20240823PAC to PIIC 1-28_Attorney Attestation.pdf

RECEIVED
Friday, August 23, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 23, 2024
Ronald L. Williams
Brandon Helgeson
Attorneys For PIIC
rwilliams(&hawleytroxell.com(C)
bhel eg son&hawleytroxell.com(C)
Bradley Mullins
brmullins(a�mwanalytics.com(C)
Val Steiner
val.st einer nitafo s.com
Kyle Williams
williamsk(&byui.edu
RE: ID PAC-E-24-04
PIIC Set 1 (1-28)
Please find enclosed Rocky Mountain Power's Responses to PIIC I" Set Data Requests 1-18, 20-
23, and 25-28 an Attachments. The remaining response 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.: Monica Barrios-Sanchez/IPUC monica.barriossanchez(�i),puc.idaho.gov (C)
S ecretary(a,yuc.Idaho.gov
Eric L. Olsen/IIPA elo(&echohawk.com(C)
Lance Kaufman/IIPA lancena,ae isg insi hg t.com(C)
Matthew Nykiel/ICL matthew.nykielkamail.com

Brad Heusinkveld/ICL bheusinkveld(a�idahoconservation.org
Thomas J. Budge/Bayer tj racineolson.com(C)
Brian C. Collins/Bayer bcollins(&consultbai.com
Greg Meyer/Bayer gme erkconsultbai.com
Kevin Higgins/Bayer khia gins&energystrat.com(C)
Neal Townsend/Bayer ntownsend(u-benergystrat.com (C)

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 1
PIIC Data Request 1
Reference the work papers of Witness Shelley McCoy: Please provide all of the
B-Tab work papers supporting Ms. McCoy's revenue requirement calculations in
the same manner provided in response to PIIC Production Request 5 in Case No.
PAC-E-21-07.
Response to PIIC Data Request 1
Please refer to Attachment PIIC 1 which provides a copy of for the B-tab work
papers for this Idaho general rate case (GRC).
Recordholder: Tyler Wells
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 2
PIIC Data Request 2
Reference the work papers of Witness Shelley McCoy: Please provide all of the
B-Tab work papers for calendar years 2020, 2021 and 2022 supporting
PacifiCorp's results of operations in manner provided in response to PIIC
Production Request 5 in Case No. PAC-E-21-07.
Response to PIIC Data Request 2
Please refer to Attachment PIIC 2 which provides the 2020 through 2022 B-Tabs
from the Idaho December Results of Operations (ROO)filings.
Recordholder: Tyler Wells
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 3
PIIC Data Request 3
Please identify the total non-NPC revenue requirement of Chehalis included in the
test period this matter, including separate detail for the following:
(a) Gross Plant.
(b) Accumulated Depreciation.
(c) Accumulated Deferred Income Taxes.
(d) Fuel Stock.
(e) Other rate base items.
(f) Operating expenses.
(g) Property Taxes.
(h) Washington State Taxes.
(i) Insurance.
0) Any Other Expenses.
Response to PIIC Data Request 3
Please refer to Attachment PIIC 3.
Recordholder: Craig Stelter
Sponsor: Nicholas Highsmith

