20110623Monsanto 25-99 to PAC.pdf

LAW OFFICES OF
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, ill
PATRICK N. GEORGE
SCOTT J. SMITH
DAVID E. ALEXANDER
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN
CANDICE M. MCHUGH
CAROL TIPPI VOLYN
JONATHON S. BYINGTON
JONATHAN M. VOLYN
BRENT L. WHITING
DAVE BAGLEY
THOMAS J. BUDGE
JASON E. FLAIG
FERRELL S. RYAN, III
AARON A. CRARY
JOHN J. BULGER
BRETT R CAHOON
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
ww.racinelaw.net
SENDER'S E-MAIL ADDRESS:rcb(íracinelaw.net
June 21,2011
Jean D. Jewell, Secretar
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. PAC-E-1l-12
Dear Mrs. Jewell
BOiSE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 300
BOISE, IDAHO 83702
TELEPHONE: [phone]
FACSIMILE: (208).433-0167
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 107
POST OFFICE BOX 50698
IDAHO FALLS, 1083405
TELEPHONE: [phone]FACSIMH..E: [phone]
ALL OFFICES TOLL FR£E
[phone]
LOUIS F. RACINE (1917-2005)WILLIAM D. OLSON. OF COUNSEL
~--é ;0Z mN ("Co m-.i "::z ni
~(..i
Please find enclosed for filing the original and three copies of Monsanto Company's Second
Data Requests to Rocky Mountain Power.
Than you for your assistance.
RCB:rr
Enclosures
cc: Service List (w/encls.)
ta
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]
RECEIVED
lOll JUN 23 AM 8: 34
unt
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 ) Case No. PAC-E-l1-12
SCHEDULES AND A PRICE INCREASE OF $32.7 )
MILLION, OR APPROXIMATELY 15.0 PERCENT )
)
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS
TO ROCKY MOUNTAIN POWER
MONSANTO COMPANY, by and through their attorneys, hereby submits this Second
Set of Data Requests to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utílity
Commission's Rules of Procedure, IDAPA 31.01.01, as follows:
Monsanto 25: Please provide actual monthly NPC for 2011 through the most recent month
available. This is a continuing request and should be updated when new information is avaílable.
Monsanto 26: Does the Company agree to allow Monsanto to use discovery responses Mr.
Widmer has in his possession from the following dockets: Washington No. UE-090205; Idaho
PAC E-1O-07; Wyoming PSC Nos. 20000-34l-EP-09, 20000-333-ER-08, 20000-352-ER-09,
20000-384-ER-10 and 20000-389-EP-ll; and Utah 10-035-l24? If not, then provide responses
to the questions asked in those dockets for use in this Idaho case.
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER-1
Monsanto 27: Please identify the normalization perod used for the following items and explain
the reasons for the utilization of different normalization periods used for these items.
a. Thermal forced and planned outages
b. Hydro forced and planed outages
c. Market caps
d. Non-firm transmission
e. STF transmission
f. Heat rates
g. Black Hils and SMUD wholesale sales including delivery points
h. System and state loss factors
Monsanto 28: Please identify any contracts the Company has signed with other paries for the
sale or purchase of electrcity that have not been included in the test year. Please provide a copy
of each such contract. This is a continuing request and should be updated when new contracts
are signed.
Monsanto 29: Please identify the call option contracts included in GRID which were prevented
from dispatching by the screening method. Provide the workpapers that support such decisions.
Monsanto 30: Please identify any wholesale sales contracts, other than FERC jurisdictional
sales, that have been excluded from NPC. If any have been excluded please explain why they
were excluded and provide a copy of each contract.
Monsanto 31: Please provide a summar of the incremental revenues that Company expects to
recover as a result of its recent FERC transmission filing segregated by the type of serces
provided and customers segregated by PacifiCorp and third paries.
Monsanto 32: Please identify how much of the incremental revenues that the Company expects
to receive as a result nfthe FERC transmission filing that have been included in the Company's
filing.
