20210827Staff 175-195 to PAC-Redacted.pdf

DAYN HARDIE (ISB No. 9917)
JOHN R. HAMMOND, JR. 0SB No. 5470)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
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' -i 411 4. I I'-I i'ii J'll
J, li;=
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomeys 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-8.2I-07
REDACTED SEVENTH
PRODUCTION REQUEST OF
THE COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the ldaho Public Utilities Commission, by and through its attomeys of
record, Dayn Hardie and John R. Hammond, Jr., Deputy Attorneys General, request that Rocky
Mountain Power ("Company") provide the following documents and information as soon as
possible, but no later than FRIDAY, SEPTEMBER 3, 2021.r
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
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER I
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AUGUST 27,2021
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
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. 175: Please provide the workpapers for adjustment 7.6 in Witness
McDougal's testimony.
REQUEST NO. 176: As a follow-up to the response to IPUC Production Request
No. 119, please provide a description of the Balancing Authority Services Agreement with
Western Area Power Administration ("WAPA") executed in March 2021. Please provide the
Normalization Adjustment for the Test Period (pro forma adjustment) for this WAPA contract
REQUEST NO. 177: Describe the Company's criteria for determining when a customer
should pay for a line extension to serve its load versus it being recovered as a system cost.
Please explain how the criteria applies to different size customers and different amounts of
capacity of the line extension infrastructure (e.g. primary distribution, secondary distribution, or
transmission) needed to serve the customer's load.
REQUEST NO. 178: Describe the Company's criteria for determining when a
transmission line should be situs assigned. Please include in the explanation how cost causation
is factored into the Company's criteria.
REQUEST NO. 179: Does the Company have any lines at transmission voltages that
are currently situs assigned rather than system allocated? If so, please explain why these lines
are situs assigned.
REQUEST NO. 180: Provide the Company's method, guidelines, and/or procedures for
calculating the amount of Contributions in Aid of Construction ("CIAC") to be charged to the
customer, developer, or entity requesting the work for transmission capital costs. How is the
amount allocated between CIAC and capital costs attributed to network upgrades?
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 AUGUST 27,2021
REQUEST NO. 181: For capital project
Please provide the following information with all workpapers in Excel format
with formulas enabled
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3
a. If the customer,did not request service, would the project be
needed? Please explain.
b. Please explain how Idaho customers other than I benefit from this project.
c. Please provide a breakdown in Megawatts ("MW") of the total capacity of the
project by: the amount of transfer capacity needed Uy I the amount of
capacity needed by current customers connected to the project, the amount of
capacity projected for future customers, and the amount of capacity needed to
support the Company's system.
d. Please provide a breakdown by the sources ofrevenue projected to recover the
cost of the transmission line between (1) I (2) Wheeling Revenue, and (3)
the Company's native load customers, excludirg I
e. Please provide the criteria describing how the Company separated the costs to be
paid by I through the CIAC versus costs included as network upgrades.
f. Please provide a breakdown of the total project cost by the major pieces of
equipment/ffiastructure included in the CIAC versus the
equipmenVinfrastructure included as network upgrades. In the breakdown,
describe the different pieces of equipment/infrastructure, an explanation
describing why the cost was included as part of the CIAC or as a system upgrade,
and the amount of cost for each piece of equipment/infrastructure.
g. Please explain why the costs of the project (not including the cost of the CIAC)
are system assigned and not situs assigned.
h. In file the
Company indicates that
Please provide evidence that the customer has made a
commitment to add the loads indicated before 2022.
Please explain why network upgrades are included within the project cost.
Specifically, did the Company identifu a need for the project to benefit the system
AUGUST 27,2021
before the customer requested the line extension. If so, please provide the cost
estimate for the upgrades before the customer's request for the line extension.
j. Please provide a breakdown of the incremental costs needed to compress the
construction schedule. Please include a description of the costs and the amounts.
k. Were costs attributed to the compressed schedule recovered through the CIAC? If
not, please explain why not.
REQUEST NO. 182: Please provide the Company's policy, guidelines, and/or
procedures for protecting transmission lines and substation facilities from forest/wildfire.
