PAC to Staff 155-173.pdf

RECEIVED
Friday,August 23, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 23, 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 9 (155-174)
Please find enclosed Rocky Mountain Power's Responses to IPUC 9th Set Data Requests 155-
156, 158, and 161-173. The remaining response will be provided under separate cover. Also
provided is Attachment IPUC 164. Provided via BOX are Confidential Attachments and
Confidential Responses. Confidential information is provided subject to protection under
IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67—Information Exempt from Public Review, and further subject to the non-
disclosure agreement(NDA)executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures
C.c.: Eric L. Olsen/IIPA elokechohawk.com(C)
Lance Kaufman/IIPA lance@ae ism h�(C)
Matthew Nykiel/ICL matthew.n, k�(&gmail.com
Brad Heusinkveld/ICL bheusinkveldgidahoconservation.org
Thomas J. Budge/Bayer tj racineolson.com(C)
Brian C. Collins/Bayer bcollinskconsultbai.com
Greg Meyer/Bayer gmeyer(&consultbai.com
Kevin Higgins/Bayer khia gins kenergystrat.com(C)
Neal Townsend/Bayer ntownsend(&energystrat.com (C)

Ronald L. Williams/PIIC rwilliams&hawleytroxell.com
Brandon Helgeson/PIIC bhel eg son ci,hawleytroxell.com
Bradley Mullins/PIIC brmullins(&mwanalytics.com
Val Steiner/PIIC val.steinergitafos.com
Kyle Williams/PIIC williamskkbvui.edu

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 155
IPUC Data Request 155
Please describe any changes made to the incentive amount, dispatch parameters,
or any other program design element for each of the Company's Demand
Response (DR)programs for the past five years or since the beginning of the
program, whichever is first.
Response to IPUC Data Request 155
Irrigation Load Control- For the 2024 season, the Company and the Contractor
renegotiated the Irrigation Load Control contract, which resulted in the following
program elements being modified:
1. The Base Incentive Rate for participants increased from $23 per kilowatt
($/kW) for pumps over 100 kilowatts (kW) or $19/kW for pumps under 100
kW to $32.50/kW for all enrolled pumps, regardless of the pump size.
2. The Voluntary Energy Reduction Payment Rate increased from $190 per
megawatt-hours ($/MWh) to $380/MWh.
3. A pump must participate in all mandatory events in order to receive the Bonus
Incentive Rate. Previously, a customer had to participate in all mandatory
events that ended at 9 PM to receive the bonus.
4. No more than three mandatory events are allowed each week throughout the
mandatory program season. Any additional event in a week will be considered
voluntary. This restriction was not defined previously
2021
1. Minimum advanced notification changed from 24 hours to 4 hours.
2. Program hours changed from 12 PM to 8 PM to 2 PM to 9 PM.
3. A 20 percent bonus was offered to sites that participated in all events that
lasted until 9 PM. This bonus was also offered in 2022 and 2023 as well.
Wattsmart Batteries -No program changes of note have occurred with the
Wattsmart Battery program since its approval in 2022.
Wattsmart Business Demand Response—No substantive program changes have
occurred with the Wattsmart Business Demand Response program since its
approval in 2023.

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 155
Recordholder: Sierra Gentry/ Shawn Grant
Sponsor: Shawn Grant

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 156
IPUC Data Request 156
For each of the Company's DR offerings, please describe the process the
Company uses to propose and implement program changes for Commission
review.
Response to IPUC Data Request 156
The Company currently offers three Demand Response (DR)programs in Idaho:
the Irrigation Load Control (ILC) program, the Commercial and Industrial (C&I)
DR program, and the Wattsmart Batteries program.
The ILC program is implemented through Schedule 105, which includes pertinent
program details such as the dispatch period, incentive amounts, and other
provisions. In order to make changes to the ILC program tariff, the Company
must propose changes via an Application process and obtain Idaho Public Utilities
Commission (IPUC) approval prior to implementation.
The C&I DR and Wattsmart Batteries programs are implemented through
Schedule 114, which was approved by the IPUC as a flexible tariff. Flexible
tariffs allow the Company to manage certain program details outside of the
program tariff, such as incentives, dispatch parameters, and other provisions. In
order to make changes to the Schedule 114 tariff itself, the Company must
propose changes via an Application process and obtain IPUC approval prior to
implementation. In order to make changes to program details managed outside of
the Schedule 114 tariff, the Company may make adjustments without advanced
IPUC approval if the Company informally obtains IPUC staff input and resolves
any IPUC staff concerns before implementing the change.Ell After IPUC staff s
concerns are resolved, the Company will post the final set of changes for at least
45 days on the Company's website for customers to see before the changes take
effect.
Recordholder: Sierra Gentry/Michael Snow
Sponsor: Shawn Grant
In the Matter ofPacifiCorp DBA Rocky Mountain Power's Application to Revise Electric Service Schedule 115 FinAnswer Express,
Case No.PAC-E-12-10,Order No.32594 at 5(July 13,2012).

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 158
IPUC Data Request 158
Please provide the following information for the "Monarch PACE Upgrade and
HW TOM"project referenced in Production Request No. 15 response from the
Company. Please include any available workpapers with formulas intact. If any of
the information requested below cannot be provided or is not available, please
explain why it is not available or cannot be provided.
(a) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.
(b) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company's economic analysis (costs and
benefits) comparing them.
(c) If a RFP or RFQ was submitted, please provide the following:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
(d) Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at
the appropriate level.
(e) Please provide the following for the Baseline Construction Project:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the
differences, explain the reason for the change, and provide
evidence that the changes were approved at the appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
(f) Please provide the following related to completion of the project:

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 158
i. Baseline construction budget-to-actual comparison by WBS and by
year;
ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category
that is over 5%, please explain the reason for the differences and
provide evidence that the amount was approved at the appropriate
level; and
iv. Please explain any slips in schedule from the baseline construction
schedule.
Response to IPUC Data Request 158
(a) Please refer to the Company's responses for the subpart below:
Proiect Explanation and Analysis
PacifiCorp's existing Supervisory Control and Data Acquisition, Energy
Management System(SCADA/EMS) is the monarch 2014 PS 10.2 system
furnished by Open Systems International Inc. (OSII). This project was to
update the monarch Energy Management System from monarch 2014 PS 10.2
to monarch 2019 and to refresh the server, network, and workstation
hardware. This update was part of the 10 year plan to support the monarch
EMS. The monarch software licensing costs are covered under the software
warranty with OSII. The update implementation costs are included in the
project costs.
This project included the implementation of new Web Platform and Security
Profiler products. These new software costs were also included in the project
costs.
The hardware infrastructure is at end of support life and a Technology
Obsolescence Management(TOM) replacement will be performed for the
Unix servers, Windows servers, network switches, and network firewalls.
These hardware costs are included in the project costs.
This implementation supports the future grid operation growth and emerging
requirements for additional generation, transmission lines, substations, and
distribution equipment. The hardware will be sized in the project for growth
needed for the next 5 years. Cost increases to the point counts software
licensing will be managed over the 5 years following the project completion.
A complete and detailed analysis justifying the need for this project is
contained in the attached MonarchPAC6PCN2-InvestmentAppraisal
document provided with Confidential Attachment IPUC 158.

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 158
(b) Please refer to Confidential Attachment IPUC 158 which provides the
attached Investment Appraisal, this upgrade was performed on the monarch
Energy Management system furnished by Open Systems International Inc.
(OSII), software already established and approved. This project was to update
the system and to refresh the server, network, and workstation hardware as
part of a 10-year plan to support the monarch EMS.
(c) Sole-Source/Non-Compete#863 was fully approved. No request for proposal
(RFP) or request for quote (RFQ)was required or submitted for the upgrade.
A document with a link to the sole-source approvals has been attached to this
response
(d) Please refer to the Company's responses for the subpart below:
Proiect Scope
As mentioned above, the project's objective was to update the monarch
Energy Management System from monarch 2014 PS 10.2 to monarch 2019
and to refresh the server, network, and workstation hardware as part of a
10-year plan to support the monarch EMS. The areas outlined below were
included in the scope.
• Multi-FEP functionality:
o The multi-FEP server functionality was required to support the
STEP CFCI project for the monitoring devices to communicate to
monarch using an IP based solution. The CFCI project implements
monitoring, and the monarch EMS will support the SCADA
functionality for the CFCI devices to communicate to the Monarch
and CADOPS environments. This multi-FEP design also stages
PacifiCorp's EMS in a scalable mode to address future (pending)
projects requiring IP based communications.
• Automatic Generation Control enhancement to support distributed
resource management (DERMS):
o The AGC application requires an expansion to better provide a
complete solution for the integration and management of multiple
distributed energy resources. This expansion/module adaptation
has the capability for the administration, real-time monitoring and
dispatching of various energy resources such as batteries, wind,
solar and demand response (DR)programs which include electric
vehicle (EV), thermostatic aggregators, like-load specific control
(irrigation pump load), micro-grid and other third-parry data
collection/aggregators. This application prepares PacifiCorp's
EMS system to support the IRP and subsequent DR RFP.
• CyberArk Access Management and YubiKey:
o The existing Control's Local Area Network software and RSA
Security tokens implementation were replaced with the new
CyberArk Access Management software and YubiKey tokens for
remote access to PAC6PROD and PAC6TEST environments.

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 158
Security identified that the YubiKey provided the required two
factor"remote"user authentication.
Proiect Budget
$1,900k in Capital Funding, $7.8k in Expense, with an 11-month
completion delay was approved (please see attached APR#18001986)to
deliver the Monarch PAC6 Upgrade &Hardware Refresh. The current and
forecast spend to date as of the Investment Appraisal and project initiation
was:
2019 Actuals 2020 Actuals ''2021 Actuals 2022 Actuals+ Forecast Total Currently Additional
Forecast Project Cost Approved Funding
Requested
Capital $ 1,944,610 $ 2,896,267 $ 2,192,819 $ 1,571,226 $ 8,604,922 $ 7,152,193 $ 1,452,729
Expense $ - $ 6,920 $ 781 $ 158 $ 7,859 $ - $ 7,859
Capital Surcharge $ 225,688 $ 154,121 $ 109,641 $ 76,781 $ 1,630,615 $ 1,183,034 $ 447,581
AFUDC $ 4,023 $ 259,993 $ 434,998 $ 365,370
Totals $ 2,174,321 $ 3,317,301 $ 2,738,239 1 $ 2,013,535 1 $10,243,396 1 $ 8,335,227 1 $ 1,908,169
The reasons for the additional budget, scope, and timeline delay were as
follows:
• Resource cost increase due to the extended delivery timeline.
• Additional hardware and labor required to complete the approved
network design.
• Additional labor to implement the new approved security
infrastructure design.
• Hardware and labor required to support added functionality of Multi-
FEP.
o The decision to purchase the multi-FEP servers was driven by the
STEP project. The servers were purchased by the STEP project.
The decision was to absorb the labor in the PAC6 project.
• AGC Licenses expansion for a modified module adaption for
increased monitoring and control of generation and demand resources.
o The expansion module of the AGC application (modelling and
visualization, monitoring and control, forecasting, real-time
estimation)would include licensing for 50 distributed energy type
resources records. Once the application is in place, the license
count is scalable, as required, for the continued support of future
awarded energy and demand response submissions.
• Additional point purchases required in 2020 was not anticipated until
2021.
o The delay of the PAC6 project from 2018 to 2019 created the need
for the additional points to be purchased in 2020 for the current
production environment. The purchases of the additional points in
the PAC6 were identified on an annual basis over a five (5)year
time span so that we were not paying maintenance for points that

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 158
were not in use. The servers' capacity are sized such that the
increase in the database is fully supported with no server
modifications going forward.
• Additional servers required for PI environment and Voyager support.
o The PAC6 project included an increase for the number of users to
access the Corporate Monarch environment. A decision was made
for the purchase a 100 user license with Voyager rather than an
upgrade to the Monarch LITE environment. The cost for an
increase of 100 users with Monarch LITE was the same as the 100
user Voyager license. The decision to upgrade the PI Historian
servers was made given that the original 2018 project delayed into
2020/2021 and the obsolescence of the PI servers would occur in
the 2021 timeframe.
• Additional ongoing burn rate with the delay of delivery due to items
mentioned above.
o With the additional scope including the Multi-FEP (STEP CFCI),
Voyager, and PI Historian work scope, there was additional time
required for these work efforts within the project.
Proiect Schedule
• The project was not able to implement in November 2021 due to:
o Further loss of key project resources that have not been filled in a
timeframe to support the November implementation date.
o Automated Generation Control (AGC) software Issues. —Defects
were found in the AGC functionality during the mini-cut over
"preproduction"testing of the generation units.
o Performance Testing Failures—The "preproduction"performance
testing resulted in instability with the workstations crashing.
o Additional Software Release—OSII provided an additional
software release to provide functionality that was part of the
Monarch 2019 release that was not delivered in time for the site
acceptance testing. The release also addressed the software issues
discovered during mini-cutover and performance testing.
Additional mini-cutover and performance tests were performed to
validate.
o Dell Workstation Crashing—The project purchased Dell
workstations for the production implementation. The initial
configuration of the Dell workstation did not have the required
software release supported by Dell. The Dell workstations were
updated to the supported operating system software release and
device drivers.
o CyberArk Security Implementation—The implementation of new
Security infrastructure using CyberArk access management
software and YubiKey cards was added to the project remote
access to PAC6PROD and PAC6TEST environments.
o PacifiCorp SCADA Data Entry Tool—A software update was

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 158
required for the PacifiCorp SCADA Data Entry Tool to support the
updates that were made with the Monarch Maintenance Center
enhanced functionality.
• To support the CFCI effort to be delivered in December 2021, a
phased approach was taken to deliver the project:
o Phase 1: December 14, 2021
■ CFCI was delivered on December 14, 2021
o Phase 2: August 10, 2022
■ The full project was delivered on August 10, 2022.
• The project start was delayed from 2018 to 2019 in order to receive the
monarch 2019 release from OSI that was being installed at PJM and
Exelon. This release provided functionality that would otherwise not
be available in the prior monarch release. The contract negotiations on
the Statement of Work(SOW) for the project were completed in
September of 2019. The purchase of the servers was made in October
of 2019 with delivery in January 2020. A decision was also made in
the project to locate the servers at PacifiCorp at PCC and SCC rather
than ship to OSI in Minneapolis. The configuration and installation of
the network to support the new PAC6 servers was completed in April
2020 and then OSI was able to start their software implementation in
the new server and network environment. By configuring and
installing the network at PacifiCorp, there was time saved when
moving from the OSI Factory Testing to the final On-Site Acceptance
Testing. During the timeframe that the servers and network were
implemented, a decision was made to purchase the multi-FEP servers
required for the STEP-CFCI project and to purchase an AGC
enhancement to support distributed energy resources.
Approvals:
The initial plan was approved by Stefan Bird on October 3, 2019. APR
#18001986 is provided in Confidential Attachment IPUC 158 as a
separate document with approval and budget information.
(e) Please refer to Company's response to subpart (d) above with separate
headings for the initial/baseline Project Scope, Project Budget, and Project
Schedule.
Baseline project budget:
Spent To Date: 0
Cil Latw MMID" Puchv Dow Sol-hag9 A TOW G6 GAC 06M TOW 5 Yr Avg 5 Yr Avg
SavKK AFUDC APR 09NSuVEJV EM
7i•9 12L665 246644 715063 0 37631E 3709705 0 3000 3.712706 0 0
:Q0 796.762 9W We 1 1 197,595 01 613 730 3 510 097 01 30,000 3510 067 0 0
ToUft MW LUM4 1 m 9 Or 7 796 0 909 ?.Xzml 0 •
The baseline scope, budget and/or schedule did not deviate from the initial
Project Plan.

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 158
The project budget broken down by WBS appears below:
Project object Project object ObjectType Status Actual costs
- Monarch PACE Upgrade and HW TOM CITE/2018/C/050 Project defin TECO 10,476,243.67 USD
L-- Monarch PACE Upgrade and HW TOM CITB/2018/C/050 WBS element TECO SETC 10,476,243.67 USD
1 Monarch PAC6 Upgrade and HW Budget CITB/2018/C/050/B WBS element CLSD AUC 0.00 USD
Monarch PAC6 Upgrade and HW Cap CITE/2018/C/O50/CAP WBS element TECO AUC SET 10,462,047.31 USD
Workstations 344405 CO internal o CLSD GMPS SET 508.341.31 USD
k Servers 344406 CO internal o CLSD GMPS SET 1,940,365.79 USD
k Networking 344407 CO internal o CLSD GMPS SET 1,113,221.74 USD
k Software; Vendor Svc 344408 CO internal o CLSD SETC 1,943,454.03 USD
k SW Internal Labor 344409 CO internal o CLSD GMPS SET 2,692,284.80 USD
k OSI Maintenance based Enh 2020 345685 CO internal o CLSD SETC 330.466.03 USD
Monarch PAC6 Upgrade and HW Omag CITE/2018/E/050/EXP WBS element CLSD SETC 14,196.36 USD
k Oracle DBA Data Move 119580 CO internal o CLSD 6.337.84 USD
k Monarch Vendor Svcs omag 252202 CO internal o CLSD SETC 7.700.82 USD
k Monarch Internal Labor omag 252203 CO internal o CLSD SETC 157.70 USD
Project status was reviewed with OSI weekly in conjunction with a
project plan. The project plan contained the relevant action items. A
sample appears below:
4Q-V O 13 1 PAC6-2020 Up
ID % Tazk Name Duraaon Sbt
1 7B%PAC6-2020 Upgrade&HW Replacement Project 587 days Thu
2 �®
3 100% HW and Architecture Meeting(@ PAC) 1 day Thu
4 100% Complete Physical and Logical Design,System Specifications,and 11 days Fri 1
Migration Strategy
5 100% HW Order-Servers and Network Hardware 5 days Mon
6 100% Receive Server&Network Hardware 60 days ��MTT}}o��n17
7 r �IIIY'1k
e 100% Quote Acceptance-Project Start 1 day Mon
9 100% Finalize Purchase Order 1 day Tue
10 200% OSI Accounting Setup 3 days Wed
11 100% Milestone 1:20%Upon Quote Acceptance 1day Mon
12 100% Thanksgiving Holiday 4 days -
13 100% Project Kickoff Meeting 1 day Thu
Scheduling
14 100% Upgrade Planning and S 10 days Fri 1
15 100% Delivery of System Configuration Diagram to PAC 7 days Fri 1
16 100% Enhancement Planning and Scheduling 50 days Mon
17 100% Review and Approve Project Schedule 1 day Mon
18 100% Milestone 2:20%Completion of Remote Hardware and Software 0 days Mon
No contractor change orders were submitted.
(f) Please provide the following related to completion of the project:
i. Please refer to the table below for the baseline construction budget-to-
actual comparison by WBS and by year; Budget to actual comparisons
Spent To Date. 0
cr LaOor I M41Aru1 Purcltal om. SwCh rgl& Toial Grote CIAC O&M Tara) 5 Yr Avg 5 Yr Avg
Yer 5rvk- AFUDC C.Pdul APR Enh
Xi'9 727.885 248841 715.Dfi3 0 378.318 370970• 0 3000 3712105 0 0
2000 798.7fi2 Sa10000 1197.505 0 613.130 35t0067 0 3000D 1510087 0 0
Tou" 1 •li • mom 721111,7111116 0 7 M 0 0

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 158
ii. Please refer to the Company's response to subpart(f) (i) above.:
Pleaser to the table below for the Budget/Schedule— actual as of project
completion:
Capital and 0&M Cost
Cal. _aw, MA I1 o Purouu Dort RNWOM Gltvage •urChog6a Tar Gras: C1AC O&M Tao Me0aula 1131111111 t
YON ser tress C46b AFI M CNOW E APR uWaft
201'i 26 192 1 290 760 627.658 0 0 0 229.711 174 0 6 2 161.241 O 0
202,: 579917 1,362804 946.546 0 0 0 414412 3,]tOb7 0 781 3.311.480 0 0
2021 666 524 567 631 79111,660 0 0 0 SM 640 737 45 0 150 2,737,616 0 0
202= ',079AN 202 Al2 21111111,052 0 0 0 4Q 15i 2,013373 0 0 2.013 377 0 0
Taal6 I ZAEL4111111 111,411111mal81 al 1111 1630914 10 353t3 01 7-&Sq 10,243,GM al •
The WBS breakdown for the project appears below:
Project object Project object ObjectType Status Actual costs
- Monarch PAC6 Upgrade and HW TOM CITE/2018/C/050 Project defin TECO 10,476,243.67 USD
L- Monarch PAC6 Upgrade and HW TOM CITB/2018/C/050 WBS element TECO SETC 10,476,243.67 USD
Monarch PAC6 Upgrade and HW Budget CITB/2018/C/050/B WBS element CLSD AUC 0.00 USD
Monarch PAC6 Upgrade and HW Cap CITB/2018/C/050/CAP WBS element TECO AUC SET 10,462,047.31 USD
Workstations 344405 CO internal o CLSD GMPS SET 508.341.31 USD
Servers 344406 CO internal o CLSD GMPS SET 1,940,365.79 USD
Networking 344407 CO internal o CLSD GMPS SET 1,113,221.74 USD
Software; Vendor Svc 344408 CO internal o CLSD SETC 1,943,454.03 USD
SW Internal Labor 344409 CO internal o CLSD GMPS SET 2,692,284.80 USD
OSI Maintenance based Enh 2020 345685 CO internal o CLSD SETC 330.466.03 USD
Monarch PAC6 Upgrade and HW Omag CITB/2018/E/O50/EXP WBS element CLSD SETC 14.196.36 USD
Oracle DBA Data Move 119580 CO internal o CLSD 6.337.84 USD
Monarch Vendor Svcs omag 252202 CO internal o CLSD SETC 7.700.82 USD
Monarch Internal Labor omag 252203 CO internal o CLSD SETC 157.70 USD
iii. Please refer to Confidential Attachment IPUC 158 which provides a
copy of the Change Request explanations which are also detailed
below
There were two significant shifts in budget/schedule from the baseline to
the actual budget/schedule at project completion. The need for the
budget/schedule changes were explained and approved by Change
Requests #1 and#2.
Change Request#1 for the project was approved by Stefan Bird on
December 15, 2020 as detailed in the attached Change Request: PCN
#94010983.
Change Request#1 Financial Analysis:
This APR increases the authorized project cost from $7.22 to $8.34
million and defers the in-service date from October 31, 2020 to November
31, 2021. A financial analysis was prepared October 3, 2019 when the
project was originally approved with APR 18001986. At that time the
estimated project cost was $7.22 million and the recommended alternative
was the least cost alternative with a present value revenue requirement

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 158
cost of$6.29 million. The project addresses technological obsolescence
and avoids $100 thousand of maintenance cost per year associated with
the outdated OSII servers. There are no feasible alternatives. An updated
financial analysis is not required.
-1 lalor Malrul Purtlt 0e -v R.—MM SL.aqa -. p A Tad Cim CNC. OaM Tad 13l mk Bsttrrt
S ro_ Cosh -F_OC APR
- 25 192 200 7W 627 659 0 229 711 2.1 32 0 0 2,174.321 0 0
2020 695 707 •10 113 1 459,•61 0 G L 1 517 3.706 0 0 3,705199 0 0
2321 t 052 3• %9 r�1 P. x 9 0 C. 511 am 2 451 i 0 0 2 4&4 408 0 0
Tadt 7 T7l2t 2968$91 2409,087 a 0 8 IJBM4 8.33SI21 0 0 1,33S.227 a a
Change Request#2 for the project was approved by Stefan Bird on
November 2, 2022 as detailed in the Change Request: PCN#94013000.
Change Request#2 Financial Analysis: This APR increases the
authorized project cost from $8.34 to $10.24 million and defers the in-
service date from November 30, 2021 to August 22, 2022.A financial
analysis was prepared October 3, 2019 when the project was originally
approved with APR 18001986. At that time the estimated project cost was
$7.22 million, and the recommended alternative had a present value
revenue requirement cost of$6.29 million. The project addresses
technological obsolescence and avoids $100 thousand of maintenance cost
per year associated with the outdated OSII servers. There are no feasible
alternatives. In addition, this project is complete. An updated financial
analysis is not required.
capkal and O&M cost
Col. Lem M9d1Y Put— C3 , 6..ChrpA Tad Gr— Ca1C O&M Tad Ne..k BtWa i
V_ s.rslds Casts ARAX Ca APR WWb
2012 25 192 +2a0.793 WWI 0 0 0 14721 2.11431 0 610 2 1812l1 0 0
2020 579217 1,382" 946.W 0 0 0 !1!!+2 3,3+0 0 7a+ 3,311,la0 0 0
2@1 a95@4 587AN 1W%3 0 0 0 5Mb10 2.73746 0 15B 2737a/6 0 0
2022 1 079855 202 312 :39 059 0 0 0 44LISI 01 0 0 2.013,377 0
T.W. ZSSL48 1 s30610 2621 N3 a a a 1ANAM 18.2nn 0 7 0 0
The attached Change Request documents also provide details regarding
budget-to-actual expenses and the need for revised schedules.
iv. Please refer to the Company's response to subpart (f) (iii) 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: Dave LaPray/Cynthia Jolliver

