20240711Staff 1-15 to PAC.pdf

RECEIVED
Thursday, July 11, 2024 9:56:28 AM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER REQUEST ) CASE NO. PAC-E-24-09
FOR APPROVAL OF THE 2024 IDAHO )
WILDFIRE MITIGATION PLAN )
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Rocky Mountain Power("Company")
provide the following documents and information as soon as possible, but no later than
THURSDAY,AUGUST 1, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 11, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please explain how jurisdictional allocations are considered and
displayed within the Wildfire Mitigation Plan("WMP"). If jurisdictional allocations are not
considered and displayed within the WMP, please explain why not.
REQUEST NO. 2: Page 18 of the WMP states that there are not any Fire High
Consequence Areas ("FHCA") in Idaho; however, in the section"Areas of Interest" ("AOI") on
page 19 in Figure 11: 2024 Areas of Interest, there are multiple Interest 1 areas identified in red.
Please explain the difference between FHCA and AOI 1.
REQUEST NO. 3: Please provide a table of each Idaho program category for both
capital and operational and maintenance expenses for 2023 through 2026 similar to the
Company's 2024 Oregon WMP - Table Nos. 37 and 38. For 2023,please provide the actual cost
of each program category.
REQUEST NO. 4: Please describe any occurrences where the Company undergrounded
any transmission lines and/or Idaho distribution lines for wildfire mitigation. If any,please
provide a supporting worksheet detailing the cost, date in service and location(within or outside
an AOI).
REQUEST NO. 5: Page 27 of the WMP describes the drone inspections performed by
Unmanned Aerial Vehicles ("UAVs"). Please provide the annual expenses of this program and
explain how often the Company utilizes the drones and any benefits provided by the use of
UAVs.
REQUEST NO. 6: Please provide the annual cost of doing full post-work audits on the
distribution cycle and correction work of the annual vegetation management program. WMP at
30.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 11, 2024

REQUEST NO. 7: As part of the Company's system hardening, the Company mentions
covered conductor may be used for wildfire mitigation. WMP at 34. Please provide a
spreadsheet with the locations covered conductor has been installed, the actual cost, and the total
miles installed. Please also provide any cost-benefit analysis completed prior to installation.
REQUEST NO. 8: "Currently, Rocky Mountain Power is continuing to evaluate the use
of underground design as part of the rebuild program on a project-by-project basis; and it uses
under-grounding where practical." WMP at 35. Please provide the criteria the Company follows
when choosing to convert overhead lines to underground lines. Additionally,please provide a
list of any completed or planned projects, locations, costs, dates, and any cost-benefit analysis
completed.
REQUEST NO. 9: "...Rocky Mountain Power may install communicating fault
indicators across the Idaho service territory on where [Elevated Fire Risk] settings are most
likely to be implemented." WMP at 37. Please explain the criteria the Company follows to
install fault indicators. Additionally, please provide additional information on fault indicators
and the criteria the Company will use to determine whether to install fault indicators.
REQUEST NO. 10: Please provide the annual meteorology department costs and
explain the benefits of a Company-owned meteorology department. WMP at 39. Also,please
provide any other sources that could provide the same information and the associated cost.
REQUEST NO. 11: Page 41 describes how the Company is planning to implement a
multi-member Wildfire Research and Forecasting ("WRF") ensemble forecasting system. Please
provide the annual Idaho cost of the WRF ensemble and explain any benefits of the system.
REQUEST NO. 12: Page 60 of the WMP states the Company is considering Starlink
devices in addition to the Cell-On-Wheels ("COW"). Please explain how many COWS the
Company has for Idaho and provide the annual costs. Also,please provide the annual cost of
Starlink, how Starlink would be used with COW, and any anticipated benefits.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 11, 2024

REQUEST NO. 13: Please explain why the annual costs of$1.05 million for the Public
Safety Power Shutoff("PSPS")program are the same each year from 2024 through 2026.
REQUEST NO. 14: Page 68 of the WMP describes Community Resource Centers
("CRCs") for customers impacted by PSPS events. Please explain the costs to activate the CRCs
and explain if there is cost sharing with public safety partners.
REQUEST NO. 15: Page 85 of the WMP states, "...[the Company] is actively
exploring whether to implement a backup power rebate program." Please provide more
information on this potential program and any expected benefits. Additionally, please explain if
the Company has similar programs in other states.
DATED at Boise, Idaho, this I Ph day of July 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-09 PR#l.docx
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 11, 2024

CERTIFICATE OF SERVICE
11
I HEREBY CERTIFY THAT I HAVE THIS 1 h
�DAY OF JULY 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
09, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL: mark.alderApacificorp.com PORTLAND OR 97232
E-MAIL: joseph.dallaskpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequestkpacificorp.com
;ZlY—'o I
PA ILIA JORDA , SECRETARY
CERTIFICATE OF SERVICE