20240917 PAC to Staff 246-249 (Redacted).pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 17, 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 13 (241-249)
Please find enclosed Rocky Mountain Power’s Responses to IPUC 13th Set Data Requests 246-249.The Confidential Responses are provided via BOX. Confidential information is providedsubject 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] Brandon Helgeson/PIIC [e-mail]
RECEIVED Tuesday, September 17, 2024IDAHO PUBLICUTILITIES COMMISSION
Bradley Mullins/PIIC [e-mail] Val Steiner /PIIC [e-mail]
Kyle Williams/PIIC [e-mail]

PAC-E-24-04 / Rocky Mountain Power September 17, 2024 IPUC Data Request 246
IPUC Data Request 246 If any proceeds from insurance claims were received for any damages or repairs that involved capitalized plant or initiated additional capital expenditures, please
provide the associated capital project and accounting treatment.
Response to IPUC Data Request 246
PacifiCorp did not have insurance recoveries on any capitalized plants or projects.
Recordholder: Wendy Wallis / Theresa Haggard Sponsor: Mariya Coleman

PAC-E-24-04 / Rocky Mountain Power September 17, 2024 IPUC Data Request 247
IPUC Data Request 247 CONFIDENTIAL REQUEST - In reference to response to Production Request No. 58(e)-ii and 59(e)-ii Confidential Files -U1/U2 project budget by WBS CONF
for the Unit 1 and Unit 2 conversion to Natural Gas project, please reconcile and
explain the three total cost amounts from the Application, and the Budget, and Actuals from Production Request No. 58 and 59, as shown in the table below:

Application (From McCoy’s
Testimony)
Budget (From Response to PR No. 58 and 59) Actual (From Response
to PR No. 58
and 59)
APR10030110/APR10030111 APR10030053/APR10030054
APR90001601/ARP90001602 APR90001716/APR90001717
Total
17,307,777
17,267,132
34,574,909
Confidential Response to IPUC Data Request 247

01/TE (U1 Test

PAC-E-24-04 / Rocky Mountain Power September 17, 2024 IPUC Data Request 247

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
Sponsor: Brad Richards
PAC-E-24-04 / Rocky Mountain Power September 17, 2024 IPUC Data Request 248
IPUC Data Request 248 CONFIDENTIAL REQUEST - In reference to response to Production Request No. 58(e) - Confidential Attachment IPUC 58 1st Supplemental for the U1/U2
Conversion to Natural Gas Project, please explain the Change Order Increase with given that the initial contract cost was only
].
Confidential Response to IPUC Data Request 248 Please refer to the Company’s 2nd Supplemental response to IPUC Data Request 58.

PAC-E-24-04 / Rocky Mountain Power September 17, 2024 IPUC Data Request 248
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

Sponsor: Brad Richards
PAC-E-24-04 / Rocky Mountain Power September 17, 2024 IPUC Data Request 249
IPUC Data Request 249 CONFIDENTIAL REQUEST - In reference to response to Production Request No. 58 – Confidential Attachments for the U1/U2 Conversion to Natural Gas
Project, please explain the reason for the difference between the Unit 1 ] project budget by WBS in the excel file and the budget shown on page 4 of the APR
#90001601 Project Proposal.
Confidential Response to IPUC Data Request 249

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
Sponsor: Brad Richards

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

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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 Set 13 contains 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 17h day of September, 2024.

Respectfully submitted,
By__________________________ Joe Dallas
Senior Attorney
Rocky Mountain Power