20230405PAC to Staff 1-9_1-17.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
April 5, 2023 Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C) RE: ID PAC-E-23-01
IPUC Set 1 (1-17) Please find enclosed Rocky Mountain Power’s Responses to IPUC 1st Set Data Requests 1-9 and 11-17. The response to IPUC 10 will be provided separately. Also provided are Attachments 2, and 14. Provided via BOX is Confidential Response IPUC 3 and Confidential Attachment IPUC 6. 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 protective agreement executed in this proceeding. If you have any questions, please feel free to call me at [phone]. Sincerely,
____/s/____
J. Ted Weston Manager, Regulation Enclosures
RECEIVED
2023 April 5, 5:31PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 1
IPUC Data Request 1 In its Application, the Company describes a complex plan with many projects and transactions that are distinct from constructing the Boardman to Hemingway
(B2H) transmission line. The following are a list of projects and transactions Staff
has identified in the Application: I. Pre-B2H Agreements:
(a) Establish the 2nd amended and restated Joint Permit Funding Agreement;
(b) The Company will renew its 510 megawatts (MW) of point to point (PTP) transmission service from Idaho Power Company (IPC); (c) Bonneville Power Association (BPA) will redirect and assign to the Company 200 MW of PTP transmission rights it holds on IPC's system; (d) The Company and BPA will amend the Midpoint-Meridian Agreement
and update multiple PTP service agreements concerning central Oregon
load service; (e) Establish the Longhorn Substation Funding Agreement; (f) IPC will acquire 500 MW of PTP transmission service from BPA between
Mid-C and Longhorn; and
(g) IPC and BPA will establish a Purchase, Sale, and Security agreement, and two related transmission agreements, to buy out BPA's permitting interest. II. The B2H Core Project: (a) Establish the Joint Construction Funding Agreement with IPC;
(b) Acquire rights-of-way;
(c) Construct access roads, the main transmission line, and communication stations; (d) Rebuild or remove certain other transmission segments;
(e) Construct the Longhorn substation;
(f) Upgrade the Hemingway substation; and (g) Construct the Midline Series Capacitor substation. III. Asset Exchanges and Related Construction Agreements with IPC: (a) IPC transfer to the Company transmission assets between Midpoint and
Borah for 300 MW west-to-east capacity;
(b) IPC transfer to the Company transmission assets between Borah and Hemingway for 600 MW east-to-west capacity; (c) The Company transfer to IPC transmission assets between Populus and Four Corners for 200 MW of bi-directional capacity; (d) The Company transfer to IPC identified Goshen area assets; (e) Establish a construction agreement and construct the Midpoint 500/34-kV Transformer Project; and (f) Establish a construction agreement and construct the Kinport-Midpoint345-kV Series Capacitor Bank Project.

PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 1
For each of these projects or transactions above (and any others inadvertently omitted by Staff), please provide the following: (1) Please identify which of these projects/transactions that the Company is
seeking Commission authorization under the Certificate of Public
Convenience and Necessity (CPCN). (2) Please identify which of these projects/transactions the Company is seeking
Commission authorization of in this case but not specifically under the CPCN.
(3) Please identify which of these projects/transactions the Company plans to seek Commission authorization of outside of this case. If seeking authorization outside of this case, when and how will the Company be seeking authorization?

(4) For any projects/transactions that will be authorized outside of this case, please discuss possible dependencies between them and the included projects/transactions.
Response to IPUC Data Request 1 (1) Rocky Mountain Power (RMP) is requesting an Idaho Public Utilities Commission order granting a certificate of public convenience and necessity (CPCN) for the Broadway-to-Hemingway (B2H) transmission line. The B2H
project consists of the following identified items under the request heading
section II “The Core B2H Project”: (a) Construct access roads, the main transmission line, and communication
stations,
(b) Rebuild or remove certain other transmission segments, (c) Construct the Longhorn substation,
(d) Upgrade the Hemingway substation, and
(e) Construct the Midline Series Capacitor substation.
(2) With respect to the Company’s B2H CPCN request as described in its
response to subpart (1) above, the Company is requesting IPUC’s review of
the relevant partnership agreements under the Term Sheet. By approving the B2H CPCN request, the Company believes that the IPUC would be indicating that the underlying partnership agreements that provide for the B2H project to be constructed are reasonable in their current forms. Even though explicit approval of the partnership agreements is not requested in this CPCN
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 1
proceeding, the partnership agreements form the basis to derive the estimated costs of the B2H project that the Company will seek to recover from its customers.
(3) All of the items identified under request heading, section III “Asset Exchanges and Related Construction Agreements with IPC”, are components of the proposed asset exchange between the Company and Idaho Power Company (IPC) that will facilitate the parties’ objectives as set forth in the various B2H agreements. The asset exchanges will not be effective until energization of B2H which is expected to occur in 2026. In a future proceeding filed in
advance of energization of B2H to allow sufficient time for IPUC review, the Company and IPC will request approval of the agreement under Idaho Code §61-328, detailing the benefits associated with the assets being exchanged and demonstrating that the transaction is consistent with the public interest.
(4) The asset exchanges discussed in the Company’s response to subpart (3)
above facilitate the ownership and operation agreements necessary for B2H by allowing for:
(a) the transfer to the Company by IPC of transmission assets between Midpoint and Borah to facilitate 300 megawatts (MW) of west-to-east capacity,
(b) the transfer to the Company by IPC of transmission assets between Borah and Hemingway to enable an additional 600 MW of east-to-west capacity, increasing from the current 1,090 MW to 1,690 MW,
(c) the transfer to IPC by the Company of transmission assets between Populus, Mona, and Four Corners (4C) to allow for 200 MW of bi-
directional capacity, and
(d) the transfer to IPC by the Company of an ownership interest in identified Goshen area assets.
Thus, the B2H project and the asset exchanges are interdependent.

Recordholder: Carla Scarsella Sponsor: Carla Scarsella
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 2
IPUC Data Request 2 Please provide detailed and legible project maps portraying the operational components (substations, lines, etc.) and proposed transfer components, as
described in agreements between the Company and its partners. Please indicate
the name, physical location, agreement reference(s), and ownership for each component on each map.
Response to IPUC Data Request 2
The assets include 345 kilovolt (kV) transmission lines and substations extending from the Four Corners (4C) substation in northwest New Mexico through Utah to the Populus substation in south central Idaho. The Goshen assets include various lines and substations at various voltages to loads served from the Goshen
substation in southern Idaho. Assets to be sold and purchased will be included in
the Joint Purchase and Sales Agreement (JPSA) and will be included in the Amended Joint Ownership and Operating Agreement (JOOA). The Boardman-to-Hemingway (B2H) project will be included in the Amended Joint Permit Funding
Agreement (JPFA), the Project Construction Agreement (PCA) and the Amended
JOOA. Please refer to the Attachment IPUC 2 which provides a list of the assets considered under the proposed JPSA to be sold together with general maps.

Recordholder: Brian Fritz Sponsor: Rick A. Vail
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 3
IPUC Data Request 3 Link Direct at 25 - Please provide the following scope and cost estimate information:

(a) Please provide a tabulated comparison of the project scope and cost that were assumed in the Updated 2021 Integrated Resource Plan (IRP), and the scope and cost that are currently included in the Boardman to Hemingway project
[as defined by the Joint Construction Funding Agreement (JCFA)];
(b) In addition to the previous comparison, please provide a detailed list of the project scope included in the JCFA and the associated costs. Please include any associated accounting costs - such as the Allowance for Funds Used During Construction (AFUDC)- to provide a comprehensive summary of the
total project cost. Also, please indicate the Company's share of the total
project cost; and (c) Please provide a list of any B2H-related costs that are outside of the JFCA,
such as the series capacitor bank at the Meridian substation.
Confidential Response to IPUC Data Request 3 (a) The Company’s 2021 Integrated Resource Plan (IRP) Update did not include a detailed cost breakdown. For details on the current scope and costs, please
refer to the Company’s responses to subparts (b) and (c) below.
(b) The project scope will include construction of the line and access roads, material purchase, and right-of-way (ROW) acquisition. Additional tasks
currently being performed under the separate Joint Permit Funding Agreement
includes all federal and state permitting, line and access road design, long lead material purchases, ROW option acquisition, land surveys geotechnical studies, and mitigation plans. PacifiCorp’s share of the costs is 54.55 percent. Direct costs are estimated at
,
overhead costs are estimated at . (c) Projects outside of the Joint Funding Construction Agreement (JFCA) include
the following projects: 1. Upgrade of the series capacitor at the Meridian substation near Medford Oregon cost to be determined.
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 3
2. The addition of a series capacitor at the Kinport substation near Pocatello Idaho with an estimated cost of
3. The addition of a 500/345 kilovolt (kV) transformer at the Midpoint
substation near Twin Falls Idaho with an estimated cost of .
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 protective agreement executed in this proceeding.
Recordholder: Dan MacNeil / Brian Fritz
Sponsor: Rick T. Link / Rick A. Vail

PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 4
IPUC Data Request 4 Link Direct at 33 - Table 4 in Company Witness Link's testimony identifies the costs and benefits of B2H. Please provide the following:

(a) Please explain and provide the worksheet(s) showing how the Company determined the net cost for B2H to be $454 million;
(b) Please explain and provide the worksheet(s) showing how the Company
determined the net cost for Asset and Reservation Exchange to be $308 million; (c) Please explain and provide the worksheet(s) showing how the Company determined the net benefit for System Dispatch Impacts in the "MM" scenario
to be $520 million; and
(d) Please explain and provide the worksheet(s) showing how the Company determined the net benefit for Central Oregon Load Service to be $1,811
million.
Response to IPUC Data Request 4 Please refer to the non-confidential work papers supporting the direct testimony of Company witness, Rick T. Link, specifically file “B2H CPCN Testimony
Support_2023 01 26 NonCONF”, tab “Table 4 PVRR(d)” which provides the
support for Table 4 (PVRR(d) Cost/(Benefit) of B2H ($ million), 2023-2042). Please refer to the confidential work papers supporting Mr. Link’s direct testimony, specifically file “B2H CPCN Testimony Support_2023 01 26 CONF”
for supporting calculations.
Each of the referenced values is a present value revenue requirement differential (PVRR(d)) between the costs of the Boardman-to-Hemingway (B2H) scenario and the No B2H scenario, over the study horizon 2023 through 2042.
(a) Please refer to the confidential work papers supporting Mr. Link’s direct
testimony, specifically file “B2H CPCN Testimony Support_2023 01 26 CONF”, tab “Detail Summary”, cell E5. This reflects the nominal levelized annual revenue requirement for the B2H project, starting in 2026 and continuing through 2042. (b) Please refer to the confidential work papers supporting Mr. Link’s direct testimony, specifically file “B2H CPCN Testimony Support_2023 01 26 CONF”, tab “Detail Summary”, and the sum of cells E6:E8. This includes three components associated with the Asset and Reservation Exchange:

PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 4
1. Lost transmission revenue from the Bonneville Power Administration (BPA) for service currently provided by PacifiCorp, on assets that are being transferred to Idaho Power Company (IPC), from whom BPA would take service going forward,

2. The incremental cost of PacifiCorp’s current point-to-point (PTP) transmission reservations on IPC’s transmission system, after the costs of B2H is accounted for in IPC’s formula rates, and

3. The incremental costs of additional PTP transmission reservations on IPC’s transmission system, which will be transferred to PacifiCorp from BPA once B2H is in service, including the impact of including B2H within IPC’s formula rates.
(c) Please refer to the confidential work papers supporting Mr. Link’s direct
testimony, specifically file “B2H CPCN Testimony Support_2023 01 26 CONF”, tab “Detail Summary”, cell E25. This reflects the difference in risk-adjusted system costs to serve PacifiCorp’s retail load, with and without B2H.
This includes the costs of new resources and transmission, including build
costs, ongoing fixed costs, and variable costs, including fuel costs where applicable, net of any applicable tax credits. It also includes fixed and variable costs for existing thermal resources, costs for current contracted resources, plus wholesale market purchase costs less wholesale market sale revenues. With B2H in service, its incremental transmission capacity can be used to
serve load or support wholesale sales, allowing for lower cost resources in
either the PacifiCorp East (PACE) or PacifiCorp West (PACW) balancing authority areas (BAA) to be dispatched.
(d) Please refer to the confidential work papers supporting Mr. Link’s direct
testimony, specifically file “B2H CPCN Testimony Support_2023 01 26 CONF”, tab “Detail Summary”, cell E14. This consists of two components: 1. The vast majority of the impact is the costs of a 725 megawatt (MW) li-ion battery with an eight-hour duration. Additional details on this cost
calculation are contained on tab “SOR Battery”.
2. A small portion of the cost savings are a result of consolidating PacifiCorp’s existing BPA transmission reservations to serve Central Oregon, as detailed on tab “BPA PTP Resv”. Recordholder: Dan MacNeil / Rohan Chatterjee Sponsor: Rick T. Link
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 5
IPUC Data Request 5 Link Direct at 25 / 26 - Company Witness Link testifies that "In the absence of B2H, providing this level of central Oregon load service would require at least
725 MW of dispatchable generation in southern Oregon".
(a) Please explain why the Company expects loads to grow from 340 MW to 680 MW in central Oregon. Link Direct at 25;

(b) Please explain why this growth will require at least 725 MW of dispatchable generation; (c) Please provide the "non-wires analysis performed by BPA, IPC, and PacifiCorp" described in footnote 14 of this testimony. Link Direct at 25; and

(d) Please explain how the Company estimates the annual fixed costs of this resource to be $230 million in 2027. Link Direct at 26.
Response to IPUC Data Request 5
(a) Load is expected to increase in central Oregon primarily due to large commercial customer growth expectations. (b) Absent the Boardman-to-Hemingway (B2H) transmission project, PacifiCorp
would have to rely on 680 megawatts (MW) of legacy scheduling rights
(instead of Open Access Transmission Tariff (OATT) point-to-point (PTP) rights) from the Bonneville Power Administration (BPA) for utilizing its PacifiCorp East (PACE) resources for serving central Oregon load. This
dispatchable generation in southern Oregon would be needed so that it could
be deployed when power flows from PACE to central Oregon loads across paths operated by BPA exceed specified levels. (c) Referencing the direct testimony of Company witness, Rick T. Link, specifically footnote 14 “A non-wires analysis performed by BPA, IPC, and
PacifiCorp indicated that obtaining 680 MW of central Oregon load service
capability in the absence of B2H would require dispatchable generation in Southern Oregon ranging from 725 MW to 1,450 MW to prevent impacts to other existing rated paths”, the Company responds as follows: The referenced analysis (the Transmission Planning - Joint Planning Study – Phase II Joint Study Report (2020-2021) – Boardman to Hemingway (B2H) and Incremental Central Oregon Load) is the joint work product of BPA, Idaho Power Company (IPC) and PacifiCorp. The referenced analysis is classified as critical information (CI). The Company requests special
handling. The Company is requesting permission from its own management,
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 5
as well as the appropriate personnel representing BPA and IPC, as to whether the referenced analysis can be provided and to determine the appropriate level of confidentiality protections of the referenced analysis. The Company will supplement this data request response when the joint participants in the
referenced analysis (PacifiCorp, BPA and IPC) have considered the
Company’s request for permission to provide in response to this data request. (d) Please refer to the confidential work papers supporting Mr. Link’s direct
testimony, file “B2H CPCN Testimony Support_2023 01 26 CONF” . Tab
“SOR Battery” contains the calculation of the referenced value in column AO. The cost consists of two components, both reflecting assumptions developed for and used in PacifiCorp’s 2023 Integrated Resource Plan (IRP): 1. The nominal annualized build cost for an eight-hour battery storage
resource in Oregon. The annualized value accounting for the savings
associated with a 30 percent investment tax credit (ITC), which is available to energy storage resources under the Inflation Reduction Act. Battery build costs have a specific cost escalation assumption in the 2023
IRP, with costs through 2028 reflecting recent experience in the
Company’s 2020 All-Source Request for Proposals (2020 All-Source RFP), then gradually returning to the National Renewable Energy Laboratory’s (NREL) 2022 Annual Technology Baseline cost projection by 2032. These assumptions were discussed at the Company’s 2023 IRP public input meeting held on October 13, 2022, specifically slides 4 and 5
of the presentation material. The presentation material is publicly available
and can be accessed by utilizing the following website link: https://www.pacificorp.com/content/dam/pcorp/documents/en/pacificorp/e
nergy/integrated-resource-plan/2023-
irp/PacifiCorp_2023_IRP_PIM_Oct_13_2022.pdf 2. The fixed operations and maintenance (FOM) expense for an eight-hour battery storage resource in Oregon. FOM expenses are forecasted to escalate at inflation.

