20171120Iverson Direct - Redacted.pdf

RECEIVED
2917NOV20 PM 3:27BEFORETHEPUBLICUTILITIESCOMMISSIONOFIDAHO
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR A )
CERTIFICATE OF PUBLIC )CASE NO.PAC-E-17-07
CONVENIENCE AND NECESSITY AND )
BINDING RATEMAKING TREATMENT )
FOR NEW WIND AND TRANSMISSION )
FACILITIES
REDACTED Direct Testimony and Exhibits Of
Kathryn E.Iverson
On Behalf of
Monsanto Company
November20,20 17
Project 10465
ORIGINAL
ROCKY MOUNTAIN POWER
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.PAC-E-17-07
Table of Contents to the
Direct Testimony of Kathryn E.Iverson
I.INTRODUCTION AND SUMMARY ................................................l
II.PROPOSED RATEMAKING TREATMENT.................................................4
Exhibits:
Exhibit 201:Qualifications of Kathryn E.Iverson
Exhibit 202:Monsanto Company's Second Data Request to Rocky Mountain Power
Exhibit 203:Annual Cost (Benefit)of Combined Projects
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Monsanto Company
ROCKY MOUNTAIN POWER
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.PAC-E-17-07
Direct Testimony of Kathryn E.Iverson
l I.INTRODUCTION AND SUMMARY
2 Q.PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
3 A.Kathryn E.Iverson,19540 N.Wessex Drive,Surprise,Arizona 85387.
4 Q.WHAT IS YOUR OCCUPATION?
5 A.I am a consultant in the field of public utility regulation with the firm of Brubaker &
6 Associates,Inc.,which specializes in energy,economic,and regulatory consulting.Our
7 main offices are at 16690 Swingley Ridge Road,Suite 140,Chesterfield,Missouri 63017.
8 Q.PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND
9 EXPERIENCE.
10 A.A description of my educational background and experience is set forth in Exhibit 201.
11 Q.ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS PROCEEDING?
12 A.I am testifying on behalf of Monsanto Company ("Monsanto").Monsanto operates
13 facilities within the service territory of Rocky Mountain Power ("RMP,""PacifiCorp,"or
14 the "Company"),from whom it purchases electricity and energy services.
15 Q.WHAT IS THE PURPOSE OF YOUR TESTIMONY?
16 A.I introduce the Monsanto witnesses who have conducted extensive analysis and are
17 providing testimony in this proceeding on the 860 MW of new wind facilities in eastern
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Monsanto Company
l Wyoming ("Wind Projects")and the 140-mile,500 kilovolt Aeolus-to-Bridger Anticline
2 transmission line and accompanying transmission facilities (the "Transmission
3 Projects").'I also address RMP's request for binding ratemaking treatment of the
4 Combined Projects.
5 Q.WHAT OTHER WITNESSES WILL BE TESTIFYING ON BEHALF OF
6 MONSANTO?
7 A.Monsanto is sponsoring testimony from the following witnesses,both employed by
8 Brubaker and Associates,Inc.:
9 Mr.Nicholas L.Phillips provides testimony regarding the Combined Projects and
10 the associated economic analysis presented and relied upon by RMP to justify its
11 proposal.Mr.Phillips'testimony discusses the risks associated with RMP's proposal and
12 illustrates how the proposed economics evaporate under modest changes to the
13 assumptions.While Mr.Phillips'ultimate recommendation is to deny RMP's request for
14 a Certificate of Public Convenience and Necessity ("CPCN"),he identifies certain
15 customer protections upon which the Idaho Public Utilities Commission ("Commission")
16 condition its approval if the Commission instead chooses to grant the CPCN requested by
17 RMP.
18 Mr.James R.Dauphinais provides testimony regarding the Transmission Projects
19 portion of RMP's request.Mr.Dauphinais specifically questions the need and identifies
20 risks associated with the proposed Transmission Projects.
'The Wind Projects and Transmission Projects are referredcollectively as the "Combined
Projects."
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Monsanto Company
l Q.TO THE EXTENT THAT YOUR TESTIMONY OR THE TESTIMONY OF THE
2 OTHER MONSANTO WITNESSES DOES NOT ADDRESS AN ISSUE,SHOULD
3 THAT BE INTERPRETED AS AN ENDORSEMENT OF RMP'S POSITION?
4 A.No.Our silence with respect to any position taken by RMP in its application or direct
5 testimony in this proceeding should not be interpreted as an endorsement of that position.
