20241010PAC to Staff 251 - 1st Supplemental .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-24-04
IPUC Set 14 (250-256)
Please fmd enclosed Rocky Mountain Power's I"Supplemental Response to IPUC 14th Set Data
Request 251 and Attachment IPUC 251 1"Supplemental. Provided via BOX to IPUC only is
Confidential Attachment IPUC 251 1st Supplemental CUSTOMER-SPECIFIC 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.
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 lance(&aegisinsi hg t�(C)
Matthew Nykiel/ICL matthew.n, kieI&gmail.com
Brad Heusinkveld/ICL bheusinkveld&idahoconservation.org
Thomas J. Budge/Bayer tjkracineolson.com(C)
Brian C. Collins/Bayer bcollins(&consultbai.com
Greg Meyer/Bayer gme erkgonsultbai.com
Kevin Higgins/Bayer khi2gins cr,energ. straw(C)

Neal Townsend/Bayer ntown send(&energystrat.com (C)
Ronald L. Williams/PIIC rwilliamskhawleytroxell.com
Brandon Helgeson/PIIC bhelgeson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinskmwanalytics.com
Val Steiner/PIIC val.steiner(cr�,itafos.com
Kyle Williams/PIIC williamsk(&byui.edu

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 251 — 1st Supplemental
IPUC Data Request 251
During the virtual meeting on August 26, 2024,between Staff and
the Company, the following three new-revenue transmission projects were
discussed:
Customer 27-UT-Trans DAM E/2022/C/002
Customer 22-UT-Trans DM ET/2022/C/015
Customer 8-UT-Trans(1) TJOR/2021/C/006
Please provide the following information for each of these three projects:
(a) Please provide work papers that determined which elements of work and
associated costs were direct assigned to the customer requesting service and
which elements and associated costs were classified as network upgrades.
(b) Please provide accounting documentation that shows how the anticipated
plant-in- service amount correlates to the network upgrade work.
(c) Please provide the current estimated in-service date.
(d) Please provide a copy of the most current project schedule (Gantt chart)
showing the duration and dependencies of the major work elements, the
critical path, and the in- service date.
11t Supplemental Response to IPUC Data Request 251
The requested information is customer-specific information. The Company
requests special handling. Please contact Mark Alder at [phone] to
make arrangements for review.
Further to the Company's response to IPUC Data Request 251 dated September
20, 2024, the Company provides the following additional information regarding
the Company's allocation of scope and cost between the customer and the
system/network(with explanation and justification for that allocation) for
Customer 8.
Please refer to Customer-Specific Confidential Attachment IPUC 251 lst
Supplemental which provides the requested information for Customer 8.
Please refer to Attachment IPUC 251 lst Supplemental which provides a copy of
Utah Electric Service Regulation Rule No. 12.
Note: Customer-Specific Confidential Attachment IPUC 251 1st Supplemental
contains customer-specific information and is considered business confidential.

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 251 — 1st Supplemental
As stated above, the Company requests special handling. This information is only
being provided to the Idaho Public Utilities Commission (IPUC).
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: Aubrey Rasmussen
Sponsor: Rick Vail

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 first supplemental response to IPUC Data Request No. 14 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 10" day of October, 2024.
Respectfully submitted,
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
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