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Home My WebLink About20240911PAC to IIPA 1_3-5_8_10.pdf RECEIVED Wednesday, September 11, 2024 IDAHO PUBLIC UTILITIES COMMISSION _ ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP 1407 W North Temple, Suite 330 Salt Lake City, Utah 84116 September 11, 2024 Eric L. Olsen (ISB#4811) ECHO HAWK& OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205 elo(a-,echohawk.com(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 1, 3-5, 8, and 10. The remaining response will be provided under separate cover. Also provided are Attachments IIPA 1, 3 and 5. The Confidential Attachment IIPA 10 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, 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 (801)220-2313. Sincerely, /s/ Mark Alder Manager, Regulation Enclosures C.c.: Lance Kaufman/IIPA lance(a),aegisinsight.com(C) Monica Barrios-Sanchez/IPUC monica.barriossanchez(a,puc.idaho.gov S ecretM(cr),puc.Idaho.gov Matthew Nykiel/ICL matthew.n. kielkgmail.com Brad Heusinkveld/ICL bheusinkveldkidahoconservation.org Thomas J. Budge/Bayer tinracineolson.com(C) Brian C. Collins/Bayer bcollins(c�r�,consultbai.com Greg Meyer/Bayer gmeyer(&consultbai.com Kevin Higgins/Bayer khiggins ckenerg_ystrat.com(C) Neal Townsend/Bayer ntownsendkenergystrat.com (C) Ronald L. Williams/PIIC rwilliamskhawleytroxell.com Brandon Helgeson/PIIC bhelgeson(&hawleytroxell.com Bradley Mullins/PIIC brmullinskmwanalytics.com Val Steiner/PIIC val.steiner(a-)itafos.com Kyle Williams/PIIC williamsknasbyui.edu PAC-E-24-04/Rocky Mountain Power September 11, 2024 IIPA Data Request 1 IIPA Data Request 1 Please refer to Stewart Direct page 28 line 7 and 8. (a) Please provide the referenced article. (b) Has RMP included any costs associated with the James litigation in the test period? If yes please identify such costs. Response to IIPA Data Request 1 (a) Please refer to Attachment IIPA 1. (b) No costs associated with recovery of the James litigation are included in the test period in this general rate case (GRC). Recordholder: Nick Highsmith/Counsel Sponsor: Joelle Steward PAC-E-24-04/Rocky Mountain Power September 11, 2024 IIPA Data Request 3 IIPA Data Request 3 Please identify all currently active wildfire related litigation where RMP is a defendant. Response to IIPA Data Request 3 PacifiCorp objects to the data request to the extent it seeks information that is protected by attorney-client and/or attorney work product privileges. The Company further objects to this data request to the extent it is overly broad and unduly burdensome as the request does not contain a reasonable time frame. PacifiCorp also objects to this data request to the extent it requests information that is outside the scope of this proceeding. Subject to and without waiving the foregoing objections, the Company responds as follows: Please refer to Attachment IIPA 3 which provides a list of all currently active wildfire related litigation where Rocky Mountain Power(RMP)is the defendant. Those highlighted in green represent all cases that are resolved through settlement and/or dismissed. Those highlighted in yellow represent all cases in which certain plaintiffs have settled, but other plaintiffs remain active. Additionally, the Company had one Utah wildfire case that was dismissed, settled through binding arbitration, which was Spence Butler et. al. vs. PacifiCorp, Case No. 4:21-cv- 00079, Utah Federal District Court. Recordholder: Counsel Sponsor: Counsel PAC-E-24-04/Rocky Mountain Power September 11, 2024 IIPA Data Request 4 IIPA Data Request 4 Please identify all wildfire related litigation in which RMP was listed as a defendant and which was resolved through settlement. Please provide the settlement agreement. Response to IIPA Data Request 4 PacifiCorp objects to the data request to the extent it seeks information that is protected by attorney-client and/or attorney work product privileges. The Company further objects to this data request to the extent it is overly broad and unduly burdensome as the request does not contain a reasonable time frame. PacifiCorp also objects to this data request to the extent it requests information that is outside the scope of this proceeding. Subject to and without waiving the foregoing objections, the Company responds as follows: Please refer to the Company's response to IIPA Data Request 3. Recordholder: Counsel Sponsor: Counsel PAC-E-24-04/Rocky Mountain Power September 11, 2024 IIPA Data Request 5 IIPA Data Request 5 Please identify all wildfire related litigation in which RMP was listed as a defendant and the fact finder ruled in favor of plaintiffs on at least one claim. Please provide the associated ruling. Response to IIPA Data Request 5 PacifiCorp objects to the data request to the extent it seeks information that is protected by attorney-client and/or attorney work product privileges. The Company further objects to this data request to the extent it is overly broad and unduly burdensome as the request does not contain a reasonable time frame. PacifiCorp also objects to this data request to the extent it requests information that is outside the scope of this proceeding. Subject to and without waiving the foregoing objections, the Company responds as follows: Please refer to Attachment IIPA 5. Recordholder: Counsel Sponsor: Counsel PAC-E-24-04/Rocky Mountain Power September 11, 2024 IPUC Data Request 8 IIPA Data Request 8 Please provide all communications, documents, and files received from or sent to RMP excess liability insurers from January 1, 2019 to present. Response to IIPA Data Request 8 The Company negotiates all insurance through an intermediary, which is the industry norm. There is no direct communication between PacifiCorp and the insurance providers. Recordholder: Jill Mingles Sponsor: Mariya Coleman PAC-E-24-04/Rocky Mountain Power September 11, 2024 IPUC Data Request 10 IIPA Data Request 10 Please provide excess liability insurance cost by year from 2019 to present. Response to IIPA Data Request 10 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: Please refer to Confidential Attachment IIPA 10. The company will update this response to include the 2024/2025 Excess Liability cost once it becomes 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: Jill Mingles Sponsor: Mariya Coleman +Joe Dallas (ISB# 10330) Rocky Mountain Power 825 NE Multnomah, Suite 2000 Portland, OR 97232 Telephone: 360-560-1937 Email:joseph.dallas@pacificorp.com 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 Idaho Irrigation Pumpers Association Data Request No. 10 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 1 Ph day of September, 2024. Respectfully submitted, By Joe Dallas Attorney Rocky Mountain Power 2