20241023PAC to Staff 277-280.pdf

RECEIVED
Wednesday, October 23, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 23, 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 19 (277-280)
Please find enclosed Rocky Mountain Power's Responses to IPUC 19th Set Data Requests 277-
280. The Confidential Attachments IPUC 279 and 280 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
C.c.: Eric L. Olsen/IIPA elogechohawk.com(C)
Lance Kaufman/IIPA lanceAae isg insi hg t.com(C)
Matthew Nykiel/ICL matthew.nykiel(&gmail.com
Brad Heusinkveld/ICL bheusinkveldgidahoconservation.org
Thomas J. Budge/Bayer tjgracineolson.com(C)
Brian C. Collins/Bayer bcollinsgconsultbai.com
Greg Meyer/Bayer gme ergconsultbai.com
Kevin Higgins/Bayer khigginsgenergystrat.com(C)
Neal Townsend/Bayer ntownsendgeneraystrat.com(C)
Ronald L. Williams/PIIC rwilliams(cr�,hawleytroxell.com

Brandon Helgeson/PIIC bhel_eg songhawleytroxell.com
Bradley Mullins/PIIC brmullins&mwanalytics.com
Val Steiner/PIIC val.steiner(cr�,itafos.com
Kyle Williams/PIIC williamsk(c�r�,byui.edu

PAC-E-24-04/Rocky Mountain Power
October 23, 2024
IPUC Data Request 277
IPUC Data Request 277
Please provide the Company's cost-assignment policy when a customer requests a
large load increase that requires a new or upgraded line extension at transmission
level voltages. The discussion should include the following issues:
(a) Please explain the Company's policy for allocating the project costs between
direct assigned to the customer and network-assigned to all ratepayers;
(b) Please explain how line extension allowances are determined, how the
Company recovers revenue for those allowances, and how the Company
accounts for the additional new revenue from the customer;
(c) Please explain if and how the above policies differ if the requesting customer
is a transmission and interconnection customer such as a municipal power
agency; and
(d) Please explain if and how the above policies differ if the load increase is
caused by the collective impact of small customer growth.
Response to IPUC Data Request 277
(a) For large customers, whether a facility is direct-assigned or is considered to be
a network upgrade is dependent, respectively, on whether a facility is being
built for the sole use and benefit of the customer requesting service or whether
the facility will be integrated with and support the Company's transmission
and distribution networks for the general benefit of all users of such networks.
Main grid network upgrades or Western Electricity Coordinating Council
(WECC) critical facilities are paid for by the Company in entirety and
incorporated into rate base.
(b) Please refer to Rule 12.3.a. The Company grants customers taking service at
46,000 volts or greater an extension allowance of the meter, current
transformers and potential transformers necessary to measure the customer's
usage. Large customers pay facilities charges to recover the cost of line
extension facilities paid for with an allowance. The Company interprets
"additional new revenue"to mean line extension advance, or contributions in
aid of construction(CIAC). Based on the foregoing interpretation, the
Company responds as follows:
For ratemaking purposes, CIAC reduces the associated rate base.
(c) Costs for large load increases on the transmission system from a Network
Customer taking Network Integration Transmission Service (NITS)under the
Company's Open Access Transmission Tariff(OATT) Section III are

PAC-E-24-04/Rocky Mountain Power
October 23, 2024
IPUC Data Request 277
assigned based on the definitions of Direct Assigned Facilities and Network
Upgrades found in the Company's OATT.
(d) The Company interprets this question to refer to subpart(a) of this data
request. The Company further interprets this question to refer to growth of
retail customer loads served by a Network Customer taking NITS under the
Company's OATT Section III. Each Network Customer has the obligation to
provide annual load and resource information updates as described in Sections
29.2(ix) and 31.6 of the GATT. Based on the foregoing interpretations,the
Company responds as follows:
Provided the Network Customer has included the projected load increases
caused by the collective small retail customer growth in the annual load and
resource update, and the load increase is not a material change as defined in
Section 31.6 of the OATT and clarified in Business Practice#9
(https://www.oasis.oati.com/woa/docs/PPW/PPWdocsBP9.pdf), the
Company will include the collective load increases in the Attachment K
planning process, and as part of the Company's Local Transmission System
Plan, and have cost responsibility to construct and place into service sufficient
electric facilities to serve the projected load increases.
Recordholder: Nick Highsmith/Kris Bremer/ Scott Beyer
Sponsor: Shelley McCoy/Rick Vail

PAC-E-24-04/Rocky Mountain Power
October 23, 2024
IPUC Data Request 278
IPUC Data Request 278
Please provide the Company's cost-assignment policy when it executes a
generation interconnection request. Please explain how the Company allocates the
project cost between direct-assigned to the generator, and network-assigned to all
ratepayers.
Response to IPUC Data Request 278
The Company assigns costs based on the relevant jurisdictional tariff
requirements which most commonly is defined in the Company's Open Access
Transmission Tariff(GATT) which contains definitions of cost allocation for
direct assigned facilities and network upgrades.
Recordholder: Kris Bremer
Sponsor: Rick Vail

PAC-E-24-04/Rocky Mountain Power
October 23, 2024
IPUC Data Request 279
IPUC Data Request 279
Please provide the following information about the "TJOR/2018/C/003 - C7 Data
Centers Load Increase"project:
(a) Please provide the initial Appropriation Request(APR) document and
subsequent changes;
(b) Please provide the current project schedule, showing the major work
breakdown structure, the current progress, and the critical path for substantial
completion;
(c) Please explain how much of the project budget was allocated between direct-
assigned and network-assigned, and the Company's basis for that allocation;
(d) Please explain if a line extension allowance was granted to the customer, and
if so,provide the worksheet calculations for that allowance; and
(e) Please explain if the network-assigned costs will be offset by any
corresponding sources of revenue for the network ratepayers, and if so, please
explain the method used.
Response to IPUC Data Request 279
(a) Please refer to Confidential Attachment IPUC 279.
(b) The "TJOR/2018/C/003 - C7 Data Centers Load Increase"project was
completed on June 27, 2023 and therefore does not have a current project
schedule.
(c) The project budget was 100 percent network upgrade. 100 percent of the
improvements needed for this project would benefit the system and not just
the customer.
(d) The customer was not given a line extension allowance.
(e) The network assigned costs were offset by the customer's contributions in aid
of construction(CIAC) for their proportionate share of the network upgrades.
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.

PAC-E-24-04/Rocky Mountain Power
October 23, 2024
IPUC Data Request 279
Recordholder: Russell Updike
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
October 23, 2024
IPUC Data Request 280
IPUC Data Request 280
Please provide the following information about the "TIUT/2020/C/004 - Q0155
DAMPS Heber Light& Power" project:
(a) Please provide the initial Appropriation Request("APR") document and
subsequent changes;
(b) Please explain how much of the project costs were allocated between direct-
assigned and network-assigned, and the Company's basis for that allocation;
and
(c) Please explain if the network-assigned costs will be offset by any
corresponding sources of revenue for the network ratepayers, and if so, please
explain the method used.
Response to IPUC Data Request 280
(a) Please refer to Confidential Attachment IPUC 280 which provides the
following documents:
• APR 24019037 Q0155 Heber 2nd POD approved 07-27-2021 CONF.
• APR 94013447 Q0155 Heber 2nd POD approved 08-03-2023 CONF.
(b) PacifiCorp determines direct assigned costs and network upgrade costs based
on the definitions in its Open Access Transmission Tariff(GATT). Direct
assigned costs were $639,904 and network upgrade costs were $6,818,021.
Please refer to Confidential Attachment IPUC 280, specifically"APR
94013447 Q0155 Heber 2nd POD approved 08-03-2023 CONF".
(c) PacifiCorp's current transmission formula rate (included in PacifiCorp's
GATT) was approved by the Federal Energy Regulatory Commission(FERC)
in Docket ERI 1-3643-000. The formula rate is a fixed method/template for
calculating a rate based on defined inputs. The Company's transmission
formula rate is updated annually with the annual transmission revenue
requirement(ATRR) that represents the annual total cost of providing firm
transmission service over the test year. The ATRR calculation incorporates all
transmission system investments by the Company, a return on rate base,
income taxes, expenses (including operations and maintenance (O&M)), and
certain revenue credits, among other specific elements and adjustments.
Transmission assets, including new transmission capital and transmission
network upgrades, are included in the ATRR, weighted by months in service.
The ATRR is converted into a rate by dividing the ATRR by firm
transmission demand, and this wheeling rate is charged to all third-party
transmission customers.

PAC-E-24-04/Rocky Mountain Power
October 23, 2024
IPUC Data Request 280
Generation(interconnection) is typically added when a customer anticipates a
need or growth in load or seeking to sell the output. Any network
interconnection cost will increase the rate base and add to the revenue
requirement shared by all network customer as required by FERC rules.
PacifiCorp does not collect revenues on generation interconnections, but any
load increase over time, or if a customer utilized point-to-point(PTP)
transmission service, will be the source of additional revenues to help cover
the network upgrade costs.
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: Eva Kwitman/Ernie Knudsen
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 response to IPUC Set 19 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 23rd day of October, 2024.
Respectfully submitted,
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
2