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HomeMy WebLinkAbout20240809PAC to Staff 58-78 _ 80-81.pdf RECEIVED Friday, August 9 2024 IDAHO PUBLIC ROCKY MOUNTAIN UTILITIES COMMISSION POWER A DIVISION OF PACIFICORP 1407 W North Temple, Suite 330 Salt Lake City, Utah 84116 August 9, 2024 Monica Barrios-Sanchez Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd. Bldg. 8, Ste. 201-A Boise, ID 83714 monica.barriossanchez(a�puc.idaho.gov SecretaU gpuc.idaho.gov RE: ID PAC-E-24-04 IPUC Set 5 (58-81) Please find enclosed Rocky Mountain Power's Responses to IPUC 5th Set Data Requests 58-78, 80 and 81. Also provided are Attachments. The remaining response will be provided under separate cover. Provided via BOX are Confidential Attachments and Responses. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of Procedure No. 67—Information Exempt from Public Review, and further subject to the non-disclosure agreement(NDA) executed in this proceeding. If you have any questions, please feel free to call me at(801) 220-2313. Sincerely, /s/ Mark Alder Manager, Regulation Enclosures C.c.: Eric L. Olsen/IIPA eloAechohawk.com(C) Lance Kaufman/IIPA lancegae_isg insi_h�(C) Matthew Nykiel/ICL matthew.n, kielggmail.com Brad Heusinkveld/ICL bheusinkveld(c-r�,idahoconservation.org Thomas J. Budge/Bayer tina,racineolson.com(C) Brian C. Collins/Bayer bcollins@consultbai.com Greg Meyer/Bayer gmey r(c-r�,consultbai.com Kevin Higgins/Bayer khigg_ins@energystrat.com(C) Neal Townsend/Bayer ntownsendgenergystrat.com(C) Ronald L. Williams/PIIC rwilliamsghawleytroxell.com Brandon Helgeson/PIIC bhel_eg son&hawleytroxell.com Bradley Mullins/PIIC brmullinskmwanalytics.com Val Steiner/PIIC val.steinerkitafos.com Kyle Williams/PIIC williamsk(a),byui.edu PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 58 IPUC Data Request 58 Please provide the following information for the Jim Bridger—Ul 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; 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 PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 58 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. iv) Please explain any slips in schedule from the baseline construction schedule. Response to IPUC Data Request 58 Please refer to Confidential Attachment IPUC 58 as well as to the Company's responses to subparts (a)through(f)below: (a) The United States (U.S.) Environmental Protection Agency (EPA)ruled that the coal-fired Jim Bridger Unit 1 would require a selective catalytic reduction (SCR) system be installed in order to operate after December 31, 2023; however, the addition of an SCR was not economically viable, so converting to natural gas was considered as an acceptable alternative to meet U.S. EPA requirements. In PacifiCorp's 2021 Integrated Resource Plan(IRP)preferred portfolio, Jim Bridger Unit 1 was to be converted from a coal-fueled to a natural gas-fueled unit in 2024,providing a low-cost reliable resource to meet load and reliability requirements. This preferred Portfolio also reflects PacifiCorp's commitment to further reduce greenhouse gas emissions. Compared to the 2019 IRP, the projected carbon dioxide (CO2) emissions in 2026 will be down 26 percent. (b) Please refer to Confidential Attachment IPUC 58, confidential file "STCostSummaryCompareP02a-MMNoGClessP02-MMJBGCRefresh CONF"which provides the economic analysis. (c) The Jim Bridger—U1 Conversion to Natural Gas and U2 Conversion to Natural Gas projects were executed together. Note: several of the documents provided in Confidential Attachment IPUC 58 apply to both projects. This project was not executed as an engineering, procurement, construction(EPC), several major request for proposals (RFP) exist. Please refer to Confidential Attachment IPUC 58, specifically the following confidential folders: Jaggaer RFX 9657 - PacifiCorp 2022 Gas conversion engineering Jaggaer RFX 9091 - Gas Conversion Materials PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 58 Oracle RFx PAC00006,1 JB 2023 Gas Conversion Construction Ul and U2 Oracle RFX PAC00016 JB 2024 Boiler Overhaul/Burner Construction (d) Please refer to Confidential Attachment IPUC 58, specifically confidential file "APR10030053&APR10030054—Proj—ProposalRevl CONF" and confidential file "APR 10030053&APR10030054—Proj—ProposalRevl CONF". (e) The Jim Bridger—U1 Conversion to Natural Gas and U2 Conversion to Natural Gas projects were executed together. Note: several of the documents provided in Confidential Attachment IPUC 58 apply to both projects. This project was not executed as an EPC, several scopes exist: i. For baseline scope,please refer to Confidential Attachment IPUC 58 and the following confidential files: "Scope of Work—GAS CONVERSION FUEL DELIVERY ENGINEERING CONF" "Scope of Work—GAS CONVERSION FUEL DELIVERY MATERIALS CONF" "Scope of Work—GAS CONVERSION FUEL DELIVERY CONSTRUCTION Rev. 2 CONF" "Scope of Work—GAS CONVERSION FIRING EQUIPMENT MATERIALS CONF" "Scope of Work—GAS CONVERSION FIRING EQUIPMENT CONSTRUCTION CONF" "Scope of Work—GAS CONVERSION FOUNDATIONS CONF" ii. Please refer to Confidential Attachment IPUC 58, specifically confidential file "U1 project budget by WBS CONF". iii. Please refer to Confidential Attachment IPUC 58, specifically confidential file "Gas Conversion schedule CONF". iv. Please refer to Confidential Attachment IPUC 58, specifically confidential files "APR90001601_Proj—Proposal CONF" and "APR90001615—Proj—Proposal CONF". Both these changes were approved at the appropriate level through SAP. Note: Project Change APR 90001716 has also been created to address unplanned charges to the project including submerged drag chain conveyor modifications, PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 58 precipitator duct cleaning, and test energy. This appropriation request (APR) will be routed for approval in the near future. v. Please refer to Confidential Attachment IPUC 58, specifically confidential file "U1&U2 PROJECT REPORTS CONF". vi. Several change orders occurred with the engineering, material supply, and construction portions of the project related to the changes outlined in APR90001601 and APR90001615. Change orders for the Fuel Delivery Construction: 3300005762-160 WY3040C-CCN-006 HP skid to Control 3300005762-150 VVY3040C-CCN-009 Fuel Train Add Socket Welds 3300005762-130 