20240605PAC to Staff 1-15.pdf

RECEIVED
2024 June 5, 5:OOPM
IDAHO PUBLIC
_ ROCKY MOUNTAIN UTILITIES COMMISSION
POWER
A DIVISION OF FACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
June 5, 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-24-06
IPUC Set 1 (1-15)
Please find enclosed Rocky Mountain Power's Responses to IPUC 1st Set Data Requests 1-15.
Also provided is Attachment IPUC 1. Provided via BOX are Confidential Response IPUC 6, 7,
9, and I I and Confidential Attachment IPUC 6. 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-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 1
IPUC Data Request 1
The Application and Confidential Exhibit No. 2 provides multiple maps with
differing boundaries for the identified "Blocks".
(a) Please provide maps with legal descriptions showing the location(s) of the
parcel(s) within each Block that are proposed to be transferred.
(b) Please reconcile Block 3's boundaries from Application Figure 2 and
Confidential Transfer Agreement Exhibit A-2.
(c) Please reconcile Block 4's boundaries from Application Figure 2 and
Confidential Transfer Agreement Exhibit A-4.
Response to IPUC Data Request 1
(a) Please refer to Attachment IPUC 1 which provides the following legal block
descriptions and an accompanying updated map:
• SLC RMP—Block IA.pdf
• SLC RMP—Block 1B.pdf
• SLC RMP—Block 2.pdf
• SLC RMP—Block 3.pdf
• SLC RMP—Block 4.pdf
• SLC LHM Exhibit 032924.pdf
(b) The maps in the application and in Confidential Exhibit No. 2 are general
depictions. The formalized boundaries and legal descriptions are provided in
Attachment IPUC 1. In addition, please refer to the following regarding
discrepancies between the Company's Application and Confidential Exhibit
No. 2:
• Block 3 in the Application does not include the rail spur and South
Temple ends at Block 1 a.
• In Confidential Exhibit No. 2, the rail spur is included and all of South
Temple is included.
(c) The maps in the Company's Application and in Confidential Exhibit No. 2 are
general depictions. The formalized boundaries and legal descriptions are
provided in Attachment IPUC 1. In addition, please refer to the following
regarding discrepancies between the Company's Application and Confidential
Exhibit No. 2:

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 1
• Block 4 in the Application does not include the future substation area
versus Confidential Exhibit No. 2 that includes the future substation area.
Recordholder: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 2
IPUC Data Request 2
While reviewing the Blocks' as described and shown in the Application, it
appears that there may be discrepancies between the Company-provided
information and the Salt Lake County Assessors map. Please reconcile all
parcel(s) located within each Block with the Salt Lake County Assessors map.
Response to IPUC Data Request 2
The parcel discrepancies between the Salt Lake County Assessors map and the
proposed development Blocks in Confidential Exhibit No. 2 are due to the site
development master plan which has not yet been fully approved by the Company,
LHM DEV E and Salt Lake City. The Blocks do not correspond to the current
parcel lines—this issue will be resolved prior to each Closing. The existing
parcels as shown in the Salt Lake County Assessors map will be updated over
time with the new development as per the site development master plan and actual
construction.
Recordholder: Mike Jenson
Sponsor: To Be Determined
' Reviewed the Blocks via 1)https:Hslco.org/assessor/(last visited May 8,2024);and 2)
https:Hslco.org/assessor/new/ParcelViewer/index.html?query=Parcel_Viewer_extemal_3 634_5.parcel_id
(last visited May 8,2024).

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 3
IPUC Data Request 3
The Company's Application describes how the Company intends to construct a
new headquarters (New HQ)and potentially a new Energy Services Building
(New ESB). Application at 7. Please explain where existing Company offices,
shops, and workspaces will be temporarily relocated. Confidential Transfer
Agreement (10)(c)(b). Please include how uninterrupted regulatory function, grid
operation, operational oversight, and the continuation of providing fair, safe, and
reliable services for Idaho customers will be maintained during and after
relocation.