Monsanto 33: Please identify the amount of increment revenues the Company expects to
receive from non network generation from third paries located in the Companies control area.
Monsanto 34: Please provide the monthly percent of natual gas burn requirements for the test
year that were hedged with swaps for price volatility. Also, provide the workpapers and source
documents used to calculate the percent hedged with all cells and formulas intact.
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER. 2
Monsanto 35: Please explain whether the generation for the Cutler and Oneida hydro
generation projects is subject to the same operating agreement as the Bear run of river projects.
Monsanto 36: Please explain whether the reserve carng capability for the Cutler and Oneida
hydro projects was based on an assumption which excludes flood control generation. If not
please explain why not and provide updated GRID inputs which have been adjusted so that
reseres cared in GRID are consistent with reseres carred during non flood control years.
Monsanto 37: Please explain how the Company modeled the amount of reserves that could be
cared on the Cutler and Oneida hydro projects. Please also provide all supporting workpapers
wil all cells and formulas intact.
Monsanto 38: Please provide a summar of GRID inputs which are different that those used in
the Company's Rebuttal NPC fied in Wyoming Docket No. 20000-384-ER-1O.
Monsanto 39: Please provide copies of root cause analyses for the period July 1, 2010 though
December 31,2010.
Monsanto 40: Please identify all theral plant liquidated damage payments the Company has
received for the perod July 1, 2010 through December 31, 2010 related to power plants included
in NPC.
Monsanto 41: Please provide the loss factor data showing the losses for the system and each
state for the most recent five calendar years.
Monsanto 42: Please provide the system level loss factors used in GRID in the latest filing in
the Company's jurisdictions other than Idaho and provide the date of each respective fiing, the
docket number and the test year.
Monsanto 43: Please provide a table showing the actual generation of each coal, gas, hydro and
wind generating unit included in NPC for the perod 2006 though the most recent period
available.
Monsanto 44: Please provide hourly generator logs for each generation plant modeled in GRID
for the perod 2000 through the most recent period available in excel format with all cells and
formulas intact.
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWR. 3
Monsanto 45: For the four-year perod, if differentthan the four-year period used in Wyoming
Docket No. 20000-384-ER-10, please provide the hourly logs for the following contracts /
resources modeled in GRID.
a. The Mid Columbia hydro project
b. All BP A contracts
c. All wind resources
d. Each long-ter sale or purchase contract
Monsanto 46: Please provide a copy of all power purchase and sales contracts, transmission
contracts and fuel contracts included in NPC which are different than those included in NPC in
Wyoming Docket No. 20000-384-ER-1O.
Monsanto 47: Please identify any changes made to maximum capacities, minimum up and
down times, and minimum capacities for theral or hydro generators modeled in GRID since
Wyoming Docket No. 20000-384-ER-1O.
Monsanto 48: Please make arangements for the review of the highy confidential gas physical
workpapers.
Monsanto 49: Please explain why the Company normalized the Black Hils wholesale sales
contract based on 36 months instead of the 48 Months proposed by Monsanto in Idaho Docket
No. PAC- E-10-07.
Monsanto 50: Please update the Black Hils wholesale sales workpapers to include 48 months
of historical information.
Monsanto 51: Regarding the Company's normalization of Cal ISO transactions, please explain
why the Company used only 2010 data for the months that did not include actual 2011 data.
Monsanto 52: Please identify all Cal ISO transmission capability that was modeled in GRID by
transmission linle
Monsanto 53: Please identify the GRID input files that were used to model Cal ISO sales and
purchase transactions.
Monsanto 54: The confidential forced outage rate workpapers do not include supporting
documents with all cells and formulas intact. Please provide the workpapers in the same format
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 4
as they were provided in Wyoming Docket No. 20000-384-ER-IO in Attachment WIEC 6.10
Confidential.
Monsanto 55: Please provide the calculation and workpapers which support the amount ofREC
revenues included in the filing.
