20101028Monsanto to PAC 1 (1-3), 2 (1-22).pdf

Rocky Mountain Power
Attn: J. Ted Weston
201 South Main, Ste 2300
Salt Lake City, Utah 84111
W. 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 TIPPI YOLYN
BRENT L. WHITING
JONATHON S. BYINGTON
DAVE BAGLEY
THOMAS J. BUDGE
JONATHAN M. YOLYN
MARK A. SHAFFER
JASON E. FLAIG
FERRELL S. RYAN, III
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
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POCATELLO, IDAHO 83204-1391
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LOUIS F. RACINE 0917-2005)
WILLIAMD. OLSON, OF COUNSEL
October 27,2010
Re: PAC-E-IO-07
RMP rand 2'ld Set Data Requests
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Please find enclosed Monsanto's responses to Rocky Mountain Power's 1 st and 2nd Set Data Requests
as follows: 1.1, 1.2,1.3, and 2.1 '- 2.22. Provided on the enclosed CD is Attachment 1.3. Provided
on the enclosed Confidential CD Confidential Attachment 1.1. The Confidential Attachments are
confidential and are provided to parties that have signed a protective order in this docket.
4
LC. BUDGE
RCB:rr
Enclosures
cc: Jean JewelllIPUC (C) - 3 copies
Eric Olsen/lIP A (C)
Ben Otto/ICL (C)
Mark Moench/RMP (C)
Paul J. Hickey/RMP (C)
Scott Woodbury/Staff (C)
October 27,2010
Page 2
Anthony Yanel (C)
Dr. Don Reading (C)
Melinda Davison (C)
Ronald L. Wiliam (C)
Brad M. Purdy (C)
P AC-E-1 0-07/Monsanto Company
October 28, 2010
RMP Data Request 1.1
RM Data Request 1.1
Please provide all workpapers and exhibits supporting Mr. Widmer's testimony with all formulas and
links to other fies intact, including but not limited to the GRID scenarios, revised inputs to the
scenarios, workpaper supporting the revisions to the Company's inputs and assumptions, and the
outputs demonstrating the impact of the adjustments. Please also identify the source of the data.
Response to RM Data Request 1.1
The GRID project including revised GRID inputs is provided as Confidential Attachment RMP 1.1 a
(Confidential). Table 1 and supporting GRID runs are provided as Attachment RMP 1.1 b
(Confidential). Table 2 and supporting workpapers are provided as Attachment RMP 1.1c
(Confidential). The sources for Table 2 are Monsanto 2.50 and Monsanto 2.7. Graph 1 and
supporting workpapers are provided as Attchment RMP LId (Confidential). The sources for
Graph 1 are Monsanto 2.42 and a GRID LTC dispatch export. Table 3 and supporting workpapers
are provided as Attachment RMP 1.1 e (Confidential). The sources for Table 3 are a GRID extract
of actual STP Mona market sales included the Company's filing and Monsanto 2.61, Workpapers
for the reserve shutdown adjustment, are provided as Attachment RMP 1.1 f (Confidential). The
source of the data used in the reserve shutdown adjustment was Monsanto 2.8. Workpapers for the
Colstrip planned outage adjustment is provided as Attachment RMP 1.1 g (Confidential). The
Colstrip adjustment was based on Mr. Widmer's judgement. Workpapers for the Bear River
adjustment are provided as Attachment RMP 1.1h. The source for the Bear River adjustment is
Attachment WIEC 5.2-2. Workpapers for the Naughton 3 outage adjustment are provided as RMP
1.li (Confidential). The source information for the Naughton adjustment is Monsanto 9.3.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC-E-l 0-07/Monsanto Company
October 28, 2010
RMP Data Request 1.2
RMP Data Request 1.2
Please provide all workpapers and exhibits supporting Mr. Collns' testimony with all formulas
and links to other fies intact. Please also identify the source of the data.
Response to RMP Data Request 1.2
None.
Recordholder: Brian Collns
Sponsor: Brian Collns
P AC-E-1 0-07/Monsanto Company
October 28, 2010
RMP Data Request 1.3
RM Data Request 1.3
Please provide all workpapers and exhibits supporting Mr. Gorman's testimony with all formulas
and links to other fies intact. Please also identify the source of the data.
Response to RM Data Request 1.3
Please refer to the attached CD for the workpapers of Mr. Gorman. Confidential information is
provided subject to the terms and conditions of the protective agreement in this proceeding.
Recordholder: Mike Gorman
Sponsor: Mike Gorman
P AC-E-1 0-07/Monsanto Company
October 28,2010
RMP Data Request 2.1
RM Data Request 2.1
Refer to Mr. Widmer's testimony page 3, Table 1. To the extent not already provided, please provide
all workpapers supporting the adjustments with formulas and links to other fies intact. Please also
identify the source of the data.
