20241010PAC to Staff 1-7.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
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-24-11
IPUC Set 1 (1-7)
Please find enclosed Rocky Mountain Power's Responses to IPUC 1st Set Data Requests 1-7.
Also provided are Attachment IPUC 2 and 4. The Confidential Attachments IPUC 5 and 7 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

PAC-E-24-11 /Rocky Mountain Power
October 10, 2024
IPUC Data Request 1
IPUC Data Request 1
Please explain how affected customers are being notified of the proposed asset
transfer.
Response to IPUC Data Request 1
There is no formal notification process in place for the proposed asset transfer
since the transfer was requested by the customer.
Recordholder: Anita Reed
Sponsor: Anita Reed

PAC-E-24-11 /Rocky Mountain Power
October 10, 2024
IPUC Data Request 2
IPUC Data Request 2
Please provide the work papers, with all formulas intact and enabled, including
source documents, used to determine the value of the assets shown in Exhibit A
(Description and Value of Assets Serving Transferred Customers), including the
Plant in Service, Income Taxes, and Separation/Estimator Costs.
Response to IPUC Data Request 2
Please refer to Attachment IPUC 2.
Recordholder: Nathan Bailey
Sponsor: Anita Reed

PAC-E-24-11 /Rocky Mountain Power
October 10, 2024
IPUC Data Request 3
IPUC Data Request 3
Please provide a list of all assets included in the transaction by description, year in
service, installed valuation, and current book value.
Response to IPUC Data Request 3
Please refer to the Company's response to IPUC Data Request 2, specifically
Attachment IPUC 2, tab "Holmes Ave".
Recordholder: Nathan Bailey
Sponsor: Anita Reed

PAC-E-24-11 /Rocky Mountain Power
October 10, 2024
IPUC Data Request 4
IPUC Data Request 4
Please provide the accounting treatment and journal entries for the following.
Please include spreadsheets with formulas intact and enabled for the following:
(a) The gain or loss on the sale of these assets;
(b) The removal of these assets from the Company's books; and
(c) Any other journal entries necessary to complete the transaction.
Response to IPUC Data Request 4
Please refer to Attachment IPUC 4.
Recordholder: Jin-Jin Fan
Sponsor: Anita Reed

PAC-E-24-11 /Rocky Mountain Power
October 10, 2024
IPUC Data Request 5
IPUC Data Request 5
Please provide copies of the 12 monthly invoices used for the revenue component
listed in Exhibit A.
Response to IPUC Data Request 5
Please refer to Confidential Attachment IPUC 5.
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: Hillary Fleming
Sponsor: To Be Determined

PAC-E-24-11 /Rocky Mountain Power
October 10, 2024
IPUC Data Request 6
IPUC Data Request 6
Please explain how the proposed transaction complies with Idaho code § 61-
328(3). This response should outline how the transaction is consistent with the
public interest and explain how the cost of-and rates for-supplying service will not
be increased by reason of such transaction. This response should also illustrate
how "the applicant for such acquisition or transfer has the bona fide intent and
financial ability to operate and maintain said property in the public service."
Idaho Code § 61-328(3)(c).
Response to IPUC Data Request 6
The Idaho Public Utilities Commission (IPUC) approved a Service Allocation
Agreement(SAA)between Idaho Falls and Rocky Mountain Power (RMP or
Company) on December 5, 2017, under the Idaho Electric Supplier Stabilization
Act (ESSA). As provided by the IPUC:
[T]he Service Allocation Agreement is the framework for implementing the
ESSA in transactions between the Company and the City. Under the Service
Allocation Agreement, the Company and the City have agreed that
compensation for transferring customer service rights and responsibilities is
167% of the transferring customer or customers' most recent 12-months
electric bills and the cost of the assets used in service of the customer or
customers plus applicable legal transactional costs, separation costs, and tax
gross-up.'
The IPUC has approved several Asset Transfer Agreements (ATA)between RMP
and Idaho Falls, including those within Case No. PAC-E-19-09, Case No. PAC-E-
20-01, Case No. PAC-E-20-06, Case No. PAC-E-20-12, Case No. PAC-E-23-02,
and Case No. PAC-E-23-15 in accordance with the approved SAA. IPUC found
that these ATAs complied with the requirements in Idaho Code 61-328 and
thereby authorized the transfer of assets between RMP and Idaho Falls in those
proceedings.
The ATA in this proceeding is similar to the prior agreements approved by the
IPUC and aligns with the terms of the approved SAA. The ATA ensures fair
compensation for facilities transferred between the parties, with an amount equal
to 167 percent of the exiting customer's revenues collected for the most recent 12
months. Moreover, RMP further represents that its cost-of and rates for supplying
service will not increase due to this transaction. RMP has also consulted with
Idaho Falls, and the City has confirmed that, as a joint applicant in this proceeding
and a subdivision of the State of Idaho, it has the bona fide intent and financial
'In the Matter of the Join Application of the City of Idaho Falls and Rocky Mountain Power for Approval
of a Service Allocation Agreement,Case No.PAC-E-19-09, Order No. 34418 (August 19, 2019).

PAC-E-24-11 /Rocky Mountain Power
October 10, 2024
IPUC Data Request 6
ability to operate and maintain the property in the public service. Considering the
above points and the customer's request for the proposed asset transfer, this asset
transfer is consistent with the public interest.
Recordholder: Legal Counsel
Sponsor: To Be Determined

PAC-E-24-11 /Rocky Mountain Power
October 10, 2024
IPUC Data Request 7
IPUC Data Request 7
Please provide legible maps showing the locations(s) of facilities to be
transferred.
Response to IPUC Data Request 7
Please refer to Confidential Attachment IPUC 7.
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: Phil Springer
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-24-11
IN THE MATTER OF ROCKY )
MOUNTAIN POWER'S AND THE CITY )
OF IDAHO FALLS' JOINT APPLICATION ) ATTORNEY'S CERTIFICATE
FOR APPROVAL OF THE HOLMES ) CLAIM OF CONFIDENTIALITY
AVENUE ASSET TRANSFER ) RELATING TO DISCOVERY
AGREEMENT ) RESPONSES
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.
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in that the information contains Company proprietary information.
1

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 10th day of October, 2024.
Respectfully submitted,
By S`
Joe Dallas
Senior Attorney
Rocky Mountain Power
2