20240829PAC to Staff 175-177_179-189_192-201_203-204.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 29, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
[e-mail]
[e-mail]
RE: ID PAC -E-24-04
IPUC Set 10 (175-204)
Please find enclosed Rocky Mountain Power’s Responses to IPUC 10th Set Data Requests 175-
204, excluding 178, 190, 191 & 202. The remaining response will be provided under separate
cover. Also provided are Attachments IPUC 175, 176-7, and 198. 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 [e-mail] (C)
Lance Kaufman/IIPA [e-mail] (C)
Matthew Nykiel/ICL [e-mail]
Brad Heusinkveld/ICL [e-mail]
Thomas J. Budge/Bayer [e-mail] (C)
Brian C. Collins/Bayer [e-mail]
Greg Meyer/Bayer [e-mail]
Kevin Higgins/Bayer [e-mail] (C)
Neal Townsend/Bayer [e-mail] (C)
RECEIVED
Thursday, August 29, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Ronald L. Williams/PIIC [e-mail]
Brandon Helgeson/PIIC [e-mail]
Bradley Mullins/PIIC [e-mail]
Val Steiner /PIIC [e-mail]
Kyle Williams/PIIC [e-mail]

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 175

IPUC Data Request 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.

Response to IPUC Data Request 175

Please refer to Attachment IPUC 175.

Recordholder: Sam Hayden

Sponsor: Julie Lewis

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 176

IPUC Data Request 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.

Response to IPUC Data Request 176

Please refer to Confidential Attachment IPUC 176 -1 and Confidential
Attachment IPUC 176-2 which provide Wellmark “Fixed Fee Guarantee”
documents for 2023 and 2024. Note: the contract is managed by Berkshire
Hathaway Energy Company (BHE).

Please refer to Confidential Attachment IPUC 176-3 and Confidential Attachment
IPUC 176-4 which provide Wellmark “Administrative Services Only” fees for
2021 through 2023 and 2024 through 2026, respectively.

Please refer to Confidential Attachment IPUC 176-5 which provides a copy of the
MetLife Dental contract, and Confidential Attachment IPUC 176-6 which
provides a copy of the amendment to the MetLife Dental contract.

The “Administrative Services Only” rates are provided below.

Please refer to Attachment IPUC 176-7 which provides the calculation of the pro-
form 401(k) expense.

Note: all 2023 actual amounts were pulled from the Company’s accounting
system for the starting point of this adjustment.

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: Denise Neimann

Sponsor: Julie Lewis
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 177

IPUC Data Request 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.

Response to IPUC Data Request 177

Please refer to Confidential Attachment IPUC 177.

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: Matthew Swanson

Sponsor: Julie Lewis

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 179

IPUC Data Request 179

Please provide a list of the Officer’s salaries by office for years 2022, 2023, and
2024.

Response to IPUC Data Request 179

Please refer to Confidential Attachment IPUC 179.

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: Matthew Swanson

Sponsor: Julie Lewis

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 180

IPUC Data Request 180

Please provide the 2022, 2023, and 2024 Federal and State employee withholding
and unemployment reports.

Response to IPUC Data Request 180

The Company’s the Company’s Federal tax returns, as well as state returns for the
states in the Company’s service territories (Oregon, Washington, California,
Idaho, Utah and Wyoming), where the majority of the Company’s employees
reside and work are highly confidential and commercially sensitive. The
Company requests special handling. Please contact Mark Alder at [phone]
to make arrangements to review the Company’s Federal tax returns, as well as
state returns for the states in the Company’s service territories (Oregon,
Washington, California, Idaho, Utah and Wyoming), where the majority of the
Company’s employees reside and work.

The Company pays Idaho withholding via Automated Clearing House (ACH)
wire every payroll period, therefore, a vendor line item report for the State of
Idaho is included for each year.

For 2022 through 2024, the Company has had a minimal number of employees
living and working in states outside of the service territory. These employees
were working in up to 17 states and there were often one or two employees in
each state. Providing additional tax returns may compromise personal data.

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: Jennifer Dudas

Sponsor: Julie Lewis

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 181

IPUC Data Request 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”.

(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.

Response to IPUC Data Request 181

(a) Emergency Purchases are modeling resources that act as backstop in the event
of energy, ramp or capacity (namely “Ancillary Services”) shortfall to meet
the system obligations.

(b) As noted in the Company’s response to subpart (a) above, the emergency
purchase resources are dispatched in the event of supply shortfall. Lines 171
through 218 of tab “Emerg Purch+Trapp Sales” in the confidential net power
costs (NPC) report “ID_GRC_2025_2023 Normalized Load.xlsm” are the
resources that were dispatched, depending on transmission constraints to
ensure that system obligations are met.

(c) Emergency purchases are valued at 125 percent of relevant market prices.

