20240730PAC to Bayer 1-20.pdf

RECEIVED
Tuesday, July 30, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF FACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
July 30, 2024
Thomas J. Budge
ti(&racineolson.com(C)
Brian C. Collins bcollins(&consultbai.com
Greg Meyer gmeyerkconsultbai.com
Kevin Higgins khiggins(c�r�,energystrat.com
Neal Townsend ntownsendkenergystrat.com(C)
RE: ID PAC-E-24-04
Bayer Set 1 (1-20)
Please find enclosed Rocky Mountain Power's Responses to Bayer 1st Set Data Requests 1-20.
Also provided are the non-confidential Attachments to Bayer. Provided via BOX are
Confidential Attachments. 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
C.c.: Eric L. Olsen/IIPA elo(&echohawk.com(C)
Lance Kaufman/IIPA lancena,ae isg insi hg t�(C)
Matthew Nykiel/ICL matthew.nykielkiamail.com
Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org
Ronald L. Williams/PIIC rwilliamsghawlevtroxell.com
Brandon Helgeson/PIIC bhelfzeson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinskmwanalytics.com
Val Steiner/PIIC val.steinerkitafos.com
Kyle Williams/PIIC williamskkbvui.edu
Monica Barrios-Sanchez/IPUC monica.barriossanchez(),puc.idaho.gov
S ecretary(a),puc.idaho.gov

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 1
Bayer Data Request 1
Test period. Please prepare and provide a complete set of Idaho revenue
requirement models, adjustments, and work papers, comparable in all respects to
RMP's as-filed models/work papers used to produce RMP witness Shelley E.
McCoy's Exhibit No. 48, but that reflects a 13-month average rate base amount
for 2024. In preparing these revenue requirement models, please do not reflect
any annualizations for any adjustments with changes occurring during the 2024
calendar year, including annualizations of post-2023 capital additions. Also,
please provide the net power cost revenue requirement for 2024 without any
annualizations. Please provide the models/work papers in Excel format with
formulas intact.
Response to Bayer Data Request 1
PacifiCorp objects to this request as overly burdensome, requiring the creation of
a new report or analysis, lacking a high degree of relevance to this general rate
case (GRC), requesting information that is not in the Company's possession or
control, and not reasonably calculated to lead to the discovery of admissible
information. Without waiving any objection, the Company responds as follows:
The Company did not prepare this GRC using a 13-month average rate base
methodology. For a discussion of how the Test Period was developed and the rate
base methodology, please refer to the direct testimony of Company witness,
Shelley McCoy.
Recordholder: Nick Highsmith
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 2
Bayer Data Request 2
2020 New Wind/Transmission Projects. In Case No. PAC-E-17-07, the Idaho
Commission conditionally approved a Stipulation and CPCN for RMP's New
2020 Wind and Transmission Projects (alternatively, "2020 Combined Projects")
upon setting an overall capital cost cap at the Company's project estimate. In its
2021 rate case (Case No. PAC-E-21-07), RMP witness Joelle Steward noted in
her direct testimony that the capital costs for the 2020 Combined Projects
exceeded the cost cap and requested recovery of the costs in excess of the cap.
(a) Has RMP included an adjustment to reflect the cost cap ordered by the Idaho
Commission in this case? If not, why not? If so,please identify the
workpaper(s) where all the adjustment(s) may be found.
(b) If RMP did not include an adjustment to reflect the cost cap, please provide all
the adjustments by FERC account and interjurisdictional allocation factor
necessary to reflect compliance with the Commission's order. Please provide
all workpapers in Excel format with formulas intact.
(c) Assuming it was not included in RMP's filing, what would be the revenue
requirement impact if RMP had applied the 2020 Combined Projects cost cap?
Response to Bayer Data Request 2
(a) No. The Company is seeking to recover the full capital costs of the New Wind
and Transmission projects that were subject to a cost cap as part of Case No.
PAC-E-17-07. In total, actual project costs are approximately $25.7 million
total-Company, or 1.3 percent, over the Idaho Public Utilities Commission
(IPUC) established cost cap.
In finding that cost cap was warranted, the IPUC stated that"the Company
controlled the cost estimates and contingencies that the Commission relied on
to impose the cap."' However, the Company could not have predicted the
circumstances that have led to the increase in costs. One primary driver being
the COVID-19 pandemic. As such, the cost increases were beyond the
Company's control but do not compromise the overall economic benefits to
customers for these prudently incurred projects.
(b) Please refer to Confidential Attachment Bayer 2.
(c) The Company has not prepared this calculation. Please refer to the Company's
response to subpart (b) above for the information required to prepare this
calculation.
1 Order No. 34139 at 3.

