20210910PAC to Staff 175-195.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 10, 2021
Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C)
RE: ID PAC-E-21-07
IPUC Set 7 (175-195)
Please find enclosed Rocky Mountain Power’s Responses to IPUC 7th Set Data Requests 176, 178-179, 182, 186-187, and 195. The remaining response will be provided under separate cover.Provided via e-mail is non-confidential Attachment IPUC 182 and provided via encryption andBOX is the Confidential Attachment 186-2 and Confidential Responses IPUC 186-187.
Voluminous Attachment IPUC 186-1 and Voluminous Confidential Attachment IPUC 187 areonly provided via BOX. Confidential information is provided subject to protected under IDAPA31.01.01.067 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 any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
____/s/____ J.Ted WestonManager, Regulation
Enclosures C.c.: Ronald L. Williams/PIIC [e-mail] G. Mullins/PIIC [e-mail] Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W) Eric L. Olsen/IIPA [e-mail] (C) Anthony Yankel/IIPA [e-mail] (C) Randall C. Budge/Bayer [e-mail] (C) Thomas J. Budge/Bayer [e-mail] (W)(C) Brian C. Collins/Bayer [e-mail] (W)(C) Maurice Brubaker/Bayer [e-mail] (C)
RECEIVED
2021 SEP 10 PM 4:59
IDAHO PUBLIC
UTILITIES COMMISSION
Kevin Higgins/Bayer [e-mail] (C) Lance Kaufman/Bayer [e-mail] (C) James R. Smith/Bayer [e-mail] (C) Brad Purdy [e-mail] (C)
Ben Otto/ICL [e-mail] (C)

PAC-E-21-07 / Rocky Mountain Power September 10, 2021 IPUC Data Request 176
IPUC Data Request 176 As a follow-up to the response to IPUC Production Request No. 119:
(a) Please provide a description of the Balancing Authority Services Agreement
with Western Area Power Administration (WAPA) executed in March 2021. (b) Please provide the Normalization Adjustment for the Test Period (pro-forma
adjustment) for this WAPA contract.
Response to IPUC Data Request 176
(a) The Balancing Area Services Agreement (BASA) is the overarching agreement for Western Area Power Administration (WAPA) to provide all ancillary services to its customers with loads and/or resources within its balancing authority area (BAA). This includes invoicing customers for those ancillary services that are provided by its BAA function (like the EI/GI for PacifiCorp’s share of Craig Unit 1 and Craig Unit 2 resources located in
WAPA’s BAA), which were previously invoiced for under other PacifiCorp’s
Network Integration Transmission Service (NITS) agreement with WAPA, in the absence of an overarching BASA. This agreement also seeks to document all points of interconnection, and all existing metering points and data communication links between WAPA and its neighboring BAAs. WAPA had joined SPP’s WEIS market, which had gone live on February 1, 2021. In
order to facilitate their integration into this market, they had executed a BASA with all their customers who have loads and/or resources within their BAA. PacifiCorp has a share of the Craig Unit 1 and Craig Unit 2 generation plants which fall in WAPA’s BAA. It also has loads scattered across
WAPA’s BAA and for serving those it has the abovementioned NITS agreement with WAPA.
(b) With regard to a forecasted change in expenses for 2021 related to the BASA executed with WAPA in March 2021, the Company advises that no new balancing authority services (scheduling, control and dispatch, reactive supply, regulation and frequency response, energy imbalance, real power losses) were procured as a result of the BASA. All ancillary services paid by PacifiCorp to WAPA are pursuant to WAPA rate schedules independent of
the BASA. The BASA is an overarching agreement that contains variances
terms and conditions surrounding these ancillary services PacifiCorp was already paying. The only new charges pursuant to the BASA is the WAPA and Southwestern Power Pool (SPP) Administration Fees of $4,186.78 per month ($/month). These new fees reflect the pass-through costs from SPP of administering the Western Energy Imbalance Service (WEIS) market, and also WAPA administrative charges of administering imbalance services for customers that are not directly participating in the WEIS.
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 IPUC Data Request 176
Recordholder: Rohan Chatterjee / Doug Young / Steve McDougal

Sponsor: Michael Wilding

PAC-E-21-07 / Rocky Mountain Power September 10, 2021 IPUC Data Request 178
IPUC Data Request 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.
Response to IPUC Data Request 178
In accordance with the 2020 PacifiCorp Interjurisdictional Allocation Protocol
methodology, transmission plant is system allocated and not situs assigned. Recordholder: Craig Larsen
Sponsor: Steve McDougal

PAC-E-21-07 / Rocky Mountain Power September 10, 2021 IPUC Data Request 179
IPUC Data Request 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.
Response to IPUC Data Request 179
There are no transmission lines that are currently allocated situs.
Recordholder: Craig Larsen Sponsor: Steve McDougal

PAC-E-21-07 / Rocky Mountain Power September 10, 2021 IPUC Data Request 182
IPUC Data Request 182 Please provide the Company’s policy, guidelines, and/or procedures for protecting transmission lines and substation facilities from forest/wildfire.
Response to IPUC Data Request 182 Please refer to Attachment IPUC 182 which provides PacifiCorp’s current plans
and documentation for both the prevention of wildfires and the protection from
forest/wildfires, specifically: - Utah Wildland Fire Protection Plan, June 1, 2020. - R.18-10-007_PacifiCorp_2021_Wildfire_Mitigation_Plan_Update_3-5-21

- Policy 357-Genics Fire Wrap Policy, August 12, 2020.
Recordholder: Russ Updike / Amy McCluskey
Sponsor: To Be Determined

PAC-E-21-07 / Rocky Mountain Power September 10, 2021 IPUC Data Request 186
IPUC Data Request 186 CONFIDENTIAL REQUEST - 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.

(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.

PAC-E-21-07 / Rocky Mountain Power September 10, 2021 IPUC Data Request 186
Response to IPUC Data Request 186 Please refer to Attachment IPUC 186-1 and Confidential Attachment IPUC 186-2.

Information requested about the request for proposals (RFP) evaluation and winning bid proposal is commercially sensitive and highly confidential. The Company requests special handling. Please contact Ted Weston at [phone]
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: Todd Jensen
Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 IPUC Data Request 187
IPUC Data Request 187 CONFIDENTIAL REQUEST - 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) 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. 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).
(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.
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 IPUC Data Request 187
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.
Response to IPUC Data Request 187
Please refer to Confidential Attachment IPUC 187.
Information requested about the request for proposals (RFP) evaluation and
winning bid proposal is commercially sensitive and highly confidential. The Company requests special handling. Please contact Ted Weston at [phone] 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: Todd Jensen Sponsor: Rick Vail
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 IPUC Data Request 195
IPUC Data Request 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.
Response to IPUC Data Request 195 The Company objects to this request as overly broad and unduly burdensome. Subject to and without waiving any objection, the Company responds as follows:

The Company does not have the requested information because costs for substation project improvements are tracked by FERC Account category, not based on the direction or flow of electricity.

Recordholder: Russell Updike Sponsor: Steve McDougal