(d) The Company assumes that the reference to “the cost impact of Emergency
Purchases on Net Power Costs” is intended to reflect the total cost of
Emergency Purchases in the NPC proposed in this general rate case (GRC).
Based on the foregoing assumption, the Company responds as follows:

The total cost of Emergency Purchases in confidential NPC report
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 181

“ID_GRC_2025_2023 Normalized Load.xlsm” is $7.6 million and is 0.032
percent of NPC.

(e) Not applicable.

(f) The Company assumes that the reference to “Column “Discount/Premium”” is
to column R on tab “Emerg Purch+Trapp Sales” in confidential NPC file
“ID_GRC_2025_2023 Normalized Load.xlsm”. Based on foregoing
assumption, the Company responds as follows:

Column R (“Discount/Premium”) represents the price at which Emergency
Purchases are calculated in NPC. Additionally, please refer to the Company’s
response to subpart (c) above.

(g) As stated in the Company’s response to subpart (f) above, the Company
assumes that the reference to “Column “Discount/Premium”” is to column R
on tab “Emerg Purch+Trapp Sales” in confidential NPC file
“ID_GRC_2025_2023 Normalized Load.xlsm”. Based on foregoing
assumption, the Company responds as follows:

Column R (“Discount/Premium”) is a multiplier that reflects a premium on
the emergency purchases modeling construct.

Recordholder: Eshwar Vyakarna Rajshekar Rao

Sponsor: Ramon Mitchell

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 182

IPUC Data Request 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.

Response to IPUC Data Request 182

(a) Utah Schedule 34 is a schedule under which large customers are supplied
under specific contractual agreements from a specific set of generating
resources. Utah Schedule 34 contains provisions that obligate the customer to
“continue to pay all of the costs of the renewable energy resource(s) acquired
by the Company on the Customer’s behalf in the event the Customer contract
is terminated early and a cost obligation related to the renewable energy
resource(s) continues beyond the termination” of the Utah Schedule 34
agreement. Information regarding Utah Schedule 34 is publicly available and
can be accessed by using the following link to the Public Service Commission
of Utah’s (UPSC) website provided below:

rockymountainpower.net/content/dam/pcorp/documents/en/rockymountainpo
wer/rates-
regulation/utah/rates/034_Renewable_Energy_Purchases_for_Qualified_Cust
omers_5000kW_and_Over.pdf

(b) Referencing confidential net power costs (NPC) report “ID_GRC_2025_2023
Normalized Load.xlsm”, column C refers to the load forecast for customers
contracted under Utah Schedule 34. Columns D through J refers to the
generation forecast from the resources noted on the tab.

(c) Referencing confidential net power costs (NPC) report “ID_GRC_2025_2023
Normalized Load.xlsm”, columns R though U refer to the costs at which the
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 182

Company buys back excess generation from the generating resource that were
designated to provide energy to customers under Utah Schedule 34.

(d) Referencing confidential net power costs (NPC) report “ID_GRC_2025_2023
Normalized Load.xlsm”, the prices in dollars per kilowatt-hour ($/kWh) units
noted in column R through column U have been approved by the UPSC under
Utah Schedule 37. Information on Utah Schedule 37 is publicly available and
can be accessed by using the following website link:

rockymountainpower.net/content/dam/pcorp/documents/en/rockymountainpo
wer/rates-
regulation/utah/rates/037_Avoided_Cost_Purchases_from_Qualifying_Faciliti
es.pdf

(e) Referencing confidential net power costs (NPC) report “ID_GRC_2025_2023
Normalized Load.xlsm”, rows 21 through 27 refer to the costs associated with
generating at the resources noted on the tab.

(f) Referencing confidential net power costs (NPC) report “ID_GRC_2025_2023
Normalized Load.xlsm”, rows 21 through 27 are the power purchase
agreement (PPA) costs of these resources as set forth in their respective
contractual agreements.

Recordholder: Eshwar Vyakarna Rajshekar Rao

Sponsor: Ramon Mitchell

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 183

IPUC Data Request 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.

Response to IPUC Data Request 183

Referencing confidential net power costs (NPC) report “ID_GRC_2025_2023
Normalized Load.xlsm”, the Company responds as follows:

(a) “EIM Inter-regional Benefit ($)” refers to the inter-entity (balancing authority
area (BAA)) energy transfer benefits associated with the Company’s
participation in the Western energy imbalance market (EIM).
PacifiCorp uses the following steps to forecast EIM benefits:

• PacifiCorp uses calculations from Power Settlements Consulting &
Software, LLC (Settlecore) to calculate the monthly historical EIM
transfer benefits for both the PacifiCorp West (PACW) and PacifiCorp
East (PACE) BAAs.

• The benefits are allocated into four categories based on BAA and energy
transfer direction:

− PACE exports.
− PACE imports.
− PACW exports.
− PACW imports.

The purpose of the categories is to isolate the different ways PacifiCorp
accrues EIM transfer benefits to forecast EIM transfer benefits more
accurately for each category.

• PacifiCorp then uses the following variables in a logarithmic regression
model to forecast EIM benefits for each category described above.

