20101227PAC 8 (1-36) to Monsanto.pdf

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Mark C. Moench
Daniel E. Solander
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. [phone]
mark.moeiich(fpacificorp.com
daniel.solander(fpacificorp.com
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Avenue, Suite 700
P.O. Box 467
Cheyenne, WY 82003-0467
Ph. 307-634-1525
Fx.307-638-7335
phickev(fhickeyevans.com
Attorneys for Rocky Mountain Power
IßlM.l£C 21 M''i 9= 23
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUNTAIN POWER FOR
APPROVAL OF CHAGES TO
ITS ELECTRIC SERVICE
SCHEDULES AND A PRICE
INCREASE OF $27.7 MILLION,
OR APPROXIMATELY 13.7
PERCENT
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CASE NO. PAC-E-I0-07
DISCOVERY REQUESTS
ROCKY MOUNTAI POWER'S EIGHTH SET OF DISCOVERY
REQUESTS TO MONSANTO COMPAN
COMES NOW, Rocky Mountain Power and hereby serves its eighth set of data requests on
Monsanto Company ("Monsanto") regarding the above docketed application of Rocky Mountain
Power, pursuant to Rule 225 of the Idaho Public Utilities Commission's Rules of Procedure,
IDAPA 31.01.01, as follows:
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DEFINITIONS AN INSTRUCTIONS
The following definitions and instrctions apply to each of the requests for production set
forth herein and are deemed to be incorporated therein.
(1) "Document" and "documentation" should be interpreted as broadly as possible
to include, but not be limited to, the original or any copy, regardless of origin or location, of any
book, pamphlet, periodical publication, letter, scrapbook, diary, calendar, canceled check,
photograph, form, memorandum, schedule, tax retu, telegram, telex, report, record, order or
notice of governental action of any kind, study, minutes, logs, graph, index, tape, disc, internal
operating manual, data sheet or data processing card, or any other wrtten, recorded, transcribed,
punched, taped, filmed, graphic or retrevable matter or data of any kind, however produced or
reproduced, to which you have or have had access. This definition is intended to include, but not
be limited to, all documents which have been created and/or which reside in any tye of
electronic format and is to be constred in its most comprehensive sense as contemplated by the
Idaho Rules of Civil Procedure.
(2) "Person or Entity" should be interpreted to denote, unless otherwise specified,
any natural person, firm, corporation, association, group, individual or organization of any tye
whatsoever.
(3) Any request to "identify" or "provide" should be interpreted to mean:
a) With respect to a natual person, that person's full name, title, job
description, and business and home address. Where the identification pertins to a past period,
as to each person identified who is stil in your employ, or the employment of the group with
which such person is identified in response to any requests, provided, in addition, that person's
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title and job description as of the time of such past period. Where the person is no longer in your
employ or the employment of the group with which such person is identified in response to any
request, provide that person's affliate, position, home and business address, if known, or if not
known, such person's last known affliation, position, home and business address, or portions
thereof as may be known.
b) With respect to an entity other than a natual person, that entity's name,
business, tye of entity, present status and present or last known address.
c) With respect to a document, that document's title, date, author (and, if
different, the signer), addresses, recipients, or other persons who assisted in the preparation,
subject matter or general nature, and any amendments thereto, present location and custodian,
whether or not such document is in the respondent's possession, custody or control and whether
or not the document is claimed to be privileged. The final version and each draft of each
document should be identified and produced separately. Each original and each non-identical
copy (bearing marks or notations not found on the original) of each final version and draft of
each document should be identified and produced separately.
d) With respect to a physical facility, the location of the facility, the intended
purpose of the facility, the actual use of such facility, the operating dates of the facility, the
installation date of the facility, the date utilization of the facility terminated if applicable, and
whether the facility is subject to the jurisdiction of the Federal Energy Regulatory Commission,
the Idaho Public Utilities Commission, or any other regulatory body.
(4) "Communication" should be interpreted to include, but not be limited to, all
forms of communication, whether written, printed, oral, pictorial, electronic or otherwise,
including testimony or sworn statement, or any means or type whatsoever.
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(5) "Relating To" or "Related To" means pertining to, presenting, discussing,
commenting on, analyzing, or mentionig in any way.
(6) The term "and" and "or" should be constred either disjunctively or
conjunctively whenever appropriate in order to bring within the scope of each request any
information or document which might otherwise be considered to be beyond its scope.
