20240812PAC to Staff 83-86_88_91_93_96-98_100-104_106-110_112_114-117.pdf

RECEIVED
Monday, August 12, 2024
IDAHO PUBLIC
_ ROCKY MOUNTAIN UTILITIES COMMISSION
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 12, 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-24-04
IPUC Set 6 (82-118)
Please find enclosed Rocky Mountain Power's Responses to IPUC 61h Set Data Requests 82-118,
excluding 82, 87, 89, 90, 92, 94-95, 99, 105, 111, 113, and 118. These remaining response will
be provided under separate cover. Also provided are non-confidential Attachments. Provided via
BOX are Confidential Attachments and Confidential Response IPUC 117. 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 elo&echohawk.com(C)
Lance Kaufman/IIPA lance(&aegisinsi hg t�(C)
Matthew Nykiel/ICL matthew.n, kiel&gmail.com
Brad Heusinkveld/ICL bheusinkveld&idahoconservation.org
Thomas J. Budge/Bayer tjkracineolson.com(C)
Brian C. Collins/Bayer bcollins(&consultbai.com
Greg Meyer/Bayer gme erkconsultbai.com
Kevin Higgins/Bayer khi2gins cr,energ. straw(C)

Neal Townsend/Bayer ntown send(&energystrat.com (C)
Ronald L. Williams/PIIC rwilliamskhawleytroxell.com
Brandon Helgeson/PIIC bhelgeson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinskmwanalytics.com
Val Steiner/PIIC val.steiner(cr�,itafos.com
Kyle Williams/PIIC williamsk(&byui.edu

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 83
IPUC Data Request 83
Please provide a detailed description of the Company's method for normalizing
energy sales and revenue. In the description, please identify any changes in the
method from Case No. PAC-E-21-07. Please provide any workpapers supporting
the energy sales and revenue normalization method, in electronic format with
links intact and formulae enabled.
Response to IPUC Data Request 83
Temperature normalization is applied to energy sales by rate schedule and the
resultant billing determinants and normalized present revenues are accordingly
adjusted. The normalization of energy sales and revenues is shown in the file "ID
GRC Blocking 2024.xlsx" included with the work papers supporting the direct
testimony of Company witness, Robert M. Meredith. Specifically tabs "Page 1
Exhibit No 60-BD", "TempREV", and"TempMWH" show how temperature
normalization is applied to sales, revenue, and billing determinants.
The method of applying temperature normalizations to sales, revenue, and billing
determinants is the same as in Case No. PAC-E-21-07. One difference is that in
Case No. PAC-E-21-07,billing determinants from calendar year 2019 were used
and adjusted to 2020 energy sales and customer counts. This was done because of
the anomalous nature of the 2020 historic period due to the COVID-19 pandemic.
Recordholder: Robert Meredith
Sponsor: Robert Meredith

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 84
IPUC Data Request 84
The document"7_Direct Testimony and Exhibit Ramon J Mitchell CONF" does
not include the confidential page of Exhibit No. 27 (General Electric Model 7F.04
Gas Turbine). Please provide the confidential version of Exhibit No. 27.
Response to IPUC Data Request 84
The Company does not have a confidential version of Exhibit No. 27. The
proprietary customer-specific information on Exhibit No. 27 was removed from
the document by General Electric and is not being provided on the record in this
general rate case (GRC).
Recordholder: Not Applicable
Sponsor: Not Applicable