− Monthly EIM benefit by BAA and energy transfer direction.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 183

− Historical monthly electricity prices.
− Historical monthly gas prices.
− Future monthly electricity prices.
− Future monthly gas prices.
− Transmission capacity connecting PACE and PACW to the California
Independent System Operator (CAISO).
− Total solar capacity from operational and planned resources in the
CAISO. Used to estimate the amount of solar energy that the CAISO
can export into the EIM during spring months.
− Dummy variable to account for when PacifiCorp and the CAISO were
the only EIM entities.
− Dummy variable to account for the Enbridge pipeline explosion.
− Error term.

• The logarithmic regression is run using the statistical computing software
R to produce forecasts for the relevant period.

(b) “EIM Inter-regional Benefit (GHG Margin) ($)” refers to the revenue received
in the EIM from greenhouse gas (GHG) requirements under California’s Cap
and Trade program. PacifiCorp uses the following steps to forecast the GHG
benefits.

• PacifiCorp uses calculations from Settlecore to calculate the monthly
historical EIM GHG benefits.

• PacifiCorp then gathers data from the following public sources.

− Historical California Air Resources Board (CARB) California Carbon
Allowance (CCA) auction prices.
− Intercontinental Exchange (ICE) CCA future prices.

• PacifiCorp uses the historical GHG benefits and historical allowance
prices to determine the average GHG benefit per dollar of allowance price
per month.

− This is then aggregated into a seasonal average historical GHG benefit
per dollar of allowance price.

• The seasonal average historical GHG benefit is then multiplied by the ICE
future allowance price, respective of the season, to determine the GHG
benefit forecast.

(c) “Wheeling - EIM Expense Booked to FERC 565” refers to the cost associated
with the EIM grid management charge (GMC) charge and transaction fee.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 183

Please refer to the confidential work paper supporting the direct testimony of
Company witness, Ramon J Mitchell, specifically confidential file
“GNw_Wheeling CONF”, tab “WheelingCosts”, rows 44 and 45 for the costs
associated with EIM expenses that are booked to FERC Account 565. The
costs for test period 2025 are based on the average of the historical costs
incurred.

Recordholder: Eshwar Vyakarna Rajshekar Rao / Vijay Singh

Sponsor: Ramon Mitchell

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 184

IPUC Data Request 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 DA/RT 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.

Response to IPUC Data Request 184

(a) The Company inputs market prices that are day-ahead / real-time (DA/RT)
adjusted. The Company does not input prices where the power purchase and
power sales are at the same OFPC, and this aligns with how pricing works in
the real electricity markets.

(b) The Company does not have the ability to identify the hours and months when
large market purchases are expected in 2025 since the Aurora model
optimizes the market purchases and sales. Based on market fundamentals such
as Company’s weather normalized load input into the Aurora model, the
Company reasonably expects the high load months during Summer and
Winter to have the highest amount of market purchases to fulfil its energy
obligations.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 184

(c) Please refer to Confidential Attachment IPUC 184 which provides the graphs
that were presented to Idaho Public Utilities Commission (IPUC) staff during
a workshop held on July 23, 2024. As can be seen in the provided attachment,
the proposed percentile modifier is more accurately representative of reality.
While the percentile modifier is not the same as the “actual modifiers”,
implementation of percentile modifiers is a step in the right direction to align
NPC forecasting with actual operational reality encountered by the Company.
Note: Implementing “actual modifiers” will increase net power costs (NPC) as
seen in the Company’s response to IPUC Data Request 107.

Additionally, please refer to the confidential work papers supporting the direct
testimony of Company witness, Ramon J. Mitchell, specifically confidential
file “Aurora GN Market Price”, tab “Adder Source”, rows 156-203 that show
the prices at which the Company purchased and sold power when compared to
the OFPC. The data shows the correct direction of changes compared to
reality during the timeframes when large amounts of transactions occurred in
the historical data that form the source for the modifier s.

(d) Please refer to the Company’s response to subpart (c) above, inclusive of the
workbook data referenced. The proposed percentile modifiers more closely
reflect the magnitude of variance that occurs in actual operations as compared
to the flat modifiers.

(e) The Company objects to this request as unduly burdensome, requesting the
creation of a new analysis or report, and not reasonably calculated to lead to
the discovery of admissible evidence. Without waiving the foregoing
objection, the Company responds as follows:

The Company has not created the requested new analysis.

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: Eshwar Vyakarna Rajshekar Rao

Sponsor: Ramon Mitchell

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 185

IPUC Data Request 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 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.

Response to IPUC Data Request 185

(a) Yes. The Company applies percentile modifiers to market sale prices as an
input into the Aurora model for net power costs (NPC ) forecasting.

