20101215PAC to Monsanto 17 (1-21).pdf

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~~R~OUNTAIN ('''r:..~.., ,!;,.
December 14,2010
201 South Main, Suite 2300
LUU) DEC i 5 prf~~~ City, Utah 84111
Radall C. Budge
RACIN, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
RE: ID PAC-E-1O-07
Monsanto 17th Set Data Request (1-21)
Please find enclosed Rocky Mountain Power's responses to Monsanto 17th Set Data Requests
17.1-17.21, excluding 17.15 and 17. 19. These responses are in process and will be provided
when available. Provided on the enclosed CD are Atthments Monsanto 17.3, 17.7, 17.8, and
17.13. Provided on the enclosed Confdential CD is Confdential Attchment Monsanto 17.1 b.
The Confdential Attachment is Confdential and is 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,
). Ttl Iv~ ~:h
J. Ted Weston
Manager, Regulation
Enclosure:
cc: Jean JewelllUC (C)/3 copies
Eric Olsen/IIPA (C)
Ben OttolICL (C)
James R. Smithonsanto (C)
Richard AndersonIonsanto (C)
George C. Carer, Ill/Monsanto (C)
Denns Peseau/onsanto (C)
Gareth R. Kajander/Monsanto (C)
Maurce Brubaker/Monsanto (C)
Brian Collns/Monsanto (C)
Michal Gormanonsanto (C)
Kath Iverson/Monsanto (C)
Mark Widmer/Monsanto (C)
4 PAC-E-10-07/Rocky Mountain Power
December 14,2010
Monsanto Data Request 17.1
Monsanto Data Request 17.1
Re: page 18 of Mr. Clements' September 30,2010 testimony. For the values
presented in the table for Value of Operatig Reserve Credit:
a. Are the moneta amounts listed for Customer # 1 and Customer #2
confidential?
b. Please provide the contracts which support the moneta amounts shown of
$4.16, $4.25 and $4.01 per kW-month. Also, if any work papers were
generated in determnig these moneta amounts, please provide in electronic
format with all formula and input.
c. For the Company models used in justifyng these credits, please provide the
names of the unts which were marginal for the development of the credit,
along with their assumed natual gas prices, heat rates, varable O&M costs
and the assumed market prices used in the developing any spark spread as
referenced on page 19.
Response to Monsanto Data Request 17.1
a. Yes
b. Please note that the dollar amounts cited in par b of ths request are
confdential. Please refer to the Company's response to Monsanto Data
Request 1.27 and Monsanto Data Request 1.30, specifically the Confdential
Attachments, for copies of the contracts requested. Please refer to
Confdential Attchment Monsanto 17.1 b for the work papers. Confdential
information is provided subject to the terms and conditions of the protective
order in this proceeding.
c. The Company considers the requested information to be of utmost commercial
sensitivity and highly confdentiaL Please contact Ted Weston at 801-220-
2963 to discuss arangements for review onsite.
Recordholder:
Sponsor:
Paul H. Clements
Paul H. Clements
P AC-E-1 0-07/Rocky Mountain Power
December 14, 2010
Monsanto Data Request 17.2
Monsanto Data Request 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.
Response to Monsanto Data Request 17.2
a. The GRID rus were completed and provided to Mr. Clements on September
17,2010.
b. The Company's net power costs group performed the rus.
Recordholder:
Sponsor:
Hui Shu
Paul H. Clements
PAC-E-10-07/Rocky Mountain Power
December 14,2010
Monsanto Data Request 17.3
Monsanto Data Request 17.3
Monsanto has received the Confdential Attachment to Monsanto Data Request
No. 5.9, but has not received a wrtten response. Please provide the wrtten
response.
Response to Monsanto Data Request 17.3
Please refer to Attchment Monsanto 17.3 for a copy of the written response to
Monsanto Data Request 5.9.
