20240801PAC to Staff 1-15.pdf

RECEIVED
Thursday, August 1, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 1, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
monica.barrio ssanchez(apuc.Idaho.gov
S ecretarygpuc.idaho.gov
RE: ID PAC-E-24-09
IPUC Set 1 (1-15)
Please find enclosed Rocky Mountain Power's Responses to IPUC I't Set Data Requests 1-15.
If you have any questions, please feel free to call me at [phone].
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures

PAC-E-24-09 /Rocky Mountain Power
August 1, 2024
IPUC Data Request I
IPUC Data Request 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.
Response to IPUC Data Request 1
Jurisdictional allocations are not considered or displayed within the Wildfire
Mitigation Plan (WMP) because the plan is focused on projects and initiatives to
mitigate fire risk. Cost allocations are outside the scope of the WMP.
Recordholder: Mark Alder
Sponsor: Allen Berreth

PAC-E-24-09 /Rocky Mountain Power
August 1, 2024
IPUC Data Request 2
IPUC Data Request 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.
Response to IPUC Data Request 2
Area of Interest(AOI) 1 includes areas of with above average FireSight model
risk scores but which remain below the threshold for inclusion in Fire High
Consequence Areas (FHCA). Area of Interest I refers to areas with risk scores
closest to the risk scores used to demarcate the FHCA. Expressed as percentiles,
the FHCA reflects areas with FireSight model risk scores in the 85th-100th
percentile while AOI I reflects areas in the 65th-85th percentile.
Recordholder: Kevin Benson
Sponsor: Joshua Jones

PAC-E-24-09/Rocky Mountain Power
August 1, 2024
IPUC Data Request 3
IPUC Data Request 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.
Response to IPUC Data Request 3
Please refer to the Table 1 (Planned Incremental Capital Investment by Program
Category ($millions)) and Table 2 (Planned Incremental Expense by Program
Category ($millions))provided below:
Table 1
Planned Incremental Capital Investment by Program Category ($millions)
Program Category 2023 Total Total Total 3 Year
Actuals 2024 2025 2026 Total
Risk Modeling and Drivers $ $ 0.35 $0.37 $0.38 $ 1.10
*System Hardening $ $ 1.80 $1.80 $1.80 $ 5.40
Asset Inspection &Correction $ 3.33 $ 0.50 $0.50 $0.50 $ 1.50
Condition Corrections $ 3.33 $ 0.50 $ 0.50 $ 0.50 $ 1.50
Situational Awareness $ 0.18 $ 0.35 $0.74 $0.10 $ 1.19
Weather Station Installs $ 0.18 $ 0.25 $ 0.18 $ 0.05 $ 0.48
Operational Weather Forecasting $ - $ 0.01 $ 0.00 $ 0.00 $ 0.01
Wildfire Detection Network $ - $ - $ 0.30 $ - $ 0.30
Operations&Work Practices $ 1.52 $ 3.00 $5.00 $5.00 $13.00
Training Apps and Ebooks $ - $ 0.00 $ - $ - $ 0.00
Operational Capital $ 1.34 $ 3.00 $ 5.00 $ 5.00 $ 13.00
Rapid Response Communications $ 0.15 $ - $ - $ - $
Fire Prepardness Equipment I0.r13 $ - $ - $ - c
Public Safety Partner Coordination $ - $ 0.07 $ - $ - $ 0.07
Grand Total $ 5.03 $ 6.07 $8.41 $7.78 $22.26

