20240829PAC to Staff 157_160.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 9 (155-174)
Please find enclosed Rocky Mountain Power’s Responses to IPUC 9th Set Data Requests 157 and
160.The remaining responses will be provided under separate cover. Also provided is
Attachment IPUC 157-2. Provided via BOX are Confidential Attachments IPUC 157-1 and 160.
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 157

IPUC Data Request 157

Please provide the following information for the “APIM-Asset Performance and
Investment Mg” project referenced in Production Request No. 15 response from
the Company. Please include any available workpapers with formulas intact. If
any of the information requested below cannot be provided or is not available,
please explain why it is not available or cannot be provided.

(a) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.

(b) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company’s economic analysis (costs and
benefits) comparing them.

(c) If a Request for Proposal (RFP) or Request for Quote (RFQ) was submitted,
please provide the following:

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

(d) Please provide the approved Initial Project Plan including the following:

i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.

(e) Please provide the following for the Baseline Construction Project:

i. Baseline project scope;
ii. Baseline project budget broken down by 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
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 157

vi. Contractor change orders.

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

i. Baseline construction budget-to-actual comparison by WBS and by year;
ii. Baseline construction schedule-to-actual comparison by WBS;
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 157

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

• Introduction
On the journey to operational excellence, PacifiCorp must implement
digital innovation to support business teams in operating and maintaining
assets better and at optimal cost levels. Deploying advanced digital
technologies such as machine learning and scenario planning tools will
capture value from the Company’s vast asset data to generate proactive
insights to improve asset performance.

• Description and Strategic Fit
PacifiCorp is undertaking a significant project to improve its current and
future Asset performance and Investment Management (APIM) software
and insights capabilities. The scope of the project is a combination of
traditional asset performance management and asset investment decision
analytics.

• Benefits

o Improved Customer Reliability
This program will allow us to increase reliability to our customers
through near real-time detection and analysis of risk factors to
identify assets with higher risk. This will reduce customer outages,
related customer costs, and increase customer satisfaction. This
will improve system average interruption duration index (SAIDI),
availability, and perfect service key performance indicators (KPI).
A major component of asset performance and investment
management is the development of customer risk forecasts by
asset. Customer risk models consider the probability of failure and
consequence of failure to assess the prioritization and optimal level
of asset replacement programs. The goal is to mitigate risk and
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 157

ensure funds are allocated appropriately to address assets with
unfavorable projected customer impacts.

o Maintenance Cost/Benefit Optimization
This program will transparently quantify the costs and benefits of
multiple maintenance investment scenarios to compare alternatives
prior to investment. This includes the ability to compare value
across asset types to optimize different program investment levels.
The optimization will enable delivery of the highest possible
customer value and recommend the best level of maintenance
investment based on our stated values. This will likely result in
cost reductions in some areas, and data-driven recommendations
for increased investment in others.

o Risk Mitigation
A major component of this program is rapid anomaly detection and
machine learning based forecasting. Both of these are design to
identify risk proactively and run scenarios to compare the
probabilistic costs and benefits of possible intervention scenarios
compared to taking no action.

o Stronger Rate Cases for Improved Rate Recovery
This program will provide data-driven investment scenario
comparisons based on a transparent set of stated values. This
program will also increase our ability to track the success rate of
maintenance programs. These will in turn provide a strong
foundation for future rate recovery business cases.

(b) The existing process in place is reactive and time-based in nature. Generally,
an asset is replaced or fixed when it breaks or fails, or based on age which can
be earlier than necessary. Unplanned interruptions impact the quality of
service the Company provides to its customers and can be more expensive due
to downtime and truck roll costs. The most significant costs of an unplanned
interruption are born by the customer. The focus of APIM is to fundamentally
change the operational and financial response from reactionary or time-based
action to proactive actions based on forecast customer impact. Asset condition
data (Maximo), location information (GIS), and operational data (PI) are the
base foundation that APIM will be built upon. Corrective maintenance and
preventative maintenance work order data along with asset level attributes
stored in Maximo will feed into the APIM tool along with historical
operational data to generate early asset replacement recommendations for
cost/benefit optimization. Improvements of only a few percent can result in
millions of dollars in value across the asset fleet.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 157

APIM Cost/Benefit Analysis:

Note: All figures are in millions

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

i. Please refer to Confidential Attachment IPUC 157-1 which provides a
copy of the request for proposals (RFP).

ii. Please refer to the Company’s response subpart (c) (iii) below:

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 157

iii. During the RFP process there were initially 34 suppliers contacted
with 248 requests for proposal requirements and 28 live demonstration
requirements. Out of the 34 suppliers, 21 of them were able to meet
the requirements to participate. From the remaining 21, there were 11
chosen to move forward and asked to offer a live demo. From these
suppliers, there were also separate evaluations by discipline with
business leads.

After these evaluations, seven were asked to move forward with the
live demo. The seven remaining were evaluated as below.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 157

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 Confidential Attachment IPUC 157-1 which provides a copy of
the initial baselined project plan, “APIM_Baseline Aug 23 CONF”. Please
note that the project plan is a global overall plan including other affiliates
along with the Company. Please refer to Confidential Attachment IPUC 157-1
for the initial project budget, file “APIM Implementation AFE EXCL ALT
CONF”.

Below is a snapshot of the approved budget for the Company from 2022 to
2030 as per the original APIM AFE.

