20240729Staff 130-154 to PAC.pdf

RECEIVED
Monday, July 29, 2024 9.41:20 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 ) EIGHTH 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 MONDAY,AUGUST 19, 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.
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 29, 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. 130: Please provide the following information for the "Gateway South
Segment F—Aeolus to Mona 500 kV"project referenced by Company witness Vail at 22.
Please include any available workpapers with formulae 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. 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.
b. 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.
c. Please provide the following for the Baseline Construction Project Plan:
i. Baseline project scope;
ii. Baseline project budget broken down by Work-Breakdown Structure
("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
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 29, 2024

vi. Contractor change orders.
d. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by Work Breakdown
Structure 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.
e. Please explain the large discrepancy of the project cost in McCoy's workpaper 8.5.3
of$2,069,785,300 and the total project cost in Company response to Production
Request No. 15 of$35,075,630.
REQUEST NO. 131: For each of the seven Gateway South Supporting Projects
described in Company witness VaiI's testimony on page 35, please answer the following:
a. 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.
b. Please provide the following related to completion of the project:
i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
ii. Initial and Actual project scope;
iii. Baseline construction budget-to-actual comparison by WBS and by year;
iv. Baseline construction schedule-to-actual comparison by WBS;
V. 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
vi. Please explain any slips in schedule from the baseline construction schedule.
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 29, 2024

REQUEST NO. 132: Please provide the following information for the "Gateway West
Segment DX'project referenced by Company witness Vail at 22. Please include any available
workpapers with formulae 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 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.
b. 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.
c. Please provide the following related to completion of the project:
i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
V. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 133: Please provide the following information for the "EV 2024
Generation Interconnection Network Upgrade"project referenced in Company witness Vail's
Testimony at 30. Please include any available workpapers with formulae 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.
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 29, 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 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 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 following related to completion of the project:
i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
V. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 134: Please provide the following information for the "Anticline 345
kV Phase Shifter"project referenced in Company witness Vail's Testimony at 34. Please
include any available workpapers with formulae 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. 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.
b. Please provide the following related to completion of the project:
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JULY 29, 2024

i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
V. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 135: Please provide the following information for"Oquirrh Terminal
345 kV"project referenced in Company witness Vail's Testimony at 39. Please include any
available workpapers with formulae 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. 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.
b. Please provide the following related to completion of the project:
i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
V. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 136: Please provide the following information for the `EV 2024
Generation Interconnection Network Upgrade"project referenced in Company witness Vail's
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 JULY 29, 2024

Testimony at 30. Please include any available workpapers with formulae 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 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 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 following related to completion of the project:
i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
V. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 137: Please provide the following information for the "Path C
Transmission Improvement"project referenced in Company witness Vail's Testimony at 43.
Please include any available workpapers with formulae 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. If a RFP or RFQ was submitted, please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 JULY 29, 2024

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.
b. Please provide the following related to completion of the project:
i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
V. Please explain any slips in schedule from the baseline construction schedule.
c. Please explain the large discrepancy of the project cost of$31,335,658 from McCoy
Workpaper 8.5.3 and project cost of$9,952,336 in Company's response to Production
Request No. 15.
REQUEST NO. 138: Please provide the following information for the Midpoint 500 kV
Series Capacitor Bank Replacement project referenced in the Company's response to Production
Request No. 15. Please include any available workpapers with formulae 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 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 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;
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 JULY 29, 2024

iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the following related to completion of the project:
i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
V. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 139: Please provide the following information for the "OTP189
Klamath Dam Removal (ESM)"project referenced in the Company's response to Production
Request No. 15. Please include any available workpapers with formulae 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 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 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 following related to completion of the project:
i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 9 JULY 29, 2024

ii. Baseline construction budget-to-actual comparison by WBS and by year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
V. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 140: Please provide the following information for the "Q754 Steel
Solar"project referenced in the Company's response to Production Request No. 15. Please
include any available workpapers with formulae 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 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 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 following related to completion of the project:
i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 10 JULY 29, 2024

V. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 141: Please provide the following information for the "Walla Walla 69
kV Loop Reconfig Reconduct"project referenced in the Company's response to Production
Request No. 15. Please include any available workpapers with formulae 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 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 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 following related to completion of the project:
i. Evidence that the Initial Project Plan and budget were approved at the
appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
V. Please explain any slips in schedule from the baseline construction schedule.
e. Please explain the large discrepancy of the project cost of$13,734,687 from McCoy
Workpaper 8.5.3 and project cost of$15,022,999 in Company's response to
Production Request No. 15.
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 11 JULY 29, 2024

REQUEST NO. 142: Please provide documentation and explain the accounting
treatment applied to any fines or penalties assigned to the Company or representatives acting as
the Company's agent during the course of Capital Project related activities impacting any Public
Right-Of-Way.
REQUEST NO. 143: Please explain the accounting treatment applied to insurance
settlements received for the recovery cost of repairs to Company assets that were damaged due to
vehicle crashes or other human causes and how it impacts the customer rate base.
REQUEST NO. 144: Please describe if the Company has any criteria in place to
determine if Contractors are ineligible to bid on or be awarded a contract with the Company.
REQUEST NO. 145: McCoy's workpaper"3.5 —Wheeling Revenue. xlsx" shows a
total proforma adjustment of$14,592,948 in wheeling revenue, which is the sum of the proforma
adjustments of the following items:
• Firm Wheeling Revenue;
• Pre-Merger Firm Wheeling Revenue—UPD;
• Ancil Revenue Sch 2-Reactive (Trans);
• Ancillary Revenue Sch I -Scheduling; and
• Transmission Point-to-Point Revenue.
Please define these items and explain how each item's proforma adjustment is determined.
Please provide the workpaper that calculates each item's proforma adjustment.
REQUEST NO. 146: McCoy's workpaper"3.5 —Wheeling Revenue. xlsx" lists the
following items that do not have proforma adjustments:
• Transmission Tariff True-up;
• Pre-Merger Firm Wheeling Revenue—PPD;
• Non-Firm Wheeling Revenue;
• Short-Term Firm Wheeling;
• Ancillary Rev Sch 6— Supp (Transm);
• Ancillary Rev Sch 6— Supp (C&T);
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 12 JULY 29, 2024

• Ancil Revenue Sch 2 -Reactive (C&T);
• Ancil Revenue Sch 3a—Regulation(Trans);
• Primary Delivery and Distribution Sub Charges;
• Ancillary Revenue Sch 3 —Reg&Freq (Transm);
• Ancillary Revenue Sch 3 —Reg&Freq (C&T);
• Ancillary Rev Sch 5 — Spin(Transm);
• Ancillary Rev Sch 5 -Spin(C&T);
• Ancil Revenue Sch 3a-Regulation(C&T);
• I/C Anc Rev Sch 1- Scheduling -Nevada Pwr 302082;
• I/C Anc Rev Sch 1- Scheduling -Nevada Pwr 302092;
• I/C Anc Rev Sch 1- Scheduling -Nevada Pwr 302822;
• I/C Other Wheeling Revenue—Sierra Pac;
• Use of Facility Revenue;
• Transmission Capacity Resales;
• Transmission Capacity Resales;
• Transmission Resales to Other Parties;
• Transmission Rev-Unreserved Use Charges;
• Transmission Schedule 3 Refund Reserve;
• Transmission Schedule 3a Refund Reserve;
• Transmission Schedule 5 Refund Reserve;
• Transmission Schedule 6 Refund Reserve; and
• Transmission Revenue-Deferral Fees.
Please define these items and explain why they do not have proforma adjustments.
REQUEST NO. 147: McCoy's workpaper"3.6—Fly Ash Revenues.xlsx" shows an ash
sales revenue of$7,649,442 in 2024. Please explain how this revenue is determined and provide
the workpaper that calculates this amount.
REQUEST NO. 148: McCoy's workpaper"5.2—BOSR&WRAP & COSR Fees.xlsx"
shows the forecasted BOSR fees ($87,654), WRAP fees ($1,354,358), and COSR Materials fees
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 13 JULY 29, 2024