Response to IPUC Data Request 3
Temporary relocation is not required. The Company will continue to use existing
facilities during construction of the New Headquarters (HQ) and New Energy
Services Building (ESB).
Recordholder: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 4
IPUC Data Request 4
Please provide supporting Excel worksheets that detail the estimated construction
costs of the New HQ and New ESB. Please include the estimated temporary and
final relocation costs, as well as any additional costs associated with maintaining
uninterrupted facility functions.
Response to IPUC Data Request 4
PacifiCorp objects to this data request to the extent it seeks information that is not
relevant, and the request is not reasonably calculated to lead to the discovery of
admissible evidence. Subject to and without waiving the foregoing objection, the
Company responds as follows:
The Company is in the design process and preparation of construction documents
for the New Headquarter(HQ) and New Energy Services Building (ESB) and
does not currently possess estimated construction costs. The Company's
Application in this proceeding does not seek regulatory approval of any proposed
capital project and only seeks approval for the transfer of property under Idaho
Code 61-328. The regulatory treatment of any costs associated with the New HQ
and New ESB will be included in future general rate cases.
Recordholder: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 5
IPUC Data Request 5
Please explain how the funds identified in the Confidential Exhibit J
"Impairment Cost Schedule"that have already been released will be allocated to
Idaho customers. Please also explain if these funds are now controlled by the
Company, and if so, please provide the associated journal entries.
Response to IPUC Data Request 5
As of May 22, 2024, the Company has received Impairment Cost Schedule funds
of$1,901,100 and a Pause Fee of$1,200,000. Funds have been applied to FERC
Account 107 (construction work in progress-electric) to offset costs which were
previously recorded to FERC Account 107 which are now impaired. All funds
received from the Impairment Cost Schedule will offset costs recorded in FERC
Account 107.
Recordholder: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 6
IPUC Data Request 6
CONFIDENTIAL RE UEST -Please provide sup-portingdocumentation of the
including cost estimates for the environmental
remediation, etc.
Confidential Response to IPUC Data Request 6
The Company completed a risk assessment and cost estimate for potential
environmental remediation in July 2023. Please refer to Confidential Attachment
IPUC 6 which provides a copy of Power District Environmental Risks By Area.
iabow*
ts the estimated remediation costs ranged
DE E conducted a similar assessment and the
parties both the Company and LHM DEV E agreed to a deduction of
from
the purchase price.
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: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 7
IPUC Data Request 7
i
FIDENTIAL RE UEST -Please ex lain the need for the
Response to IPUC Data Request 7
The Success Fee provides a potential positive sales price adjustment if conditions
described in the Master Development Agreement(MDA) are met related to LHM
DEV E development success related to Major League Baseball (MLB) and if the
Company makes certain property available within agreed upon timelines.
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: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 8
IPUC Data Request 8
Please provide the MDA. If not yet negotiated, please provide a projected date for
its execution and provide a copy as a supplemental filing when completed.
Response to IPUC Data Request 8
The Master Development Agreement(MDA) is in the process of negotiation. It is
currently anticipated that the MDA will be finalized in June 2024. The Company
will supplement this response once the MDA is finalized.
Recordholder: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 9
IPUC Data Request 9
CONFIDENTIAL REQUEST -The Company's Application provides a timeline
for property purchases from March 1, 2024, through December 31 2039.
However in Confidential Exhibit No. 2 8 e at 13
P ease reconciFtl
e1111111111116
erenceetween
purchase option dates in the timeline and Confidential Exhibit No. 2 (8)(e).
Confidential Response to IPUC Data Request 9
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: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 10
IPUC Data Request 10
Please provide the proposed accounting treatment for any relocation and/or
transmission upgrade costs associated with the asset transfer.
Response to IPUC Data Request 10
PacifiCorp objects to this request to the extent it is vague and ambiguous as to the
phrase "relocation and/or transmission upgrade costs." Subject to and without
waiving the foregoing objection, the Company responds as follows:
In this proceeding, the Company has proposed the approval of accounting order
that would authorize the recording of a regulatory liability for any net proceeds
arising from the Transfer Agreement. Any costs necessary for the asset transfer
would reduce the net proceeds recorded.
