20210701Staff 35-49 to PAC.pdf

DAYN HARDIE (lSB No. 9917)
MATT HUNTER (ISB No. 10665)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE STATE OF
IDAHO
CASE NO. PAC-E-21.07
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie and Matt Hunter, Deputy Attorneys General, request that Rocky Mountain
Power ("Company") provide the following documents and information as soon as possible, but
no later than THURSDAY, JULY 22,2021.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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1 ruLY t,2021
In addition to the written copies provided as response to the requests, please provide all
EXCEL spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO.35: Please describe the Company's method(s) for developing,
managing, executing, and completing Capital Projects in a least-cost manner. Please provide a
copy of all Company policies and procedures documenting this method.
REQUEST NO. 36: Please describe the methods used at the Crais Generating Station to
ensure capital investment projects were completed in a least-cost manner. Please include any
plant specific guidelines and procedures documenting these methods.
REQUEST NO.37: Please provide all documentation for plant investments made at the
Crais Generatine Station since 2013, between the Company and its operating partner showing
how the Company was engaged with its operating partner to minimize plant investment costs.
Please include any documentation justifuing the need for an upgrade, documentation questioning
the need for an upgrade, and any analysis comparing the cost and benefits of other altematives
considered.
REQUEST NO.38: Please list every Craie Generating Station capital project with a
budget of $250,000 or more completed since 2013, that used internal resources (intemal defined
as any ownership partner) instead of an outside contractor. For each capital project listed, please
explain why intemal resources were used instead of an outside contractor.
REQUEST NO.39: Please describe the methods used at the Colstrip Power Plant to
ensure capital investment projects were completed in a least-cost manner. Please include any
plant specific guidelines and procedures documenting these methods.
REQUEST NO. 40: Please provide all documentation for plant investments made at the
Colstrip Power Plant since 2013, between the Company and its operating partner showing how
the Company was engaged with its operating partner to minimize plant investment costs. Please
include any documentation justifuing the need for an upgrade, documentation questioning the
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 ruLY 1,2021
need for an upgrade, and any analysis comparing the cost and benefits of other alternatives
considered.
REQUEST NO. 4l: Please list every Colstrip Power Plant capital project with a budget
of $250,000 or more completed since 2013, that used internal resources (internal defined as any
ownership partner) instead of an outside contractor. For each capital project listed, please
explain why internal resources were used instead of an outside contractor.
REQUEST NO. 42: Please describe the methods used at the Hayden Power Plant to
ensure capital investment projects were completed in a least-cost manner. Please include any
plant specific guidelines and procedures documenting these methods.
REQUEST NO. 43: Please provide all documentation for plant investments made at the
Hayden Power Plant since 2013 , between the Company and its operating partner showing how
the Company was engaged with its operating partner to minimize plant investment costs. Please
include any documentation justifuing the need for an upgrade, documentation questioning the
need for an upgrade, and any analysis comparing the cost and benefits of other alternatives
considered.
REQUEST NO.44: Please list every Hayden Power Plant capital project with a budget
of $250,000 or more completed since 2013, that used internal resources (internal defined as any
ownership partner) instead of an outside contractor. For each capital project listed, please
explain why internal resources were used instead of an outside contractor.
REQUEST NO. 45: Please describe the methods used at the Hermiston Generatinq
Plant to ensure capital investment projects were completed in a least-cost manner. Please
include any plant specific guidelines and procedures documenting these methods.
REQUEST NO. 46: Please provide all documentation for plant investments made at the
Hermiston Generating Plant since 2013, between the Company and its operating partner showing
how the Company was engaged with its operating partner to minimize plant investment costs.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J ruLY 1,2021
Please include any documentation justiffing the need for an upgrade, documentation questioning
the need for an upgrade, and any analysis comparing the cost and benefits of other altematives
considered.
REQUEST NO. 47: Please list every Hermiston Generating Plant capital project with a
budget of $250,000 or more completed since 2013 that used internal resources (intemal defined
as any ownership partner) instead of an outside contractor. For each of capital project listed,
please explain why intemal resources were used instead of an outside contractor.
REQUEST NO. 48: Please provide the following documentation for each electric
generating plant capital project with a budget of $1,000,000 or more completed since 2013
(where requested information has not been provided, please explain why it was not provided and
how the Company assured the construction of the project was completed at least cost):
a. Analysis of Need - a justification of need for each project and a cost/benefit
analysis comparing alternatives.
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals ("RFP")
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
SECOND PRODUCTION REQUEST
TO ROCKY MOI.TNTAIN POWER 4 ruLY t,2021
vii. Action items list(s).
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baselineschedule-to-actualschedulecomparison.
iv. For any actual costs differing from the budget amount by plus or minus
five percent during a particular year please list and explain the reason(s)
for the budget amount difference.
REQUEST NO. 49: Please provide the following documentation for each transmission
or distribution project with a budget of $1,000,000 or more completed since 2013 (where
requested information has not been provided, please explain why it was not provided and how
the Company assured the construction of the project was completed at least cost):
a. Analysis of Need - a justification of need for each project and a cost/benefit
analysis comparison of alternatives.
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. RFP
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizationalchart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
SECOND PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER 5 ruLY t,2021
vi. Monthly project status report(s).
vii. Action items list(s).
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons leamed.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs dif[ering from the budget amount by plus or minus 5
percent during a particular year please list and explain the reason(s) for the
budget amount difference.
DATED at Boise, Idaho, this day of July 2021
AtrJ.{
Deputy Attorney General
i:umisc:prodreq/pace2 l.Tdhmhjt prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 ruLY 1,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I't DAY OF ruLY 2021, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF TITE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-21-07, BY
E.MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.rveston@pacifi corp.cont
idahodockets@ pac i tjcorp.corn
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@ pac ifi corp.com
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
BRIAN C COLLINS
MAURICE BRUBAKER
BRUBAKER & ASSOCIATES
I6690 SWINGLEY RIDGE RD #140
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
nr brubaker@consu ltbai.com
BRADLEY G MULLINS
MW ANALYTICS ENERGY
E-MAIL: [e-mail]
KYLE WILLIAMS
BYU IDAHO
E-MAIL: wi I [e-mail]
EMILY L WEGENER
MATTHEW D McVEE
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL : ern i l.v.wegener@pac ifi corp.conr
rnatthew. mcvee@pacifi corp.corn
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6l 19
POCATELLO ID 83205
E-MAIL: [e-mail]
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON
PO BOX 1391
POCATELLO ID 83204
E-MAIL: rand.v-@rac ineol son.com
[e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-MAIL: ron@willian, sbradbury.com
ADAM GARDNER
IDAHOAN FOODS
E-MAIL: [e-mail]
VAL STETNER
ITAFOS CONDA LLC
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE