20241002PAC to Bayer 34 - 1st Supplemental.pdf

RECEIVED
Wednesday, October 02, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 2, 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 2 (21-48)
Please find enclosed Rocky Mountain Power's 1st Supplemental Response to Bayer 2nd Set Data
Request 34. Provided via BOX is Confidential Attachment Bayer 34 Pt 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 lancena,ae isg insi hg t�(C)
Matthew Nykiel/ICL matthew.nykielkiamail.com
Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org
Ronald L. Williams/PIIC rwilliamsghawlevtroxell.com
Brandon Helgeson/PIIC bhelfzeson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinsgrawanalytics.com
Val Steiner/PIIC val.steinerkitafos.com
Kyle Williams/PIIC williamskkbvui.edu
Monica Barrios-Sanchez/IPUC monica.barriossanchez(),puc.idaho.gov
S ecretary(a),puc.idaho.gov

PAC-E-24-04/Rocky Mountain Power
October 2, 2024
Bayer Data Request 34— 1 st Supplemental
Bayer Data Request 34
Please refer to the Direct Testimony of Ramon Mitchell, page 61. Please provide
a summary of all power hedges to date secured for 2025. Consider this an ongoing
request to update this summary as new transactions occur.
1st Supplemental Response to Bayer Data Request 34
PacifiCorp continues to object to this data request to the extent the request is
overly broad and it would be unduly burdensome to produce the information
requested. PacifiCorp further 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 objections, the Company responds as follows:
Further to the Company's response to Bayer Data Request 34 dated August 12,
2024, the Company provides the following additional information responsive to
the request:
Please refer to Confidential Attachment Bayer 34 1st Supplemental which
provides updated information through September 30, 2024.
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: Steve Stiles
Sponsor: John Fritz/Paul Wood

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
Bayer 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 first
supplement response to Bayer Data Request No. 34 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 2nd day of October, 2024.
Respectfully submitted,
By
Joe Dallas
Attorney
Rocky Mountain Power
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