20240816Staff 205-216 to PAC.pdf

RECEIVED
Friday, August 16, 2024 1.59.37 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 ) ELEVENTH PRODUCTION
OF PROPOSED ELECTRIC SERVICE ) REQUEST OF THE
SCHEDULES AND REGULATIONS ) 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 FRIDAY,AUGUST 30, 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.
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 16, 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. 205: Company witness McCoy's Exhibit No. 48, Page 8.5.3, Major
Plant Detail lists the following three projects: 1) "Customer 27—UT—Trans"; 2) "Customer 22
—UT -Trans"; 3) "Customer 8—UT—Trans (1)". Please provide the following details for each
of these three projects:
a. Please provide a narrative description of each project scope;
b. Please identify the Customer in each project, and the facilities that will be served by
each project;
c. Please specify if the Customer provided any Contribution in Aid of Construction
("CIAC") for this project, and if so,provide the amount and how it has been applied
to the project;
d. Please provide a map of the transmission line constructed by each project, showing
how it interconnects with other transmission lines and/or generation resources in the
vicinity; and
e. Please provide a current project management Gantt chart for each project showing the
major elements of work, their duration and dependencies, and their percent complete.
Please highlight the project critical path.
REQUEST NO. 206: Company witness McCoy's Exhibit No. 48, Page 8.5.3, Major
Plant Detail lists the following project in the Transmission section: "Project Specialized" for a
total plant-in-service amount of$72,681,510. Please clarify if this is truly a single project, or an
umbrella project for several smaller ones.
a. Please provide the project scope of work;
b. Please explain why it has various in-service dates, what are the anticipated dates, and
what scope of work is associated with each in-service date. If it is an umbrella
project for several smaller projects, please provide the following:
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 16, 2024

i. Please provide a list of the subordinate projects with a unique identifier and title
for each subordinate project;
ii. Please include the estimated cost and completion date for each subordinate
project; and
iii. Please provide explanatory details for the need for each project.
REQUEST NO. 207: Company witness McCoy's Exhibit No. 48, Page 8.5.3, Major
Plant Detail lists the following project in the Transmission section: "OTP196 Nephi 2nd POD"
for a total plant-in-service amount of$6,905,150. Please provide the following information
regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide the latest project schedule showing the major elements of work, the
duration and dependencies of those work elements, the percentage complete of each
work element, and critical path for placing the plant in service.
REQUEST NO. 208: Company witness McCoy's Exhibit No. 48, Page 8.5.3, Major
Plant Detail lists the following project in the Transmission section: "Jackalope Bixby
Transmission Upgrade" for a total plant-in-service amount of$7,034,353. Please provide the
following information regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 16, 2024

c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide the latest project schedule showing the major elements of work, the
duration and dependencies of those work elements, the percentage complete of each
work element, and critical path for placing the plant in service.
REQUEST NO. 209: Attachment IPUC 15 lists the following Transmission project:
"TIUT/2020/C/012 - Q846 Horseshoe Solar, LLC" for a total plant-in-service amount of
$8,645,796. Please provide the following information regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget line
item.
REQUEST NO. 210: Attachment IPUC 15 lists the following Transmission project:
"DCED/2020/C/009 -Future Comp. LLC, 4.3 MW Load" for a total plant-in-service amount of
$7,949,285. Please provide the following information regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 16, 2024

c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget line
item.
REQUEST NO. 211: Please provide the Company's procedures and policies
documenting its capital project management controls. This should include required process
steps, verifications, and approval levels for different types of expenditures and/or dollar
thresholds.
REQUEST NO. 212: From the Company's Response to Production Request No. 55,
"Staff Attachment 55-2" (attached as Attachment No. 1) lists projects under$5 million for
Wildfire projects. Please answer the following questions in regards to the projects listed in
"Staff Attachment 55-2":
a. Please explain what the term "Mandated Wildfire Mitigation"means. Please explain
if each project with this term is mandated by a certain state or by the Company.
b. For each project with the term"Mandated Wildfire Mitigation"in project description,
please provide location of the project, narrative of the project, in-service date, and any
benefits to Idaho customers.
c. For each project with"Damage Repair", "Damage Rebuild", "Damaged Facilities",
"Fire Damage" and "Fire Restoration" in the project description, please explain the
cause of the damage, any associated names of the fire and the fire start date, the scope
of the project, total project cost and if the Company expects any insurance funds for
the project.
d. For Ref#134 "RMP 2023 ID Fire Mitigation Vehicles",please provide a list of
vehicles purchased,price, purpose, date and invoices.
e. For Ref#79 "RMP 2023 UT Fire Mitigation Vehicles", Ref#211 "RMP 2022 UT Fire
Mitigation Vehicles", Ref#531 "FHCA - 2021 UT Wildfire Vehicles",please provide
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST 16, 2024

