20240813PAC to Staff 119-129 Set 7.pdf

RECEIVED
Tuesday, August 13,
2024 IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 13, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
monica.barrio ssanchez(apuc.Idaho.gov
S ecretarygpuc.idaho.gov
RE: ID PAC-E-24-04
IPUC Set 7 (119-129)
Please find enclosed Rocky Mountain Power's Responses to IPUC 7th Set Data Requests 119-
129. Also provided are non-confidential Attachments IPUC 119 and 129. Provided via BOX are
Confidential Attachments IPUC 120, 123, 124, 135, and 126. 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 elo(&echohawk.com(C)
Lance Kaufman/IIPA lancekae.isg insi hg t.com(C)
Matthew Nykiel/ICL matthew.nykiel&amail.com
Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org
Thomas J. Budge/Bayer ti(&racineolson.com(C)
Brian C. Collins/Bayer bcollins(&consultbai.com
Greg Meyer/Bayer gmeyerkconsultbai.com
Kevin Higgins/Bayer khig gins kenergystrat.com(C)
Neal Townsend/Bayer ntownsendkenergystrat.com (C)
Ronald L. Williams/PIIC rwilliams(&hawleytroxell.com

RECEIVED
DAY, MONTH DD, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Brandon Helgeson/PIIC bhelReson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinskmwanalytics.com
Val Steiner/PIIC val.steiner(a-)itafos.com
Kyle Williams/PIIC williamsknasbyui.edu

RECEIVED
DAY, MONTH DD, 2024
PAC-E-24-04/Rocky Mountain Power IDAHO PUBLIC
August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 119
IPUC Data Request 119
Company witness Steward details the proposed Catastrophic Fire Fund with an
annual Idaho contribution of$11.1 million. Steward Direct at 49. Please provide
the supporting workpapers that detail the allocation of contributions over the 10-
year period. Additionally, please provide justification of the Company's initial
target level of$3 billion.
Response to IPUC Data Request 119
The $11.1 million annual Idaho contribution to the Catastrophic Fire Fund is a
proposal put forth by the Company as a possible allocation of the customer
contributions to the fund. The proposed$3 billion targeted level of the fund is an
estimate for discussion and will ultimately be informed by underlying insurance
coverage and analysis of potential risk in PacifiCorp's states. The Company
continues to work with stakeholders in the multi-state workshop process to further
evaluate the size and allocation of the fund.
Please see Attachment IPUC 119 for the calculation of the proposed annual Idaho
contribution of$11.1 million identified in the testimony of Company witness
Joelle R. Steward, including the allocation factors found in Table 6 and Table 7 in
Ms. Steward's testimony. The allocation factor in Table 7 was used to calculate
the $11.1 million.
Recordholder: Shelley McCoy
Sponsor: Joelle Steward

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August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 120
IPUC Data Request 120
If the Company completed a cost-benefit analysis for the Company's proposed
Catastrophic Fire Fund, please provide a copy of the cost-benefit analysis.
Response to IPUC Data Request 120
The Company has not completed a cost-benefit analysis for the proposed
Catastrophic Fire Fund. However,please see Confidential Attachment IPUC 120
for a presentation by the Brattle Group from the June 2024 multi-state stakeholder
wildfire workshop which discusses loss scenarios and coverage strategies.
Recordholder: Shelley McCoy
Sponsor: Joelle Steward

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PAC-E-24-04/Rocky Mountain Power IDAHO PUBLIC
August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 121
IPUC Data Request 121
Please provide the non-economic liability limitations in each of the states the
Company operates in. Please explain how the Company's allocation of
Catastrophic Fire Fund expenses incorporates the non-economic liability
limitations of each state.
Response to IPUC Data Request 121
PacifiCorp objects to this request to the extent it seeks legal analysis, opinions,
and/or conclusions. Subject to and without waiving the foregoing objection, the
Company responds as follows:
The allocation proposed in the Company's direct filing of this rate case does not
incorporate the non-economic liability limitations of each state. However, on
March 13, 2024,Utah Governor Spencer Cox signed into law Senate Bill 224,
which in part enacted new Utah Code § 54-24-301, which establishes a cap on
non-economic damages. For ongoing discussions regarding allocation of the
Catastrophic Fire Fund, the Company believes the different state liability laws are
a key consideration for the relative risks of liability across states and therefore
should be considered for allocations.
Recordholder: Shelley McCoy
Sponsor: Joelle Steward

RECEIVED
DAY, MONTH DD, 2024
PAC-E-24-04/Rocky Mountain Power IDAHO PUBLIC
August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 122
IPUC Data Request 122
Table 8 in Company witness Steward's testimony estimated 2025 Idaho allocated
insurance premiums to be $9.8 million. Steward Direct at 58. Please provide
supporting documentation of the Company's new liability insurance premiums for
the 2024-25 policy year when available.
(a) Additionally, please explain if the Company's proposed insurance rider is
expected to adjust on an annual basis.
Response to IPUC Data Request 122
The Company does not have an update on the new liability insurance premiums
for the 2024-25 policy, but will provide one once more information becomes
available.
(a) The insurance rider,or Insurance Cost Adjustment(ICA), as presented in this rate
case is proposed to recover the Company's commercial excess liability premiums
based on the August 2024 insurance renewal and the amortization of the approved
insurance deferral. The use of the ICA to support a potential insurance mechanism,
including when and how rates may be adjusted,will be addressed in a separate, future
filing.
Recordholder: Shelley McCoy
Sponsor: Joelle Steward