(7) The singular form of a word should be interpreted as plural, and the plural form of
a word should be interpreted as singular, whenever appropriate in order to bring within the scope
of each request any information or document which might otherwise be considered to be beyond
its scope.
(8) Rocky Mountain Power requests that Monsanto respond to these request no later
than December 30,2010, as provided for in the scheduling order in this case.
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DATA REQUESTS
RMP 8.1 Please provide all of Mr. Brian Collns' work papers supporting his testimony and
exhibits filed December 22, 2010.
RMP 8.2 Please provide all of Ms. Katie Iverson's work papers supporting her testimony
and exhibits fied on December 22,2010.
RMP 8.3 Regarding Rocky Mountain Power's obligation to serve Monsanto referenced in
Mr. Brian Collins' testimony (page 4, line 9):
a. Please explain why Monsanto is entitled to the output of firm resources if those
resources are not acquired to serve interrptible customer loads.
b. Please explain the circumstances under which interrptible customer loads can
receive service from firm resources acquired to serve firm customers.
c. Please explain if Monsanto would support being curiled if the output of the firm
resource acquired to serve the net firm obligation could be sold tothe market at a
price higher than Monsanto's contract rate.
RMP 8.4 Is it Monsanto's position that all non-firm customers offer the same value to the
Company? If no, please describe how to distinguish the value between one non-firm customer
and another non-firm customer.
RMP 8.5 Regarding Monsanto's load at the time of the system peak referenced in Mr. Brian
Collins' testimony (page 5, line 9):
a. Please explain in detail how many MW Monsanto was curailed at the time of
coincident peak for each month in 2007 though 2010.
b. Is it Monsanto's position that an operating reserve interrption is more likely to
occur at the time of a coincident peak, less likely to occur at the time of a
coincident peak, or equally likely to occur at the time of a coincident peak?
Please explain your answer.
RMP 8.6 Regarding simultaneous economic curailment and operating reserve interrptions
referenced in Mr. Brian Collins' testimony (page 5 line 17)
d. Is it Monsanto's position that Rocky Mountain Power can curail 95 MW for
operating reserves even if the 67 MW fuace is already curiled for economic
curailment?
RMP 8.7 Please refer to page 6 lines 4-6 of Mr. Brian Collns' testimony.
e. Please defme each event and detail how many MW of load can be curailed (based
on the curent contract terms) as a result of each event:
i. System emergency
ii. Period of high market prices
iii. Stressed regional resources
f. If market prices are high, regional energy supply is tight, and Rocky Mountain
Power's loads are extremely high, can Rocky Mountain Power interrpt
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Monsanto's 95 MW reserves load even if no operating reserve event has
occured?
RMP 8.8 . If generating capacity is "not constrcted or acquired to serve interrptible load
referenced on page 6 lines 16-17 of Mr. Brian Collins' testimony.
g. What resources are used by Rocky Mountain Power to provide service to
Monsanto durng the hours in which interrption does not occur?
h. What is the minimum number of hours of interrption a customer must agree to in
order for Rocky Mountain Power to not have to build any resources to serve such
customer?
RMP 8.9 Please compare the tyical asset life for a combustion tubine to the tyical
contract length for Monsanto. Referenced on page 7 line 1 of Mr. Brian Collins' testimony.
RMP 8.10 Regarding Mr. Collins's statement that Rocky Mountain Power curently uses
Monsanto's interrptibility much like it would a combustion tubine (page 7 line 9):
a. Can Monsanto provide sping reserves?
b. Can Monsanto provide load following service?
c. Can Monsanto provide automatic generation control?
d. Can Monsanto provide 162 MW for extended periods of time, such as 4 hours?
What is the maximum number of consecutive hours of curilment of 162 MW
curently allowed by the contract?
RMP 8.11 Is it Monsanto's position that Rocky Mountain Power would need to constrct a
new combustion tubine if Monsanto is either unwiling or unable to provide its interrptible
products to Rocky Mountain Power? If yes, please provide the any data, report or study used in
support of this position. (Reference page 9 lines 16-18 of Mr. Brian Collins' testimony.)
RMP 8.12 .. Please provide a justification for using the peaker method to value Monsanto's
interrptible products when the commission stated they "canot find the avoided peaker method
to be the definitive methodology for valuing the itnerrptibility credit" in its Final Order No.
29157 dated January 23, 2003 in Case No. PAC-E-01-16?
