20240829PAC to Staff 9-13.pdf

RECEIVED
Thursday,August 29, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 29, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
monica.barriossanchez(ir,puc.Idaho.gov
S ecretM(a-,puc.idaho.gov
RE: ID PAC-E-24-05
IPUC Set 3 (9-13)
Please find enclosed Rocky Mountain Power's Responses to IPUC 3rd Set Data Requests 9-13.
Also provided are Attachments IPUC 9 and 12. The Confidential Attachment IPUC 13 is
provided via BOX. 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.
If you have any questions, please feel free to call me at [phone].
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures

PAC-E-24-05 /Rocky Mountain Power
August 29, 2024
IPUC Data Request 9
IPUC Data Request 9
Please provide a schedule showing the full revenue requirement for the Chehalis
natural gas plant in 2022 and 2023. Please break out the costs by O&M,
depreciation, rate base, return on rate base, etc.
Response to IPUC Data Request 9
Please refer to Attachment IPUC 9 which provides the revenue requirement for
the Chehalis plant in calendar years 2022 and 2023.
Recordholder: Aaron Rose
Sponsor: Shelley McCoy

PAC-E-24-05 /Rocky Mountain Power
August 29, 2024
IPUC Data Request 10
IPUC Data Request 10
Please explain if there are any statutory requirements that mandate the use of
CCA funds, general government fund, low-income assistance, etc.
Response to IPUC Data Request 10
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:
Please refer to information that is publicly available at various Washington state
government websites, including, but not limited to:
hILtps://ecolo,gy.wa.gov/Air-Climate/Climate-Commitynent-Act
Recordholder: Joe Dallas
Sponsor: Not Applicable

PAC-E-24-05 /Rocky Mountain Power
August 29, 2024
IPUC Data Request 11
IPUC Data Request 11
Please provide the amount of free allowances the Company received for the CCA.
Please include how those amounts were calculated.
Response to IPUC Data Request 11
Washington Department of Ecology (Ecology) has published the annual no-cost
allowance allocation to electric utilities for the first compliance period. The
information is publicly available and can be accessed by using the following
website link:
Allowance Allocation to Electric Utilities for the First Compliance Period
Revised
To date, PacifiCorp has received the following no-cost allowances:
Allowance Vintage Quantity
2023 2,489,384
2024 2,206,443
The no-cost allowance allocation forecast determining these quantities was
calculated consistent with Washington Administrative Code (WAC) 173-446-
230(2), supplied to the Washington Utilities and Transportation Commission
(WUTC) and subsequently approved!
Recordholder: Victoria Delon
Sponsor: Kieran O'Donnell
'Washington Utitlites and Transportation Commission,In the Matter of Petition ofPacifiCorp d/b/a Pacific
Power&Light Company, For an Order Approving Forecasts Pursuant to RCW 70A.65.120, Docket No.
UE-220789,Order No.02 (May 23,2024).

PAC-E-24-05 /Rocky Mountain Power
August 29, 2024
IPUC Data Request 12
IPUC Data Request 12
Please provide a schedule showing the compliance cost the Company has incurred
to comply with CETA in each of the following years 2021, 2022, 2023, and 2024.
Response to IPUC Data Request 12
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:
The Company clarifies that any costs incurred for actions taken specifically to
comply with Washington's Clean Energy Transformation Act(CETA), or
incremental costs, have or will be cost-allocated situs to Washington customers
and are not included in Idaho rates. Based on the foregoing clarification, the
Company responds as follows:
Since 2021, the Company has incurred costs associated with the Washington
Equity Advisory Group (EAG) and other outreach and engagement efforts as
required by CETA and defined in the Company's Clean Energy Implementation
Plan (CEIP). In 2021, the total spend was $475,586, in 2022, $344,173, in 2023,
$336,219 and so far in 2024 (January through July), there has been a total spend
of$198,510. Please refer to Attachment IPUC 12, work paper"WA CETA EAG
Costs 2021-07 2024 Detail.xlsx".
In 2022 and 2023 the Company incurred incremental costs associated with an
expansion of demand-side management(DSM)program expenditures for
Washington customers, as defined by the Company's utility actions in its
approved 2021 CEIP, due to CETA requirements. In 2022, DSM program
expenditures incremental costs were $645,699,831 and in 2023 this increased to
$1,163,942,464. 2024 actual incremental costs for DSM program are not yet
available. Please refer to Attachment IPUC 12, "WA CETA DSM Program
Expenditures.xlsx".
Table 1 below includes a summary of Washington CETA incremental costs for
the 2021 through 2024 (based on the above explanation).
Table 1.Washington CETA Incremental Costs
DSM Program EAG/Engagement Total
Expenditures
2021 $0 $475,586 $475,586
2022 $1 $344,173 $344,173
2023 $1 $336,219 $336,221

PAC-E-24-05 /Rocky Mountain Power
August 29, 2024
IPUC Data Request 12
2024(Jan-Jul) Not yet available $198,510 $198,510
Recordholder: Rohini Ghosh
Sponsor: Rohini Ghosh

PAC-E-24-05 /Rocky Mountain Power
August 29, 2024
IPUC Data Request 13
IPUC Data Request 13
Please provide a schedule showing the EIM dispatch price for 2023 for the
Company's Eastern BAA.
Response to IPUC Data Request 13
The Company assumes that the reference `BIM dispatch price" is intended to ask
for the energy imbalance market (EIM) locational marginal prices (LMP) for
PacifiCorp East (PACE)balancing authority area (BAA). Based on the foregoing
assumption, the Company responds as follows:
Please refer to Confidential Attachment IPUC 13 which provides the real-time
dispatch (RTD) LMP for PACE BAA for calendar year 2023 (January 2023
through December 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: Lynn Pham
Sponsor: To Be Determined

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-24-05
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER ) ATTORNEY'S CERTIFICATE
APPROVAL OF POWER COST ) CLAIM OF CONFIDENTIALITY
DEFERRAL OF $62.4 MILLION ECAM ) RELATING TO DISCOVERY
DEFERRAL ) RESPONSES
I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a
senior 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 the Company's response IPUC Set 3 contain Company proprietary information that could
be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in that the information contains Company proprietary information.
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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 29th day of August, 2024.
Respectfully submitted,
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
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