6 Q.HAVE MONSANTO WITNESSES RELIED UPON DATA RESPONSES
7 PROVIDED BY THE COMPANY IN OTHER JURISDICTIONS?
8 A.Yes.Both Mr.Phillips and Mr.Dauphinais have relied upon RMP responses to requests
9 made in Docket No.20000-520-EA-17 (Record No.14781)before the Wyoming Public
10 Service Commission ("Wyoming New Wind/Transmission Docket").Monsanto
11 requested these documents in its Second Data Request to the Company in this
12 proceeding.A copy of Monsanto's request is included as Exhibit 202.
13 Q.PLEASE SUMMARIZE YOUR CONCLUSIONS.
14 A.I offer the following conclusions and recommendations:
15 1.Based on the Low Gas,Zero CO2 scenario analysis of the Combined Projects,
16 customers will experience some nominal annual benefit for the years 2024
17 through 2030,but would be worse off every year thereafter.In the near term,they
18 are also worse off,and on a net present value basis there is no cumulative benefit
19 to customers.As explained by Mr.Phillips,given the lower expectations for
20 natural gas prices,the absence of a federal CO2 emission policy,and RMP's
21 historical overestimation of natural gas prices,Monsanto recommends using the
22 Low Gas,Zero CO2 as the primary reference point.
23 2.Based on Monsanto's review of RMP's economic analysis,Monsanto
24 recommends the Commission deny RMP's request for a CPCN for the Combined
25 Projects.Because the Combined Projects are discretionary,uneconomical and
26 pose unacceptable risks to customers,binding ratemaking treatment is neither
27 reasonable or necessary and should be denied.
28 3.If the Commission should choose to approve the CPCN and grant binding
29 ratemaking treatment,then I recommend the creation of a new tariff rider entitled
30 Combined Projects Tracking Mechanism ("CPTM")to separately track and bill
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Monsanto Company
l customers for the Combined Projects.Under this more transparent approach,
2 customers can clearly identify the cost impacts from this unique and significant
3 expenditure,and separately monitor the expected PTC benefits and investment
4 costs and expenses of the Combined Projects.
5 4.Since Monsanto recommends the Commission place conditions on the CPCN
6 approval,these conditions should be reflected in any tracking mechanism
7 approved for recovery.These conditions include:(a)recovery only for turbines
8 that are commercially operational in time to receive 100%of the PTC benefits
9 they are being constructed to capture;(b)a specific cap on the recovery of the
10 capital cost of the Combined Projects from retail ratepayers;(c)no recovery of
11 costs may be flowed through the CPTM if RMP ceases construction of either the
12 Transmission Projects or the Wind Projects since the two are inextricably linked;
13 and (d)the CPTM will provide Idaho ratepayers their share of the full PTC
14 benefit assuming at minimum a 35%federal corporate income tax rate and based
15 upon a net capacity factor for the Wind Projects.
16 H.PROPOSED RATEMAKING TREATMENT
17 Q.PLEASE DESCRIBE THE COMPANY'S YEAR-BY-YEAR PROJECTED COSTS
18 AND BENEFITS OF THE COMBINED PROJECTS.
19 A.Exhibit 25,and PacifiCorp's supporting workpaper "Gateway Results Direct Testimony,"
20 provides the nominal annual costs and benefits of the Combined Projects.Included in
21 that exhibit are projected costs and benefits as listed below:
Costs Benefits
Transmission and New Wind Assumed wheeling revenues
Capital Recovery (Return,Income .
..Production Tax Credit ("PTC")Tax,Depreciation and Property benefitsTax)
..Reductions in Net Power CostNew Wmd PPA (QF Project)("NPC")
Operation and maintenance (O&M).Avoidance of paying potentialexpensesfederalCO2OmiSSiORStaXCS
Other variable costs...Reductions in future system fixed
costs
22 The net of these projected costs and benefits are shown in Exhibit 203 in
23 Column (1)on a year-by-year basis.Page 1 presents PacifiCorp's results for the Medium
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Monsanto Company
l Gas,Medium CO2 SCenaTiO,and page 2 presents the results of the Low Gas,Zero CO2
2 scenario.When costs exceed benefits,the annual number is shown as positive number
3 (e.g.,years 2021 and 2022).When projected benefits exceed costs,the total is shown as
4 a negative number (e.g.,years 2025 and 2016).Column (2)shows the cumulative annual
5 impacts,while Column (3)shows the discounted annual impacts and Column (4)is the
6 cumulative net present value.For the period 2017 through 2050,the net present value for
7 the Medium Gas/Medium CO2 is a net benefit of $137 million,while the net present
8 value for the Low Gas/Zero CO2 iS DCÍ COst of $174 million.
