20241009PAC to Staff 205 - 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 11 (205-216)
Please fmd enclosed Rocky Mountain Power's I"Supplemental Response to IPUC I Ith Set Data
Request 205. Provided via BOX to IPUC only is Confidential Attachment IPUC 205 1"
Supplemental CUSTOMER-SPECIFIC CONE 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 lancekae.isg insi hg t.com(C)
Matthew Nykiel/ICL matthew.nykiel&amail.com
Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org
Thomas J. Budge/Bayer ti(&racineolson.com(C)
Brian C. Collins/Bayer bcollins(&consultbai.com
Greg Meyer/Bayer gmeyerkconsultbai.com
Kevin Higgins/Bayer khig gins kenergystrat.com(C)
Neal Townsend/Bayer ntownsendkenergystrat.com (C)
Ronald L. Williams/PIIC rwilliams(&hawleytroxell.com

Brandon Helgeson/PIIC bhelgeson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinskmwanalytics.com
Val Steiner/PIIC val.steiner(a-)itafos.com
Kyle Williams/PIIC williamsknasbyui.edu

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 205 — Pt Supplemental
IPUC Data Request 205
Company witness McCoy's Exhibit No. 48, Page 8.5.3, Major Plant Detail lists
the following three projects: (1) "Customer 27—UT—Trans"; (2) "Customer 22—
UT -Trans"; (3) "Customer 8 —UT—Trans (1)". Please provide the following
details for each of these three projects:
(a) Please provide a narrative description of each project scope.
(b) Please identify the Customer in each project, and the facilities that will be
served by each project.
(c) Please specify if the Customer provided any Contribution in Aid of
Construction(CIAC) for this project, and if so,provide the amount and how it
has been applied to the project.
(d) Please provide a map of the transmission line constructed by each project,
showing how it interconnects with other transmission lines and/or generation
resources in the vicinity.
(e) Please provide a current project management Gantt chart for each project
showing the major elements of work,their duration and dependencies, and
their percent complete. Please highlight the project critical path.
V Supplemental Response to IPUC Data Request 205
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 205 dated August 30,
2024, the Company provides the following additional response regarding the
scope and cost of the entire project for Customer 8.
Please refer to Customer-Specific Confidential Attachment IPUC 205 1"
Supplemental which provides the requested information for Customer 8.
Note: Customer-Specific Confidential Attachment IPUC 205 1st Supp contains
customer-specific information and is considered business confidential. 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

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 205 — 1st Supplemental
Procedure No. 67—Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement(NDA) executed in this proceeding.
Recordholder: Nathan Adent/Aubrey Rasmussen
Sponsor: Shelley McCoy

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. 201 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 10" day of October, 2024.
Respectfully submitted,
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
2