20240829PAC to Staff 130-138_140-141_145.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 8 (130-154)
Please find enclosed Rocky Mountain Power’s Responses to IPUC 8th Set Data Requests IPUC
130-138, 140-141 and 145 and Attachments. The remaining response will be provided under
separate cover. Provided via BOX are the Confidential Attachments. 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)
Ronald L. Williams/PIIC [e-mail]
RECEIVED
Thursday, August 29, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
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 130

IPUC Data Request 130

Please provide the following information for the “Gateway South Segment F –
Aeolus to Mona 500 kV” project referenced by Company witness Vail at 22.
Please include any available workpapers with formulae 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) 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.

(b) 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.

(c) Please provide the following for the Baseline Construction Project Plan:

i. Baseline project scope;
ii. Baseline project budget broken down by Work-Breakdown
Structure (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.

(d) Please provide the following related to completion of the project:

i. Baseline construction budget-to-actual comparison by Work
Breakdown Structure 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
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 130

provide evidence that the amount was approved at the appropriate
level; and
iv. Please explain any slips in schedule from the baseline construction
schedule.

(e) Please explain the large discrepancy of the project cost in McCoy’s workpaper
8.5.3 of $2,069,785,300 and the total project cost in Company response to
Production Request No. 15 of $35,075,630.

Response to IPUC Data Request 130

Please refer to Confidential Attachment IPUC 130-1 and Attachment IPUC 130-2.
Also, some additional documentation is considered highly confidential and
commercially sensitive. The Company requests special handling. Please contact
Mark Alder at [phone] to make arrangements for review.

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

i. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

ii. Construction contractors are selected based on the following
considerations:

1. For the Gateway South project the Company conducted a
controlled competitive bid event including both a technical and
commercial evaluation:

a. The technical evaluation evaluated the bidder’s experience,
execution plan to constructing the project and confirmed
their schedule meets the overall project timeline and
milestones. The technical questions are included in the
technical evaluation reports included in response to a.iii
below.

b. The commercial evaluation assessed the bidders' proposed
costs and cost normalization of any risks, exceptions, or
clarifications the Company sees, or bidder identifies not
included in the bid process. The normalized costs were
added to the bidder's proposed costs. All technically
qualified bidders were then invited to participate in a
‘reverse auction’ event whereby bidders were able to
propose ‘best and final pricing’ at the conclusion of the
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 130

auction event the lowest bid contractor was awarded the
work.

iii. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

iv. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review..

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

i. Please refer to Confidential Attachment IPUC 130-1.

ii. Please refer to Confidential Attachment IPUC 130-1.

iii. Please refer Attachment IPUC 130-2.

iv. Please refer to Confidential Attachment IPUC 130-1.

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

i. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

ii. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

iii. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

iv. The baseline project scope and budget have varied since the initial
project plan was approved in 2022. The budget increased by
approximately $225 million as approved in APR 94013502. There were
several key drivers for the adjustment in costs; (1)The decision to add
one additional spare transformer to the Aeolus substation for improved
substation restoration times in the event of a transformer failure (2)
delayed access to the transmission line right-of-way in several areas
including Utah Department of Natural Resources property, Ute Tribe
extended permitting times and additional Bureau of Land Management
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 130

requests for stream crossing mitigations. (3) Unexpected denied
biological species variances and unexpected sensitive plant discoveries.
(4) Structure foundation changes to address access constraints
determined as unbuildable per the permit constraints. (5) Supply chain
cost increases due to post pandemic and Ukraine war impacts (6) The
elimination of China based suppliers to mitigate security and child labor
concerns.

v. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

vi. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

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

i. Please refer to Confidential Attachment IPUC 130-1.

ii. Please refer to Attachment IPUC 130-2.

iii. Refer to the response provided above in c.iv the primary reasons for the
budget changes and variances.

iv. For the transmission line, schedule variance explanations are provided in
the attachments included in the response to d.ii above. For the substations,
there were several key drivers in the schedule changes. (1) The Aeolus and
Clover substations experienced late delivery of the transformers due to
manufacturing delays which necessitated a change in the schedule. (2) The
Little Snake substation experienced a significant cultural find which
severely delayed the construction sequence. At several sites, supply chain
issues have delayed various pieces of equipment and material which has
impacted the original sequence. The Company and its contractor have
deployed several mitigations, engineering workarounds and schedule
resequencing processes such that the overall schedule will see the project
energized by the end of November 2024, and ahead of required dates for
additional wind farm generation connections.

(e) IPUC Data Request 15 requested the dollar amount for each project closed to
plant in service in excess of $5 million from 2022 through the present date in
2024. The timing of the request included amounts from 2022 through May
2024, including $27.6 million in costs for 2023. The amount in McCoy’s work
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 130

paper 8.5.3 represents the forecasted 2024 dollars expected to be in service by
the end of 2024.

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: Brandon Smith / Lori Rolow

Sponsor: Todd Jensen / Rick Vail

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 131

IPUC Data Request 131

For each of the seven Gateway South Supporting Projects described in Company
witness Vail’s testimony on page 35, please answer the following:

(a) 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.

