20240812PAC to Bayer 21-48.pdf

RECEIVED
Monday, August 12, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 12, 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(C)
Neal Townsend ntownsendkenergystrat.com(C)
RE: ID PAC-E-24-04
Bayer Set 2 (21-48)
Please find enclosed Rocky Mountain Power's Responses to Bayer 2nd Set Data Requests 21-47
and attachments. The response to Bayer 48 will be provided under separate cover. 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
August 12, 2024
Bayer Data Request 21
Bayer Data Request 21
Please provide Bayer witness Colin T. Fitzhenry with access to the AURORA
production cost model that Rocky Mountain Power used to calculate its net power
costs. Colin Fitzhenry's contact information is below.
Colin T. Fitzhenry
Associate
Brubaker&Associates, Inc.
16690 Swingley Ridge Road, Suite 140
Chesterfield, MO 63017
[e-mail]
Response to Bayer Data Request 21
The Company notes that Colin Fitzhenry of Brubaker&Associates is already in
possession of a valid temporary Aurora license (and Gurobi license)procured by
PacifiCorp. Based on the foregoing clarification, the Company responds as
follows:
On June 2, 2024, the Company purchased a 12-month temporary Aurora license
(and Gurobi license) for Colin Fitzhenry of Brubaker&Associates, representing
Bayer Corporation (Bayer), for use in this general rate case (GRC)proceeding,
Case PAC-E-24-04. The temporary Aurora license (and Gurobi license) is
provided consistent with existing license agreements between Berkshire
Hathaway Energy Company (BHE) and Energy Exemplar LLC (Energy
Exemplar). Note: the temporary Aurora license (and Gurobi license)will expire
on June 1, 2025.
On July 29, 2024, the Company provided access (via BOX) to the Aurora net
power costs (NPC)project supporting the direct testimony of Company witness,
Ramon J. Mitchell in this 2025 GRC proceeding to Colin Fitzhenry. Please refer
to the non-confidential and confidential work papers provided with and
supporting Ramon Mitchell's direct testimony. The Aurora NPC project and its
supporting work papers are confidential and are subject to the terms and
conditions of the protective order in this 2025 GRC proceeding.
Access to the Aurora and Gurobi applications/software are obtained directly
from Energy Exemplar subject to the terms and conditions of the existing license
agreements referenced above, the execution of a non-disclosure agreement (NDA)
between Energy Exemplar and Colin Fitzhenry, as well as the terms and
conditions of the confidentiality protections within the NDA executed by Colin
Fitzhenry applicable in this 2025 GRC proceeding.

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 21
Note: the Aurora NPC project is "ID PAC-E-24-04 ID GRC 2025—Mitchell
Direct Aurora v14.2.1059 CONF", and the version of the Aurora application used
by PacifiCorp's NPC group for the direct testimony filing in this 2025 GRC
proceeding is version 14.2.1059. Please be aware that NPC results are not
reproducible in other versions of Aurora.
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: Ramon Mitchell
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 22
Bayer Data Request 22
Please refer to the Direct Testimony of Ramon Mitchell, Page 9, Lines 17-22.
Please explain why the procedure described is necessary, and why the Company
cannot use the 2023 weather normalized load in its initial Aurora model run.
Response to Bayer Data Request 22
By "initial Aurora model run" the Company assumes that Bayer Corporation
(Bayer) is asking why the Company did not provide all net power costs (NPC)
analysis using 2023 weather normalized load instead of 2025 forecast load in its
Aurora runs. Based on the foregoing assumption, the Company responds as
follows:
When creating analysis comparing inputs between the 2021 general rate case
(GRC), Case No. PAC-E-21-07 and this GRC proceeding, the Company did use
2023 weather normalized load as the comparison was apples-to-apples and
meaningful to the reader. When creating analysis to support methodology updates,
reflective of actual operations, the Company did not use the 2023 weather
normalized load, as the analysis would not be comparable to actual historical data.