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 85
IPUC Data Request 85
Please confirm that bid prices in EDAM are set by each participating utility. Also,
please confirm that each participating utility can set bid prices high to avoid
dispatching a resource.
Response to IPUC Data Request 85
Just like Idaho Power Company (IPC) and other utilities in current or pending
regional organized markets around the nation, bid prices are set by each
participating utility. Please refer to the direct testimony of Company witness, John
Tsoukalis, Exhibit No. 30 which provides a list of those utilities, and their details.
Participating utilities can attempt to set prices to avoid being dispatched but there
is no guarantee because the locational marginal price (LMP), which determines
whether the resource is dispatched for energy, can be higher than the soft and hard
bid caps in the California Independent System Operator(CAISO)markets, such
as the extended day-ahead market(EDAM).
Recordholder: Lynn Pham
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 86
IPUC Data Request 86
Mitchell's Direct Testimony states that Wyoming has a sharing band, while
Oregon and Washington have both dead bands and sharing bands in their net
power cost adjustment mechanisms. Please explain each of the three state's
current sharing policies and provide an example for each in a worksheet with
formulae intact.
Response to IPUC Data Request 86
Oregon:
• Deadand—Asymmetrical $30 million positive, $15 million negative
• Sharing Band—Symmetrical 90 percent Customer and 10 percent Company
Washington:
• Deadand—Symmetrical $4 million
• Sharing Band—Asymmetrical 50 percent Customer and 50 percent Company
between $4 million and $10 million positive or 75 percent Customer and 25
percent Company between$4 million and $10 million negative. Symmetrical
90 percent Customer and 10 percent Company greater than $10 million.
Wyoming:
• Deadand—None.
• Sharing Band—Symmetrical 80 percent Customer and 20 percent Company
Additionally, please refer to Attachment IPUC 86.
Recordholder: Jack Painter
Sponsor: Jack Painter

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 88
IPUC Data Request 88
Please explain why the Company does not intend to engage in marketing efforts
for the REC Option Program.
Response to IPUC Data Request 88
The Company does not intend to engage in marketing efforts in order to minimize
program administration costs.
Recordholder: Craig Eller
Sponsor: Craig Eller

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 91
IPUC Data Request 91
Please respond to the following regarding wheeling revenue:
(a) Please confirm that all the OATT wheeling revenue is recorded in FERC
Account 456.
(b) Please state whether OATT wheeling revenue is trued up in the ECAM. If so,
please explain how. If not, please explain why.
Response to IPUC Data Request 91
(a) Confirmed.
(b) The open access transmission tariff(GATT) wheeling revenue is not trued up
in the energy cost adjustment mechanism(ECAM)because it is recorded in
FERC Account 456 which is not a net power costs (NPC)FERC Account and
is therefore not included in the ECAM deferral.
Recordholder: Jack Painter/Ernie Knudsen
Sponsor: Jack Painter/Ernie Knudsen

