20101126PAC to Monsanto Reb 2 (1-11).pdf

~~t~OUNTAIN
November 24,2010
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Randal C. Budge
RACIN, OLSON, NYE, BUDGE &
BAILEY, CHATERED
P.O. Box 1391; 201 E. Center
Pocatello, Idao 83204- 1 391
RE: ID PAC-E-I0-07
Monsanto Rebutt 2nd Set Data Request (1-11)
Please fid enclosed Rocky Mounta Power's responses to Monsanto Rebuttl 2nd Set Data
Requests 2.1-2.11. Provided on the enclosed CD is Attchment Monsanto Rebutt 2.2.
Provided on the enclosed Confdential CD ar Confdential Atthments Monsto Rebutt
2.11 c and 2.1. Confdential Atthment Monsanto Rebutt 2.1 is being provided to the
requesting par only because the inormation is propneta. The Confdential Attchments are
Confdential and are provided to pares that have signed a protective order in this docket.
If you have any questions, please feel free to call me at [phone].
Sincerely,
0l'-d tvø:~ ~
J. Ted Weston
Maer, Reguation
Enclosure:
cc: Jean Jewell/UC (C)/ 3 copies
Eric OlsenlPA (C)
Ben Oto/ICL (C)
. James R. Smithonsanto (C)
Richad Andersn/onsanto (C)
George C. Carer, III/Monsanto (C)
Denns Peseau/onsato (C)
Gath R. Kajander/Monsto (C)
Maurce BrubakerlMonsanto (C)
Brian Collinonsanto (C)
Michael Gormonsanto (C)
Kath Iversn/onsanto (C)
Mark Widmer/Monsanto (C)
P AC-E-1 0-07/Rocky Mountain Power
November 24, 201 0
Monsanto Rebutt Data Request 2.1
Monsanto Rebuttal Data Request 2.1
Re: Rebuttal of Mr. Richard Walje: At page 6, Mr. Walje cites the $30.64 per
MWH curently paid by Monsanto for non-fi serice. Pleae provide how
much Magcorp presently pays for non-fi service, and RM's best estmate of
what Magcorp will pay in 2011,2012,2013 and 2014.
Response to Monsanto Rebuttal Data Request 2.1
Please refer to Confdential Attchment Monsato Rebuttl 2.1. Ths inormation
is confdential and propneta and is provided subject to the term and conditions
of the protective agement in ths proceeding. Because the inormtion is
propneta, it is being provided to the requesting par only.
Recordholder:
Sponsor:
Wiliam R. Gnffth
Wiliam R. Gnffth
P AC-E-1 0-07/Rocky Mounta Power
November 24, 2010
Monsanto Rebutt Data Request 2.2
Monsanto Rebuttal Data Request 2.2
Re: Rebutt of Mr. Richard Walje: Pleae provide the supportin workpapers
used in denvig the average pnce to ultiate customers shown on the map on
page 8. Please explai whether these average pnces reflect only indusal sales,
or all customers.
Response to Monsanto Rebuttal Data Request 2.2
SNL Energy Financial Focus published the map shown on page 8. The source
document is provided as Attchment Monsto Rebutt 2.2. Figus indicated on
the map represent the average pnce to ultimate customers.
Recordholder:
Sponsor:
Crag Johnon
Craig Johnson
P AC-E-1 0-07/Rocky Mounta Power
November 24, 2010
Monsanto Rebutt Data Request 2.3
Monsanto Rebuttal Data Request 2.3
Re: Rebutt of Mr. Richard Walje: Please explai the relevancy of the pnces
shown on the graphic on page 8 as it relates to RM's provision of non-fi
service to an industnal customer served at trsmission servce voltage.
Response to Monsanto Rebuttal Data Request 2.3
The map indicates the pnce of electncity in Idao is among the very lowest in the
nation. Non-firm servce to an industnal customer is even lower th the pnce to
the average residential, commercial, or indusal cusomer. The relevant point is
tht the pnce of electncity to Monsanto is lower than any other customer in Idaho.
Idaho ha some of the lowest pnces in the nation. Furer, Rocky Mountan
Power provides its Idao customers some of the lowest priced electncity in the
world and prices tht are parcularly low compared to China.
Recordholder:
Sponsor:
Craig Johnson
Craig Johnson
P AC-E-1 0-07/Rocky Mounta Power
November 24, 2010
Monsanto Rebutt Data Request 2.4
Monsanto Rebuttal Data Request 2.4
Re: Rebuttal of Mr. Richard Walje: At page 10, Mr. Walje sttes "Monsanto
receives exactly the same servce as any other customer on the Company's
system." Please fully explain how all other customers experience hundrds of
hour of interrption of servce exactly as Monsanto does?
Response to Monsanto Rebuttal Data Request 2.4
Monsanto receives the same servce as any other cusomer on the Company's
system. However, Monsanto's contract allows the Company to curl tht
servce under cert terms and conditions tht are set fort in the retal special
contract.
Recordholder:
Sponsor:
Paul Clements
A. Richad Walje
P AC-E-1 0-07/Rocky Mounta Power
November 24, 2010
Monsanto Rebuttl Data Request 2.5
Monsanto Rebuttal Data Request 2.5
Re: Rebuttl of Mr. Richad Walje: At page 12, Mr. Walje believes that
Monsto wants to receive electnc servce at well below market pnce. Please
fuly explain what Mr. Walje means by "market pnce". Does Rocky Mounta
Power sell at "market price" to all its customers? If so, please provide all
supporting documentation that all Idaho customers served by RM are provided
electnc service at "market price".
Response to Monsanto Rebuttal Data Request 2.5
Mr. Walje means it appeas Monsanto desires to receive electrc service at a price
below the Company's cost to provide such service. Rocky Mounta sells power
to its customers at Commssion-approved taff raes, which are intended to reflect
the Company's costs to provide such serice.
Recordholder:
Sponsor:
Paul Clements
A. Richard Walje
P AC-E-1 0-07/Rocky Mountain Power
November 24,2010
Monsanto Rebutt Data Request 2.6
Monsanto Rebuttal Data Request 2.6
Re: Rebuttl of Mr. Richad Walje: At page 12, Mr. Walje says the Company ha
been working for over 20 yeas to bring Monsanto to ful cost of service.
a. Is the Company now claiming that Monsanto did not pay its ful cost of
service in the Power Supply Agreement dated November 1, 1995? If so,
please provide all documentation showig how RM (or its predecessor)
attempted to brig Monsanto to its ful cost of service durg tht contractu
period.
b. Is the Company now claiming tht Monsanto did not pay its full cost of
serice for rates in effect 2004 thoug 2006? If so, plea provide all
documentation showing how RMP (or its predecessor) attempted to brig
Monsanto to its ful cost of service.
Response to Monsanto Rebuttal Data Request 2.6
a. The Company files cost of servce studies in conjunction with genera rate
case fiings. The Company also performs cost of service stes when
enterig into contrct negotiatons with Monsto. The Company ha actively
sought durng contract negotiatons with Monsanto to align Monsanto's
contrt rates with the Company's calculated cost of servce for Monsanto.
b. The Company files cost of servce studies in conjunction with genera rate
case fiings. The Company also performs cost of servce studies when
enterg into contrct negotiations with Monsanto. The Company ha actively
sought durg contract negotiations with Monsanto to align Monsanto's
contrt rates with the Company's calculated cost of serice for Monsanto.
Recordholder:
Sponsor:
Pau Clements
A. Richard Walje
P AC-E-1 0-07/Rocky Mountai Power
November 24,2010
Monsanto Rebutt Data Request 2.7
Monsanto Rebuttal Data Request 2.7
Re: Rebuttl of Mr. Richard Walje: At page 12, Mr. Walje says the Company
ha been workig for over 20 yeas to brig Monsanto to fu cost of service. If
the Company settles a contested rate case in Idao for less tha it originally filed,
does ths mean that the Company clai tht none of its customers are paying ful
cost of servce? Please fully explai your answer.