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 23
Bayer Data Request 23
Please provide the following annual data for all PacifiCorp generating units for
the period 2021-2023:
(a) Net Generation.
(b) Operating Capacity (Seasonal, if Applicable).
(c) Capacity Factor.
(d) Seasonal Derates.
(e) Forced Outage Hours.
(f) Western Resource Adequacy Plan Accredited Capacity.
Response to Bayer Data Request 23
PacifiCorp objects to this data request on the grounds that it seeks information that
is not relevant and the request is not reasonably calculated to lead to the discovery
of admissible evidence. Subject to and without waiving the foregoing objection,
the Company responds as follows:
For subparts (a) through (e), please refer to Confidential Attachment Bayer 23-1.
For subpart (f), the Company responds as follows:
Please refer to Confidential Attachment Bayer 23-2 which provides Western
Resource Adequacy Program (WRAP) accredited capacity data for Winter 2022-
2023 and Summer 2023. WRAP capacity data prior to Winter 2022-2023 is not
available.
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: Gavin Mangelson/Ben Faulkinberry
Sponsor: Gavin Mangelson/Paul Wood

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 24
Bayer Data Request 24
Please provide the following data on an hourly basis for the period 2021-2023:
(a) Market Purchases (kWh).
(b) Market Sales (kWh).
(c) Market Purchase Price ($/MWh).
(d) Market Sales Price ($/MWh).
Response to Bayer Data Request 24
PacifiCorp objects to this data request on the grounds that it seeks information that
is not relevant and the request is not reasonably calculated to lead to the discovery
of admissible evidence. Subject to and without waiving the foregoing objection, the
Company responds as follows:
Please refer to Confidential Attachment Bayer 24.
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: Ray Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 25
Bayer Data Request 25
Please provide all load forecasts that support the Company's 2025 NPC forecast.
Response to Bayer Data Request 25
Please refer to Attachment Bayer 25 which provides the load forecast supporting
the Company's 2025 net power costs (NPC)forecast in this general rate case
(GRC) proceeding.
Recordholder: Lee Elder
Sponsor: Lee Elder

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 26
Bayer Data Request 26
Please provide the following data with respect to the Washington Cap and Invest
Program and the 2025 NPC forecast:
(a) Forecasted Net Generation of Chehalis Power Plant with GHG allowance.
(b) Forecasted Net Generation of Chehalis Power Plant without GHG allowance.
(c) Production cost of Chehalis Power Plant without GHG allowance price.
(d) Production cost of Chehalis Power Plant with GHG allowance price.
(e) Please explain if the Aurora model includes any additional constraints on the
Chehalis Power Plant as a result of the Washington Cap and Invest Program.
(f) Please identify the Aurora model run that does not include the Washington
Cap and Invest Program.
Response to Bayer Data Request 26
PacifiCorp assumes that the phrase "Washington Cap and Invest Program" is in
reference to the Washington Climate Commitment Act provisions codified in
RCW Chapter 70A.65. Based on the foregoing assumptions, the Company
responds as follows:
(a) For forecasted generation of Chehalis with the greenhouse gas (GHG)
allowance adder for the Company's 2025 expected net power costs (NPC),
please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, specifically confidential file
"ID_GRC_2025.xlsm", tab "NPC Summary" row 539.
(b) For forecasted generation of Chehalis without the GHG allowance adder for
the Company's 2025 expected NPC, please refer to the confidential work
paper supporting Ramon Mitchell's direct testimony, specifically confidential
file "ID_GRC_2025_WA Cap and Invest.xlsm", tab "NPC Summary" row
539.
(c) By production cost, the Company assumes Bayer Corporation (Bayer) is
asking for the forecast fuel expense for Chehalis. Based on the foregoing the
assumption, the Company responds as follows:
Please refer to the confidential work paper supporting Ramon Mitchell's
direct testimony, specifically confidential file "ID_GRC_2025.xlsm", tab

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 26
"NPC Summary"row 241.
