20240405Application.pdf

_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP RECEIVED
Friday,April 5,2024 10:20:07 AM
April 5, 2024 IDAHO PUBLIC
UTILITIES COMMISSION
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
RE: CASE NO. PAC-E-24-07
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AN
ORDER INCREASING AND EXTENDING THE SHORT-TERM DEBT AUTHORITIES
FIVE YEARS
Attention: Commission Secretary
Please find for filing with the Idaho Public Utilities Commission Rocky Mountain Power's
Application in the above referenced matter. Pursuant to Idaho Code § 61-905 please note that the
Company's Application Fee in the amount of$1,000 is being submitted under separate cover.
Informal questions related to this matter may be directed to Mark Alder, Idaho Regulatory
Manager at [phone].
Sincerely,
Joe Steward
Senior Vice President, Regulation and Customer& Community Solutions

Joe Dallas (ISB# 10330)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: joseph.dallas(&,pacificorp.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR AN ) APPLICATION
ORDER INCREASING AND EXTENDING )
THE SHORT-TERM DEBT AUTHORITIES ) CASE NO. PAC-E-24-07
FIVE YEARS )
Rocky Mountain Power, a division of PacifiCorp (the "Company"), pursuant to Idaho
Codes §§ 61-901 through 61-904 and Rules of Procedure 141 through 147 of the Idaho Public
Utility Commission (the "Commission"), respectfully makes this application (the "Application")
to the Commission for an order on or before May 15, 2024, to increase the short-term debt
authorities granted in Case No. PAC-E-22-171 through May 31, 2029, on the condition that the
Company's senior secured debt be rated at"investment grade"by both Standard & Poor's Rating
Service and Moody's Investor Services, Inc. In support of this Application, the Company
represents as follows:
I. INTRODUCTION
1. Rocky Mountain Power is an electrical corporation and public utility in the
state of Idaho, subject to the jurisdiction of the Commission, with regard to its rates,
service, and accounting practices, § 61-129. PacifiCorp also provides retail electricity
'In the Matter of the Application of Rocky Mountain Power for an Order Increasing and Extending the
Short-Term Debt Authorities Five Years,Order No. 35630.
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service in the states of California, Oregon, Utah, Washington, and Wyoming. Rocky
Mountain Power's business address is 1407 West North Temple, Salt Lake City, Utah
84116.
II. BACKGROUND
2. On February 24, 2006, PacifiCorp filed an application requesting
authorization to borrow not more than$1.5 billion aggregate principal amount in short-term
debt through April 30, 2011. On March 14, 2006, the Commission granted the Company's
application in Order No. 29999.
3. On March 9, 2011, the Company requested that the authorities granted
under Case No. PAC-E-06-01 be extended for an additional five years, or through April
30, 2016, on the condition that the Company's senior secured debt be rated at "investment
grade"by both Standard &Poor's Rating Service and Moody's Investor Services, Inc. On
April 8, 2011, the Commission granted the Company's application in Order No. 32221.
4. On January 26, 2016, the Company requested that the authorities granted
under Case No.PAC-E-11-09 be extended for an additional five years,or through April 30,
2021, on the condition that the Company's senior secured debt be rated at "investment
grade"by both Standard &Poor's Rating Service and Moody's Investor Services, Inc. On
March 4, 2016, the Commission granted the Company's application in Order No. 33476.
5. On January 25, 2021, the Company requested that the authorities granted
under Case No.PAC-E-16-03 be extended for an additional five years,or through April 30,
2 In the Matter of the Application of PacifiCorp for authority to (]) issue its promissory notes to and borrow
from commercial banks for (a) not more than $1.5 billion under revolving credit agreements, and (b) not
more than$1. S billion under other borrowing arrangements;and(2)issue and sell its commercial paper in
principal amounts not to exceed$1. S billion outstanding at any one time. Case No.PAC-E-06-01.
3 Case No.PAC-E-11-09.
4 Case No.PAC-E-16-03.
5 Case No.PAC-E-21-02.
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2026, on the condition that the Company's senior secured debt be rated at "investment
grade"by both Standard &Poor's Rating Service and Moody's Investor Services, Inc. On
February 23, 2021, the Commission granted the Company's application in Order No.