(b) As mentioned in the direct testimony of Company witness, Ramon J. Mitchell,
pages 47 and 48, “the Company has historically bought more during higher-
than-average price periods and sold more during lower-than-average price
periods. To better reflect the market prices available to the Company when it
transacts in the real-time market, the Company includes separate prices for
forecast system balancing sales and purchases in Aurora. These prices account
for the historical price differences between the Company’s purchases and
sales compared to the trading hub-indexed market prices”. This is supported
by the data and can be seen in the confidential work papers supporting Ramon
J. Mitchell’s direct testimony, specifically confidential file “Aurora GN
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 185

Market Price”, tab “Adder Source”, rows 153-204.

(c) The Company does not have the ability to identify the hours and months when
large market sales are expected in 2025 since the Aurora model optimizes the
market purchases and sales. Based on market fundamentals, the Company
reasonably expects the light load months during Spring and Fall to have
relatively higher amount of market sales due to light net load and relatively
increased hydroelectric generation.

(d) Please refer to confidential work papers supporting Ramon Mitchell’s direct
testimony, specifically confidential file “Aurora GN Market Price”, tab
“Adder Source”, rows 156-203 that show the prices at which the Company
purchased and sold power when compared to the OFPC. This data shows that
the percentile modifiers are being applied to market sales and purchases.
Additionally, the data shows the correct direction of changes compared to
reality during the timeframes when large amounts of sales occurred in the
historical data that form the source for the modifiers (i.e, during the hours
which the Company typically makes sales, the prices are adjusted downwards
and during the hours when the Company typically makes purchases, the prices
adjusted upwards). Please note that the charts provided with the Company’s
response to IPUC Data Request 184, specifically Confidential Attachment
IPUC 184, are only reflective of the adjustment to purchase prices, and do not
contain any data on sales, or sales prices.

(e) Please refer to the Company’s response to subpart (c) above, inclusive of the
workbook data referenced. The proposed percentile modifiers more closely
reflect the magnitude of variance that occurs in actual operations as compared
to the flat modifiers.

(f) The Company objects to this request as unduly burdensome, requesting the
creation of a new analysis or report, and not reasonably calculated to lead to
the discovery of admissible evidence. Without waiving the foregoing
objection, the Company responds as follows:

The Company has not created the requested new analysis.

Recordholder: Eshwar Vyakarna Rajshekar Rao

Sponsor: Ramon Mitchell

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 186

IPUC Data Request 186

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.

Response to IPUC Data Request 186

The Company objects to this request as unduly burdensome, requesting the
creation of a new analysis or report, and not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving the foregoing objection, the
Company responds as follows:

The Company has not created the requested new analysis.

Recordholder: Eshwar Vyakarna Rajshekar Rao

Sponsor: Ramon Mitchell

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 187

IPUC Data Request 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 work papers.

Confidential Response to IPUC Data Request 187

The Company assumes that the reference to “market sales volumes and revenues”
is intended to refer to the “System Balancing Sales” volumes and revenues in the
net power costs (NPC) forecast modeling. Based on the foregoing assumption, the
Company responds as follows:

(a) The megawatt-hour (MWh) amount associated with system balancing sales in
the Aurora modeling is
MWh.

(b) Please refer to the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, specifically confidential NPC report
“ID_GRC_2025_2023 Normalized Load.xlsm”, tab “NPC”; rows 379-385 for
the MWh associated with System Balancing Sales as calculated by the Aurora
model for NPC forecast.

(c) The dollar amount associated with the MWh system balancing sales as
identified in subpart (a) above is $248.4 million.

(d) Please refer to confidential NPC report “ID_GRC_2025_2023 Normalized
Load.xlsm”, tab “NPC”; row 44 for revenues associated with System
Balancing Sales as calculated by the Aurora model for NPC forecast.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 187

(e) The revenue associated with system balancing sales is calculated by the
Aurora model based on the MWh amount of sales transacted at the various
trading hubs modeled in the forecast. It is calculated as the product of market
price and MWh sales.

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: Eshwar Vyakarna Rajshekar Rao

Sponsor: Ramon Mitchell

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 188

IPUC Data Request 188

Please explain why capacity limits are only applied to market sales in the Aurora
model, but not applied to market purchases.

Response to IPUC Data Request 188

As noted in the direct testimony of Company witness, Ramon J. Mitchell, the
Aurora model has perfect foresight and when coupled with full liquidity (no
market sales capacity limits), the model will make unlimited and unrealistic off-
system sales at each of the Company’s trading hubs at all time periods in a day
which is contrary to the Company’s experience in actual operations. This can be
observed in the energy cost adjustment mechanism (ECAM), which has heavily
erroneous market sales volumes. The market capacity limits inform Aurora of the
limits on the depth of the markets being modeled, as per the Company’s historical
sales transactions at various trading hubs, thereby forcing Aurora to respect those
limits during the execution of its optimization algorithm.

Regarding market purchases, the forecast market purchase volumes have not been
heavily erroneous as compared to the market sales volumes.

Recordholder: Eshwar Vyakarna Rajshekar Rao

Sponsor: Ramon Mitchell

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 189

IPUC Data Request 189

Please provide the following information for the U0 – 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 (RFP) or Request for Quote (RFQ) was submitted,
please provide the following information:

i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.

