20240424PAC to Staff 1-3.pdf

RECEIVED
Wednesday, April 24, 2024 3:03PM
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
April 24, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
monica.barriossanchez(ir,puc.Idaho.gov
S ecretM(a-,puc.idaho.gov
RE: ID PAC-E-24-05
IPUC Set 1 (1-5)
Please find enclosed Rocky Mountain Power's Responses to IPUC 1st Set Data Requests 1-3.
The Confidential Attachment IPUC 1 and Confidential Responses IPUC 2 and 3 are provided via
BOX. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and
31.01.01.233, the Idaho Public Utilities Commission's Rules of Procedure No. 67 —Information
Exempt from Public Review.
If you have any questions, please feel free to call me at [phone].
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures

PAC-E-24-05 /Rocky Mountain Power
April 24, 2024
IPUC Data Request 1
IPUC Data Request 1
In his testimony, Company witness Painter asserted that, "coal pricing more than
doubled in 2022 and remained high into 2023."Painter Direct at 21. Please
provide historical coal pricing data from 2021 to present for a range of coal types
used by the Company's plants.
Response to IPUC Data Request 1
Please refer to Confidential Attachment IPUC 1 which contains historical short-
term coal prices for Utah, Colorado and Wyoming, as reported in Argus Coal
Daily, an Argus Media publication to which PacifiCorp subscribes.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67—Information Exempt from Public Review, and further subject
to the non-disclosure agreement (NDA) executed in this proceeding.
Recordholder: Dave Webb
Sponsor: To Be Determined

PAC-E-24-05 /Rocky Mountain Power
April 24, 2024
IPUC Data Request 2
IPUC Data Request 2
In his testimony, Company witness Painter asserted that the Company, "continued
to transport coal from the Rock Garden safety pile to the Huntington
plant...through September 2023 when the Rock Garden inventory was completely
depleted." Painter Direct at 21-22. Please describe the purpose of the Rock
Garden safety pile, its current status, and the Company's long-term plan for it.
Confidential Response to IPUC Data Request 2
The Rock Garden coal stockpile is located approximately two miles from the
Huntington Plant and is used for coal supply security for the Hunter and
Huntington plants. Rock Garden can store approximately one million tons and
i
can be ad'usted as needed to levera e strate is o ortunities.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67—Information Exempt from Public Review, and further subject
to the non-disclosure agreement(NDA) executed in this proceeding.
Recordholder: Dave Webb
Sponsor: To Be Determined

PAC-E-24-05 /Rocky Mountain Power
April 24, 2024
IPUC Data Request 3
IPUC Data Request 3
In his testimony, Company witness Painter asserted that the Company contracted
for new coal supplier for its Utah plants in 2023 and amended its existing coal
contracts with Bronco and Wolverine. Painter Direct at 21-24. Please provide the
following concerning the coal supply inventory for the Utah plants:
(a) The contracted delivery tonnage for each month in 2024 for each of the Utah
coal plants;
(b) The forecasted generation output for each of the Utah coal plants and the
resulting coal inventory, by month in 2024;
(c) An analysis of any coal-supply constraints on the output for each of the Utah
coal plants for 2024; and
(d) An analysis of any coal-supply constraints on the output for each of the Utah
coal plants beyond 2024.
Confidential Response to IPUC Data Request 3
(a) The Company objects to providing 2024 forecasted data as it is not relevant to
the energy cost adjustment mechanism(ECAM) for calendar year 2023.
Notwithstanding the foregoing objection, the Company responds as follows:
Coal supply agreements (CSA)are generally contracted for annual volumes
and do not specify monthly amounts. The Company computes forecasted
monthly amounts based on generation and load requirements.
(b) The Company objects to providing 2024 forecasted data as it is not relevant to
the ECAM for calendar year 2023. Without waiving the foregoing objection,
the Company responds as follows:
The information requested is highly proprietary and commercially sensitive.
The Company requests special handling of this information. Please contact
Mark Alder(801-589-3960) to make arrangements for review.

PAC-E-24-05 /Rocky Mountain Power
April 24, 2024
IPUC Data Request 3
(c) The Company objects to providing 2024 forecasted data as it is not relevant to
the ECAM for calendar year 2023. Notwithstanding the foregoing objection,
the Company responds as follows:
(d) The Company objects to providing forecasted data beyond 2024 as it is not
relevant to the ECAM for calendar year 2023. Notwithstanding the foregoing
objection, the Company responds as follows:
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67—Information Exempt from Public Review, and further subject
to the non-disclosure agreement (NDA) executed in this proceeding.
Recordholder: Dave Webb
Sponsor: To Be Determined

Joe Dallas (ISB# 1033)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email:[e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-24-05
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER ) ATTORNEY'S CERTIFICATE
APPROVAL OF POWER COST ) CLAIM OF CONFIDENTIALITY
DEFERRAL OF $62.4 MILLION ECAM ) RELATING TO DISCOVERY
DEFERRAL ) RESPONSES
I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a
senior attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its response, is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code Section 74-101, et seq. and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts the Company's response IPUC Data Requests No. 1, 2 and 3 contain Company proprietary
information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in that the information contains Company proprietary information.
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I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
Protective Agreement in this proceeding.
DATED this 24th day of April, 2024.
Respectfully submitted,
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
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