20110721Monsanto 100-120 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, III
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(§racinelaw.net
July 19,2011
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.-167
IDAHO FALLS OFFICE
477 SHOUP AVENUESUITE 107
POST OFFICE BOX 50698
IDAHO FALLS, 1083405TELEPHONE: [phone]'01
FACSIMILE: [phone]
ALL OFFICES TOLL FREE
(877) 232-61 01
F. RACINE (1917-2005)
D. OLSON, OF COUNSEL¡;--
~f'
;;m('rn.i:J
co..f'Q
Please find enclosed for filing the original and three copies of Monsanto Company's Third
Data Requests to Rocky Mountain Power.
Thank you for your assistance.
Sincerely,
:t!iE
RCB:rr
Enclosures
cc: Service List (w/encls.)
J'.
.,
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]
D
201l JUL 2/
AH 8: 2/
Attorneys for Intervenor 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 THIRD 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 Utility
Commission's Rules of Procedure, IDAPA 31.01.01, as follows:
Monsanto 100: Please explain and reconcile the difference between the General Business
Revenues of$218,197,789 shown on page 1, line 2 of Exhibit NO.1 and the State ofIdaho
Anual Revenue of $217,446,172 shown on page 2, line 12, column C of Exhibit 40.
Monsanto 101: Does the Company agree to allow Monsanto to use discovery responses Mr.
Pesau has in his possession from the following dockets: Washington No. UE-090205; Idaho
PAC E-1O-07; Wyoming PSC Nos. 20000-341-EP-09, 20000-333-ER-08, 20000-352-ER-09,
20000-384-ER-10 and 20000-389-EP-11; and Utah 10-035-124? Ifnot, then provide responses
to the questions asked in those dockets for use in this Idaho case.
MONSANTO COMPANY'S THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER. 1
Monsanto 102: Please provide all workpapers in electronic format with all formulas intact for
the Company's avoided costs shown in Tables 7 through 10 included in Chapter 2 of
PacifiCorp's 2011 IRP Addendum, dated June 27,2011.
Monsanto 103: Re: page 4 ofMr. Walje's Direct Testimony: Please provide the source and all
supporting workpapers of the 2.2 milion MWh in 1982 and 3.3 milion MW in 2010 for the
Idaho jursdiction.
Monsanto 104: Re: page 4 of Mr. Walje's Direct Testimony: Please provide the MWh loads
for each PacifiCorp jurisdiction for 1980 though 2010 that is on the same basis as the 2.2
milion and 3.3 millon MW figues shown for Idaho.
Monsanto 105: Re: page 4 ofMr. Walje's Direct Testimony: Please provide all supporting
workpapers, reports, studies and analysis regarding the large industral customer that wil add 40
MW of additional load to PacifiCorp's Idaho jurisdiction.
Monsanto 106: Re: page 4 of Mr. Walje's Direct Testimony: With respect to the new 40 MW
industral customer, under what rate schedule wil this new load be sered and how will RMP
plan to sere this new customer?
Monsanto 107: Re: page 4 of Mr. Walje's Direct Testimony: Please explain the ''teral
optimizer" which the witness notes that Monsanto has recently anounced plans to add, and
provide the source(s) that claim a "theral optimizer" wil be installed by Monsanto.
Monsanto 108: Re: page 4 of Mr. Walje's Direct Testimony: Please provide all supporting
workpapers, reports, studies and analysis regarding Mr. Walje's conclusion that Monsanto wil
"most likely increase energy consumption" as a result of its plans to add a "thermal optimizet'.
Please include in this support a full description of the increased energy amounts, including the
type of energy (natural gas, electrcity, etc.) and impact on Monsanto's load requirements from
RMP.
Monsanto 109: Re: page 4 of Mr. Walje's Direct Testimony: Please provide all workpapers,
studies, reports and analysis that support Mr. Walje's testimony that "Idaho has been and
continues to be the third fastest growing jurisdiction in the Company's servce terrtory." Please
also provide all the supporting analysis showing the growth rates of each of its jursdictions used
to ascertain the raning ofIdaho previously and today.
MONSANTO COMPANY'S THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 2
Monsanto 110: Re: page 4 of Mr. Walje's Direct Testimony: On April 15, 2011, the Company
filed Reply Comments in Case No. PAC-E-10-09 claiming that "Idaho is currently the second
fastest growing jursdiction in the Company's service tertory." (page 6). Mr. Walje's testimony
filed on May 27,2011, however, states that Idaho "has been and continues to be the third fastest
growing jurisdiction." Please explain and reconcile why the growth rate ofIdaho was seen as the
second fastest in April, but now is the third fastest.
Monsanto 111: Re: page 3 and 4 of Mr. Walje's Direct Testimony: How much load growth
(both demand and energy) has the Company included in its most recent integrated resource plan
for: (a) Monsanto's theral oxidizer and (b) the large industrial customer with plans to locate in
Idaho?
Monsanto 112: Do any other witnesses describe in more detail the points raised by Mr. Walje at
page 4, lines 6 through 16? If so, please identify the witness or witnesses.