a list of each vehicle purchased,price,purpose, date and invoices. Additionally,
please explain how these costs were allocated to Idaho.
f. For Ref#580 "RMP 2023 WY Fire Mitigation Vehicles",please provide a list of each
vehicles purchased,price, purpose, date and invoices. Additionally,please explain
how these costs were allocated to Idaho.
g. For Ref#1705 "Purchase Firefighting Equipment",please provide a list of the
equipment purchased, quantity,purpose, and cost of each item. Additionally, please
explain how these costs were allocated to Idaho.
REQUEST NO. 213: From the Company's Response to Production Request No. 55,
Attachment 55-2 lists the following projects: 1) "Judge-Brighton 46kV Rebld for Wildfire"; 2)
"Northeast-Medical 46kV Rbld for Wildfire"; 3) "Medical-Research 46kV Rbld for Wildfire"; 4)
"El Monte-Eden 46kV Rebuild for Wildfire"; and 5) "Span Fk-Santaquin 46kV Rbld for
Wildfire". Please provide the following details for each of these projects:
a. Please provide a narrative description of each project scope and location;
b. Please identify the facilities that will be served by each project;
c. Plant in Service amount and date;
d. Accumulated depreciation;
e. CIAC associated with the line;
f. Accumulated CIAC amortization;
g. Please provide a map of the transmission line constructed by each project showing
how it interconnects with other transmission lines and/or generation resources in the
vicinity; and
h. Please provide a current project management Gantt chart for each project showing the
major elements of work, their duration and dependencies, and their percentage
complete. Please highlight the project's critical path.
REQUEST NO. 214: Company's Attachment 55-1 lists 18 transmission projects with
no "Annual Actual Project Costs Placed in Service (by year)" from 2022 through 2024. For
each,please answer the following:
a. Please provide a narrative description of each project scope; and
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 AUGUST 16, 2024

b. Please provide a current project management Gantt chart for each project showing the
major elements of work, their duration and dependencies, and their percentage
complete. Please highlight the project's critical path.
REQUEST NO. 215: Company's Attachment 55-1 lists project"Midpoint 500 kV
Series Cap Bank Rpl (IDP)"with an in-service date of January 2024; however, it does not list
any actual project costs placed in service. Please explain if this project is in service as of July
2024 and please explain this discrepancy.
REQUEST NO. 216: Company's Attachment 55-1 lists project "Houston Lake—
Ponderosa Add Second 115 kV Line"with an in-service date of May 2024; however, it does not
list any actual project costs placed in service. Please explain if this project is in service as of July
2024 and please explain this discrepancy.
DATED at Boise, Idaho, this 16th day of August 2024.
CA
Adam Yriplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR#II.docx
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 AUGUST 16, 2024

