20240913PAC to Bayer 53.pdf

RECEIVED
Friday, September 13, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 13, 2024
Thomas J. Budge
ti(&racineolson.com(C)
Brian C. Collins bcollins(&consultbai.com
Greg Meyer gmeyerkconsultbai.com
Kevin Higgins khiggins(c�r�,energystrat.com(C)
Neal Townsend ntownsendkenergystrat.com(C)
RE: ID PAC-E-24-04
Bayer Set 3 (49-56)
Please find enclosed Rocky Mountain Power's Response to Bayer 3rd Set Data Request 53.
Provided via BOX are Confidential Attachments Bayer 53-1 and 53-2. 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 elo cr,echohawk.com(C)
Lance Kaufman/IIPA lance(&aegisinsi hg t.com(C)
Matthew Nykiel/ICL matthew.n,ielkamail.com
Brad Heusinkveld/ICL bheusinkveldkidahoconservation.org
Ronald L. Williams/PIIC rwilliamskhawleytroxell.com
Brandon Helgeson/PIIC bhel eg songhawleytroxell.com
Bradley Mullins/PIIC brmullins(a�mwanalytics.com
Val Steiner/PIIC val.steinerha,itafos.com
Kyle Williams/PIIC williamsk(&byui.edu
Monica Barrios-Sanchez/IPUC monica.barriossanchez(c puc.idaho.gov
SecretM(a puc.Idaho.gov

PAC-E-24-04/Rocky Mountain Power
September 13, 2024
Bayer Data Request 53
Bayer Data Request 53
Gateway Transmission Projects: Please refer to RMP witness Rick Link's work
papers, specifically the file "Link Workpaper- Table 3 Detail CONF".
(a) For each of the"Cost of Project" line items under each price-policy scenario,
please confirm whether or not the annual amount shown for each year reflects
a levelized revenue requirement amount.
(b) For any line item identified in subpart (a) above that reflects a levelized
annual amount, please provide a work paper showing the non-levelized annual
amount and the calculations used to derive the levelized annual amount.
Please provide the work paper(s) in Excel format with all formulas intact.
Response to Bayer Data Request 53
Please refer to Confidential Attachment Bayer 53-2 which provides the work
papers supporting this data request response.
(a) Please refer to Confidential Attachment Bayer 53-1, specifically the tab
"Identification", which provides the levelization status of each line item, and a
reference to the supporting work papers that support the line item. Column E
identifies how the production tax credits (PTC) and associated obligations
were incorrectly categorized in certain line items. In addition to this error,
some price-policy scenarios categorized part of the cost for Anticline,
Boswell, and Two Rivers in 2034 as part of the "Change in System Fixed
Cost" line item instead of the "PPA" column.
After correctly categorizing these items, the present value of revenue
requirements differential (PVRR(d)) reported for each price-policy scenario
was unchanged. Tab "Table 3 —Corrected" of Confidential Attachment Bayer
53-1 reports corrected values for each line item. Tab "Table 3 —Correction
Impacts" displays the difference in the value of each line item between the
original and corrected table.
(b) Tab "Table 3 —Nominal" of Confidential Attachment Bayer 53-1 reports
nominal, non-levelized values for each cost of project line item. Tab "Delta
Nominal less Corrected" displays the difference in the value of each line item
between the nominal and corrected tables. For additional detail on the wind
projects, nominal costs and calculations used to derive the levelized annual
amounts are included in the "Bid Templates CONF"folder and confidential
file "WY RFP FSL ST Costs CONF.xlsx". The non-levelized transmission
costs are included on tab "GWS Transmission" of the files within confidential
folder"ST Cost Summaries CONF", along with calculations used to derive
the levelized annual amounts.

PAC-E-24-04/Rocky Mountain Power
September 13, 2024
Bayer Data Request 53
Column C of Confidential Attachment Bayer 53-1 identifies the work papers
supporting each line item. The files within confidential folder"ST Cost
Summaries CONF" display itemized details that flow through to the tables
featured in Confidential Attachment Bayer 53-1. The five files within
confidential folder"ST Cost Summaries CONF" labeled"CORRECTED"
provide corrected calculations and support tab "Table 3 - Corrected". The
"Bid Templates CONF" folder provides the bid details received for the six
wind projects associated with Energy Gateway South and provides the
calculations used to derive the levelized annual amounts used in the
confidential folder"ST Cost Summaries CONF" files.
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: Samuel Zacharia
Sponsor: Rick Link

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
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 its response to Bayer Data Request No. 53 contains Company proprietary
information that could be used to its commercial disadvantage.
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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 13th day of September, 2024.
Respectfully submitted,
By
Joe Dallas
Attorney
Rocky Mountain Power
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