($60,186) in 2024. Please explain how these amounts are determined and provide workpapers
that calculate these amounts.
REQUEST NO. 149: Please respond to the following regarding Tab 7.3.1 of McCoy's
workpaper"7.3 —Production Tax Credit.xlsx":
a. Please explain whether$208,356,059 is the forecasted PTC value in 2024;
b. Please explain whether"Calendar Year 2023" in Line 6 should have been"Calendar
Year 2024";
c. Please explain how each wind facility's monthly generation amount is determined;
d. If the OFPC natural gas forecasts in Aurora are changed,please explain if each wind
facility's monthly generation amount will change; and
e. If coal prices in Aurora are changed, please explain if each wind facility's monthly
generation amount will change.
REQUEST NO. 150: Please respond to the following regarding Tab 7.6.1 of McCoy's
workpaper"7.6—Wyoming Wind Generation Tax. xlsx":
a. Please explain whether$4,047,681 is the forecasted Wyoming Wind Generation Tax
amount in 2024;
b. Please explain whether"2023" in Line 6 should have been"2024";
c. Please explain how each wind facility's generation amount in Column C is
determined;
d. If the OFPC natural gas forecasts in Aurora are changed,please explain if each wind
facility's generation amount will change; and
e. If coal prices in Aurora are changed, please explain if each wind facility's generation
amount will change.
REQUEST NO. 151: Please provide the following information for the "U21 Major
Inspection Overhaul - CY23"project referenced in production response PAC-E-24-04 Attach
IPUC 15. Please include any available workpapers with formulae 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.
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 14 JULY 29, 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 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 that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for 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 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;
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 15 JULY 29, 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 slips in schedule from the baseline construction schedule.
REQUEST NO. 152: Please provide the following information for the "U2 CSA
Variable fee - CT2 - HGP"project referenced in production response PAC-E-24-04 Attach IPUC
15. Please include any available workpapers with formulae 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 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
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;
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 16 JULY 29, 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. 153: Please provide the following information for the "ACQUIRE
REPOWER SAFE HARBOR- FC II-IV R"project referenced in production response PAC-E-
24-04 Attach IPUC 15. Please include any available workpapers with formulae 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 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:
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 17 JULY 29, 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 Plan:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
Ili. 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. 154: Please provide the following information for the "Idaho -New
Revenue -Residential"project referenced in production response PAC-E-24-04 Attach IPUC 15.
Please include any available workpapers with formulae 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.
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 18 JULY 29, 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 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
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;
M. 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
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 19 JULY 29, 2024

iv. Please explain any slips in schedule from the baseline construction schedule.
DATED at Boise, Idaho, this 291h day of July 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR 48.docx
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 20 JULY 29, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS�q: DAY OF JULY 2024,
SERVED THE FOREGOING EIGHTH 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: [e-mail] Portland, OR 97232
E-MAIL: ioseph.dallas(cr�,pacificorp.com
carla.scarsellakpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@,pacificorp.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: lance@ae isg insight.com
E-MAIL: elo(cr�,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: [e-mail] 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]
gmeyergconsultbai.com
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
ntownsend(cr�,energystrat.com E-MAIL: rwilliams&hawleytroxell.com
bhel eg [e-mail]
CERTIFICATE OF SERVICE Page 1 of 2

Electronic Service Only: Electronic Service Only:
BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITAFOS CONDA LLC
E-MAIL: brmullinskmwanalytics.com E-MAIL: Val.steiner(c�r�,itafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: wi1hamskkbyui.edu
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE Page 2 of 2