20240911PAC to Staff 217-222_224_229-240.pdf

RECEIVED
WEDNESDAY, SEPTEMBER 11, 2024
IDAHO PUBLIC
_ ROCKY MOUNTAIN UTILITIES COMMISSION
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 11, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
monica.barrio ssanchez(apuc.Idaho.gov
S ecretarygpuc.idaho.gov
RE: ID PAC-E-24-04
IPUC Set 12 (217-240)
Please find enclosed Rocky Mountain Power's Responses to IPUC 121' Set Data Requests 217-
240, excluding 223 and 225-228. The remaining response will be provided under separate cover.
Also provided is Attachment IPUC 224-2. Confidential Attachments and Confidential
Responses are provided via BOX. 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 elokechohawk.com(C)
Lance Kaufman/IIPA lance@ae ism h�(C)
Matthew Nykiel/ICL matthew.n, k�(&gmail.com
Brad Heusinkveld/ICL bheusinkveldgidahoconservation.org
Thomas J. Budge/Bayer tj racineolson.com(C)
Brian C. Collins/Bayer bcollinskconsultbai.com
Greg Meyer/Bayer gmeyer(&consultbai.com
Kevin Higgins/Bayer khia gins kenergystrat.com(C)
Neal Townsend/Bayer ntownsend(&energystrat.com (C)

Ronald L. Williams/PIIC rwilliams&hawleytroxell.com
Brandon Helgeson/PIIC bhel eg son ci,hawleytroxell.com
Bradley Mullins/PIIC brmullins(&mwanalytics.com
Val Steiner/PIIC val.steinergitafos.com
Kyle Williams/PIIC williamskkbvui.edu

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 217
IPUC Data Request 217
Please provide a description of the savings expected from the Field Ai-Field Asset
Intelligence project referenced in Production Request No. 15 —Attachment and
how they are being realized.
Response to IPUC Data Request 217
The Field Ai program, inclusive of the initiatives referenced in the Company's
response to IPUC Data Request 15 (Maximo Ia, Powerbase, AppDynamics,
Splunk, etc.), provide the benefits of increased security, system reliability, and
enhanced data quality. For PacifiCorp, this program is required to replace the
obsolete retail construction management system(RCMS)platform for which it is
increasingly difficult to maintain.
Recordholder: Amanda Lindsay
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 218
IPUC Data Request 218
Please provide the actual in-service date for the Field Ai-Field Asset Intelligence
project referenced in Production Request No. 15—Attachment. If this has not
been placed in-service, please provide a new estimated in-service date.
Response to IPUC Data Request 218
"Field Ai" is the title of a program comprised of multiple projects initiated to
create workforce efficiencies and provide integrated asset information across
systems in the transmission and distribution work and asset management space.
The Field Ai program is anticipated to close by Q2 2027 (meaning all projects
under the program structure are anticipated to be in production).
Recordholder: Amanda Lindsay
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 219
IPUC Data Request 219
Please provide the actual spending in 2024 through July 31 for the Field Ai-Field
Asset Intelligence project referenced in Production Request No. 15—Attachment.
Response to IPUC Data Request 219
The Field Ai-Field Asset Intelligence project, as defined in the Company's
response to IPUC Data Request 79 and referenced in the Company's response to
IPUC Data Request IPUC 15, specifically Attachment IPUC 15, has the following
updates:
There has not been any spending in calendar year 2024 (through July 31, 2024)
for the Field Ai-Field Asset Intelligence projects (Maximo la, Powerbase,
AppDynamics, Splunk, etc.).
For the Field Ai-Field Asset Intelligence - Graphical Work Design (GWD))
project, which was not included in the $20.5 million for Field Ai-Field Asset
Intelligence on Attachment IPUC 15 due to in-service date being subsequent to
the Company's previous response to IPUC Data Request 15,please refer to the
Company's response to IPUC Data Request 221.
Recordholder: Amanda Lindsay
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 220
IPUC Data Request 220
Please provide the actual in-service date for the Field Ai-Field Asset Intelligence -
GWD project referenced by Shelley E. McCoy in Workpaper 8.5.3 —Major Plant
Additions. If this has not been placed in-service, please provide a new estimated
in-service date.
Response to IPUC Data Request 220
The estimated in-service date for the Field Ai-Field Asset Intelligence Graphical
Work Design (GWD) project is September 20, 2024.
Recordholder: Cynthia Jolliver
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 221
IPUC Data Request 221
Please provide the actual spending in 2024 through July 31 for the Field Ai-Field
Asset Intelligence - GWD project referenced by Shelley E. McCoy in Workpaper
8.5.3 —Major Plant Additions.
Response to IPUC Data Request 221
Please refer to the table below which provides the actual spend in calendar year
2024 (through July 31, 2024) for the Field Ai-Field Asset Intelligence - Graphical
Work Design (GWD) project:
Actual spend in Calendar Year 2024 (through July 31,2024)
GWD project
Capital $6,384,477
OMAG $1,716,960
Capital Surcharge $213,093
AFUDC $427,213
Total $8,741,743
Recordholder: Cynthia Jolliver
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 222
IPUC Data Request 222
Please provide the cost savings the Company has gained or is expected to gain
from the roll out of AMI. Please show where this is represented in the Company's
rate case filing.
Response to IPUC Data Request 222
PacifiCorp achieved approximately $2.22 million in projected net advanced
metering infrastructure (AMI) benefits in 2023. The Company is projecting net
annual benefits of$2.65 million in 2024 increasing moderately each year after
that due to increases in AMI meter counts, operational efficiencies, business
process changes, and inflationary impacts.
Note: the savings identified above cannot be specifically identified in the
calculation of the Test Period revenue requirement in this general rate case (GRC)
as they are embedded in the actual cost informing the base period historical
actuals.
Recordholder: Cory Estlund
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 224
IPUC Data Request 224
For each year in 2020 through 2023, please provide:
(a) the total RECs generated for that year, and
(b) the total system load for the same year for the Company's system.
Response to IPUC Data Request 224
(a) Please refer to Confidential Attachment IPUC 224-1 which provides the total
amount of renewable energy credits (REC) generated in calendar years 2020
through 2023.
(b) Please refer to Attachment IPUC 224-2 which provides peak(megawatt
(MW)) and energy (megawatt-hour (MWh)) data for calendar years 2020
through 2023. Total system load/energy (MWh) is included at the bottom of
each of the provided files.
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: Cato Wagner, III/Chet Perry
Sponsor: David Novom/Chet Perry

