20101209Monsanto 17 (1-21) to PAC.pdf

Mrs. Jean Jewell, Secretar
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
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, II.
Dear Jean:
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
BOISE OFFICE
lOt SOUTH CAPITOL
BOULEVARD. SUITE 208
BOISE. IDAHO 83702
TELEPHONE: [phone]FACSIMILE: (208) 433w0167
TELEPHONE [phone]
FACSIMILE [phone] IDAHO FALLS OFFICE
477 SHOUP AVENUESUITE 107
POST OFFICE BOX 50698IDAHO FALLS, ID 83405
TELEPHONE: [phone]
FACSIMILE: [phone]
ww.racinelaw.net
ALL OFFICES TOLL FREE
[phone]
SENDER'S E-MAIL ADDRESS:rcb\.racinelaw.net
LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON. OF COUNSEL
December 6,2010 ~..=o~
iU'
:::i
r:N(T
Re: PAC-E-IO-07
Enclosed for fiing in the captioned matter please find the original and three copies of
Monsanto Company's Seventeenth Data Requests to Rocky Mountain Power. Than you for your
assistance.
RCB:rr
Enclosures
cc: Service List (via email)
Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
rcb(cracinelaw.net
,REC \.! n
¿"'1'1I1l DL!' Q"IJ JLl. -J IJJî 8: 26
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE APPLICA nON OF )
ROCKY MOUNTAIN POWER FOR APPROVAL)
OF CHANGES TO ITS ELECTRIC SERVICE )
SCHEDULES AND A PRICE INCREASE OF )
$27.7 MILLION, OR APPROXIMATELY )13.7 PERCENT )
)
Case No. PAC-E-io-07
MONSANO COMPAN'S SEVENTENT DATA REQUESTS
TO ROCKY MOIlNAI POWER
MONSANTO COMPANY, by and through their attorneys, hereby submits this
Seventeenth Data Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public
Utility Commissiqn's Rules of Procedure, IDAPA 31.01.01, as follows:
Monsanto 17-1: Re: page 18 ofMr. Clements' September 30,2010 testimony. For the values
presented in the table for Value of Operating Reserve Credit:
a. Are the monetar amounts listed for Customer # 1 and Customer #2
confidential?
b. Please provide the contracts which support the monetar amounts shown
of$4.16, $4.25 and $4.01 per kW-month. Also, if
any workpapers were
generated in determining these moneta amounts, please provide in
electronic format with all formula and input.
MONSANO'S SEVENTENTH DATA REQUESTS TO ROCK MOUNTAI POWER - i
c. For the Company models used in justifying these credits, please provide
the names of the units which were marginal for the development of the
credit, along with their assumed natural gas prices, heat rates, variable
O&M costs and the assumed market prices used in the developing any
spark spread as referenced on page 19.
Monsanto 17-2: For all GRID model results relied upon by Mr. Clements in his September 30,
2010 testimony:
a. Please provide the date these GRID model rus were completed and
provided to Mr. Clements.
b. Please provide the name of the person responsible for performing these
GRID model rus.
Monsanto 17-3: Monsanto has received the Confidential Attachment to Monsanto Data
Request No. 5.9, but has not received a wrtten response. Please provide the
wrtten response.
Monsanto 17-4: Re: RMP Response to Monsanto Data Request 5.6, System Capacity Loads
and Resources of the 2008 IRP, page 91. The response states that "Monsanto's
contribution to the forecasted coincident peak canot be identified." Please
provide all jurisdictional workpapers used in developing the jursdictional
forecast and explain how the forecast process recognzes and quantifes the
Monsanto load for puroses of the IRP.
Monsanto 17-5: Re: RMP Response to Monsanto Rebutt Data Request 4.6. Please explain in
more detail what RMP means by the term "proxy" when it states that the
Company includes Monsanto's firm load and firm interrptible products as a
"proxy" for capacity planng puroses. A proxy usualy implies a
substitution. To what is Monsanto being "substituted" to for as a "proxy."
