20240905PAC to Staff 178_190_191_202.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 5, 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 10 (175-204)
Please find enclosed Rocky Mountain Power’s Responses to IPUC 10th Set Data Requests 178,
190, 191 and 202. Provided via BOX are Confidential Attachments and Confidential Responses.
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.: 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]
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
IPUC Data Request 178

IPUC Data Request 178

Please provide supporting documentation for the pro forma increases to retirement
plans, benefits, disability insurance, and workers compensations shown on Page
4.2.6 of Exhibit No. 48.

Response to IPUC Data Request 178

Please refer to the Company’s response to IIPA Data Request 21.

Recordholder: Christina Lopas

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 190

IPUC Data Request 190

Please provide the following information for the 301 Generator Stator Rewind
project referenced on Attachment #55-1 of Response to Production Request No.
55. Please include any available workpapers with formula intact. If any of the
information requested below cannot be provided or is not available, please explain
why it is not available or cannot be provided.

(a) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.

(b) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company’s economic analysis (costs and
benefits) comparing them.

(c) If a RFP or RFQ was submitted, please provide the following information:

i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.

(d) Please provide the approved Initial Project Plan including the following:

i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at
the appropriate level.

(e) Please provide the following for the Baseline Construction Project Plan:

i. Baseline project scope;
ii. Baseline project budget broken down by the WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the
differences, explain the reason for the change, and provide
evidence that the changes were approved at the appropriate level;
v. Project status reports and action items; and
vi. Contractor change orders.

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 190

(f) Please provide the following related to completion of the project:

i. Baseline construction budget-to-actual comparison by the WBS
and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category
that is over 5%, please explain the reason for the differences and
provide evidence that the amount was approved at the appropriate
level; and
iv. Please explain any slips in schedule from the baseline construction
schedule.

Confidential Response to IPUC Data Request 190

(a) Please refer to Confidential Attachment IPUC 190 which provides a copy of
the appropriation request (APR).

(b) Please refer to Confidential Attachment IPUC 190 which provides a copy of
the APR.

(c) Due to the nature of this particular project, it was single-sourced. Since the
original equipment manufacturer (OEM), Siemens, was onsite during the
annually scheduled maintenance outage, the Company was able to save
tool/equipment mobilization costs and expedite the starting date of the project.

(d) Please refer to the Company’s responses to subparts i. through iv below:

i. Please refer to Confidential Attachment IPUC 190, confidential
file “APR10030374 - HTR 301 Gen Stator Rewind CONF”

ii. Initial project budget was $9,893,620.

iii. Initial proposed schedule

•
•
•
•
•

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 190

iv. Please refer to Confidential Attachment IPUC 190, confidential
file “SAP APR Approval List CONF”.

(e) Please provide the following for the Baseline Construction Project Plan:

i. Scope is the same as listed above with the addition of the
following:

a. Perform Loop Test
i. Install loop cable
ii. Perform loop test / thermovision scan of generator
stator core iron
iii. Monitor stator core per Siemens Energy Engineering
Specs
iv. Remove loop cable

b. Repair Core Iron Hot Spots
i. Etch hot spot areas
ii. Mica insertion

c. These two task items were performed several times to repair
hot spot indications identified by loop test. Repairs included
both core etching and mica insertions.

ii. Single work breakdown structure (WBS) used for project
SHTR/2022/C/020/STATOR – $12,410,104.

iii. Initial schedule was

•
•

iv. Project was extended due to core iron hot spots that were detected
with post winding loop check. Schedule was
Budget
costs were increased ($2,651,654).

v. Please refer to Confidential Attachment IPUC 190, confidential
file “Stator Rewind Final Report Summary CONF”.

vi. Please refer to Confidential Attachment IPUC 190, and the four
confidential files beginning with “EWA” (which is an abbreviation
for extra work order authorization).
PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 190

(f) Please provide the following related to completion of the project:

i. 2022) SHTR/2022/C/020/STATOR: (budget) $9,893,620 (actual)
$12,410,104

ii. Initial schedule

iii. Please refer to the Company’s response to subpart (e)iv above.

vii. Schedule extension due to post winding installation core hot spot
repairs. Budget cost increase due to hot spot repairs and additional
worn parts replacements. Please refer to Confidential Attachment
IPUC 190, and the four confidential files beginning with “EWA”.