WY3040C-CCN-010 Upper Hot Air XOVER Duct Insulation: 3300005762-140 WY3040C-CCN-011 U2 Nitrogen Purge 3300005762-170 WY3040C-CCN-014 Additional infill steel 3300005762-180 WY3040C-CCN-015 ABD Infill steel mods 3300005762-190 WY3040C-CCN-017 Unit 1 copper lines 3300005762-200 WY3040C-CCN-018 Unit 1 Delay, other T&M-Work Change orders for the Material and Engineering: 3300005374 CO#2 and First Amendment to Contract 3300005374 CO#3 Babcock Power Services, Inc. PA Fan Outlet Dampers 3300005374 CO#4 Babcock Power Services, Inc. Scanner Elimination 3300005374 CO#5 Babcock Power Services Inc. Filter Skid—FE 3300005374 CO#6 Babcock Power Services, Inc. Heating System FE 3300005374 CO#7 Babcock Power Services Inc. - Burner Tips - FE (f) Please refer to Confidential Attachment IPUC 58, specifically confidential files "U1 project budget by WBS CONF", "Gas Conversion schedule CONF", "APR90001601_Proj_Proposal CONF", "APR90001615_Proj_Proposal CONF" and"Gas Conversion schedule". Note: there are additional documents responsive to this request which are considered highly confidential and commercially sensitive. The Company requests special handling. Please contact Mark Alder at(801) 220-2313 to make arrangements for review. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of Procedure No. 67—Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement(NDA) executed in this proceeding. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 58 Recordholder: Ken Cutler Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 59 IPUC Data Request 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: 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. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 59 (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. Response to IPUC Data Request 59 Please refer to the Company's response to IPUC Data Request 58, specifically Confidential Attachment IPUC 58, as well as to the Company's responses to subparts (a)through (f)below. (a) The United States (U.S.) Environmental Protection Agency (EPA)ruled that the coal-fired Jim Bridger Unit 2 would require a selective catalytic reduction (SCR) system be installed in order to operate after December 31, 2023; however, the addition of an SCR was not economically viable, so converting to natural gas was considered as an acceptable alternative to meet U.S. EPA requirements. In PacifiCorp's 2021 Integrated Resource Plan(IRP)preferred portfolio, Jim Bridger Unit 2 was to be converted from a coal-fueled to a natural gas-fueled unit in 2024,providing a low-cost reliable resource to meet load and reliability requirements. This preferred Portfolio also reflects PacifiCorp's commitment to further reduce greenhouse gas (GHG) emissions. Compared to the 2019 IRP, the projected carbon dioxide (CO2) emissions in 2026 will be down 26 percent. (b) Please refer to the Company's response to IPUC Data Request 58, specifically Confidential Attachment IPUC 58, confidential file STCostSummaryCompareP02a-MNINoGClessP02-MMJBGCRefresh which provides the economic analysis. (c) The Jim Bridger—U1 Conversion to Natural Gas and U2 Conversion to Natural Gas projects were executed together. Note: several of the documents provided in Confidential Attachment IPUC 58 apply to both projects. This project was not executed as an engineering, procurement, construction(EPC), several major request for proposals (RFP) exist. Please refer to the Company's response to IPUC Data Request 58, specifically Confidential Attachment IPUC 58, the following confidential folders: Jaggaer RFX 9657 -PacifiCorp 2022 Gas conversion engineering PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 59 Jaggaer RFX 9091 - Gas Conversion Materials Oracle RFx PAC00006,1 JB 2023 Gas Conversion Construction U1 and U2 Oracle RFX PAC00016 JB 2024 Boiler Overhaul/Burner Construction (d) Please refer to the Company's response to IPUC Data Request 58, specifically Confidential Attachment IPUC 58, confidential files "APR10030053&APR10030054_Proj_ProposalRevl CONF" and"Evidence APRIO030054 Approved CONF". (e) The Jim Bridger—U1 Conversion to Natural Gas and U2 Conversion to Natural Gas projects were executed together. Note: several of the documents provided with the Company's response to IPUC Data Request 58, specifically Confidential Attachment IPUC 58 apply to both projects. This project was not executed as an EPC, several scopes exist: i. For baseline scope, please refer to Confidential Attachment IPUC 58 and the following confidential files: "Scope of Work—GAS CONVERSION FUEL DELIVERY ENGINEERING CONF" "Scope of Work—GAS CONVERSION FUEL DELIVERY MATERIALS CONF" "Scope of Work—GAS CONVERSION FUEL DELIVERY CONSTRUCTION Rev. 2 CONF" "Scope of Work—GAS CONVERSION FIRING EQUIPMENT MATERIALS CONF" "Scope of Work—GAS CONVERSION FIRING EQUIPMENT CONSTRUCTION CONF" "Scope of Work—GAS CONVERSION FOUNDATIONS CONF" ii. Please refer to the Company's response to IPUC Data Request 58, specifically Confidential Attachment IPUC 58, confidential file "U2 project budget by WBS CONF". iii. Please refer to the Company's response to IPUC Data Request 58, specifically Confidential Attachment IPUC 58, confidential file "Gas Conversion schedule CONF". iv. Please refer to the Company's response to IPUC Data Request 58, specifically Confidential Attachment IPUC 58, confidential files PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 59 "APR90001602_Proj_Proposal CONF" and "APR90001616_Proj_Proposal CONF". Both these changes were approved at the appropriate level through SAP. Note: Project Change APR 90001717 has also been created to address unplanned charges to the project including submerged drag chain conveyor modifications, precipitator duct cleaning, and test energy. This appropriation request (APR) will be routed for approval in the near future. v. Please refer to the Company's response to IPUC Data Request 58, specifically Confidential Attachment IPUC 58, confidential file "U1&U2 PROJECT REPORTS CONF". vi. Several change orders occurred with the engineering, material supply, and construction portions of the project related to the changes outlined in APR90001602 and APR90001616. Change orders for the Fuel Delivery Construction: 3300005762-160 WY3040C-CCN-006 HP skid to Control 3300005762-150 VVY3040C-CCN-009 Fuel Train Add