June 27, 2007, so
the data was shifted 4 days (+ 2 'yeåis). Qnce this alignment of all the
contrbuting years was complete, theyears.are averaged together to obtan a
normalized, representation for the Mònsanto class loads for the year 2009. At this
point, kWh for the 2009 normalized year (3 yr. avg.) was compared to the
forecasted kWh and adjustment factors were calculated. These adjustment factors
were used to ratio, up or down, the 2009 normalized year (3 yr. avg.) to tie to
forecasted kWh.
Please refer to Attchment Monsanto 10.10 for the data used in the process
explained above. Tab "Mons3yr" shows the 3 prior years of data and how they
were aligned with 2009 dates. Tab "Mons3yravg" shows the resulting 3 year
average. Tab "Adjfactors" shows'tl~'collparson of the 3 year average kWh to
Forecasted kWh and the adjustment fa.ctors needed to ratio, up or down, the 3 year
average kWh to tie to Forecasted kWh. Tab "Monsanto" shows Monsanto loads,
based on a 3 year average, tied to Forecasted kWh.
Recordholder:
Sponsor:
Scott Thornton
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P AC-E-l 0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.11
Monsanto Data Request 10.11
Questions Directed to C. Craig Paice
Please confirm that that all curtailments, 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.
Response to Monsanto Data Request 10.11
The hourly loads presented were derived from actual measurements at the meter,
normalized over a thee year period utilzing the process described in the
Company's response to Monsanto Data Request 10.10. As such, it depicts
normalized data based on actual usage, which would include all curailments and
interrptions. Because these meters measure actual usage, rather than non-usage
(curilment and interrptions), it is not possible to assign a value to the level of
this non-usage based on a normalized load cure. Even for non-normalized data,
it would be difficult to determine the level of curilment or interrption based on
the meter profile data. At best, the meter load profie data can provide
confirmation that a curailment event has occurred, but it can't quatify the
magnitude.
Recordholder:
Sponsor:
Scott Thornton ,
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P AC-E-1 0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.12
Monsanto Data Request 10.12
Questions Directed to C. Craig Paice ,
Please reference the spreadsheet "Attach'Monsanto 1.18" attached to RMP's
response to Monsanto Request No. 1-18. On the sheet "Energy-201 0" the energy
sales for Monsanto are simply the following hard-wired numbers:
Jan-tO 126,100,000
Feb-lO 107,000,000
Mar-tO 113,000,000
Apr-tO 113,000,000
May-tO 113,000,000
Jun-tO 113,000,000
Jul-tO 113,000,000
Aug-tO 113,000,000
Sep-IO 113,000,000
Oct-tO i 13,000,000
Nov-tO 113,000,000
Dec-tO 113,000,000
What is the source of these energy amounts? Do they reflect Monsanto energy
usage before or after any adjustment for curlment, interrptions or buy-
through? Why are all the months March through December set at exactly 113,000
MWH?
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Response to Monsanto Data Request 1Q~1,~'
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These energy amounts are from Monsanto and flow into the forecast though the
Customer and Community Manager ("CCM"). Please refer to Dr. Eelkema's
testimony for more details on the portion of test year sales which is driven by
input from the CCMs. These energy figures are gross of buy-though but net of
interrption. The March through December values are the best estimate of MWh
sales at the time the forecast was estimated.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkèma
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PAC-E-I0-07/Rocky Mountain Power
August 27, 2010
Monsanto Data Request 10.13
Monsanto Data Request 10.13
Questions Directed to C. Craig Paice
Please reference the spreadsheet "Attch Monsanto 1.18" attached to RMP's
response to Monsanto Request No. 1-18, and in paricular the sheet entitled,
"MonsantoCurail". 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 paricular, please explain why
the interrption MWH amounts are added to the monthly energy amounts shown
in Monsanto 10.9 to arive at Monsanto's energy sales?
Response to Monsanto Data Request 10.13
Please refer to Confdential Attachment Monsanto 10.13 for the calculation of the
values shown on the sheet "Monsanto Curail" of Attachment Monsanto 1.18.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
These values are the 5 year average of the MWh of buy-through and curailment.
