20101126PAC to Monsanto Reb 1 (1-9).pdf

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November 24,2010
Radall C. Budge
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHATERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
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RE: ID PAC-E- 10-07
Monsanto Rebuttl 1 st Set Data Request (1-9)
Please find enclosed Rocky Mountai Power's responses to Monsanto Rebutt 1st Set Data
Requests 1.1-1.9. Provided on the enclosed CD are Attchments Monsanto Rebutt 1.2 and 1.8.
Provided on the enclosed Confdential CD is Confdential Attchment Monsanto Rebutt 1.7.
The Confdential Atthment is Confdential and is provided to pares tht have signed a
protective order in ths docket.
If you have any questions, please feel free to call me at [phone].
Sincerely,
:1. T(ty tv~ /~
J. Ted Weston
Manager, Reguation
Enclosure:
cc: Jea Jewell/UC (C)/ 3 copies
Eric OlsenlPA (C)
Ben Oto/ICL (C)
James R. Smithonsato (C)
Richard AndersonIonsato (C)
George C. Carer, TIl/Monsanto (C)
Denns Peseau/onsanto (C)
Ga R. Kajander/Monsanto (C)
Maurce Brubaker/Monsanto (C)
Brian Collins/onsanto (C)
Michal Gormonsanto (C)
Kath IversonIonsanto (C)
Mark Widmer/Monsanto (C)
.)
.P AC-E- 10-07 /Rocky Mounta Power
November 24,2010
Monsanto Rebuttal Data Request 1.1
Monsanto Rebuttal Data Request 1.1
Please provide the liquidated damage calculation for Naughton 3 in excel format
with all cells and formula intact. Please note that ths is a follow-up question to
Monsanto 9.2 in which the Company's response did not provide the requested
information.
Response to Monsanto Rebuttal Data Request 1.1
The terms for liquidated daages were $70,000 per day, or a maximum of
$500,000 (please refer to Atthment Monsanto Rebutt 1.2). Since the outae
was extended more th eight days, the amount paid was the maimum rather
than any calculated amount.
Recordholder:
Sponsor:
Chad Teply
Chad Teply
.
.
.)
.P AC-E-l 0-07/Rocky Mountain Power
November 24,2010
Monsanto Rebutt Data Request 1.2
Monsanto Rebuttal Data Request 1.2
Please provide the all sections of the Company's Naughton 3 contract with
Siemens tht discusses liquidated damages.
Response to Monsanto Rebuttl Data Request 1.2
Please refer to Attchment Monsanto Rebutt 1.2.
Recordholder:
Sponsor:
Cha Teply
Chad Teply
.
.
.PAC-E-10-07/Rocky Mountain Power
November 24,2010
Monsanto Rebutt Data Request 1.3
Monsanto Rebuttal Data Request 1.3
Please provide support for the statement that optize NPC tends to understate
actul NPc.
Response to Monsanto Rebuttl Data Request 1.3
The Company's optization model has perfect foresight of load, market prices,
wid and hydro generation, availabilty of thermal generating unts, and
counterpar transactions. In actu operaion, decisions must be made without
knowing these factors with certty. Differences between forecass and actu
outcomes will result in less th optial dispatch of the Company's resources.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
.
.
.P AC-E- 10-07 /Rocky Mountain Power
November 24,2010
Monsanto Rebutt Data Request 1.4
Monsanto Rebuttal Data Request 1.4
Please provide the Company's updated GRID project, workpapers, and GRI
studies that support all inormation and clais contained in Dr. Shu's rebutt
testimony.
Response to Monsanto Rebuttal Data Request 1.4
Please refer to Confdential Atthment PIlC 143 -1 and Atthment PIlC 143 -2
for workpapers supporting the testiony and exhbits. The support for the
Company's rebuttal NPC is provided as par of the Company's response to PILC
Data Request 144. Please refer to Confdential Attchment PILC 144 - 1 for NPC
reports and descriptions of the changes. Pleae refer to Confdential Atthment
PIlC 144 -2 for the Company's Rebuttal GRI modeL. Please refer to
Confdential Atthment PUC 144 -3 for workpapers supporting the changes to
the inputs to the modeL.