(d) By production cost, the Company assumes Bayer is asking for the forecast
fuel expense for Chehalis. Based on the foregoing assumption, the Company
responds as follows:
Please refer to the confidential work paper supporting Ramon Mitchell's
direct testimony, specifically confidential file "ID_GRC_2025_WA Cap and
Invest.xlsm", tab "NPC Summary" row 241.
(e) No. The Aurora model does not include any additional constraints besides the
Washington Cap and Invest Program dispatch adder for Chehalis within the
Aurora model.
(f) Please refer to the confidential work papers supporting Ramon Mitchell's
direct testimony, specifically confidential file "ID_GRC_2025_WA Cap and
Invest".
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 27
Bayer Data Request 27
Please explain how cost from the GHG allowances will be recovered and utilized.
Response to Bayer Data Request 27
PacifiCorp assumes that the phrase "GHG allowances" is in references to
provisions within the Washington Climate Commitment Act. Based on the
foregoing assumption, the Company responds as follows:
The greenhouse gas (GHG) allowances would be recovered like other power costs
and utilized to pay for the costs incurred. Specifically, a base net power costs
(NPC) in rates would be set (with the inclusion of the cost of the GHG
allowances) and then the variance between the base NPC and the actual NPC
would be recovered in the energy cost adjustment mechanism (ECAM), subject to
relevant Idaho Public Utilities Commission (IPUC) orders.
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 28
Bayer Data Request 28
Please identify the Idaho allocated percentage of total company forecasted NPC.
Response to Bayer Data Request 28
All the Idaho allocated percentages of total company forecasted net power costs
(NPC) are provided in Exhibit No. 51 (ECAM Base/LCAR), specifically
"ECAM PTC Base". Please refer to Attachment Bayer 28 which provides a
Mircosoft Excel version of Exhibit No. 51 which includes the allocation
percentages on each line.
Recordholder: Aaron Rose
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 29
Bayer Data Request 29
Please provide all work papers supporting the Company's DART adjustment in
Excel format with formulae and links intact.
Response to Bayer Data Request 29
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, specifically confidential file "Aurora GN
Market Prices CONF.xlsb", tab "Adders Source"which support the Company's
day-ahead/real-time (DA/RT)percentile adder.
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 30
Bayer Data Request 30
Please provide the following information with respect to the DART adjustment
for each month of 2023:
(a) Actual net balancing cost.
(b) Actual balancing purchases (MWh).
(c) Actual balancing sales (MWh).
(d) Average cost of actual balancing purchases ($/MWh).
(e) Average cost of actual balancing sales ($/MWh).
Response to Bayer Data Request 30
Please refer to the Company's response to Bayer Data Request 29.
(a) Please refer to cells AE 192:AF203. The sum of those cells is the "Real World
Transaction Loss" at $85 million, assumed to be synonymous with "net
balancing costs".
(b) Please refer to cells C922 103. Additionally, refer to row 3 for column
headers that are named"Buy"to aggregate the actual balancing purchases
(megawatt-hours (MWh)), approximately 3.42 million MWh.
(c) Please refer to cells C42253. Additionally, refer to row 3 for column headers
that are named "Sell" to aggregate the actual balancing sales (MWh),
approximately 1.05 million MWh.
(d) Please refer to cells C42253. Additionally refer to row 3 for column headers
that are named "Buy"to aggregate the total cost of actual balancing purchases
(dollars ($)), please divide this data by the data noted in the Company's
response to subpart (b) above, approximately $94.60/MWh.
(e) Please refer to cells C42253. Additionally refer to row 3 for column headers
that are named "Sell" to aggregate the total cost of actual balancing sales (in
$). Further, to get the average cost of actual balancing sales ($/MWh), please
divide this data by the data noted in the Company's response to subpart (c)
above, approximately $78.05/MWh.
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 31
Bayer Data Request 31
Please provide a copy of the Company's current Energy Risk Management Policy.
Response to Bayer Data Request 31
Please refer to Confidential Attachment Bayer 31 which provides a copy of the
most recent and current PacifiCorp Energy Risk Management Policy, approved
July 23, 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: Steve Stiles
Sponsor: John Fritz

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 32
Bayer Data Request 32
Please explain if the Idaho Public Utilities Commission has reviewed and/or
approved the Company's current Energy Risk Management Policy.
