20241004PAC to Staff 1-10.pdf

RECEIVED
Friday, October 04, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 4, 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-24-10
IPUC Set 1 (1-10)
Please find enclosed Rocky Mountain Power's Responses to IPUC 1st Set Data Requests 1-10
and attachments. The Confidential Attachments will be 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

PAC-E-24-10/Rocky Mountain Power
October 4, 2024
IPUC Data Request 1
IPUC Data Request 1
Please provide a list of all expenses charged to the Company's Demand Side
Management(DSM) tariff rider account for years 2022 and 2023. Please
include date, vendor, amount, type of expense, and a brief description of the
expense. Please separate expenses by program so that the total amount for each
program ties to the amounts reported in the Annual DSM reports.
Response to IPUC Data Request 1
Please refer to Attachment IPUC 1.
Recordholder: Scott Judkins
Sponsor: Clay Monroe

PAC-E-24-10/Rocky Mountain Power
October 4, 2024
IPUC Data Request 2
IPUC Data Request 2
Please provide the monthly interest calculations for the balance in the DSM tariff
rider account for 2022-2023.
Response to IPUC Data Request 2
Please refer to Attachment IPUC 2.
Recordholder: Cindy Steinmetz
Sponsor: To be Determined

PAC-E-24-10/Rocky Mountain Power
October 4, 2024
IPUC Data Request 3
IPUC Data Request 3
Please provide the tariff rider revenue by month and by customer class for 2022-
2023.
Response to IPUC Data Request 3
Please refer to Attachment IPUC 3.
Recordholder: James Zhang
Sponsor: James Zhang

PAC-E-24-10/Rocky Mountain Power
October 4, 2024
IPUC Data Request 4
IPUC Data Request 4
Please provide a listing of all legal and consulting fees, including, but not limited
to Evaluation, Measurement and Verification (EM&V), charged to the Idaho
DSM tariff rider during 2022 and 2023. If any of the fees were allocated among
jurisdictions, please provide the calculation and explanation of the allocation.
Response to IPUC Data Request 4
There were no legal fees incurred during 2022 and 2023. Please refer to
Attachment IPUC 4 which provides consulting fee expenditures included in the
deferred account during 2022-2023. Note: the attachment does not include
consulting fees that were part of program administration. For common costs
shared between states, achieved kilowatt-hour(kWh) savings from the prior
program year are typically used. These common costs receive the appropriate
percentage of the expenditures based on the allocation percentage in place.
Recordholder: Scott Judkins
Sponsor: Clay Monroe

PAC-E-24-10/Rocky Mountain Power
October 4, 2024
IPUC Data Request 5
IPUC Data Request 5
Please provide the amount of labor expense charged to the DSM tariff rider for
the years 2022 and 2023. For each of those years, please also include the number
of Full Time Equivalents funded by the rider. Please also provide the general
wage adjustment percentage for non-union personnel approved by the
Compensation Committee of the Board of Directors for each year.
Response to IPUC Data Request 5
Please refer to the table below. The full-time equivalent(FTE)was calculated
using the internal labor hours charged to Idaho demand-side management(DSM)
divided by possible full-time hours in a year of 2,080. Labor expense includes
salary and benefits. Note: the general wage adjustment percentage reflects the
approved percentages for non-union personnel Company-wide, and is not
necessarily equal to the percentage of the actual payout.
Year Labor Expense FTE General Wage
(percent)
2022 $ 154,067.08 0.90 3.69%
2023 $ 151,951.32 0.86 3.50%
Recordholder: Scott Judkins
Sponsor: Clay Monroe

PAC-E-24-10/Rocky Mountain Power
October 4, 2024
IPUC Data Request 6
IPUC Data Request 6
Please provide a current organizational chart by title and name showing all Rocky
Mountain Power and contract employees who charge time to the DSM rider.
Please include complete job descriptions, required qualifications, salary ranges,
bonus opportunities, and total compensation ranges, including benefits, for all
employees identified in this request.
Response to IPUC Data Request 6
Please refer to Confidential Attachment IPUC 6-1 which provides job titles of
specific employees who have charged time to the demand-side management
(DSM)rider within the past 12 months. Included in the attachment are employee
titles, salary ranges and bonus opportunities. Because benefits costs vary greatly
based on personal options selected by each employee, total compensation ranges
are not readily available.
The Company does not maintain job descriptions or pay data for vendors.
Please refer to Attachment IPUC 6-2 which provides associated job descriptions.
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 any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Matthew Swanson
Sponsor: Julie Lewis

