20241008PAC to Staff 261-267 (Redacted).pdf

RECEIVED
Tuesday, October 08, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 8, 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 16 (261-267)
Please find enclosed Rocky Mountain Power's Responses to IPUC 161' Set Data Requests 261-
267. Also provided are Attachments IPUC 265-2,266 and 267. The Confidential Response
IPUC 264 and Confidential Attachments IPUC 262, 263 and 265-1 are 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.: Eric L. Olsen/IIPA elokechohawk.com(C)
Lance Kaufman/IIPA lance@ae ism h�(C)
Matthew Nykiel/ICL matthew.n, k�(&gmail.com
Brad Heusinkveld/ICL bheusinkveldkidahoconservation.org
Thomas J. Budge/Bayer tj racineolson.com(C)
Brian C. Collins/Bayer bcollinskconsultbai.com
Greg Meyer/Bayer gmeyer(&consultbai.com
Kevin Higgins/Bayer khia gins kenergystrat.com(C)
Neal Townsend/Bayer ntown send(&energystrat.com (C)

Ronald L. Williams/PIIC rwilliams&hawleytroxell.com
Brandon Helgeson/PIIC bhel eg son ci,hawleytroxell.com
Bradley Mullins/PIIC brmullins(&mwanalytics.com
Val Steiner/PIIC val.steinergitafos.com
Kyle Williams/PIIC williamskkbvui.edu

PAC-E-24-04/Rocky Mountain Power
October 8, 2024
IPUC Data Request 261
IPUC Data Request 261
Referencing the Company's response to Production Request No. 130, please
provide the documents describing the reasons for the Little Snake Shoo-Fly
change order and the resolution of the change order.
Response to IPUC Data Request 261
The Company assumes that the reference to "Production Request No. 130" is
intended to refer to the Company's response to IPUC Data Request 130. Based on
this assumption, the Company responds as follows:
During the initial grading of the Little Snake substation area, a significant
archaeological discovery was made. In accordance with the record of decision
issued by the United States (U.S.)Bureau of Land Management(BLM) for the
project, a historic properties treatment plan was required to be developed,
coordinated and approved by the Company, the BLM and the Tribes. This
discovery was located within a critical area inside the substation fence and caused
a significant delay to the construction schedule.
Due to the time required to establish and implement an approved treatment plan,
the Company engineered a temporary configuration that allowed construction to
continue outside the controlled discovery area, enabling the installation and
commissioning of the minimum equipment necessary to support the energization
of the transmission line in 2024. This configuration required a "shoofly" to be
constructed around the portion of the substation where construction was
prohibited during the treatment of the discovery area, connecting to the portion of
the substation that could proceed with construction.
The unaffected substation area, along with the shoofly, is on track to be
constructed, commissioned and energized by November 2024. The treatment of
the discovery has been completed, and construction in that portion of the
substation, as well as the removal of the shoofly, is on track for completion by
mid-2025, allowing for full energization through the entire substation.
The re-sequencing of this work from the original scope, along with the
construction contractors' involvement in supporting the treatment of the
archaeological discovery, required negotiations with the contractors to adjust the
work and ensure the project schedule and revised scope were met.
Recordholder: Brandon Smith
Sponsor: Todd Jensen

PAC-E-24-04/Rocky Mountain Power
October 8, 2024
IPUC Data Request 262
IPUC Data Request 262
Following up on Production Request Nos. 167 and 168, please provide the actual
coal inventory in dollars and tons as well as the tons of coal needed for 30-, 45-,
60- and 75-day supply for the following plants:
(a) Naughton
(b) Wyodak
(c) Colstrip
(d) Hayden
Response to IPUC Data Request 262
The Company assumes the reference to "Production Request Nos. 167 and 168" is
intended to be a reference to the Company's responses to IPUC Data Request 167
and IPUC Data Request 168. Based on the foregoing assumption, the Company
responds as follows:
Please refer to Confidential Attachment IPUC 262, specifically tab "Actual-
2024," for the coal inventory in dollars and tons for Naughton, Wyodak, Colstrip,
and Hayden.
Please refer to Confidential Attachment IPUC 262, specifically tab "Days Burn,"
which provides the calculation of coal inventory in tons for a 30-day, 45-day, 60-
day and 75-day coal stockpile for Naughton, Wyodak, Colstrip and Hayden.
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: Heather Garcia
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
October 8, 2024
IPUC Data Request 263
IPUC Data Request 263
Please provide the capacity factor for each coal plant used in the Company's net
power costs in this case.
Response to IPUC Data Request 263
Please refer to Confidential Attachment IPUC 263.
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: Gavin Mangelson
Sponsor: Brad Richards

