20101220PAC to Monsanto 17 (1-2, 11-12,16, 21).pdf

~~~OUNTAIN RECEi
1010 nEe 20 A~ 9: '8
December 17,2010
Radall C. Budge
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHATERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
RE: ID PAC-E-10-07
Monsanto 17th Set Data Request (1-21)
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Please fid enclosed Rocky Mountan Power's 1 st Supplementa responses to Monsto 17th Set
Data Requests 17.1, 17.2, 17.11, 17.12, 17.16, and 17.21. Provided on the enclosed Confdential
CD are Confdential Attchments Monsanto 17.1-( a-b) 1 st SupplementaL. The atthments are
being provided to the requesting par only. The Confdential Atthments are Confdential and
are provided subject to the protective order in ths docket.
If you have any questions, please feel free to call me at [phone].
Sincerely,
JT.-4W~)~
J. Ted Weston
Manger, Regulation
Enclosure:
cc: Jean Jewel1/UC (C)! 3 copies
Eric OlsenlIP A (C)
Ben Otto/ICL (C)
James R. SmithMonsanto (C)
Richad AndersonIonsanto (C)
George C. Carer, III/Monsanto (C)
Denns Peseau/onsanto (C)
Gaeth R. Kajander/Monsanto (C)
Maurce Brubaker/Monsanto (C)
Brian Collns/Monsanto (C)
Michael Gormanonsanto (C)
Kathr IversonIonsanto (C)
Mark Widmer/Monsanto (C)
P AC-E-1 0-07/Rocky Mounta Power
December 17,2010
Monsanto Data Request 17.1- 1st Supplementa Respons
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 Operating Reserve Credit:
a Are the moneta amounts listed for Customer #1 and Customer #2
confdential?
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 determg these moneta amounts, please provide in electronic
format with all formula and input.
c. For the Company models used in justifyg these credits, please provide the
names of the unts which were marginal for the development of the credt,
along with their assumed natu 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.
1 st Supplemental Response to Monsanto Data Request 17.1
a The moneta amounts ar not confdential so long as the customer nae is not
diectly lined to the amount. The combination of the identifyg customer
name and the respective moneta amount trggers the confdentiality.
b. The Cusomer #1 contract was provided in the Company's response to
Monsanto Data Request 1.27. The Curlment Credt is identified on page 5
of that contract. The terms and conditions related to that credit are identified in
Exhbit B of that contract. The Company is providing Confdential
Supplementa Atthment Monsanto 17.1 a, which is a workpaper explaig
the Operating Reserve Credit values referenced for Customer # 1 in the table on
page 18 of Mr. Clements' testiony.
The Customer #2 Operating Reserve Interrption Agreement is attched as
Confidential Supplementa Attchment Monsanto 17.1 b. The contract
provided in the Company's response to Monsanto Data Request 1.27.was the
Customer #2's Electrc Serice Agreement. Secton 5 (on page 4) of the
Operating Reserve Interrption Agreement contans the detas on the "Value
of Operating Reserve Credit" value referenced for Customer #2 in the table on
page 18 of Mr. Clements' testimony. The agrement includes the terms and
conditions related to the interrptible rights provided to the Company.
Confdential information is provided subject to the terms and conditions of the
protective ageement in this proceeding. The Company has contated Magcorp
and received their authoriztion to provide ths inormation under protection of
the confdentiality agreement, pursuat to an ageement among Magcorp,
Monsanto, and Rocky Mounta Power. The attchments are being provided to
the requesting pary only.
Recordolder:
Sponsor:
Paul H. Clements
Paul H. Clements
P AC-E-l 0-07/Rocky Mountain Power
December 17,2010
Monsanto Data Request 17.2 - 1st Supplementa Response
Monsanto Data Request 17.2
For all GRI model results relied upon by Mr. Clements in his September 30,
2010 testimony:
a. Please provide the date these GRI model ru were completed
and provided to Mr. Clements.
b. Please provide the name of the person responsible for performng
these GRID model ru.
1st Supplemental Response to Monsanto Data Request 17.2
The net power cost group includes multiple individuas who prepare, ru and
evaluate GRI model rus. Hui Shu is the Manager, Net Power Cost group, and
has reviewed and is famliar with these GRID model ru.
Recordholder:
Sponsor:
Hui Shu
Paul H. Clements
P AC-E-l 0-07/Rocky Mounta Power
December 17, 2010
Monsanto Data Request 17.11 - 1 st Supplementa. Response
Monsanto Data Request 17.11
With respect to the response to Monsto 16.10, Mr. Clements states the
following in the last line of the response: "Please note the term and conditions
ar different among curlment 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.
1st Supplemental Response to Monsanto Data Request 17.11
Although the Company believes a request for comparson of all curlment
progras is vague and overly broad the Company responds tht the terms and
conditions of Monsanto's curlment products may be compared with the terms
and çonditions of other industral curlment contracts by reviewig the contrcts
provided in the Company's response to Monsanto Data Request 1.27 and
Confdential Supplemental Atthment Monsato 17.1 b. The terms and
conditions of Monsanto's curlment products can also be compared to the terms
and conditions of other Company interrptible programs by reviewig the
appropriate tarffs or programs.
As a point of clarfication, the language Mr. Budge quotes in his December 15
e-mail was par of the Company's response to Monsanto Data Request 16.10,
which referred to Company DSM programs, rather than par of Mr. Clements'
testiony.
Recordholder:
Sponsor:
Paul H. Clements
Paul H. Clements
P AC-E-1 0-07/Rocky Mounta Power
December 17,2010
Monsanto Data Request 17.12 - 1 st Supplemental Response
Monsanto Data Request 17.12
With respect to Mr. Clements' testiony at p.4, lines 20-21, is it Mr. Clements'
position tht Monsanto sells power to the Company?
1 st Supplemental Response to Monsanto Data Request 17.12
No.
The reference to Mr. Clements' testimony on page 6, line 17 though page 7, line
13 responded to the request by describing the products Monsto provides.
Recordholder:
Sponsor:
Paul H. Clements
Paul H. Clements
P AC-E-l 0-07/Rocky Mountan Power
December 17,2010
Monsanto Data Request 17.16 - 1 st Supplementa Response
Monsanto Data Request 17.16
Does Mr. Clements agree that under the curent Monsanto contrt, Monsanto can
be interrpted in the amount of 162 MW for 12 hour due to voltage related
system integrty interrptions? If no, pleae explai.
1st Supplemental Response to Monsanto Data Request 17.16
"Yes. The reference to Mr. Clements' testimony, page 7, line 8 through page 7,
line 13, was believed to address Monsanto's question.
Recordholder:
Sponsor:
Paul H. Clements
Paul H. Clements
PAC-E-10-07/Rocky Mountan Power
December 17,2010
Monsto Data Request 17.21 - 1 st Supplementa Response
Monsanto Data Request 17.21
Please provide a copy ofPacifiCorp's application and all testiony filed in Case
No. UPL-E-92-02.
1st Supplemental Response to Monsanto Data Request 17.21
The Company has completed a search of its off-site record storage and does not
have the application or any testimony.
Recordholder: N/ ASponsor: N/i\