20110106Monsanto to PAC 8 (1-36).pdf

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, III
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD~ SUITE 208
BOISE, IDAHO 83702
TELEPHONE: -(208) 395';00 t 1
FACSIMILE: -[phone]
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
Januar 4,2011
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Mrs. Jean Jewell, Secretar
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Dear Jean:
Re: PA C-E-I 0-0 7
Enclosed for fiing in the captioned matter please find the original and three copies of
Monsanto Company's Responses to Rocky Mountain Power's Eighth Data Requests. Also enclosed
is a CD containing the public versions of Attachments 8.1 and 8.2, and another CD containing the
confidential version of Attachment 8.2. Than you for your assistance.
~E
RCB:rr
Enclosures
cc: Service List (w/encls.)
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(fracinelaw.net
?flI." ---~iU! Jl!n -6 r.Vil Q. 41d t .J. -
Attorneys for Interenor 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-IO-07
MONSANTO COMPANY'S RESPONSE TO ROCKY MOUNTAIN POWER'S
EIGHTH SET OF DATA REQUESTS
COMES NOW Monsanto Company ("Monsanto"), through counsel, and hereby responds
to Rocky Mountain Power's Eighth Set of Discover Requests dated December 23, 2010,
pursuant to Rule 225 of the Idaho Public Utilities Commission's Rules of Procedure, IDAP A
31.01.01, as follows:
RESPONSES TO RMP EIGHTH DATA REQUESTS
1
P AC- E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.1
RMP Data Request 8.1
Please provide all of Mr. Brian Collns' work papers supporting his testimony and exhibits filed
December 22,2010.
Response to RMP Data Request 8.1
Please refer to RMP 8.1 Attachment 1, RMP 8.1 Attachment 2, and RMP 8.1 Attachment 3.
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collns
2
PAC-E-1O-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.2
RMP Data Request 8.2
Please provide all of Ms. Katie Iverson's work papers supporting her testimony and exhibits fied
on December 22,2010.
Response to RMP Data Request 8.2
Please refer to RMP 8.2 Attachment 1, RMP 8.2 Attachment 2 Confidential and RMP 8.2
Attachment 3.
Recordholder:
Sponsor:
Kathr E. Iverson
Kathr E. Iverson
3
PAC-E-10-07/Rocky Mountain Power
January 4,2011
RMP Data Request 8.3
RMP Data Request 8.3
Regarding Rocky Mountain Power's obligation to serve Monsanto referenced in Mr. Brian
Collns' 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 interptible customer loads can
receive serice from firm resources acquired to serve firm customers.
c. Please explain if Monsanto would support being curailed if the output of the firm
resource acquired to sere the net firm obligation could be sold to the market at a
price higher than Monsanto's contract rate.
Response to RMP Data Request 8.3
a. Monsanto, and other interrptible customers on the RMP system, are served by the
output of firm resources acquired to support firm customers when the firm customers
do not require the use of those resources.
b. See the response to par (a) above.
c. It is Monsanto's position that all interptible customers have priority over off-system
market sales for the output of resources acquired to sere RMP's firm customers.
See also Response to RMP Data Request 8.25.
Recordholder:
Sponsor:
Brian C. Collins
Brian C. Collins
4
PAC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.4
RMP Data Request 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.
Response to RMP Data Request 8.4
No. Please see the direct testimony of Ms. Iverson at pages 22-32.
Recordholder:
Sponsor:
Kathr E. Iverson
Kathr E. Iverson
5
PAC-E-10-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.5
RMP Data Request 8.5
Regarding Monsanto's load at the time of the system peak referenced in Mr. Brian Collns'
testimony (page 5, line 9):
a. Please explain in detail how many MW Monsanto was curtailed at the time of
coincident peak for each month in 2007 through 2010.
b. Is it Monsanto's position that an operating resere 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.
Response to RMP Data Request 8.5
a. Monsanto has not perormed this analysis. As testified by Ms. Iverson at p. 21 of her
December 22, 2010 direct testimony, whether or not an interptible customer is
actually curtailed during the system peak in no way affects the benefits of
interptible load. It is the ability to be interpted durng peak times, as well as at
other times that underlies its value, not necessarly if the customer is actually called.
If there is adequate capacity to serve the load at time of peak, it would be poor
management to waste an interption that might be needed at a later time.
b. It is Monsanto's position that an operating resere interrption is equally likely to
occur at the time of coincident peak.
