20240719Staff 58-81 to PAC.pdf

RECEIVED
Friday, July 19, 2024 11:16:54 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 FOR ) CASE NO. PAC-E-24-04
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES IN IDAHO AND APPROVAL ) FIFTH PRODUCTION
OF PROPOSED ELECTRIC SERVICE ) REQUEST OF THE
SCHEDULES AND REGULATIONS ) 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 PacifiCorp d/b/a Rocky Mountain Power
("Rocky Mountain Power" or the "Company")provide the following documents and information
as soon as possible,but no later than FRIDAY,AUGUST 9, 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.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 19, 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. 58: Please provide the following information for the Jim Bridger—U1
Conversion to Natural Gas project referenced on Page 8.5.3 Exhibit No. 48 of McCoy's
Testimony. Please include any available workpapers with formulas intact. If any of the
information requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a) Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c) If a Request for Proposal ("RFP") or Request for Quote ("RFQ") was submitted,
please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Initial Project Plan including the following:
i) Initial project scope;
ii) Initial project budget;
iii) Initial proposed schedule; and
iv) Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e) Please provide the following for the Baseline Construction Project:
i) Baseline project scope;
ii) Baseline project budget broken down by Work-Breakdown Structure
("WBS");
iii) Baseline project schedule broken down by WBS;
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 19, 2024

iv) If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
v) Project status reports and action items; and
vi) Contractor change orders.
f) Please provide the following related to completion of the project:
i) Baseline construction budget-to-actual comparison by WBS and by year;
ii) Baseline construction schedule-to-actual comparison by WBS;
iii) For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv) Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 59: Please provide the following information for the Jim Bridger— U2
Conversion to Natural Gas project referenced on Page 8.5.3 Exhibit No. 48 of McCoy's
Testimony. Please include any available workpapers with formulas intact. If any of the
information requested below cannot be provided or is not available,please explain why it is not
available or cannot be provided.
a) Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Initial Project Plan including the following:
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 19, 2024

i) Initial project scope;
ii) Initial project budget;
iii) Initial proposed schedule; and
iv) Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e) Please provide the following for the Baseline Construction Project:
i) Baseline project scope;
ii) Baseline project budget broken down by WBS;
iii) Baseline project schedule broken down by WBS;
iv) If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
v) Project status reports and action items; and
vi) Contractor change orders.
f) Please provide the following related to completion of the project:
i) Baseline construction budget-to-actual comparison by WBS and by year;
ii) Baseline construction schedule-to-actual comparison by WBS;
iii) For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv) Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 60: Please provide the following information for the ILR 11.2.2.12
Beaver Bay PH 1 Renovation project referenced on Page 8.5.3 Exhibit No. 48 of McCoy's
Testimony. Please include any available workpapers with formulas intact. If any of the
information requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a) Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 19, 2024

b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Initial Project Plan including the
i) Initial project scope;
ii) Initial project budget;
iii) Initial proposed schedule; and
iv) Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e) Please provide the following for the Baseline Construction Project:
i) Baseline project scope;
ii) Baseline project budget broken down WBS;
iii) Baseline project schedule broken down by WBS;
iv) If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
v) Project status reports and action items; and
vi) Contractor change orders.
f) Please provide the following related to completion of the project:
i) Baseline construction budget-to-actual comparison by WBS and by year;
ii) Baseline construction schedule-to-actual comparison by WBS;
iii) For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JULY 19, 2024

iv) Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 61: Please provide the following information for the Swift 1 Spillway
Gate Bulkhead project referenced on Page 8.5.3 Exhibit No. 48 of McCoy's Testimony.
Please include any available workpapers with formulas intact. If any of the information
requested below cannot be provided or is not available,please explain why it is not available or
cannot be provided.
a) Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Initial Project Plan including the following:
i) Initial project scope;
ii) Initial project budget;
iii) Initial proposed schedule; and
iv) Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e) Please provide the following for the Baseline Construction Project:
i) Baseline project scope;
ii) Baseline project budget broken down by WBS;
iii) Baseline project schedule broken down by WBS;
iv) If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 JULY 19, 2024

for the change, and provide evidence that the changes were approved at the
appropriate level;
v) Project status reports and action items; and
vi) Contractor change orders.
f) Please provide the following related to completion of the project:
i) Baseline construction budget-to-actual comparison by WBS and by year;
ii) Baseline construction schedule-to-actual comparison by WBS;
iii) For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv) Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 62: Please provide the following information for the ILR 4.5 Yale
Downstream Fish Passage project referenced on Page 8.5.3 Exhibit No. 48 of McCoy's
Testimony. Please include any available workpapers with formulas intact. If any of the
information requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a) Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Initial Project Plan including the following:
i) Initial project scope;
ii) Initial project budget;
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 JULY 19, 2024

iii) Initial proposed schedule; and
iv) Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e) Please provide the following for the Baseline Construction Project:
i) Baseline project scope;
ii) Baseline project budget broken down by WBS;
iii) Baseline project schedule broken down by WBS;
iv) If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
v) Project status reports and action items; and
vi) Contractor change orders.
f) Please provide the following related to completion of the project:
i) Baseline construction budget-to-actual comparison by WBS and by year;
ii) Baseline construction schedule-to-actual comparison by WBS;
iii) For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv) Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 63: Please provide the following information for the Toketee 2
Turbine Refurbishment project referenced on Page 8.5.3 Exhibit No. 48 of McCoy's
Testimony. Please include any available workpapers with formulas intact. If any of the
information requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a) Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 JULY 19, 2024

c) If a RFP or RFQ was submitted,please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Initial Project Plan including the following:
i) Initial project scope;
ii) Initial project budget;
iii) Initial proposed schedule; and
iv) Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e) Please provide the following for the Baseline Construction Project Plan:
i) Baseline project scope;
ii) Baseline project budget broken down by WBS;
iii) Baseline project schedule broken down by WBS;
iv) If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
v) Project status reports and action items; and
vi) Contractor change orders.
f) Please provide the following related to completion of the project:
i) Baseline construction budget-to-actual comparison by WBS and by year;
ii) Baseline construction schedule-to-actual comparison by WBS;
iii) For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv) Please explain any slips in schedule from the baseline construction schedule.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 9 JULY 19, 2024

REQUEST NO. 64: Please provide the following information for the Cutler
Relicensing project referenced on Page 8.5.3 Exhibit No. 48 of McCoy's Testimony. Please
include any available workpapers with formulas intact. If any of the information requested
below cannot be provided or is not available,please explain why it is not available or cannot be
provided.
a) Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Initial Project Plan including the following:
i) Initial project scope;
ii) Initial project budget;
iii) Initial proposed schedule; and
iv) Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e) Please provide the following for the Baseline Construction Project Plan:
i) Baseline project scope;
ii) Baseline project budget broken down by WBS;
iii) Baseline project schedule broken down by WBS;
iv) If the baseline construction project scope, budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
v) Project status reports and action items; and
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 10 JULY 19, 2024

vi) Contractor change orders.
f) Please provide the following related to completion of the project:
i) Baseline construction budget-to-actual comparison by WBS and by year;
ii) Baseline construction schedule-to-actual comparison by WBS;
iii) For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv) Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 65: Please provide the following information for the IKL-Fall Creek
Hatchery project referenced on Page 8.5.3 Exhibit No. 48 of McCoy's Testimony. Please
include any available workpapers with formulas intact. If any of the information requested
below cannot be provided or is not available,please explain why it is not available or cannot be
provided.
a) Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Initial Project Plan including the following:
i) Initial project scope;
ii) Initial project budget;
iii) Initial proposed schedule; and
iv) Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 11 JULY 19, 2024

e) Please provide the following for the Baseline Construction Project Plan:
i) Baseline project scope;
ii) Baseline project budget broken down by WBS;
iii) Baseline project schedule broken down by WBS;
iv) If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
v) Project status reports and action items; and
vi) Contractor change orders.
f) Please provide the following related to completion of the project:
i) Baseline construction budget-to-actual comparison by WBS and by year;
ii) Baseline construction schedule-to-actual comparison by WBS;
iii) For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv) Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 66: Please provide a table of each Idaho program category for both
capital and operational and maintenance ("O&M") expenses for 2023 through 2024 similar to the
Company's 2024 Oregon Wildfire Mitigation Plan("WMP") - Table Nos. 37 and 38. For 2023
and 2024, please provide the actual cost of each program category. Please identify any proforma
adjustments for 2024.
REQUEST NO. 67: Please provide the total amount of capital and O&M associated
with wildfire mitigation the Company is seeking recovery in this rate case. Please identify where
the Company has included these expenses in the rate case.
a) Additionally,please explain how jurisdictional allocations are considered and
displayed within the Idaho allocated capital and O&M wildfire expenses in this rate
case.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 12 JULY 19, 2024

REQUEST NO. 68: Please provide all funding sources that the Company has explored
and received for its wildfire mitigation projects since the last rate case. Please provide
supporting documentation including applications, funding award notifications, disbursement, and
demonstrate where funds were applied to in this rate case.
REQUEST NO. 69: Please provide a brief description of any order or laws the
Company is required to comply with in relation to its WMP for any state the Company operates
in. Please include an estimate of all costs required for compliance and explain how those costs
are allocated.
REQUEST NO. 70: Please provide the Company's process guidelines and all least-cost,
least-risk analysis used to evaluate each of the wildfire mitigation projects.
REQUEST NO. 71: Please describe any occurrences where the Company
undergrounded any transmission and/or Idaho distribution lines for wildfire mitigation since the
last rate case. Please answer the following:
a) Please provide the Company's undergrounding project guidelines;
b) Please explain the location selection process for undergrounding; and
c) For any completed undergrounding project,please provide a supporting worksheet
detailing the initial budget, the actual cost, project start date, date in-service, location,
and a cost-benefit analysis.
REQUEST NO. 72: As part of the Company's system hardening, the Company
mentions covered conductor may be used for wildfire mitigation. WMP at 34. Please answer the
following:
a) Please provide the Company's covered conductor project guidelines;
b) Please explain the location selection process for installing covered conductor; and
c) For any completed covered conductor projects, please explain the need, location
installed(inside or outside of an Idaho Area of Interest("AOI")), the need, the actual
cost, the total miles installed, and any cost-benefit analysis completed prior to
installation.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 13 JULY 19, 2024

REQUEST NO. 73: Page 36 of the Company's WMP states that the Company may
replace poles with non-wooden alternatives such as steel and fiberglass. Please provide the
number of steel and fiberglass poles that were installed for wildfire mitigation by year since the
Company's last GRC.
a) For each of the replacement projects, please explain the need, location(inside or
outside of an Idaho AOI), the initial budget, the actual cost, the total number of steel
poles installed, the total number of fiberglass poles installed, and any cost-benefit
analysis completed.
REQUEST NO. 74: Page 60 of the WMP states the Company procured Cell-On-Wheels
("COW") for wildfire mitigation. Please provide how many COWs the Company has for Idaho
and provide the annual costs.
REQUEST NO. 75: Please explain if there is cost sharing with public safety partners
for any of the Company's wildfire mitigation programs. If so, please provide a list with which
program,partners, the amount shared, and cost sharing percentages.
REQUEST NO. 76: Company Witness Steward describes the Public Safety Partner
Portal. Steward Direct at 21. Please explain the function of the Public Safety Partner Portal,
total annual capital and O&M expenses, Idaho allocated capital and O&M expenses, and any
expected benefits. Additionally,please answer the following:
a) Please provide a detailed explanation for the need of the project, including the
analysis justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 14 JULY 19, 2024

iv) A copy of the winning bid.
REQUEST NO. 77: Company Witness Steward describes the Company's expanded
situational awareness through installation of new weather stations. Steward Direct at 21. Please
answer the following:
a) Please explain how many weather stations the Company installed since the last rate
case; and
b) For each of the weather stations, please explain the need, location(inside or outside
of an Idaho AOI),budget, actual cost, and any cost-benefit analysis completed.
REQUEST NO. 78: Company Witness Steward describes the Company's expanded
situational awareness through new risk modeling tools, datasets and software. Steward Direct at
21. Please provide the annual capital and O&M cost of each of the new investments and Idaho
allocation of those costs. Additionally, please provide the following:
a) Please provide a detailed explanation for the need of the project, including the
analysis justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
REQUEST NO. 79: In the Company's Response to Production Request No. 15 —
Attachment, "Field Ai-Field Asset Intelligence"has a total cost of$20,563,043. Please explain
if that cost is Idaho allocated and at what percentage. If not,please provide Idaho allocated
expenses. Additionally, please answer the following:
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 15 JULY 19, 2024

a) Please provide a detailed explanation for the need of the project, including the
analysis justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Project Plan including the:
i) Initial and Actual project scope;
ii) Initial project budget;
iii) Actual project cost;
iv) Initial and Actual schedule;
v) Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
vi) Please explain any differences in budget to actual project costs; and
vii) Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 80: In the Company's Response to Production Request No. 15 —
Attachment, "Snyderville-Park Cty 46kV Rbld for Wldfr"has a total cost of$14,095,831.
Please explain if that cost is Idaho allocated and at what percentage. If not, please provide Idaho
allocated expenses. Additionally,please answer the following:
a) Please provide a detailed explanation for the need of the project, including the
analysis justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 16 JULY 19, 2024

i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Project Plan including the following:
i) Initial and Actual project scope;
ii) Initial project budget;
iii) Actual project cost;
iv) Initial and Actual proposed schedule;
v) Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
vi) Please explain any differences in budget to actual project costs; and
vii) Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 81: In the Company's Response to Production Request No. 15 —
Attachment, "Columbia- Coal Creek Wildfire Rplcmts"has a total cost of$10,659,021. Please
explain if that cost is Idaho allocated and at what percentage. If not,please provide Idaho
allocated expenses. Additionally,please answer the following:
a) Please provide a detailed explanation for the need of the project, including the
analysis justifying the need.
b) Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c) If a RFP or RFQ was submitted, please provide the following:
i) A copy of the RFP or RFQ that was submitted;
ii) A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii) The short-list bidder scorecard; and
iv) A copy of the winning bid.
d) Please provide the approved Project Plan including the following:
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 17 JULY 19, 2024

i) Initial and Actual project scope;
ii) Initial project budget;
iii) Actual project cost;
iv) Initial and Actual schedule;
v) Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
vi) Please explain any differences in budget to actual project costs; and
vii) Please explain any slips in schedule from the baseline construction schedule.
DATED at Boise, Idaho, this 19th day of July 2024.
U
.i�
Adam Triplett
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR#5.docx
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 18 JULY 19, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS . DAY OF JULY 2024,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
04, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER CARLA SCARSELLA
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 825 NE Multnomah, Suite 2000
E-MAIL: mark.alderamacificorp.com Portland, OR 97232
E-MAIL: joseph.dallas(a�pacificorp.com
[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance@ae isg insi t.com
E-MAIL: elo(a,echohawk.com
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.n kiel(&gmail.com E-MAIL:
heusinkvelda,,idahoconservation.org
THOMAS J BUDGE BRIAN C COLILINS
RACINE OLSON PLLP GREG MEYER
PO BOX 1391 BRUBAKER&ASSOCIATES
POCATELLO ID 83204-1391 16690 SWINGLEY RIDGE RD #140
E-MAIL: [e-mail] CHESTERFIELD MO 63017
E-MAIL: [e-mail]
gmeyer(&consultbai.com
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KEVIN HIGGINS BRANDON HELGESON
NEAL TOWNSEND HAWLEY TROXELL ET AL
ENERGY STRATEGIES LLC 877 W MAIN ST
E-MAIL: khiggins@en�strat.com BOISE ID 83701
[e-mail] E-MAIL: rwilliamskhawleytroxell.com
bhel eg son(a)hawleytroxell.com
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Electronic Service Only: Electronic Service Only:
BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITAFOS CONDA LLC
E-MAIL: brmullins&mwanal ics.com E-MAIL: Val.steiner(a itafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamskkb ui.edu
PATRICIA JORDAN, SECRETARY
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