20101130PAC to Monsanto Reb 4 (1-8).pdf

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November 29, 2010
Radall C. Budge
RACINE, OLSON, NY, BUDGE &
BAlLEY, CHJTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
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RE: il PAC-E-1O-07
Monsanto Rebutt 4th Set Data Request (1-8)
201 South Main, Suite 2300
Salt Lake Cit, Utah 84111
Please find enclosed Rocky Mountan Power's responses to Monsanto Rebuttl 4th Set Data
Requests 4.1-4.8.
If you have any questions, pleas feel free to call me at [phone].
Sincerely,
~:J- T.ed Úi~ (!~
J. Ted Weston
Manager,. Regulation
Enclosur:
cc: Jean Jewel1/UC (C)/ 3 copies
Eric OlsenlIPA (C)
Ben Ot/ICL (C)
James R. Smithonsanto (C)
Richard Anderson/onsanto (C)
George C. Carer, ITI/Monsanto (C)
Denns Peseau/onsanto (C)
Gath R. Kajander/Monsanto (C)
Maurce Brubaker/Monsanto (C)
Brian Collinonsanto (C)
Michael Gormonsanto (C)
Kath Iverson/onsanto (C)
Mark Widmer/Monsto (C)
P AC-E-l 0-07/Rocky Mounta Power
November 29,2010
Monsanto Rebutt Data Request 4.1
Monsanto Rebuttal Data Request 4.1
At page 9, is it Mr. Walje's position that Chinese manufactuers of glyphosate pay
1 i cents per kWh? Please explai. Please provide all documents tht support ths
position.
Response to Monsanto Rebuttal Data Request 4.1
No. Just as Rocky Mounta Power does not publicly reveal the price of power
paid by Monsanto and other individua customers, the cost of electrcity to
individua consumers in Chi is not publicly available. The point is that if the
price of electrcity to even some indusal customers in Chia is 11 cents per
kilowatt-hour, it is unikely tht Chinese manufacturers of glyphosate pay less for
electrcity th Monsanto's Soda Sprigs operation. Ths suggests Chiese
maufactuers have no competitive advantage through lower priced electrcity.
Recordholder:
Sponsor:
A. Richad Walje
A. Richard Walje
,
PAC-E-1O-07/Rocky Mountan Power
November 29,2010
Monsanto Rebuttal Data Request 4.2
Monsanto Rebuttl Data Request 4.2
Is it Mr. Walje's position tht Monsanto's Soda Springs facilty has received firm
electrc servce since that facilty began its initial operation? Please explain.
Response to Monsanto Rebuttal Data Request 4.2
Monsanto receives the same level of servce as any other customer on the
Company's system. However, Monsanto's contrct allows the Company to
curail electrc service to Monsanto under certain terms and conditions that are set
fort in Monsanto's retail special contract.
Recordholder:
Sponsor:
Paul Clements
A. Richard Walje
PAC-E- 1 0-07/Rocky Mountain Power
November 29,2010
Monsanto Rebutt Data Request 4.3
Monsanto Rebuttal Data Request 4.3
On what date did Monsanto's Soda Springs facilty begin receiving :f electrc
servce from PacifiCorp (or its predecessors)?
Response to Monsanto Rebuttal Data Request 4.3
Monsanto ha always received :f electrc service from the Company.
Monsanto's contract includes a limited amount of interrption, allowed only
under cern terms and conditions. When that limted amount is depleted,
Monsanto's servce is equal to firm servce, Le., they will not be interrpted again.
Recordholder:
Sponsor:
Paul Clements
A. Richard Walje
PAC-E-1O-07/Rocky Mountain Power
November 29, 2010
Monsanto Rebutt Data Request 4.4
Monsanto Rebuttal Data Request 4.4
Please define "electrc service" as used in Mr. Walje's rebuttl testiony.
Response to Monsanto Rebuttal Data Request 4.4
"Electric service" means the availabilty of electrc power and energy at the
cusomer's point of delivery at the approximate voltae and for the puroses
specified in the application for electrc service, electrc service agreement or
contract, irrespective of whether electrc power and energy is actuly used.
Recordholder:
Sponsor:
Paul Clements
A. Richad Walje
P AC-E- 1O-07/Rocky Mountan Power
November 29,2010
Monsanto Rebutt Data Request 4.5
Monsanto Rebuttal Data Request 4.5
Please provide Mr. Walje's definition of firm electrc service.
Response to Monsanto Rebuttal Data Request 4.5
Please refer to the Company's response to Monsato Rebutt Data Request 4.4.
Recordholder:
Sponsor:
Paul Clements
A. Richard Walje
PAC-E-l 0-07/Rocky Mountain Power
November 29,2010
Monsanto Rebutt Data Request 4.6
Monsanto Rebuttal Data Request 4.6
Is it Mr. Duvall's position that the Company executes decisions to purchae or
consct :f resources for the PacifiCorp system based on Monsato's ful load
and not Monsanto's net load impact (where net load impact is Monsanto's:f
load mius Monsato's firm resources as those term are used by Mr. Duvall in
his rebuttl testimony)? Please explain.
Response to Monsanto Rebuttal Data Request 4.6
No, this is not Mr. Duvall's position. Whle the Company includes Monsanto's
:f load and firm interrptible products as a proxy for capacity plang
puroses, firm resource acquisition decisions are based on relative resource
economic value and need determned as par of the resource procurement process.
Recordholder:
Sponsor:
Gregory N. Duvall
Gregory N. Duvall
P AC-E- 10-07 /Rocky Mounta Power
November 29,2010
Monsanto Rebuttl Data Request 4.7
Monsanto Rebuttal Data Request 4.7
Is it Mr. Duvall's position tht Monsanto's net load impact on the PacifiCorp
system (where net load impact is Monsanto's firm load minus Monsanto's firm
resources as those terms are used by Mr. Duvall in his rebutt testimony) is not
considered for integrated resource planing puroses? Please explai.
Response to Monsanto Rebuttal Data Request 4.7
No, ths is not Mr. Duvall's position. As stted in his rebutt testiony, for IR
capacity plang puroses, Monsanto's load is treated as firm load while
interrptible products are treated as firm resources.
Recordholder:
Sponsor:
Gregory N. Duval
Gregory N. Duvall
"
PAC-E-10-07/Rocky Mountan Power
November 29,2010
Monsanto Rebutt Data Request 4.8
Monsanto Rebuttal Data Request 4.8
Is it Mr. Duvall's position that all customers' net load impact on the PacifiCorp
system (where net load impact equals :f load minus firm resources as those
terms are used by Mr. Duvall in his rebutt testimony) is not considered for
integrated resource planing puroses? Please explai.
Response to Monsanto Rebuttal Data Request 4.8
No, ths is not Mr. Duvall's position. PacifiCorp treats customer interrptible
products in a consistent maner, accounting for their :f loads and :f
interrptible products for capacity plang.
Recordholder:
Sponsor:
Gregory N. Duvall
Gregory N. Duvall