20241016PAC to Staff 252 2nd Supplemental (Redacted).pdf

RECEIVED
Wednesday, October 16,2024
IDAHO PUBLIC
_ ROCKY MOUNTAIN UTILITIES COMMISSION
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 16, 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 2nd Supplemental Response to IPUC 14d' Set Data
Request 252. Provided via BOX is Confidential Response IPUC 252 2nd 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 [phone].
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures
C.c.: Eric L. Olsen/IIPA elokechohawk.com(C)
Lance Kaufman/IIPA lance@ae ism h�(C)
Matthew Nykiel/ICL matthew.n, k�(&gmail.com
Brad Heusinkveld/ICL bheusinkveldkidahoconservation.oriz
Thomas J. Budge/Bayer tj racineolson.com(C)
Brian C. Collins/Bayer bcollinskconsultbai.com
Greg Meyer/Bayer gmeyer(&consultbai.com
Kevin Higgins/Bayer khia gins kenergystrat.com(C)
Neal Townsend/Bayer ntown send(&energystrat.com (C)

Ronald L. Williams/PIIC rwilliams&hawleytroxell.com
Brandon Helgeson/PIIC bhel eg son ci,hawleytroxell.com
Bradley Mullins/PIIC brmullins(&mwanalytics.com
Val Steiner/PIIC val.steinergitafos.com
Kyle Williams/PIIC williamskkbvui.edu

PAC-E-24-04/Rocky Mountain Power
October 16, 2024
IPUC Data Request 252 —2nd Supplemental
IPUC Data Request 252
During the virtual meeting on August 26, 2024, between Staff and the Company,
the following project was discussed:
Project Description/Project Name/Titte 0 Project Def-mitim
Project Specialized TPEN/2021/C/001
Please provide the following information for this project:
(a) Please explain how the budgeted cost for this project changed from $72.7
million in June (McCoy's Exhibit 48, Page 8.5.3 Major Plant Detail) to $38.9
million in August(worksheet provided by Mr. Alder for the subject virtual
meeting).
(b) Please confirm the Company's assertion in the virtual meeting that this
amount represents the line extension allowance determined by Oregon policy
(because the line extension supplies an Oregon customer). If confirmed,
please provide the Company's worksheets that calculate this amount in
accordance with the policy.
(c) If not confirmed, please explain the Company's basis for determining the
amount that it assigned to the network upgrades and provide worksheets
showing these calculations.
(d) Please provide the current estimated in-service date.
(e) 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.
2nd Supplemental Confidential Response to IPUC Data Request 252
Further to the Company's prior responses to IPUC Data Request 252 and in
response to an inquiry from Idaho Public Utilities Commission (IPUC) staff
requesting for more detail total projects costs and the contributions in aid of
construction (CIAC), the Company provides the following additional information:
(a) The $72.7 million represents the total transmission and distribution costs to be
placed in service in 2024. The $38.9 million represents the estimated cost of
transmission assets, excluding distribution, at the time of the Company's
submission of its response to IPUC Data Request 51. Both, the $72.7 million
and $38.9 million calculations are after CIAC is considered.

PAC-E-24-04/Rocky Mountain Power
October 16, 2024
IPUC Data Request 252 —2nd Supplemental
(b)
c) There are no network upgrades associated with this project.
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: Micheline Craw
Sponsor: Diana Knous

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 second responses to IPUC Data Request No. 252 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 16ffi day of October, 2024.
Respectfully submitted,
By z—
Joe Dallas
Senior Attorney
Rocky Mountain Power
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