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 4
PIIC Data Request 4
Does PacifiCorp own any transmission equipment interconnected to the Chehalis
Power plant? If yes, please describe all such assets and identify the revenue
requirement associated with the assets.
Response to PIIC Data Request 4
No. PacifiCorp does not own any transmission equipment interconnected to the
Chehalis power plant.
Recordholder: Louisa Bruschi-Dadik/Courtney Walton
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 5
PIIC Data Request 5
Please provide a description Washington Public Utility Tax and identify the
amount of the tax (on both a System and Idaho-allocated basis) included in
revenue requirement.
Response to PIIC Data Request 5
The Washington Public Utility Tax (PUT) is a tax for engaging in certain public
service and transportation businesses within Washington and is generally in lieu
of the Washington Business and occupation (B&O)tax. The PUT is imposed on
the gross income of the business. The amount of PUT included revenue
requirement in this docket is provided in Exhibit 48, Tab B-5 (Taxes Other than
Income) and amounts to $15,634,905 on a total-Company basis, or $833,871
Idaho allocated.
Recordholder: Brian Keyser
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 6
PIIC Data Request 6
Please explain how the Washington Public Utility Tax is assigned under the
Washington Interjurisdictional Allocation Method (WIJAM).
Response to PIIC Data Request 6
The Washington Public Utility Tax (PUT) is situs assigned to Washington under
the Washington Interjurisdictional Allocation Method(WIJAM).
Recordholder: Craig Larsen
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 7
PIIC Data Request 7
Does PacifiCorp pay any use taxes to the State of Washington for natural gas
purchased to fuel the Chehalis Power plant? If yes,please:
(a) Identify and describe all such taxes;
(b) Identify the FERC account where the taxes are recorded;
(c) State the amount of such taxes included in revenue requirement(on both a
System and Idaho-allocated basis); and
(d) State the amount of such taxes paid or incurred in calendar year 2023 (on both
a System and Idaho-allocated basis).
Response to PIIC Data Request 7
(a) PacifiCorp pays a natural gas use tax to the Washington Department of
Revenue monthly. The tax base is the purchase price of the gas plus
transportation costs. The tax rate is 3.852 percent.
(b) FERC Account 547.1.
(c) The Chehalis use tax is incorporated into the revenue requirement initially
through a gas cost multiplier in the Chehalis natural gas price curve used to
determine the Chehalis natural gas consumption forecast in the general rate
case (GRC) forecast. In the GRC, the multiplier is 1.03852 because the tax
itself is forecasted to be 3.852 percent of each dollar consumed. The amount
of Chehalis use tax included in revenue requirement therefore can be
estimated as approximately $3,261,518 total-Company [Chehalis Fuel
Expense—(Chehalis Fuel Expense/ 1.03852] = [87,932,300—
(87,932,300/1.03852)]. The state allocated amount is $192,469.
(d) In calendar year 2023, PacifiCorp incurred $5,749,922 total-company for the
Chehalis use tax. The state allocated amount is $339,314.
Recordholder: To Be Determined
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 8
PIIC Data Request 8
Please provide PacifiCorp's best estimate of the fair market value of the Chehalis
power plant as of December 31, 2023.
Response to PIIC Data Request 8
PacifiCorp objects to this request as vague, overly broad, unduly burdensome,
requesting information that is not in the Company's possession or control,
requesting the creation of a new study or analysis and not reasonably calculated to
lead to the discovery of admissible evidence. Without waiving this objection, the
Company responds as follows:
PacifiCorp has not prepared the requested information.
Recordholder: Mark Paul
Sponsor: Thomas Burns

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 9
PIIC Data Request 9
Please confirm or deny that the Chehalis power plant has a negative fair market
value as of December 31, 2023. Please explain the answer and provide analytical
work papers supporting any assertions made as to the value of the Chehalis power
plant.
Response to PIIC Data Request 9
Please refer to the Company's response to PIIC Data Request 8.
Recordholder: Mark Paul
Sponsor: Thomas Burns

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 10
PIIC Data Request 10
Please provide PIIC Witness Bradley G. Mullins with access to the Aurora model,
Aurora model project files, and all work papers and scripts necessary to duplicate
the NPC modelling PacifiCorp is proposing to include in revenue requirement in
this docket.
Response to PIIC Data Request 10
The Company notes that Bradley Mullins of MW Analytics Energy and Utility
Consulting 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 April 24, 2024, the Company purchased a 12-month temporary Aurora license
(and Gurobi license) for Bradley Mullins of MW Analytics Energy and Utility
Consulting, representing PacifiCorp Idaho Industrial Customers (PIIC), 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 April 23, 2025.
On August 12, 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 Bradley Mullins. 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 Bradley Mullins, as well as the terms and
conditions of the confidentiality protections within the NDA executed by Bradley
Mullins applicable in this 2025 GRC proceeding.
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.