9 Q.WHAT ARE CUSTOMERS PROJECTED TO EXPERIENCE ON A YEAR-BY-
10 YEAR BASIS?
11 A.With Low Gas prices (page 2)customers will experience some nominal annual benefit
12 for the years 2024 through 2030,but would be worse off every year thereafter.In the
13 near term (2021 through 2023),customers are also worse off.On a net present value
14 basis,there is no cumulative benefit.In fact,the highest cumulative net present benefit
15 does not occur until the year 2030 where it reaches a benefit of only $20 million,
16 compared to the $2.1 billion Combined Projects investment.
17 Q.IS THERE A REASON TO FOCUS ON THE LOW GAS,ZERO CO2 SCENARIO
18 RATHER THAN THE MEDIUM CASE PROPOSED BY RMP?
19 A.Yes.As explained by Mr.Phillips,given the lower expectations for natural gas prices,
20 the absence of a federal CO2 emission policy,and RMP's historical overestimation of
21 natural gas prices,Monsanto recommends using the Low Gas,Zero CO2 as the primary
22 reference point.
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Monsanto Company
l Q.PLEASE DESCRIBE THE RATEMAKING TREATMENT FOR THE
2 COMBINED PROJECTS WHICH THE COMPANY IS SEEKING COMMISSION
3 APPROVAL.
4 A.The Company requests approval of its proposal for binding ratemaking treatment for its
5 investment in the Combined Projects.In particular,RMP is proposing that its current
6 Energy Cost Adjustment Mechanism ("ECAM")tariff be expanded to include a new
7 Resource Tracking Mechanism ("RTM")and that costs and benefits of the Combined
8 Projects be tracked through this RTM and then included in the annual ECAM rate.
9 Q.SHOULD THE COMMISSION APPROVE THE BINDING RATEMAKING
10 TREATMENT FOR THE COMBINED PROJECTS?
11 A.No.Based on Monsanto's review of RMP's economic analysis,and in particular the
12 testimony of my colleague,Mr.Phillips,Monsanto recommends the Commission deny
13 RMP's request for a CPCN for the Combined Projects.Under the Company's proposal,
14 the Combined Projects present a high degree of risk that the claimed customer benefits
15 will not be realized,or that the Combined Projects will result in increased costs for
16 customers rather than net savings.Since the Combined Projects are discretionary and not
17 designed to fulfill any resource requirement or other needs,there must be a high degree
18 of confidence in achieving a positive outcome for customers.As proposed,the
19 Combined Projects do not meet that test.Because the Combined Projects are
20 discretionary,uneconomical and pose unacceptable risks to customers,binding
21 ratemaking treatment is neither reasonable or necessary and should be denied.
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Monsanto Company
l Q.IF THE COMMISSION SHOULD INSTEAD CHOOSE TO GRANT A CPCN,
2 WHAT ARE YOUR RECOMMENDATIONS FOR THE BINDING
3 RATEMAKING?
4 A.RMP proposes to incorporate the RTM in the existing ECAM in order to have "only one
5 tariff and a single line item on customer bills."2 If the Commission grants a CPCN,I
6 recommend the Company's binding ratemaking proposal be modified.
7 With an expected investment over $2.1 billion for the Combined Projects,a
8 special and independent tracking mechanism is warranted if the Commission grants the
9 CPCN and approves binding ratemaking.Consequently,I recommend the creation of a
10 new tariff rider entitled CPTM to separately track and bill customers for the Combined
11 Projects.Under this more transparent approach,customers can clearly identify the cost
12 impacts from this unique and significant expenditure,and separately monitor benefits,
13 investment costs and expenses of the Combined Projects until they are placed in base
14 rates.
15 Q.HAS RMP REQUESTED BINDING RATEMAKING TREATMENT FOR ITS
16 WIND REPOWERING INVESTMENTS IN CASE NO.PAC-E-17-06?
17 A.Yes.The Company is seeking Commission approval for binding ratemaking treatment
18 for wind repowering through a RTM.As such,the Company proposes to use the same
19 RTM as a component of the ECAM for both its wind repowering and the Combined
20 Projects.
2 Direct Testimonyof JeffreyK.Larsen,at p.7.
*Case No.PAC-E-17-06 is still ongoing with no CommissionOrder as of yet.
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Monsanto Company
l Q.DO YOU AGREE THAT BOTH THE WIND REPOWERING AND THE
2 COMBINED PROJECTS THAT ARE THE SUBJECT OF THIS PROCEEDING
3 BE RECOVERED THROUGH THE SAME TRACKING MECHANISM?
4 A No.Given that the wind repowering is related to existing generation,and that RMP
5 proposes to incorporate a surcharge cap on wind repowering,it seems reasonable to retain
6 the proposed RTM in Case No.PAC-E-17-06 for wind repowering as a component of the
7 ECAM tariff.However,having both the wind repowering and the Combined Projects
8 tracked together in one single RTM,and then lumped together in the ECAM as proposed
9 by RMP,would make unbundling and monitoring the impacts of these two distinct
10 projects (wind repowering and Combined Projects)difficult,if not impossible.
11 Consequently,it would be better to establish up-front a new CPTM for the express
12 purpose of recovering these new generation and transmission expenses if the Commission
13 grants the CPCN and binding ratemaking treatment.
14 Q.WHAT COSTS AND REVENUES WILL BE INCORPORATED IN THE CPTM?
15 A.Similar to the list included in the testimony of RMP witness Jeffrey Larsen,the deferral
16 for the Combined Projects in the CPTM will include the followingrevenue components:
17 Plant Revenue Requirement,consisting of capital investment,accumulated
18 depreciation reserve ("ADR"),accumulated deferred income tax ("ADIT"),
19 operation and maintenance expense,depreciation expense,property taxes and
20 Wyoming wind tax.
21 Wheeling revenues;
22 Production Tax Credits ("PTCs);and
23 Net Power Cost ("NPC")savings associated with the shareholders 10%share.
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Monsanto Company
l Q.HAS MONSANTO RECOMMENDED CONDITIONS ON THE CPCN
2 APPROVAL THAT SHOULD BE CONSIDERED IN DESIGNING THE CPTM?
3 A.Yes.First,the CPTM should only include recovery for turbines that are commercially
4 operational in time to receive 100%of the PTC benefits they are being constructed to
5 capture.If a turbine fails to be commercially operational in time to receive 100%of the
6 PTC benefits,it will be ineligible for inclusion in the CPTM and those turbine costs,
7 along with a capacity ratio share of any interconnection,transmission,distribution,and
8 accumulated funds used during construction ("AFUDC")costs will be disallowed.
9 Second,RMP's cost recovery on the capital cost of the Combined Projects from
10 retail ratepayers,inclusive of the new generation and transmission facilities,as well as
11 any interconnection costs,network upgrades,distribution costs,and AFUDC will be
12 capped at $1,683.49 million installed cost.Consequently at no time will the CPTM track
13 more than this capped amount.
14 Third,since the Transmission Projects and Wind Projects are inextricably linked,
15 no costs may be flowed through the CPTM if RMP ceases construction of either.For
16 example,Transmission Project costs and expenses may not be flowed through the CPTM
17 unless the Wind Projects are commercially operational.
18 And fourth,the CPTM will provide Idaho ratepayers their share of the full PTC
19 benefit as explained by Mr.Phillips,assuming at minimum a 35%federal corporate
20 income tax rate,and based on a net capacity factor of at least M for the Wind
21 Projects.Furthermore,ratepayers should be guaranteed receipt of the full grossed-up
22 value of the production tax credits without having to compensate RMP for return on any
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Monsanto Company
l deferred tax assets that may be created as a result of RMP's inability to
2 contemporaneously monetize PTCs to full value.
3 Q.HOW LONG WILL THE CPTM REMAIN IN EFFECT?
4 A.The CPTM is a tariff rider strictly in place to bridge the gap while Combined Project
5 facilities come on-line and before they are placed into rate base.For the most part,the
6 CPTM will operate similar to the wind repowering RTM,that is,after each Combined
7 Project wind and transmission facility is brought on-line and meets the conditions above,
8 the Company will defer the full amount of the capital investment,ADR,and ADIT
9 related to the facility in the CPTM.As explained by RMP witness Jeffrey Larsen,once
10 the Company transfers those facilities to rate base through a future general rate case,the
11 amount in rates will become the base plant balances,which will be subtracted from
12 capital investment in the CPTM.Once all Combined Projects are moved into base rates,
13 the CPTM will have served its purpose,and will no longer be necessary.
