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HomeMy WebLinkAbout20100830PAC to Monsanto 10 (1-27).pdf~. ROCKY MOUNTAIN POWER. A DMSION OF PAACORP 'l .d'! . . 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' Li _.. Ik--.. ~",J V..j £iii (~n: 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 Be Ot 'J . . . 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 "t'.. l' . . . f P AC-E-l 0-07/Rocky Mountain Power 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 '.~ ~ , i d "f . . . 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 ;1.1 ,'" ", .... , , T . . . 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 I, . !\ t: j'", . . . 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 .~d Ir "i :'::, ,i Ii. I'" . " . . . 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 , ' ,( : r "i .1 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 . 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 Steve McDougal..\'j: . . . PAC-E-l 0-07/Rocky Mountain Power August 27,2010 Monsanto Data Request 10.9 ¡',~ , ;. ~... i: 1 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 .'¡ i; _~',', :i ,.::", :, 'I' ,...'',\ , ;,( , , : . . . 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 . ~ 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 To Be Determined.," 'j" ;,1,,h"t" , ~; . . . 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 , To Be Determined ,\ lfi' , 1 , ~ t , ) r i. . . . . 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? i'".' 1-1, Response to Monsanto Data Request 1Q~1,~' ¡ ;i' 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 , ', ¡ '.: " . . . 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 ; ,~. t\ ~ ,1' . . . 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 . . . 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 ~ ; Please refer to the Company's response to Monsanto Data Request 10.5. Recordholder: Sponsor: Steve McDougal/Craig Paice Steve McDougal/Craig Paice (I' ( . . . 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 ,~t 1~:: i ¡'. ~ 1. .; to; .! '"( r , . . 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 .., ! .J II . , r . . . 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 I.J' l" ,I í . . . 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 l, \~ . . . 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 . '"1 L: :i . . . 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 "j ~ " . . . 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 .~ ! ":I. .-¡ f J~ .. . . . 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 ~ , ; ; 'I j__,'j, ~. .(. .. . . . 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 'i.'¡! t J, . . . . 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 .i ' i '':.' I' ,i '0 , . . . 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 i " :':-_." '.' i ! i Ii ,I' ,t~.. ~, . . . 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 . t.:. U"( .:1 i.