20240531Direct A. Bulkley.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. PAC-E-24-04
OF ROCKY MOUNTAIN POWER FOR )
AUTHORITY TO INCREASE ITS RATES ) DIRECT TESTIMONY OF
AND CHARGES IN IDAHO AND ) ANN E. BULKLEY
APPROVAL OF PROPOSED )
ELECTRIC SERVICE SCHEDULES AND )
REGULATIONS )
ROCKY MOUNTAIN POWER
CASE NO. PAC-E-24-04
May 2024

1 I . INTRODUCTION
2 Q. Please state your name and business address .
3 A. My name is Ann E . Bulkley. I am a Principal at The
4 Brattle Group ("Brattle") . My business address is One
5 Beacon Street, Suite 2600, Boston, Massachusetts 02108 .
6 Q. On whose behalf are you submitting this direct
7 testimony?
8 A. I am submitting this direct testimony before the Idaho
9 Public Utilities Commission ("Commission") on behalf of
10 PacifiCorp d/b/a Rocky Mountain Power ("RMP" or the
11 "Company") , which is an indirect wholly-owned subsidiary
12 of Berkshire Hathaway Energy Company ("BHE") .
13 Q. Please describe your background and professional
14 experience in the energy and utility industries .
15 A. I hold a Bachelor' s degree in Economics and Finance from
16 Simmons College and a Master' s degree in Economics from
17 Boston University, with over 25 years of experience
18 consulting to the energy industry. I have advised
19 numerous energy and utility clients on a wide range of
20 financial and economic issues with primary
21 concentrations in valuation and utility rate matters .
22 Many of these assignments have included the
23 determination of the cost of capital for valuation and
24 ratemaking purposes . My resume and a summary of
25 testimony that I have filed in other proceedings,
Bulkley, Di 1
Rocky Mountain Power

1 including previously before the Commission, are included
2 as Exhibit No . 4 to this testimony.
3 II . PURPOSE AND SUMMARY OF TESTIMONY
4 Q. What is the purpose of your direct testimony?
5 A. The purpose of my direct testimony is to present evidence
6 and provide a recommendation regarding the appropriate
7 Return on Equity ("ROE") for PacifiCorp' s electric
8 utility operations in Idaho and to provide an assessment
9 of its proposed capital structure to be used for
10 ratemaking purposes .
11 Q. Please provide a brief overview of the analyses that led
12 to your ROE recommendation.
13 A. I have estimated the market-based cost of equity by
14 applying traditional estimation methodologies to a proxy
15 group of comparable utilities, including the constant
16 growth form of the Discounted Cash Flow ("DCF") model,
17 the Capital Asset Pricing Model ("CAPM") , the Empirical
18 Capital Asset Pricing Model ("ECAPM") , and a Bond Yield
19 Risk Premium ("BYRP" or "Risk Premium") analysis . My
20 recommendation also takes into consideration the
21 business and regulatory risk of the Company relative to
22 the proxy group, and the Company' s proposed capital
23 structure as compared with the capital structures of the
24 operating utilities of the proxy group companies . While
25 1 do not make specific adjustments to my ROE
Bulkley, Di 2
Rocky Mountain Power

1 recommendation for these factors, I do consider them in
2 the aggregate when determining where my recommended ROE
3 falls within the range of the analytical results .
4 Q. How is the remainder of your direct testimony organized?
5 A. The remainder of my direct testimony is organized as
6 follows :
7 • Section III provides a summary of my analyses and
8 conclusions .
9 • Section IV reviews the regulatory guidelines
10 pertinent to the development of the cost of
11 capital .
12 • Section V discusses current and prospective capital
13 market conditions and the effect of those
14 conditions on the Company' s cost of equity.
15 • Section VI explains my selection of the proxy
16 group.
17 • Section VII describes my cost of equity analyses
18 and the basis for my recommended ROE in this
19 proceeding.
20 • Section VIII provides a discussion of specific
21 regulatory, business, and financial risks that have
22 a direct bearing on the ROE to be authorized for
23 the Company in this case .
24 • Section IX provides an assessment of the
25 reasonableness of the Company' s proposed capital
26 structure .
27 • Section X presents my conclusions and
28 recommendations .
Bulkley, Di 3
Rocky Mountain Power

1 III . SUMMARY OF ANALYSES AND CONCLUSIONS
2 Q. Please summarize the key factors considered in your
3 analyses and upon which you base your recommended ROE.
4 A. My analyses and recommendations consider the following:
5 • The United States ("U. S . ") Supreme Court' s Hope and
6 Bluefield decisions' established the standards for
7 determining a fair and reasonable authorized ROE
8 for public utilities, including consistency of the
9 allowed return with the returns of other businesses
10 having similar risk, adequacy of the return to
11 provide access to capital and support credit
12 quality, and the requirement that the result lead
13 to just and reasonable rates .
14 • The effect of current and prospective capital
15 market conditions on the cost of equity estimation
16 models and on investors' return requirements .
17 • The results of several analytical approaches that
18 provide estimates of the Company' s cost of equity.
19 Because the Company' s authorized ROE should be a
20 forward-looking estimate over the period during
21 which the rates will be in effect, these analyses
22 rely on forward-looking inputs and assumptions
23 (e. g. , projected analyst growth rates in the DCF
24 model, forecasted risk-free rate and market risk
25 premium in the CAPM analysis . )
26 • Although the companies in my proxy group are
27 generally comparable to PacifiCorp, each company is
28 unique, and no two companies have the exact same
29 business and financial risk profiles . Accordingly,
30 I considered the Company' s regulatory, business,
31 and financial risks relative to a proxy group of
32 comparable companies in determining where the
33 Company' s ROE should fall within the reasonable
34 range of analytical results to appropriately
35 account for any residual differences in risk.
' Federal Power Commission v. Hope Natural Gas Co. , 320 U.S. 591 (1944)
("Hope") ; Bluefield Waterworks & Improvement Co. , v. Public Service
Commission of West Virginia, 262 U.S. 679 (1923) ("Bluefield") .
Bulkley, Di 4
Rocky Mountain Power

1 Q. What are the results of the models that you have used to
2 estimate the market-based cost of equity for PacifiCorp?
3 A. Figure 1 summarizes the range of results produced by the
4 cost of equity analyses .
5 Figure 1 : Summary of Cost of Equity Analytical Results2
I
Constant Growth DCF 1 Mean
I
Constant Growth DCF-Median
I I
I I
I I
I I
1 Recommended ROE 1
Range
Company
Proposed ROE I I
I I CAPM
I 1
ECAPM
I I
I I
Risk
Premium
I I
8.50% 9.00% 9.50% 10.00% 10.50% 11.00% 11.50% 12.00% 12.50%
6 As shown, the range of results across all methodologies
7 is wide . While it is common to consider multiple models
8 to estimate the cost of equity, it is particularly
9 important when the range of results varies considerably
10 across methodologies .
2 See also Exhibit No. 5.
Bulkley, Di 5
Rocky Mountain Power

1 Q. Are prospective capital market conditions expected to
2 affect the results of the cost of equity analyses for
3 the Company during the period in which the rates
4 established in this proceeding will be in effect?
5 A. Yes . Capital market conditions are expected to affect
6 the results of the cost of equity estimation models .
7 Specifically:
8 • Long-term interest rates have increased
9 substantially over the past two years and are
10 expected to remain relatively high at least over
11 the next year in response to inflation.
12 • Since (i) utility dividend yields are less
13 attractive than the risk-free rates of government
14 bonds; (ii) interest rates are expected to remain
15 near current levels over the next year, and (iii)
16 utility stock prices are inversely related to
17 changes in interest rates; utility share prices may
18 remain depressed.
19 • Rating agencies have responded to the risks of the
20 utility sector, citing factors including elevated
21 capital expenditures, interest rates, and inflation
22 that create pressures for customer affordability
23 and prompt rate recovery, and have noted the
24 importance of regulatory support in their current
25 outlooks .
26 • Similarly, equity analysts have noted the increased
27 risk for the utility sector as a result of elevated
28 interest rates and expect the sector to
29 underperform in 2024 .
30 • Consequently, it is important to consider that if
31 utility share prices decline, the results of the
32 DCF model, which relies on current utility share
33 prices, would understate the cost of equity during
34 the period that the Company' s rates will be in
35 effect .
Bulkley, Di 6
Rocky Mountain Power

1 It is appropriate to consider all of these factors
2 when estimating a reasonable range of the
3 investor-required cost of equity and the reasonableness
4 of the Company' s proposed ROE .
5 Q. What is your recommended ROE for the Company in this
6 proceeding?
7 A. Considering the analytical results of the market-based
8 cost of equity models and current and prospective
9 capital market conditions, I conclude that an ROE in the
10 range of 10 . 25 percent to 11 . 25 percent is reasonable .
11 Based on the Company' s regulatory, business, and
12 financial risk relative to the proxy group, I conclude
13 that PacifiCorp has significantly greater risk than the
14 proxy group companies and therefore an ROE at the higher
15 end of the range of results is reasonable . However, the
16 Company is requesting a return on equity at the low end
17 of my range; 10 . 30 percent, which takes into
18 consideration the effects of inflation on its customers .
19 Q. Is the Company' s requested capital structure reasonable?
20 A. Yes . The Company' s proposed equity ratio of 50 percent
21 is well within the range of the actual capital structures
22 of the utility operating subsidiaries of the proxy group
23 companies . Further, the Company' s proposed equity ratio
24 is reasonable considering that credit rating agencies
25 have identified in their outlook for the utility sector
Bulkley, Di 7
Rocky Mountain Power

1 significant risks such as elevated interest rates and
2 inflation, record levels of capital spending, and the
3 need to fund capital spending in a credit supportive
4 manner.
5 IV. REGULATORY GUIDELINES
6 Q. Please describe the principles that guide the
7 establishment of the cost of capital for a regulated
8 utility.
9 A. The U. S . Supreme Court' s precedent-setting Hope and
10 Bluefield cases established the standards for
11 determining the fairness or reasonableness of a
12 utility' s allowed ROE . Among the standards established
13 by the Court in those cases are : (1) consistency with
14 other businesses having similar or comparable risks; (2)
15 adequacy of the return to support credit quality and
16 access to capital; and (3) the principle that the result
17 reached, as opposed to the methodology employed, is the
18 controlling factor in arriving at just and reasonable
19 rates . 3
20 Q. Has the Commission provided similar guidance in
21 establishing the appropriate return on common equity?
22 A. Yes . In a 2010 RMP rate case, the Commission findings
23 were based on the standards established in Hope and
24 Bluefield:
3 Bluefield, 262 U.S. at 692-93; Hope, 320 U.S. at 603.
Bulkley, Di 8
Rocky Mountain Power

1 The standards for determining a fair cost of
2 common equity for a regulated utility have
3 been framed by two decisions of the U. S .
4 Supreme Court : Bluefield Water Works &
5 Improvement Co. v. Public Serv. Commission of
6 West Virginia, 262 U. S . 679 (1923) and
7 Federal Power Commission v. Hope Natural Gas
8 Co. , 320 U. S . 591 (1944) . The standards to be
9 considered provide that the authorized return
10 should: (1) be sufficient to maintain
11 financial integrity; (2) be sufficient to
12 attract capital under reasonable terms; and
13 (3) be commensurate with returns investors
14 could earn by investing in other enterprises
15 of comparable risk. 4
16
17 This guidance is in accordance with the Hope and
18 Bluefield decisions and the principles that I employed
19 to estimate the ROE for PacifiCorp, including the
20 principle that an allowed rate of return must be
21 sufficient to enable regulated companies like PacifiCorp
22 to attract capital on reasonable terms . Furthermore, the
23 methodologies that I have employed are consistent with
24 the Commission' s recognition that it is important to
25 consider other information beyond the results of the
26 financial model analysis to establish a rate of return
27 on equity that is reasonable and reflects the
28 investor-required return.
a In the Matter of the Application of PacifiCorp DBA Rocky Mountain Power
for Approval of Changes to its Electric Service Schedules, Case No.
PAC-E-10-07, Order No. 32196, at 10 (Feb. 28, 2011) .
Bulkley, Di 9
Rocky Mountain Power

1 Q. Why is it important for a utility to be allowed the
2 opportunity to earn a return that is adequate to attract
3 capital at reasonable terms?
4 A. An ROE that is adequate to attract capital at reasonable
5 terms enables the Company to continue to provide safe,
6 reliable electricity service while maintaining its
7 financial integrity. That return should be commensurate
8 with returns expected elsewhere in the market for
9 investments of equivalent risk. If it is not, debt and
10 equity investors will seek alternative investment
11 opportunities for which the expected return reflects the
12 perceived risks, thereby inhibiting the Company' s
13 ability to attract capital at reasonable cost, which
14 negatively affects customers .
15 Q. Is a utility' s ability to attract capital also affected
16 by the ROES authorized for other utilities?
17 A. Yes . Utilities compete directly for capital with other
18 investments of similar risk, which include other
19 electric, natural gas, and water utilities nationally.
20 Therefore, the ROE authorized for a utility sends an
21 important signal to investors regarding whether there is
22 regulatory support for financial integrity, dividends,
23 growth, and fair compensation for business and financial
24 risk within that jurisdiction generally, and for that
25 utility particularly. The cost of capital represents an
Bulkley, Di 10
Rocky Mountain Power

1 opportunity cost to investors . If higher returns are
2 available elsewhere for other investments of comparable
3 risk over the same time-period, investors have an
4 incentive to direct their capital to those alternative
5 investments . Thus, an authorized ROE significantly
6 below authorized ROES for other utilities can inhibit
7 the utility' s ability to attract capital for investment.
8 Q. What is the standard for setting the ROE in any
9 jurisdiction?
10 A. The stand-alone ratemaking principle is the foundation
11 of jurisdictional ratemaking. This principle requires
12 that the rates that are charged in any operating
13 jurisdiction be for the costs incurred in that
14 jurisdiction. The stand-alone ratemaking principle
15 ensures that customers in each jurisdiction only pay for
16 the costs of the service provided in that jurisdiction,
17 which is not influenced by the business operations in
18 other operating companies . In order to maintain this
19 principle, the cost of equity analysis is performed for
20 an individual operating company as a stand-alone entity.
21 As such, I have evaluated the investor-required return
22 for PacifiCorp' s electric operations in Idaho .
Bulkley, Di 11
Rocky Mountain Power

1 Q. Has the Commission considered the authorized ROEs in
2 other jurisdictions?
3 A. Yes . In RMP' s 2010 case, the Commission relied on Staff' s
4 analysis of comparable earnings to determine the
5 appropriate ROE for RMP: "The comparable earnings method
6 evaluates returns earned by other companies, including
7 utilities, to quantify an investor' s expected return,
8 taking into account the risks associated with a
9 particular investment. 115 The earnings of other utilities
10 are based on their ROES .
11 Q. Does the fact that the Company is a subsidiary of BHE,
12 a publicly-traded company, affect your analysis?
13 A. No . In this proceeding, consistent with stand-alone
14 ratemaking principles, it is appropriate to establish
15 the cost of equity for the Company, not its
16 publicly-traded entity, BHE . More importantly, however,
17 it is appropriate to establish a cost of equity and
18 capital structure that provide the Company the ability
19 to attract capital on reasonable terms on a stand-alone
20 basis and within BHE .
s In the Matter of the Application of PacifiCorp dba Rocky Mountain
Power for Approval of Changes to its Electric Service Schedules, Case
No. PAC-E-10-07, Order No. 32196, at 10 (Feb. 28, 2011) .
Bulkley, Di 12
Rocky Mountain Power

1 Q. Are the regulatory framework and the authorized ROE and
2 equity ratio important to the financial community?
3 A. Yes . The regulatory framework is one of the most
4 important factors in investors' assessments of risk.
5 Specifically, the authorized ROE and equity ratio for
6 regulated utilities is very important for determining
7 the degree of regulatory support for supporting a
8 utility' s creditworthiness and financial stability in
9 the jurisdiction. To the extent that authorized returns
10 in a jurisdiction are lower than the returns that have
11 been authorized more broadly, such actions are
12 considered by both debt and equity investors in the
13 overall risk assessment of the regulatory jurisdiction
14 in which the company operates .
15 Q. Are you aware of any utilities that have experienced a
16 credit rating downgrade and/or a negative market
17 response related to the financial effects of a rate case
18 decision?
19 A. Yes . There are numerous examples in which utilities
20 have experienced a negative market response related to
21 the financial effects of a rate decision, including
22 credit rating downgrades and material stock price
23 declines . For example, ALLETE, Inc. , 6 CenterPoint Energy
6 Moody' s Investors Service, Credit Opinion: ALLETE, Inc. Update
following downgrade, at 3 (Apr. 3, 2019) .
Bulkley, Di 13
Rocky Mountain Power

1 Houston Electric, 7 and Pinnacle West Capital Corporation
2 ("PNW") 8 each received credit rating downgrades
3 following rate case decisions in the past few years for
4 reasons that included below average authorized ROES .
5 The most recent example is the decisions by the Illinois
6 Commerce Commission ("ICC") in mid-December 2023 that
7 rejected the multiyear grid plan proposals and
8 authorized lower-than-expected ROEs for both Ameren
9 Illinois Co. ("Ameren IL") 9 and Commonwealth Edison Co .
10 ("ComEd") . 10 Specifically, the ICC authorized an ROE for
11 Ameren IL of 8 . 72 percent and 8 . 905 percent for ComEd,
12 which were significant reductions from the
Fitch Ratings, Fitch Downgrades CenterPoint Energy Houston Electric to
BBB+; Affirms CNP; Outlooks Negative (Feb. 19, 2020) .
8 S&P Capital IQ Pro; Fitch Ratings, Fitch Downgrades Pinnacle West
Capital & Arizona Public Service to 'BBB+' ; Outlooks Remain Negative
(Oct. 12, 2021) ; Moody's Investors Service, Rating Actions: Moody's
downgrades Pinnacle West to Baal and Arizona Public Service to A3;
outlook negative (Nov. 17, 2021) .
9 Illinois Commerce Commission on Its Own Motion v. Ameren Company d/b/a
Ameren Illinois, Order Requiring Ameren Illinois Company to File an
Initial Multi-Year Integrated Grid Plan and Initiating Proceeding to
Determine Whether the Plan is Reasonable and Complies with the Public
Utilities Act, Ameren Illinois Company d/b/a Ameren Illinois, Petition
for Approval of a Multi-Year Rate Plan Pursuant to 220 ILCS 5/16-
108.18, Docket Nos. 22-0487, 23-0082 (cons. ) , Order (Dec. 14, 2023)
("Ameren Order") , Amendatory Order (Jan. 17, 2024) .
io Illinois Commerce Commission on Its Own Motion v. Commonwealth Edison
Company, Order Requiring Commonwealth Edison Company to File an Initial
Multi-Year Integrated Grid Plan and Initiating Proceeding to Determine
Whether the Plan is Reasonable and Complies with the Public Utilities
Act, Commonwealth Edison Company, Verified Petition for Approval of a
Multi-Year Rate Plan Under Section 16-108 of the Public Utilities Act,
Docket Nos. 22-0486, 23-0055 (cons. ) , Order (Dec. 14, 2023) ("ComEd
Order") , Amendatory Order (Jan. 10, 2024) .
Bulkley, Di 14
Rocky Mountain Power

1 Administrative Law Judge' s ("ALJ") recommendations of
2 9 . 24 percent and 9 . 28 percent, respectively. "
3 Q. How did the market respond to the ICC' s decisions for
4 these utilities?
5 A. While the Standard & Poor' s ("S&P") 500 Index was
6 increasing, the share prices of the parent companies of
7 both Ameren IL and ComEd (i . e. , Ameren Corp. and Exelon
8 Corp. , respectively) each dropped more than 7 percent on
9 December 14, 2023 after the ICC' s decision, and declined
10 again by more than 4 . 4 percent and 6 . 4 percent the
11 following day, respectively. 12 As of the close on
12 January 5, 2023, Ameren Corp. ' s and Exelon Corp. ' s stock
13 prices were 8 . 9 percent and 11 . 4 percent, respectively,
14 below where their stock prices closed on
15 December 13, 2023, or the day immediately prior to the
16 ICC' s decisions . 13
17 In addition, the reactions of equity analysts were
18 universally negative, and questioned whether the parents
19 of both Ameren IL and ComEd (i . e. , Ameren Corp. and
20 Exelon Corp. , respectively) will shift their capital
21 spending out of the jurisdiction as a result of the
11 Ameren Order at 222, 372-374, 398, and 400 (Dec. 14, 2023) ; ComEd Order
at 320, 470-472, 515, 517 (Dec. 14, 2023; see also, Allison Good,
Ameren, Exelon shares fall after Illinois regulators reject grid plans,
Platts, (Dec. 15, 2023) .
lz Yahoo! Finance.
13 Ameren Corp.' s stock price closed at $81.32 on December 13, 2023, and
$74.05 on January 5, 2023. Exelon Corp.Is stock price closed at $41.00
on December 13, 2023, and $36.31 on January 5, 2023.
Bulkley, Di 15
Rocky Mountain Power

1 uncertainty associated with the multiyear rate plan and
2 low authorized ROES . For example :
3 • Barclays characterized the ICC' s ROE authorizations
4 as "draconian" and "one of the lowest awarded in
5 recent memory, especially in an elevated interest
6 rate and cost of capital environment. 1114 Barclays
7 also stated it found it hard to believe utilities
8 "can deploy capital under the same magnitude on the
9 updated grid plans to be filed, especially under
10 the current proposed ROE framework. "
11 • In its assessment of the impact on Exelon, the
12 parent of ComEd, UBS stated that, " [t] he actions
13 taken by the ICC today call into question, in our
14 view, the regulatory backdrop in which EXC
15 operates . "15
16 • Wells Fargo stated that it was not mincing words,
17 and that the ICC' s orders were "onerous" and that :
18 We now view IL as one of the worst
19 regulatory jurisdictions in the U. S .
20 (nipping at CT ' s heels) . We think the
21 totality of the recent orders suggest
22 that the regulatory balancing act between
23 customers and investors is currently
24 heavily skewed toward customers . As a
25 result, we wonder if AEE & EXC will
26 allocate capital away from IL. Keep in
27 mind, IL represents -250 of both AEE ' s &
28 EXC' s total rate base . "16
29 • In its evaluation of Ameren IL, Bank of America
30 ("BofA") Securities characterized the ICU s
31 decision as "punitive" and stated that it was a
32 surprise based on numerous conversations with
33 investors that believed the ICC may authorize an
34 ROE above the ALJ' s recommendation, not
35 substantially lower, and that the downside surprise
36 was one of the biggest in recent memory for their
14 Barclays, AEE/EXC: Coal Stocking-Stuffer in Illinois (Dec. 14, 2023) .
is UBS, First Read Exelon Corp. , Negative Rate Case Outcome - Rating and
PT Under Review (Dec. 14, 2023) .
11 Wells Fargo, The ICC Delivers a Lump of Coal for AEE & EXC
(Dec. 14, 2023)
Bulkley, Di 16
Rocky Mountain Power