Interrption energy is added back to Monsanto energy sales to develop test year
sales as if there is no interrption, consistent with the Revised Protocol
interjurisdictional allocation methodqlogy.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
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PAC-E-I0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.14
Monsanto Data Request 10.14
Questions Directed to C. Craig Paice
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.
Response to Monsanto Data Request 10.14
Please refer to the Company's response to lIP A Data Request 15.
Recordholder:
Sponsor:
Craig Paice
Craig Paice
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PAC-E-I0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.15
Monsanto Data Request 10.15
Questions Directed to C. Craig Paice
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.
Response to Monsanto Data Request 10.15
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Please refer to the Company's response to Monsanto Data Request 10.5.
Recordholder:
Sponsor:
Steve McDougal/Craig Paice
Steve McDougal/Craig Paice
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PAC-E-I0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.16
Monsanto Data Request 10.16
Questions Directed to Dr. Samuel Hadaway
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.
Response to Monsanto Data Request 10.16
Please refer to Attachments Monsanto 10.16 -1 through, -8.
Recordholder:
Sponsor:
Dr. Samuel C. Hadaway
Dr. Samuel C. Hadaway
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Questions Directed to Dr. Samuel Hadaway
Please provide complete copies of all utility industry analyst reports, or
assessments on the electric utilty industry, reviewed by Dr. Hadaway.
Response to Monsanto Data Request 10.17
Dr. Hadaway reviewed the Value Line sheets on each of his comparable
companies, some of which discuss electric utilty industr conditions, and the
Standard & Poor's Industry Surey covering the electric utility industr, all of
which are contained in Dr. Hadaway's work papers provided in the original rate
fiing. He also reviewed the rating agency reports provided in response to ICNU
10.1 6.
Recordholder:
Sponsor:
Dr. Samuel C. Hadaway
Dr. Samuel ç. Hadaway
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PAC-E-1 0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.18
Monsanto Data Request 10.18
Questions Directed to Dr. Samuel Hadaway
Please provide complete copies of all comments, reports, etc., of how the curent
capital market and economy have impacted the electric utilty industry and its
growth outlook.
Response to Monsanto Data Request 10.18
All the comments and reports that Dr. Hadaway reviewed with respect to the
electric utility industr are the ones referred to in the Company's response to
Monsanto Data Request 10.17.
Recordholder:
Sponsor:
Dr. Samuel C. Hadaway
Dr. Samuel C. Hadaway
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PAC-E-1 0-07/Rocky Mountan Power
August 27,2010
Monsanto Data Request 10.19
Monsanto Data Request 10.19
Questions Directed to Mr. Bruce Wiliams
On an electronic spreadsheet with all formulas intact, please provide a copy of all
exhibits, analyses and workpapers used in support of Mr. Wiliams' directtestimony. .
Response to Monsanto Data Request 10.19
Please refer to the Company's response to Monsanto Data Request 1.6.
Recordholder: Bruce Willams
Sponsor: Bruce Wiliams
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PAC-E-1 0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.20
Monsanto Data Request 10.20
Questions Directed to Mr. Bruce Wiliams
Referring to page 2 of Mr. Wiliams' direct testimony, on an electronic
spreadsheet with all formulas intact;please provide the balance of the long-term
debt, preferred stock, and common equity used to derive the weight of each tye
of capital as shown in the table on lines 19 through 22.
Response to Monsanto Data Request 10.20
Please refer to the workpapers provided in the Company's response to Monsanto
Data Request 1.6.
Recordholder: Bruce Wiliams
Sponsor: Bruce Wiliams
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P AC-E-1 0-07/Rocky Mountain Power
August 27, 2010
Monsanto Data Request 10.21
Monsanto Data Request 10.21
Questions Directed to Mr. Bruce Wiliams
On an electronic spreadsheet with all formulas intact, please provide the monthly
average balances for construction work in progress and short-term debt for the
most recent 13-month period and for the five-quarter ends used to derive the
proposed capital structue.
Response to Monsanto Data Request 10.21
Please refer to Attchment Monsanto 10.21
As noted in the testimony of Mr. Willams, the Company believes it is
inappropriate and inequitable to include short-term debt in the capital structure for
PacifiCorp as short-term debt is effectively being double-counted as financing
both rate base and construction work in progress.