Response to Monsanto Rebuttl Data Request 2.7
No, it would depend where the stipulated revenues would bring each customer
class compared to that class' cost of servce.
Recordholder:
Sponsor:
Steve McDougal
Steve McDougal
PAC-E-1O-07/Rocky Mounta Power
November 24, 2010
Monsant9 Rebutt Data Request 2.8
Monsanto Rebuttal Data Request 2.8
Rebuttl of Mr. Richard Walje: At page 12, Mr. Walje references Order 30783.
Please provide the exact cite in the Order of Mr. Walje's statement regarding
Monsanto paying 87 percent of its cost of service.
Response to Monsanto Rebuttal Data Request 2.8
Page 12 lines 20 though 22 of Mr. Walje's testony states that the results of the
2008 general rate case "indicated" that even afer Monsanto's 13.5 percent
increae effective Janua 1,2008, Monsanto was only at 87 percent of their cost
of service.
Recordholder:
Sponsor:
Steve McDougal
Steve McDougal
PAC-E-10-07/Rocky Mountai Power
November 24, 2010
Monsanto Rebuttl Data Request 2.9
Monsanto Rebuttal Data Request 2.9
Re: Rebuttl of Mr. Richard Walje: Please confrm or deny tht the Companis
2008 general rate cae was filed durng a time when Monsato had a thee-year
contract with the Company.
Response to Monsanto Rebuttal Data Request 2.9
Confrmed. Ths is why on page 3 of Mr. Walje's direct testony he explaied
that while the Company's analysis indicated an overall increase of $16.3 millon
was needed it was only requesting $5.9 millon.
Recordholder:
Sponsor:
A. Richard Walje
A. Richard Walje
P AC-E-1 0-07/Rocky Mountan Power
November 24,2010
Monsanto Rebutt Data Request 2.10
Monsanto Rebuttl Data Request 2.10
Re: Rebutt of Mr. McDougal, page 43. Would Mr. McDougal agree that Ms.
Iverson removed only the revenues associated with Monsanto's interrptible credit
in her non-firm analysis? If Mr. McDougal does not agree, then please explicitly
state what revenues he believes Ms. Iverson removed from her analysis, and what
revenues should have been removed.
Response to Monsanto Rebuttal Data Request 2.10
Ms. Iverson removed revenue derived from the non-fu interrptible credit.
However, she removed 170 MW of Monsanto demand from jursdictiona load,
and only removed a portion of the revenues. Using her approach, she should have
removed all of the non-firm kW revenues. In addition, the Company believes that
under her scenaio, she should have also removed non-fir energy sales revenues.
Recordholder:
Sponsor:
Steve McDougal
Steve McDougal
P AC-E-1 0-07 /Rocky Mountan Power
November 24,2010
Monsanto Rebutt Data Request 2.11
Monsanto Rebuttal Data Request 2.11
Re: Rebutt of Mr. McDougal, page 49. Mr. McDougal states at line 26 that the
retail revenue is calculated as if there is no interrption and is diect assigned to
Idaho.
a. Please identify the amount of revenue included in the Company's filing for
Monsanto.
b. Does this amount of revenue assume that all of Monsanto is served at fi
rates? Please fuly explain your answer.
c. Of the revenues identified in (a), how much of ths is related to demand
chages not paid (that is, credited) to Monsanto. Please fuly explain your
answer.
Response to Monsanto Rebuttal Data Request 2.11
a. The amount of revenue included in the Company's filing for Monsato is
$59.5 millon.
b. Yes.
c. Pleas refer to Confdential Atthment Monsato Rebutt2.11c. Ths
inormtion is confdential and is provided subject to the term and conditions
of the protective agrement in ths case.
Recordholder:
Sponsor:
Steve McDougal
Steve McDougal