20241003PAC to IIPA 13.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116

October 3, 2024

Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
[e-mail] (C)

RE: ID PAC -E-24-04
IIPA Set 1 (1-46)

Please find enclosed Rocky Mountain Power’s Response to IIPA 1st Set Data Request 13. Also
provided is Attachment IIPA 13-1. The Confidential Attachment IIPA 13-2 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 [phone].

Sincerely,

____/s/____
Mark Alder
Manager, Regulation

Enclosures
C.c.: Lance Kaufman/IIPA [e-mail] (C)
Monica Barrios-Sanchez/IPUC [e-mail]
[e-mail]
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
Thursday, October 03, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Bradley Mullins/PIIC [e-mail]
Val Steiner /PIIC [e-mail]
Kyle Williams/PIIC [e-mail]

PAC-E-24-04 / Rocky Mountain Power
October 3, 2024
IIPA Data Request 13

IIPA Data Request 13

Please provide transaction summaries for costs recorded in all FERC Accounts for
the Test Year. Please provide data at a detail that correspond to PacifiCorp’s
Response to OPUC Staff DR 57 in OPUC Docket No. UE 433. Please include
both labor and non-labor costs and include an indicator of whether the transaction
is a labor cost.

Response to IIPA Data Request 13

Based on the discussion between representatives of the Company and the Idaho
Irrigation Pumpers Association (IIPA) on August 22, 2024, the Company
provides its response in compliance with the aforementioned discussion.

Please refer to Attachment IIPA 13-1 and Confidential Attachment IIPA 13-2
which provide line-item details for operation and maintenance (O&M) expenses
(FERC Account 500 through FERC Account 935) on a total-Company basis for
the base year, 12 months ending December 31, 2023.

Note: certain transactions are system-generated and will not include a description
in the “Text” field. Below is a list of the common document types for these
system-generated transactions.

RE – Invoice Receipt
WA – Goods Issue
WE – Goods Receipt

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: Christina Lopas

Sponsor: Shelley E. McCoy

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
attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
PacifiCorp Idaho Industrial Customer discovery requests 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 PacifiCorp Idaho Industrial Customers Data Request No. 1.13 contains
Company proprietary information that could be used to its commercial disadvantage.
2
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential 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 3rd day of October, 2024.

Respectfully submitted,

By__________________________
Joe Dallas
Attorney
Rocky Mountain Power