20101110Monsanto 3 (1-5) to PAC.pdf

Rocky Mountain Power
Attn: J. Ted Weston
201 South Main, Ste 2300
Salt Lake City, Utah 84 i i i
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 VOLYN
BRENT L. WHITING
JONATHON S. BYINGTON
DAVE BAGLEY
THOMAS J. BUDGE
JONATHAN M. VOLYN
MARK A. SHAFFER
JASON E. FLAIG
FERRELL S. RYAN, III
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702
TELEPHONE: (208) 395~OO t 1FACSIMILE: [phone]
TELEPHONE [phone]
FACSIMILE [phone] IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 107
POST OFFICE BOX 50698
IDAHO FALLS. ID 83405
TELEPHONE: [phone]
FACSIMILE: [phone]
www.racinelaw.net
ALL OFFICES TOLL FREE
[phone]
SENDER'S E-MAIL ADDREss:rcb(Qracinelaw.net
LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON, OF COUNSEL
November 9,2010 ~-i:
~-rno
~
E5..-
C'
Re: PAC-E-10-07
RMP 3rd Set Data Requests
Please find enclosed Monsanto's responses to Rocky Mountain Power's 3rd Set Data Requests as
follows: 3. i with Confidential Attachment 3. i, 3.2-3.5. Provided on the enclosed Confidential CD
is Confidential Attachment 3.5. The Confidential Attachments are confidential and are provided to
parties that have signed a protective order in this docket.
c.f:
RCB:rr
Enclosures
cc: Jean Jewell/IPUC (C) - 3 copies
Eric Olsen/IIP A (C)
Ben Otto/ICL (C)
Mark Moench/RMP (C)
Paul J. Hickey/RMP (C)
Scott Woodbury/Staff (C)
November 9, 2010
Page 2
Anthony Yanel (C)
Dr. Don Reading (C)
Melinda Davison (C)
Ronald L. Wiliam (C)
Brad M. Purdy (C)
PAC-E-1O-07/Monsanto Company
November 8, 2010
RMP Data Request 3.1
RMP Data Request 3.1
Page nine of Ms. Iverson's testimony states "First, Idaho's industrial revenue (Account 442) was
reduced by the amount of firm revenue that the Company had imputed for Monsanto's non-firm
load." Please provide the calculation, source references and rationale for the calculation ofthis
number.
Response to RMP Data Request 3.1
Please see Confidential Attachment RMP 3.1 for the calculation. The source reference for the
kW units are Exhibit No. 55, page 6 of 6, Schedule 400 Non-Firm kW. The rationale for the
calculation is that the JAM study includes revenue for Schedule 400 assuming Monsanto were
served asa firm customer at a present firm k W charge of $12.27 per kW -month.
Recordholder:
Sponsor:
Kathrn E. Iverson
Kathn E. Iverson
PAC-E-10-07
November 8, 2010
RMP Data Request 3.2-3.5
RMP 3.2 Refer to Mr. Widmer's testimony fied on November 1, 2010, please list all
changes made since the fiing of his original testimony on October 14, 2010, and explain how
each of the changes is related to the issue identified in the Commission order.
Response to Monsanto 3.2
PacifiCorp has copies ofthe original fied testimony and the revised filed testimony and can
identify the specific changes that were made.
The testimony was revised to remove pars related to the value of the Monsanto curtailment
products, three small corrections were made for adjustments 6 through 15, which in total reduced
the proposed adjustments by approximately $5,700 on an Idaho basis. These corrections
necessitated revisions to Table 1. A description of these adjustments was previously provided to
PacifiCorp via e-mail to Mark Moench on November 1,2010. Table 2 and a description of what
the table depicted were revised to correct a data sorting error. The revision did not impact the
value of the proposed adjustments.
To be conservative Graph 1 was treated as confidential in the revised fiing to be conservative
because the information was provided as par of a confdential attachment. However, it is worth
noting that this same type of Black Hils information previously has been provided on a non-
confidential basis, the contract was provided on a non-confdential basis in this case and the
anual data for the sale is available in PacifiCorp's FERC Form 1.
In addition, the terms of two Morgan Stanley call option contracts were treated as confidential in
the revised filing to be conservative because the contract was provided on a confidential basis.
However, it is worth noting that at the time of filing the contracts had expired as should have any
confidential treatment of the contracts.
RMP 3.3 Refer to Mr. Widmer's testimony on October 14, 2010, page 15 lines 34-35.
Please provide support for the statement regarding payments by retail customers.
Response to RMP 3.3
The support is included in Mr. Widmer's testimony in the second quoted section of the FERC
Order shown of page 15 of his testimony.