RECEIVED
DAY, MONTH DD, 2024
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August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 123
IPUC Data Request 123
Please provide the following documentation for the "Field Ai- Field Asset
Intelligence"project referenced in Production Request No. 15 —Attachment and
the "Field Ai-Field Asset Intelligence- GWD"projects referenced by Shelley E.
McCoy in Workpaper 8.5.3 —Major Plant Additions. If any of the information
requested below cannot be provided or is not available, please explain why it is
not available or cannot be provided.
(a) If these projects are different, please explain the difference between the two
projects.
(b) Please explain the large discrepancy between the cost in Production Request
and work paper.
(c) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.
(d) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company's economic analysis (costs and
benefits) comparing them.
(e) If a Request for Proposal (RFP) or Request for Quote (RFQ) was submitted,
please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
(f) Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence the Initial Project Plan and budget were approved at the
appropriate level.
(g) Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. ii. Baseline project budget broken down by Work-Breakdown
Structure ("WBS");

RECEIVED
DAY, MONTH DD, 2024
PAC-E-24-04/Rocky Mountain Power IDAHO PUBLIC
August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 123
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the
differences, the reason for the change, and provide evidence that
the changes were approved at the appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
(h) Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by
year;
ii. ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category
that is over 5%, please explain the reason for the differences and
provide evidence that the amount was approved at the appropriate
level; and
iv. Please explain any deviations in schedule from the baseline
construction schedule.
Response to IPUC Data Request 123
(a) Field Ai is the title of a program comprised of multiple projects initiated to
create workforce efficiencies and provide integrated asset information across
systems in the transmission and distribution (T&D) work and asset
management space. One of the projects included in Field Ai program is
Graphical Work Design (GWD).
(b) IPUC Data Request 15 asked for the dollar amount of each project closed to
plant in service in excess of$5 million from 2022 through 2024 to date. The
timing of the request included amounts from March 2022 through December
2024. The amount in McCoy's work paper 8.5.3 regarding GWD is the
forecast 2024 dollars to be in-service by December 2024.
(c) GWD Phase I provides a standardized GWD tool only, filling a gap which
became apparent during Phase 0 of the Maximo (AWM)program when it was
demonstrated that both MidAmerican Energy Company(ME)C and Nevada
Energy (NVE) utilize a GWD solution to enable designers to be more efficient
at creating compatible unit designs held within Maximo.
GWD Phase II integration with Maximo eliminates the need for a customized
solution utilizing a tabular design with costly throw away design features.
Additionally, Phase II addresses a large corporate risk by reducing the use of
multiple systems including PacifiCorp's critical and aging legacy mainframe
system RCMS, which was built in-house in 1994 and is near end-of life.

RECEIVED
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August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 123
RCMS along with the related FPI, Joint Use, and AFPR systems are becoming
obsolete and unable to provide the integration that PacifiCorp needs to quickly
adapt to Business Transformation customer requirements. GWD Phase II
reduces corporate risk by finalizing the obsolescence of the legacy RCMS
mainframe system as it relates to the graphical work design process.
(d) Berkshire Hathaway Energy Company (BHE) Information Technology (IT)
Revolution Review Process for PacifiCorp was reviewed and approved by the
BHE Transformation Steering Co on February 23, 2022. PacifiCorp signed the
contract on March 28, 2022 with SBS to deliver a fully integrated
AUD/Maximo solution. Alternatives that the company considered are
documented on page 5 of the approved ITR. Please refer to Confidential
Attachment IPUC 123 which provides a copy of the approval and supporting
Microsoft Excel file.
Approval for a non-compete award to Spatial Business Systems (SBS) AUD
solution which is the selected BHE standard for GWD. Please refer to
Confidential Attachment IPUC 123 which provides a copy of the
"[Requesting Approval] Non-compete for Graphical Work Design Solution
(SBS)".
(e) Initial project scope, budget, and scheduled are on page 2 of the approved
ITR. Initial Project Plan and budget were approved at the appropriate level.
APR Routing Status Report
APR Mnibm 18007PW
92REPEA9ME
APR 7— R—d Appover Name L. APR D—,ipboe
-ly APP—d id 18002200 Fi,Ld Ai-Fieltl Assel Inlelligerce Program
0. Appowd Dk 1bUo 18002200
0. Appoved AUee Berrelb 18002200
Qa Appavetl Mark Paul 18002200
�. Approvetl &nest K ... 18002200
�. Approved M.—Weems 18002200
0. Approved Nikki Koblika 18002200
[. Appro Nally K labri 18002200
�. Approved Ste/an Bird 18002200
�. Approved Nikki Koblika 18002200
�. Wiliam J Febrman 18002200
The Company's Chief Executive Officer((CEO) /President and Vice
President& Chief Information Officer approved the initial project plan
(MASTER PROFESSIONAL SERVICES CONTRACT) on 3/31/22.
(f) Baseline schedule—March 1, 2022 to June 1, 2023. Actual schedule—March
1, 2022 to December 27, 2024. Baseline project scope and budget breakdown
by work breakdown structure (WBS) provided below:

RECEIVED
DAY, MONTH DD, 2024
PAC-E-24-04/Rocky Mountain Power IDAHO PUBLIC
August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 123
2021 2026
MR P.r se[ GWD&Maximo 10 Dependent on each other for June
M.k-
2023 Go-Due
An
GISSysternoffn en[
Meexvr Mc wEc
ArcGIS Utilay NEnj2Lk UN Syste n of Record
NovHH Feb 2B-Jun 2
p Procurernem SDS ImplementaU
380 days
GWD Jan 10-An 26
Z AUD Upgrade/Imdem.
185 days
AUDIm ementation
u
3W days
SOS Implementation •Sequencing&Durafions are only
380 days suggestive and far representation
506 A{Y BOIM:Cammmetl
Represermtiw
2021 2021 2024
at t Q2 Q3 a, Q1 a 2024
vk 58S/GWD will be looking for regular check points&data
updates from Maxima Team to en wre alignment for SR
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Nar 26
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Feb 28 Nov 26 lun 17
Q Procurement ArcGtS utility Network Upgrade
Feb 28-Jur 30 200 days
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flepresentative
Project object Project object ObjectType Status Actual costs
Field Ai-Field Asset Intelligence CITB/2020/C/252 Project defin REL 7,625,844.09 USD
�-- Field Ai-Field Asset Intelligence CITB/2020/C/252 WBS element REL SETC 7,625,844.09 USD
L, GWD Tool CITB/2020/C/252/GWD WBS element REL AUC 7,625,844.09 USD
GWD Capital Phase 1-Tool CITB/2020/C/252/GWDC WBS element REL AUC SET 6,520,122.46 USD
P GWD Business Labor-Capital 348890 CO internal o REL SETC 594,210.47 USD
P GWD Vendor Costs-Capital 348891 CO internal o REL SETC 4,040,151.86 USD
P GWD IT Labor-Capital 348892 CO internal o REL SETC 1,216,530.98 USD
a GWD from BHE-Capital 348893 CO internal o REL SETC 0.00 USD
P Property Tax capitalizable 350424 CO internal o REL SETC 17,395.31 USD
P GWD HW/SW-Capital 350675 CO internal o REL GMPS SET 36,757.79 USD
GWD Capital Phase 2-Integration CITB/2020/C/252/GWDC2 WBS element CLSD AUC 0.00 USD
�1, GWD Business Labor-Ph 2 Cap 350665 CO internal o CLSD SETC 0.00 USD
P GWD Vendor Costs-Ph 2 Capital 350666 CO internal o CLSD SETC 0.00 USD
P GWD IT Labor-Ph 2 Capital 350667 CO internal G CLSD SETC 0.00 USD
0 GWD from BHE Ph 2-Capital 350668 CO internal o CLSD SETC 0.00 USD
GWD OMAG CITB/2020/E/252/GWDE WBS element REL 1,105,721.63 USD
�1, GWD Business Labor- OMAG 119440 CO internal o REL 1,033,097.72 USD
F GWD OMAG Vendor 254116 CO internal o REL SETC 45 853.00 USD
GWD IT Labor OMAG 254294 CO internal G REL SETC 26:770.91 USD

RECEIVED
DAY, MONTH DD, 2024
PAC-E-24-04/Rocky Mountain Power IDAHO PUBLIC
August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 123
Little to no deviation from the baseline project plan of project scope, budget,
and/or schedule—with the work provided by software vendor Spatial Business
Systems (SBS)—and the GWD program being approved for delivery within
two phases.
Detailed weekly status project status reports contain overall project health
(Budget, scope and scheduled). These reports can be found in the following
directory: GWD Phase 1 - Status Reports
No vendor change orders have been submitted/approved for work by Spatial
Business Systems (SBS). Spatial Business Systems are currently working with
PacifiCorp on the Rough Order of Magnitude (ROM) estimate for GWD
Phase 2.
(g) The baseline budget and project actuals appear below. (Cap SC and AFUDC
are not included.) The original estimated amounts for SBS/vendor deliverables
(budget-to-actual) did not deviate from the baseline project estimate.
Baseline Project Budget by Year
2021 2022 2023 2024 Totals
Capital $ 77 $ 1,437,131 $ 4,686,033 $ 575,433 $ 6,698,674
OMAG $ 21,900 $ 80,276 $ 71,350 $ 127,800 $ 301,326
$ 21,977 $ 1,517,407 $ 4,757,383 $ 703,233 $ 7,000,000
Actuals by Year(from SAP):
Project Actuals by Year
2024 Actuals
2021 Actuals 2022 Actuals 2023 Actuals to-date Totals
Capital $77 $1,240,463 $3,279,701 $2,114,881 $6,635,122
OMAG $21,900 $73,795 $7,117 $1,547,091 $1,649,903
$21,977 $1,314,258 $3,286,818 $3,661,972 $8,285,025
Project budget milestone payments (detailed in SAP and listed below) did not
deviate from the baseline budget estimates within the original statement of
work (or signed contract)with Spatial Business Systems (SBS).

RECEIVED
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PAC-E-24-04/Rocky Mountain Power IDAHO PUBLIC
August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 123
Schedule Deliverables Baseline Estimated Actual
Payments Completion Completion
MS1:Contract Execution $93,750.00 Mar-22 Mar-22
MS2-AUD Knowledge Transfer $46,875.00 Mar-22 Apr-22
MS3-Blueprint Architecture Document
$121,875.00 Apr-22 Jun-22
Delivered
M4-GLBL(HQ Design Workshops Complete $93,750.00 May-22 Oct-22
M5-GLBL(HL) Design Documents Delivered $93,750.00 Jun-22 Oct-22
M6-WIP#1 Demonstrated & Delivered $159,375.00 Jul-22 Dec-23
M7-WIP#2 Demonstrated & Delivered $159,375.00 Aug-22 Feb-23
M8-WIP#3 Demonstrated& Delivered $159,375.00 Oct-22 May-23
M9-WIP#4(E2E) Demonstrated& Delivered $159,375.00 Nov-22 Jun-23
M10-SIT Start $187,500.00 Jan-23 Oct-23
M11-SIT Complete $150,000.00 Mar-23 Feb-24
M12-UAT Start $150,000.00 Apr-23 Feb-24
M13-UAT Complete $187,500.00 May-23 Jul-24
M14-Initial Training Material Delivered $37,500.00 May-23 Dec-23
M15-End User Training Complete $18,750.00 Jun-23 Feb-24
M16-Ad Training Complete $18,750.00 Jul-23 May-24
M17—HyperAdmin Complete $18,750.00 Jul-23 —
The project budget to actuals deviated from the baseline project plan in 2024 primarily
due to:
• Significant increased OMAG charges during the training phase of the project
were incurred due to all estimators charging their training time to the project.
(This OMAG had not been budgeted for the project but is charged back to each
respective department.)
• Increased internal Labor from BHE IT support due to revised Business
Transformation schedule leading to the two-phase delivery approach.
• Internal labor from PacifiCorp estimators due to revised BHE IT Business
Transformation schedule leading to the two-phase delivery approach.
• Underestimation of network capabilities required to support the application for
estimator laptops (additional RAM, for example).
• Increase in software license costs due to increased number of contract labor
estimators being onboarded as part of wildfire mitigation work efforts.
The following are the primary reasons for the deviations in schedule from the baseline:
• Increased time was required to allow the vendor to address project complexity and
meet completion targets.
• Increased time required from both business and IT to address unforeseen technical
issues (network bandwidth capabilities, for example).

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August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 123
• Increased time from both business and IT to develop a phased approach which
was required due to BHE IT Business Transformation schedule modifications.
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: Dan Ryan
Sponsor: TBD

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August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 124
IPUC Data Request 124
Please provide the following documentation for the "Palantir Foundry"project
referenced in response to Production Request No. 15 and by Shelley E. McCoy
in Workpaper 8.5.3 —Major Plant Additions. If any of the information requested
below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
(a) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.
(b) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company's economic analysis (costs and
benefits) comparing them.
(c) If a RFP or RFQ was submitted, please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
(d) Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence the Initial Project Plan and budget were approved at the
appropriate level.
(e) Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the
differences, the reason for the change, and provide evidence that
the changes were approved at the appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.

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August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 124
(f) Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by
year;
ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category
that is over 5%, please explain the reason for the differences and
provide evidence that the amount was approved at the appropriate
level; and
iv. Please explain any deviations in schedule from the baseline
construction schedule.
Response to IPUC Data Request 124
(a) Wildfire is one of PacifiCorp's greatest risks. Further, this wildfire risk is
projected to increase due to changes in the climate and the expansion of the
Wildland-Urban Interface. As part of mitigating this risk, PacifiCorp may
execute public safety power shutoffs (PSPS) across its service territory with a
higher likelihood of shutoffs in California, Oregon, Washington, and Utah.
Performing a PSPS safely, on time, and in compliance with differing state
regulatory requirements requires complex coordination between departments
including emergency management, operations, customer service, public affairs
and legal with executive-level oversight and decision-making. Similar cross-
functional coordination is required for identifying areas of concern for
Elevated Fire Risk(EFR) settings enablement and tracking. In addition, data
management for post-event reporting, quarterly (QDR), and annual wildfire
related regulatory filings were primarily manual and ad hoc, increasing the
risk of errors and delays in achieving compliance. PacifiCorp had a limited
ability to integrate data and information from separately managed existing
systems into a single application for operational planning and decision-
making.
Palantir Foundry utilizes existing functionality to integrate data across
multiple separate systems into a common operational picture for real-time
decision-making during periods of extreme fire risk, data retention and
tracking, and regulatory reporting. This includes using a high-performance
cloud computing architecture integrated with existing PacifiCorp software and
databases. Foundry has helped reduce errors due to operational planning and
execution, data loss, and noncompliance with regulatory requirements related
to PSPS and wildfire mitigation and was analyzed to be the best solution to
allow PacifiCorp to successfully execute its wildfire mitigation plan.
Currently in use at other utilities for this purpose, Foundry's capabilities
include (1) the ability to integrate, analyze, and display weather forecasts
overlaid with existing electric asset information and system status to show
areas of concern, current system status, and other PSPS and EFR related

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IPUC Data Request 124
information; (2) creation, execution, and tracking of customer notification
campaigns for PSPS; (3) creation and publishing of PSPS event information;
(4) data retention and management for PSPS event reporting, (5) identifying
and tracking EFR settings enablement including outages, and(6) data
retention and management for recurring wildfire safety regulatory reporting
and data requests.
Failure to implement Palantir Foundry would also leave PacifiCorp behind
industry best practices. PacifiCorp invested in Palantir Foundry to safely
navigate future fire seasons, enhance operational decision making, and ensure
compliance with regulatory reporting standards.
(b) Palantir is the only known provider of mission-critical wildfire risk mitigation
software capabilities in Foundry for PSPS event management, EFR settings
management, and compliance reporting for wildfire mitigation. Foundry will
provide essential data integration, management, and validation capabilities to
support operational decision-making for PSPS events, EFR program
management, and regulatory reporting. The automation will reduce manual
errors and process delays to enable timely, accurate, and compliant execution
of these public safety programs. Foundry is a proven solution fully
implemented at the three California-based investor-owned utilities (IOU) and
is recognized by the California Public Utilities Commission (CPUC) as a
critical component of any successful Wildfire Mitigation Plan (WMP).
(c) PacifiCorp selected Palantir without conducting a competitive bidding process
because it is the only known provider of the mission-critical wildfire risk
mitigation information technologies capabilities for PSPS event management,
EFR settings, and compliance reporting for wildfire mitigation. Palantir
Foundry will provide essential data integration, management, and validation
capabilities, which will reduce manual errors and process delays to enable
timely, accurate, and compliant execution of PacifiCorp's public safety
programs.
(d) Please refer to the Company's responses to subparts i. through iv. below:
i. Please refer to Confidential Attachment IPUC 124, specifically Exhibit A
— SCOPE OF WORK, Pages 3-6 n the Palantir Foundry-MSA-
EXECUTEDCONTRACT.
ii. Please refer to the table below for the initial project budget:
Item Year 1 Year 2 Total
Subscription $4.OM $4.OM $8.OM
Professional Services $3.OM $3.OM $6.OM

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August 13, 2024 UTILITIES COMMISSION
IPUC Data Request 124
Item Year 1 Year 2 Total
Cloud Infrastructure(Variable cost
based on usage) $0.15M $0.15M $0.30M
Total $7.15M $7.15M $14.30M
iii. Please refer to the table below for the initial proposed schedule:
Activity Due Date
Project Authorization&Funding June 9,2023,
Project Kickoff June 12,2023,
Release 1 -Backend&Fire Season Tools November 30,2023,
Release 2-Expanded EFR and PSPS Tools May 30,2024,
Release 3 -Expanded Reporting Tools March 28,2025,
Project Closure I Aril 30,2025,
iv. Please refer to Confidential Attachment IPUC 124, specifically "Palantir
Foundry APR 24022686"which is a copy of the executed appropriations
request(APR)which includes the sponsoring executive approver.
(e) Please refer to the Company's responses to subparts i. through vi. below:
i. Please refer to the Company's response to subpart (d) (i) above.
ii. Please refer to the Company's responses below for the baseline project
budget broken down by work breakdown structure (WBS)
• Duration - The contract duration is five years, and the cost negotiated
covers the initial two years. Costs for the remaining three years will be
negotiated as part of the next statement of work. The project is split into
three releases. All three releases will go live within the first two years of
the contract's duration for which we have negotiated costs.
• Software subscription - The annual subscription cost covers the use of the
software and is not tied to any modules or functionality deployment. The
Year 1 subscription cost of$4 million for the billing period May 17, 2023
through May 16, 2024, will be paid in June 2023. The Year 2 subscription
cost of$4 million for the remaining period will be paid in June 2024.
• Implementation/professional Services - The professional services work is
fixed price/cost for the development work Palantir will be doing within the
software. The cost for this is $3 million for Year 1 (which covers Release
1 and Release 2) and$3 million for Year 2 (which covers Release 3) and

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IPUC Data Request 124
will be invoiced monthly in arrears.
• A $14 million liability will be booked for the two years of both the
subscription costs and professional services costs. After each annual
subscription invoice and monthly professional services invoices are paid
to Palantir, the liability will be relieved. The software can be used after the
release 1 implementation go-live (November 30, 2023) at which time the
allocable portion of Year 1 subscription costs, along with associated
professional services costs, will be placed into service.
• The project will have one WBS per release and one WBS for subscription
and professional service costs. Each release will be separately placed into
TECO status after it goes live.
WBS Year 1 Year 2 Total
DSYS/2023/C/001/LIAB $4.OM $4.OM $8.OM
DSYS/2023/C/001/REL1 $1.6M $1.6M
DSYS/2023/C/001/REL2 $1.6M $1.6M
DSYS/2023/C/001/REL3 $3.1M $3.1M
Total $7.2M $7.1M $14.3M
iii. Baseline project schedule broken down by the WBS:
WBS Activity Date
DSYS/2023/C/001/REL1 Project Authorization&Funding,Project Kickoff,
Release 1 -Backend&Fire Season Tools November 30,2023
DSYS/2023/C/001/REL2 Release 2-Expanded EFR and PSPS Tools May 31,2024
DSYS/2023/C/001/REL3 Release 3-Expanded Reporting Tools,Project
Closure Aril 30,2025
iv. The baseline construction project scope, budget and/or schedule did not
deviate from the initial project plan.
V. June 2023 through December 2023 Accomplishments:
• Backend and fire season tools:
o Backend data integration and system architecture
o Data ontology build.
o PSPS customer notifications
o EFR settings management
o QDR for outages and vegetation management
o Training for system owners and users

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January 2023 through May 2024 Accomplishments:
• Expanded wildfire safety tools:
o Refinement of data ontology
o EFR customer notifications, engineering device settings
management and updates for Rocky Mountain Power.
o Fire Encroachment Analytics (tracking and monitoring)
o PSPS meteorology tools, AFN manual call integration for
customer notifications and operational dashboard
o Outage management (outage investigations and corrective actions)
o Training for new users
o Sustainment planning and support model establishment
June '2024—Current Accomplishments:
• Expanded wildfire safety tools:
o Continued refinement of data ontology
o Fire Encroachment Analytics customer notifications and reporting.
o Updated PSPS meteorology tools, and campaign approval
workflow
o Training for new users
vi. Palantir issued Order#2 pursuant to the original contract. The scope of
services includes Foundry Use Case Maintenance (Application Technical
Maintenance and Data Pipeline Management).
(f) Please refer to the Company's responses to subparts i. through iv below:
i. The project is in progress currently. Actual-to-budget comparison by WBS
will be available upon project completion at the end of June 2025.
ii. Please refer to the table provided below:
Baseline
WBS Activity Construction Actual Schedule
Schedule
Project Authorization&Funding,Project
DSYS/2023/C/001/REL1 Kickoff,Release 1 -Backend&Fire Season November 30,2023 November 22,2023
Tools
DSYS/2023/C/001/REL2 Release 2-Expanded EFR and PSPS Tools May 31,2024 May 30,2024
DSYS/2023/C/001/REL3 Release 3 -Expanded Reporting Tools, April 30,2025 Not Available
Project Closure

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iii. The project is in progress currently. Actual-to-budget comparison by WBS
will be available upon project completion at the end of June 2025.
iv. There have been no schedule deviations. The actual schedule for activities
in REL 1 and REL2 were ahead of the baseline construction schedule.
Please refer to baseline construction schedule-to-actual comparison by
WBS.
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: Chase Talbot/Anusha Ananthanarayanan
Sponsor: Shelley E. McCoy

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IPUC Data Request 125
IPUC Data Request 125
Please provide the following documentation for the "Eng Telecom: OTLM- T 1
project" and the "OT Lease Modernization - T1 Circuits"referenced by
Shelley E. McCoy in Workpaper 8.5.3 —Major Plant Additions. If any of the
information requested below cannot be provided or is not available, please explain
why it is not available or cannot be provided.
(a) Please explain the difference between the two projects.
(b) Please provide a detailed explanation for the need of the projects including the
analysis justifying the need.
(c) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the projects were selected among the
alternatives supported by the Company's economic analysis (costs and
benefits) comparing them.
(d) If a RFP or RFQ was submitted, please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
(e) Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence the Initial Project Plan and budget were approved at the
appropriate level.
(f) Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the
differences, the reason for the change, and provide evidence that
the changes were approved at the appropriate level;
V. Project status reports and action items; and

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vi. Contractor change orders.
(g) Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by
year;
ii. ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category
that is over 5%, please explain the reason for the differences and
provide evidence that the amount was approved at the appropriate
level; and
iv. Please explain any deviations in schedule from the baseline
construction schedule.
Response to IPUC Data Request 125
(a) These are the same project with slight variation in naming. This is the official
2023 project with funding extending into 2024. Please refer to Confidential
Attachment IPUC 125 which provides the following documents:
• OT Lease Modernization - T1 Circuits
• APR: 24022456
• WBS: DZPO/2023/C/017
(b) Beginning in 2002 local exchange carriers (LECs), specifically AT&T, began
petitioning the FCC for a rulemaking on Business Data Services (BDS -
Formerly known as Special Access Services)pricing. In 2005 the Federal
Communication Commission (FCC) opened its initial BDS proceeding with a
Report and Order and Notice of Proposed Rulemaking to examine whether
and how to remove price caps on LECs' access services from price cap and
tariff regulation once they are subject to substantial competition. Since then,
the commission has increasingly granted pricing flexibility, forbearance, and
relief from ex ante pricing regulation and tariffing requirements for many
incumbent LECs' BDS offerings.
In support of electric system operations, PacifiCorp utilizes approximately
140 leased TV services to transport, voice and data between substations,
communications facilities, and system control centers. Under the previously
discussed FCC rulemaking those aforementioned T1 services are now at risk
for degraded service/support, escalating lease costs, and outright
disconnection. As seen by other affiliates of BHE, disconnection notice can be
as little as 90 days.
' T1 is a telephone data service provided over twisted copper pairs or fiber optic infrastructure to support
either 24 voice channels or 1.54 mbps of data.

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It was determined that the best path forward would be to migrate lease service
from T 1 to ethernet private line. The alternatives considered would be to build
private fiber or microwave radio. Microwave radio can cost anywhere from
$150,000 to $2,000,000 per link to add to an existing site or to build two new
sites. As well, timing can range between 9 months to 24 months to complete
the work assuming no major permitting processes (like NEPA or CEQA) are
required. Private fiber can start around $50,000 per mile and exceed$200,000
per mile depending on requirements for structure replacements. Likewise,
timing to build a new route is likely to exceed two or three years as a best case
for any significant buildout. As most of these leases are used to span large
geographic areas, the least cost approach was to utilize carrier circuits unless
there was a simple private infrastructure solution available that would be more
cost effective. Approach was reviewed on a circuit by circuit basis. In general,
commercial cellular and satellite are not feasible options due to the inherit
latency associated with those technologies and the technical timing
requirements of the services being supported by the existing circuits
(c) As discussed in narrative section B the company review the use of commercial
ethernet private line lease, private fiber, private microwave, cellular, satellite
and "do nothing". A combination of solutions has been deployed under this
initiative. The primary focus of the project has been to deploy ethernet private
line leases from Local Exchange Carriers (LECs). This approach is the least
cost solution in comparison to building private infrastructure, however not all
endpoint locations have circuit offerings from the LECs. Also, most new
circuits require some network buildout costs to extend fiber from the nearest
point of presence to our facility. One lease was deemed acceptable to move to
cellular, no leases have currently been moved to satellite. Do nothing, is not a
viable solution when it comes to the potential risk to reliable operations if the
LEC were to issue a notice of intent to disconnect and posses significant
financial risk of the carrier continuing to escalate lease rates.
(d) Please refer to the below responses:
i. Please refer to Confidential Attachment IPUC 125 which provides a copy
of OTLM RFP-SOW
ii. Vendor selection for the replacement service is unique to each individual
location being addressed as well as the telecom regulation governing such
carrier/provider franchises. Vendor labor to assess and design
replacement solutions is ongoing through existing contractor firm"World
Wide Technologies" (WWT).
iii. Not Applicable
iv. Please refer to Confidential Attachment IPUC 125 which provides a copy
of R-00756067 BHE OT Telecom Modernization
(e) Please refer to Confidential Attachment IPUC 125 which provides the
following documents:

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i. "Project Proposal—OTLM-TI—IAD"and "T1 Circuit List"
ii. "APR 24022456—OT Lease Modernization—T1 Circuits"
iii. "Project—Proposal—OTLM-TI—IAD": Section 11.
iv. "APR Approval Record"
(f) Primarily this project was scoped to focus on engineering and procurement of
materials, construction would be executed by third party service providers on
their basis of need. No baseline construction plan was created. It was largely
unknown which replacement circuits would require construction and the
LEC's ability to complete the construction.
(g) Please refer to the below responses for subparts (i) to (iv):
i. 2023 Plan: $3,827,457 Actual: $478,610
2024 Plan: $2,080,619 YTD Actual: $909,852
ii. Due to several factors including delays in project initiation, slow
responses from the local exchange carriers, and their construction delays,
the project is not maintaining the planned schedule. LEC circuit turn-ups
will likely extend into 2025 with internal labor to follow. As well, since
the LECs have been unable to provide ethernet private line services to all
of the requested locations, additional follow-on projects be required to
implement alternative solutions including private fiber and microwave
buildout.
iii. This project is currently underspent by 76.5%
iv. Please refer to the Company's response to subpart(g) (ii) 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
Procedure No. 67—Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA)executed in this proceeding.
Recordholder: Joseph Leineweber
Sponsor: TBD

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IPUC Data Request 126
IPUC Data Request 126
Please provide the following documentation for the "PAC FIPS 201 Pinnacle
Repl"project referenced by Shelley E. McCoy in Workpaper 8.5.3—Major Plant
Additions. If any of the information requested below cannot be provided or is not
available, please explain why it is not available or cannot be provided.
(a) Please explain why the PAC FIPS 201 Pinnacle Repl project was not included
in the Company's response to Production Request No. 15.
(b) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.
(c) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company's economic analysis (costs and
benefits) comparing them.
(d) If a RFP or RFQ was submitted, please provide the following information:
(a) A copy of the RFP or RFQ that was submitted;
(b) A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
(c) The short-list bidder scorecard; and
(d) A copy of the winning bid.
(e) Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence the Initial Project Plan and budget were approved at the
appropriate level.
(f) Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the
differences, explain the reason for the change, and provide
evidence that the changes were approved at the appropriate level;
V. Project status reports and action items; and

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vi. Contractor change orders.
(g) Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by
year;
ii. ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category
that is over 5%, please explain the reason for the differences and
provide evidence that the amount was approved at the appropriate
level; and
iv. Please explain any deviations in schedule from the baseline
construction schedule.
Response to IPUC Data Request 126
(a) IPUC Data Request 15 was a schedule of January 2022 through May 2024
plant in service additions by project for those greater than $5 million. The
"PAC FIPS 201 Pinnacle Repl"project is not completed and remains in FERC
Account 107 (Construction Work-in-Progress).
(b) PacifiCorp's existing Physical Access Control System(PACS) is antiquated,
has inherit security vulnerabilities that cannot be remediated using the existing
system, and no longer meets Berkshire Hataway Energy Company (BHE)
security standards.
The "PAC FIPS 201 Pinnacle Repl"project is required per BHE Information
Security Policy 210.1.2 Physical Access Control Systems mandate: Newly
acquired or upgraded Physical Access Control Systems must meet or exceed
the system specifications of the National Institute of Standards and
Technology Federal Information Processing Standard (FIPS) 201 Personal
Identity Verification (PIV) of Federal Employees and Contractors.
Physical Access Control to PacifiCorp facilities is critical for employee safety
and continuity of business operations. Insuring only authorized personnel
access CIP critical areas, information technology (IT) critical areas,
designated control areas, generation sites, and business facilities is driving this
technology upgrade for PacifiCorp. The current Pinnacle PACS is antiquated,
can be defeated by credential cloning techniques, and is not capable of
complying with BHE Information Security Policy: 210 Physical Security
Controls Policy. 210.1.2. which requires Physical Access Control Systems to
meet or exceed the system specifications of the National Institute of Standards
and Technology Federal Information Processing Standard (FIPS) 201-2
Personal Identity Verification (PIV) of Federal Employees and Contractors.

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(c) Alternatives were reviewed extensively during the request for information
(RFI) process. RFI participation was not limited to PACS integrators, a full
spectrum of PACS solutions were sought, evaluated, and demonstrated. There
were seven total RFI responses from five separate respondents yielding
evaluations of the following PACS solutions: Honeywell Pro-Watch, Lenel
OnGuard, Software House C-Cure, and Genetec Security Center. RFI
responses were highly informative and formed the basis for request for
proposals (RFP) requirements.
The RFP provided PACS integrators an opportunity to provide proposals on a
PacifiCorp PACS replacement system utilizing the Genetec Security Center
solution. Four PACS Integrators participated in the RFP process resulting in
an award to Cache Valley Electric.
(d) Please refer to Confidential Attachment IPUC 126 for the following
documents:
1) RFP -Access Control FIPS 201 RFI Summary
2) RFP -Access Control FIPS 201 RFI Conclusion
3) RFP - 1 - Scope of Work
4) RFP -Addendum PacifiCorp Use Case Matrix
5) RFP -Addendum- PacifiCorp Zone 3 and Zone 5 Design
6) RFP -Addendum- PacifiCorp Phase and Milestone Sheet
7) RFP -Addendum - PacifiCorp Federation and CMS Diagram
8) RFP -Addendum- PacifiCorp High Level SC CMS Plan Diagram
9) RFP -Addendum - PacifiCorp Network Switch Cabling Standard
A)RFP Requirements Response—Evaluation
B 1) RFP -WIN BID—AVTEC -Requirements Response
132) RFP -WIN BID - AVTEC - Statement of Work
B3) RFP - WIN BID—AVTEC -Risk Assessment
134) RFP -WIN BID—AVTEC - Phase and Milestone
135) RFP - WIN BID—AVTEC - TIMELINE
136) RFP - WIN BID—AVTEC - Pricing Schedule
137) RFP -WIN BID - AVTEC - Award Notification
(e) Please refer to Confidential Attachment IPUC 126 for the following
documents:
C) Initial Project Summary
D) Initial Project Approval - FIPS 201 APR input sheet
(f) Please refer to Confidential Attachment IPUC 126 for the following
documents:
E) PacifiCorp PACS Scope of Work

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F) PacifiCorp PACS Project Requirements
G) PACS Project Change Plan
H) Project Change Notice Approval -OO1f031f PRD
(g) Please refer to Confidential Attachment IPUC 126 for the following
documents:
G) PACS Project Change Plan
H) Project Change Notice Approval -OO1f031f PRD
Recordholder: Roger Aubry
Sponsor: TBD

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IPUC Data Request 127
IPUC Data Request 127
Please provide the following documentation for the PacifiCorp Accelerated RTU
Repl (PARR) project referenced in Production Request No. 15—Attachment.
If any of the information requested below cannot be provided or is not available,
please explain why it is not available or cannot be provided.
(a) Please explain why the PARR project was not included in the Company's
response to Production Request No. 15.
(b) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.
(c) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company's economic analysis (costs and
benefits) comparing them.
(d) If a RFP or RFQ was submitted, please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
(e) Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence the Initial Project Plan and budget were approved at the
appropriate level.
(f) Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the
differences, explain the reason for the change, and provide
evidence that the changes were approved at the appropriate level;
V. Project status reports and action items; and

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IPUC Data Request 127
vi. Contractor change orders.
(g) Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by
year;
ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category
that is over 5%, please explain the reason for the differences and
provide evidence that the amount was approved at the appropriate
level; and
iv. Please explain any deviations in schedule from the baseline
construction schedule.
Response to IPUC Data Request 127
(a) IPUC Data Request 15 was asking for projects over $5 million that had gone
into service from 2022 through May 2024. The" PacifiCorp Accelerated RTU
Repl (PARR)"project is not complete and would not have been included in
the Company's response to IPUC Data Request 15. Further, in preparing the
response for this request the Company identified that the project has been
reduced to an expected amount of$3.4 million which is below the $5 million
value of 2024 projects included in this general rate case (GRC). The Company
will remove this project in its rebuttal filing.
(b) The Company has identified this project has been reduced and will be
removed from the revenue requirement in this GRC in its rebuttal file.
(c) Please refer to the Company's response to subpart (b) above.
(d) Please refer to the Company's response to subpart (b) above.
(e) Please refer to the Company's response to subpart (b) above.
(f) Please refer to the Company's response to subpart(b) above.
(g) Please refer to the Company's response to subpart (b) above.
Recordholder: Craig Larsen
Sponsor: Shelley McCoy

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IPUC Data Request 128
IPUC Data Request 128
How does the Company rate contractors based on past experience?
Response to IPUC Data Request 128
Contractor instances of poor performance on past work or disputes are considered
and depending upon severity, may be cause for removal from the bid list or
contract termination in extreme situations.
Recordholder: Marion Stanwood
Sponsor: Marion Stanwood

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IPUC Data Request 129
IPUC Data Request 129
Please provide the Company's criteria for rating contractors.
Response to IPUC Data Request 129
The Company's criteria for rating contractors is unique to the specific goods
and/or services being procured and includes pricing as well as other criteria which
might include technical capabilities, specifications, cyber security, safety record
and programs, environmental programs, experience with providing similar
goods/services, etc. Please refer to Attachment IPUC 129 which provides a
sample evaluation matrix.
Recordholder: Marion Stanwood
Sponsor: Marion Stanwood