Socket Welds 3300005762-130 WY3040C-CCN-010 Upper Hot Air XOVER Duct Insulation: 3300005762-140 WY3040C-CCN-011 U2 Nitrogen Purge 3300005762-170 WY3040C-CCN-014 Additional infill steel 3300005762-180 WY3040C-CCN-015 ABD Infill steel mods 3300005762-210 WY3040C-CCN-016 Unit 2 copper lines 3300005762-220 WY3040C-CCN-018 Unit 2 Delay&Misc T&M Work Change orders for the Material and Engineering: 3300005374 CO#2 and First Amendment to Contract 3300005374 CO#3 Babcock Power Services, Inc. PA Fan Outlet Dampers 3300005374 CO#4 Babcock Power Services, Inc. Scanner Elimination 3300005374 CO#5 Babcock Power Services Inc. Filter Skid—FE 3300005374 CO#6 Babcock Power Services, Inc. Heating System FE 3300005374 CO#7 Babcock Power Services Inc. - Burner Tips—FE (f) Please refer to the Company's response to IPUC Data Request 58, specifically Confidential Attachment IPUC 58, confidential files"U2 project budget by WBS CONF", "Gas Conversion schedule CONF", "APR90001602_Proj_Proposal CONF", "APR90001616_Proj_Proposal CONF" and"Gas Conversion schedule CONF". Note: there are additional documents responsive to this request which are considered highly confidential and commercially sensitive. The Company requests special handling. Please contact Mark Alder at(801) 220-2313 to make PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 59 arrangements for review. Recordholder: Ryan Smith Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 60 IPUC Data Request 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. (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. 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. 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. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 60 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. 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. iv. Please explain any slips in schedule from the baseline construction schedule. Response to IPUC Data Request 60 The "ILR 11.2.2.12 Beaver Bay PH 1 Renovation"project has been delayed and will be removed from this general rate case (GRC) proceeding in the Company's rebuttal testimony. Recordholder: Gary Tawwater/Peter Martins Sponsor: Will Shallenberger PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 61 IPUC Data Request 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 work papers 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. 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. 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. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 61 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. 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. iv. Please explain any slips in schedule from the baseline construction schedule. Response to IPUC Data Request 61 (a) Please refer to Confidential Attachment IPUC 61-1. (b) Please refer to Confidential Attachment IPUC 61-1. (c) Please refer to the Company's responses to subparts i. through iv. below: i. Please refer to Confidential Attachment IPUC 61-2. ii. Please refer to Confidential Attachment IPUC 61-2. iii. Please refer to Confidential Attachment IPUC 61-2. iv. Please refer to Confidential Attachment IPUC 61-3 (d) Please refer to the Company's responses to subparts i. through iv. below: i. Please refer to Confidential Attachment IPUC 61-2. ii. Please refer to Confidential Attachment IPUC 61-1. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 61 iii. Please refer to Confidential Attachment IPUC 61-2 iv. Please refer to Confidential Attachment IPUC 61-1. (e) Please refer to the Company's responses to subparts i. through vi. below: i. Please refer to Confidential Attachment IPUC 61-2. ii. HLEW/202 I/C/054; tracked at single level. iii. HLEW/202 I/C/054; tracked at single level. iv. No deviation. v. Please refer to Confidential Attachment IPUC 61-4. vi. Please refer to Confidential Attachment IPUC 61-5 (f) Please refer to the Company's responses to subparts i. through iv below: i. Please refer to the table provided below: HLEW/2021/C/054 Budget $1,000 Actual $1,000 CY 21 160 12 CY 22 990 2,495 CY 23 4,027 2,227 CY 24 731 1,707 CY 25 0 0 CY 26 0 0 Total 5,908 6,441 Variance $ 533 Variance(%) 9.02% ii. No change. Please refer to the Company's response to subpart (f)i. above. iii. Please refer to Confidential Attachment IPUC 61-5. iv. No change. Please refer to the Company's response to subpart (f)i. above. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 61 Procedure No. 67—Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement(NDA) executed in this proceeding. Recordholder: Peter Martins/Gary Tawwater Sponsor: Will Shallenberger PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 62 IPUC Data Request 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. 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. 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. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 62 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. 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. iv. Please explain any slips in schedule from the baseline construction schedule. Response to IUC Data Request 62 The "Yale Downstream Fish Passage"project has been delayed and will be removed from this general rate case (GRC)proceeding in the Company's rebuttal testimony. Recordholder: Peter Martins/Gary Tawwater Sponsor: Will Shallenberger PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 63 IPUC Data Request 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. (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. 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. 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. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 63 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; Project status reports and action items. v. 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. iv. Please explain any slips in schedule from the baseline construction schedule. Response to IPUC Data Request 63 The "Toketee 2 Turbine Refurbishment"project has been delayed and will be removed from this general rate case (GRC)proceeding in the Company's rebuttal testimony. Recordholder: Tom Hickey Sponsor: Will Shallenberger PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 64 IPUC Data Request 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. 