20240710PAC to Staff 16-17.pdf

RECEIVED
Wednesday, July 10, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF FACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
July 10, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
monica.barrio ssanchez(apuc.Idaho.gov
S ecretarygpuc.idaho.gov
RE: ID PAC-E-24-06
IPUC Set 2 (16-17)
Please find enclosed Rocky Mountain Power's Redacted Responses to IPUC 2nd Set Data
Requests 16-17. Provided via BOX are Confidential Responses IPUC 16-17. 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.
If you have any questions, please feel free to call me at [phone].
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures

PAC-E-24-06/Rocky Mountain Power
July 10, 2024
IPUC Data Request 16
IPUC Data Request 16
In the Company's response to Production Request No. 5, please explain what the
term "Pause Fee" is and how it is implemented.
Confidential Response to IPUC Data Request 16
Referencing the Company's response to IPUC Data Request 5, 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: Mike Jenson
Sponsor: Jayson Branch

PAC-E-24-06/Rocky Mountain Power
July 10, 2024
IPUC Data Request 17
IPUC Data Request 17
Please supplement the Company's response to Production Request No. 10 by
explaining the estimated costs of the transmission line relocation and/or
transmission line upgrades as listed in Confidential Schedule 11 for the asset
transfer.
Confidential Response to IPUC Data Request 17
The estimated costs by block are shown below(subject to final design engineering
and materials):
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: Mike Jenson
Sponsor: Jyson Branch

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-24-06
IN THE MATTER OF THE )
APPLICATION OF ROCKY ) ATTORNEY'S CERTIFICATE
MOUNTAIN POWER FOR ) CLAIM OF CONFIDENTIALITY
APPROVAL OF THE TRANSFER OF ) RELATING TO DISCOVERY
PORTIONS OF THE NORTH ) RESPONSES
TEMPLE PROPERTY AND )
ACCOUNTING ORDER )
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 Audit Data Requests Nos. 16 and 17 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 10th day of July, 2024.
Respectfully submitted,
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
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