(b) Please provide the following related to completion of the project:

i. Evidence that the Initial Project Plan and budget were approved at
the appropriate level;
ii. Initial and Actual project scope;
iii. Baseline construction budget-to-actual comparison by WBS and by
year;
iv. Baseline construction schedule-to-actual comparison by WBS;
v. 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
vi. Please explain any slips in schedule from the baseline construction
schedule.

Response to IPUC Data Request 131

(a)
i. Currently, the only request for proposal (RFP) issued is for the Riverton
substation project, which was issued by way of the Line Service
Agreement (LSA) contract process. Remedial action scheme (RAS) work
will largely be performed by in-house resources.
ii. Construction contractor was selected based on the following process:
a. Using pre-qualified contractors with standing LSA contracts, bid
packages were issued to all contractors on the list. As all contractors
are pre-approved and qualified with agreed contract terms and
conditions there is no technical evaluation process, the selection
process is based upon their ability to meet the schedule at lowest cost.
This contract method is commonly used by PacifiCorp for most
capital substation, distribution, and smaller scale transmission
projects.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 131

iii. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

iv. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

(b)
i. Please refer to Confidential Attachment IPUC 131-1, specifically file
“APR94013510 GWS Supporting Projects approved 04-04-2023”.The
approver field on this appropriation request shows the final approver as
Stefan Bird who was President of Pacific Power at the time of this approval
and whose signing authority was up to $50 million
ii. Please refer to Confidential Attachment IPUC 131-1, specifically file,
“GWSSupportingProjectIAD_APR94013510” . This document
accompanied the full funding construction appropriation request for
approval and the scope of work to be completed is outlined in the executive
summary section.
iii. Please refer to Confidential Attachment IPUC 131-1, specifically file,
“Baseline construction budget to actuals_GWS Supp CONF” that shows
the baseline costs associated to the APR 94013510 versus actuals.
iv. Please refer to Attachment OPUC 131-2, file “PAC - Riverton Preliminary
Baseline Schedule”.
v. N/A
vi. The construction activities have only recently commenced, as such the
schedule is on track with no significant deviations to the baseline 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: Brandon Smith / Lori Rolow

Sponsor: Todd Jensen / Rick Vail
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 132

IPUC Data Request 132

Please provide the following information for the “Gateway West Segment D.1”
project referenced by Company witness Vail at 22. Please include any available
workpapers with formulae 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 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.

(b) 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.

(c) Please provide the following related to completion of the project:

i. Evidence that the initial project plan and budget were approved at
the appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by
year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
v. Please explain any slips in schedule from the baseline construction
schedule.

Response to IPUC Data Request 132

(a) Alternatives for the Gateway West Segment D.1 project was addressed in the
direct testimony of Richard A. Vail on page 26.
(b)
i. Please refer to Confidential Attachment IPUC 132-1, files “(i) RFP Bid
Pkg_GWW.D1 Substation CONF” and “b.i.1 GWW D.1 Tline RFP.VF”.

ii. Construction contractors are selected based on the following considerations:
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 132

1. For the Gateway West D.1 transmission line project, the Company
conducted a controlled competitive bid event including both a technical
and commercial evaluation:
a. The technical evaluation evaluated the bidder’s experience,
execution plan to constructing the project, and confirmed their
schedule meets the overall project timeline and milestones. The
technical questions are included in the Technical Evaluation
reports included in response to a.iii below.
b. The commercial evaluation assessed the bidders' proposed costs
and cost normalization of any risks, exceptions, or clarifications
the Company sees, or bidder identifies not included in the bid
process. The normalized costs were added to the bidder's proposed
costs. All technically qualified bidders were then invited to
participate in a ‘reverse auction’ event whereby bidders were able
to propose ‘best and final pricing’ at the conclusion of the auction
event the lowest bid contractor was awarded the work.
2. The Gateway West D.1 substation construction contractor was selected
based on the following process:
a. Using pre-qualified contractors with standing Line Service
Agreement contracts, a bid package was issued to all contractors
on the list. As all contractors are pre-approved and qualified with
agreed contract terms and conditions there is no technical
evaluation process, the selection process is based upon ability to
meet the schedule and lowest cost. This contract method is
commonly used by PacifiCorp for most capital substation,
distribution and smaller scale transmission projects.

iii. The requested information is considered highly confidential and commercially
sensitive. The Company requests special handing. Please contact Mark Alder at
[phone] to make arrangements to review..

iv. The requested information is considered highly confidential and commercially
sensitive. The Company requests special handing. Please contact Mark Alder at
[phone] to make arrangements to review..

(c)
i. Please refer to Confidential Attachment IPUC 132-1, file “SDOA Thon
APR94012715_signed” which indicates approval by Scott Thon PacifiCorp,
Chairman and Chief Executive Officer in 2022, of appropriation request
94012715. See also “APR 94012715 Seg D1 full funding approved 053122”.
Mr. Thon has unlimited approval for projects over $50 million
ii. Please refer to Confidential Attachment IPUC 132-1.
iii. Please refer to Attachment IPUC 132-2, file “c.v.1 GWW D1 TLine BL APP”
for the transmission line baseline schedule. Refer to file “c.v.3 GWW D1
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 132

Schedule DD July 2024” for the current schedule against baseline
performance.
iv. The Company and contractor have worked to develop a revised sequence
which achieves the project's overall completion dates. Please refer to
Confidential Attachment IPUC 132-1, files “APR94013503 Seg D1 approved
040523” and its associated investment appraisal document
“SegD1IAD_APR94014580”. Also see file “APR 94014580 Seg D1
approved 051624” and its associated investment appraisal document
“SegD1IAD_APR94014580”. with variance explanations
v. The project has been re-sequenced since the original baseline due to a variety
of factors including unexpected environmental constraints, access constraints,
climatic conditions, supply chain delays and resultant productivity challenges.
However, the projects are on track for completion in 2024.

