20120309PAC to Monsanto 1,6,9-12,16-18,24,27,28,30.pdf

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~~;~OUNTAIN RECEIVED
20'2 MAR -9 AMll: 08
201 South Main. Suite 2300
Salt Lake City. Ut 84111
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UTILITIESMarch 8, 2012
Radall C. Budge, ISB No. 1949
P.O. Box 1391; 201 E. Center
Pocatello, Idao 832041391
rcblIracinelaw.net (C)
RE: ID PAC-E-12-03
Monsanto 1 st Set Data Request (1-30)
Please fid enclosed Rocky Mounta Power's responses to Monsto 1 st Set Data Requests 1, 6,
9-12, 16-18,24,27,28, and 30. Also provided is Attchment 16. Provided on the enclosed
Confdential CD ar Confdential Attchments 1, 6, 12, 17, 18, and 28. Confidential information
is provided subject to the tes and conditions of the protective ageement in ths proceeding.
If you have any questions, please feel fre to call me at [phone].
Sincerely,-J,~q~/~
J. Ted Weston
Manager, Reguation
Enclosure
C.c.: Jea Jewell/UC (4 CDs) jean.jewelllIpuc.daho.gov (C)
Neil PricelIPUC neil.pricelIpuc.idaho.gov (C)
Maurce Brubaker/Monsanto mbrubakerlIconsultbai.com
Kate IversonIonsto kiversonlIconsultbai.com (C)
James R. Smithonsanto jim.r.smith~onsanto.com
Mark Widmer/Monsanto nweclIonlinenw.com (C)
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PAC-E-11-121R0cky Mounta Power
March 8, 2012
Monsanto Data Request 1
Monsanto Data Request 1
Please provide a copy of all Root Caus anyses prepared for the ECAM test
year.
Response to Monsanto Data Request 1
Please refer to Confidential Atthment Monsanto 1. Confdential information is
provided subject to the term and conditions of the protective agreement in ths
proceeding.
Recordholder:
Sponsor:
Grgory N. Duvall
Grgory N. Duvall
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PAC-E-11-121R0cky Mountan Power
Marh 8, 2012
Monsanto Data Request 6
Monsanto Data Request 6
Please provide all information which demonstrates tht the West Valley Toll was
a prudent resoure acquisition includ but not limted to the traction
economic anysis and all informtion necessar to validate said anysis.
Response to Monsanto Data Request 6
Plea refer to Confdential Atthment Monsanto 6. The Company also has
available a GRID project responsive to ths data request, which ca be provided to
pares who request GRID access in ths proceeding. Confdential informtion is
provided subject to the terms and conditions of the protective agrment in this
proceeding.
Recordholder:
Sponsor:
Gregory N. Duvall
Gregory N. Duvall
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PAC-E-11-121R0cky Mountan Power
March 8, 2012
Monsto Data Request 9
Monsanto Data Request 9
Plea provide the amount of Bridger Coal expe for fie and citations tht are
included in adjusted ac coal expens for the test year.
Response to Monsanto Data Request 9
Pines and citations were removed from the ECAM filing as par of the
adjustments to acl expenses.
Recordholder:
Sponsor:
Grgory N. Duvall
Grgory N. Duvall
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P AC-E-11-121R0cky Mountan Power
March 8, 2012
Monsanto Data Request 10
Monsanto Data Request 10
Pleae provide the amount of legal fees for Energy West and Bridger Coal
Company that are included in adjusted actu coal expens for the ECAM test
year.
Response to Monsanto Data Request 10
Legal fees relating to fines and citations for Energy West and Bridger Coal
Company were excluded in the ECAM filing.
Recordholder:
Sponsor:
Gregory N. Duvall
Gregory N. Duvall
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PAC..-11-121R0cky Mounta Power
Marh 8, 2012
Monsato Data Request 11
Monsanto Data Request 11
Pleae provide the sta of the Company's 2011 FERC filing for new rates and a
copy.
Response to Monsanto Data Request 11
Below is a statu reprt for the Company's pendig trmission rate case at the
Federal Energy Reguatory Commission:
. Trasmission rae case fied May 26, 2011.
. FERC issued an order Augut 8, 2011, accepting the filing, supending it for a
five-month period until Decmber 25,2011, subject to refud, and
establishig hearng and settement procedures.
. Settlement meetigs commenced November 2011 and are still pendig. The
next settlement conferences have been set for April 23-24, 2012 in
Washington, DC.
. There is no statutory deadline for settement procedures to conclude or for the
Commsion to issue a fi order.
A copy of the Company's filing may be found on its OASIS website at the
following lin:
http://ww.oasis.pacificorp.com/oasis/ppw/RteCase20 11 FERCFiling.html
Recordholder:
Sponsor:
Gregory N. Duvall
Gregory N. Duvall
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PAC-E-11-121R0cky Mounta Power
March 8, 2012
Monsanto Data Request 12
Monsanto Data Request 12
Please provide a copy of the Company's hourly genertion logs by plant for the
ECAM test year.