14 Q.HOW WILL THE CPTM REFLECT PTC BENEFITS FROM THE WIND
15 PROJECTS?
16 A.While the Wind Projects deferred balances remain in the CPTM,100%of their associated
17 PTC benefits will be included in the CPTM rather than in the ECAM.This will allow the
18 CPTM to reflect both costs and clearly identifiable benefits of the Wind Projects.Once
19 the Wind Projects are transferred to rate base in a general rate case,their PTC benefits
20 will then be tracked 100%in the ECAM just as all other wind turbines are currently
21 treated in Idaho.Any conditions placed upon Combined Project PTC benefits (federal
22 tax rate and capacity factor as explained by Mr.Phillips)would remain in place even
23 after the Wind Projects'PTC benefits are included in the ECAM.
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Monsanto Company
l Q.HOW SHOULD THE NPC SAVINGS ASSOCIATED WITH THE WIND
2 PROJECTS PORTION OF THE COMBINED PROJECTS BE HANDLED IN
3 THE CPTM?
4 A.As Wind Projects add additional zero-fuel-cost energy to the system,the total NPC will
5 be reduced.That lower NPC will flow through the ECAM,and 90%of the NPC benefits
6 will be credited to customers based on the ECAM sharing mechanism.Nothing needs to
7 be changed as a result of this case in order for Idaho ratepayers to reap the 90%of NPC
8 benefits from the Wind Projects.
9 However,in order to fully match the costs and benefits,the CPTM would also
10 need to pass on 100 percent of NPC benefits to customers in a manner similar to the
11 proposed RTM.To accomplish this,energy from the Wind Projects would be valued
12 using a monthly market price less wind integrationcosts,and the CPTM would pass 10%
13 of that value through to customers.This 10%crediting will continue until the Wind
14 Projects are included in base rates through a future general rate case.At that time,for
15 purposes of the NPC,the Wind Projects will be treated as all other wind facilities are
16 currentlytreated in the ECAM.
17 Q.WOULD THE CPTM BE FILED ANNUALLY?
18 A.Yes.The CPTM would be filed with the Commission each April 1,with a rate effective
19 date of June 1.In its annual filing,the Company would include information on facilities
20 added during the year,and would substantiate that all conditions are met for inclusion in
21 the CPTM.The filing would also include information on revenues collected from the
22 CPTM for the previous year and a true-up for over-or under-collection of the previous
23 year's balance.
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Monsanto Company
l Q.DOES THIS CONCLUDE YOUR DIRECT TESTIMONY?
2 A.Yes,it does.
REDACTED Iverson,Di -12
Monsanto Company
Monsanto Exhibit No.201
Case No.PAC-E-17-07
Page 1 of 3
Qualifications of Kathryn E.Iverson
1 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A Kathryn E.Iverson;17244 W.Cordova Court;Surprise,AZ 85387.
3 Q PLEASE STATE YOUR OCCUPATION.
4 A I am a consultant in the field of public utility regulation and an Associate with the firm
5 of Brubaker &Associates,Inc.("BAI"),energy,economic and regulatory consultants.
6 Q PLEASE SUMMARIZE YOUR EDUCATIONAL BACKGROUND AND
7 WORK EXPERIENCE.
8 A In 1980 I received a Bachelors of Science Degree in Agricultural Sciences from
9 Colorado State University,and in 1983,I received a Masters of Science Degree in
10 Economics from Colorado State University.
11 In March of 1984,I accepted a position as Rate Analyst with the consulting
12 firm Browne,Bortz and Coddington in Denver,Colorado.My duties included
13 evaluationof proposed utility projects,benefit-cost analysis of resource decisions,cost
14 of service studies and rate design,and analyses of transmission and substation
15 equipment purchases.
16 In February 1986,I accepted a position with Applied Economics Group,where
17 I was responsible for utility economic analysis including cogeneration projects,
18 computer modeling of power requirements for an industrial pumping facility,and
19 revenue impacts associated with various proposed utility tariffs.In January of 1989,I
20 was promoted to the position of Vice President.In this position,I assumed the
21 additional responsibilities of project leader on projects,including the analysis of
BRUBAKER &ASSOCIATES,INC.
Monsanto Exhibit No.201
Case No.PAC-E-l7-07
Page 2 of 3
1 alternative cost recovery methods,pricing,rate design and DSM adjustment clauses,
2 and representation of a group of industrial customers on the Conservation and Least
3 Cost Planning Advisory Committee to Montana Power Company.
4 In March 1992,I accepted a position with ERG InternationalConsultants,Inc.,
5 of Golden,Colorado as Senior Utility Economist.While at ERG,I was responsible
6 for the cost-effectiveness analysis of demand-side programs for Western Area Power
7 Administration customers.I also assisted in the development of a reference manual on
8 the process of Integrated Resource Planning including integration of supply and
9 demand resource,public participation,implementation of the resource plan and
10 elements of writing a plan.I lectured and provided instructional materials on the key
11 concept of life-cycle costing seminars held to provide resource planners and utility
12 decision-makers with a background and basic understanding of the fundamental
13 techniques of economic analysis.My work also included the evaluationof a marginal
14 cost of service study,assessment of avoided cost rates,and computer modeling
15 relating engineering simulation models to weather-normalized loads of schools in
16 California.
17 In November of 1994,I accepted a position with Drazen-Brubaker &
18 Associates,Inc.("DBA").In April 1995,the firm of Brubaker &Associates,Inc.was
19 formed.It includes most of the former DBA principals and Staff.Since joining this
20 firm,I have performed various analyses of integrated resource plans,examination of
21 cost of service studies and rate design,fuel cost recovery proceedings,as well as
22 estimates of transitioncosts and restructuring plans.
BRUBAKER &ASSOCIATES,INC.
Monsanto Exhibit No.201
Case No.PAC-E-17-07
Page 3 of 3
1 In addition to our main office in St.Louis,the firm also has branch offices in
2 Phoenix,Arizona and Corpus Christi,Texas.
3 Q HAVE YOU EVER TESTIFIED BEFORE A REGULATORY BODY?
4 A Yes.I have testified before the regulatory commissions in Colorado,Georgia,Idaho,
5 Michigan,Montana,New Mexico,Oregon,Texas,Washington and Wyoming.
BRUBAKER &ASSOCIATES,INC.
Monsanto Exhibit No.202
Case No.PAC-E-17-07
Page 1 of 5
Randall C.Budge,ISB No.1949
Thomas J.Budge,ISB No.7465
RACINE,OLSON,NYE &BUDGE,CHARTERED
P.O.Box 1391;201 E.Center
Pocatello,Idaho 83204-1391
Telephone:[phone]
Fax:[phone]
[e-mail]
[e-mail]
Attorneysfor Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE CASE NO.PAC-E-17-07
APPLICATION OF ROCKY
MOUNTAIN POWER FOR MONSANTO COMPANY'S SECOND
CERTIFICATES OF PUBLIC DATA REQUESTS TO ROCKY
CONVENIENCE AND NECESSITY MOUNTAIN POWER
AND BINDING RATEMAKING
TREATMENT FOR WIND AND
TRANSMISSION FACILITIES
MONSANTO COMPANY,by and through their attorneys,hereby submits this Second
Data Request to Rocky Mountain Power,pursuant to Rule 225 of the Idaho Public Utility
Commission's Rules of Procedure,IDAPA 31.01.01.
This Data Request is to be considered continuing,and Rocky Mountain Power is
requested to provide,by way of supplementary responses,additional documents that it or any
person acting on its behalf may later obtain that will augment the documents or information
produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title and telephone number of
the person preparing the documents.Please identify the name,job title,location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel and electronic files on CD with formulas activated.
Monsanto Set 2
MONSANTO COMPANY'S SECOND DATA REQUESTSTO ROCKY MOUNTAIN POWER -1
Monsanto Exhibit No.202
Case No.PAC-E-17-07
Page 2 of 5
Request No.2:Please provide copies of all past and future data requests and responses
received by or sent from Rocky Mountain Power to any party in related applications submitted in
other state jurisdictions.Please include both formal and informal responses.In additionto
requests made in Idaho,please provide copies of PacifiCorp's responsesto new wind and
transmission data requests submitted by all parties in the states of Utah,Washington,Oregon,
Wyoming,and California.This response should include public and confidential data responses.
Please provide all future responses at,or shortly after,the time when the Company files its
responses to other parties'requests.As responsesare provided,please include a summary of the
state name,organization and DR#s for the DRs contained within each response.
DATED this 23rd day of October,2017.