January 2022 through December 2023 plant additions-projects<$5 million
(excludes non-Idaho distribution and projects>$5m included in Attach 55-1)
Ref# Project Definition Project Description 2022 2023 Total Comment
20 TPAR/2019/C/001 Judge-Brighton 46kV Rebid for Wildfire 3,358,671 277,030 3,635,702
21 DORE/2023/C/DMW Oregon-Mandated Wildfire Mitigation 3,545,915 3,545,915
31 TROS/2020/C/002 Archie Creek Fire Damage Repair 2,201,528 1,056,354 3,257,883
54 TMET/2019/C/004 Northeast-Medical46kV Rbld for Wildfire 2,542,479 2,542,479
79 DUTH/2023/C/005 RMP2023 UTFire Mitigation Vehicles 1,985,261 1,985,261
114 TCRE/2023/C/003 Smith River Fire Restoration 1,526,237 1,526,237
134 DIDA/2023/C/002 RMP2023 ID Fire Mitigation Vehicles 1,329,887 1,329,887
142 TORE/2019/C/003 Fire Mitig ORTransmission Protection 1,296,926 (426) 1,296,500
181 TMET/2019/C/005 Medical-Research46kVRbid for Wildfire 967,880 120,494 1,088,374
187 DIDA/2023/C/DMW Idaho-Dist Mandated Wildfire Mitigation 1,048,873 1,048,873
189 TCAL/2019/C/004 CA Wildfire MitigTrans Relays Phase 2 866,282 167,258 1,033,540
211 DUTH/2022/C/008 RMP2022 UTFire Mitigation Vehicles 11,978 938,642 950,620
281 TOGD/2019/C/003 El Monte-Eden 46kV Rebuild for Wildfire 744,188 744,188
293 DMTS/2022/C/006 Mill Fire Damage Rebuild 703,405 - 703,405
450 DCAL/2019/C/003 Calif Fire Mitigation CA-D Sub Relay 130,280 309,773 440,053
486 DWAS/2023/C/DMW Washington-Mandated Wildfire Mitigation 401,686 401,686
531 DUTH/2021/C/001 FHCA-2021 UT Wildfire Vehicles 359,033 3,326 362,359
580 DWYO/2023/C/002 RMP 2023 WY Fire Mitigation Vehicles 325,725 325,725
601 TROS/2021/C/002 Jack Fire Damage Repair 306,996 1,732 308,727
774 TUTH/2021/C/TMW Utah-Tran Mandated Wildfire Mitigation 217,319 217,319
782 TCAL/2022/C/TMW California-Mandated Wildfire Mitigation 215,075 215,075
798 DUTH/2020/C/002 ALERTWildfire Systems-Wildfire Cameras 205,119 205,119
1116 DUTH/2019/C/805 RMP Wildfire Mitigation-Distribution 115,614 115,614 General plant additions portion of project
1145 DCAL/2023/C/DMW California-Mandated Wildfire Mitigation 109,951 109,951
1229 DYRE/2020/C/003 CA-Wildfire Mitig Dist Sub Relay Rpl Ph3 93,872 93,872 General plant additions portion of project
1282 DORE/2020/C/DMW Oregon-Mandated Wildfire Mitigation 85,276 85,276
1542 DCAL/2020/C/003 CA-Fire Mitig Instl Weather Statns 2020 50,712 50,712
1544 DORE/2020/C/003 OR Fire Mitig Dist Sub Relay Rplc Phs 1 50,433 50,433 General plant additions portion of project
1581 DUTH/2022/C/DMW Utah-Dist Mandated Wildfire Mitigation 46,318 46,318 General plant additions portion of project
1586 DYAK/2020/C/002 WA-Fire Mitig lnst Weather Stations 2020 45,808 45,808
1675 TAME/2019/C/005 Span Fk-Santaquin46kVRbld for Wildfire 36,817 36,817
1700 DORE/2020/C/004 OR-Fire Mitig lnstlWeatherStatns2020 (156,236) 190,885 34,649
1705 SJIM/2023/C/050 Purchase Firefighting Equipment23 34,173 34,173
1821 DCAL/2021/C/DMW California-Mandated Wildfire Mitigation 26,281 26,281
1882 DUTH/2020/C/DMW Utah-Dist Mandated Wildfire Mitigation 21,806 21,806 General plant additions portion of project
1937 TYRE/2020/C/001 Slater Fire(Happy Camp)Fire Damage 18,272 - 18,272
2032 DIDA/2022/C/DMW Idaho-Dist Mandated Wildfire Mitigation 13,082 13,082
2130 DORE/2021/C/DMW Oregon-Mandated Wildfire Mitigation 8,999 8,999
2214 TPAR/2020/C/001 Cottonwd-Snyderville 138kV Rbld-Wildfire 5,268 5,268
2222 TMED/2020/C/001 Almeda Fire Damage Repair 5,090 5,090
2223 TZRB/2021/C/002 Winchester Sub Wildfire Mitigation Upgrd 5,086 5,086
2382 TYRE/2018/C/002 Delta Fire Damaged Facilities 1,186 1,186
2496 TCAL/2019/C/003 Calif Fire MitigTransmission Line Rebid 135,096 (135,096) -
2498 TORE/2022/C/TMW Oregon-Mandated Wildfire Mitigation 43,802 (43,802) -
2618 TCAL/2019/C/001 California Fire Mitigation CA-T Sub (1,877) 387 (1,490)
2825 TORE/2019/C/001 Calif Fire Mitigation OR-T Sub (7,029) (7,029)
3121 TUTH/2019/C/805 RMP Wildfire Mitigation-Transmission (595,091) 1,226 (593,864)
3126 TKLA/2020/C/001 Two FourTwo Fire Damage Repair (714,524) - (714,524)
Attachment No. 1
Case No. PAC-E-24-04
Production Request No. 11
August XX, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS A�VDAY OF AUGUST 2024,
SERVED THE FOREGOING ELEVENTH 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.aldergpacificorp.com Portland, OR 97232
E-MAIL: joseqph.dallas&acificorp.com
carla.scarsella(gpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest&acificorp.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: lance(a,aegisinsi t.com
E-MAIL: elo _,echohawk.com
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.Wkielggmail.com E-MAIL:
heusinkveldgidahoconservation.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: tj racineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollinsgconsultbai.com
gmeyergconsultbai.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: khigginsgenergystrat.com BOISE ID 83701
ntownsendgenergystrat.com E-MAIL: [e-mail]
[e-mail]
CERTIFICATE OF SERVICE Page 1 of 2

Electronic Service Only: Electronic Service Only:
BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITAFOS CONDA LLC
E-MAIL: brmullinsgmwanalytics.com E-MAIL: Val.steinergitafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamsk(kbyui.edu
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE Page 2 of 2