34927.
6. On October 28, 2022, the Company requested that the authorization
amount to borrow granted under Case No. PAC-E-21-02 be increased to not more than
$2.0 billion aggregate principal amount in short-term debt for five years, or through
November 30, 2027, on the condition that the Company's senior secured debt be rated at
"investment grade" by both Standard & Poor's Rating Service and Moody's Investor
Services,Inc. On December 15,2022,the Commission granted the Company's application
in Order No. 35630.
III. REQUEST FOR RELIEF
7. The Company respectfully requests that the Commission increase these
short term debt authorities through May 31, 2029, by authorizing the Company to issue,
from time to time, its unsecured short-term promissory notes to and borrow from U.S. or
foreign commercial banks (or their affiliates) under the following facilities: (a) not more
than $3.0 billion in aggregate principal amount outstanding at any one time under one or
more revolving credit agreements (Agreements); and (b) not more than $3.0 billion in
aggregate principal amount outstanding at any one time under other borrowing
arrangements (Other Arrangements). The Company also respectfully request authorization
to issue and sell its commercial paper (Paper) in the U.S. or overseas, from time to time
through May 31, 2029, in aggregate principal amounts not to exceed $3.0 billion
6 Case No.PAC-E-22-17
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outstanding at any one time; provided that the aggregate principal amounts outstanding
under the Agreements, Other Arrangements and Paper not exceed $3.0 billion at any one
time.
8. The Company currently has a$2 billion revolving credit agreement expiring
June 30, 2026, with an unlimited number of maturity extension options subject to lender
consent.Under the terms of the agreement,the Company may borrow up to the full amount
or have letters of credit issued in an amount up to $300 million or a combination thereof.
9. As noted above, Rocky Mountain Power's authority to enter into these
revolving credit agreements has been in place since 2006. Through the growth of the
Company's load and customer base and the continued investment that is necessary to
support Company operations, Rocky Mountain Power is seeking to increase its ability to
issue commercial paper, which will in turn be backed by these revolving debt agreements.
PacifiCorp's capital expenditure program has grown significantly in size recently due to
adding new renewable generation resources, associated transmission, and investments in
wildfire mitigation assets to meet the needs of PacifiCorp's customers and the policy
objectives of PacifiCorp's state regulatory commissions.PacifiCorp expects that these new
or amended facilities will have terms comparable to the existing credit agreement and
reflective of then-current market conditions.
IV. STATEMENT OF PUBLIC NOTICE APPLICATION
10. Notice of this Application will be published within (7) days of this
Application in those newspapers in general circulation in the Company's service area as
explained in Section 8, Rule 141 of the Rules of Procedure of the Idaho Public Utilities
Commission.
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V. COMMUNICATIONS
11. Communications regarding this Application should be addressed to:
Mark Alder
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
Telephone: [phone]
E-mail: Mark.Alder@,pacificorp.com
Joe Dallas
Senior Attorney
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 92732
Telephone: [phone]
E-mail: Joseph.Dallasgpacificorp.com
In addition, Rocky Mountain Power respectfully requests that all data requests
regarding this matter be addressed to:
By e-mail (preferred): datarequestgpacificorp.com
By regular mail: Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
Informal inquiries may be directed to Mark Alder, State Manager [phone].
VI. MODIFIED PROCEDURE
12. Rocky Mountain Power believes that consideration of the proposals
contained in this Application do not require an evidentiary proceeding, and accordingly the
Company requests that this Application be processed under RP 201 allowing for
consideration of issues under Modified Procedure, i.e., by written submissions rather than
by an evidentiary hearing.
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WHEREFORE,Rocky Mountain Power respectfully requests that the Commission
issue an order on this matter on or before May 15, 2024, increasing the short-term debt
authorities described herein through May 31, 2029, on the condition that the Company's
senior secured debt be rated at "investment grade" by both Standard & Poor's Rating
Service and Moody's Investor Services, Inc.
DATED: April 5, 2024
Respectfully submitted,
Joe Dallas
Attorney for Rocky Mountain Power
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