Response to RM Data Request 2.1
The requested information was previously provided in response to RMP 1.1
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P A C- E-1 0-07/Monsanto Company
October 28, 2010
RMP Data Request 2.2
RM Data Request 2.2
Refer to page 1, lines 22-23. Is it correct that Mr. Widmer was referring to Exhibit 228 in the
current proceeding?
Response to RM Data Request 2.2
Yes.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
PAC-E-10-07/Monsanto Company
October 28, 2010
RMP Data Request 2.3
RM Data Request 2.3
Please identify all known errors in the GRID models studies used in Mr. Widmer's testimony.
Response to RM Data Request 2.3
There is one material error. The October 2010 energy amount for the Bear River adjustment
should have been 4.8 average megawatts instead of the 11.3 average megawatts. The correction
reduces the original proposed adjustment Included in Table 1 by $141,845 total Company and
$8,416 on an Idaho basis.
Recordholder: Mark Widmer
Sponsor: MarkWidmer
P AC- E-1 0-07/Monsanto Company
October 28,2010
RMP Data Request 2.4
RM Data Request 2.4
Please identify all known errors in the exhibits prepared by Mr. Widmer in this case.
Response.to RM Data Request 2.4
The yearly non-firm information shown in Table 2 was based on the wrong data sort. The correct
values for 2006, 2007, 2008 and 2009 are 1.76, .88,9.74 and 3.13, respectively. These Table 2
changes do not impact the four-year average or the non-firm adjustment included in Table 1.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC- E-1 0-07/Monsanto Company
October 28, 2010
RMP Data Request 2.5
RM Data Request 2.5
Refer to page 2, lines 3-4. Is Mr. Widmer proposing to changes the logic ofthe GRID model,
besides the inputs? If yes, please provide the proposed changes.
Response to RM Data Request 2.5
No.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC- E-1 0-07/Monsanto Company
October 28,2010
RMP Data Request 2.6
RM Data Request 2.6
Refer to page 2, line 11. Please explain and define "reasonable results."
Response to RM Data Request 2.6
Results are reasonable when they are reflective of the Company's system operation within the
confines of proper normalization for ratemaking.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
PAC-E-10-07/Monsanto Company
October 28,2010
RMP Data Request 2.7
RM Data Request 2.7
Refer to page 4, lines 5-9. Please explain Mr. Widmer's understanding of why the Commission
adopted the $6.50/MWh as the wind integration costs for avoided cost rates for qualifying
facilities.
Response to RM Data Request 2.7
The $6.50/MWh rate for wind integration was adopted for avoided costs as a compromise
because there was no consensus methodology for calculation of wind integration costs.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC- E-1 0-07/Monsanto Company
October 28,2010
RMP Data Request 2.8
RM Data Request 2.8
Refer to page 4, lines 9-12. Please explain how Mr. Widmer would determine the amount of
wind integration costs to be included in an ECAM.
Response to RM Data Request 2.8
Wind integration costs are embedded within actual results included in the ECAM. Actual wind
integration costs less actual wind integration costs associated with OATT customers would be
recoverable through the ECAM. The adjustment to remove actual OATT wind integration costs
should be based on a Company calculation of actual wind integration costs for the ECAM
historical period.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC-E-1 0-07/Monsanto Company
October 28, 2010
RMP Data Request 2.9
RM Data Request 2.9
Refer to page 4, line 23 to page 5 line 1. Please define the responsibility of Idaho customers.
Response to RM Data Request 2.9
Idaho retail customers should not be held accountable for costs that were caused by OATT
customers that should be recoverable from OATT customers if the Company had made a FERC
filing requesting such recovery.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
PAC-E-1 0-07/Monsanto Company
October 28, 2010
RMP Data Request 2.1 0
RM Data Request 2.10
Refer to page 6, lines 20-21. Please provide support to the assertion.
Response to RM Data Request 2.10
Attachment Monsanto 2.60 shows that the Company's filing did not include any transactions with
the Cal iso after May 3, 2010.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC-E-1 0-07/Monsanto Company
October 28, 2010
RMP Data Request 2.11
RM Data Request 2.11
Refer to page 12, lines 14-16. How does Mr. Widmer propose to calculate the actual wind
integration costs? Please explain.
Response to RM Data Request 2.11
Actual wind integration costs for the ECAM historical period should be calculated using the
Company's latest methodology for estimating wind integration costs.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
PAC-E-1 0~07 /Monsanto Company
October 28,2010
RMP Data Request 2.12
RM Data Request 2.12
Refer to page 12, lines 23~24. Does Mr. Widmer agree that the Company is authorized to use
$6.50/MWh to calculate avoided costs of the Company's system? Please explain.
