20240712PAC to Staff 16-17.pdf

RECEIVED
Friday, July 12, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
July 12, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
monica.barriossanchez(kpuc.idaho.gov
S ecretga(kpuc.idaho.gov
RE: ID PAC-E-24-04
IPUC Set 1 (1-33)
Please End enclosed Rocky Mountain Power's Responses to IPUC I" Set Data Requests 16 and
17. Provided via BOX is Confidential Attachment IPUC 16 and Confidential Response IPUC
16. 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(801) 220-2313.
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures
C.c.: Eric L. Olsen/IIPA eloAechohawk.com(C)
Lance Kaufman/IIPA lance&ae_isgi insi_h�(C)
Matthew Nykiel/ICL matthew.n. k�( izinail.com
Brad Heusinkveld/ICL bheusinkveld(kidahoconservation.org
Thomas J. Budge/Bayer tj(kracineolson.com(C)
Brian C. Collins/Bayer [e-mail]
Greg Meyer/Bayer gmeergconsultbai.com
Kevin Higgins/Bayer khiggins(&energystrat.com
Neal Townsend/Bayer ntownsendgenergystrat.com(C)
Ronald L. Williams/PIIC rwilliams(khawleytroxell.com
Brandon Helgeson/PIIC bhel eg son ckhawleytroxell.com

Bradley Mullins/PIIC brmullins&mwanalytics.com
Val Steiner/PIIC val.steinergitafos.com
Kyle Williams/PIIC williamsk&byui.edu

PAC-E-24-04/Rocky Mountain Power
July 12, 2024
IPUC Data Request 16
IPUC Data Request 16
Please provide copies of the cost/benefit analysis, internal rates of return, or
similar analysis for each capital project included in the Company's response to
Request No. 15.
Confidential Response to IPUC Data Request 16
The Company assumes that the reference to "Request No. 15" is intended to be a
reference to IPUC Data Request 15. Based on the foregoing assumption, the
Company responds as follows:
Please refer to Confidential Attachment IPUC 16 which provides supporting
documentation,where applicable/available.Note: the provided documentation is
cross-referenced using the"Ref#"numbers in column A of Attachment IPUC 15-
1 provided with the Company's response to IPUC Data Request 15.
In addition,please note the following:
• Ref# 39 (attachment IPUC 15-1 —"W-1799 EV 2020 WIND LTSA
CY2023" GEN/2023/C/909
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 finther subject
to the Non-Disclosure Agreement(NDA) executed in this proceeding.
Recordholder: Various
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
July 12, 2024
IPUC Data Request 17
IPUC Data Request 17
Please provide all documents the Company used to demonstrate the benefits
realized by the Company for each capital project included in the Company's
response to Request No. 15.
Response to IPUC Data Request 17
The Company assumes that the reference to "Request No. 15" is intended to be a
reference to IPUC Data Request 15. Based on the foregoing assumption, the
Company responds as follows:
The Company has not conducted any costs/benefits analysis after capital projects
are completed.
Recordholder: Not Applicable
Sponsor: Not Applicable

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-24-04
IN THE MATTER OF THE )
APPLICATION OF ROCKY ) ATTORNEY'S CERTIFICATE
MOUNTAIN POWER FOR ) CLAIM OF CONFIDENTIALITY
AUTHORITY TO INCREASE ITS ) RELATING TO DISCOVERY
RATES AND CHARGES IN IDAHO ) RESPONSES
AND APPROVAL OF PROPOSED )
ELECTRIC SERVICE SCHEDULES )
AND REGULATIONS )
I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a
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 that the responses and attachments provided with the Company's responses to IPUC Data
Request 1.16 contains Company proprietary information that could be used to its commercial
disadvantage.
1

Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential information that the information contains Company proprietary information.
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 12th day of July, 2024.
Respectfully submitted,
By s`
Joe Dallas
Attorney
Rocky Mountain Power
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