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: Brandon Smith / Lori Rolow

Sponsor: Todd Jensen / Rick Vail

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 133

IPUC Data Request 133

Please provide the following information for the “EV 2024 Generation
Interconnection Network Upgrade” project referenced in Company witness Vail’s
Testimony at 30. Please include any available workpapers with formulae 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) 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;
iv. A copy of the winning bid.

(d) Please provide the following related to completion of the project:

i. Evidence that the Initial Project Plan and budget were approved at
the appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by
year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
v. Please explain any slips in schedule from the baseline construction
schedule.

Response to IPUC Data Request 133

(a) As indicated in testimony provided by Richard A Vail (pg. 29 -33), the EV 2024
Generation Interconnection Network Upgrade project is actually five generation
interconnection projects that were selected from a request for proposal to
interconnect 1,640 megawatts (MW) of new wind generation to the Company’s
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 133

transmission system in eastern Wyoming that are relevant to the test period in this
rate case. The request for proposal process and the resulting resources that were
selected are described in the testimony of Company witness Rick T. Link. A
separate generation interconnection agreement was negotiated and signed for all
five projects, and each will require generation interconnection network upgrades to
interconnect and integrate with PacifiCorp’s system. These projects include:
 Q0409 Boswell Springs Wind
 Q0713 Cedar Springs IV Wind
 Q0785 Anticline Wind
 Q0835 Rock Creek Wind 1
 Q0836 Rock Creek Wind 2

(b) Please refer to the Company’s responses to (a) above.
(c) i. The requested information is considered highly confidential and commercially
sensitive. The Company requests special handing. Please contact Mark Alder at
[phone] to make arrangements to review.
ii. Construction contractors are selected based on the following considerations:
1. The Company has two approaches to selecting the bidders list for projects,
both of which ensure and/or determine if they have the qualifications,
experience, and authorizations to perform the work.
a. Pre-qualified contractors with standing Line Service Agreement
contracts are selected for most capital substation, distribution, and
smaller scale transmission projects.
b. For major transmission projects, the bidder list is selected based on
the Company’s historical experience with the contractor and global
experience in the transmission industry, as well as those with
proven experience with the scope of work being bid.
2. Company conducts a controlled competitive bid event including both a
technical and commercial evaluation:
a. The technical evaluation will evaluate the bidder’s experience,
execution plan to constructing the project, and confirm their
schedule meets the overall project timeline and milestones.
b. The commercial evaluation will assess bidders' proposed costs and
cost normalization of any risks, exceptions, or clarifications the
Company sees, or bidder identifies not included in the bid process.
The normalized costs are added to the bidder's proposed costs. If a
bidder is considered technically qualified, the lowest bid contractor
is awarded the work.
3. The company also assesses the bidder's safety records confirming the
contractors are performing their work in accordance with the Company’s
safety standards.
iii. The requested information is considered highly confidential and commercially
sensitive. The Company requests special handing. Please contact Mark Alder at
[phone] to make arrangements to review.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 133

iv. The requested information is considered highly confidential and commercially
sensitive. The Company requests special handing. Please contact Mark Alder at
[phone] to make arrangements to review.

(d)
i. Please refer to Confidential Attachment IPUC 133-1, for the following
documents:
 Q0409 Boswell Springs Wind: “APR 24020561 Q0409 Boswell
Springs Wind_APRVD 051922”
 Q0713 Cedar Springs IV Wind: “APR 24019721 Q0713 Cedar
Springs IV Wind_Approved 111721”
 Q0785 Anticline Wind: “APR 24021196 Q0785 Anticline Wind
approved 091622”
 Q0835 Rock Creek Wind 1: “APR 24019460 Q0835 Rock Creek
Wind_Approved 111521”
 Q0836 Rock Creek Wind 2: “APR 24020492 Q0836 Rock Creek
Wind_APRVD 050622”

The approver field on each of the appropriation requests, except for Q0835
Rock Creek Wind 1, lists the final approver as Richard Vail, the Vice
President of Transmission, whose signing authority at the time of the
project approvals was up to $15 million. For Rock Creek Wind 1, the final
approver was Stefan Bird, who at the time of the project approval was the
President of Pacific Power and had a signing authority of up to $50
million.