(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);
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
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 189

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.

Response to IPUC Data Request 189

Please refer to Confidential Attachment IPUC 189 which provides the project
proposal documentation used in the approval process for the U0 – Mill Blanket -
2023 project.

(a) The referenced project is a blanket to properly account for property retirement
units (PRU) associated with pulverizer components. Each year a project is
created and approved for estimated PRU replacements based on historical
replacements. Each PRU that is replaced has a sub-level appropriation request
(APR) created and justified based on corporate governance criteria.

(b) Each PRU replacement is justified based on its own merits. Typically, the
alternative to not replace the PRU will result in a permanent derate of the unit.

(c) Each PRU may or may not require a request for proposals (RFP) or request for
quotes (RFQ) based on the component. In most cases the original equipment
manufacturer (OEM) parts are required for the replacement PRU.

(d) The Initial Project Plan included the following:

• Project Scope – Mills, or pulverizers, pulverize coal pieces to a powder for
efficient combustion. To maintain generation and productivity at the Dave
Johnston, there is an amount of mill maintenance that must be completed
throughout the year. The strategic fit is to cover costs for mill maintenance
including, but not limited to, grinding zones, shaft replacements, trunnion
replacements, primary air motor refurbishments, roll sets, etc.

• The initial project budget was $1,567,500 not including allowance for
funds used during construction (AFUDC).

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 189

• The project schedule was for the 2023 calendar year.

• Please refer to the snapshot provided below for the approval workflow
showing that the final approver approved the APR.

(e) This subpart is not applicable since this is a blanket project and there is no
specific scope of work or project schedule defined. The funds approved are
merely an estimate of funds required to do mill failure work based on
historical experience.

(f) This subpart is not applicable since this is a blanket project and there is no
specific scope of work or project schedule defined. The funds approved are
merely an estimate of funds required to do mill failure work based on
historical experience.

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: Alan Dugan / Kevin Lloyd

Sponsor: To Be Determined

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 192

IPUC Data Request 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;
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.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 192

(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.

Response to IPUC Data Request 192

(a) Please refer to Confidential Attachment IPUC 192-1 which provides a copy of
appropriation request (APR) 10030260.

(b) Please refer to Confidential Attachment IPUC 192-1 which provides a copy of
APR 10030260.

Please refer to Confidential Attachment IPUC 192-2 which provides the
following documents:

• Naughton U2 Generator Stator Failure CY22 Mitigation Risk Memo
rev 1

• Naughton Unit 2 Generator Failure (Preliminary) 3_1_22 rw.

(c) Please refer to Confidential IPUC 192-3.

(d) Please refer to Confidential Attachment IPUC 192-1 and 1.92-4 which
provides the following documents:

i. Reference APR 10030260
File “3300005320-WR-GESteamPowerInc.-StatorRewind-
NaughtonU2FinalR2FE_20240821213259.983_X” Exhibit A
ii. Reference APR 10030260; $7.9M
iii. Reference APR 10030260;
File “Pacificorp Naughton Unit 2 schedule Jan 31”
iv. Reference APR 10030260.
SAP Generated Workflow Below:
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 192

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 192

(e) Please refer to Confidential Attachment IPUC 192-5 which provides
copies of the following documents:

i. Reference APR 10030260
File “3300005320-WR-GESteamPowerInc.-StatorRewind-
NaughtonU2FinalR2FE_20240821213259.983_X” Exhibit A
ii. Reference APR 10030260
File “GE Prop 1603109 Rev. 1 Pcorp Naughton LCSR” Section
4.1.1
iii. Reference APR 10030260
File “Pacificorp Naughton Unit 2 schedule Jan 31” From Section D
iv. See Project Change Orders and Extra Work Authorizations
provided in Section E Folder
v. File “Field_Service_Report_ProjectID_NEX-P-309434_SP-EE0-
006287”
vi. See Project Change Orders and Extra Work Authorizations
provided in Section E Folder

(f) Please refer to the Company’s responses to the subparts i. through iv.
below:

i. Please refer to the table provided below:

ii. No major over-runs.

iii. No major cost overages

iv. Please refer to Confidential Attachment IPUC 19 2-6.

Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 192

Recordholder: Matt Murray

Sponsor: Brad Richards
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 193

IPUC Data Request 193

Please provide a schedule showing the costs for the Company’s ESG and DEI
programs for 2021, 2022, 2023 and 2024 to date.

Response to IPUC Data Request 193

Diversity, equity and inclusion (DEI) costs were not tracked separately prior to
2023. The Company spent $60,443.95 in 2023 and has spent $114,305.39 Year to
Date (YTD) in 2024.

PacifiCorp does not have a specific individual environmental, social and
governance (ESG) program. PacifiCorp does support a number of renewable
energy electric transportation, grid modernization, energy efficiency, and
environmental compliance and stewardship activities that are necessary and
support PacifiCorp’s core business and commitments to customers.