Recordholder: Bruce Wiliams
Sponsor: Bruce Wiliams
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PAC-E-10-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.22
Monsanto Data Request 10.22
Questions Directed to Mr. Bruce Wiliams
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 strctue. Also, please break down the equity
amount for each quarer based on the retained earings, equity contributions
(paid-in capital) and other comprehensive income.
Response to Monsanto Data Request 10~2i.
Please refer to the Company's response to Monsanto Data Request 1.6 for the
amount of debt, equity and preferred stock for each of the five quarers used to
derive the Company's proposed capital strcture.
Please refer to Confidential Attachment Monsanto 10.22 for the requested break
down of the equity amounts. This information is confidential and is provided
subject to the terms and conditions of the protective agreement in this proceeding.
Recordholder: Bruce Wiliams
Sponsor: Bruce Wiliams
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PAC-E-I0-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.23
Monsanto Data Request 10.23
Questions Directed to Mr. Bruce Wiliams
On page 10 of Mr.' Wiliams' direct testimony, he states that S&P imputed
$395 millon 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.
Response to Monsanto Data Request 10.23
Please see line "Power purchase agreements" on page 6 of the April 30, 2010
Ratings Direct report by Standard & Poor's provided in the Company's response
to Monsanto Data Request 10.24.
Recordholder: Bruce Wiliams
Sponsor: Bruce Wiliams
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PAC-E-10-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.24
Monsanto Data Request 10.24
Questions Directed to Mr. Bruce Wiliams
Referrng to page 10 ofMr. 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.
Response to Monsanto Data Request 10.24
PacifiCorp objects to this request as it is overly broad, administratively
burdensome and unlikely to lead to relevant information in the curent rate case.
Notwthstanding this objection, please see recent credit rating reports concerning
PacifiCorp and also rating agency methodology concerning adjustments to
financial results. These are provided as Attachments Monsanto 10.24 -1 through
-6.
Recordholder: Bruce Wiliams
Sponsor: Bruce Wiliams
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PAC-E-10-07/Rocky Mountain Power
August 27,2010
Monsanto Data Request 10.25
Monsanto Data Request 10.25
Questions Directed to Mr. Bruce Willams
Please estimate RMP's jurisdictional credit metric financial ratios using S&P's
methodology based on RMP's curent and proposed rates. Also, please provide
all workpapers on electronic spreadsheets with all formulas intact used to respond
to this inquiry.
Response to Monsanto Data Request 10.25
PacifiCorp is unable to estimate jurisdictional credit metric financial ratios using
S&P's methodology based on PacifiCorp's current and proposed rates.
PacifiCorp has not undertaken suchan exercise. '
Recordholder: Bruce Willams
Sponsor: Bruce Wiliams
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P AC-E-1 0-07/Rocky Mountain Power
August 27, 2010
Monsanto Data Request 10.26
Monsanto Data Request 10.26
Questions Directed to Mr. Bruce Wiliams
Please provide a copy ofRMP's five-year budget for: capital expenditures,
capital fuding, and total capital requirem'ents.
Response to Monsanto Data Request 10.26
Please refer to Confidential Attachment Monsanto 10.26 for a copy of the curent
five-year capital expenditue and capital requirements budgets. This information
is confidential and is provided subject to the terms and conditions of the
protective agreement in this proceeding.
PacifiCorp relies upon a number of sources to fud its capital expenditures,
including cash from operations, debt issuances and capital infsions from its
parent. To the extent fuds are not available to support capital expenditures;
projects may be delayed or cancelled. Presently expected total capital
requirements (fuding) are shown in the attached document.
Recordholder:
Sponsor:
Robert Meehl
To Be Determined
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P AC-E-1 0~07 /Rocky Mountan Power
August 27, 2010
Monsanto Data Request 10.27
Monsanto Data Request 10.27
Questions Directed to Mr. Bruce Willams
Please provide a description of the economic strength ofRMP's service territory
considered by Mr. Wiliams and/or RMP in deriving capital budgets, revenue and
financial projections, and other planing purposes.
Response to Monsanto Data Request 10.27
Please refer to the testimony of Dr. Peter Eelkema for a description ofthe
economic strength and its impact to the company's sales and load forecasting
model, which is a major factor in determining our capital requirements and
resource plans.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
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i.