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 158
Sponsor: Dawid Zydek

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 161
IPUC Data Request 161
For rate design for Schedule 1 and Schedule 36, please answer the following for
each class and provide any associated workpapers. Additionally, if different for
each rate year, please explain.
(a) Please explain how the Company determined the differential between the
summer and winter seasons energy charges.
(b) For Schedule 1, please explain how the Company determined the differential
between energy charges for the first 700/1,000 kWh and all additional kWh in
the summer and the winter.
(c) For Schedule 36, please explain how the Company determined the On-Peak
and Off-Peak differentials for summer and winter.
(d) For Schedule 36, please explain how the Company determined its On-Peak
and Off-Peak times in the summer and winter seasons.
Response to IPUC Data Request 161
(a) The Company proposes no changes to the established structure of residential
rates, since the Idaho Public Utilities Commission (IPUC) recently decided on
residential rate design for a multi-year period as part of the Residential Rate
Modernization Plan proceeding. For Schedule 1, the Company proposed to
increase all the energy rates with equal cents per kilowatt-hour(cents/kWh) in
Step 1 effective on January 1, 2025 and Step 2 effective on January 1, 2026
while keeping the same rate differentials among the energy rates as the
corresponding present effective energy rates including summer and winter and
first tier and second tier. On June 1 of each transition period from the
Residential Rate Modernization Plan, the Company proposed to change the
corresponding effective energy rates with equal percentage while keeping
revenue neutral and the same ratios among the energy rates. Please refer to the
work paper supporting the direct testimony of Company witness, Robert M.
Meredith, specifically file "ID GRC Blocking 2024.xlsx", tabs "Page 1
Exhibit No 60-1313", "Page 2 Exhibit No 60-BD" and"Page 3 Exhibit No 60-
BD"which provide detailed calculations.
(b) Please refer to the Company's response to subpart(a) above.
(c) The Company proposes no changes to the established structure of residential
rates, since the IPUC recently decided on residential rate design for a multi-
year period as part of the Residential Rate Modernization Plan proceeding.
For Schedule 36, the Company proposed to increase all the energy rates with
equal percentage in Step 1 effective on January 1, 2025 and Step 2 effective

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 161
on January 1, 2026 while keeping the same ratios among the energy rates. On
June 1 of each transition period from the Residential Rate Modernization Plan,
the Company used two steps to calculate the proposed on-peak and off-peak
energy rates. First, all the energy rates were calculated with equal percentage
change with revenue neutral and the current time-of-use ("Existing TOU).
Second, the proposed off-peak energy rates with the new time-of-use (New
TOU)were set as the same as that from the first step with Existing TOU and
the proposed on-peak energy rates with the New TOU were set to recover the
corresponding seasonal energy revenues from the first step with Existing
TOU. Please refer to the work papers supporting Robert Meredith's direct
testimony, specifically file "ID GRC Blocking 2024.xlsx", tabs "Page 1
Exhibit No 60-BD", "Page 2 Exhibit No 60-BD", and"Page 3 Exhibit No 60-
BD"which provide the detailed calculations.
(d) Please refer to the Company's response to subpart(c) above.
Recordholder: James Zhang
Sponsor: Robert Meredith

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 162
IPUC Data Request 162
Please explain how the Company determines its summer and winter seasons for
rate design. Please provide any associated workpapers supporting the Company's
proposal.
Response to IPUC Data Request 162
The determination of summer and winter seasons was generally based on the cost.
As demonstrated and explained in the direct testimony of Company witness,
Robert M. Meredith and Exhibit No. 53 in the last general rate case (GRC), Case
No. PAC-E-21-07, for the summer season,which includes June through October,
the weighted average energy imbalance market(EIM)price is $29.73 per
megawatt-hour ($/MWh), which is about 1.11 times the weighted average price of
$26.86/MWh calculated for the winter season, which includes November through
May. The Company proposed no change to the seasons in this current GRC.
Recordholder: James Zhang
Sponsor: Robert Meredith

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 163
IPUC Data Request 163
Please provide the number and percentage of Idaho residential customers whose
primary heating source is electric.
Response to IPUC Data Request 163
There are 15,413 residential sites in Idaho where the primary heating source is
listed as electric. This represents 21 percent of all residential sites in Idaho.
Recordholder: Marty Lopas
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 164
IPUC Data Request 164
Please provide the monthly average energy usage for Idaho residential customers
for the summer season, winter season, and annually for each year from 2018
through 2023.
Response to IPUC Data Request 164
PacifiCorp objects to this request to the extent that it seeks data from time periods
more than five years prior to the filing of this proceeding as is not reasonably
calculated to lead to the discovery of admissible evidence and is therefore beyond
the scope of discovery. Subject to and without waiving the foregoing objection,
the Company responds as follows:
Please refer to Attachment IPUC 164.

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 164
Monthly Average
Winter Energy
Month Usage
201801 1256
201802 1075
201803 1064
201804 880
201805 611
201811 864
201812 1218
201901 1283
201902 1153
201903 1068
201904 841
201905 622
201911 941
201912 1173
202001 1287
202002 1143
202003 1001
202004 868
202005 558
202011 870
202012 1226
202101 1310
202102 1113
202103 1030
202104 846
202105 646
202106 173
202107 682
202108 993
202109 474
202110 472
202111 829
202112 1109
202201 1292
202202 1216

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 164
202203 1108
202204 871
202205 718
202206 342
202207 490
202208 656
202209 233
202210 298
202211 897
202212 1348
202301 1320
202302 1281
202303 1174
202304 976
202305 651
202306 282
202307 260
202308 399
202309 366
202310 348
202311 839
202312 1167

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 164
Average Annual
Year Energy Usage
2018 895
2019 906
2020 907
2021 908
2022 954
2023 932
Recordholder: Marty Lopas
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 165
IPUC Data Request 165
Please provide the minimum requirements a contractor must meet to perform
work for the Company.
Response to IPUC Data Request 165
The Company's minimum requirements for a contractor are unique to specific
goods and/or services being procured and can vary based upon the nature of the
project and the risk potential. Items typically considered include contractor's
agreement to contract terms and conditions, understanding of the scope of work
and technical qualification. In addition, a review of contractor for foreign control
or influence, contractor's information security policies, cyber security score,
financial stability, safety record and programs, environmental policies, insurance,
etc. may also be required.
Recordholder: Shelly Zoller/Marion Stanwood
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 166
IPUC Data Request 166
Please provide supporting documentation for the Company's adjustment to fly ash
revenue shown in adjustment No. 3.6.
Response to IPUC Data Request 166
Please refer to the Company's response to IPUC Data Request 147.
Recordholder: Aaron Lively
Sponsor: TBD