(e) Please refer to Confidential Attachment IPUC 157-1 which provides a copy of
the baselined project plan from OPC. Please note that the project plan is a
global overall plan including other affiliates along with the Company. We do
not breakdown the project budget by work breakdown structure (WBS).
Please refer to Attachment IPUC 157-2 which provides the copies of weekly
status reports

(f) The project is still on-going. Please refer to the table below which provides
the baseline to actual budget for the Company for 2022 and 2023. The project
actuals have been managed within the budget. For the Company2022 and
2023 budget numbers refer attached APIM AFE. Below is a snapshot of the
comparison. Budget and schedule variances shown were driven by formal
requests in 2022 and 2023 to slow spending for the Company. This project ran
very tight to the revised plans.

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.
Pacificorp 2022 Budget 2022 Actuals 2023 Budget 2023 Actuals
Capital $3,812,029 $2,156,685 $3,718,753 $2,393,040
Expense $169,867 $0 $563,018 $607,195
Total $3,981,897 $2,156,685 $4,281,771 $3,000,234
PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 157

Recordholder: Theresa Anders

Sponsor: Shelley E McCoy

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 160

IPUC Data Request 160

Please provide the following information for the “LCT Open Office Plan” project
referenced in Production Request No. 15 response from the Company. Please
include any available workpapers with formulas intact. If any of the information
requested below cannot be provided or is not available, please explain why it is
not available or cannot be provided.

(a) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.

(b) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company’s economic analysis (costs and
benefits) comparing them.

(c) If a RFP or RFQ was submitted, please provide the following:

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

(d) Please provide the approved Initial Project Plan including the following:

i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at
the appropriate level.

(e) Please provide the following for the Baseline Construction Project:

i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the
differences, explain the reason for the change, and provide
evidence that the changes were approved at the appropriate level;
v. Project status reports and action items; and
vi. Contractor change orders.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 160

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

i. Baseline construction budget-to-actual comparison by WBS and by
year;
ii. Baseline construction schedule-to-actual comparison by WBS;
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 160

(a) The Company spent approximately $30 million remodeling the Lloyd Center
Tower (LCT) to a concept that allowed for greater employee engagement. The
remodel was expected to create a sustainable competitive advantage
ultimately benefitting customers through higher employee retention and
recruitment, enhanced productivity, and greater operational performance. The
Company also evaluated the alternative of constructing an equivalent sized
building with the same collaborative design concept.

The furnishings and finishes on LCT floors were worn and dated as they were
installed in 1998 without any major changes. Hiring and retaining employees
is necessary in the competitive work environment, and the new space is
intended to increase collaboration among employees as well as contribute to
hiring and retaining employees.

(b) The Company reviewed two models. One was to remodel the LCT to meet the
project objectives. The other alternative was to relocate the office space to a
new building. There were no existing buildings with 200,000 square feet of
available office space. The relocation alternative was determined to be less
beneficial to customers and was rejected by the Company.

(c) The Company did not perform a request for proposals (RFP) specifically for
the project as the design and construction was phased on a per floor basis. The
Company had to design, vacate and construct floors one at a time, because the
office space was fully occupied. The work was released through the project as
the design of the floors were prepared and permitted.

i. PacifiCorp used existing contracts to perform the work in order to
allow for the phased construction and furniture purchases. These
existing contracts were previously bid with set mark ups.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 160

ii. The Company did not complete an RFP.

iii. The Company did not complete an RFP.

iv. The Company did not complete an RFP.

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

i. The remodel included an open office environment with all new
finishes, height-adjustable workstation furniture, a variety of sized
meeting rooms and audio-visual (AV) functionality. The new
workspace provides an environment that encourages collaboration
among employees and teams; ultimately benefitting customers.

ii. The initial project budget was $30,043,350.

iii. The completion was scheduled for 2022.

iv. Please refer to Confidential Attachment IPUC 160 which provides a
copy of the appropriation request (APR) and a copy of the price
change notice (PCN).

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

i. The project included a remodel of the floors, the purchase of
ergonomic furniture, and updated conference room and enclave
furnishings with new AV functionality. The floor plan incorporated an
open office environment to increase collaboration. All workstations
were the same size and configured for standardization. The floors were
designed independently as the Company moved through the project.
Central breakrooms were created to encourage collaboration.

ii. The project was not budgeted by work breakdown structure (WBS).

iii. The schedule was not based on WBS.

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

v. The project was managed utilizing weekly meetings to review current
issues and next steps. Project status reports were not employed as the
status updates were live. These meetings were essential to keep
stakeholders informed of the status and to maintain standards as the
floors were planned in a phased manner throughout the project.

PAC-E-24-04 / Rocky Mountain Power
August 29, 2024
IPUC Data Request 160

vi. The floors were designed and then released to the contractors. With
this method of design and construction, there were no material change
orders to the contractors.

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

i. Please refer to the table provided below:

ii. The Company did not detail the schedule by WBS.

iii. There was revision to the cost for the project that was presented to
management. Please refer to the table below which provides the
drivers for the cost increase:

iv. Due to the COVID-19 pandemic, material delivery delays and longer
construction on certain floors, the project was extended into 2024.
The 2024 work was minor. The project was substantially complete by
the end of 2023.

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 160

Recordholder: Steve Day

Sponsor: To Be Determined
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 Data Request No. 157 & 160 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