20211007PAC to Staff 175-195-Redacted.pdf

ROCKY MOUNTAIN
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October 7,2021
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-5918
ian.norivuki@nuc. idaho. gov (C)
RE: ID PAC-E-21-07
IPUC Set 7 (175-195)
Please find enclosed Rocky Mountain Power's Responses to IPUC 7h Set Data Requests l8l,
188-189,191, and 193. Provided via encryption and BOX are the Confidential Attachments and
Confidential Responses. Confidential information is provided subject to protected under IDAPA
31.01.01.067 and 3l .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,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Ronald L. Williams/PIIC [e-mail]
Bradley 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 randy@rac ineo lson. com (C)
Thomas J. Budge/Bayer tj @racineol son. com (WXC)
Brian C. Collins/Bayer bcol I ins@con su ltbai. com (WXC)
Maurice BrubakeriBayer [e-mail] (C)
Kevin Higgins/Bayer khi se ins@enereystrat. com (C)
Lance KaufmanlBayer lance@aee isinsi eht. com (C)
James R. Smith/Bayer i im. r. sm ith@ic loud. com (C)
Brad Purdy [e-mail] (C)
Ben Otto/ICL [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
October 7,2021
IPUC Data Request l8l
IPUC Data Request 181
NFIDENTIAL - For
all
papers with formulas enabled
(b)
project.
(c) Please provide a breakdown in megawatts (MW)of the total of the
: the amount of transfer needed by
the amount
current customers 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 to recover the
cost of the transmission line between
(e) Please tof,versus costs
(f) Please provide a breakdown of the total project cost by the major pieces of
equipment / infrastructure included in the CIAC versus the equipment /
infrastructure 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.
m itrJiliiEEriErilr fl fi ?!ff aFfl
(h)In file
PAC-E-21-07 / Rocky Mountain Power
October 7,2021
IPUC Data Request l8l
the customer has made a commitment to add the loads indicated before 2022.
(i) Please explain why network upgrades are included wittrin the project cost.
Specifically, did the Company identiff a need for the project to benefit the
system 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.
O 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.
Conlidential Rsponse to IPUC Data Request 181
(a) Yes. This project was constructed to add capacity to the Prineville, Oregon
area to accommodate the load request; however, planning sfudies indicate the
need for capacity increases in the lO-year horizon, and construction of this
project supports those long-term plans.
(b) This network upgrade project adds capacity to the transmission gnd. Idaho
customers benefit from PacifiCorp's transmission system that provides access
to several market areas enabling the Company to acquire and sell energy to
benefit customers. Investnent in transmission resources is system allocated
per the 2020 Inter-jurisdictional allocation methodology (2020 Protocol),
which the Idaho Public Utilities Commission (IPUC) approved in Order No.
34640.
(c) This network upgrade project added approximately 478 megavolt ampere
of transmission to the
area.
customer request
is currently in process. The remaining capacity is approximately 78
MW. Note: PacifiCorp's tansmission system is interconnected with the
Bonneville Power Administration @PA) in this area; the Company's response
to this data request does not address BPA's system capacity.
(d) All transmission investment, net of any customer contibutions, is included in
the Company's retail rates. Transmission invesftnent is also used to determine
the Federal Energy Regulatory Commission (FERC) Open Access
Transmission Tariff(OATT) that third parties pay for use of the Company's
transmission system. All wheeling revenues from the OATT are allocated as a
PAC-E-21-07 / Rocky Mountain Power
October 7,2021
IPUC DataRequest l8l
revenue credit back to retail customers.
(e) Project cost allocation was determined according to Oregon General Rules
and Regulations Rule 13 Line Extensions, Section I and Section III. Please
refer to Confidential Attachment IPUC l8l-l which provides support
documentation, and the Company's response to IPUC Data Request 180
which how the costs to
versus costs
as network upgrades
(f1 Please refer to Confidential Attachment IPUC l8l-2. The project cost
breakdown is summarized in Confidential Attachment l8l-3.
(g) Please refer to the Company's response to IPUC Data Request 180.
(h) Please refer to Confidential Attachment IPUC 1814.
(i) Please refer to the Company's response to subpart (a) above, and to the
Company's response to IPUC Data Request 180.
0)Data associated to these is not available and determination would be
contract to pay le
ofthe project upon Please
Attachment
ft) Please refer to the Company's response to subpart O above.
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:Adam Lint / JeffKeyser
Rick VailSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 7,2021
IPUC DataRequest 188
IPUC Data Request 1E8
CONF'IDENTIAL Please documentation
m response
any requested below cannot be
provided or is not available, please explain why and explain how the Company
assured the constuction of the project was completed at least cost.
(a) Analysis ofNeed - a justification of need for the project and a cost/benefit
analysis comparing altematives.
(b) Project Plan:
i. tnitial 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 fromwinning bid.
(d) Project construction documentation including
i. Constuction contact.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. Conhactors change order request(s).
(e) Company project completion analysis
i. Lessons learned.ii. Budget-to-actual comparisons for overall project and by year
Response to IPUC Data Request 188
(a) Please refer to Section 4 of Appropriation Request (APR) 20006365 provided
with the Company's response to IPUC Data Request 48. This section of the
PAC-E-21-07 / Rocky Mountain Power
October 7,2021
IPUC Data Request 188
APR contains a discussion of the "analysis of need" for the Ekola Flats wind
project.