Monsanto 113: Re: page 14, line 2-3 of Mr. Duvall's Direct Testimony: Please provide all
workpapers, studies, reports and analysis supporting the increase of 1.2 percent in the total
Company system load compared to loads reflected in the 2010 GRC, and provide the total
system loads by jursdiction.
Monsanto 114: Re: page 14, lines 19 - 21 of Mr. Duvall's Direct Testimony: Please provide
the update ofNPC from the final decision of the BP A rate cases when available.
Monsanto 115: Please provide a copy of the energy efficiency (Class 2 demand-side
management) decrement study referenced at p. 13 ofPacifiCorp's 2011 IRP Addendum, dated
June 27, 2011. In your response, please include all workpapers in electronic format with all
formulas intact.
Monsanto 116: Re: Mr. Paul H. Clements' Direct Testimony: Please provide the following
information for the GRID and Front Offce models used in the economic evaluation of
Monsanto's curailment:
a. A listing of all assumptions used in each model;
b. Complete executable copy of each model in native format with all formulas intact;
c. All workpapers and supporting documentation for the forward price cures; and
d. All other workpapers supporting the modeling and calculations of the value of
interrptible power.
MONSANTO COMPANY'S THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 3
Monsanto 117: Re: Mr. Clements' Direct Testimony: If not provided in response to other data
requests, please provide for the "Front Office Model" the following:
a. The generating units evaluated to calculate the value of operating reserves, the number of
megawatts of reserves evaluated on each unit, the incremental cost for each unit and the
market price.
b. The name and incremental cost ofthe unit(s) selected as the unit(s) "in-the-money" for
the operating reserve valuation;
c. All assumptions in the operating reserve valuation used to deterine the incremental cost
of each unit evaluated including heat rates, gas prices and variable operating and
maintenance expenses;
d. The source of the market prices used in the valuation of operating reseres and the date
the market price forecast was prepared;
e. The hours (per day, per month and per year) and loads of Monsanto modeled in the
valuation of operating reserves;
f. The market price values for each hour in the year, with the paricular 850 highest priced
hours identified in the economic curailment valuation;
g. The source of the market price values used in the valuation of the economic curtailment
and the date the market price forecast was prepared;
h. A descrption and explanation of any adjustment made in the Front Office Model for lost
revenues; and
1. A description, derivation, and explanation of any discount rate used in the Front Offce
ModeL.
Monsanto 118: Re: Mr. Clements' Direct Testimony: If not provided in response to other data
requests, please provide the following information with respect to the "GRID Model" evaluation:
a. Complete copies of both GRID model runs used in the evaluation;
b. A detailed listing of all assumptions for each model;
c. A copy of all standard output reports for each model;
d. Workpapers derving the value of the interrptible products; and
e. A detailed explanation of how the Monsanto curtailment products are modeled in the
second GRID model run (the "with Monsanto contract" run.)
Monsanto 119: Follow-up to Monsanto Data Request 2.82. In explaining the difference
between the July coincident peak in the JAM study and the Idaho Class COS study, an irrgation
curailment adjustment of 144 MW was made to the July 16, 2010 peak in the JAM study but
was not made in the Idaho Class COS study. Given the treatment of irrgation loads in the cost
studies since the last general rate case, why wasn't this 144 MW adjustment made in the Idaho
Class COS study? Shouldn't the curailment amount be added back to the irrgation class July
MONSANTO COMPANY'S THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 4
peak for purposes of class allocation since the cost of the irrgation program is now allocated to
as a system resource? If not, why not? If so, please provide a corrected Idaho Class COS study.
Monsanto 120: Please provide a description and quantification of the three interptible
customers included in Table 5.2 referenced at p. 85 ofPacifiCorp's 2011 IRP dated March 31,
2011. In your response, please include all workpapers in electronic format with all formulas
intact.
DATED this g~ay of July, 2011.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By ~ (i~
RANDALL C. BUDG
MONSANTO COMPANY'S THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER. 5
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this -ß~ay of July, 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, Secretar (original and 3)
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
E-mail: jjewell(fpuc.state.id.us U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
ted. weston(fpacificorp.com
E-Mail
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
danel.solander(fpacificorp.com
E-Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Fax: [phone]
datareguest(fpacificorp.com E-Mail
Maurice Brubaker
Katie Iverson
Brubaker & Associates, Inc.
1215 Fer Ridge Parkway, Suite 208
St. Louis, MO 63141
mbrubaker(fconsultbai.com
kiverson(fconsultbai.com
E-Mail
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
jim.r.smith(fmonsanto.com E-Mail
MONSANTO COMPANY'S THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER. 6
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
P.O. Box 1391
Pocatello, Idaho 83204-1391
e1o(ßracinelaw.net
E-Mail
Gar Kajander
Manager, Energy Procurement
Monsanto Company
800 N. Lindbergh Blvd., Z C2NF
St. Louis, Missour 63167
Gar.r .kajander(ßmonsanto .com
E-Mail
Rick Anderson
Energy Strategies, LLC
215 S. State Street, #100
Salt Lake City, Utah 84111-2322
randerson(ßenergystrat.com
E-Mail
£iM i-,~RANDALL C. BUDG~
MONSANTO COMPANY'S THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 7