Response to Bayer Data Request 32
The Company has presented its Energy Risk Management Policy to the Idaho
Public Utilities Commission (IPUC) in the past, and the Company also provides
both IPUC staff and the IPUC PacifiCorp's semi-annual hedging reports that
demonstrates its hedge positions and compliance with its PacifiCorp's Energy
Risk Management Policy.
The IPUC received the April 17, 2023 version of the policy as part of the
Company's response to IPUC Audit Data Request 7 during the 2023 Idaho ECAM
proceeding (Case No. PAC-E-24-05). Previous versions of the policy were also
provided in the Company's responses during the 2022 ECAM proceeding (Case
No. PAC-E-23-09).
Please refer to the Company's response to Bayer Data Request 31, specifically
Confidential Attachment Bayer 31,which provides a copy of the most recent
version of Energy Risk Management Policy.
Recordholder: Mark Alder
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 33
Bayer Data Request 33
Please explain if the Idaho Public Utilities Commission has previously provided
any oversight into the Company's hedging policies. Oversight might include
prudency reviews of the Company's fuel and purchased power cost or
requirements with respect to hedging practices.
Response to Bayer Data Request 33
The Idaho Public Utilities Commission (IPUC) typically reviews the Company's
hedging policies during its annual audit of the Idaho Energy Cost Adjustment
Mechanism(ECAM). Additionally, the Company submits a hedging report to the
IPUC twice a year.
Recordholder: Mark Alder
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 34
Bayer Data Request 34
Please refer to the Direct Testimony of Ramon Mitchell, page 61. Please provide
a summary of all power hedges to date secured for 2025. Consider this an ongoing
request to update this summary as new transactions occur.
Response to Bayer Data Request 34
PacifiCorp objects to this data request to the extent the request is overly broad and
it would be unduly burdensome to produce the information requested. PacifiCorp
further objects to this data request on the grounds that it seeks information that is
not relevant and the request is not reasonably calculated to lead to the discovery of
admissible evidence. Subject to and without waiving the foregoing objections, the
Company responds as follows:
Please refer to Confidential Attachment Bayer 34. The Company will provide
quarterly updates in this general rate case (GRC)proceeding.
Recordholder: Steve Stiles
Sponsor: John Fritz/Paul Wood

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 35
Bayer Data Request 35
Please explain if the Company's current hedging practices have resulted in it
procuring more power than required to serve the Company's actual load. If the
answer is in the affirmative, please explain how the Company handles sell-backs
of over-hedged positions and how these sell-backs impact NPC.
Response to Bayer Data Request 35
PacifiCorp objects to this data request to the extent it calls for speculation. Subject
to and without waiving the foregoing objection, the Company responds as follows:
The Company hedges to meet forecast peak system obligations which at times
could be in excess of actual system obligations in any given hour. However,
during periods where the Company is long, an economic decision can be made to
either sell excess length into the market or back-down Company resources.
In the event the Company is long, an economic decision is made on how best to
handle excess length. Based on system conditions and the market, the Company
can either sell or back-down generation based on economics. As noted above,
there is an assessment of how to treat the excess length, in the same way that there
would be an assessment of whether to increase generation or purchase
incremental energy in response to a shortfall. Net power costs (NPC) include
revenue associated with market sales (which reduces NPC), and any reduction in
fuel costs due to a backdown of generation would similarly be reflected in NPC.
The impact to customer rates (as opposed to NPC) cannot be discussed with any
precision because of the nature of the energy cost adjustment mechanism
(ECAM) (e.g. sharing bands, etc.). The precise impact would be conditional on
the overall level of NPC relative to the baseline and operation of the sharing
bands.
Recordholder: Steve Stiles
Sponsor: John Fritz

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 36
Bayer Data Request 36
Please refer to the Direct Testimony of Ramon Mitchell, page 62. With respect to
the simulated short-term firm transactions, please provide the following data.
