20240905PAC to IIPA 6_19_32_38_46.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 5, 2024
Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
[e-mail] (C)
RE: ID PAC -E-24-04
IIPA Set 1 (1-46)
Please find enclosed Rocky Mountain Power’s Responses to IIPA 1st Set Data Requests 6, 19,
32, 38 and 46. The remaining responses will be provided under separate cover. Provided via e-
mail are Attachments IIPA 19-1 and 38. The Confidential Attachments IIPA 19-1, 32 -2, 32-3,
and 46 are 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, 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.: Lance Kaufman/IIPA [e-mail] (C)
Monica Barrios-Sanchez/IPUC [e-mail]
[e-mail]
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]
RECEIVED
THURSDAY, SEPTEMBER 5, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Brandon Helgeson/PIIC [e-mail]
Bradley Mullins/PIIC [e-mail]
Val Steiner /PIIC [e-mail]
Kyle Williams/PIIC [e-mail]

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IIPA Data Request 6

IIPA Data Request 6

Please provide the current status of the Multi-State Process.

(a) Please refer to Stewart Direct page 34 line 1-5.

(b) Please provide all expenses associated with the Multi-State Process incurred
in the Test year.

Response to IIPA Data Request 6

Please refer to the direct testimony of Company witness, Shelley E. McCoy,
specifically page 11, lines 1 through 12. The Multi-State Process (MSP) Inter-
Jurisdictional Cost Allocation Protocol (2020 Protocol) was approved by the
Idaho Public Utilities Commission (IPUC) in Case No. PAC-E-23-13 for use
through December 31, 2025. Accordingly, the Company has applied this
approved allocation methodology when calculating the revenue requirement for
the test period in this general rate case (GRC).

On July 11, 2024, PacifiCorp filed a notice with the Idaho Public Utilities
Commission that under Section 2.2.3 of the 2020 Protocol it is unlikely that a
Post-Interim Period Method agreement will be reached before the end of the
sunset date of the 2020 PacifiCorp Inter-Jurisdictional Allocation Protocol on
December 31, 2025, and is terminating negotiations in the Framework Issues
Workgroup.

(a) Subpart (a) to this data request does not contain a question. There is nothing to
respond to.

(b) The Company cannot identify all expenses associated with MSP in the test
year. For instance, the Company utilizes resources such as office buildings,
technology, employee labor, etc., when collaborating with parties within the
context of MSP.

Recordholder: Louisa Bruschi-Dadik

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IIPA Data Request 19

IIPA Data Request 19
Please refer to 3.6 - Fly Ash Revenues.xlsx.
(a) Please provide work papers supporting the hard coded numbers on sheet 3.6.
(b) Please provide fly ash revenues and sales quantity by month, plant, and unit
from January 1, 2019 to present.

(c) Does PacifiCorp incur labor, transportation, or other expense associated
with the sale of fly ash? If no, why not? If yes, please identify such expenses
in the test year.

Response to IIPA Data Request 19

(a) Please refer to Confidential Attachment IIPA 19-1 which provides support for
the hard coded numbers in file “3.6 - Fly Ash Revenues”.

(b) Please refer to Attachment IIPA 19-2.

(c) Any costs incurred by PacifiCorp resulting from ash sales activity are de
minimis. Activities necessary to facilitate the sale of fly ash are largely
performed by the purchaser at the plant site.

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 / Louisa Bruschi-Dadik

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IIPA Data Request 32

IIPA Data Request 32

Please provide availability rate, economic curtailment rate, and congestion
curtailment rate for each wind facility by month from 2019 to present.

Response to IIPA Data Request 32
PacifiCorp objects to this data request to the extent the request is unduly
burdensome to produce the information requested and is unlikely to lead to
admissible evidence in this proceeding. Subject to and without waiving the
foregoing objection, the Company responds as follows:

For availability rate, please refer to Confidential Attachment IIPA 32-1 for
calendar years 2019 through 2023.

For economic curtailment, please refer to Confidential Attachment IIPA 32-2 for
calendar years 2019 through 2023.

For congestion curtailment, the Company responds as follows:

Qualitatively, curtailments can be generally described as resulting from
transmission outages, flow constraints, avian strike avoidance, and Western
energy imbalance market (EIM) instruction. A quantitative description of energy
curtailed according to cause categories would require historized data from both
PacifiCorp and the California Independent System Operator (CAISO), with a
minimum granularity of five minutes, for the constrained elements of
transmission corridors (TCOR) in the PacifiCorp balancing authority areas (BAA)
from CAISO, and whether the referenced projects were decremented due to
constrained transmission in the market. Without the data from CAISO, PacifiCorp
is unable to provide a description of the curtailments. The Company further
provides that the data required for determining non-EIM related curtailments is
not readily 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: Phil Austin / Will Shallenberger / Devin Hutchinson

Sponsor: To Be Determined

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IIPA Data Request 38

IIPA Data Request 38

Please refer to 8.9 - Klamath Regulatory Asset.xlsx.

(a) Please provide this work paper with formulae intact.

(b) Please explain why rate base is adjusted to 2025 13 month average while the
depreciation deferral rate base on 8.8.4 is adjusted to December 2024.

Response to IIPA Data Request 38

(a) Please refer to Attachment IIPA 38.

(b) The Company is requesting that the Klamath regulatory asset amortization be
included in the revenue requirement in this general rate case (GRC). As such,
the Company is including amortization for the 2025 period associated with the
rate effective date and an offsetting adjustment for the regulatory asset
balance using a 13-month average. This is different from the depreciation
deferral reflected on Page 8.8.4 of Exhibit No. 48 as that regulatory asset
recovery has been previously approved in Idaho. This treatment is consistent
with prior GRC methodologies used in Idaho.

Recordholder: Jeffrey Decker

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IIPA Data Request 46

IIPA Data Request 46

Please provide the company’s annual budget in effect on the first day of the
budget year from 2019 to present.

Response to IIPA Data Request 46

Please refer to Confidential Attachment IIPA 46 which provides the annual
operating budget information alongside the monthly data for January of each
requested year (2019 through 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: Brittney Davis-Smiley

Sponsor: To Be Determined

1
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

IN THE MATTER OF THE APPLICATION OF ROCKY
MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS
RATES AND CHARGES IN IDAHO
AND APPROVAL OF PROPOSED
ELECTRIC SERVICE SCHEDULES
AND REGULATIONS

)
)
)
)
)
)
)
)
)
)
)
)

CASE NO. PAC-E-24-04

ATTORNEY’S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES

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 Idaho Irrigation Pumpers Association Data Request Nos. 19, 32, and
46 contains Company proprietary information that could be used to its commercial disadvantage.
2
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 5th day of September, 2024.

Respectfully submitted,

By__________________________
Joe Dallas
Attorney
Rocky Mountain Power