PAC-E-24-09 /Rocky Mountain Power
August 1, 2024
IPUC Data Request 3
Table 2
Planned Incremental Expense by Program Category($millions)
Program Category 2023 Total Total Total 3 Year
Actuals 2024 1 2025 2026 Total
Risk Modeling and Drivers $ 0.20 $ 0.65 $ 0.67 $0.71 $2.03
FHCA Map Refresh $ 0.03 $ 0.01 $ 0.01 $ 0.05
Risk Assessment $ 0.61 $ 0.63 $ 0.66 $ 1.90
Advanced Data Analytics $ 0.02 $ 0.03 $ 0.04 $0.08
Situational Awareness $ 0.38 $ 0.21 $ 0.28 $0.31 $0.82
Meterology Department $ 0.06 $ 0.06 $ 0.06 $0.17
Operational Weather Forecasting $ 0.01 $ 0.03 $ 0.03 $0.07
Weather Station Maintenance and Data $ 0.14 $ 0.19 $ 0.22 $0.55
Wildfire Detection Network $ 0.00 $ 0.00 $ 0.00 $0.00
Operations & Work Practices $ 0.78 $ 0.87 $ 0.87 $0.87 $2.62
Patrols $ 0.25 $ 0.25 $ 0.25 $0.75
Rapid Response Communications $ 0.00 $ 0.00 $ 0.00 $0.01
Pre-EFR Corrections $ 0.10 $ 0.10 $ 0.10 $0.30
Vegetation Management $ 0.52 $ 0.52 $ 0.52 $ 1.56
*PSPS Program $ 0.02 $ 1.05 $ 1.05 $1.05 $3.15
Public Partner Coord. $ - $ 0.09 $ 0.09 $0.10 $0.28
Tabletop Exercises $ 0.01 $ 0.01 $ 0.01 $0.02
Emergency Mgmt. Team $ 0.09 $ 0.09 $ 0.09 $0.27
WMP Engagement & Plan Development $ 0.02 $ 0.05 $ 0.05 $0.05 $0.46
WMP Engagement Strategy $ 0.02 $ 0.03 $ 0.03 $ 0.08
Industry Collaboration $ 0.01 $ 0.00 $ - $ 0.01
Plan Monitoring&Implementation $ 0.02 $ 0.02 $0.02 $0.07
Grand Total $ 1.41 1 $ 2.94 $ 3.02 $3.09 $9.36
Recordholder: Babak Asgharian
Sponsor: Allen Berreth

PAC-E-24-09/Rocky Mountain Power
August 1, 2024
IPUC Data Request 4
IPUC Data Request 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).
Response to IPUC Data Request 4
PacifiCorp has not undergrounded transmission lines for wildfire mitigation
purposes to date.
One distribution undergrounding project for wildfire mitigation purposes
specifically has been completed in Idaho to date. Work order 7102896 was
completed to remove 8,4936 feet of overhead bare primary conductor and install
10,490 feet of underground primary conductor along County Road A-2 north of
Rexburg, Idaho. The project cost was $522,287.95 (against an estimated cost of
$775,419). The project was initiated on August 17, 2023 and placed in service on
November 24, 2023. This project relocated a line that was inside the area of
interest(AOI).
Recordholder: Kevin Schiedler
Sponsor: Todd Jensen

PAC-E-24-09 /Rocky Mountain Power
August 1, 2024
IPUC Data Request 5
IPUC Data Request 5
Page 27 of the WMP describes the drone inspections performed by Unmanned
Aerial Vehicles (UAV). 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.
Response to IPUC Data Request 5
Enhanced infrared inspections are performed within the Fire High Consequence
Areas (FHCA) and on interconnected lines to the FHCA area. As part of the
alternate technologies, unmanned aerial vehicles can be utilized to perform
enhanced infrared inspections, but at this time without an FHCA area, the infrared
inspections are not currently being performed. As such, there are no annual
expenses for Unmanned Aerial Vehicle (UAV) inspections in Idaho.
Recordholder: Jonathan Moulton
Sponsor: Joshua Jones

PAC-E-24-09/Rocky Mountain Power
August 1, 2024
IPUC Data Request 6
IPUC Data Request 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.
Response to IPUC Data Request 6
Post-work audits are performed primarily by foresters, not post-audit contractors.
Additionally, there is no Fire High Consequence Areas (FHCA) identified in
Idaho.' As such,post-audit costs for work completed in Idaho are not tracked
separately.
Please refer to the total estimated costs for vegetation management work
performed in Idaho provided below:
• Projected TOTAL 2024 Vegetation Management Idaho Costs: $2,250,000
• Projected TOTAL 2025 Vegetation Management Idaho Costs: $2,500,000
• Projected TOTAL 2026 Vegetation Management Idaho Costs: $2,750,000
Recordholder: Patricia Backlund
Sponsor: Allen Berreth
1 It is important to note that,while there is no area designated as FHCA in Idaho,vegetation management
work is nonetheless performed on circuits identified as potentially high risk by the company's meteorology
group.