(a) Work papers supporting all forecasted short-term firm transactions used in the
Aurora production-cost model. Please provide work papers in Excel format
with all formulae and links intact.
(b) With regard to subpart (a), please provide the forecasted prices of all short-
term firm transactions and any work papers used to derive the forecasted
prices.
(c) Given that the hedges are secured the quarter prior to their effective period,
does the Company agree that the price differential between the hedged block
and the actual market price will be minimal? Please explain.
(d) Please explain how Aurora models the fixed volumes of the hedged blocks
versus the variable volume of other market purchases using the OFPC.
Response to Bayer Data Request 36
(a) Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon I Mitchell, specifically confidential files "GN_Pre-
hedging CONF.xlsx" and"GN_STF CONF.xlsb".
(b) Please refer to the Company's response to subpart(a) above.
(c) PacifiCorp objects to this discovery request to the extent it assumes the
Company secures all its hedges in the quarter prior to the effective period.
Subject to and without waiving the foregoing objection, the Company
responds as follows:
The Company does not agree that the difference between the hedged block
and the actual market price "will be minimal." Firstly, the Company does not
secure all hedges the quarter prior to the effective period. Hedging
requirements take effect starting six quarters prior to the quarter with
increasing minimum hedge percentage positions as the time to expiry
decreases. Secondly, energy market volatility can cause prices to fluctuate
materially even if the hedges expire shortly after their execution.
(d) The fixed volumes are quarterly blocks that are input into the model at the
prevailing official forward price curve (OFPC)while the rest of the market
purchases and sales are dispatched by the Aurora model during the simulation

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 36
to balance the system at the OFPC multiplied by the day-ahead/real-time
(DA/RT)percentile adder within the Aurora model.
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 37
Bayer Data Request 37
Please provide all work papers supporting the Company's market sales capacity
limits adjustment in Excel format with formulae and links intact.
Response to Bayer Data Request 37
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, specifically confidential file "GN_Market
Capacity CONF.xlsx."
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 38
Bayer Data Request 38
Please refer to the Direct Testimony of Ramon Mitchell, page 66. Do the market
sales capacity limits create a situation where the Company's simulated hedges
cannot be sold back into the market? Please explain.
Response to Bayer Data Request 38
No. Firstly, the Aurora model is a least cost optimization model with perfect
foresight. This means that the Aurora model knows exactly what energy and
capacity supply will be and also exactly what the energy and capacity demand
will be at an hourly granularity during all hours of the simulation. Secondly, the
market sales capacity limits are calculated off 48 months of actual historical day-
ahead and real-time sales aggregated to monthly heavy load hour(HLH) and light
load hour(LLH) limits by market hub. In actual operations, unlike the Aurora
model, the Company does not know what the exact energy and capacity supply
and energy and capacity demands are for each hour of the year. Therefore, in
actual operations, the Company may sell energy if it is determined that there is
excess supply, into the bilateral markets. These sales are what are used to
calculate the market capacity limits provided to the Aurora model for the
simulation, meaning that the historical situations where the Company has excess
energy are included in the calculation of the market sales capacity limits and
therefore, the concept of"selling back"hedges into the market is negated by the
modeling construct. That is to say, the system balancing sales already
incorporates normalized"sell back" of hedges through the market sales capacity
limits.
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 39
Bayer Data Request 39
Please provide all work papers supporting the Figure Regulation Reserves on
page 70 of Mr. Mitchell's direct testimony.
Response to Bayer Data Request 39
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, specifically confidential file "Figure
Reserve CONF.xlsx", tab "Figure Reserve".
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 40
Bayer Data Request 40
Please provide the net generation and maximum operating capacity of all
PacifiCorp thermal generating units on an hourly basis for the year 2023.
Response to Bayer Data Request 40
Please refer to Confidential Attachment Bayer 40 which provides PacifiCorp's
actual hourly generation and maximum capacity data for PacifiCorp's owned
thermal generating resources for calendar year 2023.
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: Mary Kelly/Gavin Mangelson
Sponsor: Mary Kelly/Gavin Mangelson

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 41
Bayer Data Request 41
Please provide the volume (MWh) and cost($/MWh) of emergency purchases
included in the 2025 NPC forecast.
Response to Bayer Data Request 41
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, specifically confidential file
"ID_GRC_2025_2023 Normalized Load.xlsm", tab "NPC Summary". For total
dollars ($) relating to emergency purchases, please refer to row 213. For total
megawatt-hours (MWh) relating to emergency purchases, please refer to row 519.
For a dollars per megawatt-hour($/MWh) cost, please take the $ in row 213 and
divide them by the MWh in row 519.
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 42
Bayer Data Request 42
Please refer to the Direct Testimony of Ramon Mitchell, pages 58-59, and provide
the curtailments (MWh) for each applicable generation resource included in the
2025 NPC forecast.
Response to Bayer Data Request 42
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, specifically confidential file
"ID_2025_2023 Normalized Load.xlsm". Please navigate to tab
"ResourceMonth" and filter the column B for the wind plant of interest. Please
refer to column F for capability. The number in this column multiplied by the
number of hours in that month is equal to the total amount of wind megawatt-
hours (MWh) that the Aurora model could have produced if ignoring transmission
constraints and other constraints stated in Ramon Mitchell's direct testimony.
Comparing the capability multiplied by the hours in that month with the MWh on
tab "NPC Summary" for that same wind plant will provide the curtailments at the
monthly granularity for each wind plant of interest.
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 43
Bayer Data Request 43
New Wind Generation Plant—Rock Creek I. For the Rock Creek I wind
project:
(a) Please separately identify each revenue requirement component(e.g., rate
base, expense, PTCs, REC revenue) associated with Rock Creek I wind
project in the Jurisdictional Allocation Model and/or the Regulatory
Adjustment Model. In addition, please identify the location within
PacifiCorp's work papers where the amounts for each of these revenue
requirement items are located.
(b) Using each of the identified amounts in subpart (a), please provide the
revenue requirement for the Rock Creek I wind project included in the test
period in Excel format with formulas intact.
(c) Please provide the exact date the project is expected to commence commercial
operation.
(d) If during the pendency of this case, RMP changes the expected commercial
operation date for this project, please provide the revised date for commercial
operation.
Response to Bayer Data Request 43
(a) Please refer to Confidential Attachment Bayer 43.
(b) Please refer to Confidential Attachment Bayer 43.
(c) The Rock Creek I wind project is anticipated to reach commercial operation
on December 31, 2024.
(d) The Company will supplement this data request response if the anticipated
commercial operation date (COD) changes.
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: Jeff Wagner/Craig Stelter
Sponsor: Jeff Wagner/ Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 44
Bayer Data Request 44
New Wind Generation Plant—Rock River I Repower. For the Rock River I
wind repowering project:
(a) Please separately identify each revenue requirement component (e.g., rate
base, expense, PTCs, REC revenue) associated with Rock River I wind
repowering project in the Jurisdictional Allocation Model and/or the
Regulatory Adjustment Model. In addition, please identify the location within
PacifiCorp's work papers where the amounts for each of these revenue
requirement items are located.
(b) Using each of the identified amounts in a), please provide the revenue
requirement for the Rock River I wind repowering project included in the test
period in Excel format with formulas intact.
(c) Please provide the exact date the repowering project is expected to commence
commercial operation.
(d) If during the pendency of this case, RMP changes the expected commercial
operation date for this project, please provide the revised date for commercial
operation.
Response to Bayer Data Request 44
(a) Please refer to Confidential Attachment Bayer 44.
(b) Please refer to Confidential Attachment Bayer 44.
(c) The Rock River I wind repower project is anticipated to reach commercial
operation on December 1, 2024.
(d) The Company will supplement this data request response if the anticipated
commercial operation date (COD) changes.
