20241009PAC to Staff 203 - 1st Supplemental.pdf

RECEIVED
Wednesday, October 09, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 9, 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 10 (175-204)
Please find enclosed Rocky Mountain Power's I"Supplemental Response to IPUC I Oth Set Data
Request 203. Provided via BOX is Confidential Attachment IPUC 203 1"Supplemental.
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(801) 220-2313.
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
October 9, 2024
IPUC Data Request 203 — l'Supplemental
IPUC Data Request 203
Please provide the following information for the W-1799 EV 2020 WIND LTSA
CY2023 for a total amount of$ 6,261,110 as referenced in Company's Response
to Production Request No. 15. Please include any available workpapers with
formula 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) 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.
(d) 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 was approved at
the appropriate level.
(e) Please provide the following for the Baseline Construction Project Plan
including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by the WBS;
iii. Baseline project schedule broken down by the 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

PAC-E-24-04/Rocky Mountain Power
October 9, 2024
IPUC Data Request 203 — l'Supplemental
vi. Contractor change orders.
(f) Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS
and by year;
ii. Baseline construction schedule-to-actual comparison by the 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. Please explain any slips in schedule from the baseline construction
schedule.
Vt Supplemental Response to IPUC Data Request 203
Further to the Company's response to IPUC Data Request 203 dated August 29,
2024, the Company provides the following additional information:
(a) The Company pays for long-term service quarterly and the costs are recorded
internally as operation and maintenance, and administrative and general
(OMAG) and capital prepaids. OMAG prepaids are amortized over the
invoice period. The capital prepaids are amortized to construction work-in-
progress (CWIP) based on work performed under the contract. There are no
incremental costs or cash outlays for the capitalized costs, only a
reclassification of costs on the balance sheet from capital prepaid to CWIP.
The service providers provide detailed monthly reports for each plant that
identifies the work performed and hours associated with each turbine. The
Company distinguishes the work between OMAG and capital according to the
Company's capitalization policy. The capital work is matched to the
Company's property retirement unit (PRU) catalog and journal entries are
booked quarterly to reflect the capital costs in CWIP. No additional
accounting action is taken on the OMAG portion of the work as the Company
has already reflected the OMAG prepaid amortization for the quarter.
Approval of the long-term service agreements (LTSA)was provided in the
Company's original response to IPUC Data Request 203. Please refer to
Confidential Attachment IPUC 203 1st Supplemental which provides the
internal memo documenting the treatment of these service contracts and a
journal entry using the parts lists received from the service provider.
(b) All Company wind facilities are serviced by the original equipment
manufacturers (OEM) and the respective long-term service and maintenance
contracts are industry standard contracts. Please refer to Confidential

PAC-E-24-04/Rocky Mountain Power
October 9, 2024
IPUC Data Request 203 — 1st Supplemental
Attachment IPUC 203 1st Supplemental which provides copies of the
Delegation of Authority and authorization for each long-term service
agreement.
(c) Where applicable, Turbine Supply Agreements (TSA)were selected through a
competitive request for proposals (RFP)process and the LTSAs were a
component of those processes. In the case of certain wind repowering projects
in which only the OEMs could provide repowering solutions, LTSAs were
negotiated as part of the respective TSA or master retrofit contract.
(d) The Company has no detailed project budget or separate project plan approval
as there are no incremental or additional costs being expended for this work
covered under the LTSA. The construction costs are capitalization of costs
already incurred under the approved LTSA contracts. The Company is
allocating the approved contracts costs between OMAG and capital.
(e) The Company has no baseline construction project plan as the maintenance
tasks and construction costs are included in the service contract. All work is
performed in accordance with the LTSA scope and OEM requirements,
including maintenance schedule. There are no change orders associated with
the LTSAs. The status reports requested would be the parts lists received from
the supplier for work performed on each turbine each month. Please refer to
Confidential Attachment IPUC 203 1st Supplemental.
(f) As stated in the Company's responses to subparts (a) and (e) above, the actual
construction costs are derived from the parts lists received from the service
provider for work completed (O&M and capital)under the terms of the
service contract. These construction costs are included in the terms of the
contract and not incremental expenditures. The costs are reclassified quarterly
from the capital prepaid account to CWIP. There is no baseline construction
project plan to compare the costs to as work was completed in accordance
with the service contract.
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: Gary Tawwater
Sponsor: Tim Hemstreet/Will Shallenberger

Joe Dallas (ISB# 1033)
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-24-05
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER ) ATTORNEY'S CERTIFICATE
APPROVAL OF POWER COST ) CLAIM OF CONFIDENTIALITY
DEFERRAL OF $62.4 MILLION ECAM ) RELATING TO DISCOVERY
DEFERRAL ) 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 first supplemental response to IPUC Data Request No. 203 contain
Company proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in that the information contains Company proprietary information.
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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 9th day of October, 2024.
Respectfully submitted,
s
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
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