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Home My WebLink About20120305Monsanto to PAC 1-30.pdfJean D. Jewell, Secretar Idaho Public Utilities Commission P.O. Box 83720 Boise, Idaho 83720-0074 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 JOSHUA D. JOHNSON DAVID E. ALEXANDER STEPHEN J. MUHONEN CANDICE M. MCHUGH CAROL TIPPI VOLYN JONATHON S. BYINGTON JONATHAN M. VOLYN THOMAS J. BUDGE BRENT L. WHITING DAVE BAGLEY JASON E. FLAIG FERRELL S. RYAN, III AARON A. CRARY JOHN J. BULGER BRETT R CAHOON JEFFREY A. WARR Dear Mrs. Jewell: LAW OFFICES OF RACINE OLSON NYE BUDGE Be BAILEY CHARTERED 201 EAST CENTER STREET POST OFFICE BOX 1391 POCATELLO, IDAHO 83204-1391 BOISE OFFICE 10t SOUTH CAPITOL BOULEVARD~ SUITE 300 BOISE, IDAHO 83702TELEPHONE: (208) 395-0011 FACSIMILE: (208) 433~Ot67 TELEPHONE ~08) 2324101 FACSIMILE (208) 232-6109 IDAHO FALLS OFFICE 477 SHOUP AVENUE SUITE 107 POST OFFICE BOX 50698IDAHO FALLS, 1083405 TELEPHONE: (208) 528-6101FACSIMILE: (208) 528-6109 ww.racinelaw.net ALL OFFICES TOLL FREE (877) 232-8101SENDER'S E-MAIL ADDREss:rcb(§radnelaw.net LOUlS F. RACINE (1917-2005)WILLJAM D. OL.SON. OF COUNSEL February 29,2012 Re: Case No. PAC-E-12-03 :.:x IJ..o.c I'c:-,.:iJ::: IUl ;0m C)m~ma Enclosed for fiing please find the original and thee copies of Monsanto Company's First Set of Data Requests to Rocky Mountain Power. Than you for your assistance. RCB:rr Enclosures cc: Serice List ~ LLC.BUDGE Randall C. Budge, ISB No. 1949 Thomas J. Budge, ISB No. 7465 RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 RECEIVED 2012 MAR -SAM 9: 04 Attorneys for Interenor Monsanto Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ROCKY) MOUNTAIN POWER FOR AUTHORITY TO ) INCREASE RATES BY $2.6 MILLION TO RECOVER ) DEFERRED NET POWER COSTS THROUGH THE ) ENERGY COST ADJUSTMENT MECHANISM ) ) Case No. PAC-E-12-03 MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER MONSANTO COMPANY, by and though their attorneys, hereby submits this First 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 1. Please provide a copy of all Root Cause analyses prepared for the ECAM test year. Monsanto 2. Please provide the following information for liquidated damage payments received durng the ECAM test year: a. A sumar of the causes which lead to the liquidated damage payments. b. A summar of the amounts received for each liquidated damage payment. c. A descrption of how each liquidated damage payment was recorded on the Company's books. d. A copy of internal and exteral correspondence regarding each liquidated damage issue. MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER. 1 Monsanto 3. Please provide a copy of all internal reports that discuss major operational problems with any component of the Company's generation fleet during the ECAM test year. Monsanto 4. Please provide a monthly summar of the amount of hydro generation lost from forced outages durng the ECAM test year and a step by step discussion of how the information was calculated. Monsanto 5. Please provide the Company's latest calculated rate for system wind integration costs. Monsanto 6. Please provide all information which demonstrates that the West Valley Toll was a prudent resource acquisition including but not limited to the transaction economic analysis and all information necessary to validate said analysis. Monsanto 7. Please provide a comparson of all budgeted theral planed outages and actual planed outages in MWH by plant for the ECAM test period, including a detailed explanation of why individual plant budgets were exceeded for outages that exceeded budgets by 5,000 MWH or more. Monsanto 8. Please list any Company theral plant NERC outages for a paricular NERC outage code that exceeded the industr average for like kind plants for the ECAM test year. If the Company exceeded the industr average for a paricular NERC code, please provide the total MWH exceeded. Monsanto 9. Please provide the amount of Bridger Coal expense for fine and citations that are included in adjusted actual coal expense for the test year. Monsanto 10. Please provide the amount oflegal fees for Energy West and Bridger Coal Company that are included in adjusted actual coal expense for the ECAM test year. Monsanto 11. Please provide the status of the Company's 2011 