20240903PAC to Staff 120_Revised.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 3, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
[e-mail]
[e-mail]
RE: ID PAC -E-24-04
IPUC Set 7 (119-129)
Please find enclosed Rocky Mountain Power’s 1st Revised Response to IPUC 7th Set Data
Request 120.
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 [e-mail] (C)
Lance Kaufman/IIPA [e-mail] (C)
Matthew Nykiel/ICL [e-mail]
Brad Heusinkveld/ICL [e-mail]
Thomas J. Budge/Bayer [e-mail] (C)
Brian C. Collins/Bayer [e-mail]
Greg Meyer/Bayer [e-mail]
Kevin Higgins/Bayer [e-mail] (C)
Neal Townsend/Bayer [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Brandon Helgeson/PIIC [e-mail]
Bradley Mullins/PIIC [e-mail]
Val Steiner /PIIC [e-mail]
Kyle Williams/PIIC [e-mail]
RECEIVED
Tuesday, September 3, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-24-04 / Rocky Mountain Power
September 3, 2024
IPUC Data Request 120 – 1st Revised

IPUC Data Request 120

If the Company completed a cost-benefit analysis for the Company’s proposed
Catastrophic Fire Fund, please provide a copy of the cost-benefit analysis.

1st Revised Response to IPUC Data Request 120

Further to the Company’s response to IPUC Data Request 120 dated August 13, 2024, the
Company has become aware that it omitted to include in its response the appropriate
confidentiality provisions for the provided confidential attachment. The Company
therefore provides this 1st Revised response which replaces, in its entirety, the Company’s
original narrative response to now include and assert the appropriate confidentiality
provisions for the confidential attachment provided on August 13, 2024. The Company
confirms, however, that the originally provided confidential attachment remains
unchanged and valid.

The Company has not completed a cost-benefit analysis for the proposed Catastrophic
Fire Fund. However, please refer to Confidential Attachment IPUC 120 which provides a
presentation by the Brattle Group from the June 2024 multi-state stakeholder wildfire
workshop which discusses loss scenarios and coverage strategies.

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: Shelley McCoy

Sponsor: Joelle Steward