ii. Please refer to Confidential Attachment IPUC 133-1, for the following
documents: “Baseline construction budget to actuals_ Q0409 Boswell
Springs Wind”, “Baseline construction budget to actuals_Q0713 Cedar
Springs IV Wind”, “Baseline construction budget to actuals_Q0785
Anticline Wind”, “Baseline construction budget to actuals_Q0835 Rock
Creek Wind 1” and “Baseline construction budget to actuals_Q0836 Rock
Creek Wind 2” which shows the baseline costs associated to the APRs in
question d (i) versus actuals for each project.
iii. Please refer to Confidential Attachment IPUC 133-1.
iv. According to PacifiCorp's corporate governance, approval is required
through the project change notice process if the total project cost variance is
greater than $250,000 or 10 percent, whichever is higher. However, a
project change notice will also be required (regardless of the 10 percent
general rule above) if the proposed increase over the forecasted project costs
of the currently authorized AFE exceeds: 1) $5 million for projects with an
authorized cost under $250 million, 2) $10 million for projects with an
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 133

authorized cost between $250 million and $500 million, and 3) $12 million
for projects with an authorized cost greater than $500 million. The project
change history for each project is provided in Confidential Attachment
IPUC 133-1 as follows:
• Q0409 Boswell Springs Wind: No project change notices have been
approved for this project during construction.
• Q0713 Cedar Springs IV Wind: One project change notice has
been approved while under construction. See file “APR 94013557
Q0713 Cedar Springs_APPRVD 5-21-24” and its associated
investment appraisal document “PCN 94013557 Q0713 Cedar
Springs IAD”, with variance explanations, in “Attach 133Q0713
Cedar Springs IV Wind”.
• Q0785 Anticline Wind: No project change notices have been
approved for this project during construction.
• Q0835 Rock Creek Wind 1: One project change notice has been
approved while under construction. See file “APR 94014071 Q0835
Rock Creek Wind 1_APPRVD 3-12-24” and its associated
investment appraisal document “APR 94014071 for Q0835 IAD”,
with variance explanations
• Q0836 Rock Creek Wind 2: No project change notices have been
approved on this project during construction
v. Cedar Springs IV: Negotiations with the property owner for property
purchase have been lengthy and difficult. Currently, negotiations are causing
the schedule for the project to slip two to four weeks.
Q0835 Rock Creek Wind I: The schedule slips are due to lead time of
materials for the project. However, the project is on track for completion in
2024.
Q0836 Rock Creek Wind 2: No schedule slips.
Q0785 Anticline Wind: No schedule slips.
Q0409 Boswell Springs Wind: No schedule slips.

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: Brandon Smith / Lori Rolow

Sponsor: Todd Jensen / Rick Vail

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 134

IPUC Data Request 134

Please provide the following information for the “Anticline 345 kV Phase Shifter”
project referenced in Company witness Vail’s Testimony at 34. Please include
any available workpapers with formulae 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) 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.

(b) Please provide the following related to completion of the project:

i. Evidence that the Initial Project Plan and budget were approved at
the appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by
year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
v. Please explain any slips in schedule from the baseline construction
schedule.

Response to IPUC Data Request 134

(a)
i. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please contact
Mark Alder at [phone] to make arrangements to review.
ii. Construction contractors are selected based on the following considerations:
1.For the Anticline Phaseshifter project the Company conducted a controlled
competitive bid event including both a technical and commercial
evaluation:
a. The technical evaluation evaluated the bidder’s experience,
execution plan to constructing the project, and confirm their
schedule meets the overall project timeline and milestones. The
technical questions are included in the Technical Evaluation
reports included in response to a.iii below.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 134

b. The commercial evaluation assessed the bidders' proposed costs
and cost normalization of any risks, exceptions, or clarifications
the Company sees, or bidder identifies not included in the bid
process. The normalized costs were added to the bidder's proposed
costs. All technically qualified bidders were then invited to
participate in a ‘reverse auction’ event whereby bidders were able
to propose ‘best and final pricing’ at the conclusion of the auction
event the lowest bid contractor was awarded the work.

iii. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

(b)
i. Please refer to Confidential Attachment IPUC 134-1, file
“Anticline345kVPhaseShifterFehrmanSDOA_signed” indicates approval by
William J. Fehrman, PacifiCorp Chairman and Chief Executive Officer in
2020, of appropriation request 24017395. Also, see file “APR 24017395
Anticline Phase Shifter approved 091820”. At the time of approval, Mr.
Fehrman had unlimited approval for projects over $50 million
ii. Please refer to Confidential Attachment IPUC 134-1.
iii. Please refer to Attachment IPUC 134-2, file “Anticline Baseline Schedule” for
the baseline schedule and file “Anticline Schedule Schedule_July” identifying
current schedule against the baseline schedule.
iv. This project has had one project change notice approved while under
construction. Please refer to Confidential Attachment IPU C 134-1, file “APR
94013431 Antilcline Phase Shifter approved 04-05-2023” and its associated
investment appraisal document “APR 94013431 Anticline Phase Shifter
IAD”, with variance explanations.
v. The project sequence responded to several challenges driven by supply chain
issues, which led to actual-versus-baseline schedule differences. However,
with resequencing and collaborative efforts by the Company and the
contractor, the project will be energized on schedule and the original contract
final completion date will be attained.

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: Brandon Smith / Lori Rolow

Sponsor: Todd Jensen / Rick Vail
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 135

IPUC Data Request 135

Please provide the following information for “Oquirrh Terminal 345 kV” project
referenced in Company witness Vail’s Testimony at 39. Please include any
available workpapers with formulae 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) 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.

(b) Please provide the following related to completion of the project:

i. Evidence that the Initial Project Plan and budget were approved at
the appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by
year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
v. Please explain any slips in schedule from the baseline construction
schedule.