PAC-E-24-09 /Rocky Mountain Power
August 1, 2024
IPUC Data Request 7
IPUC Data Request 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.
Response to IPUC Data Request 7
Rocky Mountain Power(RMP)has not completed distribution covered conductor
installations in Idaho to date.
Recordholder: Kevin Schiedler
Sponsor: Todd Jensen

PAC-E-24-09 /Rocky Mountain Power
August 1, 2024
IPUC Data Request 8
IPUC Data Request 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.
Response to IPUC Data Request 8
Rocky Mountain Power(RMP)evaluates the potential to convert distribution
overhead lines to underground for wildfire mitigation purposes on a project-by-
project basis and selects to underground a line if practical and if costs would be
comparable to rebuilding with covered conductor. Generally, overhead
construction with covered conductor is the less expensive option and typically the
selected alternative. Conditions that may make more practical to underground
distribution lines include, but is not limited to, accessibility, right-of-way (ROW)
issues, conductor sizes, and long-term maintenance costs. Undergrounding of
transmission lines is typically not considered as it is cost prohibitive.
Please refer to response to the Company's response to IPUC Data Request 4 for a
description of the only undergrounding project that has been completed in Idaho
to date.
Recordholder: Kevin Schiedler
Sponsor: Todd Jensen

PAC-E-24-09 /Rocky Mountain Power
August 1, 2024
IPUC Data Request 9
IPUC Data Request 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.
Response to IPUC Data Request 9
Circuits that fall within the Fire High Consequence Areas (FHCA)map are
prioritized for Communicating Fault Circuit Indicator(cFCI) installation. Site
selection for cFCI sensors prioritize locations that facilitate isolation of faulted
circuit segments to align with step-restoration procedures. Sensors are typically
located on load-side getaway structures, mainline tap points, midpoint switches,
reclosers and fused taps.
Recordholder: Daniel Bosco
Sponsor: Gurpreet Singh

PAC-E-24-09/Rocky Mountain Power
August 1, 2024
IPUC Data Request 10
IPUC Data Request 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.
Response to IPUC Data Request 10
Annual meteorology costs are shown in tables 17 and 18 of the Company's 2024
Wildfire Mitigation Plan (WMP) and are summarized in the table below:
2024 2025 2026 TOTAL
Capital $0.35 $0.74 $0.10 $1.19
Expense $0.22 $0.28 $0.32 $0.82
As stated in Section 5.1 (page 39) of Rocky Mountain Power's (RMP)WMP,
having the ability to gather, interpret and translate weather data into an
assessment of utility specific risk is an essential component of effective weather-
related operational decision making. Given the volume and complexity of this
data, the Company determined that there was no viable alternative to creation of a
meteorology department.
Recordholder: Chris Walsh
Sponsor: Allen Berreth

PAC-E-24-09/Rocky Mountain Power
August 1, 2024
IPUC Data Request I I
IPUC Data Request 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.
Response to IPUC Data Request 11
Implementation of a Weather Research Forecast(WRF) ensemble forecast system
will improve the granularity and accuracy of Rocky Mountain Power's (RMP)
situational awareness regarding the location, timing, and severity of extreme
weather and fire-related threats to the grid. It will also result in a significant
reduction to forecast uncertainty and, where it still exists, support identification of
where it lies in the forecast. This, in turn, will support more precise operational
actions to mitigate risk(e.g., implementation of elevated fire risk settings, more
strategic field resource allocation, and implementation of modified work
practices). Spend for implementation of the WRF ensemble forecast system is
broken down by capital and expense in the table below:
Type 2024 2025 2026 2027 TOTAL
Capital $49,728 $582,195 $36,741 $36,741 $705,404
Expense $0 $71,954 $71,954 $80,279 $224,187
TOTAL $49,728 $654,149 $108,695 $117,020 $929,591
Recordholder: Chris Walsh
Sponsor: Allen Berreth