Recordholder:
Sponsor:
Paul H. Clements
Paul H. Clements
PAC-E-10-07/Rocky Mountain Power
December 14, 2010
Monsanto Data Request 17.4
Monsanto Data Request 17.4
Re: RM 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 jursdictional workpapers used in developing the jurisdictional forecast
and explain how the forecast process recognizes and quantifies the Monsanto load
for puroses of the IRP.
Response to Monsanto Data Request 17.4
Please refer to the Company's response to IPUC Data Request 215 for
jursdictional work papers and LIP A 110 for Idaho Hourly Loads for 2010.
Idaho's contrbution to the forecasted coincident peak is identified from the
hourly load forecast at the jursdictional leveL Ths forecast is also used in IRP
process. It is not broken out by customer class or by contrbution by any
customer. Please refer to the testimony of Dr. Eelkema for more details on the
hourly forecast.
Recordholder:
Sponsor:
Peter C. Eelkema
Paul H. Clements
PAC-E-10-07/Rocky Mountan Power
December 14,2010
Monsanto Data Request 17.5
Monsanto Data Request 17.5
Re: RM Response to Monsanto Rebutt Data Request 4.6. Please explai 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 plang puroses. A proxy usually implies a substitution.
To what is Monsanto being "substituted" to for as a "proxy."
Response to Monsanto Data Request 17.5
The word "proxy" is used in the IR to describe a resource that is being used in
the plang process as a placeholder for a yet-to-be-acquired resource. Please
refer to action item 3 on page 9 of the 2008 IR Update for an example of how
the word "proxy" is used in the IR.
Recordholder:
Sponsor:
Gregory N. Duvall
Paul H. Clements
PAC-E-10-07/Rocky Mountan Power
December 14, 2010
Monsanto Data Request 17.6
Monsanto Data Request 17.6
Re: RMP Response to Monsanto Rebutt Data Request 4.6. Please explain in
more detail what RM means by "relative resource economic value." Wht
resources are "relative" to each other? Is ths relativity as to cost, size, or other
measurement criteria? Please fully explain your response.
Response to Monsanto Data Request 17.6
The statement refers to the relative value among resources and does not attempt to
define anyone paricular resource as being "relative" to any other resources.
Typically, resource procurement analysis includes some measure of the present
value of revenue requirement, along with a risk and needs assessment. A
production cost model is usually employed by the Company in resource
procurement analyses in order to captue the interaction of potential new
resQurces with the Company's existing system and portfolio of loads and
resources.
Recordholder:
Sponsor:
Gregory N. Duvall
Paul H. Clements
PAC-E-10-07/Rocky Mountain Power
December 14, 2010
Monsanto Data Request 17.7
Monsanto Data Request 17.7
With respect to the response to Monsanto 16.1, please provide all testimony filed
by the Company (and its predecessors) regarding Monsanto's cost of service as
well as the value of Monsanto's interrptible load since 1951.
Response to Monsanto Data Request 17.7
The Company objects to ths request on the grounds that it is overly broad and
unduly burdensome. Without waiving ths objection, provided as Attchment
Monsanto 17.7, are copies of Company testimony related to the above subject
matter in Case Nos. PAC-E-05-01, PAC-E-07-05, and PAC-E-08-07. Prior to ths
the Company had not had a general rate case in Idaho since 1984.
Recordholder: N/ A
Sponsor: N/ A
PAC-E-10-07/Rocky Mountain Power
December 14, 2010
Monsanto Data Request 17.8
Monsanto Data Request 17.8
Please provide all testimony filed by Mr. Clements in all jursdictions on behalf of
PacifiCorp.
Response to Monsanto Data Request 17.8
Please refer to Attachment Monsanto 7.8.
Recordholder: N/ A
Sponsor: N/ A
PAC-E-I0-07/Rocky Mountain Power
December 14, 2010
. Monsanto Data Request 17.9
Monsanto Data Request 17.9
With respect to the response to Monsanto 16.3, please provide the following
information:
a.
b.