RACINE,OLSON,NYE
&BUDGE,CHARTERED
RANDALL C.BUDGE
MONSANTO COMPANY'S SECOND DATA REQUESTSTO ROCKY MOUNTAIN POWER-2
Monsanto Exhibit No.202
Case No.PAC-E-17-07
Page 3 of 5
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 23rd day of October,2017,I caused to be serveda true and
correct copy of the foregoing document upon the following individuals in the manner indicated
below:
Diane M.Hanian,Secretary Hand Delivery
Idaho Public Utilities Commission US Mail (postageprepaid)
P.O.Box 83702 Facsimile Transmission
472 W.Washington Street Federal Express
Boise,ID 83702-0074 Electronic Transmission
E-Mail:[e-mail]
Ted Weston .
Idaho Regulatory Affairs Manager S
(pves
age prepaid)Rocky Mountain Power .Facsimile Transmission1407WestNorthTemple,Suite 330 O Federal ExpressSaltLakeCity,UT 84116 -.
.O Electrome TransmissionE-Mail:[e-mail]
Yvonne R.Hogle O Hand DeliveryAssistantGeneralCounselOUSMail(postageprepaid)Rocky Mountain Power ..Facsimile Transmission1407WestNorthTemple,Suite 320 O Federal ExpressSaltLakeCity,UT 84116 Electronic TransmissionE-Mail:[e-mail]
Data Request Response Center .Electrome TransmissionPacificorp
825 NE Multnomah,Suite 2000
Portland,OR 97232
E-mail:[e-mail]
Brubaker &Associates Hand Delivery16690SwingleyRidgeRoad,#140 .US Mail (postageprepaid)Chesterfield,MO 63017 -
.O Facsimile TransmissionE-Mail:[e-mail] O Federal [e-mail] ---.M Electrome TransmissionMonsantoCompany
MONSANTO COMPANY'S SECONDDATA REQUESTSTO ROCKY MOUNTAIN POWER -3
Monsanto Exhibit No.202
Case No.PAC-E-17-07
Page 4 of 5
Brandon Karpen Hand DeliveryDeputyAttorneyGeneral
..US Mail (postageprepaid)Idaho Public Utilities Commission Facsimile Transmission472W.Washington (83702)Federal ExpressP.O.Box 83720 Electronic TransmissionBoise,Idaho 83720-0074
Email:[e-mail]
Commission Staff
Ronald L.Williams Hand DeliveryWilliamsBradbury,P.C·US Mail (postageprepaid)1015 W.Hays St·Facsimile TransmissionBoise,Idaho 83702 Federal ExpressEmail:[e-mail] Electronic TransmissionPICC
Bradley Mullins Hand Delivery333SWTaylor,Suite 400 US Mail (postageprepaid)Portland,OR 97204
.Facsimile TransmissionEmail:[e-mail]-Federal ExpressPICCElectronicTransmission
Jim Duke Hand DeliveryIdahoanFoodsUSMail(postageprepaid)357 Constitution Way Facsimile TransmissionIdahoFalls,ID 83742 Federal ExpressE-Mail:[e-mail] Electronic TransmissionPIIC
Kyle Williams Hand DeliveryBYUIdaho.
.US Mail (postageprepaid)Ema11:williamsk byui.edu ..Facsimile TransmissionPIICFederalExpress
Electronic Transmission
Val Steiner .Hand DehveryNu-West Industries,Inc.
.O US Mail (postageprepaid)Email:[e-mail] ---.L_I Facsimile TransmissionPIICFederalExpress
Electronic Transmission
Eric L.Olsen Hand DeliveryEchoHawk&Olsen PLLC US Mail (postageprepaid)505 Pershing Ave.,Suite 100 Facsimile TransmissionP.O.Box 6119 Federal ExpressPocatello,Idaho 83205 Electronic TransmissionEmail:[e-mail]1
IIPA
MONSANTO COMPANY'S SECOND DATA REQUESTSTO ROCKY MOUNTAIN POWER -4
Monsanto Exhibit No.202
Case No.PAC-E-17-07
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AnthonyYankel .Hand Delivery12700LakeAvenue,Unit 2505 US Mail (postageprepaid)Lakewood,OH 44107 -
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MONSANTO COMPANY'S SECOND DATA REQUESTSTO ROCKY MOUNTAIN POWER -5
Monsanto Exhibit 203
Page 1 of 2
Case NO.PAC-E-17-07
ROCKY MOUNTAIN POWER
Annual Cost (Benefit)of Combined Projects
Medium Gas,Medium CO2 ($000)
Nominal NPV
Annual Cumulative Annual Cumulative
ir Cost (Benefit)Nominal Cost (Benefit)LV
(1)(2)(3)(4)
2017 ----
2018 117 117 103 103
2019 176 294 146 146
2020 (3,650)(3,356)(2,830)(2,684)
2021 51,492 48,135 37,460 34,775
2022 27,839 75,974 19,004 53,779
2023 6,722 82,696 4,306 58,085
2024 (11,400)71,297 (6,852)51,233
2025 (32,301)38,996 (18,218)33,015
2026 (39,261)(266)(20,779)12,237
2027 (45,919)(46,184)(22,804)(10,567)
2028 (71,975)(118,160)(33,540)(44,107)
2029 (79,106)(197,266)(34,590)(78,698)
2030 (109,254)(306,519)(44,828)(123,525)
2031 24,409 (282,110)9,398 (114,127)
2032 51,184 (230,925)18,492 (95,636)
2033 16,874 (214,051)5,720 (89,915)
2034 1,784 (212,268)567 (89,348)
2035 (264)(212,532)(79)(89,427)
2036 (11,416)(223,948)(3,198)(92,624)
2037 1,023 (222,925)269 (92,355)
2038 (3,967)(226,893)(978)(93,334)
2039 (11,125)(238,018)(2,575)(95,908)
2040 (15,185)(253,203)(3,297)(99,206)
2041 (9,509)(262,712)(1,938)(101,143)
2042 (18,264)(280,976)(3,492)(104,636)
2043 (22,099)(303,075)(3,965)(108,600)
2044 (26,343)(329,418)(4,435)(113,035)
2045 (32,410)(361,828)(5,120)(118,155)
2046 (33,705)(395,534)(4,996)(123,152)
2047 (23,828)(419,361)(3,314)(126,466)
2048 (34,597)(453,958)(4,516)(130,982)
2049 (23,686)(477,644)(2,901)(133,882)
2050 (25,662)(503,305)(2,949)(136,832)
NPV @ 6.57%(136,728)
NPV 2017-2036 (92,521)
NPV 2037-2050 (44,207)
NPV 2017-2050 (136,728)
Source:Column (1)Exhibit 25
Monsanto Exhibit 203
Page 2 of 2
Case NO.PAC-E-17-07
ROCKY MOUNTAIN POWER
Annual Cost (Benefit)of Combined Projects
Low Gas,Zero CO2 ($000)
Nominal NPV
Annual Cumulative Annual Cumulative
r Cost (Benefit)Nominal Cost (Benefit)LV
(1)(2)(3)(4)
2017 ---
2018 (192)(192)(169)(169)
2019 (593)(785)(490)(490)
2020 (4,345)(5,130)(3,368)(3,858)
2021 55,202 50,073 40,159 36,301
2022 34,115 84,187 23,288 59,589
2023 13,136 97,323 8,414 68,003
2024 (2,504)94,819 (1,505)66,498
2025 (15,481)79,338 (8,732)57,766
2026 (24,613)54,725 (13,026)44,741
2027 (30,214)24,512 (15,004)29,736
2028 (35,949)(11,438)(16,752)12,984
2029 (37,441)(48,879)(16,372)(3,388)
2030 (40,743)(89,622)(16,717)(20,105)
2031 100,891 11,270 38,845 18,740
2032 65,337 76,607 23,605 42,344
2033 43,196 119,803 14,644 56,988
2034 28,158 147,961 8,957 65,945
2035 56,090 204,051 16,742 82,688
2036 49,129 253,180 13,761 96,448
2037 52,061 305,241 13,683 110,131
2038 48,174 353,414 11,881 122,012
2039 42,559 395,973 9,849 131,861
2040 39,487 435,460 8,575 140,435
2041 44,238 479,697 9,014 149,449
2042 24,425 504,123 4,670 154,119
2043 21,353 525,476 3,831 157,951
2044 18,039 543,515 3,037 160,987
2045 13,396 556,911 2,116 163,104
2046 12,825 569,736 1,901 165,005
2047 21,358 591,094 2,971 167,976
2048 14,104 605,198 1,841 169,817
2049 25,885 631,083 3,170 172,987
2050 12,315 643,398 1,415 174,402
NPV @ 6.57%174,233
NPV 2017-2036 96,279
NPV 2037-2050 77,954
NPV 2017-2050 174,233
Source:Column (1)Exhibit 25