20240910PAC to Staff 58 - 2nd Supplemental Response (Redacted).pdf

RECEIVED
Tuesday, September 10, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 10, 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 5 (58-81)
Please find enclosed Rocky Mountain Power's 2nd Supplemental Response to IPUC 5t1i Set Data
Request 58. Provided via BOX is Confidential Attachment IPUC 58 2nd Supplemental and 2nd
Supplemental Confidential Response IPUC 58. 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 elo(&echohawk.com(C)
Lance Kaufman/IIPA lancekae.isg insi hg t.com(C)
Matthew Nykiel/ICL matthew.nykiel&amail.com
Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org
Thomas J. Budge/Bayer ti(&racineolson.com(C)
Brian C. Collins/Bayer bcollins(&consultbai.com
Greg Meyer/Bayer gmeyerkconsultbai.com
Kevin Higgins/Bayer khig gins kenergystrat.com(C)
Neal Townsend/Bayer ntownsendkenergystrat.com (C)
Ronald L. Williams/PIIC rwilliams(&hawleytroxell.com

Brandon Helgeson/PIIC bhelgeson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinskmwanalytics.com
Val Steiner/PIIC val.steiner(a-)itafos.com
Kyle Williams/PIIC williamsknasbyui.edu

PAC-E-24-04/Rocky Mountain Power
September 10, 2024
IPUC Data Request 58 —2nd Supplemental
IPUC Data Request 58
Please provide the following information for the Jim Bridger—U 1 Conversion to Natural
Gas project referenced on Page 8.5.3 Exhibit No. 48 of McCoy's Testimony. 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:
1. A copy of the RFP or RFQ that was submitted;
11. 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:
1. Initial project scope;
11. 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;
11. 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
VI. Contractor change orders.

PAC-E-24-04/Rocky Mountain Power
September 10, 2024
IPUC Data Request 58 —2nd Supplemental
(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. iv) Please explain any slips in schedule from the baseline construction
schedule.
2°d Supplemental Confidential Response to IPUC Data Request 58
Further to the Company's prior responses to IPUC Data Request 58 and referencing the
meeting held on August 28, 2024 between the Company and Idaho Public Utilities
Commission (IPUC) staff, the Company provides this 2nd Supplemental response to
address the difference between"single control" and "elevation control" as noted in
Babcock's bid in file "RFX 9091 -Highly Confidential - Completed Evaluation Matrix -
Gas Conversion Materials Supply Jim Bridger". The Company responds as follows:
Single Control uses one low-pressure control skid for the entire burner system, which
reduces flexibility since all burner elevations receive the same gas pressure.
Elevation Control provides a separate low-pressure control skid for each of the five
burner elevations, offering the potential for greater boiler control flexibility, but at a
higher cost.
The burner and low- ressure flow control desi n were bid to ether.

PAC-E-24-04/Rocky Mountain Power
September 10, 2024
IPUC Data Request 58 —2nd Supplemental
Please refer to
Confidential Attachmentii9oft"sidered
n es a co of above
referenced confidential m
highly
confidential and commercially sensitive. The Company requests special handling. Please
contact Mark Alder at(801) 220-2313 to make arrangements for review.
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: Ken Cutler
Sponsor: To Be Determined

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
CASE NO. PAC-E-24-04
IN THE MATTER OF THE )
APPLICATION OF ROCKY ) ATTORNEY'S CERTIFICATE
MOUNTAIN POWER FOR ) CLAIM OF CONFIDENTIALITY
AUTHORITY TO INCREASE ITS ) RELATING TO DISCOVERY
RATES AND CHARGES IN IDAHO ) RESPONSES
AND APPROVAL OF PROPOSED )
ELECTRIC SERVICE SCHEDULES )
AND REGULATIONS )
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 its second supplemental response to IPUC Data Request No. 58 contains Company
proprietary information that could be used to its commercial disadvantage.
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