'¡ ¡
Why does the Company treat Monsanto's entire load as firm?
Is it Mr. Clements' position that constructing or purchasing
resources to serve Monsanto's entire load is the least cost means of
planing 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
planning the Company's system? Please explain.
d. Has the Company ,(fln~ its predecessors) always constructed or
contracted for generating plant to meet the interruptible demand of
its customers? Pleaseéxplain.
Response to Monsanto Data Request 17.9
a. Please refer to the Company's response to Monsanto Data Request 16.3.
b. The question is based on the incQrrect assertion that the Company does not
consider the firm availabilty of interrptible load at the time of the system
coincident peak load whenplai,in~J9r future resources. As mentioned in
Mr. Duvall's rebuttal testimony;~'the Company includes that portion of the
curailment capacity, 116 MW,~s afirm resource that contributes to its peak
capacity position and thereby treats this capacity as a proxy resource for
capacity planing puroses.
c. Please refer to the Company's response to Monsanto Data Request 17.9b
above.
d. Please refer to the Company'sresPOIist,to Monsanto Data Request 17.9babove. \, "'too', ' '.
Recordholder:
Sponsor:
Pete Waren
Paul H. Clements
j ,¡,,~.'(. ~,¡
'1
¡
PAC-E-10-07/Rocky Mountain Power
December 14,2010
Monsanto Data Request 17.10
)
Monsanto Data Request 17.10
With respect to the response to Monsanto 16.6, Mr. Clements states in response
that "The Front Office 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 quantify 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 of the
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.
Response to Monsanto Data Request 17.10
a. Both the front offce model and the GRID model use forward market prices,
which are at times at a premium to marginal operating costs of generating
assets (cost of energy) supplying the llarket. Any premium above marginal
operating costs can be considere4, animplied capacity premium. In an
efficient market, the impliedèapcÌcity 'premium would support the addition of
new capacity (when supply IS'slprt andipremiums high) or support
mothballng or retiring existingsapacity (when supply is in excess and
premiums low). Given forward markets do not differentiate implied capacity
premiums from the underlying marginal cost of supply, there is no way to
directly quantify the implied cost of capacity embedded in the forward price
curve.
'. ,;c .'n....b. Please refer to the Company's'tesponse to Monsanto Data Request 17.l0aabove. 0.f:
c. Please refer to the Company's respons,e'to Monsanto Data Request 17.1 Oa
above.
d. Please refer to the Company's response to Monsanto Data Request 17.1 Oa
above.
Recordholder:
Sponsor:
Rick Link '., i
Paul H. Clenients
, ~,;l,
~ .
P AC-E-1 0-07/Rocky Mountan Power
December 14,2010
Monsanto Data Request 17.11
Monsanto Data Request 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 curilment products so the evaluation for anyone product is
not applicable to Monsanto." Please explain how Monsanto's curlment product
terms and conditions differ from the terms and conditions of other curlment
products used by the Company.
Response toMonsanto Data Request 17.11
The Company objects to ths data request on the basis that the question is vague
and overly broad. Without waiving ths objection, PacifiCorp states as follows.
PacifiCorp uses many different curailment products. Each product has unque
terms and conditions governng the abilty for the Company to curaiL. Some of
these terms and conditions include the number of hours of curlment available in
a given time period, the notice time required prior to curlment, the lengt of the
curailment, the size of the load that can be curled, whether or not a paricular
event is required prior to allowing curlment, and whether the Company can
curil for any reason. Each curailment product terms and conditions is unque to
that paricular contract.
Recordholder:
Sponsor:
Paul H. Clements
Paul H. Clements
PAC-E-1 0-07/Rocky Mountan Power
December 14, 2010
Monsanto Data Request 17.12
Monsanto Data Request 17.12
With respect to Mr. Clements' testimony at p.4, lines 20-21, is it Mr. Clements'
position that Monsanto sells power to the Company?