Response to IPUC Data Request 135

(a) i. The requested information is considered highly confidential and commercially
sensitive. The Company requests special handing. Please contact Mark Alder at
[phone] to make arrangements to review..
ii. Construction contractors are selected based on the following considerations:
1. The Company has two approaches to selecting the bidders list for projects,
both of which ensure and/or determine if they have the qualifications,
experience, and authorizations to perform the work.
a. Pre-qualified contractors with standing Line Service Agreement
contracts are selected for most capital substation, distribution, and
smaller scale transmission projects.
b. For major transmission projects, the bidder list is selected based on
the Company’s historical experience with the contractor and global
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 135

experience in the transmission industry, as well as those with
proven experience with the scope of work being bid.
2. Company conducts a controlled competitive bid event including both a
technical and commercial evaluation:
a. The technical evaluation will evaluate the bidder’s experience,
execution plan to constructing the project, and confirm their
schedule meets the overall project timeline and milestones.
b. The commercial evaluation will assess bidders' proposed costs and
cost normalization of any risks, exceptions, or clarifications the
Company sees, or bidder identifies not included in the bid process.
The normalized costs are added to the bidder's proposed costs. If a
bidder is considered technically qualified, the lowest bid contractor
is awarded the work.
3. The company also assesses the bidder's safety records confirming the
contractors are performing their work in accordance with the Company’s
safety standards.
iii. The requested information is considered highly confidential and commercially
sensitive. The Company requests special handing. Please contact Mark Alder at
[phone] to make arrangements to review.
iv The requested information is considered highly confidential and commercially
sensitive. The Company requests special handing. Please contact Mark Alder at
[phone] to make arrangements to review.

(b)
i. Please refer to Confidential Attachment IPUC 135 -1, specifically files “APR
34013498 O-T SDOA_Thon signed” which indicates approval by Scott Thon,
PacifiCorp Chairman and Chief Executive Officer in 2023, of appropriation request
94013498 and “APR 94013498 Oquirrh-Terminal Dbl Ckt 345kV_APRVD 053123”.
Mr. Thon has unlimited approval for projects over $50 million.
ii. Please refer to Confidential Attachment IPUC 135-2, file “Baseline construction
budget to actuals_O&T”.
iii. Please refer to Confidential Attachment IPUC 135-2, files “O-T MET -2009-C-001
Schedule 041524” and “O-T MET-2009-C-001 Schedule 080324” for the
project schedule at the start of construction versus the most recent activity.
iv. According to PacifiCorp's corporate governance, approval is required through
the project change notice process if the total project cost variance exceeds
$250,000 or 10 percent, whichever is greater. However, a project change
notice will also be required (regardless of the 10 percent general rule) if the
proposed increase over the forecasted project costs of the currently authorized
AFE exceeds: (1) $5 million for projects with an authorized cost under $250
million, (2) $10 million for projects with an authorized cost between $250
million and $500 million, and (3) $12 million for projects with an authorized
cost greater than $500 million. No project change notices have been required
for the Oquirrh-Terminal during construction.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 135

v. A substantial completion date delay from October 15, 2024, to November 8,
2024, has occurred due to up front environmental survey and permitting
delays.

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: Spencer Fowler / Lori Rolow

Sponsor: Todd Jensen / Richard Vail
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 136

IPUC Data Request 136

Please provide the following information for the “EV 2024 Generation
Interconnection Network Upgrade” project referenced in Company witness Vail’s
Testimony at 30. Please include any available workpapers with formulae 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) 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 following related to completion of the project:

i. Evidence that the Initial Project Plan and budget were approved at
the appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by
year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
v. Please explain any slips in schedule from the baseline construction
schedule.

Response to IPUC Data Request 136

Please refer to the Company’s response to IPUC Data Request 133.

Recordholder: Brandon Smith / Lori Rolow

Sponsor: Rick Vail / Todd Jensen
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 137

IPUC Data Request 137

Please provide the following information for the “Path C Transmission
Improvement” project referenced in Company witness Vail’s Testimony at 43.
Please include any available workpapers with formulae 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) 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.

(b) Please provide the following related to completion of the project:

i. Evidence that the Initial Project Plan and budget were approved at
the appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by
year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
v. Please explain any slips in schedule from the baseline construction
schedule.

(c) Please explain the large discrepancy of the project cost of $31,335,658 from
McCoy Workpaper 8.5.3 and project cost of $9,952,336 in Company’s
response to Production Request No. 15.

Response to IPUC Data Request 137

(a)
i. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.
ii. Construction contractors are selected based on the following
considerations:
1) The Company has two approaches to selecting the bidders list for
projects, both of which ensure and/or determine if they have the
qualifications, experience, and authorizations to perform the work.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 137

i. Pre-qualified contractors with standing line service agreement
contracts are selected for most capital substation, distribution,
and smaller scale transmission projects.
ii. For major transmission projects, the bidder list is selected based
on the Company’s historical experience with the contractor and
global experience in the transmission industry, as well as those
with proven experience with the scope of work being bid.
2) The Company conducts a controlled competitive bid event including
both a technical and commercial evaluation:
i. The technical evaluation will evaluate the bidder’s experience,
execution plan to constructing the project, and confirm their
schedule meets the overall project timeline and milestones.
ii. The commercial evaluation will assess bidders' proposed costs
and cost normalization of any risks, exceptions, or clarifications
the Company sees, or bidder identifies not included in the bid
process. The normalized costs are added to the bidder's proposed
costs. If a bidder is considered technically qualified, the lowest
bid contractor is awarded the work.
3) The Company also assesses the bidder's safety records confirming the
contractors are performing their work in accordance with the
Company’s safety standards.

iii. Please refer to Attachment IPUC 137-2, files “Path C Milestone Schedule
20220928” and “Path C Milestone Schedule 20240808.pdf” for the baseline
schedule and final schedule compared to the baseline
iv. Please refer to Confidential Attachment IPUC 137-1 for the cost sheet,
APR, and other supporting documentation.

(b)
i. Please refer to Confidential Attachment IPUC 137.1, file “(i) APR
94011609 Path C full funding approved 04-22-21”. This appropriation
request shows that Stefan Bird, President and CEO of Pacific Power at the
time, was the final approver of project funds. Mr. Bird’s approval
authority per PacifiCorp governance was gross project costs up to $50
million
ii. Please refer to Confidential Attachment IPUC 137.1, file “Baseline
construction budget to actuals_Path C”
iii. Please refer to Attachment IPUC 137.2, file “Path C Schedule 20220928”
for the schedule prior, and “Path C Milestone Schedule 20240808” for the
current schedule.
iv. According to PacifiCorp corporate governance, approval is required
through the project change notice process if total project costs variance is
greater of $250,000 or 10 percent. However, that a project change notice
will be required (notwithstanding the 10 percent general rule above) if the
proposed increase over forecasted project costs of the currently authorized
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 137

AFE exceeds (1) $5 million for projects with an authorized project cost
under $250 million, (2) $10 million for projects with an authorized project
cost between $250 million and $500 million, and (3) $12 million for
projects with an authorized project cost greater than $500 million. During
construction this project has had three project change notices approved.
Please refer to Confidential Attachment IPUC 137-1, files “APR
94012794 Path C Improvements approved 090222”, “PR 94013124 Path C
approved 051123” and “APR 94014430 Path C_Apprvd 040924”, and
their respective investment appraisal documents, “APR 94012794 Path C
IAD”, “APR 94013124 Path C IAD” and “APR 94014430 Path C IAD”
for variance explanations
v. See the above referenced and attached APR files and investment appraisal
documents for explanations regarding schedule slips.

(c) Production Request No. 15 asked for the dollar amount of each project closed
to plant in-service in excess of $5 million from 2022 through 2024 to-date.
The timing of the request included amounts from 2022 through May 2024.
The amount in McCoy’s workpaper 8.5.3 is the forecast 2024 dollars to be in-
service by the end of 2024.

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: Lori Rolow / Suzan Baker

Sponsor: Rick Vail / Todd Jensen

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 138

IPUC Data Request 138

Please provide the following information for the Midpoint 500 kV Series
Capacitor Bank Replacement project referenced in the Company’s response to
Production Request No. 15. Please include any available workpapers with
formulae 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) 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 following related to completion of the project:

i. Evidence that the Initial Project Plan and budget were approved at
the appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by
year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
v. Please explain any slips in schedule from the baseline construction
schedule.

Response to IPUC Data Request 138

(a) PacifiCorp holds a 36.3 percent ownership interest in the series capacitor bank at
the Midpoint 500 kilovolt (kV) substation, as outlined in the Joint Ownership and
Operating Agreement between Idaho Power Company and PacifiCorp, first
executed in 2014 and subsequently amended in 2015, 2016, 2019, and 2023.
Idaho Power Company provided information regarding the series capacitor bank
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 138

at the Midpoint substation and requested PacifiCorp’s participation in the project
per the Joint Ownership and Operating Agreement in a letter dated April 12,
2021. PacifiCorp acknowledged their participation via email in May 2021.

(b) There are no viable alternatives for this project as it is requested by Idaho Power
Company under the Joint Ownership and Operating Agreement Article 5.2(d).

(c) Idaho Power Company is the majority share owner (63.7 percent) of the Midpoint
500 kV substation and subsequently manages the replacement of the series
capacitor providing monthly forecasts for PacifiCorp’s 36.3 percent ownership.
All RFP or RFQ information reside s with Idaho Power Company.

(d)
i. The appropriation request for full funding please refer to Confidential
Attachment IPUC 138, file “APR 24019373 Midpoint 500kV Series Cap
Bank 09-10-2021 CONF”. The approver field on this appropriation request
shows the final approver as Rick Vail, vice president of transmission, whose
approval authority was up to $15 million at that time
ii. See the attached Baseline construction budget-to-actual_Midpoint Series Cap
CONF.xlsx file for comparison by WBS and by year.
iii. According to Idaho Power Company, the original estimated in-service date
was October 2023 with final in-service date of January 2024.
iv. According to PacifiCorp's corporate governance, approval is required through
the project change notice process if the total project cost variance exceeds
$250,000 or 10 percent, whichever is greater. However, a project change
notice will also be required (regardless of the 10 percent general rule) if the
proposed increase over the forecasted project costs of the currently authorized
AFE exceeds: (1) $5 million for projects with an authorized cost under $250
million, (2) $10 million for projects with an authorized cost between $250
million and $500 million, and (3) $12 million for projects with an authorized
cost greater than $500 million. In August 2022, Idaho Power Company
provided information regarding the project cost increase whereby the lowest
bid for replacing the capacitor bank came in at $11.67 million. Please refer to
Confidential Attachment IPUC 138, file “APR 94012874 Midpoint 500kV
Series Cap Bank 09-06-2022 CONF” and its related investment appraisal
document “APR 94012874 Midpoint Series Cap Bank IAD CONF ”.
v. According to the Idaho Power Company, during the bid event for the
capacitor bank installation, the vendors would not bid on the project with an
October 2023 in-service date. Idaho Power Company agreed to give more
time for the manufacture and installation which shifted the in-service date to
January 2024. Further detailed construction schedule information resides with
Idaho Power.
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 138

