20241010PAC to Bayer 94-96 (Redacted).pdf

RECEIVED
Thursday, October 10, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 10, 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 9 (94-96)
Please find enclosed Rocky Mountain Power's Responses to Bayer's 9th Set Data Requests 94-
96. Also provided is Attachment Bayer 95. Provided via BOX is Confidential Response Bayer
94 and Confidential Attachment Bayer 96. 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 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 10, 2024
Bayer Data Request 94
Barer Data Request 94
Please refer to Confidential Attachment Bayer 34 provided in Response to Bayer
Data Request 34. Please explain how sellbacks of hedges Deal Nos. 2334384,
2335565, 2336726, 2336170, and 2344336 are in accordance with PacifiCorp's
Energy Risk Management Policy and will help achieve the Company's goal of
achieving physical hedges at 75%of the peak usage.
Confidential Response to Bayer Data Request 94
Please refer to the Company's response to Bayer Data Request 34, specifically
Confidential Attachment Bayer 34,confidential file "PacifiCorp 2025 Hedges as
of 20240801 CONF". Column R notes the im act on the Co m an is osition.
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: Doug Staples
Sponsor: John Fritz/Paul Wood

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
Bayer Data Request 95
Bayer Data Request 95
Please provide the following information with respect to PacifiCorp's Multi-State
Process (MSP):
(a) Current version of the PacifiCorp MSP.
(b) Expiration date of PacifiCorp's current MSP.
(c) Please explain in detail if the expiration of PacifiCorp's' current MSP could
impact the RMP Idaho revenue requirement proposed in this proceeding.
(d) Please provide any estimates of cost impacts prepared by the Company that
would impact Idaho's jurisdictional revenue requirement.
Response to Bayer Data Request 95
(a) Please refer to Attachment Bayer 95 for a copy of the 2020 PacifiCorp Inter-
Jurisdictional Allocation Protocol. (2020 Protocol)
(b) The Company filed an application for approval of the First Amendment and
Extension to the 2020 Protocol. The application asked for an extension of the
2020 Protocol through December 31, 2025. The Idaho Public Utilities
Commission (IPUC) approved the application and extension request in Case
No. PAC-E-23-13 Order No. 35984 dated November 2, 2023. The expiration
date of the 2020 Protocol is December 31, 2025
(c) The expiration date of the 2020 Protocol does not impact the revenue
requirement proposed in this general rate case (GRC). This Idaho GRC was
filed during the extended interim period. The use of an historic test year with
known and measurable changes does not request costs beyond December 31,
2024, which is well within the extended date of the 2020 Protocol as described
in the Company's response to subpart(b) above.
(d) The Company assumes that estimates of cost impacts is defined as cost impacts
related to the expiration date of the 2020 Protocol in the current GRC. Based on
the foregoing definition, the Company responds as follows:
The Company has not prepared any estimates of cost impacts to Idaho's
jurisdictional revenue requirement in this GRC for expiration of the 2020
Protocol.
Recordholder: Craig Larsen
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
Bayer Data Request 96
Bayer Data Request 96
Please provide the hourly regulation reserves (MW) included in the Aurora
Production model. Please explain if the volume of regulation reserves are
provided as an input in the Aurora model or are calculated within the model. If the
Company produces any inputs that determines the volume of regulation reserves
within the model please provide all work papers supporting the inputs in their
original format with all formulae and links intact.
Response to Bayer Data Request 96
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell. Specifically refer to confidential work
paper"Aurora GN Regulating Margin CONF", tab"1 Regulation Margin",
column F (RegUp-West) and column G (RegUp-East) and use column B (Date) to
filter for the 2025 forecast time period to get the regulation reserve megawatt
(MW) requirement for the West and East sides of PacifiCorp's system, used as an
input into the Aurora model for the forecast.
Please refer to Confidential Attachment Bayer 96 which provides the work paper
supporting the "RegUp-West" MW requirement, specifically confidential file
"NPC_Reg_Reserve_West_template-CONF.xlsm", tab "Results", column D
(Portfolio Requirement with EIM Adjustments). Please use column A (Date) to
filter for 2025 to align with the MW requirements in confidential file "Aurora GN
Regulating Margin CONF".
Please refer to Confidential Attachment Bayer 96 which provides the work paper
supporting the "RegUp-East"MW requirement, specifically confidential file
"NPC_Reg_Reserve_East template-CONF.xlsm", tab"Results", column D
(Portfolio Requirement with EIM Adjustments). Please use column A (Date) to
filter for 2025 to align with the MW requirement in confidential file "Aurora GN
Regulating Margin CONF".
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: Isaiah Zacharia
Sponsor: Ramon Mitchell

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
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 that the its response to Bayer Set 9 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 1 Oth day of October, 2024.
Respectfully submitted,
By
Joe Dallas
Attorney
Rocky Mountain Power
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