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 167
IPUC Data Request 167
Please provide the monthly coal inventory by both dollars and tons in 2024 for the
following plants:
(a) Jim Bridger;
(b) Craig;
(c) Hunter;
(d) Huntington; and
(e) Dave Johnston.
Response to IPUC Data Request 167
The Company assumes the request for"monthly coal inventory by both dollars
and tons in 2024" is intended to mean monthly ending coal inventory in both
dollars and tons for the test year as provided in work paper 8.6.1. Based on the
foregoing assumption, the Company responds as follows:
Please refer to Confidential Attachment IPUC 167 which provides the 2024
monthly ending inventory balances in dollars and tons provided in Exhibit 8.6.1
for Jim Bridger, Craig, Hunter, Huntington, and Dave Johnston plants.
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: Heather Garcia
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 168
IPUC Data Request 168
For the coal plants listed in Request No. 167 above, please provide the
measurement by month and assumptions to determine the tons of coal needed for
to have the following supply:
(a) 30-day.
(b) 45-day.
(c) 60-day.
(d) 75-day.
Response to IPUC Data Request 168
Please refer to Confidential Attachment IPUC 168 which provides the calculation
of coal inventory in tons for a 30-day, 45-day, 60-day and 75-day coal stockpile
for Jim Bridger, Craig, Hunter, Huntington, and Dave Johnston.
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: Heather Garcia
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 169
IPUC Data Request 169
Please provide a schedule showing the costs for EIM Board of State Regulators
(BOSR), Western Resource Adequacy Program (WRAP), and Committee of State
Regulators (COSR) for 2022, 2023 and 2024. Please include the invoices for
those expenses.
Response to IPUC Data Request 169
The Company assumes that the reference to "Committee of State Regulators" is
intended to be a reference to the Committee of State Representatives. Based on
the foregoing assumption, the Company responds as follows:
Please refer to Confidential Attachment IPUC 169.
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: Kelly Wiggins
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 170
IPUC Data Request 170
Please provide the supporting documentation for the forecasted BOSR, WRAP
and COSR expenses.
Response to IPUC Data Request 170
Please refer to the Company's responses to IPUC Data Request 112, IPUC Data
Request 113 and IPUC Data Request 148.
Recordholder: Ben Faulkinberry/Vijay Singh
Sponsor: Paul Wood

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 171
IPUC Data Request 171
Please provide the following information for all capital projects included for
recovery that have closed through June of 2024 in spreadsheet format. Please treat
this as a continuing request by appending to the spreadsheet for project closes
each succeeding month.
a. List of projects by project name, description, and project identifier;
b. Actual capital cost vs budgeted cost by project and by project element
(work breakdown structure);
c. Actual in-service dates vs planned in-service dates by project;
d. For any cost element (work breakdown structure) over budget by 5%,
please provide a detailed explanation for the cause of the overage; and
e. If the in-service date of the project went past the planned in-service date,
please provide a detailed explanation of the cause(s).
Response to IPUC Data Request 171
Please refer to Attachment IPUC 17.
Recordholder: Craig Larsen, Various Capital Business Units
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 172
IPUC Data Request 172
CONFIDENTIAL REQUEST -Please provide the following information for the
Foote Creek II-IV (FC) wind project referenced by Hemstreet, DI at 4. Please
include any available work papers with formulas intact. If any of the information
requested below cannot be provided or is not available, please explain why it is
not available or cannot be provided.
(a) According to Hemstreet at 18, the repowering efforts (such as replacing the
existing wind turbines, infrastructure, etc.) do not increase the overall system
capacity of the FC plant. Based on that, please explain the Company's
position in need of repowering the FC plant instead of reusing the existing
plant structures (from previous owner, Terra-Gen).
(b) According to Burns, DI at 21, the Company is forecasting yearly system load
and peak load increase during 2023 —2040 timeframe. Please explain how the
FC plant contribute to mitigating the increasing system and peak load if the
repowering efforts do not increase the plant's overall capacity.
(c) An explanation with necessary justifications, cost-benefits analysis, and
necessary documentation on reusing the existing infrastructure of the FC
plant.
(d) A list of all the potential alternatives the Company considered to fulfill the
need of repowering and explain why the project was selected from the
alternatives supported by the Company's economic analysis (costs and
benefits) comparing them.
(e) An ex lanation wh the re owered FC plant is
% overbuilt at the ca aci of
MW if the
rid curtailment asserts the interconnection limit at
W
MW. Confidential Exhibit 38 at
26.
(f) An explanation with necessary documentation on how the Company
accounted for the cost of removing 64 Wind Turbine Generators (WTGs) and
associated infrastructure, previously owned by Terra-Gen.
(g) A copy of the Large Generator Interconnection Agreement(LGIA) associated
with the FC plant.
(h) A copy of the Build Transfer Agreement (BTA) associated with the FC plant.

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 172
(i) Please provide the following information regarding all RFPs or RFQs
associated with the development and construction of the FC 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.
0) 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.
(k) Please provide the following for the Baseline Construction Project:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the differences,
explain the reason for the change, and provide evidence that the changes
were approved at the appropriate level;
v. Project status reports and action items; and
vi. Contractor change orders.
(1) 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;
in. For any budget-to-actual cost overages by major WBS category that is
over 5%, please explain the reason for the differences and provide
evidence that the amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction
schedule.
Response to IPUC Data Request 172
(a) The Foote Creek II-IV wind project provides a high relative contribution to
system capacity given the favorable wind resource at the Foote Creek Rim
site. While the repowering efforts did not increase the overall interconnection
capacity of the project, maintaining capacity from the project by repowering

