20240906PAC to Staff Response No.174.pdf

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

September 6, 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 Response to IPUC 9th Set Data Request 174.
Provided via BOX is Confidential Attachment IPUC 174. 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]
Brandon Helgeson/PIIC [e-mail]
RECEIVED
Friday, September 06, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Bradley Mullins/PIIC [e-mail]
Val Steiner /PIIC [e-mail]
Kyle Williams/PIIC [e-mail]

PAC-E-24-04 / Rocky Mountain Power
September 6, 2024
IPUC Data Request 174

IPUC Data Request 174

Please provide the following information for the Rock Creek I (RC) wind project
referenced by Wagner, DI at 2. Please include any available work papers 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 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) Please provide the following information regarding all RFPs or RFQs
associated with the development and construction of the RC plant:

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

(c) 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.

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

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.

(e) 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;
PAC-E-24-04 / Rocky Mountain Power
September 6, 2024
IPUC Data Request 174

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 174

(a) Please refer to direct testimony and supporting work papers of Company
witness, Thomas R. Burns for the economic analysis supporting the selection
of the Rock Creek I wind project. Please refer to the direct testimony of
Company witness, Rick T. Link, page 19, which identifies the six final
shortlist (FSL) resources selected from the 2020 All Source Request for
Proposals (2020AS RFP).

(b) Please refer to Thomas Burn’s direct testimony and supporting work papers
which summarize the Company’s assessment from the 2021 Integrated
Resource Plan (IRP) and 2020AS RFP, including economic analysis and the
selection of the Rock Creek I wind project.

(c) Please refer to Confidential Attachment IPUC 174 which provides a copy of
Appropriation Request (APR) 10029986 which includes the project scope,
schedule, and authorized budget.

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

i. The baseline project scope is provided in Confidential Attachment IPUC
174 (APR 10029986).

ii. The baseline project budget broken down by work breakdown structure
(WBS) is provided in Confidential Attachment IPUC 174 (APR
10029986, Attachment C).

iii. The baseline project schedule is provided in Confidential Attachment
IPUC 174, confidential file “Rock Creek I&II Combined – Appendix G
Project Schedule CONF”. The project schedule is based on work activities
not on WBS.

iv. To-date, no changes have been made to the project scope, schedule or
budget that deviate from the Initial Plan. Forecasted project costs have
been reduced relative to budget as the project has proceeded and unknown
initial costs have been finalized.

PAC-E-24-04 / Rocky Mountain Power
September 6, 2024
IPUC Data Request 174

v. Please refer to Confidential Attachment IPUC 174 which provides copies
of the monthly progress reports from Invenergy.

vi. PacifiCorp has executed no change orders to-date for Rock Creek I.

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

i. A comparison of the baseline budget to actuals to date is provided in
Confidential Attachment IPUC 174, confidential file “RCI Cost
Accounting File RC I_240805 budget to actual CONF”.

ii. Project Schedule is based on work activities not on WBS. The most recent
available project schedule update from June 2024 is provided in
Confidential Attachment IPUC 174.

iii. There have been no overages in any major WBS category to-date.

iv. Wind turbine deliveries are delayed due to delays in General Electric’s
(GE) production of machine heads and small parts. This, in turn, has
delayed ongoing turbine erection activities relative to the initial project
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: Michael Saunders

Sponsor: Jeffrey Wagner

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. 174 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 6h day of September, 2024.

Respectfully submitted,

By__________________________
Joe Dallas
Senior Attorney
Rocky Mountain Power