Response to RM Data Request 2.12
Mr. Widmer agrees that the $6.50 rate for wind integration was approved by the Commission for
avoided cost rates used in qualifying facility contracts. However, to the best of his knowledge
that rate was not approved for other purposes.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
PAC-E-1 0-07/Monsanto Company
October 28,2010
RMP Data Request 2.13
RM Data Request 2.13
Refer to page 12, lines 24-26. Is it correct to state that Mr. Widmer would recommend the
Commission reject the Company's avoided costs if the Company had entered into contracts with
qualifying facilities using the Commission authorized $6.50/MWh wind integration costs? Please
Explain.
Response to RM Data Request 2.13
No. See Monsanto's response to RMP 2.12.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC-E-1 0-07/Monsanto Company
October 28, 2010
RMP Data Request 2.14
RM Data Request 2.14
Refer to page 17, lines 1-5. Please identify the transactions that are used for wind integration
balancing references in the assertion.
Response to RM Data Request 2.14
The Company has stated on numerous occasions, including IRP workshops that wind integration
costs is comprised of intra-hour costs and inter-hour balancing costs. In response to Monsanto
3.37 the Company stated that the most used method for system balancing for inter-hour wind
integration is hourly firm wholesale transactions. Since actual hourly firm wholesale transactions
were included in the Company's fiing for the first four months of the test year, inter-hour wind
integration balancing costs were included in the Company's fiing prior to the inclusion of the
Company's separately modeled wind integration costs. This necessitates an adjustment to
remove the double count associated with the Company's separately modeled inter-hour wind
integration costs. The double count is calculated as described in Mr. Widmer's testimony. He is
not able to specifically identify which wholesale transactions were used for inter-hour wind
integration, nor is it necessary to remove the double count.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
PAC-E-10-07/Monsanto Company
October 28, 2010
RMP Data Request 2.15
RM Data Request 2.15
Refer to page 17, lines. 15-17. Please explain the logic providing the support for prorating
$6.50/MWh based on the wind integration costs determined in the Company's last IRP, besides
the mathematical computation.
Response to RM Data Request 2.15
See the Monsanto's response to RMP 2.14.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC-E-1 0-07/Monsanto Company
October 28, 2010
RMP Data Request 2.15(2)
RM Data Request 2.15(2)
Refer to page 18, lines 13-14. Please define "utilzation" in this context.
Response to RM Data Request 2.15(2)
Utilization refers to the amount ofMWh transmitted via non-firm and STP transmission.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC- E-1 0-07/Monsanto Company
October 28,2010
RMP Data Request 2.16
RM Data Request 2.16
Refer to page 18, lines 14-16. Please explain whether Mr. Widmer refers to non-firm
transmission transactions or the non-firm energy transactions.
Response to RM Data Request 2.16
The reference is to MWh shown in Confidential Attachment Monsanto 2.50.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC-E-1 0-07 /Monsanto Company
October 28, 2010
RMP Data Request 2.17
RM Data Request 2.17
Refer to page 19, Table 2. To the extent not already provided, please provide all workpapers
supporting the data with formulas and links to other files intact. Please also identify the source
of the data.
Response to RM Data Request 2.17
The requested information was previously provided in response to RMP 1.1. Also see
Monsanto's response to RMP 2.4.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
PAC-E-1 0-07/Monsanto Company
October 28,2010
RMP Data Request 2.18
RM Data Request 2.18
Refer to page 20, lines 23-24. 'Please indentify the inputs to GRID that uses forced outage rate.
Response to RM Data Request 2.18
Monsanto's recalculation of the Company's forced outage rates, excluding reserve shutdowns are
used as the GRID EFOR input.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
PAC-E-1 0-07/Monsanto Company
October 28,2010
RMP Data Request 2.19
RM Data Request 2.19
Refer to page 27, lines 18-21. Please identify the source(s) of the information.
Response to RM Data Request 2.19
The source is Monsanto 2.47.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
P AC-E-1 0-07/Monsanto Company
October 28,2010
RMP Data Request 2.20
RM Data Request 2.20
Refer to page 34, Table 3. To the extent not already provided, please provide all workpapers
supporting the data with formulas and links to other fies intact. Please also identify the source
of the data.
Response to RM Data Request 2.20
The requested information was previously provided in response to RMP 1.1.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
PAC-E-10-07/Monsanto Company
October 28, 2010
RMP Data Request 2.21
RM Data Request 2.21
Refer to page 34, Table 3. Please update the table to include purchases.
Response to RM Data Request 2.21
The requested analysis has not been prepared.
Recordholder: Mark Widmer
Sponsor: Mark Widmer
PAC-E-1 0-07/Monsanto Company
October 28, 2010
RMP Data Request 2.22
RM Data Request 2.22
Refer to page 36, lines 15-17. Please explain Mr. Widmer's understanding of the content of the
$16m.
Response to RM Data Request 2.22
The curtailment services provided by Monsanto under the curent contract are for non-spin
operating reserves, economic curailment and system integrity.
Recordholder: Mark Widmer
Sponsor: Mark Widmer