Monsanto 56: Please provide a breakdown ofREC revenues including in the filing segregated
by wind, hydro and other resources from which the RECs were generated by month for the test
year. Also, identify which months include actual information and which months include
estimated information.
Monsanto 57: Please provide a copy of all workpapers used to develop the load any energy
forecast in this proceeding, including the data used to develop jurisdictional allocation factors,
the system load forecast used in GRID and the Idaho sales and revenue forecasts.
Monsanto 58: Please indicate whether the Company excluded expenses for fines and citations
from Jim Bridger fuel expense. If yes, please provide the source workpapers which include the
expenses and the fuel price calculation which shows that the expense has been removed.
Monsanto 59: Please provide all hydro modeling workpapers that support hydro generation lost
from forced outages by unit with all cells and formulas intact.
Monsanto 60: Did the Company's hydro normalization modeling assume that it is unable to use
the water that would normally be used for generation but for a planed or forced outage though
storing the water during the outage and generating after the forced outage is over or by using the
water for generation by ruing the water through an alterative tubine at multi tubine projects.
If the answer is affirmative, please provide information for each outage used in the normalization
perod which supports the modeling assumption.
Monsanto 61: Please provide a summar of executed STF transactions included in NPC in the
same format as Confidential Attachment Wyoming Standardized 2.3-3 from Wyoming Docket
No. 20000-384-ER-10.
Monsanto 62: Please provide detailed fuel price calculation and all supporting information for
the coal generation plants included in NPC with all cells and formulas intact and circular
references corrected.
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER. 5
Monsanto 63: Please provide a plant by plant summar of all items updated for the coal fuel
price calculation as compared to the coal fuel prices used in the Company's rebuttal NPC in
Wyoming Docket No. 20000-384-ER-10.
Monsanto 64: Please provide the market cap calculation with all workpapers and other
information used to develop the caps.
Monsanto 65: Please provide the GRID topology maps if they are different than those used in
Wyoming Docket No. 20000-384- ER -10.
Monsanto 66: Please provide the screen workpapers and any other information used to model
the APS contract.
Monsanto 67: Please provide the status including an expected resolution date of the Company's
lawsuit with Arch Coal Inc. Arch Coal Sales Co. and Canyon Fuel Company. Please also and
explain the price impacts of the suit built into the coal prices used in this filing.
Monsanto 68: Please provide and update of Attachment WIEC 2.60 from Wyoming Docket No.
20000-384-ER-10.
Monsanto 69: Please verify that the Company does not expect Chelan County PUD to
renegotiate the Mid Columbia contract for a portion of the output of the Rocky Reach project.
Monsanto 70: Re: Exhibit No.2, page 3.1.4: Please provide all supporting workpapers for the
$61,415,663 booked revenues for Special Contract 1 in both hard copy and in executable
spreadsheet format.
Monsanto 71: Re: Exhibit No.2, page 3.1.4: Please provide all supporting workpapers for the
$6,464 Type 1 Adjustment to Special Contract 1 in both hard copy and in executable spreadsheet
format.
Monsanto 72: Re: Exhibit No.2, page 3.1.4: Please provide all supporting workpapers for the
($2,186,693)Type 1 Adjustment to Special Contract 1 in both hard copy and in executable
spreadsheet format.
Monsanto 73: Re: Exhibit No.2, page 3.1.4: Please provide all supporting workpapers for the
$1,067,357 Type 1 Adjustment to Special Contract 1 in both hard copy and in executable
spreadsheet format.
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 6
Monsanto 74: Re: Exhibit No.2, page 3.1.4: Please provide all supporting workpapers for the
$326,942 Type 3 Proforma Adjustment to Special Contract 1 in both hard copy and in executable
spreadsheet format.
Monsanto 75: Re: Exhibit No.2, page 3.1.4: Please provide all supporting workpapers for the
$5,594,762 Type 3 Proforma Adjustment to Special Contract 1 in both hard copy and in
executable spreadsheet format.