PAC-E-24-10/Rocky Mountain Power
October 4, 2024
IPUC Data Request 7
IPUC Data Request 7
Please provide copies of all internal audit reports referencing any of the Company's
DSM expenses and processes for 2022 to current date. If no reports were issued,
please provide the date and scope of the audit and all internal auditor workpapers.
Response to IPUC Data Request 7
PacifiCorp objects to this request on the grounds that it would require a special
study or new analysis to produce such information and is therefore overly broad
and unduly burdensome. Subject to and without waiving the foregoing objection,
the Company responds as follows:
PacifiCorp's internal audits are based on yearly risk assessments. There were no
internal audits related to demand-side management (DSM) expenses and
processes for 2022 to current date.
Recordholder: Seth Awram
Sponsor: Pete Parmenter

PAC-E-24-10/Rocky Mountain Power
October 4, 2024
IPUC Data Request 8
IPUC Data Request 8
Please provide invoices for all third-party evaluators for 2022 and 2023. Please
describe how those costs were allocated among jurisdictions.
Response to IPUC Data Request 8
Please refer to Attachment IPUC 8-1 which provides third-parry evaluator costs
for Idaho in 2022 and 2023. Please refer to Attachment IPUC 8-2 which provides
the invoices associated with the costs provided in Attachment IPUC 8-1. Note:
Attachment IPUC 8-2 includes how costs were allocated among jurisdictions.
Recordholder: Scott Judkins
Sponsor: Clay Monroe

PAC-E-24-10/Rocky Mountain Power
October 4, 2024
IPUC Data Request 9
IPUC Data Request 9
Please provide the cost-effectiveness workpapers and calculations for all DSM
programs for years 2022 and 2023 in Excel format.
Response to IPUC Data Request 9
Please refer to Confidential Attachment IPUC 9-1 and Confidential Attachment
IPUC 9-2 which provide the cost effectiveness work papers and calculations for
demand-side management(DSM)programs for years 2022 and 2023,
respectively.
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 any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Alesha Mander
Sponsor: Clay Monroe

PAC-E-24-10/Rocky Mountain Power
October 4, 2024
IPUC Data Request 10
IPUC Data Request 10
Please provide detailed dispatch data of each of the Company's demand response
programs for years 2022 and 2023. This includes, but is not limited to the
following:
(a) the date and time for each initiated event.
(b) the amount of demand saved in megawatts for each event hour.
(c) the amount of energy saved in megawatt-hours for each event hour; the value
of demand saved in each event hour.
(d) the program cost for demand saved in each event hour.
(e) the value and cost of energy saved in each event hour.
(f) the corresponding market price of energy for each event hour.
(g) a breakdown of incentives paid to each participant by event.
(h) any event adjustment for participant opt-outs.
(i) any event adjustments for non-participation.
Response to IPUC Data Request 10
Please refer to Confidential Attachment IPUC 10-1 and Confidential Attachment
10-2 which provide the requested information for the Irrigation Load Control
program for 2022 and 2023, respectively. This information was also provided in
the Company's 2022 and 2023 demand-side management (DSM) annual reports
as Confidential Appendix C, filed in Case No. PAC-E-05-10.
The Wattsmart Battery program has separate reporting metrics pursuant to Order
No. 35370 in Case No. PAC-E-21-16. The Commercial and Industrial Demand
Response program was not effective in 2022, and no events were called in 2023.
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 any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Sierra Gentry
Sponsor: Shawn Grant

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-24-10
IN THE MATTER OF THE )
APPLICATION OF ROCKY )
MOUNTAIN POWER'S ) ATTORNEY'S CERTIFICATE
APPLICATION FOR A PRUDENCY ) CLAIM OF CONFIDENTIALITY
DETERMINATION FOR ITS ) RELATING TO DISCOVERY
DEMAND SIDE MANAGEMENT ) RESPONSES
EXPENSES INCURRED IN 2022 AND )
2023 )
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 responses to IPUC Set 1 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 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 7ffi day of October, 2024.
--Resp ectf illy submitted,
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
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