Recordholder: Todd Dinehart

Sponsor: To Be Determined

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 194

IPUC Data Request 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.

Response to IPUC Data Request 194

Please refer to Confidential Attachment IPUC 194 which provides a schedule
showing rate base for electric plant in-service (EPIS), accumulated amortization
reserve and accumulated depreciation reserve. Note: the data provided is from
January 2024 through June 2024. Date for July 2024 data is not yet available. The
Company will supplement this data request when the July data becomes available
on or before September 30, 2024. The data for April 2024 through June 2024 is
confidential as the Company has not publicly reported on those amounts at this
time.

Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Craig Larsen

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 195

IPUC Data Request 195

Please provide copies or provide access to the contracts for the following projects:

(a) Wind Generation.

(b) Gateway South.

Response to IPUC Data Request 195

The Company objects to this request to the extent it is vague and ambiguous.
Subject to and without waiving the foregoing objection, the Company responds as
follows:

(a) The Company assumes that the reference to “Wind Generation” is intended to
be a reference to the following Company-owned wind generation resources
that either became commercially operational during calendar year 2023 or will
be commercially operation during calendar years 2024 and 2025. Specifically,
the Foote Creek II-IV, Rock Creek I, Rock Creek II and Rock River I wind
projects. Based on the foregoing assumption, the Company responds as
follows:

• Foote Creek II-IV – Please refer to Confidential Attachment IPUC 195-1.

• Rock Creek I – please refer to the direct testimony of Company witness,
Jeffrey R. Wagner, specifically Confidential Exhibit No. 42 (Rock Creek I
BTA).

• Rock Creek II – Please refer to Confidential Attachment IPUC 195-2.

• Rock River I - Please refer to Confidential Attachment IPUC 195-3.

(b) Energy Gateway South - Please refer to the Company’s response to IPUC
Data Request 130.

Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Tim Hemstreet / Jeff Wagner / Brandon Smith

Sponsor: Tim Hemstreet / Jeff Wagner / Todd Jensen
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 196

IPUC Data Request 196

Please provide copies of or access to the Internal Audit Reports listed in
confidential Attachment A.

Response to IPUC Data Request 196

The Company assumes that the reference to “confidential Attachment A” is
intended to be a reference to Confidential Attachment A on page 22 of the
incoming request and which lists a subset of internal audit reports from the
Company’s response to IPUC Data Request 19. Based on the foregoing
assumptions, the Company responds as follows:

For ease of reference, the subset list of internal audit reports is listed below:

Please refer to Confidential Attachment IPUC 196 which provides copies of the
Company’s internal audit reports listed in Idaho Public Utilities Commission
(IPUC) staff’s Confidential Attachment A to this request.

In addition, the Company states as follows: (1) the “Memo – Investigation
Summary” dated March 16, 2023 is a code of conduct report and therefore
classified highly confidential and business sensitive, and (2) internal report 23-
AUD-02 “PacifiCorp OTN/VA Final Report” dated February 5, 2024 is a critical
infrastructure protection standards (CIPS) report and therefore classified highly
confidential. The Company requests special handling. Please contact Mark Alder
at [phone] to make arrangements for a review.

Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 196

Recordholder: Seth Awram

Sponsor: Seth Awram

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 197

IPUC Data Request 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.

(f) 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.

Response to IPUC Data Request 197

The Company’s general rate case (GRC) filing includes projects from 2022 and
2023 in the base period. Adjustment 8.5 includes known and measurable projects
greater than $5 million for 2024. Adjustment Page 8.5.2 of Exhibit No. 48 in
McCoy’s direct testimony is included as a reference for the calculation of
annualized 2023 depreciation expense and accumulated depreciation reserve in
Adjustment 6.1 and Adjustment 6.2. The differences in the plant function amounts
are from the different time periods between the two sets of numbers. The amounts
on Adjustment Page 8.5.2 are limited to projects with electric plant in-service
(EPIS) greater than $5 million from January 2023 through December 2023. The
Company’s response to IPUC Data Request 55, specifically Attachment IPUC 55-
1 included projects with costs from 2022 through June 2024 with EPIS greater
than $5 million. Also, in Attachment IPUC 55-1 costs were reported using the
primary function of the project while Adjustment Page 8.5.2 separated costs into
the final rate base plant functions.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 197

(a) The amount in Attachment IPUC 55-1 is higher than Adjustment Page 8.5.2
because of timing, as discussed above.

(b) Please refer to the Company’s response to subpart (a) above.

(c) Please refer to the Company’s response to subpart (a) above. There are no
single distribution projects greater than $5 million in 2023, therefore, there
was no distribution amount on Adjustment Page 8.5.2.

(d) Please refer to the Company’s response to subpart (a) above.

