20241015PAC to Staff 265 1st Supplemental.pdf

RECEIVED
Tuesday, October 15, 2024
IDAHO PUBLIC
_ ROCKY MOUNTAIN UTILITIES COMMISSION
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 14, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
monica.barriossanchez(a�puc.idaho.gov
SecretgUgpuc.idaho.gov
RE: ID PAC-E-24-04
IPUC Set 16 (261-267)
Please find enclosed Rocky Mountain Power's 1st Supplemental Response to IPUC 16th Set Data
Request 265 and Attachment IPUC 265-2 lst Supplemental. Provided via BOX is Confidential
Attachment IPUC 265-1 1st Supplemental. 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(801) 220-2313.
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures
C.c.: Eric L. Olsen/IIPA eloAechohawk.com(C)
Lance Kaufman/IIPA lancegae_isg insi_h�(C)
Matthew Nykiel/ICL matthew.n, kielggmail.com
Brad Heusinkveld/ICL bheusinkveld(c-r�,idahoconservation.org
Thomas J. Budge/Bayer tina,racineolson.com(C)
Brian C. Collins/Bayer [e-mail]
Greg Meyer/Bayer gmey r(c-r�,consultbai.com
Kevin Higgins/Bayer [e-mail](C)
Neal Townsend/Bayer ntownsendgenergystrat.com(C)

Ronald L. Williams/PIIC rwilliamsghawleytroxell.com
Brandon Helgeson/PIIC bhel.eg son&hawleytroxell.com
Bradley Mullins/PIIC brmullins&mwanalytics.com
Val Steiner/PIIC val.steinerkitafos.com
Kyle Williams/PIIC williamsk(a),byui.edu

PAC-E-24-04/Rocky Mountain Power
October 14, 2024
IPUC Data Request 265 — 1st Supplemental
IPUC Data Request 265
Please re-run the Aurora model and provide updated work paper
"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
111 Supplemental Response to IPUC Data Request 265
Further to the Company's response to IPUC Data Request 265 dated October 8,
2024, the Company provides the following additional response:
Please refer to Confidential Attachment IPUC 265-1 1st Supplemental which
provides the net power costs (NPC) report provided in response to IPUC Data
Request 230 as "Scenario 2"with the Emergency Purchases valued at 101 percent
of the market prices instead of 125 percent of the market prices. This results in a
decrease in total company NPC of approximately $1 million.
Please refer to cell D243 on tab "NPC"which provides updated dollars associated
with "Emergency purchases".
Please refer to Attachment IPUC 265-2 lst Supplemental, file"5.1 NPC ID IPUC
265 1 st SUPP"which reflects the revenue requirement adjustment for the above
referenced 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 Raj shekar Rao/Tyler Wells
Sponsor: Ramon Mitchell/ 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 responses to IPUC Data Request No. 265 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 14th day of October, 2024.
Respectfully submitted,
v�1-
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
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