Ths confdential inormation is provided subject to the ter and conditions of
the protective agreement in ths proceeding..Recordholder:
Sponsor:
Hui Shu
Hui Shu
.
.P AC-E-l 0-07/Rocky Mounta Power
November 24,2010
Monsanto Rebutt Data Request 1.5
Monsanto Rebuttal Data Request 1.5
On page 8 of Dr. Shu's testimony she states that for both non-fi and STF
transmission, wheeling expenses are incured whether the trmission capacity is
fully utilized. Please provide the fixed and varable cost of each non-firm
transmission for each lin for 2009.
Response to Monsanto Rebuttl Data Request 1.5
The Company has not prepared the requested information with the requested level
of details. The Company considers tht all costs related to non-firm transmission
are not avoidable if the non-firm tranmission capacities are included in the
normalized net power costs.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
.
.
.P AC-E-1 0-07 /Rocky Mounta Power
November 24,2010
Monsanto Rebuttl Data Request 1.6
Monsanto Rebuttal Data Request 1.6
Pleae provide an estimate of actual historical wid integration cost for calendar
year 2008 or 2009 using only historical data from the year in which costs are
estimated, plus all workpapers and documents which support the caculation in
workig format with all cells and formula intat. If the Company ha not
prepared such a estimate, please state.
Response to Monsanto Rebuttal Data Request 1.6
No estimate has been made. Wind integration costs are largely drven by the
increased demand on operating reserves requied to manage the volatilty of wind
generation on PacifiCorp's system. Whle these operatig reserves were held in
2008 and 2009 consistent with the level of wind generation on PacifiCorp's
system at the time, it is not possible to dierentiate the amount of operating
reserves held to integrate wid from the operatig reserves held for other system
varables.
.Recordholder:
Sponsor:
Rick Link
Hui Shu
.
.P AC-E-1 0-07/Rocky Mountain Power
November 24,2010
Monsanto Rebuttl Data Request 1.7
Monsanto Rebuttal Data Request 1.7
Please verify and provide documentation that the Top of World wid project was
placed in servce on October 1, 2010 as previously stated by the Company.
Response to Monsanto Rebuttal Data Request 1.7
Please refer to Confdential Attchment Monsanto Rebutt 1.7 for the
documentation supporting the commercial online date.
This confdential information is provided subject to the ters and conditions of
the protective agreeement in ths proceedg.
Recordholder:
Sponsor:
Chad Teply
Chad Teply
.
.
.P AC-E-1 0-07/Rocky Mountan Power
November 24,2010
Monsanto Rebutt Data Request 1.8
Monsanto Rebuttal Data Request 1.8
Please provide all operatig ageements and other documents, which support Dr.
Shu's testimony on Bear River opetional constrts.
Response to Monsanto Rebuttal Data Request 1.8
Please refer to Attchment Monsanto Rebutt 1.8 for supporting documents.
Recordholder:
Sponsor:
Connely Baldwi
Hui Shu
.
.
.P AC-E- 1 0-07/Rocky Mounta Power
November 24,2010
Monsanto Rebutt Data Request 1.9
Monsanto Rebuttal Data Request 1.9
Please verify and provide documentation of the latest expected in-service date for
the Gateway Central transmission project.
Response to Monsanto Rebuttal Data Request 1.9
SegmentB-
. The first section, connectig the Ben Lomond and Termina substations, was
put into service for customers in March 2010.
. The second section, connecting the Populus and Ben Lomond substations, was
put into service for customers in November 2010.
SegmentC-
. The Mona to Oquirh constrction schedule begins in 2011 and the estimated
in-service date for cusomers is June 2013.
. The Oquirrh to Termnal constrction schedule begins in 201 1 and the
estimated in-service date for customers is June 2014.
.For more information about Energy Gateway please refer to the followig lin:
htt://ww.pacificorp.com/trantp/eg.html
Recordholder:
Sponsor:
Sarah Edmonds
Darell Gerrard
.