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: Laren Huntsman

Sponsor: Brad Richards

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 191

IPUC Data Request 191

Please provide the following information for the CCR Jim Bridger FGD Pond 3
project referenced on Attachment #55-1 of Response to Production Request No.
55. Please include any available workpapers with formula intact. If any of the
information requested below cannot be provided or is not available, please explain
why it is not available or cannot be provided.

(a) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.

(b) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company’s economic analysis (costs and
benefits) comparing them.

(c) If a RFP or RFQ was submitted, please provide the following information:

i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.

(d) Please provide the approved Initial Project Plan including the following:

i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at
the appropriate level.

(e) Please provide the following for the Baseline Construction Project Plan
including the following:

i. Baseline project scope;
ii. Baseline project budget broken down by the WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the
differences, explain the reason for the change, and provide
evidence that the changes were approved at the appropriate level;
v. Project status reports and action items; and
vi. Contractor change orders.

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 191

(f) Please provide the following related to completion of the project:

i. Baseline construction budget-to-actual comparison by the WBS
and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category
that is over 5%, please explain the reason for the differences and
provide evidence that the amount was approved at the appropriate
level; and
iv. Please explain any slips in schedule from the baseline construction
schedule.

Confidential Response to IPUC Data Request 191

Please refer to Confidential Attachment IPUC 191 which provides the documents
responsive to this request, and to the Company’s responses to subparts (a) through
(f) below:

(a) Please refer to the Executive Summary starting on page 1 and the Key Issues
starting on page 2 of the confidential document “Project Proposal -
APR20008114 - JB FGD Pond 3 CONF ”. The main reason for the project is
to comply with the EPA’s Coal Combustion Residual (CCR) rule (40 CFR
Part 257). The economic model shows a 4-year payback in favor of this
project based on the 2021 IRP model assumptions.

(b) Please refer to the Alternatives Considered on page 10 of the confidential
document “Project Proposal - APR20008114 - JB FGD Pond 3 CONF”.

(c) Please refer to the Company’s responses to subparts i. through iv. below:

i. Please refer to the RFX Documents CONF folder included in
Confidential Attachment IPUC 191. The RFX Documents CONF folder
includes three different components of the bidder package: commercial
documents (scope of work and applicable documents), pricing
documents, and safety documents which are required for the bidders to
submit a bid for the project and confidential document. The confidential
document “2. Exh A SOW - J7301_3_FGD POND 3_GWC PHASE
1_SPEC CONF” in the Commercial DOCS-R2 CONF folder is the
scope of work.

ii. Please refer to the confidential file “Populated Eval Matrix FGD Pond
#3 JB RevB 5 2021 100721 R6 Final CONF” in the Confidential
Attachment IPUC 191 for selection criteria and bid results. Ten bidders
were included on the initial list. After the initial bids were received,
three bidders were selected to compete in an e-auction. Searle Brothers
PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 191

was finally selected as the lowest qualified bidder. Searle’s initial bid
amount was $38,995,225 however this price was subsequently lowered
following the result of an e-auction. The e-auction is a reverse auction
process where the bidders are given another opportunity to bid on the
project. After the e-auction, the initial project price was $35.9m (which
is the sum of the base bid of $35.1m and the quality assurance bid of
$788k). The base bid is provided as “SBC Final. Exhibit B1 Pricing
Schedule (Final- post E-Auction, 10.15.21) CONF” in Searle Proposal
8-16-21 CONF folder and the quality assurance bid is provided as “SBC
Final Exhibit B2 Pricing Schedule FGD Pond (10.15.2021) CONF” in
the Searle Proposal 8-16-21 CONF folder. The e-auction results are also
included as “E-Auction Results CONF” in the Attach IPUC 191 CONF
folder.

iii. Please refer to the Company’s response to subpart (c)ii above.

iv. Please refer to the Company’s response to subpart (c)ii above.

(d) Please refer to the Company’s response to subparts i. through iv. below:

i. Please refer to the confidential document “2. Exh A SOW -
J7301_3_FGD POND 3_GWC PHASE 1_SPEC CONF” in the
Commercial DOCS-R2 CONF folder.

ii. $63,242,786 total project budget ($42.6 million PacifiCorp share).

iii. Please refer to page 22 of confidential document “Project Proposal -
APR20008114 - JB FGD Pond 3 CONF”.

iv. Please refer to confidential document
“ApprovalAPR20008114_Detail_20211214193419.043_X_2024082013
5938.938_X CONF.”