FERC filing for new rates and a copy. Monsanto 12. Please provide a copy ofthe Company's hourly generation logs by plant for the ECAM test year. Monsanto 13. Please provide a summar of employee issues experienced by the Company on outages that occurred during the ECAM test year, including the name of the unit and the amount of generation lost due to employee issues. MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 2 Monsanto 14. Please provide a summary which includes the amount and an explanation of each adjustment made to actual NPC to derive adjusted actual NPC for the ECAM test year. Monsanto 15. Please provide the hourly contingency reserves (spin and ready) cared on each resource during the ECAM test year. Monsanto 16. Please provide actual hourly wholesale market prices for each market the Company transacts. Monsanto 17. Please provide the workpapers and source documentation, which support the PSCO wholesale sales adjustment. Monsanto 18. Please provide workpapers and source documentation, which support the Douglas Wells purchase power adjustment. Monsanto 19. Please provide workpapers and source documents which support the Dave Johnston coal expense adjustments for December and November. Monsanto 20. Please provide workpapers and source documents which support the Colstrp coal expense adjustment for Februar. Monsanto 21. Please provide workpapers and source documents which support the Huntington coal expense adjustments for all months except Januar, October and Novembtt. Monsanto 22. Please provide workpapers and source documents which support the Jim Bridger coal expense adjustments for all months except September, October and November. Monsanto 23. Please provide workpapers and source documents which support the Naughton coal expense adjustments for all months except December and Augut. Monsanto 24. Please explain why the Company was agreeable to moving the Naughton price reopener from Januar 2011 to July 2010 and making a lump sum prepayment and provide the associated economic analysis which demonstrates it was beneficial to customers. Monsanto 25. Please provide a breakdown of the renewable generation shown in Exhbit 1 by month by plant. Monsanto 26. Please provide the all-in ECAM test period revenue requirement of each project included in the renewable resource adder in $/MWh. MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER. 3 Monsanto 27. Please provide all supporting workpapers and analyses used in the development of Table 1 of Mr. Duvall's Testimony, including any electronic spreadsheets with all formulae intact. Monsanto 28. Please provide Exhibit 1 electronically with all formulae intact. Monsanto 29. Please explain the difference between "Actual Tariff Customer Load" and "Tarff Customer Base Load" as shown on Exhibit 1, lines 6-9 and 14-17. Please provide the source and all workpapers associated with these loads. Monsanto 30. Do the loads shown on Exhibit i include any buy-through amounts? If so, how much? DATED this 1 st day of March, 2012. RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED BL~t'~ RANDALL C. BUDGE MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 4 CERTIFICATE OF MAILING I HEREBY CERTIFY that on this 1 st day of March, 2012, I sered a true, 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: jjewellêpuc.state.id.us U.S. Mail Ted Weston Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake City, Utah 84111 ted. weston(ipacificorp.com E-Mail Yvonne Hogle Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake city, Utah 84111 vvonne.hogle(ipacificorp.com E-Mail Data Request Response Center PacifiCorp 825 NE Multnomah, Suite 2000 Portland, Oregon 97232 Fax: 503-813-6060 datareguest(ipacificorp.com E-Mail Neil Price, Deputy AG Idaho Public Utilities Commission P.O. Box 83720; 472 W. Washington BoiseID 83720-0074 Neil. price(ipuc.idaho. gov E-Mail Maurice Brubaker Katie Iverson Brubaker & Associates, Inc. 1215 Fern Ridge Parkway, Suite 208 St. Louis, MO 63141 mbrubaker(iconsultbai.com kiverson(iconsultbai.com E-Mail MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 5 James R. Smith Monsanto Company P.O. Box 816 Soda Springs, Idaho 83276 jim.r.smithifmonsanto.eom E-Mail ~tLE:~RAUDGE MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER - 6