(e) The information provided in Attachment IPUC 55-1 did not include a project
that was included in the amount shown Adjustment Page 8.5.2. The “Hydro
Pumped Storage Due Diligence” project was written off. It was inadvertently
left in the amount shown on Adjustment Page 8.5.2. The project amount is
$9.3 million. The only impact this write-off will have to this general rate case
(GRC) is to update the annualized depreciation expense and accumulated
depreciation reserve balance in Adjustment 6.1 and Adjustment 6.2. Also, in
Attachment IPUC 55-1 costs were reported using the primary function of the
project while Adjustment Page 8.5.2 separated costs into the final rate base
plant functions.

(f) Please refer to the Company’s response to subpart (a) above.

Recordholder: Jim Etheridge / Theresa Haggard / Craig Larsen

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 198

IPUC Data Request 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.

(g) Account numbers.

Response to IPUC Data Request 198

(a) Please refer to Attachment IPUC 198.

(b) Please refer to Attachment IPUC 198.

(c) While the Company does not record or maintain accumulated depreciation at a
project-by-project level, please refer to the table below which provides the
total calculated accumulated depreciation associated with the assets for each
project as of June 30, 2024:

Project Project Description
Calculated Accumulated
Depreciation as of June
30, 2024
TIOR/2013/C/005 Troutdale Sub 230kV Swtchyd 115kV Rg Bus (1,802,308)
TWAS/2010/C/001 Union Gap Add 230 - 115kV Capacity (7,470,017)
TYAK/2008/C/001 Vantage Pomona Heights 230kV Line (6,366,432)
TZBE/2017/C/002 Vitesse - Facebook 60 MW Load Addition (4,885,257)

(d) Please refer to the table below which provides the total net book value (NBV)
associated with the assets for each project as of June 30, 2024, based on the
calculated accumulated depreciation provided in the Company’s response to
subpart (c) above:

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 198

Project Project Description Calculated Net Book
Value as of June 30,
2024
TIOR/2013/C/005 Troutdale Sub 230kV Swtchyd 115kV Rg Bus 12,025,048
TWAS/2010/C/001 Union Gap Add 230 - 115kV Capacity 40,779,954
TYAK/2008/C/001 Vantage Pomona Heights 230kV Line 67,483,742
TZBE/2017/C/002 Vitesse - Facebook 60 MW Load Addition 61,136,797

(e) Please refer to the table below which provides the calculated calendar year
2024 depreciation expense (year-to-date through June 2024) associated with
the assets for each project:

Project Project Description Calculated YTD
Depreciation Expense
through June 30, 2024
TIOR/2013/C/005 Troutdale Sub 230kV Swtchyd 115kV Rg Bus 126,744
TWAS/2010/C/001 Union Gap Add 230 - 115kV Capacity 451,642
TYAK/2008/C/001 Vantage Pomona Heights 230kV Line 708,177
TZBE/2017/C/002 Vitesse - Facebook 60 MW Load Addition 532,232

(f) Please refer to Attachment IPUC 198.

(g) Please refer to the Company’s response to subpart (a) above.

Recordholder: Justus Evangelista

Sponsor: Justus Evangelista

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 199

IPUC Data Request 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 for the change, and provide
evidence that the changes were approved at the appropriate level;
v. Project status reports and action items; and
vi. Contractor change orders.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 199

(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.

Response to IPUC Data Request 199

Please refer to the Company’s response to IPUC Data Request 151.

Recordholder: Matt Murray

Sponsor: Brad Richards

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 200

IPUC Data Request 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;
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
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 200

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.

Response to IPUC Data Request 200

Please refer to Confidential Attachment IPUC 200.

(a) Please refer to Confidential Attachment IPUC 200, specifically confidential
file “APR10016320 - U22 Major Inspec Overhaul CY23 CONF”.

(b) Please refer to Confidential Attachment IPUC 200, specifically confidential
file “APR10016320 - U22 Major Inspec Overhaul CY23 CONF”.

(c) Not applicable. Under a long-term contract; please refer to the discussion in
the provided appropriation request (APR), specifically confidential file
“APR10016320 - U22 Major Inspec Overhaul CY23 CONF”.

(d) Please refer to Company’s responses below:

i. This project is to perform the Unit 22 Major CT overhaul pursuant to
the Managed Long-Term Gas Turbine Parts and Service Contract
(LTP) between PacifiCorp and Siemens Energy, Inc.

In accordance with the LTP, Major Rotor-In overhaul is to be
conducted when the combustion turbine reaches 33,200 hours or 1,200
starts relative to the last combustion inspection outage which was
performed in 2018.