Monsanto 76: Re: Exhibit No.2, page 3.1.4: Please provide all supporting workpapers for the
$106,243 Type 3 Proforma Adjustment to Special Contract 1 in both hard copy and in executable
spreadsheet format.
Monsanto 77: Re: Exhibit No.2, page 10.13, Metered Loads (CP): Please provide all
supporting workpapers for the Idaho Metered Loads (CP) and explaìn how these peaks were
ascerained, determìned and/or calculated.
Monsanto 78: Re: Exhibit No.2, pages 10.13 and 10.14: For each of the tables, please ìdentify
how much of the Idaho monthly loads are attrbutable to Special Contract 1.
Monsanto 79: Re: Exhibit No.2, page 10.13: Please provide all supporting workpapers for the
144 MW adjustment shown for July 16, 2010 to the Idaho peak in both hard copy and ìn
executable spreadsheet format.
Monsanto 80: Re: Exhibit No.2, page 10.14: Please provide a full narrative descrbìng the
adjustment methodology and all supportìng workpapers in both hard copy and in executable
spreadsheet format for the monthly "Adjustment for Coincidental System Peaks Temperatue
Adjustment" table.
Monsanto 81: Re: Exhibit No.2, page 10.14: Please provide the Idaho "monthly actual
(metered) energy" referenced in the footnote at the bottom of the page used to develop the
coincident peaks in executable spreadsheet format. Please include all monthly energy by class
used in this calculation, as well as any loss factors.
Monsanto 82: Please fully explain why the July 16,2010 peak for Idaho is 777 MW on Exhibit
No.2, page 10.14, while the Idaho class cost of service study (Exhibit No. 42, TAB 5, page 6)
shows a July CP of 568 MW. Please quantify and explain the basis for the addìtiona1209 MW.
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 7
Monsanto 83: Please fully explain why the May 17,2010 peak for Idaho is 508 MW on Exhibit
No.2, page 10.14, while the Idaho class cost of service study (Exhibit No. 42, TAB 5, page 6)
shows a May CP of380 MW. Please quantify and explain the basis for the additional 128 MW.
Monsanto 84: Please fully explain why the October 1,2010 peak for Idaho is 375 MW on
Exhibit No.2, page 10.14, while the Idaho class cost of service study (Exhibit No. 42, TAB 5,
page 6) shows an October CP of307 MW. Please quantify and explain the basis for the
additional 68 MW.
Monsanto 85: Re: Exhibit No.2, page 5.1.2: Please provide all supporting workpapers
quantifyng the $4,908,240 figue for Magcorp Reserve in both hard copy and in executable
spreadsheet format.
Monsanto 86: Re: Exhibit No.2, page 5.1.2: Please provide all supporting workpapers
quantifyng the $4,998,000 figue for Nucor in both hard copy and in executable spreadsheet
format.
Monsanto 87: Re: Exhbit No.2, page 5.1.2: Please provide all supporting workpapers
quantifyng the $17,086,750 figue for P4 Production in both hard copy and in executable
spreadsheet format.
Monsanto 88: Re: Exhibit No.2, page 5.1.2: Please provide all supporting workpapers
quantifyng the $5,091,045 figue for Roseburg Forest Products in both hard copy and in
executable spreadsheet format.
Monsanto 89: Re: Direct Testimony of Steven R. McDougal, page 7, lines 9-10: Please
provide the complete basis for the Company's treatment of all Class 1 DSM programs as system
resources in this filing. Provide all studies, analyses and workpapers used in arving at the
Company's recommendation.
Monsanto 90: Re: Direct Testimony of Steven R. McDougal, page 7, line 8: Mr. McDougal
appears to quote the Staffs comments in Case No. PAC-E-10-09 regarding the allocation of
''tese costs".
a. The Staffs comments actually say "these cost" (sic) at page 5. To which "cost" does Mr.