Monsanto 17-6: Re: RMP Response to Monsanto Rebuttal Data Request 4.6. Please explain
in more detail what RMP means by "relative resource economic value." What
resources are "relative" to each other? Is this relativity as to cost, size, or
other measurement criteria? Please fuly explain your response.
Monsanto 17-7: With respect to the response to Monsanto 16.1, please provide all testimony
fied by the Company (and its predecessors) regarding Monsanto's cost of
service as well as the value of Monsanto's interrptible load since 1951.
Monsanto 17-8: Please provide all testimony filed by Mr. Clements in all jursdictions on
behalf ofPacifiCorp.
MONSANO'S SEVENTEENTH DATA REQUESTS TO ROCKY MOUNAIN POWER - 2
Monsanto 17-9: With respect to the response to Monsanto 16.3, please provide the following
information:
a. Why does the Company treat Monsanto's entire load as firm?
b. Is it Mr. Clements' position that constrcting or purchasing resources to
serve Monsanto's entire load is the least cost means of planning the
Company's system? Please explain.
c. Is it Mr. Clements' position that constructing or purchasing resources to
serve Monsanto's entire load is a prudent means of planing the
Company's system? Please explain.
d. Has the Company (and its predecessors) always constrcted or contracted
for generating plant to meet the interrptible demand of its customers?
Please explain.
Monsanto 17-10: With respect to the response to Monsanto 16.6, Mr. Clements states in
response that "The Front Offce and GRID models calculate the cost of
replacing the interrptible products Monsanto provides with products
provided from other sources, namely existing Company resources or market
purchases." Please provide the following information:
a. Does the cost calculated by the models include any costs for capacity? If
yes, please identify and quatify the costs of capacity. If no, please
explain why not.
b. Does the cost calculated by the models include only the costs of energy?
Please explain your response.
c. Do the models include the installed capacity costs ofthe Company's
existing resources (both owned and contracted) when calculating the cost
of replacing the interrptible products that Monsanto provides? Please
explain.
d. Do the products provided from other sources mentioned in the response
provide capacity to the Company? Please explain.
Monsanto 17-11: With respect to the response to Monsanto 16.10, Mr. Clements states the
following in the last line of the response: "Please note the terms and
conditions are different among curailment products so the evaluation for any
one product is not applicable to Monsanto." Please explain how Monsanto's
curilment product terms and conditions differ from the terms and conditions
of other curailment products used by the Company.
MONSANTO'S SEVENTENTH DATA REQUESTS TO ROCK MOUNAIN POWER - 3
Monsanto 17-12: With respect to Mr. Clements' testimony at pA, lines 20-21, is it Mr.
Clements' position that Monsanto sells power to the Company?
Monsanto 17-13: With respect to Mr. Clements' testimony at p. 13, line 22, please provide the
June 30, 2010 official forward price cure.
Monsanto 17-14: At p. 26, lines 8-12 of Mr. Clements' testimony, Mr. Clements states that the
value of a three-year strip of energy at Palo Verde has decreased by 31 percent
since the last Monsanto contract was negotiated. Please provide the following
information:
a. Identify how much the Company's actual net power costs have increased
durng the same time period.
b. Identify how much a three-year strip of energy at Mona has increased
during the same time period.
Monsanto 17-15: At p. 26, lines 5-6, what is the basis for Mr. Clements' statement that the
Monsanto contract was negotiated in June 2007?
Monsanto 17-16: Does Mr. Clements agree that under the curent Monsanto contract, Monsanto
can be interrpted in the amount of 162 MW for 12 hours due to voltage
related system integrty interrptions? If no, please explain.
Monsanto 17-17: Does Mr. Clements agree that under the curent Monsanto contract, the
Company controls the interrption of Monsanto's load? Ifno, please explain.
Monsanto 17-18: Has Mr. Clements provided any input or comments utilized by the Company
in its IRP process? If so, please cite each instance and identify the IRP
document for which Mr. Clements' provided input or comments which were
utilized by the Company.