(e) Please refer to the Company’s response to subparts i. through vi. Below and
Confidential Attachment IPUC 191:

i. Please refer to confidential document “2. Exh A SOW - J7301_3_FGD
POND 3_GWC PHASE 1_SPEC CONF” in the Commercial DOCS-R2
CONF folder.

ii. Please refer to confidential file “FGD Pond #3 WBS Structure CONF”
in the Attach IPUC 191 CONF folder.

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 191

iii. Please refer to Project Milestones on page 22 of the confidential
document “Project Proposal - APR20008114 - JB FGD Pond 3 CONF”.
Also see confidential document “FGD Pond 3 Construction Schedule
CONF” for additional tasks for the WBS SJIM/2017/C/100/IMPSUM.

Proposed Schedule for FGD Pond 3 Construction Support
WBS Task / Milestone Date / Timeframe
SJIM/2017/C/100/DP
MLBR
Draft Composite Liner Design Certification (40
CFR 257.72(c))
1 Week After Construction Contract
Award
SJIM/2017/C/100/DP
MLBR
Final Composite Liner Design Certification (40
CFR 257.72(c))
1 Week After Receipt of PacifiCorp
Comments
SJIM/2017/C/100/IM
PSUM
Draft Semi-Annual Progress Reports on FGD
Pond 3 Construction
April 8, 2022 / October 7, 2022 / April
7, 2023
SJIM/2017/C/100/IM
PSUM
Final Semi-Annual Progress Reports on FGD
Pond 3 Construction
April 29, 2022 / October 28, 2022 /
April 28, 2023
SJIM/2017/C/100/IM
PSUM
Draft U.S. EPA CCR Rule Compliance
Documents August 1, 2023
SJIM/2017/C/100/IM
PSUM
Final U.S. EPA CCR Rule Compliance
Documents August 31, 2023
SJIM/2017/C/100/IM
PSUM As-Built Drawings 4 Weeks After Substantial Completion

iv. The greatest impact to scope, budget, and schedule was the condition of
the pond bottom soil. Due to the limited time to dewater the pond, the
base required significant time and materials for stabilization. The
weather also greatly impacted the schedule with an unusual amount of
rain in May and June, which caused delays with the liner deployment.
The wind presented another challenge to the liner installation, so
schedules were adjusted to install the liner during less windy times.
Despite these challenges, the pond was completed and commissioned on
time. Each change order was approved at the appropriate level as
required in SAP. The approval limits are set in SAP and will not allow a
requisition to be approved by those without approval authority. The
overall project was under the approved APR limit, which was approved
by Gary Hoogeveen.

v. Please refer to Confidential Attachment IPUC 191, specifically folder
“Weekly Status Report CONF”.

vi. Several change orders were issued during the project, including the
following.

CO#1 – Cost escalation due to contract delay.
PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 191

CO#2 – Backhoe charges to excavate around a spring that was
discovered at the western edge of the pond.
CO#4 – Haul rip rap for erosion control.
CO#5 – Soil stabilization for pond bottom.
CO#6 – Additional pond bottom stabilization and French drain to
remove water.
CO#7 – Additional pond stabilization.
CO#8 – Liner expansion needed for anchor trench.
CO#9 – Concrete ramp added.
CO#10 – Installation of French Drain to dewater pond bottom.
CO#11 – Installation of another French Drain to dewater pond bottom.
CO#12 – French drain pump work.
CO#13 – Additional pond bottom stabilization material.
CO#14 – Add epoxy-coated rebar to ramps.
CO#15 – Well development.
CO#16 – Additional liner construction.

(f) Please provide the following related to completion of the project:

i. Please refer to Confidential Attachment IPUC 191, specifically file,
FGD3 Budget v Actuals.

ii. The major project milestone was to cease the receipt of FGD waste into
FGD Pond 2. This milestone had a deadline of October 15, 2023. The
FGD Pond 3 was commissioned on October 12, 2023, which also
marked the end of sending FGD waste to FGD Pond 2.

iii. Project was under budget. Please refer to confidential file “FGD3
Budget v Actuals CONF” in Confidential Attachment IPUC 191.

iv. The critical tasks were completed on time, such that the pond was
commissioned prior to the deadline. Some other work was delayed, such
as the perimeter road development. The reason for the delay was due to
the condition of the pond bottom, which required additional dewatering
and stabilization. The schedule was also impacted by weather delays, so
critical tasks were given greater priority in order to meet hard deadlines.

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: Ken Cutler

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 191

Sponsor: To Be Determined
PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 202

IPUC Data Request 202

Please provide the following information for the U1 CSA Variable fee – CT1 -
HGP for a total amount of $ 11,220,684 as referenced in Company’s Response to
Production Request No. 15. Please include any available workpapers with formula
intact. If any of the information requested below cannot be provided or is not
available, please explain why it is not available or cannot be provided.