1 regulated utility coverage . 17 While BofA Securities
2 acknowledged that Ameren IL represents less than 20
3 percent of Ameren Corp. ' s consolidated rate base,
4 it will nonetheless need to offsets or capital
5 expenditures elsewhere in order to hit its earnings
6 growth rate targets . 18
7 • After the decisions, Guggenheim questioned, "Is
8 Illinois Becoming the Next Connecticut?"
9 Guggenheim noted that investors questioned whether
10 Illinois was "slowly becoming a CT-esque
11 jurisdiction, " and that equity and debt holders are
12 going to be wary of Illinois as a jurisdiction going
13 forward and that the ICC is "simply sending a
14 negative message to investors . "19
15 Also, after the ICC' s decisions, Regulatory
16 Research Associates ("RRA") lowered its rating of the
17 Illinois regulatory jurisdiction from Average/2 to
18 Average/3 due to the "concerning pattern of restrictive"
19 rate actions in the state . 20
20 Q. What are your conclusions regarding regulatory
21 guidelines?
22 A. The ratemaking process is premised on the principle
23 that, for investors and companies to commit the capital
24 needed to provide safe and reliable utility services, a
25 utility must have a reasonable opportunity to recover
26 the return of, and the market-required return on, its
27 invested capital . Accordingly, the Commission' s order
17 BofA Securities, Ameren Corporation, Illinois delivers downside
surprise (Dec. 15, 2023) .
is Id.
i9 Guggenheim, IL: Is Illinois Becoming the Next Connecticut? To Be
Determined, but Taking a Neutral Stance on the State (Dec. 15, 2023) .
20 Russell Ernst, Concerning pattern of restrictive Ill. rate actions
prompts rankings revision, Market Intelligence (Dec. 18, 2023) .
Bulkley, Di 17
Rocky Mountain Power

1 in this proceeding should establish rates that provide
2 the Company with a reasonable opportunity to earn an ROE
3 that is : (1) adequate to attract capital at reasonable
4 terms; (2) sufficient to ensure its financial integrity;
5 and (3) commensurate with returns on investments in
6 enterprises with similar risk. It is important for the
7 ROE authorized in this proceeding to take into
8 consideration current and projected capital market
9 conditions, as well as investors' expectations and
10 requirements for both risks and returns . Because
11 utility operations are capital-intensive, regulatory
12 decisions should enable the utility to attract capital
13 at reasonable terms under a variety of economic and
14 financial market conditions . Providing the opportunity
15 to earn a market-based cost of capital supports the
16 financial integrity of the Company, which is in the
17 interest of both customers and shareholders .
18 V. CAPITAL MARKET CONDITIONS
19 Q. Why is it important to analyze capital market
20 conditions?
21 A. The models used to estimate the cost of equity rely on
22 market data and thus the results of those models can be
23 affected by prevailing market conditions at the time the
24 analysis is performed. While the ROE established in a
25 rate proceeding is intended to be forward-looking, the
Bulkley, Di 18
Rocky Mountain Power

1 analyst uses current and projected market data,
2 including stock prices, dividends, growth rates, and
3 interest rates, in the cost of equity estimation models
4 to estimate the investor-required return for the subject
5 company.
6 Analysts and regulatory commissions recognize that
7 current market conditions affect the results of the cost
8 of equity estimation models . As a result, it is
9 important to consider the effect of the market
10 conditions on these models when determining an
11 appropriate range for the ROE, and the ROE to be used
12 for ratemaking purposes for a future period. If
13 investors do not expect current market conditions to be
14 sustained in the future, it is possible that the cost of
15 equity estimation models will not provide an accurate
16 estimate of investors' required return during that rate
17 period. Therefore, it is important to consider
18 projected market data to estimate the return for that
19 forward-looking period.
20 Q. What factors are affecting the cost of equity for
21 regulated utilities in the current and prospective
22 capital markets?
23 A. The cost of equity for regulated utility companies is
24 affected by several factors in the current and
25 prospective capital markets, including: (1) changes in
Bulkley, Di 19
Rocky Mountain Power

1 monetary policy; (2) relatively high inflation; and (3)
2 increased interest rates that are expected to remain
3 relatively high over the next few years . These factors
4 affect the assumptions used in the cost of equity
5 estimation models .
6 A. Inflationary Expectations in Current and
7 Projected Capital Market Conditions
8 Q. What has the level of inflation been over the past few
9 years?
10 A. As shown in Figure 2, core inflation increased
11 steadily beginning in early 2021, rising from 1 . 41
12 percent in January 2021 to a high of 6 . 64 percent in
13 September 2022, which was the largest 12-month
14 increase since 1982 . 21 Since that time, while core
15 inflation has declined in response to the Federal
16 Reserve' s monetary policy, it continues to remain
17 significantly above the Federal Reserve' s target level
18 of 2 . 0 percent .
19 In addition, I also considered the ratio of
20 unemployed persons per job opening, which is currently
21 0 . 7 and has been consistently below 1 . 0 since 2021,
zl Figure 2 presents the year-over-year ("YOY") change in core inflation,
as measured by the Consumer Price Index ("CPI") excluding food and
energy prices as published by the Bureau of Labor Statistics. I
considered core inflation because it is the preferred inflation
indicator of the Federal Reserve for determining the direction of
monetary policy. Core inflation is preferred by the Federal Reserve
because it removes the effect of food and energy prices, which can be
highly volatile.
Bulkley, Di 20
Rocky Mountain Power

1 despite the Federal Reserve' s accelerated policy
2 normalization. This metric indicates sustained strength
3 in the labor market . Further, the January 2024 jobs
4 report showed that the U. S economy added 353, 000 jobs in
5 that month, which was significantly higher than the
6 expectation, demonstrating the strength of the economy. 22
7 Given the Federal Reserve' s dual mandate of maximum
8 employment and price stability, the continued increased
9 levels of core inflation coupled with the strength in
10 the labor market has resulted in the Federal Reserve' s
11 sustained focus on the priority of reducing inflation.
22 CNN Business, Another shockingly good jobs report shows America's
economy is booming (Feb. 2, 2024) .
Bulkley, Di 21
Rocky Mountain Power

1 Figure 2 : Core Inflation and Unemployed Persons-to-
2 Job Openings, January 2019 to April 202423
7.00% 6
—CPI-Less Food&Energy
—Unemployed persons per job opening ratio
L 6.00%
„ 5
w A
b
0 5.00% I '
w 4
11
w
4.00% I o
a
� I 1 30
a 3.00% I d
U o
U 2 I o
..
a a
Q 2.00% `
U `
0 1.00%
J
0.00% 0
rl N ti H ti ti N N N N N N N N N N N N N N N N N N N N N N N N N N
R d O R R G�i O R Gai O tLd '� Y O R R R O M
z �' m 'z ti m z h m z
3 Q. What are the expectations for inflation over the near-
4 term?
5 A. The Federal Reserve has indicated that it expects
6 inflation will remain elevated above its target level
7 until 2026 and that the extent to which it maintains the
8 restrictive monetary policy will depend on market
9 indicators going forward. Over the last several months
10 the Federal Open Market Committee ("FOMC") has been
11 clear that they intend to rely on market data before
23 Bureau of Labor Statistics.
Bulkley, Di 22
Rocky Mountain Power

1 making any changes to interest rates . In the FOMC' s
2 meeting on March 20, 2024, Chairman Powell observed that
3 the FOMC will make their decision "meeting by meeting"
4 and while he believes that it will be appropriate to
5 reduce the Federal Funds rate at some point in 2024, the
6 FOMC is prepared to maintain the current Federal Funds
7 rate range higher for longer if needed to reduce
8 inflation:
9 We know that reducing policy restraint too
10 soon or too much could result in a reversal of
11 the progress we have seen on inflation and
12 ultimately require even tighter policy to get
13 inflation back to 2 percent . At the same time,
14 reducing policy restraint too late or too
15 little could unduly weaken economic activity
16 and employment . In considering any adjustments
17 to the target range for the federal funds
18 rate, the Committee will carefully assess
19 incoming data, the evolving outlook, and the
20 balance of risks . The Committee does not
21 expect it will be appropriate to reduce the
22 target range until it has gained greater
23 confidence that inflation is moving
24 sustainably down toward 2 percent . Of course,
25 we are committed to both sides of our dual
26 mandate, and an unexpected weakening in the
27 labor market could also warrant a policy
28 response . We will continue to make our
29 decisions meeting by meeting. 24
30 Moreover, Atlanta Federal Reserve President Raphael
31 Bostic, who is a voting member of the FOMC in 2024,
32 recently commented that he expects one rate cut in 2024
21 Federal Reserve, Transcript of Chair Powell's Press Conference,
March 20, 2024, p. 3.
Bulkley, Di 23
Rocky Mountain Power

1 but would not rule out the possibility of either two or
2 zero rate cuts depending on the direction of the
3 macroeconomic data. 25 Mr. Bostic' s expectations of one
4 rate cut is less than the three that were forecast at
5 the recent FOMC meeting in March 2024 . Similarly,
6 Federal Reserve Governor Michelle Bowman, also a voting
7 member of the FOMC, recently noted that while it is not
8 her baseline forecast, there is the possibility that
9 rates will need to increase in 2024 to control inflation
10 as she still sees "a number of potential upside risks to
11 inflation" . 26
12 Q. Have there been economic indicators published since the
13 FOMC published the summary of Economic Projections on
14 March 20 , 2024 that indicate strength in the U. S .
15 Economy?
16 A. Yes . Since that time, the following macroeconomic data
17 has been released demonstrating the unexpected strength
18 in the U. S . economy:
19 • U. S . employers added 303, 000 jobs in March, far
20 exceeding economists' expectation of 200, 000 . 27
21 • The unemployment rate declined from 3 . 9 percent
22 in February to 3 . 8 percent in March. 28
25 Jennifer Schonberger, Fed's Bostic still expects 1 rate cut in 2024
but does not rule out 0 or 2, Yahoo! Finance (Apr. 9, 2024) .
26 Jeff Cox, Fed Governor Bowman say additional rate hike could be needed
if inflation stays high, CNBC (Apr. 5, 2024) .
27 See, e.g. , Jeff Cox, Job growth zoomed in March as payrolls jumped by
303,000 and unemployment dropped to 3. 8o, CNBC (Apr. 5, 2024) .
28 Id.
Bulkley, Di 24
Rocky Mountain Power

1 • Average hourly earnings increased 0 . 3 percent in
2 March 2024, up 4 . 1 percent year-over-year
3 ("YoY") . 29
4 • The YoY change in core inflation as measured by
5 the Consumer Price Index ("CPI") excluding food
6 and energy prices was 3 . 8 percent in March 2024
7 exceeding economists' estimates of 3 . 7 percent
8 and equal to the 3 . 8 percent YoY change in core
9 inflation reported in February 2024 . 30
10 Q. What is the market' s expectation about interest rate
11 cuts?
12 A. The market has recognized the strength in the economy
13 and the labor market and has tempered its expectations
14 that regarding how much the FOMC will decrease the
15 federal funds rate in 2024 . The CME Group, which
16 publishes a "FedWatch" probability chart of FOMC
17 activity, reported on April 8, 2024, that federal funds
18 rate futures contracts reflect expectations of
19 approximately 60 basis points in rate cuts this year
20 which is substantially lower than the 150 basis points
21 in rate cuts that were expected in January 2024 . 31 In
22 summary, the market is expecting that interest rates
23 will remain higher for longer than anticipated in at the
24 beginning of 2024 .
29 Id.
31 Jeff Cox, Consumer prices rose 3.5% from a year ago in March, more
than expected, CNBC (Apr. 10, 2024) .
31 Reuters, Fed rate cut expectations for 2024 fall to lowest since
October (Apr. 8, 2024) .
Bulkley, Di 25
Rocky Mountain Power

1 B. The Federal Reserve to Continue Use of Monetary
2 Policy to Address Inflation
3 Q. What policy actions has the Federal Reserve enacted to
4 respond to increased inflation?
5 A. The dramatic increase in inflation has prompted the
6 Federal Reserve to pursue an aggressive normalization of
7 monetary policy, removing the accommodative policy
8 programs used to mitigate the economic effects of
9 COVID-19 . Since the March 2022 FOMC meeting, the Federal
10 Reserve increased the target federal funds rate through
11 a series of increases from a range of 0 . 00 - 0 .25 percent
12 to a range of 5 .25 percent to 5 . 50 percent . While
13 inflation has declined from its peak, it still is above
14 the Federal Reserve' s target of 2 . 0 percent, and
15 therefore, as just noted, the Federal Reserve
16 anticipates maintaining short-term interest rates higher
17 for longer in order to achieve its goal of 2 . 0 percent
18 inflation over the long-run.
Bulkley, Di 26
Rocky Mountain Power

1 C. The Effect of Inflation and Monetary Policy on
2 Interest Rates and the Investor-Required Return
3 Q. Have the yields on long-term government bonds responded
4 to inflation and the Federal Reserve' s normalization of
5 monetary policy?
6 A. Yes . As the Federal Reserve has substantially increased
7 the federal funds rate in response to increased levels
8 of inflation that have persisted for longer than
9 originally projected, longer term interest rates have
10 also increased. As shown in Figure 3, since the Federal
11 Reserve' s December 2021 meeting, the yield on 10-year
12 Treasury bonds has more than tripled, increasing from
13 1 . 47 percent on December 15, 2021 to 4 . 69 percent at the
14 end of April 2024 .
Bulkley, Di 27
Rocky Mountain Power

1 Figure 3 : 10-Year Treasury Bond Yield - January 2021
2 through April 2024
5.00%
4.50% Federal Reserve Meeting
(December 16,2021)
4.00%
3.50%
3.00%
2.50%
2.00%
1.50%
1.00%
0.50%
Ot Ot Ot Ol Ol Ol O O O O O O e-I e-I a—I rl e-I ci N N N N N N m m m m m m v v v
O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O
N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N
'\-I \-I '\-I r\-I e\-I e\-I \-I \-I '\-I '\-I c\-I e\-I e\-I e\-I a\—I \-I e\-I r\-I c\-I c\-I e\-I --I .\-I --I e--I e--I c--I --I --I --I --I '\-I e--I
n O\t '\-I e\-I M l\A n O\l .\-I '\-I M Il
3 Q. How have interest rates and inflation changed since the
4 Company' s last rate case?
5 A. As shown in Figure 4, both short-term and long-term
6 interest rates have increased substantially since both
7 the Company filed and adopted the settlement in its last
8 rate proceeding. Even though inflation has reduced
9 since the Company' s last rate case, long-term interest
10 rates have increased approximately 258 basis points
11 since the settlement filed and approximately 272 basis
12 points since the Commission adopted the settlement in
13 this proceeding.
Bulkley, Di 28
Rocky Mountain Power

1 Figure 4 : Change in Market Conditions Since Company' s Last
2 Rate Case
30-Day Avg
Federal 30 Year Core
Funds Treasury Inflation Requested
Docket Date Rate Bond Yield Rate ROE
Settlement filed- PAC-E-21-07 10/25/2021 0.08% 2.01% 4.59%
Settlement adopted-PAC-E-21-07 12/30/2021 0.08% 1.87% 5.52% 10.20%
Current 4/30/2024 5.33% 4.59% 3.88% 10.30%
3 Q. What have equity analysts said about long-term
4 government bond yields?
5 A. Equity analysts have noted that they expect the yields
6 on long-term government bonds to remain elevated. For
7 example, the consensus estimate of the average yields on
8 the 10-year and 30-year Treasury bonds reported by Blue
9 Chip Financial Forecasts are 4 .22 percent and
10 4 . 48 percent, respectively, through the first quarter of
11 2025 . 32 Therefore, investors expect interest rates to
12 remain elevated for at least the next 15 months . As a
13 result, it is reasonable to expect that if government
14 bond yields remain elevated, the cost of equity will
15 remain materially higher than at the time of the
16 Company' s last rate proceeding.
32 Blue Chip Financial Forecasts, Vol. 42, No. 12, at 2 (Dec. 1, 2023) .
Bulkley, Di 29
Rocky Mountain Power

1 D. Expected Performance of Utility Stocks and the
2 Investor-Required Return on Utility Investments
3 Q. Are utility share prices correlated to changes in the
4 yields on long-term government bonds?
5 A. Yes . Interest rates and utility share prices are
6 inversely correlated, which means that increases in
7 interest rates result in declines in the share prices of
8 utilities and vice versa. For example, Goldman Sachs and
9 Deutsche Bank examined the sensitivity of share prices
10 of different industries to changes in interest rates
11 over the past five years . Both Goldman Sachs and
12 Deutsche Bank found that utilities had one of the
13 strongest negative relationships with bond yields (i . e. ,
14 increases in bond yields resulted in the decline of
15 utility share prices) . 33
16 Q. How did the utility sector perform in 2023?
17 A. In 2023, utility stocks have significantly
18 underperformed the broader market, as Treasury bond
19 yields have increased to levels greater than the
20 dividend yields of utility stocks . For example, as shown
21 in Figure 5, since January 1, 2023, the yield on the
22 30-year Treasury bond has increased by nearly 91 basis
23 points, while the share prices for the
24 vertically-integrated electric utilities included in my
33 Justina Lee, Wall Street Is Rethinking the Treasury Threat to Big Tech
Stocks, Bloomberg.com (Mar. 11, 2021) .
Bulkley, Di 30
Rocky Mountain Power

1 proxy group (discussed in the following section) have
2 declined by 11 . 56 percent and the S&P 500 Index has
3 increased approximately 31 . 55 percent . The stock price
4 underperformance for the utility sector indicates that
5 the cost of equity has increased since the Company' s
6 last rate proceeding.
7 Figure 5 : Relative Performance of the Proxy Group and the
8 S&P 500 Index, January 2023 through April 202434
40.00 5.50
—Proxy Group-Index Value(Daily)(%)
30.00 —S&P 500 Price Return-Index Value(Daily)(%) 5.00
—30y US T-Bond-Rate Value(Daily) ^
e
20.00 d
4.50
e .o
e D 10.00 °e
� W
a
J4.00 .'
u0.00 01
a 3.50
A
-10.00 �
e
M
-20.00 3.00
-30.00 2.50
N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N
O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O
N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N
y MZZ N z N N Ii-'� N N r N N N N N y M N N 7 N
9 Q. How do equity analysts expect the utilities sector to
10 perform in 2024?
11 A. Equity analysts have recently projected the continued
12 underperformance of the utility sector, and have not
13 changed their views on the sector:
14 • Fidelity Investments classifies the utility sector
15 as underweight; 35
34 S&P Capital IQ Pro.
35 Fidelity Investments, Fourth Quarter 2023 Investment Research Update
(Oct. 19, 2023)
Bulkley, Di 31
Rocky Mountain Power

1 • Bank of America recently noted that they are "not
2 so constructive on [u] tilities" given that the
3 dividend yields for utilities are below both the
4 yields available on long- and short-term treasury
5 bonds; 36
6 • UBS recently classified the 11 sectors of the S&P
7 500 as most preferred, natural, and least preferred
8 for 2024 with the utility sector being classified
9 as one of UBS' s three least preferred sectors
10 (i . e. , utilities, materials, and real estate; 37 and
11 • Professional investors surveyed by Barron's in its
12 most recent Big Money poll selected the utility
13 sector as one of the four equity sectors that they
14 liked the least over the next twelve months,
15 indicating they are projecting that utilities will
16 underperform the broader market in 2024 . 38
17 Finally, while Ned Davis Research classified the
18 utility sector as market weight, they cited risks going
19 forward that could result in a downgrade of their rating
20 to underweight :
21 Key drivers : Falling yields have made
22 Utilities' dividend yield more attractive, but
23 the sector still yields less than the 10-year
24 Treasury. At the end of December, only 400 of
25 the sector' s stocks yielded more than the
26 10-year Treasury, 0 . 6 standard deviations
27 below its long-term average . Lower interest
28 rates or a continuation of the sector' s
29 decline in price will be needed to attract
30 dividend-hungry investors .
36 Julien Dumoulin-Smith, et. al. , US Electric Utilities & IPPs: As the
leaves fall, preparing for Autumn utility outlook. Macro still has
potholes. , BofA Securities (Sept. 6, 2023) .
37 Jason Capul, UBS Prefers Info Tech, Consumer Staples, and Energy in
2024, Seeking Alpha (Dec. 12, 2023) ,
https://seekingalpha.com/news/4045578-ubs-outlines-its-sector-
outlook-and-offers-a-year-end-sp-price-target.
38 Nicolas Jasinski, Big Money Pros Are Split on the Outlook for Stocks.
But They Are Fans of Bonds, Barron' s (Oct. 27, 2023) .
Bulkley, Di 32
Rocky Mountain Power

1 Indicators to watch: Utilities saw slight
2 sector model score deterioration in December,
3 as one of its relative overbought/oversold
4 indicators flipped from bullish to neutral
5 during the month. Utilities starts 2024 tied
6 with Consumer Staples and Financials for the
7 lowest composite scores among all sectors . We
8 see the possibility for more defensive
9 leadership in the new year, but the sector
10 model has us much closer to a downgrade of the
11 sector than an upgrade . 39
12 Q. Why do equity analysts expect the utility sector to
13 continue to underperform over the near-term?
14 A. Equity analysts expect the utility sector to continue to
15 underperform given that, on average, the yields for the
16 utility sector remain lower than the yields on long-term
17 government bonds . To illustrate this point, I examined
18 the difference between the dividend yields of utility
19 stocks and the yields on long-term government bonds from
20 January 2010 through April 2024 (i . e. , yield spread) . I
21 selected the dividend yield on the S&P Utilities Index
22 as the measure of the dividend yields for the utility
23 sector and the yield on the 10-year Treasury bond as the
24 estimate of the yield on long-term government bonds .
25 As shown in Figure 6, the recent significant
26 increase in long-term government bonds yields has
27 resulted in the yield on long-term government bonds
28 exceeding the dividend yields of utilities . The yield
39 Ned Davis Research, Risk-on leadership closes out 2023, at 18 (Jan. 4,
2024)
Bulkley, Di 33
Rocky Mountain Power

1 spread as of April 30, 2024, was negative 1 . 36 percent,
2 meaning that the yield on the 10-year Treasury bond
3 exceeds the dividend yield for the S&P Utilities Index.
4 However, the long-term average yield spread from 2010 to
5 present is 1 . 18 percent . Therefore, the current yield
6 spread is well below the long-term average . Because of
7 the fact that the yield spread is currently well below
8 the long-term average, and the expectation that interest
9 rates will remain relatively high through at least the
10 next year, it is reasonable to conclude that the utility
11 sector will most likely underperform over the near-term.
12 This is because investors that purchased utility stocks
13 as an alternative to the lower yields on long-term
14 government bonds would otherwise be inclined to rotate
15 back into government bonds, particularly as the yields
16 on long-term government bonds remain elevated, thus
17 resulting in a decrease in the share prices of utilities .
Bulkley, Di 34
Rocky Mountain Power