RMP 8.13 Regarding Mr. Collns' statement that Monsanto's interrptibility is treated and
operated as a peakig capacity resource (page 11 lines 21-23)
a. Please describe the number of operating reserve interrptions (as a percentage of
total operating reserve interrptions) that occured durng the peak period of HE
13:00 though HE 20:00 MST for each year for the time period 2007-2009.
b. Please describe the total number of hours 162 MW has been curailed for each
year for the time period 2007-2009.
c. Please describe the maximum number of consecutive hours 162 MW has been
curiled each year for the time period 2007-2009.
RMP 8.14 Please provide the referenced article in its entirety wrtten by Eric C. Woychik
referenced on page 12 line 1 of Mr. Brian Collns' testimony.
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RMP 8.15 Regarding Mr. Collins' statement that the Company controls the interrptions that
Monsanto has committed to provide (page 12 lines 27-28)
a. Can the Company control when an operating reserve event occurs?
b. Can the Company control when a double contingency event occurs?
c. Can the Company control when a voltage related event occurs?
RMP 8.16 Regarding Mr. Collins' statement that wind generation makes Monsanto's
provision of operating reserves more valuable referenced on page 13 line 16-18 of Mr. Brian
Collns' testimony;
i. Please describe in detail how the addition of wind generation makes non spining
operating reserves more valuable.
RM 8.17 Please provide any work papers supporting Mr. Collins' assertion that a 9.7%
capacity factor compares favorably to Rocky Mountain Power's capacity factor for its Gadsby
CT.
RMP 8,18 Regarding Mr. Collins' assertions that Monsanto is more reliable than a
combustion tubine (page 14 lines 3-9), can Rocky Mountain Power control when Monsanto
takes its furnaces offine for maintenance?
RMP 8.19 Regarding Mr. Collns' reference to the Utah order in Docket No. 06-035-T14
(page 16 lines 7-19), is Monsanto aware that the discussion in that docket pertained to the use of
those rates to evaluate the price at which Rocky Mountain Power may sell to a special contract
customer and not the price at which Rocky Mountain Power may buy products from a special
contract customer?
RMP 8.20 Please provide evidence to support Monsanto's position that a system integrity
event (as defined in the Monsanto contract) is most likely to occur at a time when the WECC
price cap of $400 is setting the market price?
RMP 8.21 Regarding Ms. Iverson's testimony please provide the number of hours and the
specific times in which the market price reached $400 for the time period 2007-2009.
RMP 8.22 Please describe the minimum amount of interrptible hours a customer needs to
curtail for Ms. Iverson to consider them a "non firm" customer?
RMP 8.23 Is it Ms. Iverson's position that the number of hours of interrption and the terms
of the interrption (i.e. the events that allow the Company to call for an interrption) impact the
cost incurred by the Company to serve the customer? Please fully explain your answer.
RMP 8.24 Is it Ms. Iverson's position that the value of the specific interrptible terms and
conditions should reflect the difference between the cost to serve a firm customer and the cost to
serve the interrptible customer? Please fully explain your answer.
RMP 8.25 Regarding Ms. Iverson's statement that load supplied on an interrptible basis
does not require the installation of generating capacity.
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a. Is it Monsanto's position that it should only be allowed to take service from
Rocky Mountain Power when there is excess generating capacity on Rocky
Mountain Power's system?
b. If Rocky Mountain Power uses resources built for other firm customers to serve
Monsanto's interrptible loads, at what price should Monsanto receive service
from those resources?
c. If the output from those resources could be sold to the market at a price higher
thanMonsanto's contrct price, please explain why firm customers are not better
off selling the excess capacity and energy to market instead of selling to
Monsanto.
RMP 8.26 Regarding Ms. Iverson's asserton that the utility does not incur the obligation to
serve interrptible customers durng heavy load periods, please provide the average hourly load,
in MW, for Monsanto durng the heavy load periods for each year in the time period 2007-2009.
RMP 8.27 Regarding Ms. Iverson's statement that interrptible load helps the utility avoid
installng excess capacity (page 12 lines 16-18), please provide any studies performed by
Monsanto or the Company that clearly demonstrate that the removal of the Monsanto
interrptible product from PacifiCorp's resource portfolio creates the need for the Company to .
acquire a combustion tubine in the same nameplate quantity as the amount of Monsanto
interrptible product that was removed.