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 2
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: Justin Waterman
Sponsor: Shelley McCoy/Joelle Steward

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 3
Bayer Data Request 3
Accumulated Depreciation/Amortization Reserve. Is RMP adjusting the
accumulated depreciation/amortization reserve for existing plant in the base
period to reflect year-end 2024 balances? If not, please explain why RMP didn't
reflect year-end 2024 balances and identify the time period RMP is proposing for
this reserve balance in its filing. If so, please provide a workpaper in Excel format
that rolls forward the year-end 2023 reserve balances to year-end 2024 balances
and the location within RMP's adjustments where each of the roll forward
adjustments are located.
Response to Bayer Data Request 3
No. Base period accumulated depreciation reserve/amortization reserve does not
update base period existing plant to year-end 2024 balances. The balance is left at
the December 2023 year-end base period amount since it matches the base period
electric plant in service (EPIS) amounts. Idaho general rate cases (GRCs) are filed
on a historical basis with known and measurable adjustments rather than a fully
forecasted basis. A fully forecast case would walk the base period plant balance
forward for all capital additions, including depreciation expense and accumulated
depreciation reserve and related accumulated deferred income tax (ADIT)balance
amounts. The Company's method incorporates adjustments only for discrete
capital projects greater than $5 million for capital additions placed in-service in
2023 or 2024 and is consistent with previously filed Idaho GRCs.
Recordholder: Craig Larsen
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 4
Bayer Data Request 4
Capital Additions. Please provide RMP's projected calendar year 2024 plant
additions. For the distribution plant, please limit the response to the capital
additions for the state of Idaho. Please separate these projected calendar year 2024
plant additions into the following functional categories: Steam Generation, Hydro
Generation, Other Production Generation, Transmission, Distribution, General,
and Intangible Plant and provide the appropriate interjurisdictional allocation
factor for each. Please provide this schedule in Excel format as well as any
associated workpapers with formulas intact. If there is any differences from the
forecasted capital additions included in the Utah general rate case referenced in
the subsequent data request, please reconcile and explain any differences.
Response to Bayer Data Request 4
The Company assumes that the reference to "subsequent data request" is intended
to be a reference to Bayer Data Request 5. Based on the foregoing assumption, the
Company responds as follows:
Please refer to the Company's response to Bayer Data Request 8, specifically
Confidential Attachment Bayer 8, which provides a listing of the 2024 plant
additions. A listing of 2024 plant additions was also provided with the work
papers for 8.5 —Major Plant Additions adjustment see tab 8.5.3.
The differences from the Utah general rate case (GRC) data is that the 2024
capital projects in Idaho are discrete projects over $5 million and the Utah 2024
data is fully forecasted for all capital additions forecast to go into service in 2024
and 2025.
Recordholder: Craig Larsen
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 5
Bayer Data Request 5
Capital Additions. Please provide RMP's forecasted capital additions work
papers in its current Utah rate case (Utah Docket No. 24-035-04). Specifically,
please provide the Utah Adjustment 8.5 Proforma Plant Additions work papers
and the Confidential Utah Adjustment 8.15 New Wind Generation Capital
Additions work papers in Excel format with formulas intact. Please confirm that
these work papers presents the forecasted calendar year 2024 (& calendar year
2025) projected capital additions by month separated by the following functional
categories - Steam Generation, Hydro Generation, Other Production Generation,
Transmission, Distribution, General, and Intangible Plant- and provides the
appropriate interjurisdictional allocation factor for each.
Response to Bayer Data Request 5
The Company objects to this data request to the extent it seeks information that is
not relevant and requests information from a Company filing in another state.
Subject to and without waiving the foregoing objection, the Company responds as
follows:
Please refer to the Attachment Bayer 5-1 and Confidential Attachment Bayer 5-2 for the
requested workpapers from Utah Docket No. 24-035-04.
The Company confirms these workpapers present the forecasted 2024 and 2025 capital
additions by month separated by functional category and allocation factor. It is important
to note that the Idaho and Utah GRC's use different subsets of capital additions based on
the criteria used in each of these filings.
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: Craig Stelter
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 6
Bayer Data Request 6
Accumulated Deferred Income Taxes. On p. 5 of 303 (p. 1.3)of RMP witness
Shelley E. McCoy's Exhibit 48, Ms. McCoy provides Idaho's share
($143,870,486) of the unadjusted 2023 accumulated deferred income tax balance
in Col. (1). Please provide a 2024 forecast of accumulated deferred income taxes
(both Total Company and Idaho allocated) that is not otherwise included in the
various RMP adjustments summarized on p. 6 of 303 (p. 1.4) of Exhibit 48.