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 10
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 23, 2024
PIIC Data Request 11
PIIC Data Request 11
Please provide a fully functional, linked version of the NPC template, including
links to the DART adjustment work papers and any other native links.
Response to PIIC Data Request 11
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell. Please specifically refer to confidential file
"ID_GRC_2025_2023 Normalized Load.xlsm", tab "STF DA-RT"which
provides the links to confidential file "Aurora GN Market Prices CONF.xlsb"
which in turn contains the supporting calculations for the day-ahead/real-time
(DA/RT) adjustment.
Recordholder: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 12
PIIC Data Request 12
Reference work paper"Aurora GN Market Prices CONF," Tab "Adders Source":
(a) Please provide the source data used to calculate the values in the referenced
work paper.
(b) Please provide the equivalent DA/RT data over the period January 1, 2015
through December 31, 2019.
(c) Please also provide the source data used to calculate the DART values over
the period January 1, 2015 through December 31, 2019.
Response to PIIC Data Request 12
(a) Please refer to Confidential Attachment PIIC 12-1, specifically the
confidential files containing "2020", "2021", "2022" or"2023" in the file
names. Please refer to Attachment PIIC 12-2 for the revision history of the
processed source data.
(b) Please refer to Confidential Attachment PIIC 12-1, specifically the
confidential files containing "2015", "2016", "2017", "2018"or"2019" in the
file names. Please refer to Attachment PIIC 12-2 for the revision history of the
processed source data.
(c) Please refer to Confidential Attachment PIIC 12-1, specifically tab
"HourlySourceData" in each of the provided confidential files. Please refer to
Attachment PIIC 12-2 for the revision history of the processed source data.
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: Isaiah Zacharia
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 13
PIIC Data Request 13
PacifiCorp has announced its intention to cease all MSP negotiations. Please
explain how PacifiCorp proposes to calculate actual net power costs included in
the Energy Cost Adjustment Mechanism following the expiration of the 2020
Protocol.
Response to PIIC Data Request 13
To clarify, PacifiCorp terminated the negotiations with the Framework Issues
Workgroup (FIWG). Per the terms of the 2020 Multi-State Process Inter-
Jurisdictional Cost Allocation Protocol (2020 Protocol), PacifiCorp will develop
an allocation methodology for use in rate proceedings in each state commission,
in accordance with state procedures, to replace the current allocation
methodology. PacifiCorp will calculate actual net power costs (NPC) in
accordance with the subsequent allocation methodology.
Recordholder: Matt McVee
Sponsor: Matt McVee

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 14
PIIC Data Request 14
Reference McCoy work paper"4.9 - Pension Non-Service Expense,"Tab "4.9.1
(a) Please explain what pension non-service expenses and post-retirement non-
service expenses are and how they are calculated.
(b) Why did PacifiCorp set the GL 554012 Pension Non-Service Expense amount
to zero in the forecast period?
(c) Please provide the GL 554012 Pension Non-Service expense /benefit by
month over the period January 1, 2020 through December 31, 2023.
(d) Reference GL 554022 Post-Retirement Non-Service Expense: Please provide
the GL 554012 Pension Non-Service expense /benefit by month over the
period January 1, 2020 through December 31, 2023
(e) Please provide PacifiCorp's most recent actuarial reports calculating pension
non-service expenses and other post-retirement benefit non-service expenses.
Response to PIIC Data Request 14
(a) Pension Non-Service Expenses include interest costs related to the benefit
obligation, the expected return on plan assets, the amortization of prior service
cost/credit, the amortization of any annual remeasurement gains/losses that are
initially recognized in other comprehensive income, and any amortization of
transition obligation or asset from the initial adoption of Financial Accounting
Standards (FAS) 87.
Calculation.
Add: Interest Cost
Add: Expected Return on Assets(Gain)/Loss
Add: Amortization of Transition(Asset)Obligation
Add: Amortization of Prior Service Cost(Credit)
Add: Amortization of(Gain)/Loss
Total Pension Non-Service Expenses
Post-Retirement Non-Service Expenses_include interest costs related to the
benefit obligation, the expected return on plan assets, the amortization of prior
service cost/credit, the amortization of any annual remeasurement gains/losses
that are initially recognized in other comprehensive income, and any
amortization of transition obligation or asset from the initial adoption of FAS
87.

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 14
Calculation:
Add: Interest Cost
Add: Expected Return on Assets(Gain)/Loss
Add: Amortization of Prior Service Cost/(Credit)
Add: Amortization of(Gain)/Loss
Total Post-Retirement Non-Service Expenses
(b) Per Idaho Public Utilities Commission (IPUC) Order No. 32196, the 2023
accrual basis pension expense for the PacifiCorp Retirement Plan (PRP) is
removed and is replaced by a three-year average of cash contributions made
by the Company to pension expense. The Company has not made any cash
contributions in the past three years nor does it plan to make any contributions
in the foreseeable future resulting in the zero forecast period to the test year.
(c) Please refer to the table provided below:
,12020 1±12021 -12022 �12023
<1/30/2020
Jan (399,614.16) (701,504.92) (103,907.25) (617,215.92)
Feb (399,614.16) (701,504.92) (103,907.25) (617,215.92)
Mar (399,614.16) (701,504.92) (103,907.25) (617,215.92)
Apr (399,614.16) (701,504.92) (103,907.25) (617,215.92)
May (399,614.16) (701,504.92) (103,907.25) (617,215.92)
Jun (399,614.16) (701,504.92) (103,907.25) (617,215.92)
Jul (399,614.16) (701.504.92) (103,907.25) (617,215.92)
Aug (399,614.16) 8,981,731.60(1) (103,907.25) (617,215.92)
Sep (399,614.16) 34,688.60 (103,907.25) (617,215.92)
Oct (399,614.16) 34,688.60 (103,907.25) (617,215.92)
Nov (399,614.16) 34,688.60 (103,907.25) (617,215.92)
Dec (399,614.16) 6,734,032.68(2)24,576,679.75(3) (617,215.92)
Total (4,795,369.92) 10,909,295.64 23,433,700.00 (7,406,59L04)
(1) 8,981,731.60 Included 713L21 PENSION REMEASUREMENT of$8.947,043
(2) 6,734,032.68 Included 2021 settlement true-up of($356,278.27)and YEAR END PENSION ADJUSTMENT of$7.055,622.35
(3) 24,576,679.75 Included 2022 settlementtrue-upof($246,074)and YEAR END PENSION ADJUSTMENT of$24,926.661
(d) Please refer to the table provided below:
1402020 u2021 111022 -2023
<1/31/2020
Jan (363,429.27) (107,969.04) (178,492.84) (435,671.16)
Feb (363,429.27) (107,969.04) (178,492.84) (435,671.16)
Mar (363,429.27) (107,969.04) (178,492.84) (435,671.16)
Apr (363,429.27) (107,969.04) (178,492.84) (435,671.16)
May (363,429.27) (107,969.04) (178,492.84) (435,671.16)
-Jun (363,429.27) (142,103.16) (178,492.84) (435,671.16)
Jul (369,812.36) (113,658.06) (178,492.84) (435,671.16)
Aug (364,341.14) (113,658.06) (178,492.84) (435,671.16)
Sep (364,341.14) (113,658.06) (178,492.84) (435,671.16)
Oct (364,341.14) (108,439.50) (178,492.84) (435,671.16)
Nov (364,341.14) (61,472.46) (178,492.84) (435,671.16)
Dec (364,341.14) (108,439.50) (178,492.84) (435,671.16)
Total (4,372,093.68) (1,301,274.00) (2,141,914.08) (5,228,053.92)

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 14
(e) Please refer to Attachment PIIC 14.
Recordholder: Ivy Widjaja
Sponsor: Sheila Diver

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 15
PIIC Data Request 15
Please identify all costs included in revenue requirement associated with
allocations from Berkshire Hathaway Energy Holdings Company or any other
affiliate. Please provide this detail by FERC account.
Response to PIIC Data Request 15
Please refer to Attachment PIIC 15.
Recordholder: Sheila French
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 16
PIIC Data Request 16
Please provide the intercompany allocation manual that establishes how costs are
allocated to and from PacifiCorp affiliates.
Response to PIIC Data Request 16
Please refer to Attachment PIIC 16.
Recordholder: Sheila French
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 17
PIIC Data Request 17
Please provide transaction level details supporting all amounts allocated to
PacifiCorp from Berkshire Hathaway Energy Holdings Company or any other
affiliate.
Response to PIIC Data Request 17
Please refer to the Company's response to PIIC Data Request 15.
Recordholder: Sheila French
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 18
PIIC Data Request 18
Please identify all memberships and dues included in revenue requirement
through an intercompany allocation to PacifiCorp from an affiliate or parent, with
detail of amount and the organization to which the amounts were paid.
Response to PIIC Data Request 18
Please refer to Attachment PIIC 18.
Recordholder: Sheila French
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 20
PIIC Data Request 20
Please provide PacifiCorp's calculation of the effective rates for Allowance for
Funds Used for Construction that were used for calendar year 2023, with details
of all debt items and equity costs included in that calculation.
Response to PIIC Data Request 20
Please refer to Attachment PIIC 20.
Recordholder: Zack Much
Sponsor: Sheila Diver