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collins
6
P AC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.6
RMP Data Request 8.6
Regarding simultaneous economic curtailment and operating reserve interrptions referenced in
Mr. Brian Collins' testimony (page 5 line 17)
a. Is it Monsanto's position that Rocky Mountain Power can curtail 95 MW for
operating reserves even if the 67 MW fuace is already curtailed for economic
curailment?
Response to RMP Data Request 8.6
a. Yes.
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collns
7
PAC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.7
RMP Data Request 8.7
Please refer to page 6 lines 4-6 of Mr. Brian Collins' testimony.
a. Please define each event and detail how many MW ofload can be curtailed (based on
the current contract ters) as a result of each event:
i. System emergency
ii. Period of high market prices
iii. Stressed regional resources
b. If market prices are high, regional energy supply is tight, and Rocky Mountain
Power's loads are extremely high, can Rocky Mountain Power interrpt Monsanto's
95 MW reseres load even if no operating reserve event has occured?
Response to RMP Data Request 8.7
a. Based on curent contract ters:
i. A system emergency (i.e., lack of system resources adequate to serve firm
load) could exist durng a system emergency event as defined in the current
interrptible contract between Monsanto and RMP (162 MW).
11. A perod of high market prices relative to RMP's generation costs could exist
durng an economic curailment event as defined in the current interptible
contract between Monsanto and RMP (67 MW) and could also exist durng an
operating resere event as defined in the curent interptible contract between
Monsanto and RMP (95 MW).
iii. Stressed regional resources could exist durng an economic curailment event
as defined in the curent interptible contract between Monsanto and RMP
(67 MW) and could also exist durng an operating reserve event as defined in
the curent interrptible contract between Monsanto and RMP (95 MW).
b. Monsanto has in the past provided Rocky Mountain Power with additional
interrptions outside of the specific contract requirements and is wiling to do so in
such a situation as described.
Recordholder:
Sponsor:
Brian C. Collins
Brian C. Collins
8
P AC- E-1 0-07/Rocky Mountain Power
Januar 4, 2011
RMP Data Request 8.8
RMP Data Request 8.8
If generating capacity is "not constrcted or acquired to sere interrptible load referenced on
page 6 lines 16-17 of Mr. Brian Collns' testimony.
a. What resources are used by Rocky Mountain Power to provide service to Monsanto
during the hours in which interption does not occur?
b. 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 sere such
customer?
Response to RMP Data Request 8.8
a. Monsanto is sered by the output of firm resources acquired to support firm
customers when the firm customers do not require the use of those resourçes.
b. This analysis has not been performed. See also Response to RMP Data Request 8.22.
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collns
9
P AC-E-1 0-07/Rocky Mountain Power
January 4,2011
RMP Data Request 8.9
RMP Data Request 8.9
Please compare the typical asset life for a combustion turbine to the typical contract length for
Monsanto. Referenced on page 7 line 1 of Mr. Brian Collins' testimony.
Response to RMP Data Request 8.9
The Company has not defined the typical asset life of a combustion turbine as used in the request
above (e.g. economic life, serice life, depreciable life, or useful life).
Monsanto's current contract lengt is 3 years and is wiling to enter into longer ter contract
terms as long as contact terms and conditions are agreeable. Monsanto has been an interptible
customer for 59 years and intends to remain an interptible customer as long as it is a customer
ofRMP.
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collns
10
PAC-E-10-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.10
RMP Data Request 8.10
Regarding Mr. Collns's statement that Rocky Mountain Power currently uses Monsanto's
interrptibility much like it would a combustion turbine (page 7 line 9):
a. Can Monsanto provide spinning 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 curtailment of 162 MW currently
allowed by the contract?
Response to RMP Data Request 8.10
a. No
b. No.
c. No.
d. Yes. For system integrty purposes, 162 MW can be provided for up to 12 hour.
The curent contract also allows for simultaneous economic curtailments and
operating reserve interrptions of 162 MW as descrbed in Mr. Collns' testimony at
page 5.
Recordholder:
Sponsor:
Brian C. Collins
Brian C. Collns
11
P AC-E-1 0-07/Rocky Mountain Power
Januar 4, 2011
RMP Data Request 8.11
RMP Data Request 8.11
Is it Monsanto's position that Rocky Mountain Power would need to constrct a new combustion
turbine if Monsanto is either unwiling or unable to provide its interptible 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.)
