20240905PAC to Staff 139.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 5, 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 Response to IPUC 8th Set Data Request IPUC
139.Also provided is Attachment IPUC 139-2. Provided via BOX is Confidential Attachment
IPUC 139-1. 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, SEPTEMBER 5, 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
September 5, 2024
IPUC Data Request 139

IPUC Data Request 139

Please provide the following information for the “OTP189 Klamath Dam
Removal (ESM)” 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 139

Please refer to Confidential Attachment IPUC 139-1 and Attachment IPUC 139-2.

(a) Please refer to the investment appraisal document (IAD), confidential file
“APR 94013034 OTPQ0189 IAD KDam Removal CONF” which outlines the
PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 139

need for the project.

(b) No alternatives were considered as part of this project due to a customer
request.

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

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.

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 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. The 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.

PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 139

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.

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

i. Please refer to confidential file “APR 94013034 OTP189 Klamath Dam
Rmvl CONF”. This appropriation request (APR) shows that Richard Vail,
vice president of PacifiCorp Transmission, was the final approver of
project funds.

ii. Please refer to confidential file “Baseline construction budget to
actual._Klamath Dam Removal_CONF”.

iii. Please refer to file “Construction Schedule- Line work”.

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 APR 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.
Please refer to confidential file “APR 94013951 OTP189 Klamath Dam
Removal CONF” and its associated IAD, confidential file “ APR
94013951 OTP189 KDam Removal IAD CONF”.

v. The work to expand the substation yard and add the capacitor bank was
originally planned for completion in late 2023. The capacitor bank was the
priority, and that part of the project was completed on schedule in
December 2023. However, it was not energized until February 2024 due to
the discovery of clearance issues at one of the associated substations (JC
Boyle). The line work to resolve the clearance issues took several weeks,
which delayed the energization of the capacitor bank. Additionally, the
final civil work associated with the substation expansion was not
PAC-E-24-04 / Rocky Mountain Power
September 5, 2024
IPUC Data Request 139

completed until May 2024. The delay was due to the discovery of
additional rock that required crushing in the subsurface soils, as well as
weather-related delays during the winter months, which slowed the ability
to transport materials to the job site.

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: John Aniello / Lori Rolow

Sponsor: Todd Jensen / Richard Vail

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. 139 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 5th day of September, 2024.

Respectfully submitted,

By__________________________
Joe Dallas
Attorney
Rocky Mountain Power