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 93
IPUC Data Request 93
Page 57 of Mitchell's Direct Testimony states that"trapped energy is a modeling
concept only and does not exist in actual operations. It represents any excess
generation that cannot be used to serve load due to transmission constraints or
system-level oversupply." Please explain why trapped energy does not exist in
actual operations and how Aurora resolves the issue.
Response to IPUC Data Request 93
In actual operations, supply and demand must be in continuous balance to
maintain reliability of the bulk electric system (BES). The concept of"trapped
energy" refers to a "surplus" of energy on the transmission grid (supply greater
than demand). However, this is not permissible by North American Electric
Reliability Corporation (NERC) standards. Identical to actual operations, the
Aurora model lowers supply in proper economic order to maintain the supply
demand balance to prevent a surplus of energy ("trapped energy). As mentioned
in the direct testimony of Company witness, Ramon Mitchell, the prior production
cost model, the Generation and Regulation Initiative Decision Tool (GRID), was
incapable of reflecting the proper economic order of all system resources.
Recordholder: Ramon Mitchell
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 96
IPUC Data Request 96
Does Aurora treat PURPA energy as non-curtailable energy? If so, how?
Response to IPUC Data Request 96
Yes. The Company models Public Utility Regulatory Policies Act of 1978
(PURPA) (qualifying facilities (QF)) energy as fixed generation resources with a
fixed amount of generation(must-take resource), at all times /granularities in the
Aurora model.
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, specifically confidential file "Aurora GNw
Resource Table QFs CONF ' and files linked to it.
Recordholder: Eshwar Vyakarna Rajshekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 97
IPUC Data Request 97
For PPAs, does Aurora curtail these resources according to their contracts?
Response to IPUC Data Request 97
For the Top of the World power purchase agreement(PPA), the Aurora model
curtails this resource. For the other PPAs, the Aurora model does not curtail these
resources, consistent with actual operations.
Recordholder: Eshwar Vyakarna Rajshekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 98
IPUC Data Request 98
Please explain whether curtailment only applies to wind, not solar, in the Aurora
model.
Response to IPUC Data Request 98
The Company does not own any solar resources. Solar resources are not curtailed
in the Aurora model, consistent with actual operations.
Recordholder: Eshwar Vyakarna/Rajshekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 100
IPUC Data Request 100
Please respond to the following regarding Jim Bridger on Tab "NPC Summary"
of file "ID_GRC_2025_2023 Normalized Load.xlsm", given the in-service dates
of April 2024 for Jim Bridger units 1 and 2 as a gas plant:
(a) Please explain how each month's coal fuel cost is determined for Jim Bridger
(Line 234).
(b) Please explain how each month's gas fuel cost is determined for Jim Bridger
(Line 246).
Response to IPUC Data Request 100
(a) The fuel costs for Jim Bridger coal plant is calculated based on the expected
coal supply availability for the plant per the coal supply agreements (CSA)
executed d by the Company. The calculation for the costs is provided on tab
"Coal Expense Calculation" tab of the net power costs (NPC) report
"ID GRC 2025 2023 Normalized Load.xlsm".
(b) The fuel cost for Jim Bridger is determined by the real forward market gas
prices relevant to the Jim Bridger gas plant. The cost is the sum of gas fuel
costs and fuel start costs for the plant. The source for the gas fuel price (in
dollars per million British thermal units ($/MMbtu)) and gas fuel start costs
are provided with the confidential work papers supporting the direct
testimony of Company witness, Ramon J. Mitchell, specifically confidential
files "Aurora GNw Resource Table Thermal" and "Aurora GN Fuel Prices".
Recordholder: Eshwar Vyakarna Raj shekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 101
IPUC Data Request 101
Please respond to the following regarding PURPA QFs:
(a) Please explain how generation amounts of QFs are determined in calculating
NPC.
(b) Please confirm that QF generation is treated as a must-take resource in
Aurora.
Response to IPUC Data Request 101
(a) The generation for qualifying facilities (QF) are based on rolling 48-month
historical averages of the facilities' generation. Please refer to the confidential
work papers supporting the direct testimony of Company Witness, Ramon J.
Mitchell, specifically confidential file "Aurora GNw Resource Table QFs
CONF". Please also refer to Confidential Attachment IPUC 101 which
provides the data for QF generation.
(b) Confirmed.
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: Eshwar Vyakarna Raj shekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 102
IPUC Data Request 102
Page 61 of Mitchell's Direct Testimony states that"on average, a minimum of 75
percent of each month's largest generation deficit is hedged in the first quarter of
the future (e.g., in December 2024 this would apply to the first quarter of 2025)."
Furthermore, Page 62 of Mitchell's Direct Testimony states that quarterly 25 MW
energy blocks of heavy or light load hour products are loaded into the model to
reflect the Company's hedging policy. Please provide an example illustrating
these statements.
Response to IPUC Data Request 102
The Company assumes that this request is intended to ensure that the PacifiCorp's
Energy Risk Management Policy is reflective of the description it received in the
quoted testimony (on average, a minimum of 75 percent of each month's largest
generation deficit is hedged in the first quarter of the future (e.g., in December
2024 this would apply to the first quarter of 2025)). Based on the forgoing
assumption, the Company responds as follows:
Please refer to the Company's response to Bayer Data Request 31, specifically
Confidential Attachment Bayer 31,which provides a copy of PacifiCorp's most
recent Energy Risk Management Policy, approved July 23, 2024.
The Company assumes the reference to "Page 62 of Mitchell's Direct Testimony
states that quarterly 25 MW energy blocks of heavy or light load hour products
are loaded into the model to reflect the Company's hedging policy" is intended to
verify that the Company's proposed Aurora modeling enhancement models
hedges in 25 megawatts (MW) increments, as described in Ramon Mitchell's
direct testimony. Based on the forgoing assumption, the Company responds as
follows:
Please refer to the confidential work papers supporting Ramon Mitchell's direct
testimony, specifically confidential work paper, "GN_Prehedging CONF".
Recordholder: Eshwar Vyakarna Rajshekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 103
IPUC Data Request 103
Please provide the work papers for determining the "normal hydro and
temperature conditions" as explained on Page 91 of McCoy Exhibit No. 48.
Response to IPUC Data Request 103
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon I Mitchell, specifically confidential files "GN_Weekly
Hydro CONF", "Aurora GN Hydro Generation CONF" and the files linked to
them. The hydro conditions are normalized as stated in the Company's response
to IPUC Data Request 106.
The Company assumes the reference to "temperature conditions" is intended to be
a reference to the weather normalized load conditions that are modeled in the
Aurora net power costs (NPC) modeling in this general rate case (GRC). Based on
the foregoing assumption, the Company responds as follows:
Please refer to the Company's response to IPUC Data Request 105 which
discusses the weather normalization of load in this GRC proceeding.
Recordholder: Eshwar Vyakarna Rajshekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 104
IPUC Data Request 104
For purposes of determining the NPC impact of modeling changes, according to
Mitchell's Direct Testimony, the Company uses a 2025 forecasted load. Please
respond to the following:
(a) Please explain whether the expected 2025 forecast load is temperature-normal
(i.e. (Normal based on the historic 20-year rolling window) and whether the
extreme weather adjustment is applied or not.
(b) Please explain why the Company didn't use the 2023 weather-normalized load
to do the analysis.
Response to IPUC Data Request 104
(a) The 2025 Forecast load is based on the historic 20-year rolling window
percentile adjusted to achieve climate change expectations. The climate
adjusted normal weather uses the data from the historical 20-year rolling
window (2003 through 2022) and adjusts the percentile of the data to achieve
the expected target average annual temperature and calculate the HDD and
CDD and peak producing weather used within the energy forecast and peak
forecast, respectively. This is the same methodology adopted in the
Company's 2023 Integrated Resource Plan(IRP). The expected target
average annual temperatures are based on the United States Bureau of
Reclamation, March 2021, Managing Water in the West, Technical
Memorandum No. ENV-2021-001, West-Wide Climate Risk Assessments:
Hydroclimate Projections.
(https://www.usbr.gov/climate/secure/docs/2021 secure/westwidesecurereportl
-2.pdf)
(b) Please refer to direct testimony of Company witness, Ramon J. Mitchell, page
9, line 17. The Company believes that the forecasted load conditions for test
period 2025 are accurate and that therefore the determining the net power
costs (NPC) impacts of modeling changes using 2025 forecasted load is
accurate as the other modeling assumptions use forecasted system conditions
of 2025. The load and other system conditions for the test period 2025 are
representative of expected system conditions for 2025.
Recordholder: Eshwar Vyakarna Rajshekar Rao /Lee Elder
Sponsor: Ramon Mitchell/Lee Elder