(a) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.

(b) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected from among the
alternatives supported by the Company’s economic analysis (costs and
benefits) comparing them.

(c) Please provide the following information regarding all RFPs or RFQs
associated with the development and construction of the RC plant:

i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and
list of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.

(d) Please provide the approved Initial Project Plan including the following:

i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget was approved at the
appropriate level.

(e) Please provide the following for the Baseline Construction Project Plan
including the following:

i. Baseline project scope;
ii. Baseline project budget broken down by the WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the differences,
explain the reason for the change, and provide evidence that the changes
were approved at the appropriate level;
v. Project status reports and action items; and
vi. Contractor change orders.
PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 202

(f) Please provide the following related to completion of the project:

i. Baseline construction budget-to-actual comparison by the WBS and by
year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is
over 5%, please explain the reason for the differences and provide
evidence that the amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction
schedule.

Confidential Response to IPUC Data Request 202

(a) Please refer to Confidential Attachment IPUC 202 and confidential document
“APR10009803_Proj_Proposal CONF” which provides a copy of the project
proposal document for the U1 CSA Variable fee – CT1 - HGP project.

(b) No other alternatives were considered due to a contractual obligation with the
supplier under the Contractual Service Agreement (CSA).

(c) This is not applicable for this project because the project is completed
pursuant to the terms of a long-term contract.

(d) Please refer to the Company’s responses to subparts i. through iv. below:

i. This project is to perform the hot gas path overhaul on combustion turbine
1 pursuant to the Contractual Service Agreement (CSA) between
PacifiCorp and General Electric International, Inc. (GE) amended and
restated as of January 15, 2016. Performing the necessary overhaul will
result in the units being able to operate an additional
before the next scheduled outage. The major inspection overhaul includes
the removal and replacement of the following combustion program parts
as outlined in the CSA:

Program Parts
FUEL NOZZLE ASMBY
COMBUSTION LINERS
TRANSITION PIECES
BUCKETS: STAGE 1
BUCKETS: STAGE 2
BUCKETS: STAGE 3
NOZZLES: STAGE 1
NOZZLES: STAGE 2
NOZZLES: STAGE 3
PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 202

Program Parts
SHROUDS: STAGE 1
SHROUDS: STAGE 2
SHROUDS: STAGE 3

ii. This project is in the approved 2022 budget for $11,664,460 excluding
allowance for funds used during construction (AFUDC).
CAPITAL EXPENDITURES - $000 - PACIFICORP SHARE
PRIOR CY22 CY23 CY24 FUTURE TOTAL
Budget (without AFUDC)- 11,664 - - 11,664
Budget Escalated (without AFUDC)- 11,664 - - - 11,664
APR Requested (without AFUDC)- 11,664 - - 11,664
Difference - - - - - -
Requested AFUDC - 59 - - 59
TOTAL Requested Funds - 11,723 - - - 11,723

iii. This outage is anticipated to be for

. Evidence that the Initial Project Plan and
budget was approved at the appropriate level.

iv. Please refer to the table below:

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 202

(e) Please refer to the Company’s responses to subparts i through vi below:

i. Please refer to the initial project scope provided in the Company’s
response to subpart (d) i. above.

ii. The project is defined in one work breakdown structure (WBS)
(OCLS/2022/C/010) in the budgeted amount of $11,526,950 excluding
AFUDC.

iii. The project is defined in one WBS (OCLS/2022/C/010), the schedule is

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 202

.

iv. Please refer to the confidential signed change orders in Attach IPUC 202
CONF.

v. Not Applicable

vi. Please refer to the Company’s response from (e)iv. and the attached
documents.

(f) Please refer to the Company’s responses to subparts i. through vi. below.

i. This project is in the approved 2022 budget for $11,664,460 excluding
AFUDC. Actuals show us at $11,526,342 excluding AFUDC translating to
the project coming in at $137,510 under budget.

ii. The baseline construction schedule was estimated to be about

.

iii. N ot Applicable.

iv. Repairs to the generator studs lead to an increase in the outage time by
days.

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
September 5, 2024
IPUC Data Request 202

Procedure No. 67 – Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Matt Murray

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
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 Data Request Nos. 190, 191, and 202 contain Company
proprietary information that could be used to its commercial disadvantage.
2
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in 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
Senior Attorney
Rocky Mountain Power