20240830PAC to Staff 205-211_214-216.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116

August 30, 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 11 (205-216)

Please find enclosed Rocky Mountain Power’s Responses to IPUC 11th Set Data Requests 205-
216, excluding 212 and 213. The remaining response will be provided under separate cover.
Also provided are Attachments IPUC 207-2 and 214. Confidential Attachments will be provided
via BOX on Tuesday along with the attorney attestation. 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
Friday, August 30, 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 30, 2024
IPUC Data Request 205

IPUC Data Request 205

Company witness McCoy’s Exhibit No. 48, Page 8.5.3, Major Plant Detail lists
the following three projects: (1) “Customer 27 – UT – Trans”; (2) “Customer 22 –
UT -Trans”; (3) “Customer 8 – UT – Trans (1)”. Please provide the following
details for each of these three projects:

(a) Please provide a narrative description of each project scope.

(b) Please identify the Customer in each project, and the facilities that will be
served by each project.

(c) Please specify if the Customer provided any Contribution in Aid of
Construction (CIAC) for this project, and if so, provide the amount and how it
has been applied to the project.

(d) Please provide a map of the transmission line constructed by each project,
showing how it interconnects with other transmission lines and/or generation
resources in the vicinity.

(e) Please provide a current project management Gantt chart for each project
showing the major elements of work, their duration and dependencies, and
their percent complete. Please highlight the project critical path.

Response to IPUC Data Request 205

The requested information is customer-specific information. The Company
requests special handling. Please contact Mark Alder at [phone] to make
arrangements for review.

Please refer to Customer-Specific Confidential Attachment IPUC 205 which
provides the requested information for customer projects:

(1) “Customer 27 – UT – Trans”;

(2) “Customer 22 – UT -Trans”; and

(3) “Customer 8 – UT – Trans (1)”.

Note: Customer-Specific Confidential Attachment IPUC 205 contains customer-
specific information and is considered business confidential. As stated above, the
Company requests special handling. This information is only being provided to
the Idaho Public Utilities Commission (IPUC).

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 205

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: Nathan Adent

Sponsor: Shelley E McCoy

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 206

IPUC Data Request 206

Company witness McCoy’s Exhibit No. 48, Page 8.5.3, Major Plant Detail lists
the following project in the Transmission section: “Project Specialized” for a total
plant-in -service amount of $72,681,510. Please clarify if this is truly a single
project, or an umbrella project for several smaller ones.

(a) Please provide the project scope of work.

(b) Please explain why it has various in-service dates, what are the anticipated
dates, and what scope of work is associated with each in-service date. If it is
an umbrella project for several smaller projects, please provide the following:

i. Please provide a list of the subordinate projects with a unique identifier
and title for each subordinate project;

ii. Please include the estimated cost and completion date for each
subordinate project; and

iii. Please provide explanatory details for the need for each project.

Response to IPUC Data Request 206

(a) Please provide the project scope of work.

Construct new 230-34.5 kV substation and two new 230 kV transmission
lines, approx. 1.2 miles each, for new customer major load addition. Project
includes two new 230 kV interconnections with Umatilla Electric Cooperative
(UEC).

(b) Please explain why it has various in-service dates, what are the anticipated
dates, and what scope of work is associated with each in-service date. If it is
an umbrella project for several smaller projects, please provide the following:

Project has a single in-service date of July 25, 2024.

i. Please provide a list of the subordinate projects with a unique
identifier and title for each subordinate project;

There are no subordinate projects associated with Project
Specialized.

ii. Please include the estimated cost and completion date for each
subordinate project; and

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 206

Please see response to DR 206 subpart (b) i above.

iii. Please provide explanatory details for the need for each project.

Please see response to DR 206 subpart (b) i above.

Recordholder: Ernest Hasselbring / Jeff Keyser / Marcus Kohler

Sponsor: Diana Knous

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 207

IPUC Data Request 207

Company witness McCoy’s Exhibit No. 48, Page 8.5.3, Major Plant Detail lists
the following project in the Transmission section: “OTP196 Nephi 2nd POD” for a
total plant -in-service amount of $6,905,150. Please provide the following
information regarding this project:

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

(b) Please list all potential alternatives the Company considered and explain why
the Company selected this solution.

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

• Initial project scope, including maps and/or drawings depicting the scope;
• Initial project budget;
• Initial proposed schedule; and
• Evidence that the plan and budget were approved at the appropriate level.