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: Arianne Poindexter / Lori Rolow

Sponsor: Richard Vail
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 140

IPUC Data Request 140

Please provide the following information for the “Q754 Steel Solar” project
referenced in the Company’s response to Production Request No. 15. Please
include any available workpapers with formulae 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) 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 following related to completion of the project:

i. Evidence that the Initial Project Plan and budget were approved at
the appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by
year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
v. Please explain any slips in schedule from the baseline construction
schedule.

Response to IPUC Data Request 140

(a) Please refer to Confidential Attachment IPUC 140-1 which provides a copy of
the investment appraisal document (IAD) routed with the construction
appropriation request, “IPUC Data Request 140 (a&b) – IAD CONF”.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 140

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

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

i. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review
ii. Construction contractors are selected based on the following
considerations:
1. The Company has two approaches to selecting the bidders list for
projects, both of which ensure and/or determine if they have the
qualifications, experience, and authorizations to perform the work.
a. Pre-qualified contractors with standing line service
agreement contracts are selected for most capital
substation, distribution, and smaller scale transmission
projects.
b. For major transmission projects, the bidder list is selected
based on the Company’s historical experience with the
contractor and global experience in the transmission
industry, as well as those with proven experience with the
scope of work being bid.
2. Company conducts a controlled competitive bid event including
both a technical and commercial evaluation:
a. The technical evaluation will evaluate the bidder’s
experience, execution plan to constructing the project, and
confirm their schedule meets the overall project timeline
and milestones.
b. The commercial evaluation will assess bidders' proposed
costs and cost normalization of any risks, exceptions, or
clarifications the Company sees, or bidder identifies not
included in the bid process. The normalized costs are added
to the bidder's proposed costs. If a bidder is considered
technically qualified, the lowest bid contractor is awarded
the work.
3. The company also assesses the bidder's safety records confirming
the contractors are performing their work in accordance with the
Company’s safety standards.

iii. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.
iv. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 140

(d) Please refer to the Company’s responses to subparts below:
i. The appropriation request for full funding to construct the project is
provided in Confidential Attachment IPUC 140-1, specifically file,
“IPUC Data Request 140 (d) i – APR 94012267”.. The approver field on
this appropriation request shows the final approver as Richard Vail, Vice
President of Transmission, whose approval authority at the time of this
APR was up to $15 million.
ii. Please refer to Confidential Attachment IPUC 140-1 specifically file,
“Baseline construction budget to actual_Q754 Steel Solar”.
iii. Please refer to Attachment IPUC 140 for the following files::
• IPUC Data Request 140 (d) iii – Baseline Schedule
• IPUC Data Request 140 (d) iii – Actual Schedule
iv. Project actual costs are less than authorized funds.
v. The contract back-feed date was delayed from September 2022 to
February 2023, due to material delays associated with COVID-19 and the
adjusted utility schedule to align with the customer schedule. Commercial
operations were delayed until May 2024, due to customers solar panel
delays in United States Customs and Border Protection processes.

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: Jeff Howcroft / Lori Rolow

Sponsor: Todd Jensen / Rick Vail

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 141

IPUC Data Request 141

Please provide the following information for the “Walla Walla 69 kV Loop
Reconfig Reconduct” project referenced in the Company’s response to Production
Request No. 15. Please include any available workpapers with formulae 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) 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 following related to completion of the project:

i. Evidence that the Initial Project Plan and budget were approved at
the appropriate level;
ii. Baseline construction budget-to-actual comparison by WBS and by
year;
iii. Baseline construction schedule-to-actual comparison by WBS;
iv. 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
v. Please explain any slips in schedule from the baseline construction
schedule.

(e) Please explain the large discrepancy of the project cost of $13,734,687 from
McCoy Workpaper 8.5.3 and project cost of $15,022,999 in Company’s
response to Production Request No. 15.

Response to IPUC Data Request 141

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 141

(a) Please refer to Confidential Attachment IPUC 14-1 which provides copy of the
investment appraisal , APR 24018089 WallaWallaIAD that was routed with the first
appropriation request for this project.