PAC-E-24-09/Rocky Mountain Power
August 1, 2024
IPUC Data Request 12
IPUC Data Request 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.
Response to IPUC Data Request 12
There are no Cell-On-Wheels (COW) permanently placed in Idaho, however,
there are up to three units that would be made available to Idaho service areas in
the event of an emergency. Each COW has a$3,999 annual support cost as well
as approximately $3,000 annual usage cost.
There are seven dedicated Starlink mobile units deployed in Idaho, each
approximately $3,000 annual usage cost. The Starlink units can be setup quickly
but only provide Wi-Fi service and require users to have smartphones that can
place calls over Wi-Fi. Compact Response Deployable (CRD)devices are needed
where that cannot be done for telephone use and FirstNet and Verizon cellular are
needed. CRD units require a trailer and more difficult to transport and setup but
are beneficial for larger groups such as a fire camp or complete outage of a
service center.
Recordholder: Mark Gutowski
Sponsor: Michael Hindman

PAC-E-24-09/Rocky Mountain Power
August 1, 2024
IPUC Data Request 13
IPUC Data Request 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.
Response to IPUC Data Request 13
As discussed in Section 5 and Section 8 of Rocky Mountain Power's (RMP) 2024
Wildfire Mitigation Plan (WMP), situational awareness reports are generated
daily by the meteorology department to aid in decision making during periods of
elevated risk. These reports identify where fuels (dead and live vegetation) are
critically dry, where and when critical fire weather conditions are expected(gusty
winds and low humidity), and where and when the weather is forecast to
negatively impact system performance and reliability. However, when these
factors will combine to trigger a potential public safety event cannot be predicted
in advance. To that end, RMP has opted to forecast that the annual projected cost
of Public Safety Power Shutoff(PSPS) events will be the same year-over-year.
Recordholder: Nora Yotsov
Sponsor: Allen Berreth

PAC-E-24-09/Rocky Mountain Power
August 1, 2024
IPUC Data Request 14
IPUC Data Request 14
Page 68 of the WMP describes Community Resource Centers (CRC) 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.
Response to IPUC Data Request 14
Rocky Mountain Power(RMP)partners with FireDAWG for emergency support
services including the stand up of community resource centers (CRC).Costs
associated with the setup of the CRC's depends on the duration of the event and
the support services needed. These costs are not shared with RMP public safety
partners.
Recordholder: Nora Yotsov
Sponsor: Allen Berreth

PAC-E-24-09/Rocky Mountain Power
August 1, 2024
IPUC Data Request 15
IPUC Data Request 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.
Response to IPUC Data Request 15
The objective of the Company's backup power rebate programs is to mitigate the
impact of Public Safety Power Shutoff(PSPS), Elevated Fire Risk (EFR) settings
implementation and emergency de-energization on customers by the provision of
one rebate on a qualifying backup power supply.
Currently, the Company has backup power rebate programs in California and
Oregon and is investigating whether to expand them to the other states in its
service territory. In California, all residential customers are eligible to claim a
rebate up to $300 on one qualifying backup generator,power station or battery.
Additionally, residential customers actively enrolled in the Company's medical
program or any bill payment assistance program are eligible for a rebate of up to
$800. In Oregon, eligible customers are able to claim a rebate of up to $4,000 on a
qualifying portable power station, battery, or permanent standby backup power
system. To qualify, customers must be:
• Actively enrolled in the Company's medical program,
• A licensed adult family home, assisted living facility or hospice, or
• A local provider of support services to seniors and people with disabilities in
the Company's service territory (i.e., a public safety partner or community
based organization (CBO)).
Recordholder: Cara Glennon-Olsen
Sponsor: Allen Berreth