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Home My WebLink About20241101PAC to PIIC 40_41_43_44_45_47_48.pdf RECEIVED Friday, November 1, 2024 IDAHO PUBLIC _ ROCKY MOUNTAIN UTILITIES COMMISSION POWER A DIVISION OF FACIFICORP 1407 W North Temple, Suite 330 Salt Lake City, Utah 84116 November 1, 2024 Ronald L. Williams Brandon Helgeson Attorneys For PIIC rwilliams(&hawleytroxell.com(C) bhel eg son&hawleytroxell.com(C) Bradley Mullins brmullins(c�mwanalytics.com(C) Val Steiner val.st einer nitafo s.com Kyle Williams williamsk(&byui.edu RE: ID PAC-E-24-04 PIIC Set 2 (29-50) Please find enclosed Rocky Mountain Power's Responses to PIIC 2nd Set Data Requests 40, 41, 43, 44, 45, 47 and 48. Provided via BOX are the Confidential Attachments. 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.: Monica Barrios-Sanchez/IPUC monica.barriossanchez(i7�,puc.idaho.gov (C) S ecretary(a,yuc.Idaho.gov Eric L. Olsen/IIPA elo(&echohawk.com(C) Lance Kaufman/IIPA lancena,ae isg insi hg t.com(C) Matthew Nykiel/ICL matthew.nykielkamail.com Brad Heusinkveld/ICL bheusinkveld(a�idahoconservation.org Thomas J. Budge/Bayer tj racineolson.com(C) Brian C. Collins/Bayer bcollins(&consultbai.com(C) Greg Meyer/Bayer gme erkconsultbai.com(C) Kevin Higgins/Bayer khia gins&energystrat.com(C) Neal Townsend/Bayer ntownsend(u-benergystrat.com (C) PAC-E-24-04/Rocky Mountain Power November 1, 2024 PIIC Data Request 40 PIIC Data Request 40 Please provide the work papers used to calculate the currently effective OATT ancillary service rates for OATT ancillary service Schedule 3, Schedule 5 and Schedule 6. Response to PIIC Data Request 40 There are no work papers to provide; the currently effective Open Access Transmission Tariff(GATT)ancillary service rates for Schedule 3, Schedule 5 and Schedule 6 were reached by consensus through settlement. Recordholder: Ernie Knudsen Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power November 1, 2024 PIIC Data Request 41 PIIC Data Request 41 For each customer that received services under the OATT ancillary service Schedule 3, Schedule 5 and Schedule 6 in calendar year 2023, please provide the billing determinants used to assess service to the customer's service charges under those schedules. Response to PIIC Data Request 41 Please refer to Confidential Attachment PIIC 41. 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: Ernie Knudsen Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power November 1, 2024 PIIC Data Request 43 PIIC Data Request 43 Reference PacifiCorp's OATT Volume No. 11, Page 307: (a) Please provide a general explanation for the purpose and effect of the ARTSOA moratorium period included in PacifiCorp's current OATT for Schedule 3. (b) Please specify the amount of test period revenues foregone as a result of the referenced ARTSOA moratorium. (c) Please provide the monthly aggregate Schedule 3 billing demands over calendar year 2023 for the Utah Municipal Power Agency, the Deseret Generation & Transmission Co-Operative, Inc. and the Utah Associated Municipal Power Systems, with each stated separately. (d) Please provide the monthly non-aggregated Schedule 3 billing demands over calendar year 2023 for the Utah Municipal Power Agency, the Deseret Generation& Transmission Co-Operative, Inc. and the Utah Associated Municipal Power Systems, with each stated separately. Response to PIIC Data Request 43 (a) The Company directs the PacifiCorp Idaho Industrial Customers (PIIC) to PacifiCorp's Open Access Transmission Tariff(GATT),pages 307 through 308, which provide a general explanation of the purpose and effect of the Amended and Restated Transmission Service and Operating Agreement (ARTSOA). (b) The Company objects to this request as outside the scope of discovery permitted by Idaho authorities, because the Company has not created, nor does it otherwise possess, the information requested. The Company also objects to this request because it seeks information that is not relevant to this proceeding: the ARTSOA was approved in a Federal Energy Regulatory Commission FERC jurisdictional proceeding, is currently included in PacifiCorp's GATT, and as a result cannot be a contested issue in this proceeding. (c) Please refer to the Company's response to PIIC Data Request 41. (d) Please refer to the Company's response to PIIC Data Request 48, specifically Confidential Attachment PIIC 48 for hourly loads in the PacifiCorp East (PACE) and PacifiCorp West(PACW). PAC-E-24-04/Rocky Mountain Power November 1, 2024 PIIC Data Request 43 Recordholder: Ernie Knudsen Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power November 1, 2024 PIIC Data Request 44 PIIC Data Request 44 Reference witness Mitchell work paper"GNw_Non Owned Generation CONF.xlsx:" Please identify each non-owned resource included in the referenced work paper that is owned by the Utah Municipal Power Agency, the Deseret Generation & Transmission Co-Operative, Inc. and the Utah Associated Municipal Power Systems and state which of these three entities owns the generation resource. Response to PIIC Data Request 44 The Company objects to this request as outside the scope of information discoverable under Idaho authorities, because it is overly burdensome to respond to, and otherwise more readily available through public sources. Without waiving that objection, the Company responds: Please refer to the following websites for Utah Municipal Power Agency (UMPA), the Deseret Generation and Transmission Co-Operative, Inc. (Deseret), and the Utah Associated Municipal Power Systems (DAMPS), for more information: www.umpa.energy www.deseretpower.com www.uamps.com. Recordholder: Legal Counsel Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power November 1, 2024 PIIC Data Request 45 PIIC Data Request 45 Reference witness Mitchell work paper"GNw_Non Owned Generation CONF.xlsx:" For each resource included in the referenced work paper, please state the amount of monthly revenue received for OATT ancillary service Schedule 3, Schedule 5 and Schedule 6 in calendar year 2023. Response to PIIC Data Request 45 PacifiCorp tracks this data by customer, not by"resource". Please refer to the Company's response to PIIC Data Request 41, specifically Confidential Attachment PIIC 41. Recordholder: Ernie Knudsen Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power November 1, 2024 PIIC Data Request 47 PIIC Data Request 47 Please identify each entity, which serves retail load in PacifiCorp's East and/or West Balancing Authority Area, and state the balancing authority area where the entity's retail loads are served. Response to PIIC Data Request 47 Please refer to Confidential Attachment PIIC 47. Note: the information provided identifies only the retail load serving entities (LSE) that PacifiCorp transmission function's network and transmission system and operating agreements customers provide service to under their agreements. 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: Veronica Whitesmith Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power November 4, 2024 PIIC Data Request 48 PIIC Data Request 48 For each entity which serves retail load in PacifiCorp's East and/or West Balancing Authority Area,please provide the hourly loads of such entities' loads for calendar year 2023. Response to PIIC Data Request 48 Please refer to Confidential Attachment PIIC 48 which provides third-party hourly loads in the PacifiCorp East(PACE) balancing authority area (BAA) and the PacifiCorp West(PACW)BAA. 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: Ernie Knudsen Sponsor: To Be Determined