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 106
IPUC Data Request 106
Page 29 of Mitchell's Direct Testimony states that"[a] long-term drought, dating
back to the 2019-2020 winter, continues across parts of the Pacific Northwest
(current hydroelectric generation is 25 percent lower than the 10-year average at
the regional level) and is picked up in the normalized hydroelectric generation
forecast. Furthermore, the removal of four Company-operated hydroelectric
projects along the Klamath river contribute to this decrease. These projects totaled
approximately 180 MW of capacity and have ceased generation."Please explain
how the long-term drought is picked up in the normalized hydroelectric
generation forecast.
Response to IPUC Data Request 106
For hydro plants located on the Lewis River, the Company uses the median of 94
years of water flow data to estimate total annual flow.
For hydro plants located on the North Umpqua river, the Company uses the
median of 74 years of water flow data to estimate total annual flow.
For hydro plants located on the Columbia river, the Company uses the median of
10 years of water flow data to estimate total annual flow.
For all run-of-river hydro plants, the Company uses the median of 30 years of
water flow data to estimate total annual flow.
Since historical data is used to determine the median, the long-term drought
would be picked up in the normalized hydroelectric generation forecast by
shifting the median in a downwards direction.
Recordholder: Eshwar Vyakarna Rajshekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 107
IPUC Data Request 107
The proposed NPC is based on the OFPC dated March 29, 2024. Please respond
to the following:
(a) Please provide the latest OFPC.
(b) Please explain when the OFPC is dated.
(c) Please determine the new NPC based on the latest OFPC.
(d) Please update Mitchell's "ID_GRC_2025_2023 Normalized Load.xlsm" work
paper based on the latest OFPC.
Response to IPUC Data Request 107
(a) PacifiCorp's latest/most recent official forward price curve (OFPC)was
produced on June 28, 2024. Please refer to Attachment IPUC 107-1.
(b) Please refer to the Company's response to subpart (a) above.
(c) Please refer to Confidential Attachment IPUC 107-2, specifically confidential
work paper "0624 OFPC ID_GRC_2025_Update_2023 Normalized Load
CONF".
(d) Please refer to the Company's response to subpart (c) above.
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: Elaine Biggs/Eshwar Vyakarna Raj shekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 108
IPUC Data Request 108
Page 75 of Mitchell's Direct Testimony states that market capacity limits are
applied to all trading hubs. Please answer the following:
(a) Please list market capacity limits for each trading hub and provide how the
limits were determined for each hub.
(b) Please provide specific historic evidence that outside sales transactions could
not be transacted at market prices due to unavailable buyers.
Response to IPUC Data Request 108
(a) The market capacity sales limit is calculated as the 48-month rolling average
of the Company's historical sales transactions (only spot market sales
volumes) for each trading hub. For the market capacity limits at each trading
hub calculations, please refer to the confidential work papers supporting the
direct testimony of Company witness, Ramon J. Mitchell, specifically
confidential file "GN_Market Capacity CONF".
(b) Please refer to the confidential work papers supporting Ramon Mitchell's
direct testimony, specifically confidential file "Aurora GN Market Prices
CONF", tab "Adder Source", section "Historical Dollars vs Indexed Dollars",
rows 155:203, and average calculated price difference section "Historical
Dollars vs Indexed Dollars- Monthly Average", rows 205:218. The average
price difference as seen in the above referenced sections for sales transactions
show that the Company transacted at prices that were below market prices for
sales of its electricity.
Recordholder: Eshwar Vyakarna Raj shekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 109
IPUC Data Request 109
Pages 34-35 of Mitchell's Direct Testimony shows coal prices for Hunter's
Bronco Utah Operations contract, Hunter's Wolverine Fuel Sales contract, and
Huntington's Wolverine Fuel Sales contract are high due to "Utah market supply
shortages". Please provide evidence that these contracts are prudent.
Response to IPUC Data Request 109
PacifiCorp objects to this request to the extent it seeks legal analysis, opinions,
and/or conclusions. Subject to and without waiving the foregoing objection, the
Company responds as follows:
The requested information is highly confidential and commercially sensitive. The
Company requests special handling. Please contact Mark Alder at(801) 220-2313
to make arrangements to review.
Recordholder: Heather Garcia
Sponsor: David Webb/Brian Greer

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 110
IPUC Data Request 110
Page 38 of Mitchell's Direct Testimony states that"Aurora can receive more than
one incremental price for the purpose of forecasting dispatch of coal-fired
resources and can recognize and optimize around volumetric constraints in each
price tier." Please respond to the following:
(a) Please provide an example to illustrate tiered prices in Aurora.
(b) Please explain how tiered prices affect dispatch of coal plants.
(c) Please explain the extent that the Company's coal contracts use tiered prices
backed up with evidence.
Response to IPUC Data Request 110
(a) Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, specifically confidential work paper,
"Aurora GN Fuel Prices CONF", tab "Coal Costs 2025". As shown in the
referenced work paper, coal supply agreements (CSA) for the different coal-
fired resources have tiered prices that are input into the Aurora model,
specifically refer to tab "Fuel Price". The "Fuel Price" tab shows the different
tiers for each coal-fired resource. Column "Reference Fuel"in tab "Fuel
Price" is used to assimilate the different tiers for each tier.
(b) In the Aurora model, tiered prices inform the model during the commitment
and dispatch about the amount of coal available in each tier and the price
associated with each tier.
(c) Please refer to Confidential Attachment IPUC 110. This file illustrates the
tiered pricing and volumes available in the Company's coal contracts, and
which were used for the Aurora modeling.
Recordholder: Eshwar Vyakarna Rajshekar Rao /Dan Moody
Sponsor: Ramon Mitchell/Dan Moody

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 112
IPUC Data Request 112
Please respond to the following regarding Western Resource Adequacy Program
(WRAP) fees:
(a) How is the amount of the forecasted 2024 WRAP fees determined?
(b) How is the amount of the 2023 WRAP fees determined?
(c) Why do the fees decrease in 2024 compared to 2023?
(d) Please explain when Idaho ratepayers will begin receiving benefits from the
WRAP.
Response to IPUC Data Request 112
(a) Please refer to the Western Power Pool's (WPP)Western Resource Adequacy
Program (WRAP)Detailed Design publication. Specifically Section 1.7 (Cost
Allocation), subsection 1.7.1 (Allocating Costs to the WRAP Participants),
Table 1-2 (Cost Allocation for Participants) of the WRAP Detailed Design
publication breaks out how WRAP costs are allocated to participants. The
WRAP Detailed Design publication is publicly available and can be accessed
by using the following website link:
https://www.westeMpowerpool.org/private-media/documents/2023-03-
10 WRAP Draft Design Document FINAL.pdf).
Base costs and 50 percent of the dual benefit costs are charged equally to all
WRAP participants. Load costs and 50 percent of the dual benefit costs are
allocated based upon a participant's megawatt(MW) load in relation to the
total MW load of the program.
Please refer to Attachment IPUC 112 which provides a copy of the WRAP
budget forecast.
(b) Please refer to the Company's response to subpart (a) above, specifically
Table 1-2 in the WRAP Detailed Design publication.
(c) The WRAP fees decreased in 2024 compared to 2023 because the program
footprint expanded, which spread costs amongst more WRAP participants.
Additionally, the WPP created a more robust set of hourly rates for charging
time to the WRAP resulting in some work being done to support the WRAP
could be charged at a lower hourly rate.

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 112
(d) PacifiCorp is currently an active member of the WRAP and currently
realizing benefits for Idaho customers. These benefits are largely realized
through system planning and resource adequacy allowing for greater
reliability in the West.
Recordholder: Ben Faulkinberry
Sponsor: Paul Wood

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 114
IPUC Data Request 114
Please respond to the following regarding Wyoming Wind Generation Tax as
discussed on Page 38 of McCoy's Direct Testimony:
(a) Please confirm that the excise tax is not levied for wind generation that is used
to meet native customer load.
(b) How does the Company determine that energy for sales or trade came from a
Wyoming wind facility and not another Company resource?
Response to IPUC Data Request 114
(a) Regarding the Wyoming Wind Generation Tax, the Company responds as
follows:
The excise tax is levied for all Wyoming wind generation output. All
Wyoming wind generation is subject to the tax, except for generation from
new facilities, which are exempt from the tax for three years following the
date the facility first produces electricity for sale.
(b) As discussed in the direct testimony of Company witness, Shelley E. McCoy,
page 38, "[t]he tax is on the production of any electricity produced from wind
resources for sale or trade on or after January 1, 2012". As it concerns test-
period commercially online resources, paraphrasing the above language
results in the following statement: the tax is on all electricity output onto the
transmission system from Wyoming wind resources.
The Company determines that electricity came onto the transmission system
from any given Wyoming wind facility by metering the output of the facility.
Recordholder: Deanna Fladstol
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 115
IPUC Data Request 115
Please provide the Excel version of Page 90 of Exhibit No. 48 of McCoy's Direct
Testimony.
Response to IPUC Data Request 115
The "Adjustment Summary for Net Power Cost", page 90 of Exhibit No. 48, is a
result of the macros contained within the Regulatory Adjustment Model (RAM)
and previously provided as a work paper by Company witness, Shelley E.
McCoy. Please specifically refer to tab "Adj Summary" of the RAM workpaper.
Recordholder: Nick Highsmith
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 116
IPUC Data Request 116
Please explain what types of costs are included on the allowance line item in
Exhibit No. 51 of McCoy's Direct Testimony. Specifically, are all the costs
associated with Washington CCA allowances?
Response to IPUC Data Request 116
Referencing the direct testimony of Company witness, Shelley McCoy, Exhibit
51, the Company responds as follows:
The costs included on the"Allowance" line item(row 14) of Exhibit No. 51 are
related to the cost of complying with Washington's Climate Commitment Act
(CCA), specifically the total cost associated with generation at Chehalis plant
times the Washington CCA allowance costs.
Recordholder: Eshwar Vyakarna Rajshekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 117
IPUC Data Request 117
Please respond to the following regarding the cost of Washington CCA
allowances:
(a) Please provide the cost of Washington CCA allowances at the Company level
and for the Idaho jurisdiction.
(b) Please explain how the system and Idaho-allocated allowance costs are
determined.
(c) Please provide the work papers that determine the system and Idaho-allocated
allowance costs.
(d) Please identify the specific tabs and line items that contain these allowance
costs in Excel file "ID GRC 2025 2023 Normalized Load.xlsm".
Confidential Response to IPUC Data Request 117
(a) Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, specifically confidential work paper
"Aurora GNw Resource Table Thermal CONF ' tab " r x". The Washington
Climate Commitment Act CCA allowance cost is
RNote: the Company uses system level data for its net power costs
PC) odeling.
(b) Consistent with Washington Department of Ecology (Ecology) greenhouse
gas (GHG)reporting requirements, Ecology assigns each emitting resource an
emissions factor expressed in million metric ton carbon dioxide equivalents
per megawatt-hour(MT CO2e/MWh). Chehalis's assigned emissions factor is
0.4 metric ton per megawatt-hour(MT/MWh). Because each allowance
covers 1 MT of CO2e annually, this is equivalent to 2.5 MWh/MT—or 2.5
MWh/allowance regardless of the resource's generation.
(c) Please refer to the Company's response to IPUC Data Request 116.
(d) Referencing file ""ID_GRC_2025_2023 Normalized Load.xlsm", please refer
to tab "NPC", row 282 for the costs associated with the Washington CCA
allowance. The cost of this allowance in NPC modeling is calculated by
multiplying the cost of allowance times the modeled megawatt-hours (MWh)
generation from the Chehalis plant.
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

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
IPUC Data Request 117
Procedure No. 67—Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement(NDA) executed in this proceeding.
Recordholder: Eshwar Vyakarna Raj shekar Rao
Sponsor: Ramon Mitchell

Joe Dallas (ISB# 10330)
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 IPUC set 6 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 12'h day of August, 2024.
Respectfully submitted,
Y \v)
Joe Dallas
Attorney
Rocky Mountain Power
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