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: Tim Hemstreet/Craig Stelter
Sponsor: Tim Hemstreet/ Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 45
Bayer Data Request 45
New Wind Generation Plant—Foote Creek 114V Repower. For the Foote
Creek II-IV wind repowering project:
(a) Please separately identify each revenue requirement component(e.g., rate
base, expense, PTCs, REC revenue) associated with Foote Creek II-1V wind
repowering project in the Jurisdictional Allocation Model and/or the
Regulatory Adjustment Model. In addition, please identify the location within
PacifiCorp's work papers where the amounts for each of these revenue
requirement items are located.
(b) Using each of the identified amounts in a), please provide the revenue
requirement for the Foote Creek II-IV wind repowering project included in the
test period in Excel format with formulas intact.
(c) Please provide the exact date the repowering project went into commercial
operation.
Response to Bayer Data Request 45
(a) Please refer to Attachment Bayer 45.
(b) Please refer to Attachment Bayer 45.
(c) The new turbines within the Foote Creek II-IV Repower project reached
commercial operation on November 21, 2023. Therefore, the project has
already achieved commercial operation.
Recordholder: Tim Hemstreet/ Craig Stelter
Sponsor: Tim Hemstreet/ Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 46
Bayer Data Request 46
New Transmission Plant—Gateway South. For the Gateway South
transmission project:
(a) Please separately identify each revenue requirement component(e.g., rate
base, expense, PTCs, REC revenue) associated with the Gateway South
transmission project in the Jurisdictional Allocation Model and/or the
Regulatory Adjustment Model. In addition, please identify the location within
PacifiCorp's work papers where the amounts for each of these revenue
requirement items are located.
(b) Using each of the identified amounts in a), please provide the revenue
requirement for the Gateway South transmission project included in the test
period in Excel format with formulas intact. If RMP expects to place various
segments of the project into service at different times, please separately
identify the revenue requirement for each time period.
(c) Please provide the exact date(s) the transmission project is expected to
commence commercial operation.
(d) If during the pendency of this case, RMP changes the expected commercial
operation date(s) for this project, please provide the revised date(s) for
commercial operation.
Response to Bayer Data Request 46
(a) Please refer to Attachment Bayer 46.
(b) Please refer to Attachment Bayer 46.
(c) The Company is currently projecting an in-service date in November 2024.
(d) Any material change of this date during the pendency of the general rate case
(GRC) will be communicated.
Recordholder: Todd Jensen/Craig Stelter
Sponsor: Rick Vail/ Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 47
Bayer Data Request 47
New Transmission Plant—Gateway West Segment D.1. For the Gateway West
Segment D.1 transmission project:
(a) Please separately identify each revenue requirement component(e.g., rate
base, expense, PTCs, REC revenue) associated with the Gateway West
Segment D.1 transmission project in the Jurisdictional Allocation Model
and/or the Regulatory Adjustment Model. In addition, please identify the
location within PacifiCorp's work papers where the amounts for each of these
revenue requirement items are located.
(b) Using each of the identified amounts in a), please provide the revenue
requirement for the Gateway West Segment D.1 transmission project included
in the test period in Excel format with formulas intact. If RMP expects to
place various segments of the project into service at different times, please
separately identify the revenue requirement for each time period.
(c) Please provide the exact date(s) the transmission project is expected to
commence commercial operation.
(d) If during the pendency of this case, RMP changes the expected commercial
operation date(s) for this project, please provide the revised date(s) for
commercial operation.
Response to Bayer Data Request 47
(a) Please refer to Attachment Bayer 47.
(b) Please refer to Attachment Bayer 47.
(c) The Company is currently projecting an in-service date of the complete
Gateway West D.1 project in December 2024.
(d) Any material change of this date during the pendency of the case will be
communicated.
Recordholder: Todd Jensen/Craig Stelter
Sponsor: Rick Vail/ 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 2 contains Company proprietary information that could be
used to its commercial disadvantage.
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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 12ffi day of August, 2024.
Respectfully submitted,
By
Joe Dallas
Attorney
Rocky Mountain Power
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