20241001PAC to Staff 206 - 1st Supplemental.pdf

RECEIVED
Tuesday, October 01, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 1, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
monica.barrio ssanchez(apuc.Idaho.gov
S ecretarygpuc.idaho.gov
RE: ID PAC-E-24-04
IPUC Set 11 (205-216)
Please find enclosed Rocky Mountain Power's I"Supplemental Response to IPUC I Ith Set Data
Request 206. Provided via BOX is Attachment IPUC 206 1"Supplemental. 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.: Eric L. Olsen/IIPA elo(&echohawk.com(C)
Lance Kaufman/IIPA lancekae.isg insi hg t.com(C)
Matthew Nykiel/ICL matthew.nykiel&amail.com
Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org
Thomas J. Budge/Bayer ti(&racineolson.com(C)
Brian C. Collins/Bayer bcollins(&consultbai.com
Greg Meyer/Bayer gmeyerkconsultbai.com
Kevin Higgins/Bayer khig gins kenergystrat.com(C)
Neal Townsend/Bayer ntownsendkenergystrat.com (C)
Ronald L. Williams/PIIC rwilliams(&hawleytroxell.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
October 1, 2024
IPUC Data Request 206— l'Supplemental
IPUC Data Request 206
Company witness McCoy's Exhibit No. 48, Page 8.5.3, Major Plant Detail lists
the following project in the Transmission section: "Project Specialized" for a total
plant-in-service amount of$72,681,510. Please clarify if this is truly a single
project, or an umbrella project for several smaller ones.
(a) Please provide the project scope of work.
(b) Please explain why it has various in-service dates, what are the anticipated
dates, and what scope of work is associated with each in-service date. If it is
an umbrella project for several smaller projects, please provide the following:
i. Please provide a list of the subordinate projects with a unique identifier
and title for each subordinate project;
ii. Please include the estimated cost and completion date for each
subordinate project; and
iii. Please provide explanatory details for the need for each project.
I't Supplemental Response to IPUC Data Request 206
Further to the Company's response to IPUC Data Request 206 dated August 30,
2024, and in response to an inquiry from Idaho Public Utilities Commission
(IPUC) staff requesting for more detail on the project scope, the Company
provides the following additional information:
(b) Please refer to Confidential Attachment IPUC 206 1 St Supplemental which
provides a detailed scope of the project.
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: Micheline Craw
Sponsor: Diana Knous

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
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 first supplemental response IPUC 206 contains Company proprietary
information that could be used to its commercial disadvantage.
1

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 1st day of October, 2024.
Respectfully submitted,
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
2