Response to Monsanto Data Request 12
Please refer to Confdential Atthment Monsato 12. Confdential information
is provided subject to the terms and conditions of the protective agreement in ths
proceeding.
Recordholder:
Sponsor:
Grgory N. Duvall
Gregory N. Duvall
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PAC-E-11-12/Rocky Mounta Power
March 8, 2012
Monsanto Data Request 16
Monsanto Data Request 16
Please provide actu hourly wholese maket prices for each market the
Company tracts.
Response to Monsanto Data Request 16
Pleas refer to Attchment Monsanto 16, which provides the available ICE daly
prices for the makets in which the Company tranacts.
Recordholder:
Sponsor:
Gregory N. Duvall
Gregory N. Duvall
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PAC-E-11-12/Rocky Mounta Power
March 8, 2012
Monsanto Data Request 17
Monsanto Data Request 17
Pleae provide the workpape and sour documentation, which support the
PSCO wholesale sales adjustment.
Response to Monsanto Data Request 17
Pleas refer to Confdential Atthment Monsanto 17. Confdential inormation is
provided subject to the term and conditions of the protective agreement in ths
proceedng.
Recordho1der:
Sponsor:
Gregory N. Duvall
Grgory N. Duvall
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PAC-E-11-12/Rocky Mounta Power
March 8, 2012
Monsato Data Request 18
Monsanto Data Request 18
Please provide workpapers and source documentation, which support the Douglas
Wells purcha power adjusent.
Response to Monsanto Data Request 18
Please refer to Confdential Attchment Monsto 18. Confdential inormation
is provided subject to the terms and conditions of the protective ageement in ths
proceeding.
Recordholder:
Sponsor:
Grgory N. Duvall
Grgory N. Duvall
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PAC-E-11-12/Rocky Mounta Power
March 8, 2012
Monsanto Data Request 24
Monsanto Data Request 24
Pleae explai why the Company was agreeable to moving the Nàughton price
reopener from Janua 2011 to July 2010 and makg a lump sum prepayment
and provide the associated economic analysis which demonstes it was
beneficial to customers.
Response to Monsanto Data Request 24
At that time, the Company's long-term coal supply agreement with Chevron
Min's Kemmerer Mine extended thugh 2016 and included several market
price-reopeners. The next applicable re-opener was scheduled for Janua 1,
2011. Due to ficial pressures being incured at the mine, Chevron Ming
requested tht the Company consider advancing the market price re-opener date
earlier. The contract provided for an intial period of time for the paies to arve
at a negotiated price and if the pares were unble to agee to a new contrct
price, the Company would then be requied to issue a solicitation for both coal
supplies and tranporttion servce. Chevron Mig then would have the option
to match the resulti bid price for a five year perod sting Janua 2011.
The Company was successfu in negotiatig a new coal price with Chevron which
eliminated the 2011 market price reopener provision and enter into a new coal
supply agreement. In exchange for the below market price commitment from
Chevron Mining, the Company agred to move the effective contract price from
Janua 2011 to July 2010. The coal supply agreement delivers coal supplies
thugh December 2021.
The requestd economic anysis is highy confdential and will be mae available
for review at PacifiCorp's offces.
Recordholder:
Sponsor:
Gregory N. Duvall
Grgory N. Duvall
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PAC-E-11-12/Rocky Mountan Power
March 8, 2012
Monsanto Data Request 27
Monsanto Data Request 27
Please provide all support workpapers and anyses used in the development of
Table 1 of Mr. Duvall's Testiony, includig any electronic spreadheets with all
formulae intat
Response to Monsanto Data Request 27
The supportg workpapers for Table 1 is Exhbit 1. Please refer to the Sumar
tab in Exhbit 1, Excel file provided as Confdential Atthment Monsanto 28,
Ths tab ha the formula references where the data was pulled from Exhbit 1.
Recordholder:
Sponsor:
Gregory N. Duvall
Gregory N. Duvall
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PAC-E-11-121R0cky Mountan Power
March 8, 2012
Monsanto Data Request 28
Monsanto Data Request 28
Pleas provide Exhbit 1 electronically with all formulae intat.
Response to Monsanto Data Request 28
Pleas refer to Confdential Atthment Monsanto 28 for the confdential
workpapers of Gregory N. Duvall, includin the electronic version of Exhibit 1.
Confdential inormation is provided subject to the term and conditions of the
protective agreement in ths proceedig.
Recordholder:
Sponsor:
Gregory N. Duvall
Gregory N. Duvall
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PAC-E- I 1-12/Rocky Mounta Power
March 8, 2012
Monsato Data Request 30
Monsanto Data Request 30
Do the load shown on Exhbit 1 include any buy-thugh amounts? If so, how
much?
Response to Monsanto Data Request 30
Yes. The Monsato actu load and actu Idao jursdctional load include
approximately 5,293 MW and 8,285 MW of buy-though in October and
November 2011, respectively.
Recordholder:
Sponsor:
Gregory N. Duvall
Gregory N. Duvall