Please refer to the Company's response to IPUC Data Request 3 for more
information pertaining to temporary relocation.
Recordholder: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request I I
IPUC Data Request 11
CONFIDENTIAL REQUEST -The Master Plan includes a re uirement for the
Develo er and the Com an to include
Con i entia Ex i it No. 2 8 viii) at
14. Please explain why the agreement includes plan and design for property
outside of the described Blocks in the Application.
Response to IPUC Data Request 11
Inasmuch as the river is an important part of the full site development experience,
LHM DEV E also acquired property east of the Company's property and will
combine those parcels into one cohesive master plan with the river experience
being a focus. Note: LHM DEV E also acquired property to the west of the
Company's property. There will not be a separate master plan for the Company
property that does not also include LHM DEV E's additionally acquired property
on the Company's east and west flanks.
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: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 12
IPUC Data Request 12
Please provide the timeline for the New HQ and ESP projects.
Response to IPUC Data Request 12
PacifiCorp objects to this data request on the grounds that it seeks information that
is not relevant and the request is not reasonably calculated to lead to the discovery
of admissible evidence. Subject to and without waiving the foregoing objection,
the Company responds as follows:
The Company assumes that the reference to "ESP"is intended to be a reference to
the energy services building (ESB) project. Based on the foregoing assumption,
the Company responds as follows:
The timeline for the New Headquarters (HQ) and ESB projects will be agreed
upon in the Master Development Agreement(MDA). The Company will
supplement this response after the MDA has been executed. The Company's
Application in this proceeding does not seek regulatory approval of any proposed
capital project and only seeks approval for the transfer of property under Idaho
Code 61-328. The regulatory treatment of any costs associated with the New HQ
and New ESB will be included in future general rate cases (GRC).
Recordholder: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 13
IPUC Data Request 13
Please provide documentation for the approved financing or how the New HQ and
ESP projects are being funded.
Response to IPUC Data Request 13
PacifiCorp objects to this data request on the grounds that it seeks information that
is not relevant and the request is not reasonably calculated to lead to the discovery
of admissible evidence. Subject to and without waiving the foregoing objection, the
Company responds as follows:
The Company assumes that the reference to "ESP"is intended to be a reference to
the energy services building (ESB) project. Based on the foregoing assumption,
the Company responds as follows:
The Company is still exploring financing options and has not made a final
determination. The Company's Application in this proceeding does not seek
regulatory approval of any proposed capital project and only seeks approval for
the transfer of property under Idaho Code 61-328. The regulatory treatment of any
costs associated with the New HQ and New ESB will be included in future
general rate cases.
Recordholder: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 14
IPUC Data Request 14
Please provide an update to the Feasibility Period. The Developer had until April
30, 2024, to confirm if they will proceed with this transaction or terminate this
agreement.
Response to IPUC Data Request 14
The Developer has paid the Feasibility Period activity from the Impairment Cost
Schedule. The parties are still negotiating final terms of the Master Development
Agreement (MDA).
Recordholder: Mike Jenson
Sponsor: To Be Determined

PAC-E-24-06/Rocky Mountain Power
June 5, 2024
IPUC Data Request 15
IPUC Data Request 15
Please provide the accounting treatment and journal entries for the
following: Please include any spreadsheets with formulas intact and enabled.
(a) The removal of these real property assets from the Company's books.
(b) Any other journal entries necessary to complete the transaction.
Response to IPUC Data Request 15
(a) Please refer to the table provided below:
Debit Credit
Proposed Regulatory Account as described in $714,000
the Transfer Agreement
FERC 101-Electric Plant In Service $(714,000)
(b) There are no other journal entries necessary as it pertains to the removal of the
real property assets from the Company's books.
Recordholder: Mike Jenson
Sponsor: To Be Determined