Response to Monsanto Data Request 17.12
Please refer to Mr. Clements' testimony on page 6, line 17 though page 7, line 13
for a description ofthe interrptible products provided by Monsanto.
Recordholder:
Sponsor:
Paul H. Clements
Paul H. Clements
PAC-E-10-07/Rocky Mountain Power
December 14,2010
Monsanto Data Request 17.13
Monsanto Data Request 17.13
With respect to Mr. Clements' testimony at p. 13, line 22, please provide the June
30,2010 offcial forward price cure.
Response to Monsanto Data Request 17.13
Please refer to Attchment Monsanto 17.13 for a copy of the June 30, 2010
official forward price cure.
Recordholder:
Sponsor:
Rick Lin
Paul H. Clements
P AC- E-1 0-07/Rocky Mounta Power
December 14, 2010
Monsanto Data Request 17.14
Monsanto Data Request 17.14
At p. 26, lines 8-12 of Mr. Clements' testimony, Mr. Clements states that the
value of a thee.:year strp of energy at Palo Verde ha decreased by 31 percent
since the last Monsanto contract was negotiated. Please provide the following
information:
a. Identify how much the Company's actul net power costs have increased durg
the same time period.
b. Identify how much a three-year strp of energy at Mona has increased durg the
same time period.
Response to Monsanto Data Request 17.14
a. The Company's net power costs for the 12-month ended June 2007 and June 2010
were approximately $912 milion and $1,064 millon, respectively.
b. The thee-year strip of energy prices at Mona over the same period decreased by
32%.
Recordholder:
Sponsor:
Hui Shu / Rick Lin
Paul H. Clements
PAC-E-1 0-07/Rocky Mountain Power
December 14, 2010
Monsanto Data Request 17.16
')
Monsanto Data Request 17.16
Does Mr. Clements agree that under the current 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 explai.
Response to Monsanto Data Request 17.16
Please refer to Mr. Clements' testimony on page 7, line 8 though page 7, line 13.
Recordholder:
Sponsor:
Paul H. Clements
Paul H. Clements
PAC-E-10-07/Rocky Mountain Power
December 14,2010
Monsanto Data Request 17.17
Monsanto Data Request 17.17
Does Mr. Clements agree that under the curent Monsanto contract, the Company
controls the interrption of Monsanto's load? If no, please explain.
Response to Monsanto Data Request 17.17
The Company has the abilty to interrpt Monsanto's load pursuant to the specific
terms and conditions set fort in the contract.
Recordholder:
Sponsor:
Paul H. Clements
Paul H. Clements
P AC-E-1 0-07/Rocky Mountain Power
December 14,2010
Monsanto Data Request 17.18
Monsanto Data Request 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 IR document for
which Mr. Clements' provided input or comments which were utilized by the
Company.
Response to Monsanto Data Request 17.18
Yes. The Company does not track "each instace" or "IRP document" where Mr.
Clements has provided input or comments utilzed by the Company in its IRP
process.
Recordholder:
Sponsor:
Gregory N. Duvall
Paul H. Clements
PAC-E-10-07/Rocky Mountain Power
December 14,2010
Monsanto Data Request 17.20
Monsanto Data Request 17.20
With respect to Mr. Duvall's rebuttl testimony at page 2, lines 19-22 and page 3,
lines 1-13, please identify all persons responsible for the planng assumption
change related to Monsanto's interrptible load.
Response to Monsanto Data Request 17.20
Mr. Duvall is responsible for the plang assumption chage related to
Monsanto's interrptible load.
Recordholder:
Sponsor:
Gregory N. Duvall
Paul H. Clements
/PAC-E-1 0-07/Rocky Mountain Power
December 14, 2010
Monsanto Data Request 17.21
Monsanto Data Request 17.21
Please provide a copy ofPacifiCorp's application and all testimony fied in Case
No. UPL-E-92-02.
Response to Monsanto Data Request 17.21
If the Company stil has records from this proceeding, they are in off-site storage.
Recordholder: N/ A
Sponsor: N/A