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. 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. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 64 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; Project status reports and action items. v. 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. iv. Please explain any slips in schedule from the baseline construction schedule. Response to IPUC Data Request 64 (a) Please refer to Confidential Attachment IPUC 64. (b) Please refer to the Company's response to subpart(a) above. (c) Not applicable. (d) Please refer to Confidential Attachment IPUC 64. (e) The Cutler Relicensing Project will acquire the new license for the project and no construction is involved. Implementation of new license requirements will be through future capital expenditure (CAPEX)projects and operations and maintenance, and administrative and general (OMAG)provisions. (f) The Cutler Project is maintained at single level work breakdown structure (WBS) element. There is no construction schedule for the Cutler Project as this is an operating license for the hydroelectric facility. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 64 Procedure No. 67—Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement(NDA) executed in this proceeding. Recordholder: Todd Olsen/ Gary Tawwater Sponsor: Will Shallenberger PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 65 IPUC Data Request 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 an 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. 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. 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. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 65 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. 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. iv. Please explain any slips in schedule from the baseline construction schedule. Confidential Response to IPUC Data Request 65 (a) The Fall Creek Hatchery was constructed to allow PacifiCorp to satisfy its obligations under Interim Measure 19 of the Klamath Hydroelectric Settlement Agreement(KHSA). Interim Measure 19 of the KHSA obligates PacifiCorp to provide continued hatchery production for eight years after the removal of Iron Gate Dam, consistent with hatchery mitigation objectives established by the California Department of Fish and Wildlife (CDFW) in consultation with the National Marine Fisheries Service (NMFS). In accordance with Interim Measure 19, "Plan implementation may include PacifiCorp contracting with the owners or administrators of other identified hatchery facilities and/or funding the planning, design,permitting, and construction of measures identified in the Plan as necessary to continue to meet mitigation production objectives". (b) PacifiCorp reviewed the following alternatives to satisfy its obligation to provide for hatchery production continuity as required by KHSA Interim Measure 19: PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 65 PAC-E-24-04 /Rocky Mountain Power August 9, 2024 IPUC Data Request 65 (c) Please refer to the Company's responses to subparts i. through iv below: I. Please refer to Confidential Attachment IPUC 65-1. ii. Please refer to Confidential Attachment IPUC 65-2. in. The short-list bidder scorecard is no longer available as the Jaegger procurement system in which it was maintained is no longer available to the Company. iv. Please refer to Confidential Attachment IPUC 65-3. (d) Please refer to the Company's responses to subparts i. through iv below: I. Please refer to Confidential Attachment IPUC 65-4 which provides the appropriation request(APR) for the project which includes the original scope, schedule and budget for the project. ii. Please refer to the Company's response to subpart(d) i. above. iii. Please refer to the Company's response to subpart (d) i. above. iv. Please refer to the Company's response to subpart (d) i. above. (e) Please refer to the Company's responses to subparts i. through vi below: I. Please refer to Confidential Attachment IPUC 65-5. ii. Please refer to Confidential Attachment IPUC 65-6. iii. Please refer to Confidential Attachment IPUC 65-7. iv. There were no significant deviations between the baseline construction project scope, budget or schedule relative to the Initial Project Plan. v. Please refer to Confidential Attachment IPUC 65-8. vi. Please refer to Confidential Attachment IPUC 65-9. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 65 (f) Please refer to the Company's responses to subparts i. through iv below i. Please refer to Confidential Attachment IPUC 65-10. ii. A baseline to actual construction schedule comparison is not available. The project was delivered on schedule with all critical milestone dates related to infrastructure online dates achieved. iii. The budget for the Fall Creek Hatchery project was not exceeded. Please refer to Confidential Attachment IPUC 65-10. iv. All critical milestone dates in the construction schedule related to infrastructure online dates were achieved on time. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of Procedure No. 67—Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement(NDA) executed in this proceeding. Recordholder: Tim Hemstreet/Robert Roach Sponsor: Tim Hemstreet PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 66 IPUC Data Request 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. Response to IPUC Data Request 66 Please refer to Attachment IPUC 66. Recordholder: Thomas Turner Sponsor: Jeffery Vickers PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 67 IPUC Data Request 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. Response to IPUC Data Request 67 Please refer to Attachment IPUC 67 which provides a list of the capital projects associated with wildfire mitigation that the Company is seeking recovery for in this general rate case (GRC)proceeding. These items are included in the electric plant in-service (EPIS)balance. Please refer to Exhibit No. 48—Test Period Results of Operations—Twelve Months ending December 2023. The total amount of Idaho allocated operation and maintenance (O&M) associated with wildfire mitigation that the Company is seeking recovery for in this GRC proceeding is $1.97 million. Please refer to Exhibit No. 48 —Test Period Results of Operations—Twelve Months ending December 2023 in the Incremental O&M adjustment,page 4.10. (a) The jurisdictional allocations assigned to the capital and O&M wildfire mitigation expense is based on the approved allocation methodology, the 2020 Multi-State Process (MSP) Inter-Jurisdictional Cost Allocation Methodology (2020 Protocol). The treatment of jurisdictional factors related to specific FERC Accounts is provided in Appendix B of the 2020 Protocol. Recordholder: Aaron Rose Sponsor: Shelley McCoy PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 68 IPUC Data Request 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. Response to IPUC Data Request 68 Please refer to the Company's response to IPUC Data Request 56 which provides information regarding funding sources explored and received for wildfire mitigation projects since the last general rate case (GRC), Case No. PAC-E-21- 07. Recordholder: Rohit Nair Sponsor: Gurpreet Singh PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 69 IPUC Data Request 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. Response to IPUC Data Request 69 PacifiCorp objects to this data request to the extent it seeks information of costs incurred and assigned for recovery from customers in other jurisdictions and as such is outside the scope of this proceeding. Subject to and without waiving the foregoing objection, PacifiCorp states as follows: California: • In 2018, the California legislature adopted Senate Bill (SB) 901, of which a key element were the new provisions under California Public Utilities Code (PUC) Section 8386, which requires electric utilities to develop annual wildfire mitigation plans (WMP) to prevent, combat, and respond to wildfires within their service territories. Under PUC 8386(c), utilities must include in their WMPs statutorily prescribed content addressing a list of specific issues. SB 901 was implemented under California Public Utilities Commission (CPUC) Rulemaking (R) 18-10-007. • In 2019, Assembly Bill (AB) 1054 was passed to focus on reducing wildfire risk through the establishment of a Wildfire Advisory Board, Safety Culture, ongoing annual compliance processes and a new agency, the Office of Energy Infrastructure Safety(Energy Safety). Starting on July 1, 2021, Energy Safety was established on July 1, 2021 to ensure electrical utilities are taking effective actions to reduce utility-related wildfire risk and to oversee WMP filings and ongoing compliance. Energy Safety dockets which established the annual Guidelines for WMP filings are in the following dockets: 2023-2025- WMPs, 2022-WMPs and 2021-WMPs. • PacifiCorp's wildfire spend is provided in the Company's most recent WMP filed with the CPUC July 8, 2024,1 Section 4.3, pp.29-30. 'https://www.pacificorp.com/content/dam/pcorp/documents/en/pacificorp/wildfire- mitigation/CA_2025_WMP-Update.pdf PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 69 Oregon: • Executive Order 20-04 (EO 20-04), Section 5(B)(4), directed the Public Utility Commission of Oregon(OPUC) to "Evaluate electric companies' risk-based wildfire protection plans and planned activities to protect public safety,reduce risks to utility customers, and promote energy system resilience in the face of increased wildfire frequency and severity, and in consideration of the recommendations made by the Governor's Council on Wildfire Response 2019 Report and Recommendations". • Senate Bill (SB) 762 (2021), incorporated as Oregon Revised Statutes (ORS) 757.960 through 757.969, established standards for electric utility's WMP. • Oregon Administrative Rules (OAR) Chapter 860 Division 300 states the requirements for WMPs and OPUC's process for approval of the WMPs. • Order No. 23-220, approving PacifiCorp's 2023 WMP directed PacifiCorp to consult with OPUC staff regarding implementation of OPUC. • Chapter 13 of PacifiCorp's 2024 WMP filed on December 28, 2023 in Oregon docket UM 22072 provides an estimate of the incremental operations and maintenance expense by category(Table 37) and incremental capital costs by category(Table 38)to implement the WMP. Washington: • PacifiCorp has not yet filed a WMP in Washington. Revised Code of Washington(RCW) 80.28.440 requires investor-owned utilities (IOU) to review and revise its WMP by October 31, 2024, and every three years thereafter. Utilities must use a recommended format and elements (RCW 76.04.185) and submit WMPs to the Washington Utilities and Transportation Commission(WUTC). Idaho: • Order No. 36045 in Case No. PAC-E-23-18 required PacifiCorp to submit as a separate filing a final copy of its WMP for Idaho within 30 days of its completion but no later than April 15, 2024. On April 15, 2024, PacifiCorp submitted its 2024 WMP, in compliance with Order No. 36045. The submitted 2024 WMP provides an estimate of the incremental operations and maintenance 2 hLtps:Hedocs.puc.state.or.us/efdocs/HAQ/um2207hag325929054.pdf PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 69 expense by category(Table 18)and incremental capital costs by category(Table 17)to implement the WMP. Utah: • Utah Code § 54-24-201 and § 54-24-202 and Utah Administrative Code R746-315-3 require the Company to submit a Wildland Fire Protection Plan on or before October 1 of every third year after calendar year 2020, and annual compliance report no later than June 1 of each year and an annual report on cost recovery. The costs of the Utah WMP are detailed in the latest 2024 Wildland Fire Cost and Compliance Report submitted to the Utah Public Service Commission on May 30, 2024 and are provided with Attach IPUC 69. Wyoming: • There are no orders issued by the Wyoming Public Service Commission (WPSC) or laws passed by the Wyoming Legislature pertaining to wildfire mitigation or the Company's WMP at this time. Therefore, there are no costs to comply with an approved WMP in Wyoming. Costs incurred for wildfire mitigation work are allocated by state/jurisdiction consistent with the 2020 Multi-State Process Interjurisdictional Cost Methodology (2020 Protocol). Recordholder: Mark Alder Sponsor: Joelle Steward PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 70 IPUC Data Request 70 Please provide the Company's process guidelines and all least-cost, least-risk