20101213Monsanto 18 (1-22) to PAC.pdf

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]
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Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION 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-I0-07
MONSANTO COMPANY'S EIGHTEENTH DATA REQUESTS
TO ROCKY MOUNTAIN POWER
MONSANTO COMPANY, by and through their attorneys, hereby submits this
Eighteenth Data Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public
Utilty Commission's Rules of Procedure, IDAPA 31.01.01, as follows:
Monsanto 18-1: Page 24, line 16 of Mr. Clements' Supplemental Testimony. The witness
recommends a total credit for the three products of $6.1 millon in 2011.
Please provide this credit on a $ per kW-month basis for puroses of
establishing an interrptible demand charge. Please provide all calculations
showing the derivation of the proposed interrptible demand charge.
Monsanto 18-2: Please provide the revenue impact to Monsanto if the Company's requestedincrease to firm rates is accepted along with the Company's proposed credit of
$6.1 milion. Please provide all workpapers supporting the revenue impact
showing the anual impact on both a dollar basis, and on a percentage basis.
Monsanto 18-3: Follow-up to Confidential Response to Monsanto Rebuttal Data Request 2.1.
Please provide the supporting calculations showing the 2011 price paid by the
MONSANTO'S EIGHTEENTH DATA REQUESTS TO ROCKY MOUNTAIN POWER _ 1
interrptible customer. Does this price reflect the Operating Reserve Credit
shown on page 18 of Mr. Clements' Supplemental Testimony? If so, please
identify and quantify the Operating Reserve Credit that was reflected in the
price shown in the Confidential Response to Monsanto Rebuttal Data Request
2.1. If not, please show the overall price paid which reflects the inclusion of
the Operating Reserve Credit.
Monsanto 18-4: For the Interrptible Customer #1 shown on page 18 of
Mr. Clements'
Supplemental Testimony:
a. Please provide the Rate Case Percentage Changes and Effective Dates
used in adjusting the 2009 rates for 2010 and 2011. Please provide all
supporting workpapers used in developing the rates for 2010 and 2011.
b. Does this customer receive both an Operating Reserve Credit as shown on
the table, plus an economic curailment credit? Please fully explain your
response.
c. What was the overall net price paid by Interrptible Customer #1 in 2010
for electric service with all so-called curailment products included
(whatever they may be labeled)? Please provide all supporting
workpapers showing the calculation of this price.
d. What is the overall net price paid by Interrptible Customer # 1 in 2011 for
electric service with all so-called curtailment products included (whatever
they may be labeled)? Please provide all supporting workpapers showing
the calculation of this price.
Monsanto 18-5: With respect to Mr. Clements' Supplemental Testimony at page 20, lines
13-14 and page 21, lines 1-5, please provide the following information:
a. Please provide by year the actual number of hours of load- following
service each Company owned or contracted combustion turbine provided
the Company for the period 2007 through 2010 to date.
b. Please provide by year the actua number of hours of spinning reserveservice each Company owned or contracted combustion turbine provided
the Company for the period 2007 through 2010 to date.
c. Please provide by year the actual number of hours of regulating reserve
service each Company owned or contracted combustion turbine provided
the Company for the period 2007 through 2010 to date.
Monsanto 18-6: For each Company owned or contracted combustion turbine, please provide
by year the actual number of turbine stars for the period 2007 through 2010 to
date.
MONSANTO'S EIGHTEENTH DATA REQUESTS TO ROCKY MOUNTAIN POWER _ 2
Monsanto 18-7: For each Company owned or contracted combustion turbine, please provide
by year the number of attempted turbine stars for the period 2007 through
2010 to date.
Monsanto 18-8: For each Company owned or contracted combustion turbine, please provide
by year the actual number of failed tubine stars for the period 2007 through
2010 to date.
Monsanto 18-9: For each Company owned or contracted combustion turbine, please provide
the unt's ramp rate.
Monsanto 18-10: For each Company owned or contracted combustion turbine, please provide
by year the actual number of days for which natural gas was nominated for
each turbine for the period 2007 through 2010 to date.
Monsanto 18-11: Page 8, line 15 of Mr. Clements' Supplemental Testimony. Please confirm or
deny that the "cost incured to generate that megawatt" represents only the
runing cost, and no capacity cost. If denied, please explain in detail how the
capacity cost is included in the "opportunity cost."