(d) Please provide the latest project schedule showing the major elements of
work, the duration and dependencies of those work elements, the percentage
complete of each work element, and critical path for placing the plant in
service.

Response to IPUC Data Request 207

(a) Please refer to Confidential Attachment IPUC 207-1 which provides the
appropriation request (APR) approved for this project and the corresponding
investment appraisal document (IAD) which outlines the project need,
alternatives, schedule, and budget. The approved line on the APR shows
approval by Richard Vail, vice president of PacifiCorp Transmission. Richard
Vail’s approval authority was up to $15 million at the time of this approval.

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

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

(d) Please Attachment IPUC 207-2 which provides the most recent schedule. This
project will no longer be placed in service in 2024. Revised in service date is
March 2025. The Company will remove this project in its rebuttal filing.

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
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 207

Procedure No. 67 – Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Lori Rolow

Sponsor: Richard Vail
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 208

IPUC Data Request 208

Company witness McCoy’s Exhibit No. 48, Page 8.5.3, Major Plant Detail lists
the following project in the Transmission section: “Jackalope Bixby Transmission
Upgrade” for a total plant-in -service amount of $7,034,353. Please provide the
following information regarding this project:

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

(b) Please list all potential alternatives the Company considered and explain why
the Company selected this solution.

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

i. Initial project scope, including maps and/or drawings depicting the
scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate
level.

(d) Please provide the latest project schedule showing the major elements of
work, the duration and dependencies of those work elements, the
percentage complete of each work element, and critical path for placing the
plant in service.

Response to IPUC Data Request 208

(a) Please refer to the Company’s response below:

• Combining block load growth and the retirement of Orpha and Douglas
town substations, along with a 1.5 percent annual growth rate, the total
load projection for Jackalope substation will increase to 31 megavolt
ampere (MVA) in 2022, which is at 103 percent capacity of the Western
Area Power Administration (WAPA) 115 kilovolt (kV) source.

• The current configuration of the transmission system feeding the Douglas,
Wyoming area creates an N-1 issue, which consists of a radial 115 kV line
served from WAPA via Wagonhound substation.

• The load addition on the 115 kV system as a result of the removal of
Orpha and Douglas town only exacerbate the issue with the addition of
6.25 MVA onto Jackalope substation.

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 208

• Over the past five years, there have been four loss of supply outages from
WAPA resulting in 187,508 Customer Minutes Lost (CML) as well as a
tornado in 2018 that damaged the radial 115 kV line from Wagonhound.

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

At Wagonhound substation:
• Install 5-breaker ring bus

Between Dave Johnston Tap South – Wagonhound substation and Dave
Johnston Tap North – Wagonhound substation:
• Rebuild 115 kV lines totaling 48.1 miles utilizing 1272 aluminum
conductor steel-reinforced (ACSR) conductor.

Cost of this alternative is approximately $30,300,000.

Advantages:
• Increases Wagonhound system capacity up to limitation of Wagonhound-
Jackalope 115 kV line (110 MVA).

• Alleviates limitations on Wagonhound source for an indefinite amount of
time.

• Does not require new right-of-way (ROW).

• Wagonhound sub possibly utilized for retirement of 57 kV system in the
Glendo area

Disadvantages:
• Continued exposure (for reliability purposes) to long segments of
WAPA’s line between WAPA Glendo-Casper (5,609 customers
impacted).

• Continued expenditures associated with Jackalope substation’s monthly
energy consumption on balance sheet accounted per WAPA-PacifiCorp
legacy agreement.

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

i. Please refer to the information provided below:

• Tap off existing Bixby – Chalk Butte 115 kV line at structure #6/18 and
install 1.16 miles of new line along Cold Springs Road in new ROW until
the line reaches the existing (abandoned) Dave Johnston – Douglas 57 kV
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 208

line which is de-energized.

• Install 3.24 miles of a new 115 kV line along the existing 57 kV ROW and
remove the existing 57 kV conductor and structures.

• Install a new switch on structure #6A/18 on an existing fiberglass pole.

• Rebuild 4.4 miles of distribution under-build on new transmission line
using existing overhead conductor, where possible.

At Jackalope Substation – Install motor operators on switches 2H833 and
2H831, CCVTs on each line, and an auto throw-over control scheme.

At Bixby Substation – Develop new relay settings for the Chalk Butte line.

Install 4.4 miles of new 115kV transmission line along Cold Springs Road and next to the Dave
Johnson-Douglas 57kV line that is to be removed.
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 208

ii. Please refer to the Company’s 1st Revised response to IPUC Data Request
171, specifically Attachment IPUC 171 which provides the Initial Project
Budget.