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 21
PIIC Data Request 21
Reference McCoy work paper"4.4 - Outside Service Expense,"Tab "4.4.1":
(a) Please provide the equivalent data for each calendar year 2018, 2019, and
2020.
(b) Please explain why the outside services expenses increase so significantly in
2022 and 2023.
(c) Was the increase in 2022 and 2023 related to wildfire litigation? If yes, please
quantify the amount of the increase related to wildfire litigation.
Response to PIIC Data Request 21
(a) Please refer to Attachment PIIC 21.
(b) Outside Service Expense increased $8.1 million in 2023 compared to 2022
and $13.9 million in 2022 compared to 2021.
In 2023 compared to 2022, $5.3 million of the increase resulted from higher
affiliate charges for information technology(IT), telecommunications and
security charges. Another$13.5 million of the increase was due to higher legal
consulting fees, of which $4.6 million was due to the reversal of an expected
insurance recovery. These increases were partially offset by the Company's
$6.8 million obligation recorded in 2022 to provide funding to an Oregon
agency for water quality improvement projects required under the Klamath
Hydroelectric Settlement Agreement(KHSA). Please refer to the Company's
response to subparts (b) and(c)below.
In 2022 compared to 2021, $7.7 million of the increase resulted from higher
affiliate charges for IT, telecommunications and security charges. Another
$6.8 million of the increase resulted from accruing the Company's obligation
to provide funding to an Oregon agency for water quality improvement
projects required under the KHSA. Another$2.5 million of the increase was
due to reserves associated with cost deferrals in Oregon for wildfire cost
recovery mechanisms. These increases were partially offset by a $4.6 million
credit representing expected insurance recoveries. Please refer to the
Company's response to subpart (c) below.
(c) Of the total increases in Outside Service Expense in 2023 compared to 2022,
$13.2 million was due to legal fees associated with wildfire litigation. Of the
total increases in Outside Service Expense in 2022 compared to 2021, a
partially offsetting decrease of$6.1 million was due to legal fees associated
with wildfire litigation, of which $4.6 million represented expected insurance