Response to RMP Data Request 8.11
No. It is Monsanto's position that the Company would need to acquire firm resources equal to
Monsanto's interrptible load plus reseres if Monsanto does not provide its interptibility to
the Company. Though a combustion tubine is the least cost generating resource that could be
constrcted by RMP in ters of capital cost, the selection of a paricular resource, whether or not
a combustion turbine, would depend on the results of economic analysis perormed by the
Company and the needs of the entire RMP system. See also Response to RMP Data Request
8.27.
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collns
12
PAC-E-10-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.12
RMP Data Request 8.12
Please provide a justification for using the peaker method to value Monsanto's interptible
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
Januar 23,2003 in Case No. PAC-E-01-16?
Response to RMP Data Request 8.12
The peaker method is one method that can be used to value the interptibility of customer's
loads. Please see the December 22,2010 direct testimony of Brian Collns for Monsanto's
justification for using the peaker method to value Monsanto's interrptible products.
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collns
13
PAC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.13
RMP Data Request 8.13
Regarding Mr. Collns' statement that Monsanto's interptibility is treated and operated as a
peaking capacity resource (page 11 lines 21-23)
a. Please describe the number of operating reserve interptions (as a percentage of total
operating resere interrptions) that occurred during the peak period of HE 13:00
through HE 20:00 MST for each year for the time perod 2007-2009.
b. Please describe the total number of hours 162 MW has been curtailed for each year
for the time perod 2007-2009.
c. Please describe the maximum number of consecutive hour 162 MW has been
curtailed each year for the time perod 2007-2009.
Response to RMP Data Request 8.13
No such analysis has been perormed by Mr. Collins. The Company has this information in its
records.
Recordholder:
Sponsor:
Brian C. Collins
Brian C. Collns
14
P AC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.14
RMP Data Request 8.14
Please provide the referenced article in its entirety written by Eric C. Woychik referenced on
page 12 line 1 of Mr. Brian Collns' testimony.
Response to RMP Data Request 8.14
Please refer to RMP 8.14 Attachment 1.
Recordholder:
Sponsor:
Brian C. Collins
Brian C. Collns
15
PAC-E-10-07/Rocky Mountain Power
January 4,2011
RMP Data Request 8.15
RMP Data Request 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?
Response to RMP Data Request 8.15
a. Though the Company canot control the actual occurrence of such an event, the
Company can control whether or not an operating resere event is called per the
contract that requires Monsanto to interpt.
b. Though the Company canot control the actual occurence of such an event, the
Company can control whether or not a double contingency event is called per the
contract that requires Monsanto to interpt.
c. Though the Company canot control the actual occurrence of such an event, the
Company can control whether or not a voltage related event is called per the contract
that requires Monsanto to interrpt.
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collins
16
P AC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.16
RMP Data Request 8.16
Regarding Mr. Collns' statement that wind generation makes Monsanto's provision of operating
reseres more valuable referenced on page 13 line 16-18 of Mr. Brian Collins' testimony;
a. Please descrbe in detail how the addition of wind generation makes non spinning
operating reserves more valuable.
Response to RMP Data Request 8.16
a. The existence of Monsanto's interrptibility allows RMP to avoid the installation of
generation used for operating resere. As more wind generation is added to the
system, RMP requires additional operating reserve. The existence of Monsanto as
non-spinning resere provides the Company the opportnity to provide additional
spinnng resere economically from online-generating units that can do so.
Recordholder:
Sponsor:
Brian C. Collins
Brian C. Collins
17
PAC-E-1O-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.17
RMP Data Request 8.17
Please provide any work papers supporting Mr. Collns' assertion that a 9.7% capacity factor
compares favorably to Rocky Mountain Power's capacity factor for its Gadsby CT.
Response to RMP Data Request 8.17
Please refer to RMP 8.17 Attaèhment 1 ConfidentiaL.
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collns
18
PAC-E-10-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.18
RMP Data Request 8.18
Regarding Mr. Collns' asserions that Monsanto is more reliable than a combustion turbine
(page 14 lines 3-9), can Rocky Mountain Power control when Monsanto takes its furnaces
offine for maintenance?
Response to RMP Data Request 8.18
Monsanto has historically coordinated furnace maintenance with RMP and is willng to continue
to do so.
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collns
19
PAC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.19
RMP Data Request 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?
