20230825PAC to Staff 1 Supplemental.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
August 25, 2023 Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C) RE: ID PAC-E-23-10
IPUC Set 1 (1-10) Please find enclosed Rocky Mountain Power’s 1st Supplemental Response to IPUC 1st Set Data Request 1. Provided via BOX is Confidential Attachment IPUC 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 protective agreement executed in this proceeding. If you have any questions, please feel free to call me at [phone]. Sincerely, ____/s/____
Mark Alder
Manager, Regulation Enclosures
RECEIVED
2023 AUGUST 25, 2023 3:28PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-10 / Rocky Mountain Power August 25, 2023 IPUC Data Request 1 – 1st Supplemental
IPUC Data Request 1 Please provide avoided cost work papers for each energy efficiency and demand response program and measure in Excel format with formulas
enabled and intact.
1st Supplemental Response to IPUC Data Request 1
Further to the Company’s response to IPUC Data Request 1 dated July 5, 2023,
the Company provides the following additional information: The Company continues to assume that this request relates to PacifiCorp’s 2023 Integrated Resource Plan (IRP), filed with the Idaho Public Utilities Commission (IPUC) on May 31, 2023, and therefore the avoided cost work papers for each
energy efficiency (EE) and demand response (DR) program and measure
considered and included in PacifiCorp’s 2023 IRP. Based on the foregoing assumptions, the Company responds as follows:
The Company has now prepared the work paper used to evaluate energy
efficiency (EE) and demand response (DR) programs and measures based on the results of the 2023 IRP. Please refer to Confidential Attachment IPUC 1 1st Supplemental which now provides the requested 2023 IRP demand-side management (DSM) avoided 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: Peter Schaffer Sponsor: Thomas R. Burns

1
Joe Dallas (ISB# 1033) 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
IN THE MATTER OF PACIFICORP’S APPLICATION FOR ACKNOWLEDGEMENT OF THE 2023 INTEGRATED RESOURCE PLAN

-E-23-10

I, Joe Dallas , represent Rocky Mountain Power in the above captioned matter. I am an
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 that the Company’s first supplemental response to IPUC data request 1 contains Company
proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned response contains
confidential in that the information contains Company proprietary information.
2
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 25th day of August, 2023.

Respectfully submitted,

By__________________________
Joe Dallas Senior Attorney Rocky Mountain Power