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 229
IPUC Data Request 229
Please respond to the following regarding the CCA costs associated with the
Chehalis plant.
(a) Please provide the dispatch cost in $/MWh for the Chehalis plant used in the
Aurora model.
(b) Please explain whether the dispatch cost includes any allowance cost in
$/MWh.
(c) If so, please provide the allowance cost in $/MWh assumed in the dispatch
cost.
(d) Please provide the CCA allowance price in"$/allowance" that was used to
calculate the CCA allowance unit price in "$/MWh".
(e) Please explain how the $/allowance unit price is determined.
(f) Please explain and provide work papers showing how the CCA unit price is
converted from $/allowance to $/MWh.
(g) Please explain whether the CCA unit price included in the dispatch cost is the
same as the CCA unit price stated in Response to Production Request No. 117
(a).
(h) If not, please reconcile and explain the causes for any difference.
Response to IPUC Data Request 229
(a) The Company assumes that the reference to dispatch price is intended to
reference the costs input into the Aurora model for the determination of
Chehalis's position in the resource stack. Based on the foregoing assumption,
the Company responds as follows:
The Chehalis plant has three main cost assumptions that help the Aurora
model determine its position in the resources stack.
I. Variable operation and maintenance (VOM) costs—Please refer to the
confidential work papers supporting the direct testimony of Company
witness, Ramon J. Mitchell, specifically confidential file "Aurora GNw
Resource Table Thermal".
2. Fuel costs—Please refer to the confidential work papers supporting
Ramon Mitchell's direct testimony, specifically confidential file "Aurora

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 229
GN Fuel Price", tab "mn x". Note: the units for fuel costs are in dollars
per million British thermal unit($/MMBtu).
Heat rate assumptions—please refer to the confidential work supporting
Ramon Mitchell direct testimony, specifically confidential file "Aurora
GN Heat Rate Definitions". Note: the units for heat rate is million British
thermal units per megawatt-hour(MMBtu/MWh).
These two values together help determine the fuel cost of Chehalis plant,
dependent on its operational level.
3. Washington Cap and Invest Program Allowance costs—Please refer to the
Company's response to IPUC Data Request 117.
Collectively, the three input cost assumptions noted above are the costs for
Chehalis plant input into the Aurora model. These three costs help determine
the position of the resource in the Aurora model's optimization resource stack.
(b) Yes. The dispatch cost includes an allowance price as input in dollar per
megawatt-hour($/MWh) units.
(c) Please refer to the Company's response to IPUC Data Request 117 subpart
(a).
(d) Please refer to Confidential Attachment IPUC 229 which provides the
allowance price in units of dollars per metric ton of carbon dioxide equivalent
($/MT CO2e).
(e) The settlement"$/allowance"price is determined in each auction by
acceptance of bids per Washington Administrative Code (WAC) 173-446-357
and is subject to a floor and ceiling price per WAC 173-446-335.After each
auction, the Washington State Department of Ecology (Ecology)posts an
Auction Summary Report outlining information about the settlement price and
number of allowances sold, as well as different aspects of auctions and market
participation. The referenced Auction Summary Reports are publicly available
and can be accessed by using the follow website links:
Current Year:
Auctions and market - Washington State Department of Ecology
Archive:
https://apps.ecology.wa.gov/publicationsiUIPages/PublicationLi st.aspx?Index
TypeName=Topic&NameV alue=Cap-and-
Invest+%e2%80%94+Market+Reports&DocumentTypeName=Publication

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 229
(f) Please refer to Confidential Attachment IPUC 229. Additionally, please refer
to the Company's response to IPUC Data Request 117 subpart(b) which
explains the conversion of"$/allowance" to a dispatch cost in $/MWh. Using
the conversion factor noted in the referenced response, the dispatch cost is
calculated in $/MWh units.
(g) Yes. The dispatch cost noted in the Company's response to IPUC Data
Request 117 is the same dispatch cost included in the net power costs (NPC)
modeling.
(h) Please refer to the Company's response to subpart(g) above.
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: Eshwar Vyakarna Raj shekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 230
IPUC Data Request 230
Please re-run Aurora model and provide updated work paper
"ID_GRC_2025_2023 Normalized Load.xlsm" and updated McCoy's work paper
"5.1 —NPC.xlsx" to reflect the result of each scenario below:
Scenario Modifications
1 • Remove the CCA allowance cost from the dispatch cost of the Chehalis plant
in the Aurora model;and
• Remove the post-modeling CCA costsz,which were calculated based on the
multiplication of Chehalis's generation amounts and the CCA allowance cost.
2 • Use the official forward price curve(OFPC)dated on June 28,2024,from
Response to Production Request No. 107 in the Aurora model;
• Remove the CCA allowance cost from the dispatch cost of the Chehalis plant
in the Aurora model;and
• Remove the post-modeling CCA costs,which were calculated based on the
multiplication of Chehalis's generation amounts and the CCA allowance cost.
3 • Use the OFPC dated on June 28,2024,from Response to Production Request
No. 107 in the Aurora model;
• Remove the CCA allowance cost from the dispatch cost of the Chehalis plant
in the Aurora model;
• Remove the post-modeling CCA costs,which were calculated based on the
multiplication of Chehalis's generation amounts and the CCA allowance cost.
• Production Request No. 184(e).
4 • Use the OFPC dated on June 28,2024,from Response to Production Request
No. 107 in the Aurora model;
• Remove the CCA allowance cost from the dispatch cost of the Chehalis plant
in the Aurora model;and
• Remove the post-modeling CCA costs,which were calculated based on the
multiplication of Chehalis's generation amounts and the CCA allowance cost.
• Production Request No. 185(f).
5 • Use the OFPC dated on June 28,2024,from Response to Production Request
No. 107 in the Aurora model;
• Remove the CCA allowance cost from the dispatch cost of the Chehalis plant
in the Aurora model;and
• Remove the post-modeling CCA costs,which were calculated based on the
multiplication of Chehalis's generation amounts and the CCA allowance cost.
9 Production Request No. 186.

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 230
Response to IPUC Data Request 230
The Company objects to this request as unduly burdensome, requesting the
creation of a new analysis or report, and not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving the foregoing objection, the
Company responds as follows:
For Scenario 1, the Company responds as follows:
The Company has not performed the requested analysis using the 2023
normalized load input assumptions. However, the Company did provide a
scenario wherein it removed the Washington Climate Commitment Act (CCA)
costs from the modeling under the 2025 forecast load assumptions and provided a
net power costs (NPC)report for this scenario. Please refer to the confidential
work papers supporting the direct testimony of Company witness, Ramon J
Mitchell, specifically confidential work paper"ID_GRC_2025_WA Cap and
Invest". The removal of the Washington CCA costs are on tab "NPC", row 282.
For Scenario 2 through Scenario 5, the Company responds as follows:
The Company has not created the requested new analysis.
Recordholder: Eshwar Vyakarna Rajshekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 231
IPUC Data Request 231
Please explain whether the Aurora model run in response to Production Request
No. 107 uses an updated gas price forecast and an updated electricity price
forecast, both of which came from the latest OFPC of June 28, 2024.
Response to IPUC Data Request 231
Referencing the Company's response to IPUC Data Request 107, the Company
responds as follows:
Correct. The Company used an updated gas price and electricity forecast, both of
which came from the most recent official forward price curve (OFPC); the June
28, 2024 OFPC.
Recordholder: Eshwar Vyakama Rajshekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 232
IPUC Data Request 232
Please explain whether the proposed Net Power Cost is determined based on the
expected resources in 2025, under the expected system conditions for 2025, and
against a 2023 weather-normalized load.
Response to IPUC Data Request 232
Correct. The proposed net power costs (NPC) in the current general rate case
(GRC)use input assumptions that are reflective of the Company's expectation of
system conditions in calendar year 2025 (inclusive of system resources) with a
load input of 2023 weather normalized load.
Recordholder: Eshwar Vyakarna Rajshekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 233
IPUC Data Request 233
Response to Production Request No. 108 states that Section"Historical Dollars vs
Indexed Dollars" and Section "Historical Dollars vs Indexed Dollars-Monthly
Average" on Tab "Adder Source" of the confidential file "Aurora GN Market
Prices CONF" show that"[t]he average price difference as seen in the above
referenced sections for sales transactions show that the Company transacted at
prices that were below market prices for sales of its electricity." Please respond to
the following:
(a) The two sections contain both positive and negative values, meaning the
Company transacted at prices that were both above and below market prices
for sales of its electricity. Please explain why the Company believes that these
two sections show the Company transacted at prices that were below market
prices for sales of its electricity.
(b) Please explain why the price difference is due to unavailable buyers, instead
of inaccurate forecasts and provide evidence supporting the explanation.
Response to IPUC Data Request 233
Referencing the Company's response to IPUC Data Request 108 and more
specifically the confidential work papers supporting the direct testimony of
Company witness, Ramon J. Mitchell, confidential file "Aurora GN Market Prices
CONF", tab "Adder Source", section "Historical Dollars vs Indexed Dollars",
rows 155:203, the Company responds as follows:
(a) The two sections show that the Company executed sales transactions
throughout the four-year history at prices that were below market prices on
average (emphasis added).
(b) The referenced data is historical data and therefore is not, in any manner,
derived from the Company's net power costs (NPC) forecasts. Regardless,
since the Company seeks to lower NPC whenever possible, if a market sale
transaction is executed below the market price index (i.e., there is a
difference) then it stands to reason that there were no buyers available to
purchase the energy at the market price index,because if there were, the
Company would have sold the energy at that higher price and further
decreased NPC.
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
September 11, 2024
IPUC Data Request 233
Recordholder: Eshwar Vyakarna Raj shekar Rao
Sponsor: Ramon Mitchell

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 234
IPUC Data Request 234
Please explain and reconcile the difference between the proposed WRAP fee in
2024 ($1,354,358) and the forecasted WRAP fee in 2024 ($9,774,000)included in
Attachment IPUC 112.
Response to IPUC Data Request 234
The Western Resource Adequacy Program (WRAP) fee outlined in the
Company's response to IPUC Data Request 112, specifically Attachment IPUC
112, shows the budget/forecast for the entire program, of which the Company is
one of 22 members. The portion of the WRAP fees which pertain to the Company
is calculated as explained below:
There are two portions of the fee, the (1) Base Cost fee, and the (2) Load Cost fee.
Base Cost Fee Calculation: The Base Cost fee is divided evenly between the 22
member entities. As shown in the graphic which makes up Attachment IPUC 112
and highlighted in the below screenshot, the Base Cost fee forecasted for the
"FY2024-2025"is $1,027,000. This amount is divided evenly between the 22
members of WRAP, therefore, the Company's portion of the Base Cost fee is
calculated by dividing $1,027,000 by 22. The Company's portion of the Base
Cost fee is therefore $46,682.
FY2024-2025*
Base Cost Load Cost
$2,478,000
$764,000
$263,000 $263,000
$4,353,000
$200,000
$400,000
$500,000
$553,000
$1,027,000 $8,747,000
$9,774,000
$46,700+$153'r
Load Cost Fee Calculation: The Load Cost fee is based on the Company's
portion of the load. Currently calculated as 14.95 percent. The total Load Cost fee
forecasted for the FY2024-2025 is $8,747,000, therefore, the Company's portion
of the Load Cost fee is calculated by multiplying $8,747,000 by 14.95 percent.
The Company's portion of the Load Cost fee is therefore $1,307,677.

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 234
Combining the Company's Base Cost fee portion ($46,682)with the Company's
Load Cost fee portion ($1,307,677) equals $1,354,358. This is the amount shown
on page 5.2.1 of Exhibit No. 48 in this general rate case (GRC)proceeding.
Recordholder: Benjamin Faulkinberry/Jeffrey Decker
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 235
IPUC Data Request 235
CONFIDENTIAL REQUEST - In reference to Response to Production Request
No. 61(e)—Confidential Attachment 61-5 for the Swift 1 Spillway Gate Bulkhead
Project the Contractor re uested the chan e order CO-PRMT for an increase of
Please ex lain wh
Also,please
provide work papers with the calculation of the increase and the basis used for the
increase.
Response to IPUC Data Request 235
The Company's project manager responsible for permitting on the Swift
Hydroelectric Project left the Company in October 2022. Given the complexity of
the permit package and the required timing, the work was outsourced to an
external contractor.
Please refer to the Company's response to IPUC Data Request 61, specifically
Confidential Attachment IPUC 61-5, which provides supporting work papers,
including the calculation of the increase and the basis used for the increase.
Recordholder: Peter Martins /Gary Tawwater
Sponsor: Will Shallenberger

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 236
IPUC Data Request 236
CONFIDENTIAL REQUEST - In reference to Response to Production Request
No. 61(a) - Confidential Attachment 61-1 for the Swift 1 S illwa Gate Bulkhead
Project lease reconcile the difference between the
budget shown in the
Confidential Attachment 6 1-1 and the $5,991,111 udget in Response to
Production Request No. 55 —Attachment 55-1.
Confidential Response to IPUC Data Request 236
The budget referenced in the Company's response to IPUC Data Re uest 61,
specifically Confidential Attachment IPUC 6 1-1, is
] and the budget amount
referenced in the Company's response to IPUC Data Request 55, specifically
Attachment IPUC 55-1, is $5,991,111. Confidential Attachment IPUC 61-1 is the
Company's project proposal document and excludes allowance for funds used
during construction (AFUDC) in the budget total. The budget amount in
Attachment IPUC 55-1 includes AFUDC as the total cost of the project going in-
service.
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: Peter Martins/Gary Tawwater
Sponsor: Will Shallenberger

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 237
IPUC Data Request 237
CONFIDENTIAL REQUEST -Please answer the following in reference to the
Swift 1 Spillway Gate Bulkhead Project:
(a) Please reconcile the difference between the
actua cost"sown WnReSponse to
Production Request No. 61 i and the total project cost of
with
Change Orders #6 from Response to Production Request No. 61 —
Confidential Attachment 61-5, and provide a cost breakdown by category (i.e.
Internal Labor, Contract Services, Capital Surcharge, AFUDC, etc.) of the
APR(Appropriation Request)budget and actual cost to explain the difference.
(b) Please reconcile the above costs with the $6,153,991 cost on Page 8.5.3,
Exhibit No. 48 of McCoy's Testimony.
Confidential Response to IPUC Data Request 237
(a) The actuals of
_ reflected in the Company's response to IPUC Data Request 61
subpart(f)(i) is the projected total cost of the project including capital
surcharge and allowance for funds used during construction AFUDC . The
in
Confidential Attachment IPUC 61-5 is the original requisition with the
primary construction vendor plus the associated change orders. This amount
excludes internal labor, employee expenses, third parry testing and inspection,
capital surcharge, and AFUDC.
(b) The $6,153,991 on Page 8.5.3 Exhibit No. 48 of McCoy's direct testimony
was the current forecast time at the time of the general rate case (GRC) filing
was prepared. The current increase in projected cost is due to higher debris
than anticipated requiring additional underwater debris removal by divers.
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: Peter Martins/Gary Tawwater
Sponsor: Will Shallenberger

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 238
IPUC Data Request 238
CONFIDENTIAL REQUEST -For the Culter Relicensin Pro*ect lease
reconcile the difference between the
budget in Response to Production Request No. 64
and the 8,446,875 cost in Exhibit No. 48, Page 8.5.3, of McCoy's Testimony.
Confidential Response to IPUC Data Request 238
The expenditure request ER for the Cutler Relicensing Project approved in 2019
a total of
The amount of$8,446,875 reflected in the Company's response to IPUC Data
Request 64 is the forecast at the time the general rate case (GRC)was prepared
and reflects inflationary pressures.
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: Todd Olson/Gary Tawwater
Sponsor: Will Shallenberger

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 239
IPUC Data Request 239
CONFIDENTIAL REQUEST - In reference to the IKL-Fall Creek Hatchery
Construction Project the total contract cost including change orders is
as
shown in Response to Production Request No. 65(e)-vi - Confidential Attachment
65-9. Please explain and reconcile that amount with the
actual cost for Contract
Services (including Removal, Materials & Supplies, Contingency) as shown in
Response to Production Request No. 65(F)-Confidential Attachment 65-10.
Please include work papers with a detailed breakdown to explain your answer.
Confidential Response to IPUC Data Request 239
The Company's response to IPUC Data Request 65 subpart(e)-vi, specifically
Confidential Attachment IPUC 65-9, provided the change orders specific to the
construction contractor implementing the Fall Creek Hatchery project. The
contract value including change orders under that contract is
as
stated. However, there are other contracts for design, engineering, construction
and safety oversight, communications equipment, and other miscellaneous
supplies and services required for the project that were included in Confidential
Attachment IPUC 65-10. Please refer to Confidential Attachment IPUC 239
which provides a summary of the other contract services. Note: Confidential
Attachment IPUC 239 reflects actual contract expenditures through June 30,
2024, therefore, the construction contract amounts reflect actuals, not total
contract value. Also, additional work under the construction contract is reflected
in the Company's response to IPUC Data Request 240.
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: Robert Roach
Sponsor: Tim Hemstreet

PAC-E-24-04/Rocky Mountain Power
September 11, 2024
IPUC Data Request 240
IPUC Data Request 240
In reference to Response to Production Request No. 65(f) - Confidential
Attachment 65-10 for the IKL-Fall Creek Hatchery Construction Project, please
clarify whether there will be actual costs incurred after July 1, 2024.
Response to IPUC Data Request 240
The project has achieved substantial completion, and actual costs continue to be
incurred as the project is finalized. The additional costs are erosion control and
access road improvements required to comply with permit requirements.
Recordholder: Robert Roach/Gary Tawwater
Sponsor: Tim Hemstreet