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 172
the site provides an important contribution to maintaining the existing system
capacity provided by wind resources. PacifiCorp's experience with
repowering the adjacent Foote Creek I site with similar turbine types as were
originally installed at Foote Creek II-IV made it clear that operating the
existing Foote Creek II-IV project without repowering would not be economic
for customers given the high cost of operating the turbines originally installed
at the site. Repowering the site with new turbines provided a better economic
outcome for customers given the ability of a repowered project to qualify for
production tax credits (PTC) and because modern, higher capacity wind
turbines provided lower operations and maintenance (O&M) costs while
producing significantly more energy. Unlike other, later vintage projects
PacifiCorp has repowered, the existing Mitsubishi turbines at the Foote Creek
II-IV wind project did not have wind turbine components that could be reused
since Mitsubishi no longer sells wind turbines in the United States (U.S.) and
there was no partial repowering solution available that would have reused the
existing plant structures.
(b) While the Foote Creek plant's interconnection capacity was not modified as
part of repowering, retaining the energy and capacity provided by the Foote
Creek II-IV wind project helps mitigate increasing system and peak load
conditions by not losing a valuable wind resource that contributes to meeting
energy and capacity requirements. Additionally, the higher generation output
from the project after repowering increases system energy and capacity
benefits as compared to the original project without repowering. Please also
refer to the Company's response to subpart(a) above.
(c) As described in the Company's response to subpart(a) above, unlike most
other wind projects that PacifiCorp has repowered, it was not possible to reuse
existing turbine infrastructure at Foote Creek II-IV because the original
equipment manufacturer(OEM), Mitsubishi Heavy Industries, Inc., did not
offer a repowering solution that would have allowed existing plant wind
turbine components to be reused while requalifying the project for PTCs.
PacifiCorp's experience with the adjacent Foote Creek I facility, which used
similar turbines, indicated that full site repowering was a much better
economic alternative for customers than retaining existing project wind
turbine infrastructure. This economic outcome was a result of increased
energy production available from new wind turbines with lower O&M costs,
and the ability of a repowered project to qualify for PTCs, which are available
to the Foote Creek II-IV wind project at 110 percent value under the Inflation
Reduction Act of 2022 (IRA). Where possible, the Foote Creek II-IV wind
project utilized existing plant infrastructure including site access roads,
switchgear facilities, and existing O&M facilities, resulting in reduced project
costs.

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 172
(d) Please refer to the Company's response to IPUC Data Request 153 subpart
(b).
(e) The Foote Creek II-IV wind project has an installed nameplate turbine
capacity higher than the interconnection limit because the site has very
favorable wind conditions across a broad range of wind speeds and the site is
not land-constrained. The higher installed nameplate capacity allows a greater
amount of energy to be produced from the project at all times other than
infrequent periods when wind speeds are at their greatest and project output
would exceed the interconnection limit. This increases the amount of cost-
effective generation from the project that can serve customers.
(f) Terra-Gen removed the 64 wind turbine generators (WTG) and other
associated infrastructure not relevant to the repowering effort prior to
PacifiCorp's acquisition of the project. As such, the Company had no special
accounting treatment, such as a retirement, related to Terra-Gen's actions to
prepare the site for acquisition by PacifiCorp.
(g) Please refer to Confidential Attachment IPUC 172.
(h) There is no build transfer agreement (BTA) associated with the Foote Creek
II-IV wind project. The Company executed a turbine supply agreement(TSA)
and a balance of plant(BOP) wind energy construction agreement to complete
the project.
(i) Please refer to the Company's response to IPUC Data Request 153 subpart
(c).
(j) Please refer to the Company's response to IPUC Data Request 153 subpart
(d).
(k) Please refer to the Company's response to IPUC Data Request 153 subpart
(e).
(1) Please refer to the Company's response to IPUC Data Request 153 subpart(f).
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: Shruti Ladge
Sponsor: Tim Hemstreet

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 173
IPUC Data Request 173
CONFIDENTIAL REQUEST -Please provide the following information for the
Rock River I (RR)wind project referenced by Hemstreet, DI at 5. Please include
any available work papers with formulas intact. If any of the information
requested below cannot be provided or is not available, please explain why it is
not available or cannot be provided.
(a) According to Hemstreet at 18, the repowering efforts (such as replacing the
existing wind turbines, infrastructure, etc.) do not increase the overall system
capacity of the RR plant. Based on that, please explain the Company's
position in need of repowering the RR plant instead of reusing the existing
plant structures (from previous owner, Shell).
(b) According to Burns, DI at 21, the Company is forecasting yearly system load
and peak load increase during 2023 —2040 timeframe. Please explain how the
RR plant contribute to mitigating the increasing system and peak load if the
repowering efforts do not increase the plant's overall capacity.
(c) An explanation with necessary justifications, cost-benefits analysis, and
necessary documentation on reusing the existing infrastructure of the RR
plant.
(d) A list of all the potential alternatives the Company considered to fulfill the
need of repowering and explain why the project was selected from the
alternatives supported by the Company's economic analysis (costs and
benefits) comparing them.
(e) An explanation why the re powered RR plant is
OXO overbuilt at the ca acity of
MW if the
rid curtailment asserts the interconnection limit at
MW. Confidential Exhibit 39 at 23.
(f) An explanation with necessary documentation on how the Company
accounted for the cost of removing 50 Wind Turbine Generators (WTGs) and
associated infrastructure, previously owned by Shell.
(g) A copy of the Large Generator Interconnection Agreement (LGIA) associated
with the RR plant.
(h) A copy of the Build Transfer Agreement (BTA) associated with the RR plant.

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 173
(i) Please provide the following information regarding all RFPs or RFQs
associated with the development and construction of the RR 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.
0) 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.
(k) Please provide the following for the Baseline Construction Project:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the differences,
explain the reason for the change, and provide evidence that the changes
were approved at the appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
(1) 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;
in. For any budget-to-actual cost overages by major WBS category that is
over 5%, please explain the reason for the differences and provide
evidence that the amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction
schedule.
Response to IPUC Data Request 173
(a) The Rock River I wind project provides a high relative contribution to system
capacity given the favorable wind resource in the Foote Creek Rim area where
the project is located. While the repowering efforts did not increase the overall
interconnection capacity of the project, maintaining capacity from the project