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

(c) Please refer to Company’s responses below for the subparts:

i. Bids were solicited and reviewed based on pre-qualified LSA firms, with
Michels Pacific Energy being selected as the low bidder and least-cost
option.
ii. Construction contractors are selected based on the following
considerations:

The Company has two approaches to selecting the bidders list for projects, both of
which ensure and/or determine if they have the qualifications, experience, and
authorizations to perform the work.
1. Pre-qualified contractors with standing Line Service Agreement contracts
are selected for most capital substation, distribution, and smaller scale
transmission projects.
a. For major transmission projects, the bidder list is selected based on the
Company’s historical experience with the contractor and global
experience in the transmission industry, as well as those with proven
experience with the scope of work being bid.
The Company conducts a controlled competitive bid event including both a
technical and commercial evaluation:
2. The technical evaluation will evaluate the bidder’s experience, execution
plan to constructing the project, and confirm their schedule meets the overall
project timeline and milestones.
a. The commercial evaluation will assess bidders' proposed costs and
cost normalization of any risks, exceptions, or clarifications the
Company sees, or bidder identifies not included in the bid process. The
normalized costs are added to the bidder's proposed costs. If a bidder is
considered technically qualified, the lowest bid contractor is awarded
the work.
The company also assesses the bidder's safety records confirming the contractors
are performing their work in accordance with the Company’s safety standards.

iii. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review
iv. The requested information is considered highly confidential and
commercially sensitive. The Company requests special handing. Please
contact Mark Alder at [phone] to make arrangements to review.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 141

(d) The appropriation request for full funding to construct the project is provided
in Confidential Attachment IPUC 141-1 specifically file,,file “APR 24018089
Walla Walla Loop_APRVD 011921 CONF”. The approver field on this
appropriation request shows the final approver as Richard Vail, the Vice
President of Transmission, and at the time of this approval his signing
authority was up to $15 million.
i. Please refer to Confidential Attachment IPUC 141-1, specifically file,
“Baseline construction budget to actual_Walla Walla Loop CONF”.xlsx.
ii. Please refer to the Company’s response to subpart i above..
iii. Please refer Attachment IPUC 141-2 specifically file, “Walla Walla 69kV
Schedule Compare”..
iv. According to PacifiCorp's corporate governance, approval is required
through the project change notice process if the total project cost variance
exceeds $250,000 or 10 percent, whichever is greater. Additionally, a
project change notice will be required (regardless of the 10 percent general
rule) if the proposed increase over the forecasted project costs of the
currently authorized AFE exceeds: (1) $5 million for projects with an
authorized cost under $250 million, (2) $10 million for projects with an
authorized cost between $250 million and $500 million, and (3) $12
million for projects with an authorized cost greater than $500 million. The
project has had one project change notice approved while under
construction which is provided in Confidential Attachment IPUC 141-1,
specifically file “APR 94012806 Walla Walla Loop_APRVD 051623
CONF” and its associated investment appraisal document “APR 94012806
Walla Walla Loop IAD CONF” with variance explanations.
v. The Walla Walla Tap and Central-Mill Creek section of project were de-
scoped for budgetary reasons. These sections will be added back into the
project for 2025 construction.
(e) Production Request No. 15 asked for the dollar amount of each project closed to
plant in service in excess of $5 million from 2022 through 2024 to date. The
request included amounts from 2022 through May 2024 and reflects $3.0 million
of costs in 2023. The amount in McCoy’s workpaper 8.5.3 represents the
forecasted 2024 dollars expected to be in-service by the end of 2024.

The requested information above marked "highly confidential" is commercially
sensitive and the Company requests special handling. Please contact Mark Alder at
[phone] to make arrangements to 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 141

Recordholder: Rick Williams / Bryce Foster / Lori Rolow

Sponsor: Rick Vail /Todd Jensen

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 145

IPUC Data Request 145

McCoy’s work paper “3.5 – Wheeling Revenue. xlsx” shows a total proforma
adjustment of $14,592,948 in wheeling revenue, which is the sum of the proforma
adjustments of the following items:

• Firm Wheeling Revenue;
• Pre-Merger Firm Wheeling Revenue – UPD;
• Ancil Revenue Sch 2- Reactive (Trans);
• Ancillary Revenue Sch 1 -Scheduling; and
• Transmission Point-to-Point Revenue.

Please define these items and explain how each item’s proforma adjustment is
determined.

Please provide the work paper that calculates each item’s proforma adjustment.

Response to IPUC Data Request 145

• Firm Wheeling Revenue: Please refer to Confidential Attachment IPUC 145
supporting the approximately $1.5 million in additional revenues.

• Pre-Merger Firm Wheeling Revenue – UPD: Please refer to Confidential
Attachment IPUC 145 supporting the approximately $11.049 million in
additional revenues..

• Ancil Revenue Sch 2- Reactive (Trans): “Please refer to Confidential
Attachment IPUC 145 supporting the approximately $247,000 decrease in
revenues.

• Ancillary Revenue Sch 1 -Scheduling: Please refer to Confidential
Attachment IPUC 145 supporting the approximately $45,000 decrease in
revenues.

• Transmission Point-to-Point Revenue: Please refer to Confidential Attachment
IPUC 145 supporting the approximately $1.2 million increase in revenues.

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: Ernie Knudsen

Sponsor: Ernie Knudsen
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 145

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
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 Data Request No. 130-35, 137 -38, 140-41, 145 contains
Company proprietary information that could be used to its commercial disadvantage.
2
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 3rd day of September, 2024.

Respectfully submitted,

By__________________________
Joe Dallas
Attorney
Rocky Mountain Power