Costs Prior Years 2021 2022 Total
10 Year Plan Budget: $350,000 $4,148,162 $0 $4,498,162
APR (Gross): $0 $224,953 $4,698,711 $4,923,664
- Reimbursements:
- Contingency:
APR (Net): $0 $224,953 $4,698,711 $4,923,664

iii. Initial Proposed Schedule

• Project start date – July 1, 2021
• Engineering IFC – June 24, 2022
• Construction start date – June 30, 2022
• In service date – September 15, 2022

1-2 115 kV transm ission w ith 8,000 ft . si ngle ci rcu it under b uil d -ex ist ing 3-p h 556 AAC ,
336 neu t ra l to be t ra nsferre-d t o new Tx st ruct ur es o n lower circu it position . Tra nsf er
fro m new subst ation getaway rise r po le near FP 0 5232071.0-089063 to FP 080562.
EJ909A doubl e ci rcu it f ram i n" ands acin
2-3 115 kV t ransmissi on w ith 9,100 ft . single ci rcu it under bu il d -existing 3p h 7 95 AAC
with 477 AAC n.e-ut ra l to be t ransferred an d i ns t a ll ed on new Tx st r uctures fro m
FP05232071.0-080562 to 05232072.0 -12 1901 . EJ909 sin le circuit frami n
3-4 115 kV t ransm is si on w ith ex isting 6,45 0 ft_ lph und er bu i ld -New 1/0 ACSR and
Neut ra l to repl ace exi sting fi2 ACS R & N. Bu i ld structures with al lowabl e spaci ng for
f utu re 3ph 477 AAC (EJ 909) from FP0 52 32072.0-121901 t o 110960.
I
l
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 208

iv. Evidence that the plan and budget were approved at the appropriate level

(d) This project was deferred to December 31, 2028 due to resource constraints. The
new project schedule and critical path milestones have not been re-developed yet.
The Company will remove this project in its rebuttal filing.

Recordholder: Nathan Adent

Sponsor: Shelley E McCoy
Appropriat ion Req uest Summary Report
APR: 24017340
Title: Jackal ope - Bixby 11 5 kV Transmission Upgrade
Es ti mate Type :
Re que sting Cost Center 12556 -Doug las Local Tran -M
Investment Reason: N9
Pri ority:
Implementation Start: 1210312021
Asset Location: 565100
WBS TDOUl 2020ICI 001 1B
Fun e Group· TRM TU N
State: WY
Plant 20 15
Statu s· App roved
ln-SeMce Date: 09115/2022 Res ponsible Mana ge r: SPENC E R F OWL ER
Approver: Gary Hoogeveen Approved On: 10/07/2021
Spent To Date: 1,631 ,33 7
Capit al and O&M Costs
Costs
'"·"' 00.119 '°""' ~910
125.670 999.m 2.766.110 "'" 3111.281
To tal s. 212,457 1,059,84 2,806,910 2'9.784 341 ,281
" nes cnouan of Asset s and Work oc Pcaoosed Chaooe-
-Tap off ex;sang Bixby -Chalk Butte 11 5 kV line atstructure #6118
and install 1.16 miles of new line along Co.Id Springs Road in new
right-of-way until the line reaches the existing (abandoned) Dave
Johnston -Dougl as 57 kV line which is de-ener gized.
-Install 3.24 miles of a new11 5 kV line al ong the existing 57 kV
right-of-way and remove the existing 57 kV conductor and structur es.
-Install a new switch on structure #6Al18 on an existing fiberglass
p o l e.
-Rebuild 4.4 miles of distribution underbuild on new transmission line.
This p roject is in the currently proposed 2022 capital pl an with S4.5m
of spend in 2022. This project is in the currently approved capital plan
with $4.1m in 2021 but was.deterred one ye<Y to allow other higher
priority projects
Printed 08121/2024
Sa l yag e S..cti..-gi, & Total G ross
Ar uoc
""" """"
4.698.711
473,390 4,923,SS4
Page 1
~PAclFICORP
E,cpenset APR Upg n d et
"'·""
4.698.711
4,923,664
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 209

IPUC Data Request 209

Attachment IPUC 15 lists the following Transmission project: “TIUT/2020/C/012
- Q846 Horseshoe Solar, LLC” for a total plant-in-service amount of
$8,645,796. Please provide the following information regarding this project:

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

(b) Please list all potential alternatives the Company considered and explain
why the Company selected this solution.