Response to RMP Data Request 8.19
Yes. It is Monsanto's position that the rates are relevant to Monsanto's interptibility valuation
since the Company treats interrptible load as a Class I demand side resource in its Integrated
Resource Plan and the Utah order in Docket No. 06-035-T14 states at page 2 that the rates may
be used to evaluate demand side resource programs:
"Schedule No. 37 prices may also be used to evaluate special contracts, demand
side resource programs and form the basis of credits paid under Electrc Serice
Schedule No. 135, the Company's Net Metering Serice tarff" (emphasis added)
Recordholder:
Sponsor:
Brian C. Collns
Brian C. Collins
20
PAC-E-10-07/Rocky Mountain Power
Januar 4, 2011
RMPData Request 8.20
RMP Data Request 8.20
Please provide evidence to support Monsanto's position that a system integrty 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?
Response to RMP Data Request 8.20
The Company's characterzation of Monsanto's position is incorrect. As power supply becomes
scarce during a system integrty event, many high cost marginal resources would be put online to
serve the demand for power. Monsanto's position is that high market prices for power would
result from a system integrty event.
Recordholder:
Sponsor:
Brian C. Collins
Brian C. Collns
21
PAC-E-1 0-07/Rocky Mountain Power
January 4,2011
RMP Data Request 8.21
RMP Data Request 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.
Response to RMP Data Request 8.21
Ms. Iverson's testimony makes no reference to a market price of $400 for the time period 2007-
2009. Ms; Iverson has not performed such an analysis.
Recordholder:
Sponsor:
Kathr E. Iverson
Kathr E. Iverson
22
P AC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.22
RMP Data Request 8.22
Please describe the minimum amount of interptible hours a customer needs to curail for Ms.
Iverson to consider them a "non firm" customer?
Response to RMP Data Request 8.22
Ms. Iverson's testimony discusses the unique interrptible load of Monsanto and does not
propose any "minimum" threshold. Her testimony does note that Rocky Mountain Power itself
has labeled the majority of Monsanto's load as "non firm" in Exhibits 55 and 84, and Ms. Iverson
would agree with these Rocky Mountain Power exhibits that the majority of Monsanto's load is
"non firm".
Recordholder:
Sponsor:
Kath E. Iverson
Kathr E. Iverson
23
PAC-E-1O-07/Rocky Mountain Power
Januar 4, 2011
RMP Data Request 8.23
RMP Data Request 8.23
Is it Ms. Iverson's position that the number of hours of interption 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.
Response to RMP Data Request 8.23
Yes. There are several factors that may influence the level of an interrptible rate. For example,
Customer A who can interrpt within ten minutes of being notified to curtail is desering of a
rate that is lower than Customer B who requires two hours notification. Customer A is receiving
lower quality service, and providing the utility with greater value than Customer B.
Consequently, a rate that is just and reasonable for Customer B would be overcharging
Customer A.
Other additional factors which impact the interptible rate include:
· The total number of hours for which the customer can be interpted; up to a point, the
more hours, the more value to the utility and thus the lower the rate.
· The maximum number of hours which the customer can be interpted with each
notification -- in general the longer the duration in each interption, the more value to
the utility and thus the lower the rate.
· The number of times an interption can be called -- again, generally, the more times the
more value to the utility, and thus the lower the rate.
· The conditions under which interptions can be called; generally the fewer restrctions
on what conditions are necessary to trgger an interption, the more value to the utility,
and thus the lower the rate.
Recordholder:
Sponsor:
Kathr E. Iverson
Kathr E. Iverson
24
PAC-E-10-07/Rocky Mountain Power
Januar 4, 2011
RMP Data Request 8.24
RMP Data Request 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.
Response to RMP Data Request 8.24
The differential in price between firm and interrptible service should bear a close relationship in
the difference in cost to serve.
Recordholder:
Sponsor:
Kathr E. Iverson
Kathr E. Iveron
25
PAC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.25
RMP Data Request 8.25
Regarding Ms. Iverson's statement that load supplied on an interrptible basis does not require
the installation of generating capacity.
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 sere
Monsanto's interrptible loads, at what price should Monsanto receive serice from
those resources?
c. If the output from those resources could be sold to the market at a price higher than
Monsanto's contract price, please explain why firm customers are not better off
sellng the excess capacity and energy to market instead of selling to Monsanto.
Response to RMP Data Request 8.25
a. No. See Response to RMP Data Request 5.16 and RMP Data Request 8.3.
b. Please see Ms. Iverson's direct testimony at page 32.
c. Rocky Mountain Power does not sell power to its jurisdictional customers on the
basis of market prices, but rather on tarff rates established on cost of serice.
Specifically, rates for service to jursdictional customer as determined by this
Commission are not premised upon an "opportity cost" RMP may potentially profit
from if it sells power into the marketplace, but rather on regulatory principles that
allow the utility to recover its expenses and an opportity to ear a fair and
reasonable return on its investments.