RMP 8.28 Please reconcile the statement made by Ms. Iverson on page 17 lines 13-14 in
which she states operating reserve interrptions have priority over economic curailment with
the language in Section 2.2.3 which states as follows:
2.2.3 If two furnaces are operating and the third is unavailable due to Economic
Curtailment, Monsanto wil curtail one furnace. The furnace so curtailed wil be
the largest operating furnace.
RMP 8.29 Is it Ms. Iverson's position that the Company can curail 95 MW for operating
reserves when the 67 MW fuace is curtailed for economic curtailment?
RMP 8.30 In Ms. Iverson's opinion, what is the likelihood that the 67 MW fuace wil be
curailed for economic curailment durng peak periods?
RMP 8.31 Please explain how the Company's de-rating is completely unwaranted (page 18
line 5) when Monsanto does not provide 95 MW of operating reserves at times when the 67 MW
fuace is curailed for economic curilment.
RMP 8.32 On page 24 line 20-21 Ms. Iverson states that Mr. Clements is not being entirely
truthful about the full credit level for 2011 for Customer #1. Please reference where in Mr.
Clements testimony he states the credit level for 2011 for Customer # 1.
RMP 8.33 Please provide all work papers, formulas intact, for Ms. Iverson's calculation of
$33.49 per MWH on page 25 line 4.
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RMP 8.34 Please reconcile Ms. Iverson's statement on page 25 lines 22-23 that the
maximum duration of any single interrption is 60 minutes with Section D of Exhibit B of
Customer #l's contract which allows for subsequent interrptions applicable to 50 MW out of
the total of85 MW.
RMP 8.35 Please provide all work papers, formulas intact, for Ms. Iverson's calculation of
the rate comparison to Customer #2 on page 27 line 7.
RMP 8.36 Is Monsanto wiling to accept the interrptible terms and conditions set forth in
Customer #2' s contract?
DATED this 23rdday of December 2010.
Respectfully submitted,
ROCKY MOUNTAIN POWER
lsi
Mark C. Moench
Daniel E. Solander
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. [phone]
mark.moench(fpacificorp.com
daniel. solander(ßpacificorp.com
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Avenue, Suite 700
P.O. Box 467
Cheyenne, WY 82003-0467
Ph. 307-634-1525
Fx. 307-638-7335
phickey(fhickeyevans.com
Attorneys for Rocky Mountain Power
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CERTIFICATE OF SERVICE
I hereby certify that on this 23rd day of December, 2010, I caused to be served, via E-mail, a tre
and correct copy of Rocky Mountain Power's Eighth Set of Discovery Requests to Monsanto in
PAC-E-1O-07 to the following:
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey,
Chartered
201 E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
E-Mail: elo(áracinelaw.net
Tim Buller
Jason Hars
Agrum, Inc.
3010 Conda Road
Soda Springs, ID 83276
E-Mail: tbuller(ßagrum.com
JAHarrs0)agrium.com
Brad Purdy
CAPAI
2019 N. 17th St.
Boise, ID. 83702
E-mail: bmpurdy(ßhotmaiL.com
Anthony Yankel
29814 Lake Road
Bay Vilage, Ohio 44140
E-mail: tony(ßyanke1.net
James R. Smith (E-mail only)
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
E-Mail: jim.r.smith0)monsanto.com
Ronald L. Willams
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID, 83702
E-mail: ron(fwillamsbradbur.com
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey,
Charered
201 E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
E-Mail: rcb(ßracinelaw.net
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Ave., Suite 700
PO Box 467
Cheyenne, WY 82003
E-Mail: phickey(ßhickeyevans.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
P.O. Box 844
Boise, Idao 83702
E-mail: botto(ßidahoconservation.org
Katie Iverson (E-mail only)
Brubaker & Associates
17244 W. Cordova Cour
Sunrse, Arizona 85387
E-Mail: kiverson(ßconsultbai.com
Melinda J. Davison
Davison Van Cleve, P.e.
333 S.W. Taylor, Suite 400
Portland, OR 97204
E-mail: mjd(ßdvc1aw.com
Dr. Don Reading (E-mail Only)
Idaho Conservation League
6070 Hil Road
Boise, ID 83703
E-mail: dreading(fmiiidspring.com
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Scott Woodbur
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
E-Mail: scott.woodburaP,puc.idaho.gov
lsi
Arel Son
Coordinator, Administrative Services
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