PAC-E-24-04/Rocky Mountain Power
October 8, 2024
IPUC Data Request 264
IPUC Data Request 264
In calculating wheeling revenues, the Company has provided inconsistent
information as shown below. Please identify which set of information is the
correct version and why it is correct.
Attack IPUC
Proposed m Attach IPUC IJS 1st
MCC 0V s 115 RS la])
R'orL a r C0NF.zlsz CO\'F.zlsz
Line-Ton
Line-Incremental Adj a:tmear.'
Line"Ac cttm Totals..
Has Incremental Adja:tmeotz Are C aknlated
Remote Ref=&and Other
Ourof-Period Adj =ens
AmuaL»d Charges
Profottna Adju=ent;
Incremental Adjustments
Response to IPUC Data Request 264
Both data sets are accurate. The Company's' response to IPUC Data Request 145
requested pro forma details for the following accounts:
• Firm Wheeling Revenue;
• Pre-Merger Firm Wheeling Revenue—UPD;
• Ancil Revenue Sch 2-Reactive (Trans);
• Ancillary Revenue Sch 1 -Scheduling; and
• Transmission Point-to-Point Revenue.
The Company's response to the IPUC Data Request 145 addressed only the
accounts questioned and not every account with adjustments.
Recordholder: Ernie Knudsen
Sponsor: Ernie Knudsen

PAC-E-24-04/Rocky Mountain Power
October 8, 2024
IPUC Data Request 265
IPUC Data Request 265
Please re-run the Aurora model and provide updated workpaper
"ID_GRC_2025_2023 Normalized Load.xlsm" and updated McCoy's work paper
"5.1 —NPC.xlsx" to reflect the result of the scenario below:
a) Use the OFPC dated on June 28,2024,from Response to Production Request No. 107
Scenario in the Aurora model;
b) Remove the CCA allowance cost from the dispatch cost of the Chehalis plant in the
Aurora model;
c) Remove the post-modeling CCA costs,which were calculated based on the
multiplication of Chehalis's generation amounts and the CCA allowance cost; and
d) Use 101%of market prices to value Emergency Purchases
Response to IPUC Data Request 265
Please refer to Confidential Attachment IPUC 265-1, confidential file "Attach
IPUC 265—NPC Report CONF", which provides the net power cost (NPC)report
for the requested scenario. The NPC impact of changing the value of Emergency
Purchases to 101 percent of market prices is $1.06 million and this value is
calculated as the difference between the NPC in confidential file "Attach IPUC
265 NPC Report CONF", tab "NPC", cell D331 and the NPC report provided
with the Company's response to IPUC Data Request 107, specifically
Confidential Attachment IPUC 107-2, confidential file "0624 OFPC
ID_GRC_2025 Update_2023 Normalized Load CONF", tab "NPC", cell D331.
Please refer to Attachment IPUC 265-2, file "5.1 NPC ID IPUC 265"which
reflects the revenue requirement adjustment for the requested NPC scenario run.
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: Eshwar Vyakarna Rajshekar Rao /Tyler Wells
Sponsor: Ramon Mitchell/ Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
October 8, 2024
IPUC Data Request 266
IPUC Data Request 266
As a follow up to Response to Production Request No. 212 Attachments 212-2,
212-3, and 212-4, please explain if the Company made payment before or after
delivery of each item. If before, please provide the delivery date of each item.
Response to IPUC Data Request 266
The Company assumes the reference to "Production Request No. 212
Attachments 212-2, 212-3, and 212.4"is intended to be a reference to the
Company's response to IPUC Data Request 212, and to Attachment IPUC 212-2,
Attachment IPUC 212-3 and Attachment IPUC 21-4. Based on the foregoing
assumption, the Company responds as follows:
Please refer to Attachment IPUC 266.
Recordholder: Steven Baker
Sponsor: Nikki Kobliha

PAC-E-24-04/Rocky Mountain Power
October 8, 2024
IPUC Data Request 267
IPUC Data Request 267
Please provide the Company's vehicle replacement policy.
Response to IPUC Data Request 267
Please refer to Attachment IPUC 267.
Recordholder: Mike Cedar
Sponsor: To Be Determined

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 responses to IPUC Set 16 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 8 h day of October, 2024.
Respectfully submitted,
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
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