RMP 3.4 Monsanto response to RMP 1.1 is incomplete. For the following, please identify
the workpapers or the location in the workpapers, if already provided, otherwise, please provide
the workpapers as requested in RMP 1.1:
"Please provide all workpapers and exhibits supporting Mr. Widmer's testimony with all
formulas and links to other files intact, including but not limited to the GRID scenarios, revised
inputs to the scenarios, workpaper supporting the revisions to the Company's inputs and
1
assumptions, and the outputs demonstrating the impact of the adjustments. Please also identif
the source of the data. "
a. Workpapers supporting Mr. Widmer's adjustment 3, related to the capacity and costs of
the NF transmission.
b. Workpapers supporting Mr. Widmer's adjustment 5, related to the determination of the
inputs to GRID for the adjusted outages.
c. Workpapers supporting Mr. Widmer's adjustment 7, related to determination ofthe
amount adjusted for Cal iso fees.
d. Workpapers supporting Mr. Widmer's adjustment 10, for source ofCholla 4's capacity.
e. Workpapers supporting Mr. Widmer's adjustment 12, related to the determination ofthe
inputs to GRID for adjusted hydro generation.
f. Workpapers supporting Mr. Widmer's adjustment 13, related to the determination of the
inputs to GRID for the Black Hils contract.
g. Workpapers supporting Mr. Widmer's adjustment 14, related to the determination of the
inputs to GRID for the Mona market.
h. Workpapers supporting Mr. Widmer's adjustment 15, related to the determination of the
inputs to GRID for the adjusted Naughton 3 outages.
Response RMP 3 Aa
The workpapers for the adjustment 3 Non-Firm Transmission, were provided on a CD provided
in response to RMP 1.1 in the folder labeled Attchment RMP 1.1 c. The name of the file
including the workpapers is Attach Monsanto 2.50 CONFNF Trans.
Response RMP 3.4b
Workpapers supporting Adjustment 5 Reserve Shutdowns, was provided on the CD provided to
Daniel Solander on November 3, 2010.
Response to RMP 3 Ac
Workpapers supporting Adjustment 7 Cal iSO, were provided to PacifiCorp on November 3,
2010 on the CD sent to Daniel Solander.
Response to RMP 3 Ad.
The 395 MW capacity used in Adjustment 10 Cholla 4 Capacity, was calculated by adding the
380 MW capacity used by PacifiCorp in Case No. PAC-E-08-07 and provided as Attachment
Monsanto 2.3 in this docket and the 15 MW capacity upgrade shown in Attachment Monsanto
2.27. It should be noted that the 390 MW capacity referenced in direct testimony should have
been 395 MW.
Response to RMP 3 Ae
The workpapers for Adjustment 12 Bear River Hydro Normalization, were provided on a CD
provided in response to RMP 1.1 in the folder labeled Attachment RMP 1. Ih. As explained in
RMP 1.1 the fie name for the source is Attachment WIEC 5.2-2. The Historical generation tab
was used to develop the GRID inputs.
2
Response to RMP 3.4 f
The workpapers for Adjustment 13 Black Hils Shaping, were provided on a CD provided in
response to RMP 1.1 in the folder labeled Attachment RMP 1.1 d. This is the same location that
the Black Hils workpaper referenced by PacifiCorp in RMP 3.5 is located.
Response to RMP 3.4g
The workpapers for Adjustment 14 Mona Market, were provided on a CD provided in response
to RMP 1.1 in the folder labeled Attachment RMP 1.1 e. The names of the workpapers used to
develop the GRID adjustment are 2006 STF Mona Market, 2007 STF Mona Market, 2008 STF
Mona Market and Copy of 2009 STF Mona Market. The calculation of the GRID inputs for the
adjustment is included in the Mona Market tab of the 2006 STF Mona Market fie.
Response to RMP 3.4h
The corrected workpaper for the Adjustment 15 Naughton 3 Outage, was included in the CD
provided to Daniel Solander on November 3, 2010.
RMP 3.5 The separation of the Black Hils history into Heavy Load Hours and Light Load
Hours in Mr. Widmer's file entitled "BHPL.xls" appears to be incorrect. Please explain how it
was done and why it is appropriate.
Response to RMP 3.5
The macro used to calculate the historical HLH and LLH energy for the sale does include a small
error. The date/time used in the macro should have been converted from hour ending to hour
beginning before being sent to the HLH macro. Correction of this error reduces the impact of the
adjustment by approximately $1,800 on an Idaho basis. The corrected workpaper is provided as
Confidential Attachment RMP 3.5.
Recordholder:
Sponsor:
Mark Widmer
Mark Widmer
3