20240814Staff 175-204 to PAC.pdf

RECEIVED
Wednesday, August 14, 2024 1.06.48 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR ) CASE NO. PAC-E-24-04
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES IN IDAHO AND APPROVAL ) REDACTED TENTH
OF PROPOSED ELECTRIC SERVICE ) PRODUCTION REQUEST OF
SCHEDULES AND REGULATIONS ) THE COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that PacifiCorp d/b/a Rocky Mountain Power
("Rocky Mountain Power" or the "Company")provide the following documents and information
as soon as possible,but no later than WEDNESDAY,AUGUST 28, 2024.1
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0318.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 14, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulae intact and enabled.
REQUEST NO. 175: Please provide copies of, or access to, the 2023 and 2024
contracts for Union workers used to escalate payroll expenses referenced in Adjustment No.
4.2.4.
REQUEST NO. 176: Please provide the supporting documentation, including contracts
for the Company's Medical, Dental, and 401(k) expense shown on Page 4.2.6 of Exhibit No. 48.
REQUEST NO. 177: Please provide a copy of the Company's policy on employee
incentive pay that includes how target levels are established and how the final incentive amounts
are calculated. Please provide these metrics and other supporting documentation for the Annual
Incentive Plan payments in 2021 through 2023, as shown on Page 4.2.5 of Exhibit No. 48.
REQUEST NO. 178: Please provide supporting documentation for the pro forma
increases to retirement plans, benefits, disability insurance, and workers compensations shown
on Page 4.2.6 of Exhibit No. 48.
REQUEST NO. 179: Please provide a list of the Officer's salaries by office for years
2022, 2023, and 2024.
REQUEST NO. 180: Please provide the 2022, 2023, and 2024 Federal and State
employee withholding and unemployment reports.
REQUEST NO. 181: Please respond to the following regarding Tab "Emerg Purch+
Trapp Sales" of Excel File "ID_GRC_2025_2023 Normalized Load.xlsm".
a. Please define "Emergency Purchases".
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 14, 2024

b. Please explain how the MWh amounts of Emergency Purchases from Line 171 to
Line 218 are determined.
c. Please explain how the costs of Emergency Purchases from Line 61 to Line 108 are
determined.
d. Please explain the cost impact of Emergency Purchases on Net Power Costs.
e. If the cost impact is zero, please explain why it is zero. Also, if the cost impact is
zero, please confirm that the net expenses on Line 112 are not included in the
proposed Net Power Cost.
f. Please explain what Column "Discount/Premium"represents.
g. Please explain how"Discount/Premium" is used in the calculation of the costs of
Emergency Purchases.
REQUEST NO. 182: Please respond to the following regarding Tab "Schedule 34" of
Excel File "ID GRC 2025 2023 Normalized Load.xlsm".
a. Please explain what types of customers are under Utah's Schedule 34.
b. Please explain how the MWh amounts in Column C through Column J are
determined.
c. Please explain how the prices in Column R through Column U are determined.
d. Please explain whether the prices in Column R through Column U have been
approved by the Utah Commission.
e. Please explain what Line 21 through Line 27 represent.
f. Please explain how the values in Line 21 through Line 27 are determined.
REQUEST NO. 183: Please respond to the following regarding Tab "EIM"of Excel
File "ID GRC 2025 2023 Normalized Load.xlsm".
a. Please define "EIM Inter-regional Benefit ($)" and explain how the benefit values are
determined.
b. Please define "EIM Inter-regional Benefit(GHG Margin) ($)" and explain how the
benefit values are determined.
c. Please define "Wheeling -EIM Expense Booked to FERC 565" and explain how the
wheeling costs are determined.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 14, 2024

