20240926Reply Comments.pdf

RECEIVED
Thursday, September 26, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
September 26, 2024
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
RE: CASE NO. PAC-E-24-09
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
REQUESTING APPROVAL OF 2024 IDAHO WILDFIRE MITIGATION PLAN
Attention: Commission Secretary
Pursuant to Commission Order No. 36275 providing public notice of the Company's Application,
authorizing the processing of the Application by Modified Procedure, and establishing the
procedural schedule please find Rocky Mountain Power's Reply Comments in the above
referenced matter.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313.
Very truly yours,
9k--)a1--D
Joe Steward
Senior Vice President, Regulation and Customer& Community Solutions

Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email:joseph.dallaskpacificorp.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. PAC-E-24-09
OF ROCKY MOUNTAIN POWER )
REQUESTING APPROVAL OF THE 2024 )REPLY COMMENTS OF
IDAHO WILDFIRE MITIGATION PLAN )ROCKY MOUNTAIN POWER
I. INTRODUCTION
1. Pursuant to Idaho Code § 61-626 and Rule 331 of the Rules of Procedure of the
Idaho Public Utilities Commission (the "Commission"), Rocky Mountain Power, a division of
PacifiCorp (the "Company"), hereby submits its reply comments ("Reply Comments"), pursuant
to Order No. 36275 issued by the Commission in this proceeding on July 25, 2024. The Company
respectfully requests the Commission issue an order approving its 2024-26 Idaho Wildfire
Mitigation Plan ("2024 WMP").
II. BACKGROUND
2. On December 29, 2023, the Commission issued an order approving the deferral of
Idaho's allocated incremental liability insurance premiums that exceed the amount already in base
rates. Order No. 36045 required the Company to submit as a separate filing a final copy of its
wildfire mitigation plan for Idaho within 30 days of its completion but no later than April 15,2024.
On April 15,2024,the Company submitted its 2024 WMP in compliance with the Order No. 36045
in Case No. PAC-E-23-18. On June 7, 2024 the Company submitted an application requesting
Rocky Mountain Power's Reply Comments Page 1

approval of its 2024 WMP. On September 12, 2024, Commission Staff submitted comments on
the Company's 2024 WMP. The Company submits these reply comments in response to the
comments submitted by Staff.
III. REPLY COMMENTS
3. Staff, in their comments,recommended that the Commission acknowledge the 2024 WMP.
The Company appreciates Staff's review of the 2024 and agrees with this recommendation. In
addition to acknowledgment of the 2024 WMP, Staff had several recommendations.The pages that
follow address each of Staff's recommendations:
A.WMP Modeling and Least-Cost Least-Risk
4. Staff recommends the Commission order the Company to develop a least-cost least-risk
analysis to evaluate its wildfire mitigation projects such as undergrounding lines, covered
conductor, etc. PacifiCorp agrees with the underlying objective and is currently developing a risk
spend efficiency ("RSE") framework to provide objective guidelines for such an analysis.
PacifiCorp plans to use RSE in its future Wildfire Mitigation Plans in Idaho. The specific
calculations to determine risk reduction effectiveness are in development based on inputs from
PacifiCorp subject matter experts, benchmarking with other utilities, and technical planning with
Technosylva, the company which provides software and other support for PacifiCorp's wildfire
risk analysis.PacifiCorp plans to provide additional information on its risk reduction effectiveness
calculations in its next wildfire mitigation plan following completion of the RSE framework
evaluation.
5. Staff recommends the Company be required to provide an analysis and a comparison of
alternatives it considered for each project or program when recovery of costs are requested. The
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Company is not opposed to providing supporting documentation for wildfire mitigation projects
when recovery of cost are requested, likely in a future rate case. However, to hold each wildfire
mitigation project up to a heightened standard of prudency, as suggested by Staff, creates an
unnecessary regulatory burden for the Company.
6. As mentioned above, the Company is developing a RSE framework, but this is the
Company's first WMP in Idaho and the Company must prioritize areas of concern. In addition to
Idaho, the Company operates in five other states with thousands of line miles across its territory.
To provide an analysis for each project is not practical. In order to help with prioritizing the line
segments for system hardening, the Company reviews the terrain and wind event risk scores as
described in the Idaho WMR1 The priority of system hardening line rebuild projects or advanced
system protection and control projects are focused on areas within the Fire High Consequence
Area("FHCA")and on circuits with a higher overall terrain or wind risk score. System Operations
projects and Field Operations and Work Practices such as the installation of new relays, use of
Enhanced Safety Settings ("ESS"), and installation of fault indicators could be prioritized based
on the situational awareness data inputs. The data inputs could be related to the real time weather
and risk modeling as described in Section Five: `Situational Awareness' of the 2024 WMP. The
Company is continuing to look at the best methods for evaluating wildfire mitigation projects but
believes it would be premature to impose additional prudency requirements on the Company at
this time.
B. Cadence of Filings
7. Staff has several recommendations for the Company regarding the cadence of WMP filings.
Staff recommends: 1) the Company create a rolling 5 year WMP, which should also include cost
' See Section One: `Baseline Risk Analysis' of the 2024 WMP
Rocky Mountain Power's Reply Comments Page 3

forecasts that display previous year's budget to actual expenses; 2) file a copy of version changes
to the WMP with the Commission when they occur, at least every 2 years, for the Commission
records; and 3) conduct semi-annual (pre-fire season and post-fire season) wildfire updates with
the Commission.
8. Rocky Mountain Power regularly evaluates each wildfire mitigation plan across its
six-state service territory and does not object to regularly updating the Idaho plan and providing
updates to the commission on a regular basis,however the Company has several recommendations.
i. Rolling 5-Year WMP
9. While RMP understands the value of a long-term perspective,it is important to note
that WMP in Idaho is new. The WMP for Idaho is still evolving, and the landscape at the end of
five years could look vastly different. To adapt to these changes, the Company recommends a
three-year cadence for the Idaho WMP, with a corresponding three-year planning horizon. This
more frequent triennial filing schedule will allow the Company to incorporate both small and
significant updates, ensuring the plan remains relevant, adaptable, and effective. Rocky Mountain
Power is already updating its Utah and Wyoming WMP on a triennial filing schedule. Aligning
Idaho to that schedule will ensure that the same changes for the other states are captured in Idaho's
WMP.
ii. Filing Version Changes with the Commission
10. As the Company plans to establish its WMP with a three-year perspective, the
requirement for filings with the Commission more frequently than three years is not necessary.
Adopting a triennial filing schedule will allow the Company to provide updates only when
significant updates to Idaho's WMP have been made and avoid unnecessary filings that may not
be the best use of Commission, stakeholder, or Company resources.
Rocky Mountain Power's Reply Comments Page 4

Mr. Semi-Annual Wildfire Updates
11. The Company believes that updates twice a year or even once a year is not currently
warranted due to no FHCA areas currently being identified within the Company's Idaho service
territory and no Public Safety Power Shutoff("PSPS") events to date. However, if future models
indicate the emergence of FHCA areas in Idaho, or an increase in PSPS events, the Company is
open to transitioning to annual updates, should the Commission deem it necessary. Until an FHCA
area is identified, RMP believes that the triennial WMP filing, which will include updates on the
status of WMP in Idaho, will adequately address any wildfire updates required for Idaho's plan.
C. Potential Backup Power Program and Labor Forecast
12. The Company agrees with Staff's recommendation to seek approval from the
Commission before expanding a backup power rebate program into Idaho. In addition, Staff
recommends the Commission order the Company to include a line item in the cost forecast for
internal labor of the wildfire safety department. The Company is not opposed to providing wildfire
safety internal labor costs but does not break down the Wildfire Safety Department into line item
details. The below table shows the cost of the Wildfire Safety Department for 2024, 2025, and
2026. The table only represents Idaho's share of the costs.
Table 1: Idaho Wildfire S fety Internal Labor Cost
Actuals Jan-Au 2024 $ 11,500
Forecasted 2024 $ 23,000
Projected 2025 $ 121,333
Projected 2026 $ 126,187
Rocky Mountain Power's Reply Comments Page 5

D. Additional Staff Recommendations
i. Risk Models
13. Staff is concerned about overlapping modeling methods that could result in
unnecessary costs. The Company is not opposed to exploring cost-saving opportunities while
monitoring potential FHCA areas in Idaho. However, the FireSight model and the Company's
meteorology models serve different functions. The FireSight model is used to identify high-risk
circuits where certain vegetation management strategies and system hardening projects are
implemented,as described in the WMP. The Company's meteorology group uses a different model
to provide a daily forecast based on real-time data to determine the current short-term fire potential.
Forecasts are used to help guide operations during periods of elevated risk. While a short-term
forecast by meteorology may trigger additional vegetation work, this type of targeted activity is
distinct from the program level strategies which are guided by the FireSight modelling tool.
ii. Industry Collaboration
14. Staff has raised concerns about costs for industry collaboration. Rocky Mountain
Power is committed to maintaining collaboration with other industry groups, which is crucial for
staying up to date with the latest advancements and best practices. This collaboration ultimately
benefits our operations and,by extension, our customers. Rocky Mountain Power will continue to
seek a balance between cost-efficiency and the valuable insights gained through these
collaboration efforts.
iii. PSPS and Wildfire Systems Operations Procedure ("SOP")
15. Finally, Staff notes that they will work with the Company on establishing proper
communication with the Commission in the event of a potential PSPS. The Company currently
Rocky Mountain Power's Reply Comments Page 6

has procedures in place for communicating emergencies and power outages to the Commission
and agrees that a similar procedure for PSPS and Wildfire SOP would be beneficial and will work
with Staff to establish this procedure.
IV. CONCLUSION
16. Rocky Mountain Power respectfully requests that the Commission issue an order
approving the 2024 WMP.
DATED this 26th day of September, 2024
Respectfully submitted,
ROCKY MOUNTAIN POWER
z
c .
Joe Dallas (ISB# 10330)
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: Joseph.dallasgl2acificor2.com
Attorney for Rocky Mountain Power
Rocky Mountain Power's Reply Comments Page 7