REQUEST NO. 183: For capital project
I, please provide the following:
a. Does the Company have insurance to cover this loss? If not, please explain why
not.
b. If the Company has insurance for this loss, did the Company file a claim? If not,
please explain why not.
c. Please explain why ratepayers outside the state/jurisdiction where the fire
occurred should pay for costs to repair the damaged facilities caused by the fire.
d. Please provide a transmission/distribution map showing the Company's facilities
affected by the fire. Please detail and label the damaged facilities specific to
transmission and separately distribution.
e. Please explain whether there are any transmission line segments affected by this
fire that supply electricity at transmission level voltages to customers from a
single flow direction (i.e. a radial transmission line)? If so, please explain
whether the Company is seeking recovery of those costs, from ratepayers outside
of the state/jurisdiction affected by the fire.
f. Please explain how distribution costs for the project arelwill be recovered by the
Company.
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 27,2021
REQUEST NO. 184: For capital project
I, please provide the following:
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5
a. Does the Company have insurance to cover this loss? If not, why not, please
explain.
b. If the Company has insurance for this loss, did the Company file a claim? If not,
please explain why not.
c. Please explain why ratepayers outside the state/jurisdiction where the fire
occurred should pay for costs to repair the damaged facilities caused by the fire.
d. Please provide a transmission/distribution map showing the Company's facilities
affected by the fire. Please detail and label the damaged facilities specific to
transmission and separately distribution.
e. Please explain whether there are any transmission line segments affected by this
fire that supply electricity at transmission level voltages to customers from a
single flow direction (i.e. a radial transmission line)? If so, please explain
whether the Company is seeking recovery of those costs, from ratepayers outside
of the state/jurisdiction affected by the fire.
REQUEST NO. 185: For capital project
please provide the following:
a. Does the Company have insurance to cover this loss? If not, please explain why
not.
b. If the Company has insurance for this loss, did the Company file a claim? If not,
please explain why not.
c. Please explain why ratepayers outside the state/jurisdiction where the fire
occurred should pay for costs to repair the damaged facilities caused by the fire.
d. Please provide a transmission/distribution map showing the Company's facilities
affected by the fire. Please detail and label the damaged facilities specific to
transmission and separately distribution.
e. Please explain whether there are any transmission line segments affected by this
fire that supply electricity at transmission level voltages to customers from a
single flow direction (i.e. a radial transmission line)? If so, please explain
AUGUST 27,2021
whether the Company is seeking recovery of those costs, from ratepayers outside
of the state/jurisdiction affected by the fire.
REQUEST NO. 186: Please provide the following documentation for
submitted in response to IPUC Production Request
No. 48. If any of the information requested below cannot be provided--or is not available-
please explain why and explain how the Company assured the construction of the project was
completed at least cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposedschedule.
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. Constructioncontract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
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.
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOI-INTAIN POWER 6 AUGUST 27,2021
iii. Baseline schedule-to-actual schedule comparison.
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. 187: Please provide the following documentation
submitted in response to IPUC Production Request No. 48.
If any of the information requested below cannot be provided or is not available, please explain
why and explain how the Company assured the construction of the project was completed at least
cost.
a. Please provide justification and evidence why the project should be system
assigned rather than situs assigned to Utah. Specifically, please provide evidence
that the transmission line provides benefits to the overall system.
b. Analysis of Need - a justification of need for the project and a cost/benefit
analysis comparing alternatives.
c. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
d. Requests for proposals ("RFP";
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
e. Project construction documentation including:
i. Constructioncontract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 AUGUST 27,2021
vii. Action items list(s).
viii. Contractors change order request(s).
f. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison.
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. 188: Please provide the following documentation for
submitted in response to IPUC Production Request No
48. If any of the information requested below cannot be provided or is not available, please
explain why and explain how the Company assured the construction of the project was
completed at least cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposedschedule.
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.
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 AUGUST 27,2021
v. Baseline Schedule.
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 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.
R-EQUEST NO. 189: Please provide the following documentation for
submiued in response to IPUC Production Request No. 48. If
any of the information requested below cannot be provided or is not available, please explain
why and explain how the Company assured the construction of the project was completed at least
cost.
a. Analysis of Need - a justification of need for the 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.
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 9 AUGUST 27,2021
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
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. Baseline schedule-to-actual schedule comparison.