REQUEST NO. 184: Please respond to the following regarding percentile adders to
market purchase prices.
a. Please explain whether the Company purchases power and sells power at the same
OFPC in the Aurora model before the DART adjustment is applied.
b. Please identify specific hours and months in 2025 when large amounts of market
purchases are expected to occur and explain how the timeframes are determined.
c. Based on historical data, please explain the extent proposed percentile adders reflect
the correct direction of changes compared to reality during the timeframes when large
amounts of purchases occurred. (i.e. When prices should be adjusted downward,
proposed percentile adders result in lower prices; when prices should be adjusted
upward, proposed percentile adders result in higher prices.)
d. Based on historical data, please explain the extent proposed percentile adders reflect
the magnitude of adjustment that should occur compared to reality during the
timeframes when large amounts of purchases occurred. (i.e. Does the magnitude of
adjustment calculated under the percentile adder method reflect the magnitude that
needs to occur to match reality?)
e. Please re-run Aurora model to quantify the cost impacts on Net Power Cost if
proposed percentile adders only apply to the timeframes when large amounts of
market purchases are expected to occur in 2025.
REQUEST NO. 185: Please respond to the following regarding percentile adders to
market sale prices.
a. Please explain whether the Company proposes to apply percentile adders to market
sale prices in this case.
b. If yes,please explain why it is necessary. If not, please explain why not.
c. Please identify specific hours and months in 2025 when large amounts of market
sales are expected to occur and explain how the timeframes are determined.
d. Based on historical data, please explain the extent proposed percentile adders reflect
the correct direction of changes compared to reality during the timeframes when large
amounts of sales occurred. (i.e. When prices should be adjusted downward,proposed
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 14, 2024

percentile adders result in lower prices; when prices should be adjusted upward,
proposed percentile adders result in higher prices.)
e. Based on historical data, please explain the extent proposed percentile adders reflect
the magnitude of adjustment that should occur compared to reality during the
timeframes when large amounts of sales occurred. (i.e. Does the magnitude of
adjustment calculated under the percentile adder method reflect the magnitude that
needs to occur to match reality?)
f. Please re-run the Aurora model to quantify the cost impacts on Net Power Cost if
proposed percentile adders only apply to the timeframes when large amounts of
market sales are expected to occur in 2025.
REQUEST NO. 486: Please re-run Aurora model to quantify the impacts on Net Power
Cost if proposed percentile adders only apply to the timeframes when large amounts of market
purchases are expected to occur in 2025 and if proposed percentile adders only apply to the
timeframes when large amounts of market sales are expected to occur in 2025.
REQUEST NO. 187: Please respond to the following regarding market sales volumes
and revenues.
a. Please provide the MWh amount of market sales in 2025 calculated by Aurora as
proposed.
b. Please identify the specific tabs and line items that contain the MWh amount of
revenue associated with the market sales in Excel file "ID GRC 2025 2023
Normalized Load.xlsm".
c. Please provide the dollar amount of revenue associated with the market sales
identified in(a) above.
d. Please identify the specific tabs and line items that contain the dollar amount of
revenue associated with the market sales in Excel file"ID GRC 2025 2023
Normalized Load.xlsm".
e. Please explain how the dollar amount of revenue associated with the market sales is
calculated and provide the workpapers.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST 14, 2024

REQUEST NO. 188: Please explain why capacity limits are only applied to market
sales in the Aurora model,but not applied to market purchases.
REQUEST NO. 189: Please provide the following information for the UO—Mill
Blanket-2023 project referenced on Attachment#55-1 of Response to Production Request No.
55. Please include any available workpapers with formula 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 ("REP") 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.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by Work-Breakdown Structure
("WBS");
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 AUGUST I4, 2024

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
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 190: Please provide the following information for the 301 Generator
Stator Rewind project referenced on Attachment#55-1 of Response to Production Request No.
55. Please include any available workpapers with formula intact. If any of the information
requested below cannot be provided or is not available,please explain why it is not available or
cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a RFP or RFQ was submitted, please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 AUGUST 14, 2024

d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan:
i. Baseline project scope;
ii. Baseline project budget broken down by the 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
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 191: Please provide the following information for the CCR Jim
Bridger FGD Pond 3 project referenced on Attachment#55-1 of Response to Production
Request No. 55. Please include any available workpapers with formula 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.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 AUGUST 14, 2024

b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a RFP or RFQ was submitted, please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by the 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
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 9 AUGUST 14, 2024

iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 192: Please provide the following information for the U2 Stator
Rewind CY 22-23 project referenced on Attachment#55-1 of Response to Production
Request No. 55. Please include any available workpapers with formula intact. If any of the
information requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a RFP or RFQ was submitted,please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by the WBS;
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 10 AUGUST I4, 2024

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
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 193: Please provide a schedule showing the costs for the Company's
ESG and DEI programs for 2021, 2022, 2023 and 2024 to date.
REQUEST NO. 194: Please provide a schedule showing the rate base for plant in
service for each month in 2024 to present. Please break this out by plant in service, accumulated
depreciation, CIAC, etc.
REQUEST NO. 195: Please provide copies or provide access to the contracts for the
following projects:
a. Wind Generation; and
b. Gateway South.
REQUEST NO. 196: Please provide copies of or access to the Internal Audit Reports
listed in confidential Attachment A.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 11 AUGUST 14, 2024

REQUEST NO. 197: Page 8.5.2 of Exhibit No. 48 in McCoy's Testimony shows the
Plant Additions from Jan 23 to Dec 23. Attachment 55-1 in Response of Production Request No.
55 shows the actual cost of each capital project type (i.e. Steam Production Plant, Hydro
Production Plant, etc.). Please explain the difference between the amounts for the Jan 23 to Dec
23 Plant Additions in Exhibit 48 and the total amounts for each capital project type in Response
to Production Request No. 55 for each of the following. In the explanation, please identify any
specific costs that are not assigned to the Idaho jurisdiction.
a. Steam Production Plant: The total steam production plant is $48,962,604 in
Attachment 55-1, while Page 8.5.2 shows it is $47,400,178.
b. Other Production Plant: The total wind production cost is $77,282,876 in the
Attachment 55-1, while Page 8.5.2 shows it is $75,510,427.
c. Distribution Plant: The total distribution is $2,603,354 in the Attachment, but there is
no distribution cost on Page 8.5.2.
d. Transmission Plant: Attachment 55-1 shows the total transmission cost is
$110,813,775, while the cost is $90,734,484 on Page 8.5.2.
e. General Plant: The total general plant is $6,870,591 in Attachment 55-1, while Page
8.5.2 shows it is $17,099,905.
£ Intangible Plant: The total intangible plant is $11,312,074 in Attachment 55-1, while
Page 8.5.2 shows it is $5,697,879.
REQUEST NO. 198: Please provide the following information regarding the Vitesse—
Facebook 60 MW Load Addition(TZBE/2017/C/002), Troutdale Sub 230kV Swtchyd 115kV
Rg Bus (TIOR/2013/C/005), Vantage to Pomona Heights 230 kV transmission line
(TYAK/2008/C/001), and the Union Gap Add 230 - 115kV Capacity (TWAS/2010/C/001)
capital projects as of June 30, 2024:
a. Account numbers;
b. Plant-in-Service Value;
c. Accumulated depreciation;
d. Book value;
e. Depreciation expense;
f. Depreciation rates; and
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 12 AUGUST 14, 2024

g. Account numbers.
REQUEST NO. 199: Please provide the following information for the U21 Major
Inspection Overhaul-CY23 for a total amount of$19,195,163 as referenced in Company's
Response to Production Request No. 15. Please include any available workpapers with formula
intact. If any of the information requested below cannot be provided or is not available,please
explain why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c. Please provide the following information regarding all RFPs or RFQs associated with
the development and construction of the RC plant:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget was 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 the 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
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 13 AUGUST 14, 2024

for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 200: Please provide the following information for the U22 Major
Inspection Overhaul-CY23 for a total amount of$18,605,763 as referenced in Company's
Response to Production Request No. 15. Please include any available workpapers with formula
intact. If any of the information requested below cannot be provided or is not available,please
explain why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c. Please provide the following information regarding all RFPs or RFQs associated with
the development and construction of the RC plant:
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;
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 14 AUGUST 14, 2024

ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget was approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by the WBS;
Ili. 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
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 201: Please provide the following information for the U2 CSA
Variable fee- CT2 -HGP for a total amount of$11,266,115 as referenced in Company's
Response to Production Request No. 15. Please include any available workpapers with formula
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.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 15 AUGUST 14, 2024

b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c. Please provide the following information regarding all RFPs or RFQs associated with
the development and construction of the RC plant:
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 was approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by the 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
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 16 AUGUST 14, 2024

iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 202: Please provide the following information for the Ul CSA
Variable fee—CT1 -HGP for a total amount of$ 11,220,684 as referenced in Company's
Response to Production Request No. 15. Please include any available workpapers with formula
intact. If any of the information requested below cannot be provided or is not available,please
explain why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c. Please provide the following information regarding all RFPs or RFQs associated with
the development and construction of the RC plant:
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;
it. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget was approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 17 AUGUST 14, 2024

ii. Baseline project budget broken down by the 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
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 203: Please provide the following information for the W-1799 EV
2020 WIND LTSA CY2023 for a total amount of$ 6,261,110 as referenced in Company's
Response to Production Request No. 15. Please include any available workpapers with formula
intact. If any of the information requested below cannot be provided or is not available,please
explain why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c. Please provide the following information regarding all RFPs or RFQs associated with
the development and construction of the RC plant:
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;
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 18 AUGUST 14, 2024

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 was approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by the 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
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 204: Please provide the following information for the U1 Generator
Rewind for a total amount of$5,946,741 as referenced in Company's Response to Production
Request No. 15. Please include any available workpapers with formula intact. If any of the
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 19 AUGUST 14, 2024

information requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
c. Please provide the following information regarding all RFPs or RFQs associated with
the development and construction of the RC plant:
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 was approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by the 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
vi. Contractor change orders.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 20 AUGUST 14, 2024

f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the 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.
DATED at Boise, Idaho, this 141h day of August 2024.
Adam Triplett
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR#10.docx
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 21 AUGUST 14, 2024

- Attachment A
Case No. PAC-E-24-04
Production Request No. 10
August 14, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I� DAY OF AUGUST 2024,
SERVED THE FOREGOING REDACTED TENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-
E-24-04, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER CARLA SCARSELLA
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 825 NE Multnomah, Suite 2000
E-MAIL: mark.alder(Z,pacificorp.com Portland, OR 97232
E-MAIL: joseph.dallas it pacificorp.com
carl a.scars el l a(up aci fi coip.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest(a7—paci ficorp.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK & OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lanceAae ig'sinsi hg t.com
E-MAIL: elo a,echohawk.com
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6T" STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.n kiel ,gmail.com E-MAIL:
heusinkveld i,idahoconservation.org
THOMAS J BUDGE BRIAN C COLILINS
RACINE OLSON PLLP GREG MEYER
PO BOX 1391 BRUBAKER& ASSOCIATES
POCATELLO ID 83204-1391 16690 SWINGLEY RIDGE RD #140
E-MAIL: tina,racineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollins a,consultbai.com
gmeyer a,consultbai.com
Electronic Service Only: RONALD L WILLIAMS
KEVIN HIGGINS BRANDON HELGESON
NEAL TOWNSEND HAWLEY TROXELL ET AL
ENERGY STRATEGIES LLC 877 W MAIN ST
E-MAIL: khiggins(a,energystrat.com BOISE ID 83701
ntownsend(&energystrat.com E-MAIL: rwilliams(i,hawleytroxell.com
bhelgesona,hawleytroxel l.com
CERTIFICATE OF SERVICE Page 1 of 2

Electronic Service Only: Electronic Service Only:
BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITAFOS CONDA LLC
E-MAIL: brmullins(&mwanal ics.com E-MAIL: Val.steiner(a)itafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamsk(d)byui.edu
PAT ILIA JORDAN, S CRETARY
CERTIFICATE OF SERVICE Page 2 of 2