Please provide this forecasted amount broken down by function (e.g. generation,
transmission, distribution, etc.). Please provide any work papers supporting this
response in Excel format with formulas intact.
Response to Bayer Data Request 6
PacifiCorp objects to this request as overly broad, unduly burdensome, requiring
the creation of a new analysis that is beyond the scope of discovery in this
proceeding, and not reasonably calculated to lead to the discovery of admissible
evidence. In addition, the requested 2024 forecast would be inconsistent with the
test period used and with plant additions and depreciation expense included in this
general rate case (GRC)proceeding. Without waiving the foregoing objection, the
Company responds as follows:
Please refer to page 142 of Exhibit No. 48, Major Plant Additions. The
accumulated deferred income taxes (ADIT)were aligned with the plant additions
included in this GRC proceeding.
Recordholder: Deanna Fladstol
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 7
Bayer Data Request 7
Depreciation Expense/Accumulated Depreciation Reserve. In its Incremental
Depreciation Expense Adjustment 6.1, RMP includes an adjustment(Total
Company= $5,080,376; Idaho Allocated= $274,487) to annualize the
depreciation expense for the portion of the major capital additions that were
placed in service during the 2023 historic test year. Did RMP include an
adjustment to the Accumulated Depreciation Reserve to reflect this incremental
depreciation expense? If not, why not? If so, please identify the location within
RMP's work papers where this adjustment to the accumulated depreciation
reserve is located.
Response to Bayer Data Request 7
No. The Company did not include an adjustment to accumulated depreciation
reserve for the 2023 incremental depreciation expense. Since the historical rate
case begins with year-end rate base, the Company does not add additional
depreciation reserve for base period capital items, because they are already
included on a year-end basis.
Recordholder: Craig Larsen
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 8
Bayer Data Request 8
Adjustment 8.5—Major Plant Additions. In the 8.5 exhibit workpaper file, the
values on p. 8.5.2 & 8.5.3 appear to show the calendar year 2023 & 2024 major
plant gross plant-in-service capital additions. Please confirm that RMP is
reflecting a 2024 end-of-period plant in service balance for each project (in
addition to the 2023 end of period balances). For major plant addition project,
please provide a work paper deriving the 13-month average balance for 2024 for
gross plant, accumulated depreciation, and accumulated deferred income taxes.
Please reconcile any differences with the rate base amounts included in RMP's
filing.
Response to Bayer Data Request 8
Rocky Mountain Power(RMP)objects to this request as overly burdensome,
requiring the creation of a new report or analysis, lacking a high degree of
relevance to this general rate case (GRC), requesting information that is not in the
company's possession or control, and not reasonably calculated to lead to the
discovery of admissible information. Without waiving any objection, the
Company responds as follows:
RMP confirms that the major plant additions shown on page 8.5.2 relating to 2023
projects are year-end 2023 balances. The major plant additions shown on pages
8.5.2 and 8.5.3 relating to 2024 projects are year-end 2024 balances.
A 13-month average plant balance calculation has not been prepared by RMP.
Please refer to Confidential Attachment Bayer 8 which provides a monthly listing
of the 2024 pro-forma project capital additions, depreciation expense,
accumulated depreciation reserve and accumulated deferred income taxes
(ADIT).
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: Craig Larsen
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 9
Bayer Data Request 9
Adjustment 8.5—Major Plant Additions. For any new major capital addition in
which some portion of the project has an in-service date during calendar year
2023, please provide a monthly breakdown of the capital additions for both
calendar years 2023 & 2024. As part of this response, please include the pro
forma monthly depreciation expense, accumulated depreciation, and accumulated
deferred income taxes by month for each project. If there is any difference from
the amounts included in RMP's filing, please reconcile the difference with the
requested amount in the filing.
Response to Bayer Data Request 9
Please refer to Attachment Bayer 9 which provides the 2023 monthly major
capital additions detail of the projects greater than $5 million. The Company has
not prepared monthly depreciation expense, accumulated depreciation reserve or
accumulated deferred income taxes (ADIT) for this data. The provided attachment
includes composite depreciation rates that can be used to calculate monthly
depreciation expense. 2023 ADIT are calculated in the Company's PowerTax
system. Note: vintage data from the PowerTax system is available by plant
function but not by individual project.
For 2024 information, please refer to the Company's response to Bayer Data
Request 8.
Recordholder: Craig Larsen
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 10
Bayer Data Request 10
Annual Incentive Plan. Please provide all documentation that explains the
different components of RMP's Annual Incentive Plan (AIP). The response
should describe the different metrics used to award AIP payments.
Response to Bayer Data Request 10
Please refer to the Company's response to Bayer Data Request 11.
Recordholder: Matthew Swanson
Sponsor: Julie Lewis

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request I I
Bayer Data Request 11
Annual Incentive Plan. Please provide a copy of the Annual Incentive Plan
documents for each year, 2021 through 2023, and if available, 2024.
Response to Bayer Data Request 11
Please refer to Confidential Attachment Bayer l l which provides copies of
PacifiCorp's Annual Incentive Plan (AIP) for calendar years 2021 through 2024.
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: Matthew Swanson
Sponsor: Julie Lewis

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 12
Bayer Data Request 12
Annual Incentive Plan. Please provide the PacifiCorp Scorecards applicable to
the Annual Incentive Plan for each year 2021 through 2023, and if available,
2024.
Response to Bayer Data Request 12
Please refer to Confidential Attachment Bayer 12.
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: Julie Leavitt
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 13
Bayer Data Request 13
Annual Incentive Plan. Please provide the RMP Bonus and Awards payment
balances for the last five years (2019-2023).
Response to Bayer Data Request 13
Please refer to the table below which provides the total Company bonus and
awards payment balances for the last five years (2019 through 2023) as reported
in the Company's Idaho December Results of Operations (ROO)filings:
Total Company
Bonus and Awards
2019 $1,776,665
2020 $6,887,562
2021 $6,655,902
2022 $2,200,130
2023 $2,902,897
Recordholder: Christina Lopas
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 14
Bayer Data Request 14
Annual Incentive Plan. For 2023 and 2024, please provide a detailed description
of all actions performed that would qualify for a bonus or award payment.
Response to Bayer Data Request 14
All eligible participants had (in 2023) and will have (in 2024) an award
opportunity based upon Company, department and individual performance.
Recordholder: Matthew Swanson
Sponsor: Julie Lewis

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 15
Bayer Data Request 15
Payroll costs. Is RMP seeking to include payroll increases in cost of service
beyond the 2024 test year in this case? If so,please provide a detailed explanation
of all increases.
Response to Bayer Data Request 15
No. The Company is not including any projected increases to payroll beyond the
2024 Test Year.
Recordholder: Christina Lopas
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 16
Bayer Data Request 16
Payroll costs. Please refer to Exhibit No. 48,page 4.2.2. Please separately state
the percentage of total labor dollars assigned to (a)Non-Utility Labor and (b)
Capitalized Labor for the last five years (2019-2023) and pro-forma 2024.
Response to Bayer Data Request 16
Please refer to the table below which provides PacifiCorp's estimated bare labor
(salary and annual incentive plan(AIP)) costs, for the following years, as reported
in the Company's Federal Energy Regulatory Commission (FERC)Form 1 for
non-utility and capitalized labor:
Total Total
Estimated Non- Estimated Capitalized Estimated Non-Utility/ Estimated
Non-Utility o Labor /o Capitalized o Non-Utility/ Capitalized Salaries and
Labor$ Utility /o Labor$ Capitalized Labor Total%
Labor$ Wages
2019 1,426,868 0.26% 179,684,237 33.08% 181,111,105 33.35% 543,112,099
2020 747,785 0.13% 197,785,285 34.96% 198,533,070 35.09% 565,827,630
2021 1,833,030 0.33% 194,102,897 34.97% 195,935,927 35.30% 555,089,264
2022 975,792 0.17% 211,427,979 36.59% 212,403,771 36.75% 577,907,432
2023 2,539,250 0.41% 231,780,579 37.34% 234,319,829 37.75% 620,737,216
Note: PacifiCorp's 2024 FERC Form I data will not be available until Q2 2025.
For the capitalization calculation used in this general rate case (GRC), the
Company used actual 2023 percentages consistent with the Base Period data.
Recordholder: Christina Lopas
Sponsor: Shelley Mccoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 17
Bayer Data Request 17
Employee count. Please provide the actual full time equivalent (FTE) employee
count by month, beginning in January 2019 and continuing through the most
recent date available. In this response, please indicate the day of the month to
which the FTE counts correspond (e.g., 1 st of the month, last day of the month,
etc.). Please supplement this response as new information becomes available
during the pendency of this case.
Response to Bayer Data Request 17
Please refer to Attachment Bayer 17 which provides actual (full-time equivalent
(FTE)) workforce,by month, January 2019 through June 2024.Note: the amounts
provided are based on the Company's end of month workforce data.
Recordholder: Brittney Davis-Smiley
Sponsor: Brittney Davis-Smiley