Recordholder:
Sponsor:
Kathr E. Iverson
Kath E. Iverson
26
PAC-E-10-07/Rocky Mountain Power
Januar 4, 2011
RMP Data Request 8.26
RMP Data Request 8.26
Regarding Ms. Iverson's assertion that the utility does not incur the obligation to serve
interptible customers during heavy load periods, please provide the average hourly load, in
MW, for Monsanto during the heavy load perods for each year in the time period 2007-2009.
Response to RMP Data Request 8.26
No such analysis has been performed by Mr. Iverson. The Company has this information in its
records.
Recordholder:
Sponsor:
Kath E. Iverson
Kathr E. Iverson
27
PAC-E-10-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.27
RMP Data Request 8.27
Regarding Ms. Iverson's statement that interrptible load helps the utility avoid installing 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 interptible 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.
Response to RMP Data Request 8.27
The Company's current IRP includes 157 MW of interptible resource. If that resource is no
longer available, Rocky Mountain Power must replace this capacity plus reserves with another
resource. A combustion turbine is generally considered the least cost capacity, and is often used
as the marginal resource for purposes of establishing marginal capacity costs. Whether this exact
"same nameplate quantity" is acquired is irrelevant. See also Response to RMP Data Request
8.1 1.
Recordholder:
Sponsor:
Kath E. Iverson
Kath E. Iverson
28
PAC-E-10-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.28
RMP Data Request 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 curtailment 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 curailed wil be the
largest operating furnace.
Response to RMP Data Request 8.28
The language in the 2008 Agreement, Appendix A, 2.1 clearly states, "Operating Reserve
interrptions shall have priority over Economic Curtailment."
Section 2.2 of Appendix A of the 2008 Agreement provides the specifics as to curailments, with
Section 2.2.3 being only one of four possible conditions. Section 2.2.3 is applicable only during
those times that Monsanto does not buy-through an economic curailment. For example, if thee
furnaces are operating and an economic curailment is called, Monsanto interpts furnace #9 (67
MW). If Monsanto does not buy-through for fuace #9, then two furnaces are operating and if
an operating reserve interrption is called at that time, then provision 2.2.3 allows Monsanto to
keep the smallest furnace operating, i.e., it must curail the largest operating furnace.
Alteratively, if Monsanto buys-through the economic curailment in order to keep fuace #9
operating, and an operating reserve interption is called, then Monsanto must curail 95 MW per
the condition addressed in Section 2.2.1.
Recordholder:
Sponsor:
Kathr E. Iverson
Kath E. Iverson
29
P AC- E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.29
RMP Data Request 8.29
Is it Ms. Iverson's position that the Company can curtail 95 MW for operating reseres when the
67 MW furnace is curtailed for economic curtailment?
Response to RMP Data Request 8.29
Yes. See Response to RMP Data Request 8.28. Mr. Collns' testimony also provides specific
examples of such occurances.
Recordholder:
Sponsor:
Kath E. Iverson
Kath E. Iverson
30
PAC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.30
RMP Data Request 8.30
In Ms. Iverson's opinion, what is the likelihood that the 67 MW furnace wil be curtailed for
economic curailment during peak perods?
Response to RMP Data Request 8.30
The decision as to when economic curailments are called is at the discretion of Rocky Mountain
Power, and it would not be unreasonable to assume the Company utilizes those economic
curailments durng peak perods.
Recordholder:
Sponsor:
Kathr E. Iverson
Kath E. Iverson
31
PAC-E-10-07/Rocky Mountain Power
Januar 4, 2011
RMP Data Request 8.31
RMP Data Request 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 reseres at times when the 67 MW furnace is
curailed for economic curtailment.
Response to RMP Data Request 8.31
Please see Response to RMP Data Request 8.29.
Recordholder:
Sponsor:
Kath E. Iveron
Kathr E. Iverson
32
PAC-E-10-07/Rocky Mountain Power
January 4,2011
RMP Data Request 8.32
RMP Data Request 8.32
On page 24 line 20-21 Ms. Iverson states that Mr. Clements is not being entirely trthful 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.
Response to RMP Data Request 8.32
That is precisely the point. He states neither the full credit for prior years, nor the 2011 amount.
Recordholder:
Sponsor:
Kathr E. Iverson
Kath E. Iverson
33
PAC-E-1O-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.33
RMP Data Request 8.33
Please provide all work papers, formulas intact, for Ms. Iverson's calculation of$33.49 per
MWH on page 25 line 4.