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 173
by repowering the site provides an important contribution to maintaining the
existing system capacity provided by wind resources. PacifiCorp's experience
with repowering the adjacent Foote Creek I site with similar turbine types as
were originally installed at Rock River I made it clear that repowering the site
with new turbines provided a better economic outcome for customers given
the ability of a repowered project to qualify for production tax credits (PTC)
and because modern, higher capacity wind turbines provided lower operations
and maintenance costs while producing significantly more energy. Unlike
other, later vintage projects PacifiCorp has repowered, the existing Mitsubishi
turbines at the Rock River I project did not have wind turbine components that
could be reused since Mitsubishi no longer sells wind turbines in the United
States (U.S.) and there was no partial repowering solution available that
would have reused the existing plant structures.
(b) While the Rock River I plant's interconnection capacity was not modified as
part of repowering, retaining the energy and capacity provided by the Rock
River I wind project helps mitigate increasing system and peak load
conditions by not losing a valuable wind resource that contributes to meeting
energy and capacity requirements. Additionally, the higher generation output
from the project after repowering increases system energy and capacity
benefits as compared to the original project without repowering. Please also
refer to the Company's response to subpart(a) above.
(c) As described in the Company's response to subpart(a) above, unlike most
other wind projects that PacifiCorp has repowered, it was not possible to reuse
existing turbine infrastructure at Rock River I because the original equipment
manufacturer (OEM), Mitsubishi Heavy Industries, Inc., did not offer a
repowering solution that would have allowed existing plant wind turbine
components to be reused while requalifying the project for PTCs. PacifiCorp's
experience with the nearby Foote Creek I facility, which used similar vintage
turbines, indicated that full site repowering was a much better economic
alternative for customers than retaining existing project wind turbine
infrastructure. This economic outcome was a result of increased energy
production available from new wind turbines with lower operations and
maintenance (O&M) costs, and the ability of a repowered project to qualify
for PTCs,which are available to the Rock River I wind project at 110 percent
value under the Inflation Reduction Act of 2022 (IRA). Where possible, the
Rock River I wind project utilized existing plant infrastructure including
energy collector system components, site access roads, and existing O&M
facilities, resulting in reduced project costs.
(d) The Rock River I wind project was reviewed as part of the Company's 2021
Integrated Resource Plan (IRP) and the project was made available as a
potential resource that could meet customer energy and capacity needs in the
model used to develop the 2021 IRP. The Company's 2021 IRP showed a

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 173
need for additional resources to meet energy and capacity needs. Because the
resource was found to be beneficial to customers it was included as part of a
least-cost, least-risk portfolio, and was identified as a resource in the preferred
portfolio. Action Item 2b of the 2021 IRP included acquisition and repowering
of the Rock River I project consistent with the current timeframe of the
project. The alternative of not pursuing the acquisition and repowering of the
Rock River I wind project was considered, but this would not allow the
benefits of the project to flow to customers, resulting in increased customer
costs. As mentioned in the Company's response to subpart (a) above, the
project was reviewed in the 2021 IRP and compared against other resource
alternatives and selected as a component of the least-cost, least-risk portfolio.
Please refer to PacifiCorp's 201 IRP, Volume I, Chapter 7 (Resource Option),
Table 7.1 (2021 Supply-Side Resource Table (2020$)) which provides a list of
alternative resources available for selection by the IRP planning model.
(e) The Rock River I wind project has an installed nameplate turbine capacity
higher than the interconnection limit because the site has very favorable wind
conditions across a broad range of wind speeds and the site is not land-
constrained. The higher installed nameplate capacity allows a greater amount
of energy to be produced from the project at all times other than infrequent
periods when wind speeds are at their greatest and project output would
exceed the interconnection limit. This increases the amount of cost-effective
generation from the project that can serve customers.
(f) The former owners of the project removed the originally installed wind
turbine generators (WTG) and other associated infrastructure not relevant to
the repowering effort prior to PacifiCorp's acquisition of the project. As such,
the Company had no special accounting treatment, such as a retirement,
related to the former owners' actions to prepare the site for acquisition by
PacifiCorp.
(g) Please refer to Confidential Attachment IPUC 173-1.
(h) There is no build transfer agreement (BTA) associated with the Rock River I
wind project. The Company executed a turbine supply agreement(TSA) and a
balance of plant (BOP)wind energy construction agreement to complete the
project.
(i) A request for proposals (RFP)was submitted for both the turbine supply and
balance of plant (BOP) construction components of the project.
Please refer to Confidential Attachment IPUC 173-3 which provides
information related to the wind turbine RFP for the project, specifically
confidential folders (1) "TSA RFP Package CONF", (2) "TSA Bids and
evaluation scorecard matrix CONF"which provides the selection criteria and

PAC-E-24-04/Rocky Mountain Power
August 23, 2024
IPUC Data Request 173
result, and(3) "TSA Accepted bid CONF"which provides the winning bid
documentation.
Please refer to Confidential Attachment IPUC 173-2 which provides the
requested BOP RFP documentation, specifically confidential folders (1) "BoP
RFP Package CONF". Note: the RFP package was issued to potential bidders
that included all firms that had previously provided wind repower services or
field work to PacifiCorp, (2) "BoP Bidder Scorecard CONF"which provides
the selection process scorecards, and (3) `BoP Accepted Proposal CONF"
which provides the auction report.
(j) Please refer to Confidential Attachment IPUC 173-3 which provides the
appropriation request(APR) 90001555 which includes the requested detailed
project scope, project budget, and initial proposed project schedule. The
special delegation of authority document is the evidence of the project plan
and budget approval at the appropriate level.
(k) Please refer to Confidential Attachment IPUC 173-3 which provides the APR
and includes the baseline construction project plan, scope, budget and
schedule. A more refined description of the project's construction scope and
schedule is provided in Confidential Attachment IPUC 173-4. The Rock River
I wind project is proceeding within the approved cost and schedule consistent
with the APR. Please refer to Confidential Attachment IPUC 173-5 which
provides copies of the change orders for the balance of plant construction
agreement and turbine supply agreement.
(1) The Rock River I repowering project is currently ongoing and it is on
schedule and within the budget approved in the APR (please refer to
Confidential Attachment IPUC 173-3 which provides the supporting
documents). The Rock River I wind project has yet to achieve commercial
operation.
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.
Responder: Shruti Ladge
Sponsor: Tim Hemstreet

Joe Dallas (ISB# 10330)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email:[e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-24-04
IN THE MATTER OF THE )
APPLICATION OF ROCKY ) ATTORNEY'S CERTIFICATE
MOUNTAIN POWER FOR ) CLAIM OF CONFIDENTIALITY
AUTHORITY TO INCREASE ITS ) RELATING TO DISCOVERY
RATES AND CHARGES IN IDAHO ) RESPONSES
AND APPROVAL OF PROPOSED )
ELECTRIC SERVICE SCHEDULES )
AND REGULATIONS )
I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a
attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its response,is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code Section 74-101, et seq. and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the response to IPUC set 9 contains Company proprietary information that could be
used to its commercial disadvantage.
1

Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential information that the information contains Company proprietary information.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
Protective Agreement in this proceeding.
DATED this 23rd day of August, 2024.
Respectfully submitted,
L�- -
By
Joe Dallas
Attorney
Rocky Mountain Power
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