The Ekola Flats wind project was part of PacifiCorp's Energy Vision 2020
(EV 2020) project. The economic analysis supporting PacifiCorp's EV 2020
resources was provided with the testimonies of Company witness, Rick T.
Link which was before the ldaho Public Utilities Commission (IPUC) in Case
PAC-E-I7-07.
(b) The Ekola Flats wind project's overall project scope, budget, and schedule is
provided in APR 20006365. The Company did not create a written project
execution plan for the Ekola Flats wind project.
(c) The Company interprets the request for proposals (RFP) information / support
to be referencing RFP information / support for the construction of the Ekola
Flats wind project. Based on this interpretation, the Company responds as
follows:
The requested information is considered commercially sensitive and highly
confidential. The Company requests special handling. Please contact Ted
Weston at [phone] to make arangements for review.
(d) Please refer to Confidential Attachment IPUC 188-l which provides a
construction schedule. The requested balance of plant (BOP) agreement and
the BOP monthly report is considered commercially sensitive and highly
confidential. The Company requests special handling. Please contact Ted
Weston at [phone] to make arrangements to review Monthly Reports
over the term of the BOP Agreement. Schedule variances from plan to actual
in reference to the early construction schedule provided are primarily the
result of the COVID-I9 pandemic and the associated late deliveries of wind
turbines. Late delivery of wind turbines pushed erection activities into late
fall2020 unfavorable wind speeds and weather. Please refer to Confidential
Attachment IPUC 188-3 which provides copies of BOP Contact Scope
Change Orders.
(e) A written project execution lesson's leamed is not available. Please refer to
Confidential Attachment IPUC 188-6 which provides a budget-to-actual cost
comparison.
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.
PAC-E-21-07 / Rocky Mountain Power
October 7,2021
IPUC DataRequest 188
Recordholder:Timothy J. Hemstreet
Timothy J. HemstreetSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 7,2021
IPUC DataRequest 189
IPUC Data Request 189
CONFIDENTIAL UEST - Please the fo documentation for
response to
any 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. Constuction contact.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. Contactors 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 arnount 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
October 7,2021
IPUC DataRequest 189
Response to IPUC Data Request 189
(a) Please refer to Confidential Attachment IPUC 189 which provides the project
proposals for Jim Bridger Unit 3 and Jim Bridger Unit 4 selective catalytic
reduction (SCR) projects. Project proposals provide a summary of the
"analysis of need".
(b) Please refer to Confidential Attachment IPUC 189.
(c) The requested information is considered commercially sensitive and highly
confidential. The Company requests special handling. Please contact Ted
Weston at [phone] to make arrangement for review.
(d) The requested information is considered commercially sensitive and highly
confidential. The Company requests special handling. Please contact Ted
Weston at [phone] to make arrangement for review.
(e) A summary project execution lessons leamed is not available.
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 - lnformation Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Richard Goff
Sponsor:James Owen
PAC-E-21-07 / Rocky Mountain Power
October 7,2021
IPUC Data Request l9l
IPUC Data Request 191
CONFIDENTIAL - Please
any requested below
cannot be provided or is not available, please explain why and explain how the
Company assured the constnrction 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 fromwinning bid.
(d) Project construction documentation includ ing:
i. Constuction contact.ii. Organizational chart.iii. Scope document.
iv. Work breakdown structure.v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items lis(s).
viii. Contactors 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 arnount 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
October 7,2021
IPUC Data Request l9l
Response to IPUC Data Request 191
(a) Please refer to the appropriation request (APR) provided with the Company's
response to IPUC Data Request 48.
(b) Please refer to the Company's response to subpart (a) above.
(c) Please refer to the APR submitted with the Company's response to IPUC Data
Request 48 which includes an explanation of the circumstances and necessary
process.
(d) The copy of the service agreement change order which serves as the conhact
and the project status reports requested information are considered
commercially sensitive and highly confidential. The Company requests
special handling. Please contact Ted Weston at [phone] to make
arrangement for review. The remaining information is included in the APR
which was provided with the Company's response to IPUC Data Request 48.
(e) The actual project completion date time was January 10,2020. Please refer to
the APR which was provided with the Companyos response to IPUC Data
Request 48.
Recordholder: Robert Van Engelenhoven
Sponsor: Robert Van Engelenhoven
PAC-E-21-07 / Rocky Mountain Power
October 7,2021
IPUC Data Request 193
IPUC Data Request 193
CONFIDENTIAL - Please documentation for
response to
any 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 scopeii. 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 includ ing :
i. Construction contact.
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
October 7,2021
IPUC DataRequest 193
Response to IPUC Data Request 193
(a) Please refer to Confidential Attachment IPUC 193.
(b) Please referto subpart (a) above.
(c) The requested information is considered commercially sensitive and highly
confidential. The Company requests special handling. Please contact Ted
Weston at [phone] to make arangement for review.
(d) The requested information is considered commercially sensitive and highly
confidential. The Company requests special handling. Please contact Ted
Weston at [phone] to make arrangement for review.
(e) The requested information is considered commercially sensitive and highly
confidential. The Company requests special handling. Please contact Ted
Weston at [phone] to make arrangement 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 - lnformation Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Robert Van Engelenhoven
Robert Van EngelenhovenSponsor: