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