Monsanto 17-19: At, page 20, lines 9-11, Mr. Clements states that a combustion tubine is
available to customers for their benefit 8,410 hours year assuming a 96%
availability. Please provide the following information:
a. Does the Company nominate gas on a daily basis for each day of the year
for its combustion turbines?
b. How many days of the year would the Company have to nominate gas for
a combustion turbine in order for it to be available for 8,410 hours?
c. What costs would the Company incur to nominate natual gas for a
combustion tubine for a day? Please explain.
MONSATO'S SEVENTEENT DATA REQUESTS TO ROCKY MOUNTAIN POWER - 4
d. Would the Company be responsible for any costs to nominate natural gas
for a combustion tubine for a day even if the combustion turbine did not
operate on that day? Please explain.
e. Can a combustion turbine operate and serve load on a day in which the
Company has not nominated natural gas for the turbine? Please explain.
Monsanto 17-20: With respect to Mr. Duvall's rebuttal testimony at page 2, lines 19-22 and
page 3, lines 1-13, please identify all persons responsible for the planing
assumption change related to Monsanto's interrptible load.
Monsanto 17-21: Please provide a copy ofPacifiCorp's application and all testimony fied in
Case No. UPL-E-92-02.
DATED this 6th day of December, 2010.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By_~M~-~
RANDALL C. BUDGE
MONSANO'S SEVENTENT DATA REQUESTS TO ROCKY MOUNAI POWER - 5
CERTIFICATE OF MALING
I HEREBY CERTIFY that on this7th day of December, 2010, I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretary (original and 3)
Idaho Public Utilties Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail: jjewell(Ðpuc.state.id.us U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: ted.westonØ)pacificorp.com E-Mail
Paul J. Hickey
Hickey & Evans, LLP
1800 CareyAve., Ste 700
PO Box 467
Cheyenne, WY 82003
E-mail: phickeyØ)hickeyvans.com E-Mail
Mark C. Moench
Daniel Solander
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, Utah 84111
E-mail: mark.moenchØ)pacificorp.com
daniel.solanderØ)pacificorp.com
E-Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
E-mail: datarequestØ)pacificorp.com
E-Mail
Scott Woodbury
Deputy Attorney General
Idaho Public Utilties Commission
P. O. Box 83720
Boise, Idaho 83720-0074
E-mail: scott.woodburyØ)puc.idaho.gov
E-Mail
MONSANO'S SEVENTEENTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 6
Katie Iverson
Brubaker & Associates
17244 W. Cordova Court
Surprise, Arizona 85387
E-mail: kiverson(ßconsultbai.com
E-Mail
James R. Smith
Monsanto Company
P. O. Box 816
Soda Springs, Idaho 83276
E-mail: jim.r.smith(ßmonsanto.com
E-Mail
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
P.O. Box 1391
Pocatello, Idaho 83204-1391
E-mail: elo(ßracinelaw.net
E-Mail
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
E-mail: tony(ßyankeL.net
E-Mail
Tim Buller
Jason Haris
Agrium, Inc.
3010 Conda Road
Soda Springs, Idaho 83276
E-mail: tbuller(ßagrium.com
jaharris(ßagrium.com
E-mail
Benjamin J. Otto
Idaho Conservation League
P. O. Box 844
Boise, Idaho 83702
E-mail: botto(ßidahoconservation.org
E-Mail
Melinda J. Davison
Davison Van Cleve, P.C.
333 SW Taylor, Suite 400
Portland, Oregon 97204
E-mail: mjd(ßdvclaw.com
E-Mail
Ronald L. Wiliams
Willams Bradbury, P.C.
1015 W. Hays Street
Boise, Idaho 83702
E-mail: ron(ßwillamsbradbury.com
E-Mail
MONSANO'S SEVENTEENT DATA REQUESTS TO ROC MOUNAIN POWER-7
9210/187585
Brad M. Purdy
Attorney at Law
2019 N. 17tl Street
Boise, Idaho 83702
E-mail: bmpurdy(ihotmail.com
E-Mail
èJo~~
MONSANO'S SEVENTEENm DATA REQUESTS TO ROCKY MOUNTAIN POWER - 8