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 18
Bayer Data Request 18
Employee count. Please confirm that the Company's test period labor expenses
are effectively based on the average full time equivalent employee count for the
base period ended December 31, 2023. If not, please indicate the time period
corresponding to the employee count upon which test period labor expenses are
based.
Response to Bayer Data Request 18
PacifiCorp does not base labor expenses on full-time equivalent (FTE) count.
Instead, PacifiCorp prepares test year labor expenses using the actual dollars
recorded during the base period 12 months ended December 31, 2023, and then
escalates those dollar figures to the test year using contractual and target rates.
Please refer to the direct testimony of Company witness, Shelley McCoy, Exhibit
No. 48,page 4.2.1,which provides further details on how the test year labor
expenses are derived.
Recordholder: Christina Lopas
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 19
Bayer Data Request 19
Employee count. Please indicate whether the Company has made any
adjustments to the base period to reflect known and measurable changes that
include changes to the number of employees. If so,please explain and cite to the
adjustment(s) in the Company's filing.
Response to Bayer Data Request 19
Please refer to the Company's response in Bayer Data Request 18.
Recordholder: Christina Lopas
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 20
Bayer Data Request 20
Customer Service Deposits. Please refer to Ms. McCoy's Exhibit No. 48
(Results of Operations), page 2.28.
(a) Please explain why the entries corresponding to Customer Service Deposits
(lines 2147-2149) are zero.
(b) Please compare these entries to the comparable entries in Exhibit
RMP_(SEM-3), page 2.29, lines 2284-2286, in Utah Public Service
Commission Docket No. 24-035-04. In the Utah docket, $13 million of
Customer Service Deposits are adjusted into the 2025 test period as a credit
against rate base. Please explain in detail why there is no analogous
adjustment for Idaho and provide any documentation and work papers
supporting such explanation.
(c) Please provide the actual (if available) or projected monthly balance of Idaho
Customer Service Deposits for each month from December 2022 to December
2024. Please indicate whether each amount provided represents an actual or
projected balance.
(d) Please provide the actual (if available) or projected monthly Idaho interest
expense on Customer Service Deposits for each month from January 2023 to
December 2024. Please indicate whether each amount provided represents an
actual or projected amount.
Response to Bayer Data Request 20
(a) Customer service deposits are currently, and have historically been, excluded
from utility rate base for multiple reasons. First, the Company pays interest on
these deposits at the customer deposit rate established annually by the Idaho
Public Utilities Commission (IPUC). Secondly, the customer deposits are paid
by specific customers and those customers are paid the appropriate interest to
compensate them for the time-value of their money. To include customer
deposits as a rate base deduction would unfairly reduce rates for all customers
based on deposits paid by only certain customers who, for various reasons,
require a deposit to secure payment on their electric service. Finally, customer
deposits are held as an offset to operations costs the Company incurs for
customers who default on their payment obligation. Deposits do not offset
capital financing used for capital projects, which clearly distinguishes deposits
from items more properly included in rate base.
(b) Please refer to the Company's response to subpart (a) above.

PAC-E-24-04/Rocky Mountain Power
July 30, 2024
Bayer Data Request 20
(c) Please refer to Attachment Bayer 20 which provides actual balances from
December 2022 through June 2024.Note: The Company does not project
customer service deposits or interest therefore projected balances are not
available.
(d) Please refer to the Company's response to subpart (c) above.
Recordholder: Louisa Bruschi-Dadik
Sponsor: Shelley McCoy

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 response to Bayer Set 1 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 30th day of July, 2024.
Respectfully submitted,
By
Joe Dallas
Attorney
Rocky Mountain Power
2