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 21
recoveries to be applied to legal fees incurred as a result of wildfire litigation.
In 2023, as a result of the magnitude of the wildfire losses arising from the
litigation, the Company determined that all expected insurance recoveries
would instead be applied to third-parry damages and the $4.6 million was
reversed, contributing to the increase in 2023. Consequently, the $4.6 million
of expected insurance recoveries was reflected as an offset to wildfire losses
reflected in account 925 during 2023.
Recordholder: Shelley McCoy
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 22
PIIC Data Request 22
Please provide transaction level detail of all legal expenses included in the test
period revenue requirement, with a description of the legal matter on which the
legal services were performed.
Response to PIIC Data Request 22
The Company does not have transaction level detail of legal expenses for the Test
Period. The legal expenses in the Test Period are unknown and not incurred actual
expenses by the Company at this date. Furthermore, the legal matters expected in
the Test Period are also unknown and unable to be provided for the Test Period.
Based on the foregoing clarification, the Company responds as follow:
Please refer to Confidential Attachment PIIC 22 containing legal expenses
recorded during calendar year 2023 which are included in the base year.
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: Christina Lopas
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 23
PIIC Data Request 23
Please provide transaction level detail of all expert witness consulting services
accrued in the test period revenue requirement, with a description of the matter on
which the services were performed.
Response to PIIC Data Request 23
The Company does not have transaction level detail of witness consulting service
accruals for the Test Period. The witness consulting service expenses in the Test
Period are unknown and not incurred actual expenses by the Company at this
date. Furthermore, the matters for which witness consulting services which will
be performed in the Test Period are also unknown and unable to be provided for
the Test Period. Based on the foregoing clarification, the Company responds as
follows:
Please refer to the Company's response to PIIC 22, specifically Confidential
Attachment PIIC 22,which provides all legal expenses (including accruals)
recorded during calendar year 2023 which are included in the base year.
Recordholder: Christina Lopas
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 25
PIIC Data Request 25
Please identify each long-term service agreement that PacifiCorp has for its power
plants, and describe the terms of the agreement, including the amounts paid, the
timing of payment and how the rates change over time.
Response to PIIC Data Request 25
The Company assumes that this request is associated with PIIC Data Request 24
and specifically to McCoy's work paper"4.5 - Generation Overhaul Expense"
and to PacifiCorp's thermal resources. Based on the foregoing assumptions, the
Company responds as follows:
The Company has entered into Long-Term Service Agreement (LTSA) contracts
with original equipment manufacturers (OEM) for the Lake Side, Currant Creek,
and Chehalis plants. These contracts provide overhaul services, equipment, parts
discounts, and certain warranties.
The Company makes quarterly payments under the LTSAs based on the operating
hours of each combustion turbine at each respective plant. The payments
represent combustion turbine equipment usage that will be replaced and overhaul
services to be provided by the OEM during upcoming hot gas path (HGP)and
major overhauls. The LTSAs requires that the combustion turbine be maintained
to the standards agreed upon per the contract and should occur after a specified
number of factored fired hours or equivalent gas turbine starts. Because the
overhaul services will not be performed nor equipment/materials replaced until
the overhauls occur, amounts paid under the LTSAs are recorded as prepayments
on the balance sheet. When the actual services are performed, and the
equipment/materials are installed, the prepayments are then reclassified to capital
expenses or operation and maintenance (O&M) expenses.
The contract pricing is subject to escalation per the terms of the LTSAs,which is
based off a formula which utilizes market indexes.
Recordholder: Chad Ahlmer
Sponsor: Chad Ahlmer

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 26
PIIC Data Request 26
Reference McCoy work paper"3.6 - Fly Ash Revenues.":
(a) Please explain why fly ash revenues are expected to decline so significantly in
2024, and
(b) Please provide all executed fly ash sales agreements in effect in calendar years
2023, 2024, and 2025.
Response to PIIC Data Request 26
(a) Fly ash revenues decline in 2024 as a result of Jim Bridger Unit 1 and Jim
Bridger Unit 2 converting to gas-fired units. Upon conversion to gas, these
units will no longer produce ash available for sale.
(b) Please refer to Confidential Attachment PIIC 26-1 and Confidential
Attachment PIIC 26-2 for the Jim Bridger plant, Confidential Attachment
PIIC 26-3 for the Huntington plant, Confidential Attachment PIIC 26-4 for the
Naughton plant, and Confidential Attachment PIIC 26-5 for the Craig 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
Procedure No. 67—Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement(NDA) executed in this proceeding.
Recordholder: Aaron Lively
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 27
PIIC Data Request 27
Please provide PacifiCorp's financial statement tax provision calculation by book-
tax difference item as of December 31, 2023.
Response to PIIC Data Request 27
Please refer to Attachment PIIC 27 which includes the calculation of income taxes
for this general rate case (GRC)proceeding. The financial statement tax provision
calculation as of December 31, 2023, are provided in column F of tab "Current
Income Tax Expense"tab.
Recordholder: Deanna Fladstol
Sponsor: Ryan Fuller

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
PIIC Data Request 28
PIIC Data Request 28
Please provide the Jim Bridger Fuel stock balance by month over the period
January 1, 2023 through July 31, 2024.
Response to PIIC Data Request 28
Please refer to Confidential Attachment PIIC 28 which provides actual monthly
Jim Bridger Fuel Stock ending inventory balances for January 1, 2023 through
July 31, 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: Heather Garcia
Sponsor: To Be Determined

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 PacifiCorp Idaho Industrial Customers (PIIC) 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 23rd day of August, 2024.
Respectfully submitted,
�1-
By
Joe Dallas
Attorney
Rocky Mountain Power
2