Recordholder: Lee Elder / Rohan Chatterjee / Dan MacNeil Sponsor: Rick T. Link
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 6
IPUC Data Request 6 Link Direct at 37 - Company Witness Link testifies that "...BPA will redirect and then assign to PacifiCorp 200MW of PTP transmission rights it holds on IPC's
system". Please provide the following:
(a) Please provide a detailed explanation of the need for this agreement;
(b) Please provide maps portraying the existing and proposed PTP routes; and
(c) Please explain the Company's contingency plan if this exchange is prevented or not implemented. Response to IPUC Data Request 6

(a) The referenced point-to-point (PTP) transmission rights will provide eastbound scheduling rights, represented in PacifiCorp’s Integrated Resource plan (IRP) model between Walla Walla and Borah/Populus, which will
provide additional options for serving loads in the PacifiCorp East (PACE)
balancing authority area (BAA). This results in lower dispatch costs during those periods when lower cost PacifiCorp West (PACW) BAA resources or market purchases are available can be transferred to displace higher cost PACE resources that would otherwise be dispatched. This can also result in higher reliability, to the extent additional resources are available in PACW
during periods when PACE has the potential for shortfalls.
(b) Please refer to Confidential Attachment IPUC 6.
(c) In the absence of these long-term transmission rights being assigned to
PacifiCorp, the Company will continue to rely on purchases of short-term PTP transmission over Idaho Power Company’s (IPC) system. Absent availability of any short-term transmission over IPC’s system, PacifiCorp would have to rely on higher cost PacifiCorp East (PACE) resources or market purchases in the southwest markets (such as Four Corners (4C), Palo Verde (PV), Mona
etc.).
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 protective agreement executed in this proceeding. Recordholder: Dan MacNeil / Rohan Chatterjee
Sponsor: Rick T. Link
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 7
IPUC Data Request 7 Company Witness Vail testifies that "...BPA will be responsible for designing, procuring, and constructing the Longhorn substation...." Vail Direct at 6-7. He
also testifies that "The [Longhorn Substation Funding Agreement] will be
contingent upon BPA completing its obligations and responsibilities under various environmental compliance laws." Vail Direct at 29. Please explain the following:

(a) Please itemize the responsibilities that BPA must complete and identify any that pose a significant degree of risk or uncertainty; (b) Please list the estimated timeline for BPA to complete its responsibilities; and
(c) Please describe the Company's contingency plan if BPA is unable to complete
its responsibilities. Response to IPUC Data Request 7

(a) Bonneville Power Administration (BPA) will be the owner and operator of the 500/230 kilovolt (kV) Longhorn substation where the Boardman-to-Hemingway (B2H) line will terminate at the 500 kV side of the substation. BPA will be responsible for all environmental reviews, permitting, design, procurement, and construction of the substation. No risks have been identified
at this time.
(b) Substation completion is planned to coincide with the termination of the B2H line in support of a July 2026 in-service date.

(c) At this time, there are no contingencies that would provide for connecting the line into BPA’s 500 kV transmission system. Recordholder: Brian Fritz

Sponsor: Rick A. Vail
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 8
IPUC Data Request 8 Company Witness Vail testifies that "B2H is necessary for the Company to meet its customers' short- and long-term energy demand..." Vail Direct at 4.
Please provide the following:
(a) Please provide the Company's 20-year Load & Resource Balance (L&RB) showing the year and deficits justifying this need. Please ensure this
information clearly identifies the deficits in central Oregon and in the vicinity
of Longhorn substation; (b) Please explain how the Company will serve its customers if B2H is not approved; and
(c) Please explain how the Company will serve its customers if B2H is approved
but completion is delayed beyond any deficit date. Response to IPUC Data Request 8

(a) The Company has not prepared the requested analysis. The load and resource balance presented in the Company’s Integrated Resource Plan (IRP) and IRP Update provides detail for the PacifiCorp East (PACE) and PacifiCorp West (PACW) balancing authority areas (BAA), and does not have detail by load bubble. As discussed in the direct testimony of Company witness, Rick T.
Link, load growth in the vicinity of the Longhorn substation is projected to be
served by either third-party transmission, or the Boardman-to-Hemingway (B2H) transmission project in conjunction with additional upgrades in the vicinity of the load. The Company’s existing transmission system and
reservations with third-party transmission providers would not be sufficient to
serve this additional load and the Company has no resources at that location. (b) In the absence of B2H being approved, additional southern Oregon resources in excess of PacifiCorp’s southern Oregon loads would be needed to alleviate flows on other transmission paths and while maintaining 680 megawatts
(MW) of Central Oregon load service. PacifiCorp’s analysis assumes that a
lithium-ion battery with eight-hour duration would need to be located in southern Oregon and be available for dispatch whenever flow-based restrictions occur. (c) If B2H is approved but completion is delayed, PacifiCorp would have to rely on short-term Bonneville Power Administration (BPA) point-to-point (PTP) transmission for serving its load growth needs.
Recordholder: Dan MacNeil / Rohan Chatterjee
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 8
Sponsor: Rick T. Link
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 9
IPUC Data Request 9 The Company states that "...BPA decided to transition out of its role as a joint permit funding coparticipant." Application at 6. Please explain why BPA wanted
out of its role. Please explain why IPC is buying out BPA instead of the
Company, or instead of both companies sharing the buyout. Response to IPUC Data Request 9

PacifiCorp is not able to provide a response. The Company respectfully requests that the Idaho Public Utilities Commission (IPUC) direct this request to the Bonneville Power Administration (BPA) and to the Idaho Power Company (IPC).
Recordholder: Brian Fritz
Sponsor: Rick A. Vail
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 10
IPUC Data Request 10 Please explain all potential funding sources the Company has considered and pursued to finance B2H by answering the following:

(a) Has the Company pursued available Federal funds for grid resilience and transmission? If not, why not? If yes, please describe the funds available, status of funding pursued, and how these funds potentially reduce impact to
ratepayers;
(b) Has the Company pursued available State funds through the Office of Energy and Mineral Resources (OEMR)? If not, why not? If yes, please describe the funds available, status of funding pursued, and how these funds potentially reduce impact to ratepayers;

(c) Has the Company pursued funds through the Federal Emergency Management Agency (FEMA) and the Office of Emergency Management (OEM)? If not, why not? If yes, please describe the funds available, status of funding pursued,
and how these funds potentially reduce impact to ratepayers;
(d) Has the Company applied for any grants or other funding for the project? If so, what were the sources, amounts, and application dates; and (e) Has the Company been awarded any grants or other funding for the project? If
so, what were the sources, amounts, and dates awarded?
Response to IPUC Data Request 10
(a) PacifiCorp has not applied for, nor received, any outside funding for the
Boardman-to-Hemingway (B2H) transmission project. (b) PacifiCorp has not identified any available state funds applicable to the B2H transmission project through the Office of Energy and Mineral Resources (OEMR).

(c) PacifiCorp has not identified any available state funds applicable to the B2H transmission project through the Federal Emergency Management Agency (FEMA) or the Office of Emergency Management (OEM). (d) PacifiCorp has not applied for grants or other funding for the B2H transmission project. (e) PacifiCorp has not been awarded any grants or funding for the B2H transmission project.

PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 10
Recordholder: Lisa Harkins Sponsor: Rick Vail
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 11
IPUC Data Request 11 Company Witness Vail testifies that there are additional asset exchanges proposed between IPC and the Company that are related to B2H but are separate from
the main B2H project. Vail Direct at 21-24. For the four proposed asset
exchanges, please provide the following: (a) Please explain the interdependencies of each exchange with each other and
with the B2H project; and
(b) Please explain the Company's contingency plans if any of the asset exchanges are prevented or not implemented. Response to IPUC Data Request 11

(a) The Goshen area asset sale provides the Bonneville Power Administration (BPA) a single transmission wheel from the Longhorn substation to their customer loads served from the Goshen Idaho substation. This is a key benefit
to BPA that allows for the added load service capability in central Oregon for
PacifiCorp. The Borah West asset sale provides PacifiCorp with 600 megawatts (MW) of east to west capacity between Borah and Hemingway, and 300 MW of west to east capacity between Hemingway and Midpoint, that aligns with PacifiCorp’s capacity on the Boardman-to-Hemingway (B2H) transmission line. The Four Corners (4C) to Populus asset sale provides a key
benefit to the Idaho Power Company (IPC).
(b) There is no contingency plan.

Recordholder: Brian Fritz Sponsor: Rick A. Vail
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 12
IPUC Data Request 12 Please describe how the Company will monitor IPC's construction progress and costs for the B2H project. Please provide any supporting documents.
Response to IPUC Data Request 12 PacifiCorp is part of the oversight committee where project progress, planned
actions, costs, schedule and scope are reviewed. The agreements allow for
PacifiCorp’s review of all changes and provides for rights to audit Idaho Power Company (IPC), as the project manager, and requires IPC, as the project manager, to submit project cost forecasts and on-going cost details for PacifiCorp review.
Recordholder: Brian Fritz
Sponsor: Rick A. Vail
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 13
IPUC Data Request 13 Please describe how the Company will allocate project costs to Idaho customers. Please provide supporting documents that describe the Company's cost
allocation policies.
Response to IPUC Data Request 13
After the project is placed into service, cost analysis determines the proper
Federal Energy Regulatory Commission (FERC) accounts for the project costs. The allocation factors will be assigned using the approved jurisdictional cost allocation methodology in effect at that time, for example, currently the allocation would use the FERC accounts as shown in Appendix B of the 2020 Multi-State Process (MSP) Inter-Jurisdictional Cost Allocation Methodology (2020 Protocol)
which was filed with and approved by the Idaho Public Utilities Commission
(IPUC) in Case No. PAC-E-19-20.
Recordholder: Nick Highsmith
Sponsor: Nick Highsmith
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 14
IPUC Data Request 14 Please describe the Company's current Idaho load. Please explain the benefits the proposed B2H project will confer to Idaho customers. Please provide supporting
work papers.
Response to IPUC Data Request 14
Please refer to Attachment IPUC 14 which provides PacifiCorp’s current Idaho
load forecast. PacifiCorp forecasting uses all of its owned resources, contracted resources and transmission assets to serve all of its retail load in the most cost-effective manner possible. Idaho customers would receive their share of the system benefits
enabled by the Boardman-to-Hemingway (B2H) transmission project in
accordance with the 2020 Multi-State Process (MSP) Inter-Jurisdictional Cost Allocation Methodology (2020 Protocol) or its successor. As a result, Idaho customers would receive the benefit of lower costs for system dispatch, Central
Oregon load service, and Longhorn area load service, as described in the direct
testimony of Company witness, Rick T. Link. PacifiCorp has not prepared an estimate of the benefits associated with the B2H transmission project on an Idaho-allocated basis.
Recordholder: Lee Elder / Dan MacNeil
Sponsor: Rick T. Link
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 15
IPUC Data Request 15 From the Exhibit 2 tab "Study Detail", please explain the eight pre-B2H requirements under the section "Load Interconnection".

(a) Please explain if these requirements are included in the B2H construction project; and
(b) If so, please explain how costs will be shared between the Company and
partners. Response to IPUC Data Request 15 The Company assumes that the reference to “Exhibit 2” is intended to be a
reference to Confidential Exhibit No. 2 (PVRR(d) Calculations) to the direct
testimony of Company witness, Rick T. Link. Based on the foregoing assumption, the Company responds as follows:
The eight pre-Boardman-to-Hemingway (B2H) requirements listed in
Confidential Exhibit No. 2, tab “Study Detail”, section “Load Interconnection” were inadvertently included within the provided Microsoft Excel file. The calculations on tab “Study Detail” were part of an internal study to identify what would be necessary to accommodate significant load growth in the area. These requirements are not included in the B2H construction project and, if constructed,
would likely have separate timelines apart from B2H. B2H ultimately benefits
area load serving capacity and may eventually be required to meet load growth, but the timing of the need for B2H and the need for the eight projects is dependent on actual load levels and the ability to leverage third-party transmission service.

Recordholder: Adam Lint Sponsor: Rick T. Link
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 16
IPUC Data Request 16 Company Witness Link describes the proposed Ozone Transport Rule and its requirements of the Company's thermal facilities in Utah and Wyoming.

(a) Please quantify the amount of electricity from the Company's Utah and Wyoming thermal facilities that meets the requirements of the proposed Ozone Transport Rule that can be transmitted on the proposed B2H
transmission line; and
(b) Please provide supporting work papers that include the yearly requirements from the proposed rule and the corresponding impact on the Company's production levels from Utah and Wyoming thermal facilities.
Response to IPUC Data Request 16
(a) PacifiCorp’s Integrated Resource Plan (IRP) models that were used in the Company’s analysis were not specifically set to identify which sources of
supply were associated with particular transmission paths, therefore, the
Company has not quantified the requested information. Notwithstanding, the foregoing clarification, the Company responds as follows: All of PacifiCorp’s coal-fired and natural gas-fired generation facilities in Utah and Wyoming are subject to the proposed requirements under the Ozone
Transport Rule reflected in the Company’s modeling. The total capacity of
these resources is well in excess of the proposed Boardman-to-Hemingway (B2H) transmission line. While the requirement to have allowances for emissions from these facilities is expected to reduce the frequency at which
they are dispatched, at least for those units with high nitrous oxide (NOx)
emissions rates, their maximum output is not impacted, and the full amount is likely to be relied upon in hours where it is critical to system reliability or highly economic. PacifiCorp would also note that generation in the months of October through April is not subject to the proposed Ozone Transport Rule, therefore, output from these resources would be more economic and likely
higher.
(b) Please refer to the confidential work papers supporting the direct testimony of Company witness, Rick T. Link, folder “ST Results CONF”, specifically the “ST Cost Summary…” files. Rows 130 through 151 on tab “Cost Summary” provide details on the estimated cost impacts associated with the emissions allowances for Ozone Transport Rule compliance. While production at each of the Company’s coal-fired and natural gas-fired generation facilities in Utah and Wyoming is impacted by the Ozone Transport Rule, PacifiCorp has not calculated what production for these facilities would have been in the absence
of the proposed rule. PacifiCorp would note that thermal facilities with low
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 16
NOx emissions rates are likely to generate more to make up for reduced output from facilities with higher emission rates.
Recordholder: Dan MacNeil
Sponsor: Rick T. Link
PAC-E-23-01 / Rocky Mountain Power April 5, 2023 IPUC Data Request 17
IPUC Data Request 17 Link Direct at 21 - Company Witness Link referred to a study on the proposed Ozone Transport Rule effects.

(a) Please explain if the study will include an evaluation of the Rule's impact on Idaho costs; and
(b) Please provide the expected timeline for the study to be completed.
Response to IPUC Data Request 17 (a) PacifiCorp assumes that the reference to a “study” is intended to be a reference to the direct testimony of Company witness, Rick T. Link’s, page
21, lines 21 through 23, specifically “PacifiCorp calculated a system present-
value revenue requirement (PVRR) by identifying least-cost resource portfolios and dispatching system resources through 2042, which aligns with the 20-year forecast period used in PacifiCorp’s forthcoming 2023 IRP”.
Based on the foregoing assumption, PacifiCorp responds as follows:
The “study” referenced in Mr. Link’s direct testimony, page 21, lines 21 through 23, is the PLEXOS model results used by PacifiCorp’s integrated resource planning (IRP) team to identify the system costs to reliably and cost-effectively serve PacifiCorp load over a 20-year horizon (2023 through 2042).
These results are calculated on a system basis for every “Short-Term” (ST)
scenario run within PLEXOS model as part of the Boardman-to-Hemingway (B2H) analysis. The results reported for each scenario include estimated costs associated with Ozone Transport Rule compliance based on the parameters of
the proposed rule and the thermal resource dispatch calculated by the
PLEXOS model specific to that scenario. For details on these costs, please refer to the confidential work papers supporting Mr. Link’s direct testimony, folder “ST Results CONF”, specifically the “ST Cost Summary” files, tab “Cost Summary”, rows 130 through 151. Note: PacifiCorp has not prepared an estimate of these costs allocated to its Idaho retail customers.

(b) Please refer to the Company’s response to subpart (a) above. Recordholder: Dan MacNeil Sponsor: Rick T. Link