20240723Staff 119-129 to PAC.pdf

RECEIVED
Tuesday, July 23, 2024 11.30.39 AM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
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 ) SEVENTH 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 TUESDAY, AUGUST 13, 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.
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 23, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulae intact and enabled.
REQUEST NO. 119: Company witness Steward details the proposed Catastrophic Fire
Fund with an annual Idaho contribution of$11.1 million. Steward Direct at 49. Please provide
the supporting workpapers that detail the allocation of contributions over the 10-year period.
Additionally,please provide justification of the Company's initial target level of$3 billion.
REQUEST NO. 120: If the Company completed a cost-benefit analysis for the
Company's proposed Catastrophic Fire Fund, please provide a copy of the cost-benefit analysis.
REQUEST NO. 121: Please provide the non-economic liability limitations in each of
the states the Company operates in. Please explain how the Company's allocation of
Catastrophic Fire Fund expenses incorporates the non-economic liability limitations of each
state.
REQUEST NO. 122: Table 8 in Company witness Steward's testimony estimated 2025
Idaho allocated insurance premiums to be $9.8 million. Steward Direct at 58. Please provide
supporting documentation of the Company's new liability insurance premiums for the 2024-25
policy year when available.
a. Additionally,please explain if the Company's proposed insurance rider is expected to
adjust on an annual basis.
REQUEST NO. 123: Please provide the following documentation for the"Field Ai-
Field Asset Intelligence"project referenced in Production Request No. 15 —Attachment and the
"Field Ai-Field Asset Intelligence- GWD"projects referenced by Shelley E. McCoy in
Workpaper 8.5.3 —Major Plant Additions. 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. If these projects are different, please explain the difference between the two projects.
b. Please explain the large discrepancy between the cost in Production Request and
Workpaper.
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 23, 2024

c. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
d. 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.
e. If a Request for Proposal ("RFP") or Request for Quote ("RFQ") was submitted,
please provide the following information:
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.
f. 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 the Initial Project Plan and budget were approved at the appropriate
level.
g. Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by Work-Breakdown Structure ("WBS");
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated from
the Initial Project Plan, please explain the differences, 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.
h. 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;
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 23, 2024

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 deviations in schedule from the baseline construction schedule.
REQUEST NO. 124: Please provide the following documentation for the "Palantir
Foundry"project referenced in response to Production Request No. 15 and by Shelley E. McCoy
in Workpaper 8.5.3 —Major Plant Additions. 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 information:
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 the Initial Project Plan and budget were approved at the appropriate
level.
e. Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by the WBS;
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 23, 2024

iv. If the baseline construction project scope,budget, and/or schedule deviated from
the Initial Project Plan, please explain the differences, 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 deviations in schedule from the baseline construction schedule.
REQUEST NO. 125: Please provide the following documentation for the "Eng
Telecom: OTLM - TI project" and the "OT Lease Modernization - TI Circuits"referenced by
Shelley E. McCoy in Workpaper 8.5.3 —Major Plant Additions. 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 explain the difference between the two projects.
b. Please provide a detailed explanation for the need of the projects including the
analysis justifying the need.
c. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the projects were selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
d. If a RFP or RFQ was submitted, please provide the following information:
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.
e. Please provide the approved Initial Project Plan including the following:
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JULY 23, 2024

i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence the Initial Project Plan and budget were approved at the appropriate
level.
f. Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated from
the Initial Project Plan, please explain the differences, 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.
g. 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 deviations in schedule from the baseline construction schedule.
REQUEST NO. 126: Please provide the following documentation for the "PAC FIPS
201 Pinnacle Repl"project referenced by Shelley E. McCoy in Workpaper 8.5.3 —Major Plant
Additions. 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 explain why the PAC FIPS 201 Pinnacle Repl project was not included in the
Company's response to Production Request No. 15.
b. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 JULY 23, 2024

c. 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.
d. If a RFP or RFQ was submitted, please provide the following information:
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.
e. 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 the Initial Project Plan and budget were approved at the appropriate
level.
f. Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by the 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.
g. 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
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 JULY 23, 2024

iv. Please explain any deviations in schedule from the baseline construction schedule.
REQUEST NO. 427: Please provide the following documentation for the PacifiCorp
Accelerated RTU Repl (PARR)project referenced in Production Request No. 15 —Attachment.
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 explain why the PARR project was not included in the Company's response to
Production Request No. 15.
b. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
c. 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.
d. If a RFP or RFQ was submitted, please provide the following information:
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.
e. 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 the Initial Project Plan and budget were approved at the appropriate
level.
f. Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by the 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
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 JULY 23, 2024

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.
g. 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 deviations in schedule from the baseline construction schedule.
REQUEST NO. 128: How does the Company rate contractors based on past
experience?
REQUEST NO. 129: Please provide the Company's criteria for rating contractors.
DATED at Boise, Idaho, this 23rd day of July 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR#7.docx
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 9 JULY 23, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS OkJ DAY OF JULY 2024,
SERVED THE FOREGOING SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
04, BY &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.alder&acificorg.com Portland, OR 97232
E-MAIL: joseph.dallas&acificorp.com
carla.scars ella&acificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest&acificorp.com
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: lanceaae isg insi hg t.com
E-MAIL: [e-mail]
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: [e-mail] gmail.com E-MAIL:
[e-mail]
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]
[e-mail]
Electronic Service Only: RONALD L WILLIAMS
KEVIN HIGGINS BRANDON HELGESON
NEAL TOWNSEND HAWLEY TROXELL ET AL
ENERGY STRATEGIES LLC 877 W MAIN ST
E-MAIL: [e-mail] BOISE ID 83701
[e-mail] E-MAIL: rwilliams(a-hawleytroxell.com
bhelizeson@,hawlgylroxell.com
CERTIFICATE OF SERVICE Page 1 of 2

Electronic Service Only: Electronic Service Only:
BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITAFOS CONDA LLC
E-MAIL: brmullinsgmwanalytics.com E-MAIL: Val.steinergitafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamsk(kb. u
/f/1�G1
PATRICIA JORDAN SECRETARY
CERTIFICATE OF SERVICE Page 2 of 2