McDougal believe the Staff is referng to in its comments: all Class 1 DSM programs, or
just the Idaho Irrgation Load Control Program? Please explain your answer.
b. At page 7 of its comments in that same case referenced by Mr. McDougal, the Staff
provides the following recommendation: "Staff recommends the 2010 Protocol be
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 8
adopted with the modification for the Idaho Irrgation Load Control Program. Costs
associated with this program should be allocated on a system basis." Does Mr.
McDougal agree that the Staff's recommendation in Case No. PAC-E-1O-09 relates only
to the Idaho Irrgation Load Control Program? If not, please explain.
Monsanto 91: Re: Exhibit No. 42, TAB 5 - Page 7: Please fully explain the apparent anomaly
in the June CP of Special Contract 2 of 1,276 kW.
Monsanto 92: Please confirm that in 2010 Monsanto was curtailed on August 2, 4,5,6, 7, 8, 9,
10, 11, 12, 13, 14, 15, 16, 18,20,21,23,24,25,26,27,28,30, and 31.
Monsanto 93: Please confirm that the 2010 coincident peak for August occured on August 17.
Monsanto 94: Please fully explain why Monsanto was not curtailed on the day of the August
2010 coincident peak.
Monsanto 95: Please confirm that Monsanto must stand ready to be curailed or interrpted in
all months of the year.
Monsanto 96: In order for the Company to recognize that a customer's load is interptible or
curailable, must that load be actually interpted or curtailed at the time of monthly system peak
durng the test period?
Monsanto 97: If the Company historically curtails an interrptible customer only durng certain
months of the year, would it then be reasonable for the customer to stand ready for curtailments
durng only those specific months?
Monsanto 98: Assume Monsanto and the Company can agree to a "Special Contract without
Ancilary Servce Contract Attbutes" for the 67 MW of economic curailment. How would Mr.
McDougal propose the jurisdictional study be revised (according to Appendix D of the 2010
Protocol) in order to recognze Monsanto's reduction in load? How would an event such as what
happened in August 2010 be handled? Would the Company claim that Monsanto should be
indirectly penalized through a higher than otherwise allocation because it was not actually
curtailed on the hour of the monthly system peak in August?
Monsanto 99: Are the monthly coincident peaks shown for Monsanto in Exhibit No. 42 the
same monthly coincident peaks for Monsanto that have been included in Exhibit NO.2? In other
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER. 9
words, can we assume that the Idaho monthly coincident peaks in Exhibit NO.2 include
Monsanto loads as presented in Exhibit No. 42. Why or why not?
JI-
DATED this 2/ day of June, 2011.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By~(J.~
RANDALL. BUDil
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER -10
CERTIFICA~Ef.F MAILING
I HEREBY CERTIFY that on this 3d day of June, 2011, I sered a tre, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretar (original and 3)
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
E-mail: jjewell(ipuc.state.id.us U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
ted. westonCipacificorp.com
E-Mail
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
daniel.solanderCipacificorp.com
E-Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Fax: [phone]
datareguestCipacificorp.com E-Mail
Maurce Brubaker
Katie Iverson
Brubaker & Associates, Inc.
1215 Fer Ridge Parkway, Suite 208
St. Louis, M063l4l
mbrubakerCiconsultbai.com
kiversonCiconsultbai.com
E-Mail
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
jim.r .smithCimonsanto.com E-Mail
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER. 11
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
P.O. Box 1391
Pocatello, Idaho 83204-1391
elo(ßracinelaw.net
Gar Kajander
Manager, Energy Procurement
Monsanto Company
800 N. Lindbergh Blvd., Z C2NF
St. Louis, Missouri 63 i 67
Gar.r.kajander(ßmonsanto.com
Rick Anderson
Energy Strategies, LLC
215 S. State Street, #100
Salt Lake City, Utah 84111-2322
randerson(ßenergystrat.com
E-Mail
E-Mail
E-Mail
~~c~
RAALL C. BUDGE ~
MONSANTO COMPANY'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER. 12