Response to RMP Data Request 8.33
Please see Response to RMP Data Request 8.2.
Recordholder:
Sponsor:
Kathr E. Iverson
Kath E. Iverson
34
P AC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.34
RMP Data Request 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 of 85 MW.
Response to RMP Data Request 8.34
Ms. Iverson's statement is describing Section B ("Commencement and Lengt ofInterption")
of Appendix B if Customer #1 's contract, in paricular that the "maximum duration of any single
interrption shall be (60) minutes" (emphasis added). Section D of Appendix B concerns not the
lengt of interrption, but the number of interptions. Ms. Iverson agrees that Section D
provides that applicable to 50 MW out of the total 85 MW, RMP may request subsequent
interrptions without restoring service between interrptions.
Recordholder:
Sponsor:
Kathr E. Iverson
Kathr E. Iverson
35
P AC-E-1 0-07/Rocky Mountain Power
Januar 4,2011
RMP Data Request 8.35
RMP Data Request 8.35
Please provide all work papers, formulas intact, for Ms. Iverson's calculation of the rate
comparson to Customer #2 on page 27 line 7.
Response to RMP Data Request 8.35
Please see Response to RMP Data Request 8.2.
Recordholder:
Sponsor:
Kathr E. Iverson
Kathr E. Iverson
36
PAC-E-10-07/Rocky Mountain Power
Januar 4, 2011
RMP Data Request 8.36
RMP Data Request 8.36
Is Monsanto wiling to accept the interrptible terms and conditions set forth in Customer #2's
contract?
Response to RMP Data Request 8.36
Monsanto remains flexible as to consideration of possible terms and conditions necessar to
achieve a competitive energy price.
Recordholder:
Sponsor:
Kathr E. Iverson
Kath E. Iverson
37
DATED this s Yh day of January, 2011.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
BY~t'~A
RANDALL C. BUnGE '
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this s- Jiay of Januar, 2011, I served a tre, 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: jjewell~puc.state.id.us Overnight Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: ted.weston(ßpacificorp.com Overnight Mail
Paul J. Hickey
Hickey & Evans, LLP
1800 CareyAve., Ste 700
PO Box 467
Cheyenne, WY 82003
E-mail: phickey(ßhickeyvans.com Overnight Mail
Mark C. Moench
Daniel Solander
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, Utah 84111
E-mail: mark.moench(ßpacificorp.com
daniel.solander(ßpacificorp.com
Overnight Mail
38
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
E-mail: datarequestilpacificorp.com
Scott Woodbury
Deputy Attorney General
Idaho Public Utilties Commission
P. O. Box 83720
Boise, Idaho 83720-0074
E-mail: scott. woodburyilpuc.idaho .gov
Katie Iverson
Brubaker & Associates
17244 W. Cordova Court
Surprise, Arizona 85387
E-mail: kiversonilconsultbai.com
James R. Smith
Monsanto Company
P. O. Box 816
Soda Springs, Idaho 83276
E-mail: jim.r.smithilmonsanto.com
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
P.O. Box 1391
Pocatello, Idaho 83204-1391
E-mail: eloilracinelaw.net
Anthony Yanke i
298 i 4 Lake Road
Bay Vilage, Ohio 44140
E-mail: tonyilyankel.net
Tim Buller
Jason Harris
Agrium, Inc.
3010 Conda Road
Soda Springs, Idaho 83276
E-mail: tbullerilagrium.com
j aharri silagri um .com
Benjamin J. Otto
Idaho Conservation League
P. O. Box 844
Boise, Idaho 83702
E-mail: bottoilidahoconservation.org
39
Overnight Mail
Overnight Mail
U.S. Mail
U.S. Mail
Hand Delivery
U.S. Mail
U.S. Mail
U.S. Mail
Dr. Don Reading
6070 Hil Road
Boise, Idaho 83703
Melinda J. Davison
Davison Van Cleve, P.e.
333 SW Taylor, Suite 400
Portland, Oregon 97204
E-mail: mjdCidvclaw.com
Ronald L. Wiliams
Wiliams Bradbury, P.e.
1015 W. Hays Street
Boise, Idaho 83702
E-mail: ronCiwiliamsbradbury.com
'"Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
E-mail: bmpurdyCihotmaiL.com
U.S. Mail
U.S. Mail
u.S. Mail
u.S. Mail
J:~JEL~
40