analysis used to evaluate each of the wildfire mitigation projects. Response to IPUC Data Request 70 Rocky Mountain Power(RMP) does not currently have a least-cost, least-risk analysis in place to evaluate its wildfire mitigation projects. However, the Company is developing the methodologies and process to: • Estimate the effectiveness of select risk mitigations, • Calculate the risk effectiveness relative to cost to compare mitigation alternatives as appropriate, • Review and update estimated mitigation effectiveness measures as appropriate, and • Identify if there are new mitigations with sufficient data to estimate effectiveness Recordholder: Alex Vaz/Kevin Benson Sponsor: Joshua Jones PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 71 IPUC Data Request 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. (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. Response to IPUC Data Request 71 (a) 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. (b) Locations considered for wildfire hardening are within fire high consequence areas (FHCA). PacifiCorp performed risk modeling to determine these high- risk areas. Areas in the FHCA are considered for hardening with covered conductor or undergrounding. There are no FHCA areas in Idaho. Areas of Interest are currently not subject to the wildfire line rebuild program. (c) No transmission lines have been undergrounded for wildfire mitigation purposes in any state served by PacifiCorp.No Idaho distribution lines have been undergrounded for fire mitigation with exception of the "DBS 11/SPENCER FIRE JOB OVH TO UG RELO"project listed below. On this project, about 1.6 miles of existing wood poles were relocated from a location with difficult access that posed a fire risk to a nearby road. DBS11/SPENCER FIRE JOB OVH December 1,2023 December 31,2023 $522,288 TO UG RELO PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 71 Recordholder: Alex Vaz Sponsor: Joshua Jones PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 72 IPUC Data Request 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. (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. Response to IPUC Data Request 72 (a) All lines located within the fire high consequence area(FHCA) are reviewed and prioritized for rebuild with covered conductor or underground. Covered conductor is typically less expensive and often the preferred alternative. The company is working to create a cost-benefit analysis approach using a risk spend efficiency (RSE) model to ensure investments are prudent. (b) Locations considered for wildfire hardening are within FHCA. PacifiCorp performed risk modeling to determine these high-risk areas. Areas in the FHCA are considered for hardening with covered conductor or undergrounding. There are no FHCA areas in Idaho. Areas of Interest are currently not subject to the wildfire line rebuild program. (c) Transmission lines that are rebuilt for wildfire mitigation are constructed with steel poles and bare conductor. Note: A few transmission lines in Utah have been rebuilt and a list of Plant Placed In-Service (PPIS) can be provided by investment delivery or finance.No distribution lines in Idaho have been rebuilt with covered conductor. Recordholder: Alex Vaz Sponsor: Joshua Jones PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 73 IPUC Data Request 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. Response to IPUC Data Request 73 Rocky Mountain Power(RMP) has not replaced any wood poles in the State of Idaho with steel or fiberglass for the purposes of wildfire mitigation. Recordholder: Alex Vaz Sponsor: Joshua Jones PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 74 IPUC Data Request 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. Response to IPUC Data Request 74 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. Recordholder: Mark Gutowski Sponsor: Michael Hindman PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 75 IPUC Data Request 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. Response to IPUC Data Request 75 Rocky Mountain Power(RMP) does not have any cost sharing with public safety partners for its wildfire mitigation programs in Idaho. Recordholder: Nora Yotsov Sponsor: Allen Berreth PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 76 IPUC Data Request 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: 1. A copy of the RFP or RFQ that was submitted; 11. 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. Response to IPUC Data Request 76 The Public Safety Partner(PSP)portal is a secure interactive map-centric, web- based solution that hosts contact and location information of customers that have been identified as critical facilities or infrastructure. Key information includes location,primary/secondary contact information, and backup generation capabilities, etc. The portal is accessible to public safety partners during public safety power shutoff(PSPS) events to assist in notification and collaboration with potentially effected facilities. The total capital and operations and maintenance (O&M) expenses are as follows: • Capital—$7,098,175.42 • O&M—$46,011.40 Costs incurred for the PSP are allocated by state/jurisdiction consistent with the 2020 Multi-State Process Interjurisdictional Cost Methodology(2020 Protocol). PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 76 The expected benefits of the PSP include: • The PSP portal provides a tool that public safety partners can use during and in preparation for wildfire and PSPS that meets the OPUC's interactive mapping requirement. • The PSP portal also supports PacifiCorp's efforts to prioritize restoration, backup power evaluation, additional communications, and other resources before and during PSPS events. • The PSP provides regulatory compliance. Specifically, the PSP achieves PacifiCorp's compliance with the California Public Utilities Commission (CPUC) and Public Utilities Commission of Oregon(OPUC) requirements for a web-based PSP portal. (a) The guidelines and rules of CPUC Decision(D) 21-06-034 require that all electric investor-owned utilities (IOU) establish a web-based portal where PSP can view and download critical customer/facility data before and during PSPS events. Part of the PacifiCorp 2022 Wildfire Protection Plan (WMP), filed in response to the OPUC Administrative Rule (OAR) 938 Interim Permanent Rules, PacifiCorp committed to delivering a similar web-based PSP portal. PacifiCorp initially developed a proof of concept(POC)using its internal SharePoint site to meet the CPUC's minimum requirements. However, it was determined early on that this solution would not meet all the requirements set forth by the OPUC,particularly the interactive mapping requirement. Additionally, continuing to use SharePoint posed security risks to PacifiCorp's network. To address these issues, the Company chose a more robust PSP portal. (b) Alternative: Implementation of a SharePoint solution. Advantages: • Cost savings. Can be maintained by the business owner with minimal information technology (IT) involvement. Disadvantages: • Microsoft's 365 guest access expires every 60 days, regardless of usage. This poses a significant issue for a system where immediate access is needed in emergency situations. • SharePoint is not capable of delivering the interactive map data that the OPUC requires. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 76 • Hosting the portal on the BHE Tenant presents security risks to PacifiCorp's network that would not be there otherwise. Alternatives considered that do not resolve the critical issues/needs: • An Oracle solution was also evaluated,but implementation could not meet the OPUC and CPUC commissions' timelines or functional requirements. (c) Please refer to the Company's responses for subparts I to IV below: I. No formal request for proposal (RFP)/request for quote (RFQ) was submitted. Bidders included software vendors previously vetted by BHE Information Technology. Verbal discussions and examples of desired functionality were presented to each vendor. Additionally question and answers sessions were offered to each respondent as the need arose to clarify high-level requirements. II. Informal scoring was used in the selection process. Initial bids submitted were reviewed and low-price vendor was selected. III. Not available IV. Not available Recordholder: Amanda Lindsay Sponsor: Tyler Averyt PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 77 IPUC Data Request 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. Response to IPUC Data Request 77 (a) PacifiCorp installed 11 weather stations in 2022 and 10 weather stations in 2023 for a total of 21 weather stations since the last general rate case (GRC), Case No. PAC-E-21-07. (b) A weather station network is a critical component to wildfire mitigation and emergency response. While public weather station data is available, it is often not representative of the weather conditions on Rocky Mountain Power's (RMP) infrastructure due to the sparsity of data and the complexity of Idaho's topography. Data from weather stations maintained by RMP are calibrated annually and repaired quickly if equipment malfunctions, thus increasing the reliability of the information. Additionally, RMP's weather station data is updated every 10 minutes, while publicly available weather data may have significantly longer update intervals. Many RMP weather stations also have the ability to update every 30 seconds during events that must be monitored closely, in real time. In addition to being a critical real time situational awareness tool, historical data from weather stations has beneficial applications as well. Historical data contributes to improving the accuracy of computer-generated weather forecast models through machine learning and artificial intelligence for both publicly owned weather models and RMP's in- house weather model. Climatological wind gust percentiles are also calculated using historical weather station data. Correlating these percentiles to the historical frequency of impacts to infrastructure provides insight into the severity of weather conditions that local infrastructure can withstand. Weather station locations were chosen based upon an area's wildfire risk, gaps in publicly owned weather station data and in especially wind-prone areas. Budget and actual cost for the 21 installed stations is shown below. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 77 Installation Year QTY Project Number Budget Actual (APR) Cost Idaho Weather 11 DIDA/2021/C/004 $200,657 $ 168,934 Stations(2022) Idaho Weather 10 DREX/2023/C/001 $251,988 $ 175,515 Stations(2023) Recordholder: Alex Vaz/Chris Walsh Sponsor: Joshua Jones/Allen Berreth PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 78 IPUC Data Request 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. Response to IPUC Data Request 78 (a) As described in Section 1.2 (pp. 13-18) of its 2024 Wildfire Mitigation Plan (WMP), Rocky Mountain Power(RMP) relies on FireSight, a module in Technosylva's Wildfire Analyst Enterprise (WFA-E) software suite, to perform risk evaluation. Additionally, as described in Section 5.4 (pp. 44-48), the Company also relies on two seasonal wildfire models (included in Technosylva's Wildfire Analyst Enterprise (WFA-E)), FireCast and FireSim, to forecast the risk and potential behavior of wildfire, should one occur. (b) When the Company chose to implement Technosylva's WFA-E software, it was the only solution proven to be capable of combining high-resolution weather forecast data, fuels data, and advanced wildfire modeling to identify circuits of greatest wildfire risk and consequence. For that reason, RMP was unable to consider any potential alternatives. (c) Not applicable. RMP obtained a sole source agreement for the services provided by Technosylva. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 78 Recordholder: Chris Walsh Sponsor: Allen Berreth PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 80 IPUC Data Request 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: 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. Response to IPUC Data Request 80 The $14,095,831 is total Company. The Idaho allocated amount is $763,097 calculated using Idaho's system generation (SG) allocation factor of 5.4136 percent. (a) The Snyderville-Park City 46 kilovolt(kV) transmission line is in the fire high consequence area(FHCA). Review of existing assets concluded that the line requires reconstruction due to age (average pole age is 44 years; conductor PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 80 age is 53 years) to mitigate the risk of a failure that might result in ignition of a wildfire. No communications link exists between the Snyderville and Park City substations. Existing protection and control may not operate fast enough to clear a high-impedance fault before it damages conductor to the point that it falls to the ground and potentially ignites a wildfire. (b) No viable alternatives exist for this need. (c) A request for proposal (RFP)was sent out to all line service agreement(LSA) contractors. i. Please refer to Confidential Attachment IPUC 80, specifically confidential folder"CY'which provides the cover letter and RFP ii. This was bid out through Jaegger as per Pacificorp standards. iii. LSA evaluation sheet attached. iv. Titan Electric pricing schedule attached. (d) Please refer to the Company's responses to subparts i. through vi. below: i. Please refer to Confidential Attachment IPUC 80, specifically confidential folder"D.I"which provides the Planning and Scoping Review and Approval Team(PSRAT) scope. ii. Initial Project Budget: $10,969,392. Appropriation request(APR) 94012456 and+-10 percent estimate. iii. Actual to date spend is $14,643,015, forecasted to be completed at $14,713,537. iv. APR 94013598 was approved on May 31, 2023 changing the project in service date (ISD) from November 30, 2022 to November 30, 2023. The project was substantially completed on November 13, 2023. V. Approved APR 94012456. SAP routing report for APR 94012456. vi. APR 94013598 was approved on May 31, 2023 increasing the project funding from $10,969,392 to $15,430,582 to account for the additional construction costs associated with undergrounding all the distribution and higher than originally estimated material and external services. PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 80 APR 94013598. vii. APR 94013598 was approved on May 31, 2023 changing the project in-service date from November 30, 2022 to November 30, 2023 to align with the revised distribution design schedule moving from overhead to underground as well as the additional permitting and rights of way (ROW)required for the change from overhead to underground distribution. The project was substantially completed on November 13, 2023. APR 94013598. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of Procedure No. 67—Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement(NDA) executed in this proceeding. Recordholder: Thomas Turner Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 81 IPUC Data Request 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. No viable alternatives exist for this need. (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: 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. Response to IPUC Data Request 81 The $10,659,021 is a total Company number. The Idaho allocated amount is $577,041 calculated using Idaho's system generation(SG) allocation factor of 5.4136 percent. (a) Issue 1: The 46 kilovolt(kV) oil circuit breakers at Columbia substation pose a wildfire ignition risk due to age (65 years), increased time that it takes to PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 81 open the breaker for a fault and the additional risk associated with an oil spill in the case of a catastrophic failure. Issue 2: Both the Columbia—Coal Creek#1 and#2 46kV transmission lines have an average of 40 years old which meets the age criteria for wildfire mitigation of needing replacement to mitigate wildfire ignition risk. Issue 3: Currently the 46 kV transmission line relays at Coal Creek and Columbia Substations on the Columba—Coal Creek#1 and#2 lines are electromechanical and do not provide fault location. Issue 4: There is no communications link between Coal Creek and Columbia substations currently. Issue 5: The current 138 kV transmission line relays at Columbia substation for the Columbia—Sunnyside Gen and Columbia—Mounds lines need replaced due to not being able to provide fault location and having a possible failure risk due to age. Issue 6: The distribution breaker 11 Distribution Protection Unit(DPU) relay has a significant failure rate that results in the relay not tripping the breaker in the case of a fault. (b) No viable alternatives exist for this need. (c) Only Columbia Sub portion was bid out. Rebuilding Coal creek-Mathington & Columbia-Coal lines were done internally. I. Please refer to Confidential Attachment IPUC 81-1 which provides a copy of the request for proposal (RFP), (2.1 RFP & 1.1 Cover letter RFP). II. This was bid out through Jaegger as per Pacificorp standards. III. Please refer to Attachment IPUC 8 1-1 which provide the Line Service Agreement (LSA) evaluation sheet. IV. Please refer to Attachment IPUC 8 1-1 which provide the Pricing Schedule. (d) Please refer to the Company's responses to subparts I. through VII. below: I. Please refer to Confidential Attachment IPUC 81-2 which provide the Planning and Scoping Review and Approval Team (PSRAT) attached II. $ 11,120,094 (PSRAT Estimate) III. $ 10,861,912 (actual to date),Forecasted to be completed at $ 10,917,269 PAC-E-24-04/Rocky Mountain Power August 9, 2024 IPUC Data Request 81 IV. PCN 94012546 was approved on May 2, 2022 changing the project In Service Date (ISD) from December 31, 2022 to December 31, 2023. Project was substantially completed by February 1, 2024. Delay for over a year was due to Permitting (Environmental Assessment needed to be approved by the United States (U.S.) Bureau of Land Management(BLM)) and material delays (conductor for Columbia-Coal creek line was delayed by over a year). V. Approved PCN 94012546 uploaded. SAP routing report uploaded. VI. Saving from budget to actual costs are due to using internal crews for transmission work. VII. PCN 94012546 was approved on May 2, 2022 changing the project ISD from December 31, 2022 to December 31, 2023. Project was substantially completed by February 1, 2024. Delay for over a year was due to Permitting (Environmental Assessment needed to be approved by BLM) and material delays (conductor for Columbia- Coal creek line was delayed by over a year). Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of Procedure No. 67—Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement(NDA) executed in this proceeding. Recordholder: Thomas Turner Sponsor: To Be Determined