20130228Monsanto 1-19 to PAC.pdf

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LAW OFFICES OF
RACINE OLSON NYE BUDGE & BAILEY
W. MARCUS W. NYE CHARTERED RANDALL C. BUDGE
JOHN A. BAILEY, JR. BOISE OFFICE
JOHN R. GOODELL 201 EAST CENTER STREET 101 SOUTH CAPITOL
JOHN B. INGELSTROM POST OFFICE BOX 1391 BOULEVARD, SUITE 300
DANIEL C. GREEN POCATELLO, IDAHO 83204-1391 BOISE, IDAHO 83702
BRENT 0. ROCHE ______________ TELEPHONE: [phone]
KIRK B. HADLEY FACSIMILE: [phone]
FRED J. LEWIS TELEPHONE [phone]
ERIC L. OLSEN FACSIMILE [phone] IDAHO FALLS OFFICE
CONRAD J. AIKEN 477 SHOUP AVENUE
RICHARD A. HEARN, M.D. SUITE 107
LANE V. ERICKSON www.radnelaw.net POST OFFICE BOX 50698
FREDERICK J. HAHN, III IDAHO FALLS, ID 83405
PATRICK N. GEORGE TELEPHONE: [phone]
SCOTT J. SMITH FACSIMILE, [phone]
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN ALL OFFICES TOLL FREE
DAVID E. ALEXANDER [phone]
CANDICE M. MCHUGH SENDER'S E-MAIL ADDRESS: [e-mail]
CAROL TIPPI VOLYN
JONATHAN M. VOLYN
THOMAS J. BUDGE LOUIS F. RACINE (1917-2005)
BRENT L. WHITING WILLIAM D. OLSON, OF COUNSEL
DAVE BAGLEY JONATHON S. BYINGTON, OF COUNSEL
JASON E. FLAIG
FERRELL S. RYAN, III 1-. February 26, AARON A. CRARY
JOHN J. BULGER
BRETT R CAHOON
NOLAN E. WITTROCK
Mrs Jean Jewell, Secretary
Idaho Public Utilities Commission rl
P.O.Box 83720
Boise, Idaho 83720-0074
Re PAC-E-13-03 (ECAM)
Dear Jean:
Enclosed for filing in the captioned matter please find the original and three copies of
Monsanto Company's First Data Requests to Rocky Mountain Power. Thank you for your
assistance.
Sincerely,
1DRRANDALL C. BUDGE
RCB:rr
Enclosures
cc: Ted WestonIRMP
Yvonne Hogle/RMP
S
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: [phone]
Fax: [phone]
Attorneys for Intervenor Monsanto Company
nroo t' c.rfl
.0 IIH C
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR AUTHORITY )
TO INCREASE RATES BY $2.2 MILLION TO )
RECOVER DEFERRED NET POWER COSTS ) Case No. PAC-E-13-03
THROUGH THE ENERGY COST ADJUSTMENT )
MECHANISM )
MONSANTO COMPANY'S FIRST DATA REQUESTS
TO ROCKY MOUNTAIN POWER
MONSANTO COMPANY, by and through their attorneys, hereby submits this First Data
Request 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 data requests received from Commission Staff and
other parties. Please consider this to be a continuing request and supplement your response as
additional requests are received.
Monsanto 2: Please provide a copy of your responses to the data requests from Commission
Staff and other parties. Please consider this to be a continuing request and supplement your
response as additional requests are received.
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER - I
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Monsanto 3: Please provide a copy of your responses to requests conveyed to Rocky Mountain
Power other than through formal data requests from Commission Staff and other parties. Please
consider this to be a continuing request and supplement your response as additional requests are
received.
The following questions pertain to the Direct Testimony of Brian S. Dickman:
Monsanto 4: For line 15 of "ID Actual Loads" of Exhibit 1, please provide all supporting
workpapers used in the development of the monthly energy amounts. Also, please provide a
narrative of how and where these loads are metered, measured and adjusted, if so.
Monsanto 5: For line 26 of "ID Actual Loads" of Exhibit 1, please provide an explanation of
the large percentage differences shown for the adjustment factors, both positive and negative.
Please expand this explanation beyond the standard explanation that these loads are developed
for different purposes and with different methodologies. For example, does the Company have
any explanation why adjustment factor is 23% in June, and -13% in August? Are there different
assumptions as to customer load? Does the Company still maintain that these differences are
entirely due to moving wholesale energy?
Monsanto 6: 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 7: Please provide a comparison of all budgeted thermal planned outages and actual
planned 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 thermal plant outage for a particular NERC outage code
that exceeded the industry average for like kind plants for the ECAM test year. If the Company
exceeded the industry average for a particular NERC code, please provide the total MWH
exceeded.
Monsanto 9: Please provide a copy of all internal reports that discuss operational problems with
any component of the Company's generation fleet during the ECAM test year.
Monsanto 10: Please provide a monthly summary of the amount of hydro generation lost from
forced outages during the ECAM test year and a step by step discussion of how the information
was calculated.
Monsanto 11: Please provide a monthly summary of the amount of thermal generation lost
from forced outages during the ECAM test year and a step by step discussion of how the
information was calculated.
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER -2
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Monsanto 12: Please provide a copy of the Company's hourly generation logs by plant for the
ECAM test year.
Monsanto 13: Please provide actual hourly wholesale market prices for each market the
Company transacts.
Monsanto 14: Please provide the hourly contingency reserves (spin and ready) carried on each
resource during the ECAM test year.
Monsanto 15: Please provide the electric and natural gas forecasts used in the base NPC as
described at line 1, page 11 of Mr. Dickman's testimony.
Monsanto 16: Please provide the actual wholesale electricity and natural gas prices for the
deferral period referenced by Mr. Dickman at line 22, page 10 and line 1, page 11 of his
testimony. Please provide actual monthly average numbers for all pricing hubs.
Monsanto 17: Please provide all workpapers supporting the statement at lines 2-3, page 11 of
Mr. Dickman's testimony.
Monsanto 18: Please provide Monsanto access to all GRID models supporting the direct
testimony of Mr. Dickman.
Monsanto 19: Please provide copies of all GRID model inputs for all GRID models supporting
the direct testimony of Mr. Dickman.
DATED this 7,1 day of February, 2013.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By
- RANDALL C. B GE
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER -3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this Z,,L day of February, 2013, 1 served a true, 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: [e-mail] U.S. Mail
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111 E-Mail
[e-mail]
Yvonne Hogle
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111 E-Mail
[e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Fax: [phone]
datareguest(pacificorp.com E-Mail
Maurice Brubaker
Katie Iverson
Brubaker & Associates, Inc.
1215 Fern Ridge Parkway, Suite 208
St. Louis, MO 63141
[e-mail] E-Mail
[e-mail]
RANDALL C. BUE
MONSANTO COMPANY'S FIRST DATA REQUEST FOR ROCKY MOUNTAIN POWER -4