Monsanto 18-12: Please provide all testimony sponsored by the Company in the last ten years in
each of its jurisdictions that references the "indifference principle. "
Monsanto 18-13: Page 11, line 18 of Mr. Clements' Supplemental Testimony. Please provide
all support for the statement that the "probabilty of a double contingency
event occuring is equal for all hours of the year." In the response, provide
the basis for Mr. Clements' statement, as well as identify all Company
personnel with whom Mr. Clements consulted to form his conclusion.
Monsanto 18-14: Please provide the language used in the 2003 Contract with Monsanto as to
System Integrity and the definition used. If this language is different than the
curent contract language, please explain when this language was changed and
upon what basis and upon which pary's insistence. Was Monsanto informed
that any change in the language of the System Integrity section would be used
by the Company as basis for claiming that "it would not be reasonable to
assume that a double contingency would occur at the time of the Company's
system coincident peak for planing purposes" (see the Rebuttal Testimony of
Gregory Duvall at p. 3 lines 18-20)? If so, please state when Monsanto was
informed of this change prior to the signing of the contract.
Monsanto 18-15: Page 3, lines 18-20 of Gregory Duvall's Rebuttal Testimony. Please provide
all support for Mr. Duvall's statement that "it would not be reasonable to
assume that a double contingency would occur at the time of the Company's
system coincident peak for planing purposes." In the response, provide the
basis for Mr. Duvalls statement, as well as identify all Company personnel
with whom Mr. Duvall consulted to form his conclusion.
MONSANTO'S EIGHTEENTH DATA REQUESTS TO ROCKY MOUNTAIN POWER _ 3
Monsanto 18-16: Please confirm or deny that PacifiCorp may request System Integrity
Interrptions of up to 162 MW if the System Integrity Interrption is voltage
related. If denied, please fully explain your response.
Monsanto 18-17: Page 13 of Mr. Clements' Supplemental Testimony. At line 3, Mr. Clements
states, "For example, one model... ". To which model is Mr. Clements
referring here in his example, the GRID model, the Front Office Model, or
some other model? Please fully explain your response.
Monsanto 18-18: Page 13 of Mr. Clements' Supplemental Testimony. At line 7, Mr. Clements
states, "A second model... ". To which model is Mr. Clements referring here
in his example, the GRID model, the Front Offce Model, or some other
model? Please fully explain your response.
Monsanto 18-19: Page 15 of Mr. Clements' Supplemental Testimony. At line 12, Mr. Clements
states "This represents what the Company would be wiling to pay on behalf
of customers for the next megawatt of operating reserves if it needed to
acquire additional operating reserves."
a. Please confirm or deny that both Lakeside and Gadsby are used in the
Company's Front Office Model for valuing operating reserves. If denied,
please fully explain your response.
b. For the Front Office and GRID model results shown at the top of page 15,please explain what these values would be on a cost per megawatt basis,
and provide the calculations.
c. Please provide the cost per megawatt Rocky Mountain Power has incurred
on behalf of customers to acquire Lakeside and Gadsby.
Monsanto 18-20: Please reconcile the following two statements of Mr. Clements with the results
of his two models shown at the top of page 15 which indicate the GRID model
values are consistently equal or lower than the Front Office values:
Front Offce Model: "This model determines. .. the most economic or least
cost means by which the Company can provide operating reserves" (page 15,
lines 6-8, emphasis added)
GRID Model: "This value represents the value of the highest cost, or most
expensive, operating reserves that would no longer be required if Monsanto's
operating reserve product is available instead." (page 16, lines 1 0-12,
emphasis added).
Why are the GRID Model results lower if the model supposedly represents the
"most expensive" operating reserves no longer required?
MONSANTO'S EIGHTEENTH DATA REQUESTS TO ROCKY MOUNAIN POWER _ 4
Monsanto 18-21: At page 17 of Mr. Clements' Supplemental Testimony, he discusses two
contracts with large industrial customers for non-spinning operating reserves.
Monsanto requested copies of those contracts in its First Set of discovery to
Rocky Mountain Powerin 1-27 and 1-30.
a. For the contract executed in late 2006, please indicate where in the
provided contract the credit for non-spinning operating reserves is
discussed. If not referenced in the contract provided to Monsanto, please:
(1) provide the contract which does discuss non-spinning operating
reserves provided by the large industrial customer; (2) indicate why ths
contract was not provided when initially requested by Monsanto and
(3) explain the source of the curailment credit shown on page 8 of
Confdential Attachment 1.27.
b. For the contract executed in late 2006, provide all workpapers and
calculations used in developing the $4. 16/kW month initially set and the
$4.25/kW month average for 2007-2010.
Monsanto 18-22: At page 22 of Mr. Clements' Supplemental Testimony, lines 12 - 15, he states
that "The Company uses the GRID model to determine net power costs in this
rate case. Since Monsanto's interrptible credit is included as a component of
net power costs, it is logical to use the same model to determine value of the
interrptible products provided by Monsanto."
a. Please confirm or deny that Rocky Mountain Power includes its own
generation resources as a "component of net power costs." If denied,
please fully explain your response.
b. If Rocky Mountain Power's own generation resources are included as a
component of net power costs, why are capital costs of those resources
included in rate base? Please fully explain your response.
c. Please confirm or deny that the GRID model is strictly energy based in
that it measures the difference in system net power costs with and without
Monsanto. If denied, please fully explain your response.
d. Please confrm or deny that the GRID model does not include any cost
reductions associated with capacity resource deferrals. If denied, please
fully explain your response.
MONSANTO'S EIGHTEENTH DATA REQUESTS TO ROCKY MOUNTAIN POWER _ 5
DATED this 10th day of December, 2010.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
BY-~PuR RAND
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 10th 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 Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail: liewell~puc.state.id.us U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 8411 i
E-mail: ted.weston~pacificorp.com E-Mail
Paul J. Hickey
Hickey & Evans, LLP
1800 CareyA ve., Ste 700
PO Box 467
Cheyenne, WY 82003
E-mail: phickey~hickeyvans.com E-Mail
MONSANTO'S EIGHTEENTH DATA REQUESTS TO ROCKY MOUNTAIN POWER _ 6
Mark C. Moench
Daniel Solander
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, Utah 84111
E-mail: mark.moench~pacificorp.com
daniel.solander~pacificorp.com
E-Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
E-mail: datarequest~pacificorp.com
E-Mail
Scott Woodbury
Deputy Attorney General
Idaho Public Utilties Commission
P. O. Box 83720
Boise, Idaho 83720-0074
E-mail: scott. woodbury~puc.idaho.gov
E-Mail
Katie Iverson
Brubaker & Associates
17244 W. Cordova Court
Surprise, Arizona 85387
E-mail: kiverson~consultbai.com
E-Mail
James R. Smith
Monsanto Company
P. O. Box 816
Soda Springs, Idaho 83276
E-mail: jim.r.smith~monsanto.com
E-Mail
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
P.O. Box 1391
Pocatello, Idaho 83204-1391
E-mail: elo~racinelaw.net
E-Mail
Anthony Yanke i
29814 Lake Road
Bay Vilage, Ohio 44140
E-mail: tonyrgyankeL.net
E-Mail
Tim Buller
Jason Haris
Agrium, Inc.
3010 Conda Road
MONSANTO'S EIGHTEENTH DATA REQUESTS TO ROCKY MOUNTAIN POWER _ 7
9210/187585
Soda Springs, Idaho 83276
E-mail: tbuller~agrium.com
jaharris~agrium.com
E-mail
Benjamin J. Oto
Idaho Conservation League
P. O. Box 844
Boise, Idaho 83702
E-mail: botto~idahoconservation.org
E-Mail
Melinda J. Davison
Davison Van Cleve, P.C.
333 SW Taylor, Suite 400
Portland, Oregon 97204
E-mail: mjd~dvclaw.com
E-Mail
Ronald L. Wiliams
Wiliams Bradbury, P.C.
1015 W. Hays Street
Boise, Idaho 83702
E-mail: ron~wiliamsbradbury.com
E-Mail
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
E-mail: bmpurdy~hotmaiL.com
E-Mail
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MONSANTO'S EIGHTEENTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 8