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. 190: Please provide the following documentation for
submitted in response to IPUC Production Request No. 48. If any of the
information requested below cannot be provided or is not available, please explain why and
explain how the Company assured the construction of the project was completed at least cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposedschedule.
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.
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 10 AUGUST 27,2021
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
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. Baseline schedule-to-actual schedule comparison.
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. 191: Please provide the following documentation for
submitted in response to IPUC
Production Request No. 48. If any of the information requested below cannot be provided or is
not available, please explain why and explain how the Company assured the construction of the
project was completed at least cost.
a. Analysis of Need - a justification of need for the 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.
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER 11 AUGUST 27,2021
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).
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 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. 192: Please provide the following documentation for
submitted in response to IPUC Production Request No. 48. If any of
the information requested below cannot be provided or is not available, please explain why and
explain how the Company assured the construction of the project was completed at least cost.
a. Analysis of Need - a justification of need for the 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.
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 12 AUGUST 27,2021
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).
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 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. 193: Please provide the following documentation for
submitted in response to IPUC Production
Request No. 48. If any of the information requested below cannot be provided or is not
available, please explain why and explain how the Company assured the construction of the
project was completed at least cost.
a. Analysis of Need - a justification of need for the 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.
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER 13 AUGUST 27,2021
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.
vi. Monthly project status report(s).
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. Baseline schedule-to-actual schedule comparison.
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. 194: Please provide the following documentation for
submitted in response to IPUC Production Request
No. 48. If any of the information requested below cannot be provided or is not available, please
explain why and explain how the Company assured the construction of the project was
completed at least cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit
analysi s comparing alternatives.
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposedschedule.
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 14 AUGUST 27,2021
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).
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. Baseline schedule-to-actual schedule comparison.
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. 195: For all substation project investments included in this case for
recovery, please provide a breakdown of each project and the associated investment amounts by
the cost of infrastructure needed to connect and transfer power between two or more
transmission lines versus the cost of any infrastructure needed to transfer power from the
transmission system to the distribution system of a local load area. Please include the
jurisdiction(s) the project and the distribution area supports.
REDACTED SEVENTH PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER 15 AUGUST 27,2021
DATED at Boise,Idaho, *r2Jbu*of August 2021.
Dayn
Doputy Attorney General
i:umiso:ptodroq/paoo?I.7.dhmhjt prod req 7
REDACTED SEVENTH PRODUCTI ]\I REQUEST
TO ROCKY MOIJNTAIN POWER 16 AUGUST 27,2CI21
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27fi DAY OF AUGUST 2021,
SERVED THE FOREGOING REDACTED SEVENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO ROCKY MOIJNTAIN 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: [e-mail]
idahodockets@.pac i fi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@paci fi corp.com
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
BRIAN C COLLINS
MAURICE BRUBAKER
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD #I4O
CHESTERFIELD MO 63017
E-MAIL : [e-mail]
mbrubaker@.consultbai.com
LANCE KAUFMAN
AEGIS INSIGHT
E-MAIL: [e-mail]
EMILY L WEGENER
MATTHEW D McVEE
ROCKY MOI.'NTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I16
E-MAIL : emi [e-mail]
m atth ew. mc vee @ pac i ficorp. c om
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: elo@.echohawk.com
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON
PO BOX l39l
POCATELLO ID 83204
E-MAIL: randy @racineolson.com
[e-mail]
JAMES R SMITH
MIKE VEILE
BAYER CORPORATION
E-MAIL: [e-mail]
[e-mail]
KEVIN HIGGINS
COURTNEY HIGGINS
MILLI PICHARO
NEAL TOWNSEND
ENERGY STRATEGTES
E-MAIL: [e-mail]
chiq [e-mail]
mpichardo@energy strat.com
ntownsend@energy strat.com
CERTIFICATE OF SERVICE
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-MAIL : [e-mail]
ADAM GARDNER
IDAHOAN FOODS
E-MAIL: [e-mail]
VAL STEINER
ITAFOS CONDA LLC
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N ITTH ST
BOISE ID 83702
E-MAIL : [e-mail]
BRADLEY G MULLINS
MW ANALYTICS ENERGY
E-MAIL: [e-mail]
KYLE WILLIAMS
BYU IDAHO
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
""ld /L2r-r<
SECRETAFIY--
CERTIFICATE OF SERVICE