20241029PAC to Staff 5 1st Supplemental_Attorney.pdf

RECEIVED
Tuesday, October 29, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 29, 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-24-11
IPUC Set 1 (1-7)
Please find enclosed Rocky Mountain Power's 1st Supplemental Response to IPUC 1st Set Data
Request 5. The Confidential Attachment IPUC 5 1st Supplemental is 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

PAC-E-24-11 /Rocky Mountain Power
October 29, 2024
IPUC Data Request 5 — 1st Supplemental
IPUC Data Request 5
Please provide copies of the 12 monthly invoices used for the revenue component
listed in Exhibit A.
1st Supplemental Response to IPUC Data Request 5
Further to the Company's response to IPUC Data Request 5 dated October 10,
2024, please refer to Confidential Attachment IPUC 5 1st Supplemental which
provides the additional monthly billing statements for June and July 2023.
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: Hillary Fleming
Sponsor: To Be Determined

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-24-11
IN THE MATTER OF THE )
APPLICATION FOR APPROVAL OF ) ATTORNEY'S CERTIFICATE
THE ASSET TRANSFER ) CLAIM OF CONFIDENTIALITY
AGREEMENT BETWEEN ROCKY ) RELATING TO DISCOVERY
MOUNTAIN POWER AND THE CITY ) RESPONSES
OF IDAHO FALLS — HOLMES )
AVENUE )
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. 5 contains Company
proprietary information that could be used to its commercial disadvantage.
I

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 29ffi day of October, 2024.
Respectfully submitted,
B
Y
Joe Dallas
Senior Attorney
Rocky Mountain Power
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