Combustion internal extension program parts are to be supplied and
delivered by Siemens for installation during this Rotor in Major
scheduled outage on Combustion Turbine 21 per the Managed Long
Term Gas Turbine Parts and Services Contract Change effective
September 24, 2020. This project, according to the LTP, requires
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 200

Siemens to prove the equipment that will operate another 33,200 hours
after completion of Rotor in Major Outage.

ii. The initial project budget was $17,287,805, however additional hours
were run on the turbine. Because the fees are calculated by the number
of hours run, this resulted in an increased project amount of
$18,359,458 Direct (excluding allowance for funds used during
construction (AFUDC)). Overhauls are intended to occur at specific
hours intervals based on total run hours incurred on the combustion
turbines. These hours are prepaid in the form of equivalent base hours
(EBH) fees and paid quarterly per total hours run and booked to a
prepaid account. The prepaid account is cleared and booked to capital
at every major inspection. In the case of Lake Side’s CT21 turbine, the
outage was intended to occur 33,200 hours or 1,350 starts after the
2018 Hot Gas Path (HGP). In early 2023, Siemens granted an
engineering departure allowing for additional run hours above the
contractual 33,200. The additional hours are predicted to be 5,155
hours above the 33,000. on CT21. These additional hours result in a
total increase over budget of $1,071,653.

The benefits associated with the expenditure including continued
operation are also included in the 2023 budget plan.

iii. The initial proposed schedule for the project was approximately 37
days from going offline to coming back online: October 1, 2023 to
November 7, 2023.

iv. Please refer to the table below:

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 200

(e) Please refer to the Company’s responses below:

i. See initial project scope above in item (d)i.

ii. The project is defined in one WBS (OLSP/2023/C/018) in the
budgeted amount of $17,287,805 Direct (excluding AFUDC).

iii. The project is defined in one WBS (OLSP/2023/C/018) scheduled
to take place over approximately 37 days, from October 1, 2023 to
November 7, 2023.

iv. The baseline construction project scope, budget, and/or schedule
did not deviate from the initial project plan.

v. Not applicable

vi. Siemens Energy, Inc. issued the following five change orders
(extra work orders) pursuant to the original contract:

f. Please provide the following related to completion of the project:

i. The baseline construction budget (excluding AFUDC) was
$17,287,805, with actuals (excluding AFUDC) amounting to
$18,839,227.

ii. The baseline construction schedule was estimated to last
approximately 37 days, from October 1, 2023, to November 7,
2023. The actual construction schedule was approximately 40 days
from going offline to coming back online, from October 1, 2023, to
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 200

November 11, 2023.

iii. There was a budget-to-actuals cost overage of $2,012,103 Direct
(excluding AFUDC), or 11.64 percent. This overage is due to the
additional run hours granted by Siemens in the engineering
departure, and the costs for part of the scaffolding and crane
support during the outage. The additional run hours incurred a cost
of $1,071,653, and the costs for scaffolding and crane support
account for the remainder of the overage in the amount of
$479,769.

iv. Extra work driven by discovery resulted in approximately four
days added to the schedule.

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: Matt Murray

Sponsor: Brad Richards

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 201

IPUC Data Request 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.

(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
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 201

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.

Response to IPUC Data Request 201

Please refer to the Company’s response to IPUC Data Request 152.

Recordholder: Matt Murray

Sponsor: Brad Richards

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 203

IPUC Data Request 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;
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
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 203

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.

Response to IPUC Data Request 203

The Company entered into Long-Term Service Agreements (LTSA) for the Ekola
Flats, Pryor Mountain and TB Flats wind projects and these full-service
agreements encompass both operations and maintenance (O&M) and capital
repairs and invoices are paid quarterly. The Company capitalizes the portion of
the quarterly invoice that relates to capital work performed under the agreement
during the prior quarter. “W-1799 EV 2020 WIND LTSA CY2023” is the
capitalized work performed under the LTSAs for calendar year 2023. A separate
economic analysis was not performed for capitalization of the LTSAs. There is no
construction plan for work performed under the agreements.

Please refer to Confidential Attachment IPUC 203 which provides copies of
executed LTSAs.

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: Gary Tawwater

Sponsor: Tim Hemstreet / Will Shallenberger

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 204

IPUC Data Request 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 work papers 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;
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.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 204

(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.

Response to IPUC Data Request 204

PacifiCorp maintains a Contractual Service Agreement with General Electric
International Inc. In the CSA article 2, the contractor (GE) shall provide covered
maintenance and repair of collateral damage. It further states in exhibit B what
qualifies as a covered unit and CT1 generator serial number 338X439 is
identified. The repair was conducted by GE to maintain the integrity of the CSA
and to uphold the warranty provisions of article 8.

Please refer to Confidential Attachment IPUC 204 which provides a copy of the
appropriation request (APR), project scope and schedule.

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: Gavin Mangelson

Sponsor: Brad Richards

1
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

IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS
RATES AND CHARGES IN IDAHO
AND APPROVAL OF PROPOSED
ELECTRIC SERVICE SCHEDULES
AND REGULATIONS

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CASE NO. PAC-E-24-04

ATTORNEY’S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES

I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a
senior 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 the Company’s response IPUC Set 10 contain Company proprietary information that could
be used to its commercial disadvantage.
2
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in 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 29th day of August, 2024.

Respectfully submitted,

By__________________________
Joe Dallas
Senior Attorney
Rocky Mountain Power