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

• Initial project scope, including maps and/or drawings depicting the scope;
• Initial project budget;
• Initial proposed schedule; and
• Evidence that the plan and budget were approved at the appropriate level.

(d) Please provide a comparison of the actual expenditures to the budget, by
budget line item.

Response to IPUC Data Request 209

Please refer to Confidential Attachment IPUC 209 which provides the first
appropriation request (APR) approved for this project and the corresponding
investment appraisal document (IAD) which outlines the project need,
alternatives, schedule, and budget. The approved line on the appropriation request
shows approval by Stefan Bird, who was president and chief executive officer
(CEO) of Pacific Power (PP) at the time of this approval. Stefan Bird’s approval
authority was up to $50 million.

Please also refer to Confidential Attachment IPUC 209 which provides the actual
expenditures to the budget, by line item and the subsequent APRs that shows
approval for the cost increases.

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

Sponsor: Richard Vail
-
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 210

IPUC Data Request 210

Attachment IPUC 15 lists the following Transmission project:
“DCED/2020/C/009 - Future Comp. LLC, 4.3 MW Load” for a total plant-in-
service amount of $7,949,285. Please provide the following information
regarding this project:

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

(b) Please list all potential alternatives the Company considered and explain why
the Company selected this solution.

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

• Initial project scope, including maps and/or drawings depicting the scope;
• Initial project budget;
Initial proposed schedule; and
• Evidence that the plan and budget were approved at the appropriate level.

(d) Please provide a comparison of the actual expenditures to the budget, by
budget line item.

Response to IPUC Data Request 210

(a) A new 4.3 MW load requested by Future Composites LLC in
Gunnison, Utah was projected to result in 0.86 pu voltage at Gunnison
substation summer 2022. The voltage standard is 0.9 pu. In 2023,
additional customer load will result in 0.78 pu voltage at Gunnison.
This 46 kV substation is 25 miles from its source, Sigurd substation.
The low voltage can be mitigated by installing 12.2 miles of 1272
ACSR. While this will meet the voltage standard, existing load growth
in the area will cause substandard voltage in following years. The
solution is to extend the rebuild to include a total of 17 miles

(b) Alternative: Convert Gunnison substation to 138 kV

Advantages:
• Provides more capacity for future growth than proposed solution

Disadvantages:
• Costs more than proposed solution
• Equipment procurement times may be too long for solution to be in place
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 210

before 2022

Block estimate: $19,000,000

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

• Sigurd-Gunnison #2:
• Beginning at Sigurd substation, rebuild 17 miles to 1272 ACSR
138 kV construction
• Swap Sigurd-Gunnison #2 and Sigurd-Gunnison #1 lines at
termination of rebuild south of Axtell, Utah.
Distribution:
• 1- PMH 9 SWITCH GEAR_______1- THREE PHASE
PRIMARY RISER
• 1- 2500 KVA 277/480 PADMOUNT TRANSFORMERS
• 2- 4000 AMP CT METERING UNITS
• 1- THREE CAT BANK 1200 KVAR
• 3238' OF 4/0 AAAC PRIMARY
• 3993 OG 477 AAC PRIMARY
• 500' OF_3-1000 15 KV URD PRIMARY
• 400' OF 4/O URD THREE PHASE PRIMARY
• 4- 45' THREE PHASE POLES
• 3-50' THREE PHASE POLES___3- SINGLE PHASE PRIMARY
RISERS
• REMOVE
• 4- 40' THREE PHASE POLES______3800' OF 4#1/O ACSR
PRIMARY
• 2-45' THREE PHASE POLES_____3-SINGLE PHASE PRI.
RISERS
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 210

• 794' OF 3#250 AL PRIMARY

Figure 1: Transmission Improvements

Figure 2: On-site Distribution Infrastructure
Aurora
Vermillion
Western Clay
Feed Plant
Salina
Gunnison
N.O.
Sigurd
To Fayette To Manti
2022: Rebuild 10.5 mile
Sigurd-Gunnison #2 to
1272 ACSR. Swap line
feeds south of Salina.
Move Aurora to Sigurd -
Gunnison #1.
Si
g
u
r
d
-Gu
n
n
i
s
o
n

#2
Si
g
u
r
d
-Gu
n
n
i
s
o
n

#1
2021 On -Site infrastructure
Install ri ser pole
Install PME9 sw itchgear
Install 2500 kVA 12470-277 /!!_8.Q..i/_o.1)
pad mount transformer
1060' of 3#1000-AL underground
cab le from rise r pole to gro und
sleeve
30' of 3#4/0 -A L undergroun d
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 210

Figure 3: Offsite Distribution Infrastructure
• Initial project budget; $9,000,000

• Anticipated project start date or actual project start date: 4/01/2021
In-service date: 5/15/2022

• Evidence that the plan and budget were approved at the appropriate level.

(d) Please refer to the table below which provide a comparison of the actual
expenditures to the budget, by budget line item.

@
Gunnison
Substation
1 Systl!!m Status Rl!!sult
Master data lo .. , Approved
Approved
ApprCNed
Approved
Approved
ApprO'ied
App roved
App roved
ApprOll'ed
Approved
App roved
__ A~ed
(
~:t __ j
I
2021 Off-Site
Infrast ructure
1-3 Rebuild 4 ,991' of 3#2-AS t o
3#477-AL overhead between
FP 160406 and FP 167602
Install 1200 kVAR switched
capacitor FP 166601
! --: """dltael021
1
r. J ----See On-Site --7
Jes o t i [_ __ _
@I
1'
Approv@r Nam4!!
Brandon Smith
Cindy Dimond
Thomas Turner
Russell Upd ike
Natha n Bailey
Jaren J Ca mpbell
1200 kVAR
Sw itched
lnvst RI! ...
NJ
Jenafer Erramouspe
Jayso n Branch
Nikki Ko~iha
Curtis Mansfield
~eveen
APR
94011665
94011665
94011665
94011665
940 11665
94011665
94011665
94011665
94011665
94011665
94011665
94011665
Ol!!saiption
Future Comp. LLC, 2.5 MW Load
Total Cost Approver Workflow Tim@ Sta ...
9,000,000.00
P06193 03/29/202 1 -05 53 32
P10313 03/29/2021 -13:07:04
Pl 5249 04/08/2021 -09:31:20
P97548 04/08/2021 -15:05:31
P1203 4 04/12/202 1 -13:52:20
P44361 04/12/2021-14:29:47
P44552 04/14/2021 -08:11:5 1
P16264 04/14/202 1 -08:30:36
P74018 04/20/202 1 -11:36:29
Pl 0272 04/20/202 1 -13:08:20
P3605 2 04/20/2021 -13:33:17
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 210

Recordholder: Thomas Turner

Sponsor: Shelley E McCoy

I Lead co lumn II Plan 1 II Act ual II Variance II Var% I
!o ve rall II 1,305,66411 8,617,38611 (7,3 11,722)11 (560 .o)I
I--------------------11--------------11--------------11--------------11--------------I
IA II Previous yea rs II 1,305,66411 8,617,38611 (7,3 11,722)11 (560 .o)I
12023 II 1,305,66411 3,045,74911 (1,740,085)11 (133.3)1
12024 II oil 80,52911 (80,529)11 x/ol
" " "
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 211

IPUC Data Request 211

Please provide the Company’s procedures and policies documenting its capital
project management controls. This should include required process steps,
verifications, and approval levels for different types of expenditures and/or dollar
thresholds.

Response to IPUC Data Request 211

Please refer to Confidential Attachment IPUC 211.

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: Kristi Olsen

Sponsor: Ryan Weems

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 214

IPUC Data Request 214

Company’s Attachment 55-1 lists 18 transmission projects with no “Annual
Actual Project Costs Placed in Service (by year)” from 2022 through 2024. For
each, please answer the following:

(a) Please provide a narrative description of each project scope.

(b) Please provide a current project management Gantt chart for each project
showing the major elements of work, their duration and dependencies, and
their percentage complete. Please highlight the project's critical path.

Response to IPUC Data Request 214

The Company assumes that the reference to “Attachment 55-1” is intended to be a
reference to the Company’s response to IPUC Data Request 55 and Attachment
IPUC 55-1. Based on the foregoing assumption, the Company responds as
follows:

For the following projects please refer to the Company’s responses to IPUC Data
Requests 130 through 141.

• Anticline 34 kilovolt (kV) Phase Shifter
• GWS 230 kV Supporting projects (GW)
• Oquirrh-Terminal 345 kV Line
• TMP EV2024 Q0835 Rock Creek Wind LLC- Rock Crk Wind
• TMP EV2024 Q0713 Cedar Springs Wind IV Wind
• TMP EV2024 Q0409 Boswell Springs Wind
• TMP EV2024 Q0785 Anticline Wind

For the following project, please refer to the Company’s response to IPUC Data
Request 205:

• Customer 27 – UT – Trans
• Customer 22 – UT - Trans

For the following project, please refer to the Company’s response to IPUC Data
Request 207:

• OTP Q196 Nephi 2nd POD

For the following project, please refer to the Company’s response to IPUC Data
Request 208:

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 214

• Jackalope-Bixby Transmission Upgrade

For the following projects, please refer to Attachment IPUC 214:

• Houston Lake- Ponderosa Add Second 115 kV Line
• Tucker 69 kV Line
• Line 30 & 65 Convert to 115 kV: New 230-69 kV Sub T

Note: The Tucker 69 kV Line and the Line 30 & 65 Convert to 115 kV: New 230-69 kV
Sub T projects will not be completed in 2024 and the Company will remove the projects
from its application in its rebuttal filing.

For the following project, please refer to the information provided below:

• Fort Hall/BIA Jim Bridger Kinport G-2067 - shared IPC

(a) The Jim Bridger – Kinport 345 kV transmission line Grant of Right of
Way (ROW) expired March 15, 2024. The Bureau of Indian Affairs, the
Shoshone Bannock Tribes, Allottees, and Rocky Mountain Power (RMP)
have been working since February 15, 2019 on a renewal. All Code of
Federal Regulation (CFR) requirements have been achieved or will be
complete within the next six months. The Fort Hall Business Council and
RMP are still negotiating a final compensation amount of approximately
$4,375,000 for a 20-year term for a ROW that is 14.46 miles long and 140
to 150 feet in width that totals 258.113 acres. National Environmental
Policy Act (NEPA) requirements will be completed and a Finding of No
Significant Impact (FONSI) will be signed by the end of 2024.

(b) Project milestones include and schedule include:

• New survey completed in 2023 (100 percent complete).
• NEPA (Environmental Assessment, Cultural and Biological Studies)
will be completed in 2024 (95 percent complete).
• Compensation negotiations will be completed in 2024 (60 percent
complete).
• Allottee consent forms will be sent as soon as compensation
negotiations are complete (5 percent complete).
• Recorded and funded – Expected June 30, 2025

Recordholder: Thomas Turner

Sponsor: Shelley E McCoy

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 215

IPUC Data Request 215

Company's Attachment 55-1 lists project "Midpoint 500 kV Series Cap Bank Rpl
(IDP)" with an in-service date of January 2024; however, it does not list any
actual project costs placed in service. Please explain if this project is in service as
of July 2024 and please explain this discrepancy.

Response to IPUC Data Request 215

The Company assumes that the reference to “Attachment 55-1” is intended to be a
reference to the Company’s response to IPUC Data Request 55 and Attachment
IPUC 55-1. Based on the foregoing assumption, the Company responds as
follows:

The Midpoint 500 kilovolt (kV) Series Cap Bank Rpl (IDP) project was
inadvertently listed on Attachment IPUC 55-1. The Company’s pro-forma capital
projects are limited to known and measurable projects defined as projects
expected to be placed in-service by the January 1, 2025, rate effective date and
greater than $5 million dollars. While the above mentioned project did get placed
in-service, it was not requested for recovery in the Company’s direct filing as it
was forecasted to be less than $5 million dollars. As such, where the Company did
not seek recovery in the direct filing, this project should have been excluded from
Attachment IPUC 55-1.

Recordholder: Nick Highsmith / Theresa Haggard

Sponsor: Shelley E McCoy

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
IPUC Data Request 216

IPUC Data Request 216

Company's Attachment 55-1 lists project "Houston Lake - Ponderosa Add Second
115 kV Line" with an in-service date of May 2024; however, it does not list any
actual project costs placed in service. Please explain if this project is in service as
of July 2024 and please explain this discrepancy.

Response to IPUC Data Request 216

The Company assumes that the reference to “Attachment 55-1” is intended to be a
reference to the Company’s response to IPUC Data Request 55 and Attachment
IPUC 55-1. Based on the foregoing assumption, the Company responds as
follows:

The in-service date indicated in the Attachment IPUC 55-1 was in error.
Construction started in June 2024 and the current contractor schedule is for
completion in December 2024.

Recordholder: Ron Nagel / Lori Rolow

Sponsor: Todd Jensen

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 11 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 3rd day of September, 2024.

Respectfully submitted,

By__________________________
Joe Dallas
Senior Attorney
Rocky Mountain Power