1 Figure 6: Spread between the S&P Utilities Index Dividend
2 Yield and the 10-year Treasury Bond Yield, January 2010 -
3 April 202440
4.00%
3.00%
2.00
y
v LOW/,
v
0.00'%
-1.00%
-2.00%
N N N N N N N N N
O O O O O O O O C O O O O O O C O O O O O O C O O O O O O
N N N N N N N N N N N N N N N N N N N N N N N N N N N N N
ti r ti r i r ti h � h - 1� ti r i � - r .•i 1� ti r � r i r .•i 1� i
4 E. Conclusion
5 Q. What are your conclusions regarding the effect of
6 current market conditions on the cost of equity for the
7 Company?
8 A. As shown in Figure 4, currently interest rates are 272
9 basis points higher than when the decision was issued in
10 the Company' s last rate proceeding. Further, as shown in
11 Figure 5, the utilities sector has continued to
12 underperform the broader market . In addition,
13 macroeconomic indicators demonstrate that the economy is
14 strong, which has caused the FOMC to maintain its current
15 stance on monetary policy. Therefore, at this time, the
16 market is not expecting a near term rate cut . Given the
40 S&P Capital IQ Pro and Bloomberg Professional.
Bulkley, Di 35
Rocky Mountain Power

1 aforementioned factors, the cost of equity is
2 directionally higher than at the time that the
3 Commission decided on the Company' s ROE in the 2021 rate
4 case .
5 VI . PROXY GROUP SELECTION
6 Q. Please provide a brief profile of PacifiCorp.
7 A. PacifiCorp is an indirect, wholly-owned subsidiary of
8 BHE, and provides electric utility service to
9 approximately 2 . 1 million residential, commercial and
10 industrial customers in Utah, Oregon, Wyoming,
11 Washington, Idaho and California. 41 As of
12 December 31, 2023, the Company provided approximately
13 3, 500 gigawatt-hours of electric sales in Idaho. The
14 Company' s electric operations in Idaho represented
15 approximately 6 percent of PacifiCorp' s electric sales
16 in 2023 . 42 PacifiCorp currently has an investment grade
17 long-term rating of BBB+ (Outlook: Negative) from S&P
18 and Baal (Outlook: Stable) from Moody' s . 43 The Company
19 is not separately rated from PacifiCorp.
41 PacifiCorp SEC Form 10-K, December 31, 2023, at 3.
42 PacifiCorp SEC Form 10-K, December 31, 2023, at 3.
43 S&P Global Ratings, PacifiCorp Ratings Affirmed Following Archie Creek
Settlement; Outlook Negative (Dec. 12, 2023) ; Moody's Investors,
Issuer Comment, PacifiCorp, Dec. 8, 2023.
Bulkley, Di 36
Rocky Mountain Power

1 Q. Why have you used groups of proxy companies to estimate
2 the Cost of Equity for PacifiCorp?
3 A. In this proceeding, the cost of equity is being estimated
4 for an electric utility company that is not itself
5 publicly traded. Because the cost of equity is a
6 market-based concept and because the Company' s
7 operations do not make up the entirety of a publicly
8 traded entity, it is necessary to establish a group of
9 companies that is both publicly traded and comparable to
10 the Company in certain fundamental business and
11 financial respects to serve as its `proxy" for purposes
12 of estimating the cost of equity.
13 Even if the Company was a publicly-traded entity, it
14 is possible that transitory events could bias its market
15 value over a given period. A significant benefit of
16 using a proxy group is that it moderates the effects of
17 unusual events that may be associated with any one
18 company. The proxy companies used in my analyses all
19 possess a set of operating and risk characteristics that
20 are substantially comparable to the Company, and thus
21 provide a reasonable basis to estimate the appropriate
22 cost of equity for the Company.
Bulkley, Di 37
Rocky Mountain Power

1 Q. How did you select the companies in your proxy group?
2 A. I began with the group of 36 companies that Value Line
3 classifies as Electric Utilities and applied the
4 following screening criteria to select companies that :
5 • pay consistent quarterly cash dividends, because
6 companies that do not cannot be analyzed using the
7 DCF model;
8 • have investment grade long-term issuer ratings from
9 S&P and/or Moody' s;
10 • have positive long-term earnings growth forecasts
11 from at least two utility industry equity analysts;
12 • own regulated generation assets that are in rate
13 base;
14 • derive more than 40 percent of its megawatt-hour
15 sales from its owned generation facilities;
16 • derive more than 60 percent of their total
17 operating income from regulated electric
18 operations; and,
19 • were not parties to a merger or transformative
20 transaction during the analytical periods relied
21 on.
22 Q. What is the composition of your proxy group?
23 A. Applying these screening criteria results in a proxy
24 group consisting of the companies shown in Figure 7 (as
25 well as in Exhibit No . 6)
Bulkley, Di 38
Rocky Mountain Power

1 Figure 7 : Proxy Group
Company Ticker
ALLETE, Inc. ALE
Alliant Energy Corporation LNT
Ameren Corporation AEE
American Electric Power Company,Inc. AEP
Avista Corporation AVA
CMS Energy Corporation CMS
Duke Energy Corporation DUK
Entergy Corporation ETR
Evergy,Inc. EVRG
IDACORP,Inc. IDA
NextEra Energy,Inc. NEE
NorthWestern Corporation NWE
OGE Energy Corporation OGE
Pinnacle West Capital Corporation PNW
Portland General Electric Company POR
Southern Company SO
Xcel Energy Inc. XEL
2 VII . COST OF EQUITY ESTIMATION
3 Q. Please briefly discuss the ROE in the context of a
4 regulated utility.
5 A. The rate of return for a regulated utility is the
6 weighted average cost of capital, in which the costs of
7 the individual sources of capital are weighted by their
8 respective proportion (i . e. , book values) in the
9 utility' s capital structure . The ROE is the cost rate
10 applied to the equity capital in calculating the rate
11 of return. While the costs of debt and preferred stock
12 can be directly observed, the cost of equity is market-
13 based and, therefore, must be estimated based on
14 observable market data.
Bulkley, Di 39
Rocky Mountain Power

1 Q. How is the required cost of equity determined?
2 A. The required cost of equity is estimated by using
3 analytical techniques that rely on market-based data to
4 quantify investor expectations regarding equity returns,
5 adjusted for certain incremental costs and risks .
6 Informed judgment is then applied to determine where the
7 company' s cost of equity falls within the range of
8 results produced by multiple analytical techniques . The
9 key consideration in determining the cost of equity is
10 to ensure that the methodologies employed reasonably
11 reflect investors' views of the financial markets in
12 general, as well as the subject company (in the context
13 of the proxy group) , in particular.
14 Q. What methods did you use to estimate the cost of equity
15 for the Company in this proceeding?
16 A. I consider the results of the constant growth form of
17 the DCF model, the CAPM, the ECAPM, and a BYRP analysis .
18 A reasonable cost of equity estimate appropriately
19 considers alternative methodologies and the
20 reasonableness of their individual and collective
21 results .
22 Q. Is it important to use more than one analytical approach?
23 A. Yes . Because the cost of equity is not directly
24 observable, it must be estimated based on both
25 quantitative and qualitative information. When faced
Bulkley, Di 40
Rocky Mountain Power

1 with the task of estimating the cost of equity, analysts
2 and investors are inclined to gather and evaluate as
3 much relevant data as reasonably can be
4 analyzed. Several models have been developed to
5 estimate the cost of equity, and I use multiple
6 approaches to estimate the cost of equity. As a
7 practical matter, however, all of the models available
8 for estimating the cost of equity are subject to limiting
9 assumptions or other methodological
10 constraints . Consequently, many well-regarded finance
11 texts recommend using multiple approaches when
12 estimating the cost of equity. For example, Copeland,
13 Koller, and Murrin99suggest using the CAPM and Arbitrage
14 Pricing Theory model, while Brigham and Gapenski45
15 recommend the CAPM, DCF, and BYRP approaches .
16 Further, the recent changes in market conditions
17 discussed previously highlight the benefit of using
18 multiple models since each model relies on different
19 assumptions, certain of which better reflect current and
20 projected market conditions at different times . For
21 example, the CAPM and ECAPM analyses rely directly on
22 interest rates as an assumption in the models and
44 Tom Copeland, Tim Koller and Jack Murrin, Valuation: Measuring and
Managing the Value of Companies, at 214 (311 ed. 2000) .
45 Eugene Brigham and Louis Gapenski, Financial Management: Theory and
Practice, at 341 (7t' ed. 1994) .
Bulkley, Di 41
Rocky Mountain Power

1 therefore may more directly reflect the market
2 conditions expected when the Company' s rates are in
3 effect . Accordingly, it is important to use multiple
4 analytical approaches to ensure that the cost of equity
5 results reflect market conditions that are expected
6 during the period that the Company' s rates will be in
7 effect .
8 Q. Has the Commission recognized that it is important to
9 consider the results of multiple ROE estimation models?
10 A. Yes . In RMP' s 2010 rate case, the Commission considered
11 multiple models, including DCF, comparable earnings,
12 risk premium analysis, and the capital asset pricing
13 model . 46
14 A. DCF Model
15 Q. Please describe the DCF approach.
16 A. The DCF approach is based on the theory that a stock' s
17 current price represents the present value of all
18 expected future cash flows . In its most general form,
19 the DCF model is expressed as follows :
_ D1 + DZ D.
P° (l+k) �l+k�2 +...+(l+ky [1]
46 In the Matter of the Application of PacifiCorp dba Rocky Mountain
Power for Approval of Changes to its Electric Service Schedules, Case
No. PAC-E-10-07, Order No. 32196, at 10 (Feb. 28, 2011) .
Bulkley, Di 42
Rocky Mountain Power

1 Where Po represents the current stock price, D1...D- are
2 all expected future dividends, and k is the discount
3 rate, or required ROE . Equation [1] is a standard
4 present value calculation that can be simplified and
5 rearranged into the following form:
k= Do('+g)+g
6 P° [2]
7 Equation [2] is often referred to as the constant
8 growth DCF model in which the first term is the expected
9 dividend yield and the second term is the expected
10 long-term growth rate .
11 Q. What assumptions are required for the constant growth
12 DCF model?
13 A. The constant growth DCF model requires the following
14 four assumptions : (1) a constant growth rate for
15 earnings and dividends; (2) a stable dividend payout
16 ratio; (3) a constant price-to-earnings ratio; and (4)
17 a discount rate greater than the expected growth rate .
18 To the extent that any of these assumptions are violated,
19 considered judgment and/or specific adjustments should
20 be applied to the results .
21 Q. What market data did you use to calculate the dividend
22 yield in your constant growth DCF model?
23 A. The dividend yield in my constant growth DCF model is
24 based on the proxy group companies' current annual
Bulkley, Di 43
Rocky Mountain Power

1 dividend and average closing stock prices over the 30-,
2 90-, and 180-trading days ended April 30, 2024 .
3 Q. Why did you use three averaging periods for stock prices?
4 A. In my constant growth DCF model, I use an average of
5 recent trading days to calculate the term Po in the DCF
6 model to ensure that the cost of equity is not skewed by
7 anomalous events that may affect stock prices on any
8 given trading day. The averaging period should also be
9 reasonably representative of expected capital market
10 conditions over the long term.
11 Q. Did you make any adjustments to the dividend yield to
12 account for periodic growth in dividends?
13 A. Yes . Because utility companies tend to increase their
14 quarterly dividends at different times throughout the
15 year, it is reasonable to assume that dividend increases
16 will be evenly distributed over calendar quarters . Given
17 that assumption, it is reasonable to apply one-half of
18 the expected annual dividend growth rate for purposes of
19 calculating the expected dividend yield component of the
20 DCF model . This adjustment ensures that the expected
21 first-year dividend yield is, on average, representative
22 of the coming twelve-month period, and does not
23 overstate the aggregated dividends to be paid during
24 that time .
Bulkley, Di 44
Rocky Mountain Power

1 Q. Why is it important to select appropriate measures of
2 long-term growth in applying the DCF model?
3 A. In its constant growth form, the DCF model (i . e. ,
4 Equation [2] ) assumes a single long-term growth rate in
5 perpetuity. In order to reduce the long-term growth
6 rate to a single measure, one must assume that the
7 dividend payout ratio remains constant and that earnings
8 per share ("EPS") , dividends per share, and book value
9 per share all grow at the same constant rate . However,
10 over the long run, dividend growth can only be sustained
11 by earnings growth, meaning earnings are the fundamental
12 driver of a company' s ability to pay dividends .
13 Therefore, projected EPS growth is the appropriate
14 measure of a company' s long-term growth. In contrast,
15 changes in a company' s dividend payments are based on
16 management decisions related to cash management and other
17 factors . For example, a company may decide to retain
18 earnings rather than pay out a portion of those earnings
19 to shareholders through dividends . Therefore, dividend
20 growth rates are less likely than earnings growth rates
21 to accurately reflect investor perceptions of a
22 company' s growth prospects . Accordingly, I have
23 incorporated a number of sources of long-term EPS growth
24 rates into the constant growth DCF model .
Bulkley, Di 45
Rocky Mountain Power

1 Q. What sources of long-term growth rates did you rely on
2 in your Constant Growth DCF model?
3 A. My constant growth DCF model incorporates three sources
4 of long-term projected EPS growth rates : (1) Zacks
5 Investment Research ("Zacks") ; (2) Yahoo ! Finance; and
6 (3) Value Line.
7 Q. Why are EPS growth rates the appropriate growth rates to
8 be relied on in the DCF model?
9 A. Earnings are the fundamental driver of a company' s
10 ability to pay dividends; therefore, projected EPS
11 growth is the appropriate measure of a company' s
12 long-term growth. In contrast, changes in a company' s
13 dividend payments are based on management decisions
14 related to cash management and other factors . For
15 example, a company may decide to retain earnings rather
16 than pay out a portion of those earnings to shareholders
17 through dividends . Therefore, dividend growth rates are
18 less likely than earnings growth rates to reflect
19 accurately investor perceptions of a company' s growth
20 prospects .
21 Q. How do you calculate the range of results for the
22 constant growth DCF models?
23 A. I calculate the low-end result for the constant growth
24 DCF model using the minimum growth rate of the three
25 sources (i . e. , the lowest of the Zacks, Yahoo ! Finance,
Bulkley, Di 46
Rocky Mountain Power

1 and Value Line projected EPS growth rates) for each of
2 the proxy group companies . I use a similar approach to
3 calculate a high-end result, using the maximum growth
4 rate of the three sources for each proxy group company.
5 Lastly, I also calculate results using the average EPS
6 growth rate from all three sources for each proxy group
7 company.
8 Q. What are the results of your constant growth DCF models?
9 A. Exhibit No. 7 summarizes the results of the constant
10 growth DCF models . While I also summarize the DCF
11 results using the minimum growth rates, given the market
12 response to the recent ICC decisions for Ameren IL and
13 ComEd as discussed previously, it is evident that the
14 market would not consider these DCF results reflective
15 of the investor-required return, and thus I do not give
16 these DCF results any material weight at this time .
17 Figure 8 : Constant Growth DCF Model Results
Constant Growth DCF
Minimum Average Maximum
Growth Rate Growth Rate Growth Rate
Mean Results:
30-Day Avg. Stock Price 9.32% 10.63% 11.66%
90-Day Avg. Stock Price 9.39% 10.70% 11.73%
180-Day Avg. Stock Price 9.43% 10.74% 11.77%
Average 9.38% 10.69% 11.72%
Median Results:
30-Day Avg. Stock Price 9.40% 10.44% 11.39%
90-Day Avg. Stock Price 9.52% 10.46% 11.49%
180-Day Avg. Stock Price 9.57% 10.45% 11.55%
Average 9.50% 10.45% 11.48%
Bulkley, Di 47
Rocky Mountain Power

1 Q. Have regulatory commissions acknowledged that the DCF
2 model might understate the cost of equity given the
3 current capital market conditions of relatively high
4 inflation and elevated interest rates?
5 A. Yes . For example, in its May 2022 decision establishing
6 the cost of equity for Aqua Pennsylvania, Inc . , the
7 Pennsylvania Public Utility Commission concluded that
8 the current capital market conditions of high inflation
9 and increased interest rates has resulted in the DCF
10 model understating the utility cost of equity, and that
11 weight should be placed on risk premium models, such as
12 the CAPM, in the determination of the ROE :
13 To help control rising inflation, the Federal
14 Open Market Committee has signaled that it is
15 ending its policies designed to maintain low
16 interest rates . Aqua Exc. at 9 . Because the
17 DCF model does not directly account for
18 interest rates, consequently, it is slow to
19 respond to interest rate changes . However,
20 I&E' s CAPM model uses forecasted yields on
21 ten-year Treasury bonds, and accordingly, its
22 methodology captures forward looking changes
23 in interest rates .
24 Therefore, our methodology for determining
25 Aqua' s ROE shall utilize both I&E' s DCF and
26 CAPM methodologies . As noted above, the
27 Commission recognizes the importance of
28 informed judgment and information provided by
29 other ROE models . In the 2012 PPL Order, the
30 Commission considered PPL' s CAPM and RP
Bulkley, Di 48
Rocky Mountain Power

1 methods, tempered by informed judgment,
2 instead of DCF-only results . We conclude that
3 methodologies other than the DCF can be used
4 as a check upon the reasonableness of the DCF
5 derived ROE calculation. Historically, we have
6 relied primarily upon the DCF methodology in
7 arriving at ROE determinations and have
8 utilized the results of the CAPM as a check
9 upon the reasonableness of the DCF derived
10 equity return. As such, where evidence based
11 on other methods suggests that the DCF-only
12 results may understate the utility' s ROE, we
13 will consider those other methods, to some
14 degree, in determining the appropriate range
15 of reasonableness for our equity return
16 determination. In light of the above, we shall
17 determine an appropriate ROE for Aqua using
18 informed judgement based on I&E' s DCF and CAPM
19 methodologies .
20 ...
21 We have previously determined, above, that we
22 shall utilize I&E' s DCF and CAPM
23 methodologies . I&E' s DCF and CAPM produce a
24 range of reasonableness for the ROE in this
25 proceeding from 8 . 90% [DCF] to 9 . 89% [CAPM] .
26 Based upon our informed judgment, which
27 includes consideration of a variety of
28 factors, including increasing inflation
29 leading to increases in interest rates and
30 capital costs since the rate filing,
Bulkley, Di 49
Rocky Mountain Power

1 we determine that a base ROE of 9 . 75% is
2 reasonable and appropriate for Aqua. 47
3 Similarly, the Massachusetts Department of Public
4 Utilities in a recent rate case for NSTAR Electric
5 Company concluded that given the recent increase in
6 interest rates there was "greater certainty" that the
7 results of the DCF model were understating the cost of
8 equity for the utility. 48
9 B. CAPM Analysis
10 Q. Please briefly describe the Capital Asset Pricing Model .
11 A. The CAPM is a risk premium approach that estimates the
12 cost of equity for a given security as a function of a
13 risk-free return plus a risk premium to compensate
14 investors for the non-diversifiable or "systematic" risk
15 of that security. 99 This second component is the product
16 of the market risk premium and the beta coefficient,
17 which measures the relative riskiness of the security
18 being evaluated.
47 Penn. Pub. Util. Comm'n et.al. v, Aqua Penn. Wastewater Inc., Docket
Nos. R-2021-3027385 and R-2021-3027386, Opinion and Order at 154-155
(May 12, 2022) .
48 Petition of NSTAR Electric Company, doing business as Eversource
Energy, pursuant to G.L. c. 164, § 94 and 220 CMR 5. 00, for Approval
of a General Increase in Base Distribution Rates for Electric Service
and a Performance Based Ratemaking Plan, Docket D.P.U. 22-22, Final
Order at 385-386 (Nov. 30, 2022) .
49 Systematic risk is the risk inherent in the entire market or market
segment, which cannot be diversified away using a portfolio of assets.
Unsystematic risk is the risk of a specific company that can,
theoretically, be mitigated through portfolio diversification.
Bulkley, Di 50
Rocky Mountain Power

1 The CAPM is defined by four components, each of which
2 must theoretically be a forward-looking estimate :
Ke = rf + P(rm-rf) [3
3 Where :
4 Ke = the required market ROE;
5 R = the beta coefficient of an individual
6 security;
7 rf = the risk-free rate of return; and
8 rm = the required return on the market as a
9 whole .
10 In this specification, the term (rm - rf)
11 represents the market risk premium. According to the
12 theory underlying the CAPM, because unsystematic risk
13 can be diversified away, investors should only be
14 concerned with systematic or non-diversifiable risk.
15 Systematic risk is measured by beta, which is a measure
16 of the volatility of a security as compared to the market
17 as a whole . Beta is defined as :
_ Covariance (re, rm)
Variance (rm) [4]
18 Variance (rm) represents the variance of the market
19 return, which is a measure of the uncertainty of the
20 general market . Covariance (re, rm) represents the
21 covariance between the return on a specific security and
22 the general market, which reflects the extent to which
23 the return on that security will respond to a given
24 change in the general market return. Thus, beta
Bulkley, Di 51
Rocky Mountain Power

1 represents the risk of the security relative to the
2 general market .
3 Q. What risk-free rate did you use in your CAPM analysis?
4 A. I rely on three sources for my estimate of the risk-free
5 rate (1) the current 30-day average yield on 30-year
6 U. S . Treasury bonds, which is 4 . 59 percent; 50 (2) the
7 average projected 30-year U. S . Treasury bond yield for
8 the third quarter of 2024 through the third quarter of
9 2025, which is 4 . 32 percent; 51 and (3) the average
10 projected 30-year U. S . Treasury bond yield for 2025
11 through 2029, which is 4 . 10 percent . 52
12 Q. What beta coefficients do you use in your CAPM analysis?
13 A. As shown in Exhibit No . 8, I use the beta coefficients
14 for the proxy group companies as reported by Bloomberg
15 and Value Line. The beta coefficients reported by
16 Bloomberg are calculated using ten years of weekly
17 returns relative to the S&P 500 Index. The Value Line
18 beta coefficients are calculated based on five years of
19 weekly returns relative to the New York Stock Exchange
20 Composite Index. Additionally, as shown in Exhibit No .
21 8, I also consider an additional CAPM analysis that
22 relies on the long-term average utility beta coefficient
so S&P IQ Pro, as of April 30, 2024.
51 Blue Chip Financial Forecasts, Vol. 43, No. 5, at 2 (May 1, 2024) .
52 Blue Chip Financial Forecasts, Vol. 42, No. 12, at 14 (Dec. 1, 2023) .
Bulkley, Di 52
Rocky Mountain Power

1 for the companies in my proxy group from 2013 through
2 2023, which are presented in Exhibit No . 9 .
3 Q. How do you estimate the market risk premium in the CAPM?
4 A. I estimate the market risk premium as the difference
5 between the implied expected equity market return and
6 the risk-free rate . As shown in Exhibit No . 10, the
7 expected market return is calculated using the constant
8 growth DCF model discussed previously as applied to the
9 companies in the S&P 500 Index. Based on an estimated
10 market capitalization-weighted dividend yield of
11 1 . 72 percent and a weighted long-term growth rate of
12 11 . 09 percent, the estimated required market return for
13 the S&P 500 Index as of April 30, 2024 is 12 . 91 percent.
14 Q. How does the expected market return compare to observed
15 historical market returns?
16 A. As show in Figure 9, given the range of annual equity
17 returns that have been observed over the past century,
18 a current expected market return of 12 . 91 percent is not
19 unreasonable . In 50 out of the past 97 years (or
20 approximately 52 percent of observations) , the realized
21 equity market return was at least 12 . 91 percent or
22 greater.
Bulkley, Di 53
Rocky Mountain Power

1 Figure 9 : Realized U. S . equity market returns (1926-2022) ss
60%
40`%o
20(Vo
W% 11 11 1112 111 it �1 11 111
-20%
-40%
-60%
10 01 N M O ti le r O M 10 01 N kn le r O M �Z 01 NW) OC IV r O M �Z C1 N
N N M M M It 'IT 'It kn kn M M �Z �O �O [- l-- l- 00 = = = 01 01 01 O O O -- .
01 01 01 O1 O1 Cr) 01 O1 01 01 01 01 O1 O1 O1 01 01 O1 O1 O1 01 41 01 01 01 O O O O O O O O
. . . . . . . . . . . . . . . . . . . . . . . . . N N N N N N N N
2 Q. Did you consider another form of the CAPM in your analysis?
3 A. Yes . I have also considered the results of an ECAPM in
4 estimating the cost of equity for the Company. 54 The
5 ECAPM calculates the product of the adjusted beta
6 coefficient and the market risk premium and applies a
7 weight of 75 . 00 percent to that result . The model then
8 applies a 25 . 00 percent weight to the market risk premium
9 without any effect from the beta coefficient. The
10 results of the two calculations are summed, along with
13 Depicts total annual returns on large company stocks, as reported in
the 2023 Kroll SBBI Yearbook.
11 See, e.g. , Roger A. Morin, New Regulatory Finance, Public Utilities
Reports, Inc. , at 189 (June 1, 2006) .
Bulkley, Di 54
Rocky Mountain Power

1 the risk-free rate, to produce the ECAPM result, as noted
2 in Equation [5] below:
3 ke = rf + 0 . 75(3 (rm - rf) + 0 .25 (rm - rf) [5]
4 Where :
5 ke = the required market ROE
6 a = Adjusted Beta coefficient of an individual
7 security
8 rf = the risk-free rate of return
9 r,, = the required return on the market as a whole
10 The ECAPM addresses the tendency of the
11 "traditional" CAPM to underestimate the cost of equity
12 for companies with low beta coefficients such as
13 regulated utilities . In that regard, the ECAPM is not
14 redundant to the use of adjusted betas in the traditional
15 CAPM, but rather it recognizes the results of academic
16 research indicating that the risk-return relationship is
17 different (in essence, flatter) than estimated by the
18 CAPM, meaning that the CAPM underestimates the "alpha, "
19 or the constant return term. ss
20 Consistent with my CAPM, my application of the
21 ECAPM uses the forward-looking market risk premium
22 estimates, the three yields on 30-year Treasury
23 securities noted earlier as the risk-free rate, and the
ss Id. , at 191.
Bulkley, Di 55
Rocky Mountain Power

1 current Bloomberg, current Value Line, and long-term
2 Value Line beta coefficients .
3 Q. What are the results of your CAPM and ECAPM analyses?
4 A. The results of my CAPM and ECAPM analyses are summarized
5 in Figure 10, as well as presented in Exhibit No . 8 .
6 Figure 10 : Summary of CAPM and ECAPM Results
30-Year Treasury Bond Yield
Current Near-Term Longer-Term
30-Day Avg Projected Projected
CAPM:
Current Value Line Beta 12.25% 12.22% 12.21%
Current Bloomberg Beta 11.14% 11.08% 11.03%
Long-term Avg. Value Line Beta 10.92% 10.86% 10.81%
ECAPM:
Current Value Line Beta 12.41% 12.39% 12.38%
Current Bloomberg Beta 11.58% 11.53% 11.50%
Long-term Avg. Value Line Beta 11.42% 11.37% 11.33%
7 C. BYRP Analysis
8 Q. Please describe the BYRP approach.
9 A. In general terms, this approach is based on the
10 fundamental principle that equity investors bear the
11 residual risk associated with equity ownership and
12 therefore require a premium over the return they would
13 have earned as bondholders . In other words, because
14 returns to equity holders have greater risk than returns
15 to bondholders, equity holders require a higher return
16 for that incremental risk. Thus, risk premium approaches
17 estimate the cost of equity as the sum of the equity
Bulkley, Di 56
Rocky Mountain Power

1 risk premium and the yield on a particular class of
2 bonds . In my analysis, I use actual authorized returns
3 for vertically integrated electric utilities as the
4 historical measure of the cost of equity to determine
5 the risk premium.
6 Q. What is the fundamental relationship between the equity
7 risk premium and interest rates?
8 A. It is important to recognize both academic literature
9 and market evidence indicating that the equity risk
10 premium (as used in this approach) is inversely related
11 to the level of interest rates (i . e. , as interest rates
12 increase, the equity risk premium decreases, and vice
13 versa) . Consequently, it is important to develop an
14 analysis that: (1) reflects the inverse relationship
15 between interest rates and the equity risk premium; and
16 (2) relies on recent and expected market conditions .
17 The analysis presented in Exhibit No. 11 establishes
18 that relationship using a regression of the risk premium
19 as a function of Treasury bond yields . When the
20 authorized ROES serve as the measure of required equity
21 returns and the long-term Treasury bond yield is defined
22 as the relevant measure of interest rates, the risk
23 premium is the difference between those two points . 56
56 See e.g. , S. Keith Berry, Interest Rate Risk and Utility Risk Premia
during 1982-93, Managerial and Decision Economics, Vol. 19, No. 2 (Mar.
Bulkley, Di 57
Rocky Mountain Power

1 Q. Is the BYRP analysis relevant to investors?
2 A. Yes . Investors are aware of authorized ROES in other
3 jurisdictions and they consider those awards as a
4 benchmark for a reasonable level of equity returns for
5 utilities of comparable risk operating in other
6 jurisdictions . As discussed previously, utilities have
7 experienced credit rating downgrades and been subject to
8 a negative market reaction related to the financial
9 effects of a rate case decision that included a below
10 average authorized ROE. Because my BYRP analysis is
11 based on authorized ROEs for utility companies relative
12 to corresponding Treasury yields, it provides relevant
13 information to assess the return expectations of
14 investors in the current interest rate environment .
15 Q. What did your BYRP analysis reveal?
16 A. As shown in Figure 11, from 1980 through April 2024,
17 there was a strong negative relationship between risk
18 premia and interest rates . To estimate that
19 relationship, I have conducted a regression analysis
20 using the following equation:
21 RP = a + b(T) [61
22 Where :
1998) (the author used a similar methodology, including using
authorized ROEs as the relevant data source, and came to similar
conclusions regarding the inverse relationship between risk premia and
interest rates) . See also, Robert S. Harris, Using Analysts' Growth
Forecasts to Estimate Shareholder Required Rates of Return, Financial
Management, at 66 (Spring 1986) .
Bulkley, Di 58
Rocky Mountain Power

1 RP = Risk Premium (difference between authorized
2 ROEs and the yield on 30-year Treasury bonds)
3 a = intercept term
4 b = slope term
5 T = 30-year Treasury bond yield
6 Data regarding authorized ROES were derived from
7 all of the vertically-integrated electric utility rate
8 cases over this period as reported by RRA. 57 The
9 equation' s coefficients are statistically significant at
10 the 99 . 00 percent level .
11 Figure 11 : Risk Premium Results
8.50%
•
•♦ y=-0.431x+0.0806
7.50% Rz=0.8452
s
6.50% • ••♦ •••
•
5.50% ••• 1�♦ ♦ • • •
a 4.50% • •
M
Vi ♦
3.50% • • • •» •
2.50% •
1.50%
•♦ N
0.50%
1.00% 3.00% 5.00% 7.00% 9.00% 11.00% 13.00% 15.00%
U.S.Government 30-year Treasury Yield
57 The data was screened to eliminate limited issue rider cases, electric
transmission cases, electric distribution-only (i.e., no generation)
cases, and cases that were silent with respect to the authorized ROE.
Bulkley, Di 59
Rocky Mountain Power

1 Q. What are the results of your BYRP analysis?
2 A. Figure 12 presents the results of my BYRP analysis, which
3 is also presented in more detail in Exhibit No . 11 .
4 Figure 12 : BYRP Results
30-Year Treasury Bond Yield
Current Near-Term Longer-Term
30-Day Avg Projected Projected
Bond Yield Risk Premium 10.67% 10.52% 10.39%
5
6 Q. How did the results of the BYRP analysis inform your
7 recommended ROE for the Company?
8 A. I have considered the results of the BYRP analysis in my
9 recommended ROE for the Company. As noted, investors
10 consider the authorized ROE for a utility when assessing
11 the risk of that company as compared to utilities of
12 comparable risk operating in other jurisdictions .
13 VIII . REGULATORY AND BUSINESS RISKS
14 Q. Do the results of the cost of equity analyses alone
15 provide an appropriate estimate of the cost of equity
16 for the Company?
17 A. No . These results provide only a range of the
18 appropriate estimate of the Company' s cost of equity.
19 Several additional factors must be considered when
20 determining where the Company' s cost of equity falls
21 within the range of analytical results . These risk
Bulkley, Di 60
Rocky Mountain Power

I factors, discussed below, should be considered with
2 respect to their overall effect on the Company' s risk
3 profile relative to the proxy group.
4 A. Wildfire Risk
5 Q. Have equity analysts and credit rating agencies
6 recognized wildfire as a substantial risk to the
7 electric utility sector?
8 A. Yes . While wildfire risk is not a new threat to utility
9 investors, it has become a much larger focus to both
10 equity investors and credit rating agencies . For
11 example, BofA has stated that wildfire risk has become
12 the top question among all different investor types . 58
13 In fact, BofA has stated that it sees "the consistent
14 existential risk posed by wildfires outflanking any
15 other factor exposure of a given utility equity. 1159 For
16 example, BofA highlighted the catastrophic wildfires in
17 California in 2017-2018 that led to the bankruptcy of
18 PG&E Corporation and its subsidiary Pacific Gas and
19 Electric Company ("PG&E") and caused material
20 liabilities that weakened the earnings growth for
21 Southern California Edison ("SoCalEd") , but noted that
22 the current wildfire risk feels worse given the
58 BofA Global Research, US Utilities & IPPs, Wildfire wakeup: what the
Hawaiian fires mean for the sector as prudency shifts (Aug. 28, 2023) .
59 BofA Global Research, US Utilities & IPPs, As the leaves fall,
preparing for Autumn utility outlook. Micro still has potholes (Sept.
6, 2023) .
Bulkley, Di 61
Rocky Mountain Power

1 increased occurrences of wildfires across multiple
2 states, even outside of the traditional wildfire season,
3 and the billions in potential wildfire liabilities
4 currently faced by PacifiCorp in Oregon, Xcel Energy in
5 Colorado, and Hawaiian Electric. 60 A such, a utility' s
6 exposure to wildfire risk is expected to be a defining
7 factor for utility valuations :
8 Should there be further events, we perceive a
9 risk that the `new' premium utility will be
10 defined by its exposure to wildfire factors .
11 The first screen is simply geography and
12 FEMA' s assessment of wildfire risk, while the
13 second consideration is the legal and
14 regulatory construct under which the utility
15 operates . We anticipate having explicit and
16 refreshed plans will become a necessity for
17 any utilities operating in geographies .
18 *****
19 On balance, the added wildfire concerns across
20 the west, with their disproportionate
21 manifestation across small- and even mid-caps
22 makes us incrementally cautious on the entire
23 sub-group of utilities . 61
24 As further stated by BofA:
25 PacifiCorp and Xcel Energy (XEL) are each
26 facing billions in potential wildfire-related
27 liabilities . Hawaiian Electric may not have
28 shareholder value if wholly responsible for
29 the -$5 . 4Bn estimated wildfire damage . In the
30 past week, Evergy (EVRG) had a fire caused by
31 its downed poles, and Entergy Corp (ETR)
32 warned of fire hazards . The increased
60 BofA Global Research, US Utilities & IPPs, Wildfire wakeup: what the
Hawaiian fires mean for the sector as prudency shifts (Aug. 28, 2023) .
61 BofA Global Research, US Utilities & IPPs, As the leaves fall,
preparing for Autumn utility outlook. Micro still has potholes (Sept.
6, 2023) .
Bulkley, Di 62
Rocky Mountain Power

1 occurrences in multiple states, even outside
2 of the traditional wildfire season has
3 investors of all types on edge . 62
4
5 From the credit rating agency perspective, Moody' s
6 has noted that wildfire risk "can reach catastrophic
7 levels at utilities, " and that it is difficult to
8 determine which utilities are most at risk given that
9 the recent wildfires in Oregon and Hawaii were in
10 moderate risk zones . 63 S&P has stated that " [d] amages
11 and related costs from physical risks are escalating in
12 North America as regions designated as high-fire risk
13 expand, " and that over the past 6 years, utility credit
14 downgrades directly related to physical risks have
15 increased significantly. 64 Similarly, FitchRatings
16 ("Fitch") has noted the higher regulatory risk
17 associated with wildfires, and stated that extreme
18 weather, which includes wildfires, has driven
19 approximately one-quarter of its downgrades in the past
20 6 years, yet was not a driver of downgrades in the
21 6 years prior. 65 The most recent example is Hawaiian
22 Electric Industries Inc. and its subsidiaries after the
62 Id.
63 Moody's Investors Service, Breakfast with the Analysts, 58th Annual EEI
Financial Conference, at 30 (Nov. 13, 2023) .
64 S&P Global Ratings, A Storm is Brewing: Extreme Weather Events
Pressure North American Utilities' Credit Quality, at 1 (Nov. 9, 2023) .
65 Fitch Ratings, Climate Related Risks in Focus, 35th Annual Presentation
at EEI Financial Conference, at 5, 11 (Nov. 13, 2023) .
Bulkley, Di 63
Rocky Mountain Power

1 catastrophic Maui fires in August 2023 when S&P,
2 Moody' s, and Fitch all downgraded to "junk" status in
3 response to the potential wildfire liabilities faced by
4 the utility. 66
5 Q. Has wildfire risk been specifically identified as a risk
6 for the Company in Idaho?
7 A. Yes . S&P has recently highlighted PacifiCorp' s wildfire
8 risk, noting that it could lead to a credit downgrade :
9 We could lower the ratings on PacifiCorp over
10 the next 24 months if the number of claimants
11 and estimated damages concerning its wildfire
12 lawsuits, including the James case, grow
13 significantly such that we anticipate
14 materially weaker leverage, increased
15 business risk, or a weaker degree of group
16 support from its parent . Furthermore, we
17 could also lower ratings if the company' s
18 stand-alone FFO to debt consistently weakens
19 to below 130 or if PacifiCorp contributes to
20 a future significant wildfire . 67
21 S&P also stated that it could affirm its rating on
22 PacifiCorp and revise its outlook to stable if the
23 Company were to achieve favorable legal outcomes that
24 limit existing wildfire liabilities the company is not
25 the cause of a future materially significant wildfire. 68
66 See, e.g., Fitch downgrades Hawaiian Electric to junk on worries over
wildfire exposure, Reuters (Aug. 21, 2023) ; S&P downgrades Hawaiian
Electric to 'B-'as wildfires raise market-access worries, Reuters
(Aug. 24, 2023) ; Moody's downgrades Hawaiian Electric's credit to junk
amid Maui wildfire scrutiny, Reuters (Aug. 18, 2023) .
67 S&P Global Ratings, PacifiCorp Ratings Affirmed Following Archie Creek
Settlement; Outlook Negative, at 2 (Dec. 12, 2023) .
6s Id.
Bulkley, Di 64
Rocky Mountain Power

1 Q. Is wildfire risk to utilities limited to a few states?
2 A. No . The Federal Emergency Management Agency ("FEMA")
3 publishes a National Risk Index that ranks the wildfire
4 risk by county and census tract in five categories : Very
5 High, Relatively High, Relatively Moderate, Relatively
6 Low, and Very low. Based on FEMA' s assessment, wildfire
7 risk is much more broad than a few states, with the risk
8 identified primarily as west of the Mississippi River,
9 Hawaii, Florida, and the southeastern coast of the U. S . 69
10 Q. Have you conducted any analysis to evaluate the wildfire
11 risk in Idaho as compared to the jurisdictions in which
12 the companies in the proxy group operate?
13 A. Yes . Based on FEMA' s rankings of the Expected Annual
14 Loss associated with wildfire for each state, I have
15 conducted an analysis to compare the wildfire risk of
16 Idaho to the jurisdictions in which the utility
17 operating subsidiaries of the companies in the proxy
18 group operate. Specifically, I have applied a numeric
19 ranking system to the FEMA rankings with "Very Low"
20 assigned the lowest ranking (i . e. , a "1") and "Very High"
21 assigned the highest ranking (i . e. , a "5") . As shown on
22 Exhibit No. 12, Idaho is ranked "Relatively Moderate"
23 (i . e. , a "3") This ranking for Idaho indicates a higher
69 FEMA, National Risk Index; https://hazards.fema.gov/nri/map#
(wildfire risk by census tract)
Bulkley, Di 65
Rocky Mountain Power

1 risk relative to the proxy group, which has an average
2 ranking of between "Relatively Low" and "Relatively
3 Moderate" (i . e. , a "2 . 14") .
4 Q. How is the risks associated with wildfires being
5 addressed?
6 A. The Company has established a Wildfire Mitigation Plan
7 that outlines the initiatives that the Company has
8 undertaken, and it plans for the future mitigation of
9 wildfire risk including capital investments and
10 expenses needed to implement the plan. In addition to
11 the Company' s plans, the state of Idaho recognizes
12 that this is a significant risk factor facing
13 utilities . It is my understanding that the governor
14 recently concluded a series of workshops that may
15 inform future legislation on this issue . While there
16 is a cap on non-economic damages in Idaho, it is
17 unclear how or whether this cap would apply in the
18 event of damages related to a wildfire event . Further,
19 the Company may also be exposed to other risks from
20 such an unforeseen event .
21 Q. What are your conclusions regarding the effect of
22 wildfire risk on the Company in Idaho?
23 A. Wildfire risk presents one of the most significant
24 business, operational, and financial threats for
25 utilities in states subject to such risks . Idaho has
Bulkley, Di 66
Rocky Mountain Power

1 greater wildfire risk as compared to the proxy group
2 utilities, and it is clear that equity investors and
3 credit rating agencies are reflecting the incremental
4 risk for companies that have been affected by wildfire
5 exposure and that the electric utility sector overall
6 has increased risk related to this threat . The capital
7 costs associated with wildfire mitigation can be
8 significant and continue over many years, thus making
9 the timeliness of cost recovery important . Absent
10 meaningful regulatory or legislative support for the
11 utilities in the states subject to substantial potential
12 losses from wildfires, the investor-required return
13 increases significantly due to the higher risk of
14 wildfire exposure . Addressing this risk in a timely
15 manner should be a top regulatory priority to provide
16 the Company with the ability to access capital on
17 reasonable terms and make the capital investments needed
18 going forward.
19 B. Capital Expenditures
20 Q. Please summarize the Company' s capital expenditure
21 requirements .
22 A. The Company' s current projection of capital expenditures
23 for 2024 through 2028 totals approximately
24 $14 . 1 billion, which represents approximately
25 52 .2 percent of the Company' s approximate $27 billion in
Bulkley, Di 67
Rocky Mountain Power

1 net utility plant as of December 31, 2023 . 70
2 Q. How do the Company' s capital expenditures compare to
3 those of the proxy group?
4 A. As shown on Exhibit No . 13, 1 have calculated the ratio
5 of expected capital expenditures to net utility plant
6 for the Company and the ratio of expected capital
7 expenditures to net utility plant for each of the
8 companies in the proxy group by dividing each company' s
9 projected capital expenditures for the period from 2024
10 through 2028 by its total net utility plant as of
11 December 31, 2023 . As shown Exhibit No . 13 (see also
12 Figure 13 below) , the Company' s ratio of capital
13 expenditures as a percentage of net rate base is
14 approximately 0 . 98 times the median for the proxy group
15 companies of 53 . 1 percent .
70 Data provided by the Company.
Bulkley, Di 68
Rocky Mountain Power

1 Figure 13 : Comparison of Capital Expenditures—Proxy Group
2 Companies
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0 `ol COI �,QG Vle, �4G°R PJP �CQ` OJT Vol G�5 Q�`� IVP 4&
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3
4 Q. How is PacifiCorp' s risk profile affected by its capital
5 expenditure requirements?
6 A. As with any utility facing increased capital expenditure
7 requirements, the Company' s risk profile may be
8 adversely affected in two significant and related ways :
9 (1) the heightened level of investment increases the
10 risk of under recovery or delayed recovery of the
11 invested capital; and (2) an inadequate return would put
12 downward pressure on key credit metrics .
13 Q. Do credit rating agencies recognize the risks associated
14 with elevated levels of capital expenditures?
15 A. Yes . From a credit perspective, the additional pressure
16 on cash flows associated with higher levels of capital
17 expenditures exerts corresponding pressure on credit
Bulkley, Di 69
Rocky Mountain Power

1 metrics and, therefore, credit ratings . To that point,
2 S&P explains the importance of regulatory support for
3 large capital projects :
4 When applicable, a jurisdiction' s willingness
5 to support large capital projects with cash
6 during construction is an important aspect of
7 our analysis . This is especially true when
8 the project represents a major addition to
9 rate base and entails long lead times and
10 technological risks that make it susceptible
11 to construction delays . Broad support for all
12 capital spending is the most
13 credit-sustaining. Support for only specific
14 types of capital spending, such as specific
15 environmental projects or system integrity
16 plans, is less so, but still favorable for
17 creditors . Allowance of a cash return on
18 construction work-in-progress or similar
19 ratemaking methods historically were
20 extraordinary measures for use in unusual
21 circumstances, but when construction costs are
22 rising, cash flow support could be crucial to
23 maintain credit quality through the spending
24 program. Even more favorable are those
25 jurisdictions that present an opportunity for
26 a higher return on capital projects as an
27 incentive to investors . 71
28 Recently, S&P evaluated the capital expenditure
29 trends in the utility sector, noting that the balance
30 between operating with negative discretionary cash flow
71 S&P Global Ratings, Assessing U.S. Investor-Owned Utility Regulatory
Environments, at 7 (Aug. 10, 2016) .
Bulkley, Di 70
Rocky Mountain Power

1 from operations offset by reliable access to capital
2 markets for financing may be tested through
3 ever-increasing capital expenditure requirements as a
4 result of the transformation of the energy sector
5 through the focus on low/no carbon generation,
6 electrification, and the replacement of aging
7 infrastructure :
8 Some companies have been unable to support
9 financial metrics consistent with former
10 ratings as their discretionary cash flow
11 deteriorated. This trend was a significant
12 contributor to the sector seeing the median
13 rating decline to 'BBB+' from 'A- ' for the
14 first time in 2022 . What is less clear is
15 whether or not management teams will take
16 steps to forestall another step down in credit
17 quality as high capital outlays persist . So
18 far in 2023, we have not seen evidence that
19 equity issuance is keeping pace with debt
20 issuance to fill ever-deepening discretionary
21 cash flow shortfalls, but time will tell .
22 . .
23 Despite the improvement in the economic
24 outlook, we expect inflation, high interest
25 rates, higher capital spending, and the
26 strategic decision by many companies to
27 operate with only minimal financial cushion
28 from their downgrade thresholds to continue to
29 pressure the industry' s credit quality. We are
30 cautious about the durability of the current
Bulkley, Di 71
Rocky Mountain Power

1 stable ratings outlook given persistently high
2 capital spending that now supports a trend of
3 deterioration in discretionary cash flow.
4 Without a commensurate focus on balance sheet
5 preservation through equity support of
6 discretionary cash flow deficits, limited
7 financial cushions could give rise to another
8 round of negative rating actions . The question
9 then comes back to management priorities and
10 financial policy decisions, or utilities may
11 be faced with another step down in the median
12 ratings . 72
13 Therefore, to the extent that the Company' s rates
14 do not continue to reasonably permit the recovery its
15 prudently-incurred capital investments on a timely
16 basis, the Company would face increased recovery risk
17 and thus increased pressure on its credit metrics .
18 Q. Does the Company have a capital tracking mechanism to
19 recover the costs associated with capital expenditures
20 on a timely basis between rate cases?
21 A. No . PacifiCorp has Energy Cost Adjustment Mechanism
22 ("SCAM") which allows for deferral of net power costs
23 and recovery of PTCs . 73 In addition, the Company has
24 wildfire mitigation cost recovery through its
25 Catastrophic Fire Fund however the recovery of costs
26 through this mechanism can be onerous and delayed.
72 S&P Global Ratings, Record CapEx Fuels Growth Along With Credit Risk
For North American Investor-Owned Utilities, at 5, 7-8 (Sept. 12,
2023) .
73 PacifiCorp 2023 SEC Form 10-K at 43.
Bulkley, Di 72
Rocky Mountain Power

1 Q. What are your conclusions regarding the effect of the
2 Company' s capital spending requirements on its risk
3 profile and cost of capital?
4 A. The Company' s capital expenditure requirements as a
5 percentage of net utility plant are significant and are
6 expected to continue over the next few years . The
7 Company' s capital cost recovery is limited between rate
8 proceedings and the Catastrophic Fire Fund which is
9 limited to operating and capital expenditures that are
10 necessary to implement the Company' s Wildfire protection
11 plan that are incremental expenses to those already
12 included in rate base and do not provide for the recovery
13 of expenditures unrelated to wildfire mitigation,
14 non-renewable generation resources, or timely recovery
15 of other capital expenditures between rate cases .
16 C. Regulatory Risks
17 1 . Cost Recovery Mechanisms
18 Q. How does the regulatory environment affects investors'
19 risk assessments?
20 A. The ratemaking process is premised on the principle
21 that, for investors and companies to commit the capital
22 needed to provide safe and reliable utility service, the
23 subject utility must have the opportunity to recover the
24 return of, and the market-required return on, invested
25 capital . Regulatory commissions recognize that because
Bulkley, Di 73
Rocky Mountain Power

1 utility operations are capital intensive, regulatory
2 decisions should enable the utility to attract capital
3 at reasonable terms, and that doing so balances the
4 long-term interests of investors and customers .
5 Utilities must finance their operations and thus require
6 the opportunity to earn a reasonable return on their
7 invested capital to maintain their financial profiles .
8 The Company is no exception, and in that respect, the
9 regulatory environment is one of the most important
10 factors considered in both debt and equity investors'
11 risk assessments .
12 From the perspective of debt investors, the
13 authorized return should enable the utility to generate
14 the cash flow needed to meet its near-term financial
15 obligations, make the capital investments needed to
16 maintain and expand its systems, and maintain the
17 necessary levels of liquidity to fund unexpected events .
18 This financial liquidity must be derived not only from
19 internally generated funds, but also by efficient access
20 to capital markets . Moreover, because fixed income
21 investors have many investment alternatives, even within
22 a given market sector, a utility' s financial profile
23 must be adequate on a relative basis to ensure its
24 ability to attract capital under a variety of economic
25 and financial market conditions .
Bulkley, Di 74
Rocky Mountain Power

1 Equity investors require that the authorized return
2 be adequate to provide a risk-comparable return on the
3 equity portion of the utility' s capital investments .
4 Because equity investors are the residual claimants on
5 the utility' s cash flows (i . e. , the equity return is
6 subordinate to interest payments) , they are particularly
7 concerned with the strength of regulatory support and
8 its effect on future cash flows .
9 Q. Do credit rating agencies consider regulatory risk in
10 establishing a company' s credit rating?
11 A. Yes . Both S&P and Moody' s consider the overall
12 regulatory framework in establishing credit ratings .
13 Moody' s establishes credit ratings based on four key
14 factors : (1) regulatory framework; (2) the ability to
15 recover costs and earn returns; (3) diversification; and
16 (4) financial strength, liquidity and key financial
17 metrics . Of these criteria, regulatory framework and
18 the ability to recover costs and earn returns are each
19 given a broad rating factor of 25 . 00 percent . Therefore,
20 Moody' s assigns regulatory risk a 50 . 00 percent
21 weighting in the overall assessment of business and
22 financial risk for regulated utilities . 74
74 Moody' s Investors Service, Rating Methodology: Regulated Electric and
Gas Utilities, at 4 (June 23, 2017) .
Bulkley, Di 75
Rocky Mountain Power

1 S&P also identifies the regulatory framework as an
2 important factor in credit ratings for regulated
3 utilities, stating: "One significant aspect of
4 regulatory risk that influences credit quality is the
5 regulatory environment in the jurisdictions in which a
6 utility operates . "75 S&P identifies four specific
7 factors that it uses to assess the credit implications
8 of the regulatory jurisdictions of investor-owned
9 regulated utilities : (1) regulatory stability; (2)
10 tariff-setting procedures and design; (3) financial
11 stability; and (4) regulatory independence and
12 insulation. 76
13 Q. How does the regulatory environment in which a utility
14 operates affect its access to and cost of capital?
15 A. The regulatory environment can significantly affect both
16 the access to and cost of capital in several ways .
17 First, the proportion and cost of debt capital available
18 to utility companies are influenced by the rating
19 agencies' assessment of the regulatory environment . As
20 noted by Moody' s, " [fIor rate regulated utilities, which
21 typically operate as a monopoly, the regulatory
22 environment and how the utility adapts to that
75 Standard & Poor's Global Ratings, U.S. , and Canadian Regulatory
Jurisdictions Support Utilities' Credit Quality—But Some More So Than
Others, at 2 (June 25, 2018) .
76 Id., at 1.
Bulkley, Di 76
Rocky Mountain Power

1 environment are the most important credit
2 considerations . 177 Moody' s further highlighted the
3 relevance of a stable and predictable regulatory
4 environment to a utility' s credit quality, noting:
5 " [b] roadly speaking, the Regulatory Framework is the
6 foundation for how all the decisions that affect
7 utilities are made (including the setting of rates) , as
8 well as the predictability and consistency of
9 decision-making provided by that foundation. "'$
10 Q. Have you conducted any analysis of the regulatory
11 framework in Idaho relative to the jurisdictions in
12 which the companies in your proxy group operate?
13 A. Yes . I have evaluated the regulatory framework in Idaho
14 based on three factors that are important in terms of
15 providing a regulated utility an opportunity to earn its
16 authorized ROE . These factors are : (1) the test year
17 convention for ratemaking (i . e. , forecast vs . historical
18 test year) ; (2) use of rate design and/or other
19 mechanisms that mitigate volumetric risk and stabilize
20 revenue; and (3) prevalence of capital cost recovery
21 between rate cases . The results of my regulatory risk
22 assessment are shown in Exhibit No. 14 and are summarized
23 below.
77 Moody' s Investors Service, Rating Methodology: Regulated Electric and
Gas Utilities, at 6 (June 23, 2017) .
78 Id.
Bulkley, Di 77
Rocky Mountain Power

1 • Test Year Convention: The Company relies on a
2 historical test year for ratemaking purposes .
3 Similarly, as shown in Exhibit No . 14,
4 approximately 55 percent of the operating utility
5 subsidiaries of the proxy group companies provide
6 service in jurisdictions that use a historical test
7 year. However, forecast test years result in more
8 prompt recovery of incurred costs and thus
9 mitigates the regulatory lag associated with
10 historical test years . As Lowry, Hovde, Getachew,
11 and Makos (2010) explain:
12 This report provides an in depth
13 discussion of the test year issue . It
14 includes the results of empirical
15 research which explores why the unit
16 costs of electric IOUs are rising and
17 shows that utilities operating under
18 forward test years realize higher returns
19 on capital and have credit ratings that
20 are materially better than those of
21 utilities operating under historical
22 test years . The research suggests that
23 shifting to a future test year is a prime
24 strategy for rebuilding utility credit
25 ratings as insurance against an uncertain
26 future.79
27 • Revenue Stabilization/Non-Volumetric Rate Design:
28 The Company does not have protection against
29 volumetric risk in Idaho . In contrast, as shown in
30 Exhibit No . 14, approximately 60 percent of the
31 utility operating subsidiaries of the proxy group
32 companies have some form of revenue stabilization
33 through either decoupling, formula-based rates,
34 and/or straight-fixed variable rate design that
35 allow them to break the link between customer usage
36 and revenues .
37 • Capital Cost Recovery: The Company has capital cost
38 recovery mechanisms for the construction of new
39 renewable generation and associated transmission,
40 as well as dam removal and wildfire mitigation
41 expenditures . Similarly, as shown in Exhibit No .
42 14, approximately 67 percent of the operating
43 utility subsidiaries of the proxy group companies
79 Mark Newton Lowry, David Hovde, Lullit Getachew, and Matt Makos.
Forward Test Years for US Electric Utilities, at 1, (Prepared for the
Edison Electric Institute, Aug. 2010) ; emphasis added.
Bulkley, Di 78
Rocky Mountain Power

1 also have some form of capital cost recovery
2 allowing for the recovery of capital investments
3 placed into service between rate cases .
4 2 . Authorized ROES
5 Q. How do recent returns in Idaho compare to the authorized
6 returns in other jurisdictions?
7 A. Figure 14 below shows the authorized returns for
8 vertically-integrated electric utilities in Idaho and
9 other jurisdictions throughout the United States over
10 the past decade . As shown in Figure 14, the authorized
11 returns for electric utilities in Idaho have
12 consistently been below the national average since 2013 .
13 Figure 14 : Comparison of Idaho and U. S . Authorized
14 Vertically Integrated Electric Returns80
11.50%
-■-U.S.Average Exel.ID
° U.S.Authorized ROEs
11.00%
■ Idaho Authorized ROES
10.50%
C 10.00%
0 0 00 ° o 0 90 0 0 0 -o '■ � °800�
d 9.50%
o
9.00% o 0
o Rate Case Data through April 30,2024
8.50
80 S&P Capital IQ Pro.
Bulkley, Di 79
Rocky Mountain Power

1 Q. Should the Commission be concerned about authorizing
2 equity returns that are at the low-end of the range
3 established by other state regulatory jurisdictions?
4 A. Yes . Placing PacifiCorp at the low end of authorized
5 ROEs across the U. S . can negatively affect the Company' s
6 access to capital and the overall cost of capital over
7 the longer term. As noted in Section IV, there are
8 numerous examples in which utilities have experienced a
9 negative market response related to the financial
10 effects of a rate decision, including credit rating
11 downgrades and material stock price declines . Further,
12 as noted previously, interest rates increased
13 significantly in 2022 due to inflation and the Federal
14 Reserve' s normalization of monetary policy, which is
15 expected to remain restrictive for the near-term. While
16 historical authorized ROEs provide investors with a
17 range of recent returns, it is important to recognize
18 that the recent decisions do not take into consideration
19 the effect of the recent change in market conditions on
20 the investor-required return. Therefore, it is
21 important that the Commission consider the results of
22 forward-looking methodologies such as the CAPM, ECAPM,
23 and BYRP which rely directly on current and projected
24 interest rates in the estimation of the cost of equity.
Bulkley, Di 80
Rocky Mountain Power

1 Q. How should the Commission use the information
2 regarding authorized ROES in other jurisdictions in
3 determining the ROE for PacifiCorp?
4 A. The companies in the proxy group operate in multiple
5 jurisdictions across the U. S . Since PacifiCorp must
6 compete directly for capital with investments of similar
7 risk, it is appropriate to review the authorized ROES in
8 other jurisdictions . The comparison is important because
9 investors are considering the authorized returns across
10 the U. S . and are likely to invest equity in those
11 utilities with the highest returns . However, when
12 reviewing this data, it is important to recognize that
13 the authorized ROES are based on the market conditions
14 at the time of the rate proceeding. Therefore, while it
15 is reasonable to review this data, it is important to
16 consider differences in market conditions and the
17 investor required return at the time that the ROE was
18 authorized. Furthermore, investors are also likely to
19 consider business and financial risks for a company like
20 PacifiCorp, which faces increased risk as a result of
21 its capital expenditure plan and more limited cost
22 recovery mechanisms . Therefore, authorizing an ROE for
23 PacifiCorp that is equivalent to the average authorized
24 ROE for other vertically integrated electric utilities
25 is not sufficient to compensate investors for the added
Bulkley, Di 81
Rocky Mountain Power

1 risk of PacifiCorp. As such, it is important that the
2 Commission consider, as I have in my recommendation, the
3 additional risk of PacifiCorp and place the authorized
4 ROE for PacifiCorp towards the high end of authorized
5 ROEs for other vertically integrated electric utilities .
6 Q. Have you conducted any additional analyses to evaluate
7 the regulatory environment in Idaho as compared to the
8 jurisdictions in which the companies in the proxy group
9 operate?
10 A. Yes, I have conducted two additional analyses to compare
11 the regulatory framework of Idaho to the jurisdictions
12 in which the companies in the proxy group operate .
13 Specifically, I considered two different rankings : (1)
14 the RRA ranking of regulatory jurisdictions; and (2)
15 S&P' s ranking of the credit supportiveness of regulatory
16 jurisdictions .
17 Q. How does RRA evaluate the regulatory environment in each
18 jurisdiction?
19 A. RRA evaluates the regulatory environment from an
20 investor perspective, considering the relative
21 regulatory risk associated with ownership of securities
22 issued by the companies that are regulated in each
23 jurisdiction. RRA considers several factors that affect
24 the regulatory process including gubernatorial,
25 legislative and court activity, rate case decisions and
Bulkley, Di 82
Rocky Mountain Power

1 other regulatory decisions, and information obtained
2 through contact with commissioners, staff, utilities,
3 and government outreach.
4 Q. How do you use the RRA ratings to compare the regulatory
5 jurisdictions of the proxy group companies with the
6 Company' s regulatory jurisdiction?
7 A. RRA assigns a ranking for each regulatory jurisdiction
8 as "Above Average", "Average" or "Below Average", and
9 then within each of those categories, a numeric ranking
10 from 1 to 3 . Thus, there are a total of nine RRA
11 rankings, with the rankings for each jurisdiction
12 ranging from "Above Average/1", which is considered the
13 most supportive, to "Below Average/3, " which is the
14 least supportive . I have applied a numeric ranking
15 system to the RRA rankings with "Above Average/1"
16 assigned the highest ranking (i . e. , a "1") and "Below
17 Average/3" assigned the lowest ranking (i . e. , a "9") .
18 As shown on Exhibit No . 15, the Idaho
19 jurisdictional ranking is "Average / 2" (i . e. , a "5") ,
20 which is below the proxy group average ranking of between
21 "Average/l" and "Average/2" (i . e. , a "4 . 59") .
22 Q. How do you conduct your analysis of the S&P credit
23 supportiveness ranking?
24 A. For credit supportiveness, S&P classifies each
25 regulatory jurisdiction into five categories that range
Bulkley, Di 83
Rocky Mountain Power

1 from "Most Credit Supportive" down to "Credit
2 Supportive . " My analysis of the credit supportiveness
3 of the regulatory jurisdictions in which the proxy
4 companies operate as compared to the Company' s
5 regulatory jurisdiction is similar to the analysis of
6 the RRA overall regulatory ranking discussed above .
7 Specifically, I have assigned a numerical ranking to
8 each category, from Most Credit Supportive (i . e. , a "1")
9 to Credit Supportive (i . e. , a "5") .
10 As shown on Exhibit No . 16, S&P ranks Idaho as "Very
11 Credit Supportive" (i . e. , a "3") , which is below the
12 proxy group average ranking of "2 . 45" .
13 Q. Is it important that the Commission consider how the ROE
14 to be authorized for the Company in this proceeding
15 compares to other comparable utilities?
16 A. Yes . As discussed previously, the Company must compete
17 for discretionary capital within the PacifiCorp
18 corporate structure, as well as within the BHE corporate
19 structure, which must in turn compete for capital with
20 other utilities and businesses . Investors consider the
21 business and financial risks of the Company relative to
22 other comparable investments . Therefore, the Commission
23 should consider how the authorized ROE for the Company
24 in this proceeding compares to the ROES authorized for
25 other vertically-integrated utilities, assess that
Bulkley, Di 84
Rocky Mountain Power

1 comparison relative to the changes in capital market
2 conditions, as well as consider the specific business
3 and regulatory risks of the Company relative to the proxy
4 group, so that the Company' s future access to capital is
5 not negatively impacted. To the extent that the returns
6 in a jurisdiction are lower than the returns that have
7 been authorized more broadly, credit rating agencies
8 will consider this in the overall risk assessment of the
9 regulatory jurisdiction in which the company operates .
10 As noted previously, there are various examples of
11 utilities that have experienced a credit rating
12 downgrade and/or a negative market response related to
13 the financial effects of a rate decision.
14 Q. What are your conclusions regarding the perceived risks
15 related to the regulatory environment in Idaho?
16 A. Both Moody' s and S&P have identified the supportiveness
17 of the regulatory environment as an important
18 consideration in developing their overall credit ratings
19 for regulated utilities . Based on my analysis, the
20 Company' s regulatory risk and the ability to timely
21 recover its prudently incurred costs is moderately
22 higher relative to the operating utilities of the proxy
23 group given the Company' s risk associated with fuel cost
24 recovery and the lack of revenue stabilization. For
25 these reasons, I conclude that the Company has greater
Bulkley, Di 85
Rocky Mountain Power

1 than average regulatory risk when compared to the proxy
2 group.
3 IX. CAPITAL STRUCTURE
4 Q. Is the capital structure of the Company an important
5 consideration in the determination of the appropriate
6 ROE?
7 A. Yes . The equity ratio is the primary indicator of
8 financial risk for a regulated utility. All else equal,
9 a higher debt ratio increases the risk to investors .
10 Specifically, for debt holders, higher debt ratios
11 result in a greater portion of the available cash flow
12 being required to meet debt service, thereby increasing
13 the risk associated with the payments on debt . The
14 result of increased risk is a higher interest rate . The
15 incremental risk of a higher debt ratio is more
16 significant for common equity shareholders, whose claim
17 on the cash flow of the Company is secondary to debt
18 holders . Therefore, the greater the debt service
19 requirement, the less cash flow is available for common
20 equity holders .
21 Q. What is the Company' s proposed capital structure?
22 A. PacifiCorp is proposing a capital structure that is
23 composed of 50 percent common equity and 49 . 99 percent
24 long-term debt and 0 . 01 percent preferred stock.
Bulkley, Di 86
Rocky Mountain Power

1 Q. Did you conduct any analysis to determine if the
2 requested equity ratio was reasonable?
3 A. Yes . I compared the Company' s proposed capital
4 structure relative to the actual capital structures of
5 the utility operating subsidiaries of the companies in
6 the proxy group. The cost of equity is estimated based
7 on the return that is derived from companies in the proxy
8 group that are deemed to be comparable in risk to the
9 Company; however, those companies must be publicly-
10 traded in order to apply the cost of equity models . The
11 operating utility subsidiaries of the proxy group
12 companies are most risk-comparable to the Company, and
13 thus it is reasonable to look to the average capital
14 structure of the operating utilities of the proxy group
15 to benchmark the equity ratios for the Company.
16 Specifically, I have calculated the average
17 proportion of common equity, long-term debt, and
18 preferred equity for the most recent eight quarters for
19 each of the utility operating subsidiaries of the proxy
20 group companies . As shown in Exhibit No . 17, the mean
21 and median equity ratios for the utility operating
22 subsidiaries of the proxy group are 53 . 43 percent and
23 52 . 61 percent respectively, which are higher than the
24 Company' s proposed equity ratio percent .
Bulkley, Di 87
Rocky Mountain Power

1 Q. Are there other factors to be considered in setting the
2 Company' s capital structure?
3 A. Yes, there are other factors that should be considered
4 in setting the Company' s capital structure, namely the
5 challenges that the credit rating agencies have
6 highlighted as placing pressure on the credit metrics
7 for utilities .
8 For example, while Moody' s recently revised its
9 outlook for the utility sector from "negative" to
10 "stable", Moody' s continues to note that high interest
11 rates and increased capital spending will place pressure
12 on credit metrics . Thus, Moody' s highlights
13 constructive regulatory outcomes that promote timely
14 cost recovery as a key factor in supporting utility
15 credit quality. 81
16 S&P also recently revised its outlook for the
17 industry; however, S&P downgraded its outlook from
18 stable to negative . 82 S&P noted that for the fifth
19 consecutive year it expects downgrades will exceed
20 upgrades with the industry facing significant risks over
21 the near-term as a result of physical risks due to
22 climate change, increased levels of capital spending and
81 Moody' s Investors Service, Outlook turns stable on low prices and
credit-supportive regulation. (Sept. 7, 2023) .
12 S&P Global Ratings, Rising Risks: Outlook For North American
Investor-Owned Regulated Utilities Weakens, (Feb. 14, 2024) .
Bulkley, Di 88
Rocky Mountain Power

1 cash-flow deficits that are not being "funded in a
2 sufficiently credit supportive manner" . 83 In regard to
3 the effect of increased capital spending, S&P noted:
4 The industry' s capital spending remains at
5 record levels, supporting initiatives for
6 safety, reliability, energy transition, and
7 growth. We consider these trends long term and
8 expect that capital spending will only
9 continue to increase over this decade .
10 Accordingly, cash flow deficits have
11 increased, pressuring the industry' s credit
12 quality. For 2024, our base case assumes that
13 the industry will fund its approximate $85
14 billion of cash flow deficits with about $40
15 billion in asset sales and equity issuance .
16 For 2023, the industry' s actual equity
17 issuance was considerably below our
18 expectations, resulting in a weakening of
19 financial performance and credit quality. If
20 this trend persists, credit quality will again
21 likely experience pressure in 2024 . 84
22 Fitch has stated that it is maintaining a
23 "deteriorating outlook" on the U. S . utility sector in
24 2024 based on elevated capital spending and continuing
25 higher interest rates that place pressure on credit
26 metrics . Fitch noted that bill affordability will
27 remain a major issue for the industry that could affect
28 future regulatory outcomes, and that while it expects
29 authorized ROES to start trending up with the increase
30 in interest rates, albeit with a lag, given the uncertain
83 Id.
84 Id. , at 6-8.
Bulkley, Di 89
Rocky Mountain Power

1 macroeconomic environment and bill pressure on
2 customers, the lag could be longer than in previous
3 cycles . 85
4 The continued concerns of the credit rating
5 agencies over the negative effects of inflation and
6 increased capital expenditures underscore the importance
7 of maintaining adequate cash flow metrics for the
8 industry as a whole, and PacifiCorp in particular in the
9 context of this proceeding.
10 X. CONCLUSIONS AND RECOMMENDATIONS
11 Q. What is your conclusion regarding a fair ROE for the
12 Company?
13 A. Based on the various quantitative analyses summarized in
14 Figure 15, a reasonable range for the Company' s ROE is
15 from 10 . 25 percent to 11 . 25 percent . Considering the
16 qualitative analyses presented in my direct testimony,
17 and the Company' s regulatory, business, and financial
18 risk relative to the proxy group, I conclude that the
19 Company has significantly greater risk than the proxy
20 group companies and therefore an ROE at the higher end
21 of the range of results is reasonable . However, the
22 return that the Company is requesting, 10 . 30 percent, is
85 Fitch Ratings, North American Utilities, Power & Gas Outlook, S&P
Market Intelligence (Nov. 13, 2023) .
Bulkley, Di 90
Rocky Mountain Power

1 at the low end of my range and takes into consideration
2 the effect of inflation on its customers .
3 Figure 15 : Summary of Analytical Results
Constant Growth DCF
Minimum Average Maximum
Growth Rate Growth Rate Growth Rate
Mean Results:
30-Day Avg. Stock Price 9.32% 10.63% 11.66%
90-Day Avg. Stock Price 9.39% 10.70% 11.73%
180-Day Avg. Stock Price 9.43% 10.74% 11.77%
Average 9.38% 10.69% 11.72%
Median Results:
30-Day Avg. Stock Price 9.40% 10.44% 11.39%
90-Day Avg. Stock Price 9.52% 10.46% 11.49%
180-Day Avg. Stock Price 9.57% 10.45% 11.55%
Average 9.50% 10.45% 11.48%
CAPM/ECAPM/Bond Yield Risk Premium
30-Year Treasury Bond Yield
Current Near-Term Longer-Term
30-Day Avg Projected Projected
CAPM:
Current Value Line Beta 12.25% 12.22% 12.21%
Current Bloomberg Beta 11.14% 11.08% 11.03%
Long-term Avg. Value Line Beta 10.92% 10.86% 10.81%
ECAPM:
Current Value Line Beta 12.41% 12.39% 12.38%
Current Bloomberg Beta 11.58% 11.53% 11.50%
Long-term Avg. Value Line Beta 11.42% 11.37% 11.33%
Bond Yield Risk Premium 10.67% 10.52% 10.39%
Bulkley, Di 91
Rocky Mountain Power

1 Q. What is your conclusion with respect to the Company' s
2 proposed capital structure?
3 A. My conclusion is that the Company' s proposal to
4 establish a capital structure consisting of 50 percent
5 common equity and 49 . 99 percent long-term debt, and
6 0 . 01 percent preferred stock is reasonable when compared
7 with the capital structures of the utility operating
8 companies owned by the proxy group companies . Further,
9 maintaining the Company' s credit ratings and the ability
10 to access capital on reasonable terms, particularly at
11 a time when the Company has significant capital
12 requirements, provides benefits to customers over the
13 long-term. Therefore, I conclude that the Company' s
14 proposed capital structure is reasonable and should be
15 approved.
16 Q. Does this conclude your direct testimony?
17 A. Yes .
Bulkley, Di 92
Rocky Mountain Power

Case No. PAC-E-24-04
Exhibit No. 4
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Resume and Testimony Listing of Ann E . Bulkley
May 2024

Rocky Mountain Power
Exhibit No.4 Page 1 of 20
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
Ed
Brattle Ann E. Bulkley
PRINCIPAL
Boston 508.981.0866 [e-mail]
With more than 25 years of experience in the energy industry, Ms.
Bulkley specializes in regulatory economics for the electric and natural
gas and water utility sectors, including valuation of regulated and
unregulated utility assets, cost of capital, and capital structure issues.
Ms. Bulkley has extensive state and federal regulatory experience, and she has provided expert
testimony on the cost of capital in nearly 100 regulatory proceedings before 32 state regulatory
commissions and the Federal Energy Regulatory Commission (FERC).
In addition to her regulatory experience, Ms. Bulkley has provided valuation and appraisal services for a
variety of purposes, including the sale or acquisition of utility assets, regulated ratemaking, ad valorem
tax disputes, and other litigation purposes. In addition, she has experience in the areas of contract and
business unit valuation, strategic alliances, market restructuring, and regulatory and litigation support.
Ms. Bulkley is a Certified General Appraiser licensed in the Commonwealth of Massachusetts and the
State of New Hampshire.
Prior to joining Brattle, Ms. Bulkley was a Senior Vice President at an economic consultancy and held
senior positions at several other consulting firms.
AREAS OF EXPERTISE
• Regulatory Economics, Finance & Rates
• Regulatory Investigations & Enforcement
• Tax Controversy&Transfer Pricing
• Electricity Litigation & Regulatory Disputes
• M&A Litigation
ME Brattle Ann E. Bulkley brattle.com 1

Rocky Mountain Power
Exhibit No.4 Page 2 of 20
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
Brattle
EDUCATION
• Boston University
MA in Economics
• Simmons College
BA in Economics and Finance
PROFESSIONAL EXPERIENCE
• The Brattle Group(2022—Present)
Principal
• Concentric Energy Advisors, Inc. (2002-2021)
Senior Vice President
Vice President
Assistant Vice President
Project Manager
• Navigant Consulting, Inc. (1997-2002)
Project Manager
• Reed Consulting Group(1995-1997)
Consultant- Project Manager
• Cahners Publishing Company(1995)
Economist
SELECTED CONSULTING EXPERIENCE & EXPERT TESTIMONY
REGULATORY ANALYSIS AND RATEMAKING
Have provided a range of advisory services relating to regulatory policy analysis and many aspects of
utility ratemaking, with specific services including:
• Cost of capital and return on equity testimony, cost of service and rate design analysis and
testimony, development of ratemaking strategies
• Development of merchant function exit strategies
MEBrattle Ann E. Bulkley brattle.com 2

Rocky Mountain Power
Exhibit No.4 Page 3 of 20
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
Ed
Brattle
• Analysis and program development to address residual energy supply and/or provider of last resort
obligations
• Stranded costs assessment and recovery
Performance-based ratemaking analysis and design
• Many aspects of traditional utility ratemaking(e.g., rate design, rate base valuation)
COST OF CAPITAL
Have provided expert testimony on the cost of capital and capital structure in nearly 100 regulatory
proceedings before state and federal regulatory commissions in the United States.
RATEMAKING
Have assisted several clients with analysis to support investor-owned and municipal utility clients in the
preparation of rate cases. Sample engagements include:
• Assisted several investor-owned and municipal clients on cost allocation and rate design issues
including the development of expert testimony supporting recommended rate alternatives.
• Worked with Canadian regulatory staff to establish filing requirements for a rate review of a newly
regulated electric utility.Along with analyzing and evaluating rate application, attended hearings
and conducted investigation of rate application for regulatory staff and prepared, supported, and
defended recommendations for revenue requirements and rates for the company.Additionally,
developed rates for gas utility for transportation program and ancillary services.
VALUATION
Have provided valuation services to utility clients, unregulated generators, and private equity clients for
a variety of purposes, including ratemaking,fair value, ad valorem tax, litigation and damages, and
acquisition.Appraisal practices are consistent with the national standards established by the Uniform
Standards of Professional Appraisal Practice.
Representative projects/clients have included:
• Prepared appraisals of electric utility transmission and distribution assets for ad valorem tax
purposes.
• Prepared appraisals of hydroelectric generating facilities for ad valorem tax purposes.
• Conducted appraisals of fossil fuel generating facilities for ad valorem tax purposes.
• Conducted appraisals of generating assets for the purposes of unwinding sale-leaseback
agreements.
• For a confidential utility client, prepared valuation of fossil and nuclear generation assets for
financing purposes for regulated utility client.
Brattle Ann E. Bulkley brattle.com 3

Rocky Mountain Power
Exhibit No.4 Page 4 of 20
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
Ed
Brattle
• Conducted a strategic review of the acquisition of nuclear generation assets. Review included the
evaluation of the operating costs of the facilities and the long-term liabilities associated with the
assets including the decommissioning of the assets.
• Prepared a valuation of a portfolio of generation assets for a large energy utility to be used for
strategic planning purposes.Valuation approach included an income approach, a real options
analysis, and a risk analysis.
• Assisted clients in the restructuring of NUG contracts through the valuation of the underlying assets.
Performed analysis to determine the option value of a plant in a competitively priced electricity
market following the settlement of the NUG contract.
• Prepared market valuations of several purchase power contracts for large electric utilities in the sale
of purchase power contracts.Assignment included an assessment of the regional power market,
analysis of the underlying purchase power contracts, and a traditional discounted cash flow
valuation approach, as well as a risk analysis.Analyzed bids from potential acquirers using income
and risk analysis approached. Prepared an assessment of the credit issues and value at risk for the
selling utility.
• Prepared appraisal of a portfolio of generating facilities for a large electric utility to be used for
financing purposes.
• Conducted a valuation of regulated utility assets for the fair value rate base estimate used in
electric rate proceedings in Indiana.
• Prepared an appraisal of a fleet of fossil generating assets for a large electric utility to establish the
value of assets transferred from utility property.
• Conducted due diligence on an electric transmission and distribution system as part of a buy-side
due diligence team.
• Provided analytical support and prepared testimony regarding the valuation of electric distribution
system assets in five communities in a condemnation proceeding.
• Prepared feasibility reports analyzing the expected net benefits resulting from municipal ownership
of investor-owned utility operations.
• Prepared independent analyses of proposal for the proposed government condemnation of the
investor-owned utilities in Maine and the formation of a public power district.
• Valued purchase power agreements in the transfer of assets to a deregulated electric market.
STRATEGIC AND FINANCIAL ADVISORY SERVICES
Have assisted several clients across North America with analytically-based strategic planning, due
diligence, and financial advisory services.
Representative projects include:
Brattle Ann E. Bulkley brattle.com 14

Rocky Mountain Power
Exhibit No.4 Page 5 of 20
Case PAC04
Witness:s:Ann E..Bulkl Bulkley
Brattle
• Preparation of feasibility studies for bond issuances for municipal and district steam clients.
• Assisted in the development of a generation strategy for an electric utility. Analyzed various NERC
regions to identify potential market entry points. Evaluated potential competitors and alliance
partners. Assisted in the development of gas and electric price forecasts. Developed a framework for
the implementation of a risk management program.
• Assisted clients in identifying potential joint venture opportunities and alliance partners. Contacted
interviewed and evaluated potential alliance candidates based on company-established criteria for
several LDCs and marketing companies. Worked with several LDCs and unregulated marketing
companies to establish alliances to enter into the retail energy market. Prepared testimony in
support of several merger cases and participated in the regulatory process to obtain approval for
these mergers.
• Assisted clients in several buy-side due diligence efforts, providing regulatory insight and developing
valuation recommendations for acquisitions of both electric and gas properties.
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Rocky Mountain Power
Exhibit No.4 Page 6 of 20
Case PAC-E-24-04
Witness:
Ann E.Bulkley
Brattle
BULKLEY TESTIMONY LISTING
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
Arizona Corporation Commission
UNS Electric 11/22 UNS Electric Docket No. E-04204A- Return on Equity
15-0251
Tucson Electric Power 6/22 Tucson Electric Power Docket No. G-01933A- Return on Equity
Company Company 22-0107
Southwest Gas Corporation 12/21 Southwest Gas Docket No. G-01551A- Return on Equity
Corporation 21-0368
Arizona Public Service 10/19 Arizona Public Service Docket No. E-01345A- Return on Equity
Company Company 19-0236
Tucson Electric Power 04/19 Tucson Electric Power Docket No. E-01933A- Return on Equity
Company Company 19-0028
Tucson Electric Power 11/15 Tucson Electric Power Docket No. E-01933A- Return on Equity
Company Company 15-0322
UNS Electric 05/15 UNS Electric Docket No. E-04204A- Return on Equity
15-0142
UNS Electric 12/12 UNS Electric Docket No. E-04204A- Return on Equity
12-0504
Arkansas Public Service Commission
Oklahoma Gas and Electric Co 10/21 Oklahoma Gas and Electric Docket No. D-18-046- Return on Equity
Co FR
Arkansas Oklahoma Gas 10/13 Arkansas Oklahoma Gas Docket No. 13-078-U Return on Equity
Corporation Corporation
California Public Utilities Commission
PacifiCorp, d/b/a Pacific 5/22 PacifiCorp, d/b/a Pacific Docket No.A-22-05- Return on Equity
Power Power 006
San Jose Water Company 05/21 San Jose Water Company A2105004 Return on Equity
Colorado Public Utilities Commission
Public Service Company of 01/24 Public Service Company of Docket No. 24AL- G Return on Equity
Colorado Colorado
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Rocky Mountain Power
Exhibit No.4 Page 7 of 20
Case PAC-E-24-04
Witness:
Ann E.Bulkley
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
Public Service Company of 11/22 Public Service Company of Docket No. 22AL-0530E Return on Equity
Colorado Colorado
Public Service Company of 01/22 Public Service Company of Docket No. 22AL-0046G Return on Equity
Colorado Colorado
Public Service Company of 07/21 Public Service Company of 21AL-0317E Return on Equity
Colorado Colorado
Public Service Company of 02/20 Public Service Company of 20AL-0049G Return on Equity
Colorado Colorado
Public Service Company of 05/19 Public Service Company of 19AL-0268E Return on Equity
Colorado Colorado
Public Service Company of 01/19 Public Service Company of 19AL-0063ST Return on Equity
Colorado Colorado
Atmos Energy Corporation 05/15 Atmos Energy Corporation Docket No. 15AL-0299G Return on Equity
Atmos Energy Corporation 04/14 Atmos Energy Corporation Docket No. 14AL-0300G Return on Equity
Atmos Energy Corporation 05/13 Atmos Energy Corporation Docket No. 13AL-0496G Return on Equity
Connecticut Public Utilities Regulatory Authority
The Southern Connecticut Gas 11/23 The Southern Connecticut Docket No. 23-11-02 Return on Equity
Company Gas Company
Connecticut Natural Gas 11/23 Connecticut Natural Gas Docket No. 23-11-02 Return on Equity
Corporation Corporation
Connecticut Water Company 10/23 Connecticut Water Docket No.23-08-32 Return on Equity
Company
United Illuminating 09/22 United Illuminating Docket No.22-08-08 Return on Equity
United Illuminating 05/21 United Illuminating Docket No. 17-12- Return on Equity
03RE11
Connecticut Water Company 01/21 Connecticut Water Docket No.20-12-30 Return on Equity
Company
Connecticut Natural Gas 06/18 Connecticut Natural Gas Docket No. 18-05-16 Return on Equity
Corporation Corporation
Yankee Gas Services Co.d/b/a 06/18 Yankee Gas Services Co. Docket No. 18-05-10 Return on Equity
Eversource Energy d/b/a Eversource Energy
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Rocky Mountain Power
Exhibit No.4 Page 8 of 20
Case PAC-E-24-04
Witness:
Ann E.Bulkley
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
The Southern Connecticut Gas 06/17 The Southern Connecticut Docket No. 17-05-42 Return on Equity
Company Gas Company
The United Illuminating 07/16 The United Illuminating Docket No. 16-06-04 Return on Equity
Company Company
Federal Energy Regulatory Commission
Sea Robin Pipeline 12/22 Sea Robin Pipeline Docket No. RP22-_ Return on Equity
Northern Natural Gas 07/22 Northern Natural Gas Docket No. RP22-_ Return on Equity
Company Company
Transwestern Pipeline 07/22 Transwestern Pipeline Docket No. RP22-_ Return on Equity
Company, LLC Company, LLC
Florida Gas Transmission 02/21 Florida Gas Transmission Docket No. RP21-441 Return on Equity
TransCanyon 01/21 TransCanyon Docket No. ER21-1065 Return on Equity
Duke Energy 12/20 Duke Energy Docket No. EL21-9-000 Return on Equity
Wisconsin Electric Power 08/20 Wisconsin Electric Power Docket No. EL20-57- Return on Equity
Company Company 000
Panhandle Eastern Pipe Line 10/19 Panhandle Eastern Pipe Docket Nos. Return on Equity
Company, LP Line Company, LP RP19-78-000
RP19-78-001
Panhandle Eastern Pipe Line 08/19 Panhandle Eastern Pipe Docket Nos. Return on Equity
Company, LP Line Company, LP RP19-1523
Sea Robin Pipeline Company 11/18 Sea Robin Pipeline Docket#RP19-352-000 Return on Equity
LLC Company LLC
Tallgrass Interstate Gas 10/15 Tallgrass Interstate Gas RP16-137 Return on Equity
Transmission Transmission
Idaho Public Utilities Commission
Intermountain Gas Co 12/22 Intermountain Gas Co C-INT-G-22-07 Return on Equity
PacifiCorp d/b/a Rocky 05/21 PacifiCorp d/b/a Rocky Case No. PAC-E-21-07 Return on Equity
Mountain Power Mountain Power
Illinois Commerce Commission
Peoples Gas Light&Coke 01/23 Peoples Gas Light&Coke D-23-0069 Return on Equity
Company Company
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Rocky Mountain Power
Exhibit No.4 Page 9 of 20
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
Ed
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
North Shore Gas Company 01/23 North Shore Gas D-23-0068 Return on Equity
Company
Illinois American Water 02/22 Illinois American Water Docket No. 22-0210 Return on Equity
North Shore Gas Company 02/21 North Shore Gas No. 20-0810 Return on Equity
Company
Indiana Utility Regulatory Commission
Southern Indiana Gas and 12/23 Southern Indiana Gas and IURC Cause No.45990 Return on Equity
Electric Company d/b/a Electric Company d/b/a
CenterPoint Energy Indiana CenterPoint Energy
South Indiana South
Indiana Michigan Power Co. 08/23 Indiana Michigan Power IURC Cause No.45933 Return on Equity
Co.
Indiana American Water 03/23 Indiana and Michigan IURC Cause No.45870 Return on Equity
Company American Water
Company
Indiana Michigan Power Co. 07/21 Indiana Michigan Power IURC Cause No.45576 Return on Equity
Co.
Indiana Gas Company Inc. 12/20 Indiana Gas Company Inc. IURC Cause No.45468 Return on Equity
Southern Indiana Gas and 10/20 Southern Indiana Gas and IURC Cause No.45447 Return on Equity
Electric Company Electric Company
Indiana and Michigan 09/18 Indiana and Michigan IURC Cause No.45142 Return on Equity
American Water Company American Water
Company
Indianapolis Power and Light 12/17 Indianapolis Power and Cause No.45029 Fair Value
Company Light Company
Northern Indiana Public 09/17 Northern Indiana Public Cause No.44988 Fair Value
Service Company Service Company
Indianapolis Power and Light 12/16 Indianapolis Power and Cause No.44893 Fair Value
Company Light Company
Northern Indiana Public 10/15 Northern Indiana Public Cause No.44688 Fair Value
Service Company Service Company
Indianapolis Power and Light 09/15 Indianapolis Power and Cause No.44576 Fair Value
Company Light Company Cause No.44602
AV
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Rocky Mountain Power
Exhibit No.4 Page 10 of 20
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
Kokomo Gas and Fuel 09/10 Kokomo Gas and Fuel Cause No.43942 Fair Value
Company Company
Northern Indiana Fuel and 09/10 Northern Indiana Fuel Cause No.43943 Fair Value
Light Company, Inc. and Light Company, Inc.
Iowa Department of Commerce Utilities Board
MidAmerican Energy 06/23 MidAmerican Energy Docket No. RPU-2023- Return on Equity
Company Company
MidAmerican Energy 01/22 MidAmerican Energy Docket No. RPU-2022- Return on Equity
Company Company 0001
Iowa-American Water 08/20 Iowa-American Water Docket No. RPU-2020- Return on Equity
Company Company 0001
Kansas Corporation Commission
Evergy Kansas 04/23 Evergy Kansas Docket No. 23-EKCE- Return on Equity
775-RTS
Atmos Energy Corporation 08/15 Atmos Energy Corporation Docket No. 16-ATMG- Return on Equity
079-RTS
Kentucky Public Service Commission
Kentucky American Water 06/23 Kentucky American Water Docket No. 2023- Return on Equity
Company Company
Kentucky American Water 11/18 Kentucky American Water Docket No. 2018-00358 Return on Equity
Company Company
Maine Public Utilities Commission
Central Maine Power 08/22 Central Maine Power Docket No.2022-00152 Return on Equity
Central Maine Power 10/18 Central Maine Power Docket No.2018-194 Return on Equity
Maryland Public Service Commission
Maryland American Water 06/18 Maryland American Water Case No.9487 Return on Equity
Company Company
Massachusetts Appellate Tax Board
Hopkinton LNG Corporation 03/20 Hopkinton LNG Docket No. Valuation of LNG
Corporation Facility
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Rocky Mountain Power
Exhibit No.4 Page 11 of 20
Case PAC-E-24-04
Witness:
Ann E.Bulkley
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
FirstLight Hydro Generating 06/17 FirstLight Hydro Docket No. F-325471 Valuation of
Company Generating Company Docket No. F-325472 Electric
Docket No. F-325473 Generation Assets
Docket No. F-325474
Massachusetts Department of Public Utilities
Massachusetts Electric 11/23 Massachusetts Electric DPU 23-150 Return on Equity
Company Company
Nantucket Electric Company Nantucket Electric
d/b/a National Grid Company
d/b/a National Grid
National Grid USA 11/20 Boston Gas Company DPU 20-120 Return on Equity
Berkshire Gas Company 05/18 Berkshire Gas Company DPU 18-40 Return on Equity
Unitil Corporation 01/04 Fitchburg Gas and Electric DTE 03-52 Integrated
Resource Plan,
Gas Demand
Forecast
Michigan Public Service Commission
Michigan Gas Utilities 03/24 Michigan Gas Utilities Case No. U-21540 Return on Equity
Corporation Corporation
Indiana Michigan Power Co. 09/23 Indiana Michigan Power Case No. U-21461 Return on Equity
Co.
Michigan Gas Utilities 03/23 Michigan Gas Utilities Case No. U-21366 Return on Equity
Corporation Corporation
Michigan Gas Utilities 03/21 Michigan Gas Utilities Case No. U-20718 Return on Equity
Corporation Corporation
Wisconsin Electric Power 12/11 Wisconsin Electric Power Case No. U-16830 Return on Equity
Company Company
Michigan Tax Tribunal
New Covert Generating Co., 03/18 The Township of New MTT Docket No. Valuation of
LLC. Covert Michigan 000248TT and 16- Electric
001888-TT Generation Assets
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Rocky Mountain Power
Exhibit No.4 Page 12 of 20
Case PAC-E-24-04
Witness:
Ann E.Bulkley
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
Covert Township 07/14 New Covert Generating Docket No. 399578 Valuation of
Co., LLC. Electric
Generation Assets
Minnesota Public Utilities Commission
ALLETE, Inc.d/b/a Minnesota 11/23 Allete, Inc.d/b/a D-E-015/GR-23-155 Return on Equity
Power Minnesota Power
CenterPoint Energy Resources 11/23 CenterPoint Energy D-G-008/GR-23-173 Return on Equity
Resources
Minnesota Energy Resources 11/22 Minnesota Energy Docket No.G011/GR- Return on Equity
Corporation Resources 22-504
Corporation
CenterPoint Energy Resources 11/21 CenterPoint Energy D-G-008/GR-21-435 Return on Equity
Resources
ALLETE, Inc.d/b/a Minnesota 11/21 Allete, Inc.d/b/a D-E-015/GR-21-630 Return on Equity
Power Minnesota Power
Otter Tail Power Company 11/20 Otter Tail Power Company E017/GR-20-719 Return on Equity
ALLETE, Inc.d/b/a Minnesota 11/19 Allete, Inc.d/b/a E015/GR-19-442 Return on Equity
Power Minnesota Power
CenterPoint Energy Resources 10/19 CenterPoint Energy G-008/GR-19-524 Return on Equity
Corporation d/b/a Resources Corporation
CenterPoint Energy d/b/a CenterPoint Energy
Minnesota Gas Minnesota Gas
Great Plains Natural Gas Co. 09/19 Great Plains Natural Gas Docket No. G004/GR- Return on Equity
Co. 19-511
Minnesota Energy Resources 10/17 Minnesota Energy Docket No.G011/GR- Return on Equity
Corporation Resources 17-563
Corporation
Missouri Public Service Commission
Evergy Missouri West 2/24 Evergy Missouri West File No. ER-2024-0189 Return on Equity
Ameren Missouri 08/22 Ameren Missouri File No. ER-2022-0337 Return on Equity
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Rocky Mountain Power
Exhibit No.4 Page 13 of 20
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
Ed
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
Missouri American Water 07/22 Missouri American Water Case No.WR-2022- Return on Equity
Company Company 0303
Case No.SR-2022-0304
Evergy Missouri West 1/22 Evergy Missouri West File No. ER-2022-0130 Return on Equity
Evergy Missouri Metro 1/22 Evergy Missouri Metro File No. ER-2022-0129 Return on Equity
Ameren Missouri 03/21 Ameren Missouri Docket No. ER-2021- Return on Equity
0240
Docket No. GR-2021-
0241
Missouri American Water 06/20 Missouri American Water Case No.WR-2020- Return on Equity
Company Company 0344
Case No.SR-2020-0345
Missouri American Water 06/17 Missouri American Water Case No.WR-17-0285 Return on Equity
Company Company Case No.SR-17-0286
Montana Public Service Commission
Montana-Dakota Utilities Co. 11/22 Montana-Dakota Utilities D2022.11.099 Return on Equity
Co.
Montana-Dakota Utilities Co. 06/20 Montana-Dakota Utilities D2020.06.076 Return on Equity
Co.
Montana-Dakota Utilities Co. 09/18 Montana-Dakota Utilities D2018.9.60 Return on Equity
Co.
New Hampshire-Board of Tax and Land Appeals
Liberty Utilities(EnergyNorth 07/23 Liberty Utilities Docket No. DG 23-067 Return on Equity
Natural Gas) (EnergyNorth Natural
Gas)
Liberty Utilities(Granite State 05/23 Liberty Utilities(Granite Docket No. DE 23-039 Return on Equity
Electric) State Electric)
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Exhibit No.4 Page 14 of 20
Case PAC-E-24-04
Witness:
Ann E.Bulkley
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
Public Service Company of 11/19 Public Service Company Master Docket No. Valuation of
New Hampshire d/b/a 12/19 of New Hampshire d/b/a 28873-14-15-16-17PT Utility Property
Eversource Energy Eversource Energy and
Generating
Assets
New Hampshire Public Utilities Commission
Public Service Company of 05/19 Public Service Company of DE-19-057 Return on Equity
New Hampshire New Hampshire
New Hampshire-Merrimack County Superior Court
Northern New England 04/18 Northern New England 220-2012-CV-1100 Valuation of
Telephone Operations, LLC Telephone Operations, LLC Utility Property
d/b/a FairPoint d/b/a FairPoint
Communications, NNE Communications, NNE
New Hampshire-Rockingham Superior Court
Eversource Energy 05/18 Public Service Commission 218-2016-CV-00899 Valuation of
of New Hampshire 218-2017-CV-00917 Utility Property
New Jersey Board of Public Utilities
Elizabethtown Gas Company 2/24 Elizabethtown Gas GR24020158 Return on Equity
Company
Public Service Electric and Gas 11/23 Public Service Electric and ER23120924 Return on Equity
Company Gas Company GR23120925
New Jersey American Water 01/22 New Jersey American WR22010019 Return on Equity
Company, Inc. Water Company, Inc.
Public Service Electric and Gas 10/20 Public Service Electric and E018101115 Return on Equity
Company Gas Company
New Jersey American Water 12/19 New Jersey American WR19121516 Return on Equity
Company, Inc. Water Company, Inc.
Public Service Electric and Gas 04/19 Public Service Electric and E018060629 Return on Equity
Company Gas Company G018060630
Public Service Electric and Gas 02/18 Public Service Electric and GR17070776 Return on Equity
Company Gas Company
Public Service Electric and Gas 01/18 Public Service Electric and ER18010029 Return on Equity
Company Gas Company GR18010030
RBrattle Ann E. Bulkley brattle.com 1 14

Rocky Mountain Power
Exhibit No.4 Page 15 of 20
Case PAC-E-24-04
Witness:
Ann E.Bulkley
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
New Mexico Public Regulation Commission
Southwestern Public Service 07/19 Southwestern Public 19-00170-UT Return on Equity
Company Service Company
Southwestern Public Service 10/17 Southwestern Public Case No. 17-00255-UT Return on Equity
Company Service Company
Southwestern Public Service 12/16 Southwestern Public Case No. 16-00269-UT Return on Equity
Company Service Company
Southwestern Public Service 10/15 Southwestern Public Case No. 15-00296-UT Return on Equity
Company Service Company
Southwestern Public Service 06/15 Southwestern Public Case No. 15-00139-UT Return on Equity
Company Service Company
New York State Department of Public Service
Liberty Utilities(New York 5/23 Liberty Utilities(New York Case 23-W-0235 Return on Equity
Water) Water)
New York State Electric and 05/22 New York State Electric 22-E-0317 Return on Equity
Gas Company and Gas Company 22-G-0318
22-E-0319
Rochester Gas and Electric Rochester Gas and Electric 22-G-0320
Corning Natural Gas 07/21 Corning Natural Gas Case No.21-G-0394 Return on Equity
Corporation Corporation
Central Hudson Gas and 08/20 Central Hudson Gas and Electric 20-E-0428 Return on Equity
Electric Corporation Electric Corporation Gas 20-G-0429
Niagara Mohawk Power 07/20 National Grid USA Case No.20-E-0380 Return on Equity
Corporation 20-G-0381
Corning Natural Gas 02/20 Corning Natural Gas Case No.20-G-0101 Return on Equity
Corporation Corporation
New York State Electric and 05/19 New York State Electric 19-E-0378 Return on Equity
Gas Company and Gas Company 19-G-0379
19-E-0380
Rochester Gas and Electric Rochester Gas and Electric 19-G-0381
Brattle Ann E. Bulkley brattle.com 1 15

Rocky Mountain Power
Exhibit No.4 Page 16 of 20
Case PAC-E-24-04
Witness:
Ann E.Bulkley
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
Brooklyn Union Gas Company 04/19 Brooklyn Union Gas 19-G-0309 Return on Equity
d/b/a National Grid NY Company d/b/a National 19-G-0310
KeySpan Gas East Corporation Grid NY
d/b/a National Grid KeySpan Gas East
Corporation d/b/a National
Grid
Central Hudson Gas and 07/17 Central Hudson Gas and Electric 17-E-0459 Return on Equity
Electric Corporation Electric Corporation Gas 17-G-0460
Niagara Mohawk Power 04/17 National Grid USA Case No. 17-E-0238 Return on Equity
Corporation 17-G-0239
Corning Natural Gas 06/16 Corning Natural Gas Case No. 16-G-0369 Return on Equity
Corporation Corporation
National Fuel Gas Company 04/16 National Fuel Gas Case No. 16-G-0257 Return on Equity
Company
KeySpan Energy Delivery 01/16 KeySpan Energy Delivery Case No. 15-G-0058 Return on Equity
Case No. 15-G-0059
New York State Electric and 05/15 New York State Electric Case No. 15-E-0283 Return on Equity
Gas Company and Gas Company Case No. 15-G-0284
Rochester Gas and Electric Rochester Gas and Electric Case No. 15-E-0285
Case No. 15-G-0286
North Dakota Public Service Commission
Otter Tail Power Company 11/23 Otter Tail Power Company Case No. PU-23-_ Return on Equity
Montana-Dakota Utilities Co. 11/23 Montana-Dakota Utilities Case No. PU-23-_ Return on Equity
Co.
Montana-Dakota Utilities Co. 05/22 Montana-Dakota Utilities C-PU-22-194 Return on Equity
Co.
Montana-Dakota Utilities Co. 08/20 Montana-Dakota Utilities C-PU-20-379 Return on Equity
Co.
Northern States Power 12/12 Northern States Power C-PU-12-813 Return on Equity
Company Company
Northern States Power 12/10 Northern States Power C-PU-10-657 Return on Equity
Company Company
RBrattle Ann E. Bulkley brattle.com 1 16

Rocky Mountain Power
Exhibit No.4 Page 17 of 20
Case PAC-E-24-04
Witness:
Ann E.Bulkley
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
Oklahoma Corporation Commission
Oklahoma Gas& Electric 12/23 Oklahoma Gas& Electric Cause No. PUD2023- Return on Equity
000087
Oklahoma Gas&Electric 12/21 Oklahoma Gas&Electric Cause No. PUD Return on Equity
202100164
Arkansas Oklahoma Gas 01/13 Arkansas Oklahoma Gas Cause No. PUD Return on Equity
Corporation Corporation 201200236
Oregon Public Service Commission
PacifiCorp d/b/a Pacific 03/22 PacifiCorp d/b/a Pacific Docket No. UE-399 Return on Equity
Power&Light Power& Light
PacifiCorp d/b/a Pacific 02/20 PacifiCorp d/b/a Pacific Docket No. UE-374 Return on Equity
Power& Light Power& Light
Pennsylvania Public Utility Commission
American Water Works 11/23 Pennsylvania-American Docket No. R-2023- Return on Equity
Company Inc. Water Company 3043189 (water)
Docket No. R-2023-
3043190(wastewater)
American Water Works 04/22 Pennsylvania-American Docket No. R-2020- Return on Equity
Company Inc. Water Company 3031672 (water)
Docket No. R-2020-
3031673 (wastewater)
American Water Works 04/20 Pennsylvania-American Docket No. R-2020- Return on Equity
Company Inc. Water Company 3019369 (water)
Docket No. R-2020-
3019371(wastewater)
American Water Works 04/17 Pennsylvania-American Docket No. R-2017- Return on Equity
Company Inc. Water Company 2595853
South Dakota Public Utilities Commission
MidAmerican Energy 05/22 MidAmerican Energy D-NG22-005 Return on Equity
Company Company
Northern States Power 06/14 Northern States Power Docket No. EL14-058 Return on Equity
Company Company
FEBrattle Ann E. Bulkley brattle.com 1 17

Rocky Mountain Power
Exhibit No.4 Page 18 of 20
Case PAC-E-24-04
Witness:
Ann E.Bulkley
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
Texas Public Utility Commission
I-
Entergy Texa Inc. 07/22 Entergy Texas, Inc. D-53719 Return on Equity
Southwestern Public Service 08/19 Southwestern Public Docket No. D-49831 Return on Equity
Commission Service Commission
Southwestern Public Service 01/14 Southwestern Public Docket No.42004 Return on Equity
Company Service Company
Texas Railroad Commission
CenterPoint Energy Entex and 10/23 CenterPoint Energy Entex 2023 Texas Division Return on Equity
CenterPoint Energy Texas Gas and CenterPoint Energy Rate Case
Texas Gas Case No. OS-23-
00015513
Utah Public Service Commission
PacifiCorp d/b/a Rocky 05/20 PacifiCorp d/b/a Rocky Docket No. 20-035-04 Return on Equity
Mountain Power Mountain Power
Virginia State Corporation Commission
Virginia American Water 11/23 Virginia American Water Docket No. PUR-2023- Return on Equity
Company, Inc. Company, Inc. 00194
Virginia American Water 11/21 Virginia American Water Docket No. PUR-2021- Return on Equity
Company, Inc. Company, Inc. 00255
Virginia American Water 11/18 Virginia American Water Docket No. PUR-2018- Return on Equity
Company, Inc. Company, Inc. 00175
Washington Utilities Transportation Commissior
Cascade Natural Gas 03/24 Cascade Natural Gas Docket No. UG-24008 Return on Equity
Corporation Corporation
PacifiCorp d/b/a Pacific 03/23 PacifiCorp d/b/a Pacific Docket No. UE-230172 Return on Equity
Power& Light Power& Light
Cascade Natural Gas 06/20 Cascade Natural Gas Docket No. UG-200568 Return on Equity
Corporation Corporation
PacifiCorp d/b/a Pacific 12/19 PacifiCorp d/b/a Pacific Docket No. UE-191024 Return on Equity
Power& Light Power&Light
RBrattle Ann E. Bulkley brattle.com 1 18

Rocky Mountain Power
Exhibit No.4 Page 19 of 20
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
Ed
Brattle
SPONSOR DATE CASE/APPLICANT DOCKET/CASE NO. SUBJECT
Cascade Natural Gas 04/19 Cascade Natural Gas Docket No. UG-190210 Return on Equity
Corporation Corporation
West Virginia Public Service Commission
West Virginia American Water 05/23 West Virginia American Case No.23-0383-W- Return on Equity
Company Water Company 42T
West Virginia American Water 04/21 West Virginia American Case No.21-02369-W- Return on Equity
Company Water Company 42T
West Virginia American Water 04/18 West Virginia American Case No. 18-0573-W- Return on Equity
Company Water Company 42T
Case No. 18-0576-S-42T
Wisconsin Public Service Commission
Wisconsin Power and Light 05/23 Wisconsin Power and Light Docket No. 6680-UR- Return on Equity
124
Wisconsin Electric Power 04/22 Wisconsin Electric Power Docket No.05-UR-110 Return on Equity
Company and Wisconsin Gas Company and Wisconsin
LLC Gas LLC
Wisconsin Public Service Corp. 04/22 Wisconsin Public Service 6690-UR-127 Return on Equity
Corp.
Alliant Energy Alliant Energy Return on Equity
Wisconsin Electric Power 03/19 Wisconsin Electric Power Docket No.05-UR-109 Return on Equity
Company and Wisconsin Gas Company and Wisconsin
LLC Gas LLC
Wisconsin Public Service Corp. 03/19 Wisconsin Public Service 6690-UR-126 Return on Equity
Corp.
Wyoming Public Service Commission
PacifiCorp d/b/a Rocky 02/23 PacifiCorp d/b/a Rocky Docket No. 20000-633- Return on Equity
Mountain Power Mountain Power ER-23
PacifiCorp d/b/a Rocky 03/20 PacifiCorp d/b/a Rocky Docket No. 20000-578- Return on Equity
Mountain Power Mountain Power ER-20
Montana-Dakota Utilities Co. 05/19 Montana-Dakota Utilities 30013-351-GR-19 Return on Equity
Co.
Brattle Ann E. Bulkley brattle.com 1 19

Rocky Mountain Power
Exhibit No.4 Page 20 of 20
Case PAC04
Witness:s:Ann E..Bulkl Bulkley
Brattle
CERTIFI CAT IONS/ACCREDI TAT 10NS
Certified General Appraiser, licensed in the Commonwealth of Massachusetts
Brattle Ann E. Bulkley brattle.com 1 20

Case No. PAC-E-24-04
Exhibit No. 5
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Summary of Results
May 2024

Rocky Mountain Power
Exhibit No.5 Page 1 of 2
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
COST OF EQUITY ANALYSES
SUMMARY OF RESULTS
Constant Growth DCF
Minimum Average Maximum
Growth Rate Growth Rate Growth Rate
Mean Results:
30-Day Avg.Stock Price 9.32% 10.63% 11.66%
90-Day Avg.Stock Price 9.39% 10.70% 11.73%
180-Day Avg.Stock Price 9.43% 10.74% 11.77%
Average 9.38% 10.69% 11.72%
Median Results:
30-Day Avg.Stock Price 9.40% 10.44% 11.39%
90-Day Avg.Stock Price 9.52% 10.46% 11.49%
180-Day Avg.Stock Price 9.57% 10.45% 11.55%
Average 9.50% 10.45% 11.48%
CAPM/ECAPM/Bond Yield Risk Premium
30-Year Treasury Bond Yield
Current Near-Term Longer-Term
30-Day Avg Projected Projected
CAPM:
Current Value Line Beta 12.25% 12.22% 12.21%
Current Bloomberg Beta 11.14% 11.08% 11.03%
Long-term Avg. Value Line Beta 10.92% 10.86% 10.81%
ECAPM:
Current Value Line Beta 12.41% 12.39% 12.38%
Current Bloomberg Beta 11.58% 11.53% 11.50%
Long-term Avg. Value Line Beta 11.42% 11.37% 11.33%
Bond Yield Risk Premium 10.67% 10.52% 10.39%

Rocky Mountain Power
Exhibit No.5 Page 2 of 2
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
X Y
Constant Growth Mean DCF 9.38% 8.0 Constant Growth DCF Mean
10.69% 8.0
11.72% 8.0
Constant Growth Median DCF 9.50% 7.0 Constant Growth DCF-Median
10.45% 7.0
11.48% 7.0 i
CAPM 10.81% 3.0
12.25% 3.0
ECAPM 11.33% 2.0 Recommended ROE
12.41% 2.0 Range
Risk Premium 10.39% 0.5
10.67% 0.5 Company
Low End ROE Recommendation 10.25% 0.0 Proposed ROE
10.25% 9.0 CAPM
High End ROE Recommendation 11.25% 0.0
11.25% 9.0
Company Proposed ROE 10.30% 4.0 j j ECAPM
i Risk I
j Premium j
8.50% 9.00% 9.50% 10.00% 10.50% 11.00% 11.50% 12.00% 12.50%

Case No. PAC-E-24-04
Exhibit No. 6
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Proxy Group Selection
May 2024

Rocky Mountain Power
Exhibit No.6 Page 1 of 1
Case No.PAC-E-24-04
PROXY GROUP SCREENING DATA AND RESULTS Witness:Ann E.Bulkley
[1] [2] [3] [4] [5] [6] [7] [9]
Positive Growth Rates %Company- %Regulated
S&P Credit from at least two sources Generation Owned Electric
Rating Between Covered by More (Value Line,Yahoo!First Assets Included Generation> Operating Announced
Company Ticker Dividends BBB-and AAA Than 1 Analyst Call,and Zacks) in Rate Base 40% Income>60% Merger
ALLETE,Inc. ALE Yes BBB Yes Yes Yes 43.27% 100.56% No
Alliant Energy Corporation LNT Yes A- Yes Yes Yes 72.75% 87.90% No
Ameren Corporation AEE Yes BBB+ Yes Yes Yes 75.34% 84.57% No
American Electric Power Company,Inc. AEP Yes A- Yes Yes Yes 51.62% 97.34% No
Avista Corporation AVA Yes BBB Yes Yes Yes 59.47% 73.85% No
CMS Energy Corporation CMS Yes BBB+ Yes Yes Yes 42.50% 65.48% No
Duke Energy Corporation DUK Yes BBB+ Yes Yes Yes 81.53% 91.02% No
Entergy Corporation ETR Yes BBB+ Yes Yes Yes 71.43% 98.21% No
Evergy,Inc. EVRG Yes BBB+ Yes Yes Yes 62.14% 100.00% No
IDACORP,Inc. IDA Yes BBB Yes Yes Yes 65.35% 99.91% No
NextEra Energy,Inc. NEE Yes A- Yes Yes Yes 96.40% 92.16% No
NorthWestem Corporation NWE Yes BBB Yes Yes Yes 55.82% 84.28% No
OGE Energy Corporation OGE Yes BBB+ Yes Yes Yes 50.65% 100.00% No
Pinnacle West Capital Corporation PNW Yes BBB+ Yes Yes Yes 76.09% 100.00% No
Portland General Electric Company POR Yes BBB+ Yes Yes Yes 54.88% 100.00% No
Southern Company SO Yes BBB+ Yes Yes Yes 76.85% 75.31% No
Xcel Energy Inc. XEL Yes A- Yes Yes Yes 57.97% 86.47% No
Notes:
[1]Bloomberg Professional
[2]Bloomberg Professional
[3]Yahoo!Finance and Zacks
[4]Yahoo!Finance,Value Line Investment Survey,and Zacks
[5]S&P Capital IQ Pro
[6]S&P Capital IQ Pro
[7]Form 10-K's for 2022,2021,and 2020
[8]Form 10-K's for 2022,2021,and 2020
[9]S&P Capital IQ Pro Financial News Releases

Case No. PAC-E-24-04
Exhibit No. 7
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Constant Growth Discounted Cash Flow Model
May 2024

Rocky Mountain Power
Exhibit No.7 Page 1 of 3
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
30-DAY CONSTANT GROWTH DCF
[1] [2] [3] [4] [5] [6] [7] [8] [9] [10] [11]
Value Line Average Cost of Cost of Cost of
Expected Projected Yahoo!Finance Zacks Projected Equity: Equity: Equity:
Annualized Stock Dividend Dividend EPS Growth Projected EPS Projected EPS EPS Growth Minimum Mean Maximum
Company Ticker Dividend Price Yield Yield Rate Growth Rate Growth Rate Rate Growth Rate Growth Rate Growth Rate
ALLETE,Inc. ALE $2.82 $59.03 4.78% 4.95% 6.00% 8.10% n/a 7.05% 10.92% 12.00% 13.07%
Alliant Energy Corporation LNT $1.92 $48.76 3.94% 4.06% 6.50% 6.55% 6.10% 6.38% 10.16% 10.45% 10.62%
Ameren Corporation AEE $2.68 $72.88 3.68% 3.79% 6.50% 4.80% 6.50% 5.93% 8.57% 9.72% 10.30%
American Electric Power Company,Iru AEP $3.52 $83.94 4.19% 4.31% 6.50% 5.72% 5.10% 5.77% 9.40% 10.09% 10.83%
Avista Corporation AVA $1.90 $34.60 5.49% 5.66% 6.00% 6.20% n/a 6.10% 11.66% 11.76% 11.86%
CMS Energy Corporation CMS $2.06 $59.10 3.49% 3.60% 5.00% 7.40% 7.40% 6.60% 8.57% 10.20% 11.01%
Duke Energy Corporation DUK $4.10 $96.20 4.26% 4.39% 5.00% 6.86% 6.30% 6.05% 9.37% 10.44% 11.27%
Entergy Corporation ETR $4.52 $103.58 4.36% 4.47% 0.50% 6.80% 7.50% 4.93% 4.87% 9.40% 12.03%
Evergy,Inc. EVRG $2.57 $51.97 4.94% 5.07% 7.50% 2.50% 5.00% 5.00% 7.51% 10.07% 12.63%
IDACORP,Inc. IDA $3.32 $92.13 3.60% 3.69% 5.00% 4.40% n/a 4.70% 8.08% 8.39% 8.69%
NextEra Energy,Inc. NEE $2.06 $63.94 3.22% 3.35% 8.50% 7.84% 8.00% 8.11% 11.19% 11.47% 11.86%
NorthWestem Corporation NWE $2.60 $49.67 5.23% 5.35% 4.00% 4.50% n/a 4.25% 9.34% 9.60% 9.85%
OGE Energy Corporation OGE $1.67 $33.65 4.97% 5.11% 6.50% negative 5.00% 5.75% 10.10% 10.86% 11.63%
Pinnacle West Capital Corporation PNW $3.52 $72.49 4.86% 5.01% 4.50% 6.90% 7.60% 6.33% 9.47% 11.34% 12.64%
Portland General Electric Company POR $1.90 $41.72 4.55% 4.76% 6.00% 12.50% n/a 9.25% 10.69% 14.01% 17.34%
Southern Company SO $2.80 $70.95 3.95% 4.06% 6.50% 7.30% 4.00% 5.93% 8.03% 10.00% 11.39%
Xcel Energy Inc. XEL $2.19 $53.62 4.08% 4.22% 7.00% 6.73% 6.40% 6.71% 10.61% 10.93% 11.23%
Mean 9.32% 10.63% 11.66%
Median 9.40% 10.44% 11.39%
Notes:
[1]Bloomberg Professional as of April 30,2024
[2]Bloomberg Professional 30-day average as of April 30,2024
[3]Equals[1]/[2]
[4]Equals[3]x(1+0.5 x[8])
[5]Value Line
[6]Yahoo!Finance
[7]Zacks
[8]Equals average of[5],[6],[7]
[9]Equals[3]x(1+0.5 x(min([5],[6],[7]))+(min([5],[6],[7])
[10]Equals[4]+[8]
[11]Equals[3]x(1+0.5 x(max([5],[6],[7]))+(max([5],[6],[7])

Rocky Mountain Power
Exhibit No.7 Page 2 of 3
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
90-DAY CONSTANT GROWTH DCF
[1] [2] [3] [4] [5] [6] [7] [8] [9] [10] [11]
Value Line Average Cost of Cost of Cost of
Expected Projected Yahoo!Finance Zacks Projected Equity: Equity: Equity:
Annualized Stock Dividend Dividend EPS Growth Projected EPS Projected EPS EPS Growth Minimum Mean Maximum
Company Ticker Dividend Price Yield Yield Rate Growth Rate Growth Rate Rate Growth Rate Growth Rate Growth Rate
ALLETE,Inc. ALE $2.82 $58.75 4.80% 4.97% 6.00% 8.10% n/a 7.05% 10.94% 12.02% 13.09%
Alliant Energy Corporation LNT $1.92 $48.63 3.95% 4.07% 6.50% 6.55% 6.10% 6.38% 10.17% 10.46% 10.63%
Ameren Corporation AEE $2.68 $71.30 3.76% 3.87% 6.50% 4.80% 6.50% 5.93% 8.65% 9.80% 10.38%
American Electric Power Company,Ini AEP $3.52 $81.59 4.31% 4.44% 6.50% 5.72% 5.10% 5.77% 9.52% 10.21% 10.95%
Avista Corporation AVA $1.90 $34.15 5.56% 5.73% 6.00% 6.20% n/a 6.10% 11.73% 11.83% 11.94%
CMS Energy Corporation CMS $2.06 $58.01 3.55% 3.67% 5.00% 7.40% 7.40% 6.60% 8.64% 10.27% 11.08%
Duke Energy Corporation DUK $4.10 $94.96 4.32% 4.45% 5.00% 6.86% 6.30% 6.05% 9.43% 10.50% 11.33%
Entergy Corporation ETR $4.52 $100.69 4.49% 4.60% 0.50% 6.80% 7.50% 4.93% 5.00% 9.53% 12.16%
Evergy,Inc. EVRG $2.57 $50.97 5.04% 5.17% 7.50% 2.50% 5.00% 5.00% 7.61% 10.17% 12.73%
IDACORP,Inc. IDA $3.32 $92.02 3.61% 3.69% 5.00% 4.40% n/a 4.70% 8.09% 8.39% 8.70%
NextEra Energy,Inc. NEE $2.06 $59.91 3.44% 3.58% 8.50% 7.84% 8.00% 8.11% 11.41% 11.69% 12.08%
NorthWestern Corporation NWE $2.60 $48.80 5.33% 5.44% 4.00% 4.50% n/a 4.25% 9.43% 9.69% 9.95%
OGE Energy Corporation OGE $1.67 $33.36 5.01% 5.16% 6.50% negative 5.00% 5.75% 10.14% 10.91% 11.68%
Pinnacle West Capital Corporation PNW $3.52 $70.12 5.02% 5.18% 4.50% 6.90% 7.60% 6.33% 9.63% 11.51% 12.81%
Portland General Electric Company POR $1.90 $41.21 4.61% 4.82% 6.00% 12.50% n/a 9.25% 10.75% 14.07% 17.40%
Southern Company SO $2.80 $69.30 4.04% 4.16% 6.50% 7.30% 4.00% 5.93% 8.12% 10.09% 11.49%
Xcel Energy Inc. XEL $2.19 $56.29 3.89% 4.02% 7.00% 6.73% 6.40% 6.71% 10.42% 10.73% 11.03%
Mean 9.39% 10.70% 11.73%
Median 9.52% 10.46% 11.49%
Notes:
[1]Bloomberg Professional as of April 30,2024
[2]Bloomberg Professional 90-day average as of April 30,2024
[3]Equals[1]/[2]
[4]Equals[3]x(1+0.5 x[8])
[5]Value Line
[6]Yahoo!Finance
[7]Zacks
[8]Equals average of[5],[6],[7]
[9]Equals[3]x(1+0.5 x(min([5],[6],[7]))+(min([5],[6],[7])
[10]Equals[4]+[8]
[11]Equals[3]x(1+0.5 x(max([5],[6],[7]))+(max([5],[6],[7])

Rocky Mountain Power
Exhibit No.7 Page 3 of 3
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
180-DAY CONSTANT GROWTH DCF
[1] [2] [3] [4] [5] [6] [7] [8] [9] [10] [11]
Value Line Average Cost of Cost of Cost of
Expected Projected Yahoo!Finance Zacks Projected Equity: Equity: Equity:
Annualized Stock Dividend Dividend EPS Growth Projected EPS Projected EPS EPS Growth Minimum Mean Maximum
Company Ticker Dividend Price Yield Yield Rate Growth Rate Growth Rate Rate Growth Rate Growth Rate Growth Rate
ALLETE,Inc. ALE $2.82 $56.50 4.99% 5.17% 6.00% 8.10% n/a 7.05% 11.14% 12.22% 13.29%
Alliant Energy Corporation LNT $1.92 $48.72 3.94% 4.07% 6.50% 6.55% 6.10% 6.38% 10.16% 10.45% 10.62%
Ameren Corporation AEE $2.68 $73.72 3.64% 3.74% 6.50% 4.80% 6.50% 5.93% 8.52% 9.68% 10.25%
American Electric Power Company,Ini AEP $3.52 $78.92 4.46% 4.59% 6.50% 5.72% 5.10% 5.77% 9.67% 10.36% 11.11%
Avista Corporation AVA $1.90 $33.49 5.67% 5.85% 6.00% 6.20% n/a 6.10% 11.84% 11.95% 12.05%
CMS Energy Corporation CMS $2.06 $56.50 3.65% 3.77% 5.00% 7.40% 7.40% 6.60% 8.74% 10.37% 11.18%
Duke Energy Corporation DUK $4.10 $91.88 4.46% 4.60% 5.00% 6.86% 6.30% 6.05% 9.57% 10.65% 11.48%
Entergy Corporation ETR $4.52 $97.22 4.65% 4.76% 0.50% 6.80% 7.50% 4.93% 5.16% 9.70% 12.32%
Evergy,Inc. EVRG $2.57 $50.80 5.06% 5.19% 7.50% 2.50% 5.00% 5.00% 7.62% 10.19% 12.75%
IDACORP,Inc. IDA $3.32 $93.51 3.55% 3.63% 5.00% 4.40% n/a 4.70% 8.03% 8.33% 8.64%
NextEra Energy,Inc. NEE $2.06 $59.64 3.45% 3.59% 8.50% 7.84% 8.00% 8.11% 11.43% 11.71% 12.10%
NorthWestern Corporation NWE $2.60 $48.79 5.33% 5.44% 4.00% 4.50% n/a 4.25% 9.44% 9.69% 9.95%
OGE Energy Corporation OGE $1.67 $33.39 5.01% 5.15% 6.50% negative 5.00% 5.75% 10.14% 10.90% 11.67%
Pinnacle West Capital Corporation PNW $3.52 $71.42 4.93% 5.08% 4.50% 6.90% 7.60% 6.33% 9.54% 11.42% 12.72%
Portland General Electric Company POR $1.90 $41.13 4.62% 4.83% 6.00% 12.50% n/a 9.25% 10.76% 14.08% 17.41%
Southern Company SO $2.80 $68.24 4.10% 4.23% 6.50% 7.30% 4.00% 5.93% 8.19% 10.16% 11.55%
Xcel Energy Inc. XEL $2.19 $57.05 3.84% 3.97% 7.00% 6.73% 6.40% 6.71% 10.36% 10.68% 10.97%
Mean 9.43% 10.74% 11.77%
Median 9.57% 10.45% 11.55%
Notes:
[1]Bloomberg Professional as of April 30,2024
[2]Bloomberg Professional 180-day average as of April 30,2024
[3]Equals[1]/[2]
[4]Equals[3]x(1+0.5 x[8])
[5]Value Line
[6]Yahoo!Finance
[7]Zacks
[8]Equals average of[5],[6],[7]
[9]Equals[3]x(1+0.5 x(min([5],[6],[7]))+(min([5],[6],[7])
[10]Equals[4]+[8]
[11]Equals[3]x(1+0.5 x(max([5],[6],[7]))+(max([5],[6],[7])

Case No. PAC-E-24-04
Exhibit No. 8
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Capital Asset Pricing Model and Empirical Capital Asset
Pricing Model
May 2024

Rocky Mountain Power
Exhibit No.8 Page 1 of 9
Case No.PAC-E-24-04
CAPITAL ASSET PRICING MODEL Witness:Ann E.Bulkley
CURRENT RISK FREE RATE AND VALUE LINE BETA
K=Rf+R(Rm-Rf)
K=Rf+0.25 x(Rm-Rf)+0.75 x R x(Rm-Rf)
[1] [2] [3] [4] [5] [6]
Current 30-day Market
average of 30- Risk
year U.S. Market Premium
Treasury bond Return (Rm- CAPM ECAPM
Company Ticker yield Beta((3) (Rm) Rf) ROE(K) ROE(K)
ALLETE,Inc. ALE 4.59% 0.95 12.91% 8.31% 12.49% 12.59%
Alliant Energy Corporation LNT 4.59% 0.90 12.91% 8.31% 12.07% 12.28%
Ameren Corporation AEE 4.59% 0.90 12.91% 8.31% 12.07% 12.28%
American Electric Power Company,Inc. AEP 4.59% 0.80 12.91% 8.31% 11.24% 11.66%
Avista Corporation AVA 4.59% 0.95 12.91% 8.31% 12.49% 12.59%
CMS Energy Corporation CMS 4.59% 0.85 12.91% 8.31% 11.66% 11.97%
Duke Energy Corporation DUK 4.59% 0.90 12.91% 8.31% 12.07% 12.28%
Entergy Corporation ETR 4.59% 0.95 12.91% 8.31% 12.49% 12.59%
Evergy,Inc. EVRG 4.59% 0.95 12.91% 8.31% 12.49% 12.59%
IDACORP,Inc. IDA 4.59% 0.85 12.91% 8.31% 11.66% 11.97%
NextEra Energy,Inc. NEE 4.59% 1.00 12.91% 8.31% 12.91% 12.91%
NorthWestem Corporation NWE 4.59% 0.95 12.91% 8.31% 12.49% 12.59%
OGE Energy Corporation OGE 4.59% 1.05 12.91% 8.31% 13.32% 13.22%
Pinnacle West Capital Corporation PNW 4.59% 0.95 12.91% 8.31% 12.49% 12.59%
Portland General Electric Company POR 4.59% 0.90 12.91% 8.31% 12.07% 12.28%
Southern Company SO 4.59% 0.95 12.91% 8.31% 12.49% 12.59%
Xcel Energy Inc. XEL 4.59% 0.85 12.91% 8.31% 11.66% 11.97%
Mean 12.25% 12.41%
Median 12.49% 12.59%
Notes:
[1]Bloomberg Professional 30-day average as of April 30,2024
[2]Value Line
[3]Market Return
[4]Equals [3]-[1]
[5]Equals [1]+[2]x[4]
[6]Equals [1]+0.25 x([4])+0.75 x([2]x[4])

Rocky Mountain Power
Exhibit No.8 Page 2 of 9
Case No.PAC-E-24-04
CAPITAL ASSET PRICING MODEL Witness:Ann E.Bulkley
NEAR TERM PROJECTED RISK-FREE RATE AND VALUE LINE BETA
K=Rf+0(Rm-Rf)
K=Rf+0.25 x(Rm-Rf)+0.75 x R x(Rm-Rf)
[1] [2] [3] [4] [5] [6]
Near-term Market
projected 30-year Risk
U.S.Treasury Market Premium
bond yield(Q3 Return (Rm- CAPM ECAPM
Company Ticker 2024-Q3 2025) Beta(P) (Rm) Rf) ROE(K) ROE(K)
ALLETE,Inc. ALE 4.32% 0.95 12.91% 8.59% 12.48% 12.58%
Alliant Energy Corporation LNT 4.32% 0.90 12.91% 8.59% 12.05% 12.26%
Ameren Corporation AEE 4.32% 0.90 12.91% 8.59% 12.05% 12.26%
American Electric Power Company,Inc. AEP 4.32% 0.80 12.91% 8.59% 11.19% 11.62%
Avista Corporation AVA 4.32% 0.95 12.91% 8.59% 12.48% 12.58%
CMS Energy Corporation CMS 4.32% 0.85 12.91% 8.59% 11.62% 11.94%
Duke Energy Corporation DUK 4.32% 0.90 12.91% 8.59% 12.05% 12.26%
Entergy Corporation ETR 4.32% 0.95 12.91% 8.59% 12.48% 12.58%
Evergy,Inc. EVRG 4.32% 0.95 12.91% 8.59% 12.48% 12.58%
IDACORP,Inc. IDA 4.32% 0.85 12.91% 8.59% 11.62% 11.94%
NextEra Energy,Inc. NEE 4.32% 1.00 12.91% 8.59% 12.91% 12.91%
NorthWestem Corporation NWE 4.32% 0.95 12.91% 8.59% 12.48% 12.58%
OGE Energy Corporation OGE 4.32% 1.05 12.91% 8.59% 13.34% 13.23%
Pinnacle West Capital Corporation PNW 4.32% 0.95 12.91% 8.59% 12.48% 12.58%
Portland General Electric Company POR 4.32% 0.90 12.91% 8.59% 12.05% 12.26%
Southern Company SO 4.32% 0.95 12.91% 8.59% 12.48% 12.58%
Xcel Energy Inc. XEL 4.32% 0.85 12.91% 8.59% 11.62% 11.94%
Mean 12.22% 12.39%
Median 12.48% 12.58%
Notes:
[1]Blue Chip Financial Forecasts,Vol.43,No.5,May 1,2024,at 2
[2]Value Line
[3]Market Return
[4]Equals [3]-[1]
[5]Equals [1]+[2]x[4]
[6]Equals [1]+0.25 x([4])+0.75 x([2]x[4])

Rocky Mountain Power
Exhibit No.8 Page 3 of 9
Case No.PAC-E-24-04
CAPITAL ASSET PRICING MODEL Witness:Ann E.Bulkley
LONG-TERM PROJECTED RISK-FREE RATE AND VALUE LINE BETA
K=Rf+0(Rm-Rf)
K=Rf+0.25 x(Rm-Rf)+0.75 x P x(Rm-Rf)
[1] [2] [3] [4] [5] [6]
Projected 30-year Risk
U.S.Treasury Market Premium
bond yield(2025 - Return (Rm- CAPM ECAPM
Company Ticker 2029) Beta(0) (Rm) Rf) ROE(K) ROE(K)
ALLETE,Inc. ALE 4.10% 0.95 12.91% 8.81% 12.47% 12.58%
Alliant Energy Corporation LNT 4.10% 0.90 12.91% 8.81% 12.03% 12.25%
Ameren Corporation AEE 4.10% 0.90 12.91% 8.81% 12.03% 12.25%
American Electric Power Company,Inc. AEP 4.10% 0.80 12.91% 8.81% 11.14% 11.59%
Avista Corporation AVA 4.10% 0.95 12.91% 8.81% 12.47% 12.58%
CMS Energy Corporation CMS 4.10% 0.85 12.91% 8.81% 11.59% 11.92%
Duke Energy Corporation DUK 4.10% 0.90 12.91% 8.81% 12.03% 12.25%
Entergy Corporation ETR 4.10% 0.95 12.91% 8.81% 12.47% 12.58%
Evergy,Inc. EVRG 4.10% 0.95 12.91% 8.81% 12.47% 12.58%
IDACORP,Inc. IDA 4.10% 0.85 12.91% 8.81% 11.59% 11.92%
NextEra Energy,Inc. NEE 4.10% 1.00 12.91% 8.81% 12.91% 12.91%
NorthWestem Corporation NWE 4.10% 0.95 12.91% 8.81% 12.47% 12.58%
OGE Energy Corporation OGE 4.10% 1.05 12.91% 8.81% 13.35% 13.24%
Pinnacle West Capital Corporation PNW 4.10% 0.95 12.91% 8.81% 12.47% 12.58%
Portland General Electric Company POR 4.10% 0.90 12.91% 8.81% 12.03% 12.25%
Southern Company SO 4.10% 0.95 12.91% 8.81% 12.47% 12.58%
Xcel Energy Inc. XEL 4.10% 0.85 12.91% 8.81% 11.59% 11.92%
Mean 12.21% 12.38%
Median 12.47% 12.58%
Notes:
[1]Blue Chip Financial Forecasts,Vol.42,No. 12,December 1,2023,at 14
[2]Value Line
[3]Market Return
[4]Equals [3]-[1]
[5]Equals [1]+[2]x[4]
[6]Equals [1]+0.25 x([4])+0.75 x([2]x[4])

Rocky Mountain Power
Exhibit No.8 Page 4 of 9
Case No.PAC-E-24-04
CAPITAL ASSET PRICING MODEL Witness:Ann E.Bulkley
CURRENT RISK FREE RATE AND BLOOMBERG BETA
K=Rf+R(Rm-Rf)
K=Rf+0.25 x(Rm-Rf)+0.75 x R x(Rm-Rf)
[1] [2] [3] [4] [5] [6]
Current 30-day Market
average of 30- Risk
year U.S. Market Premium
Treasury bond Return (Rm- CAPM ECAPM
Company Ticker yield Beta((3) (Rm) Rf) ROE(K) ROE(K)
ALLETE,Inc. ALE 4.59% 0.81 12.91% 8.31% 11.37% 11.75%
Alliant Energy Corporation LNT 4.59% 0.78 12.91% 8.31% 11.09% 11.54%
Ameren Corporation AEE 4.59% 0.74 12.91% 8.31% 10.76% 11.30%
American Electric Power Company,Inc. AEP 4.59% 0.75 12.91% 8.31% 10.86% 11.37%
Avista Corporation AVA 4.59% 0.75 12.91% 8.31% 10.86% 11.37%
CMS Energy Corporation CMS 4.59% 0.74 12.91% 8.31% 10.76% 11.30%
Duke Energy Corporation DUK 4.59% 0.71 12.91% 8.31% 10.51% 11.11%
Entergy Corporation ETR 4.59% 0.85 12.91% 8.31% 11.69% 11.99%
Evergy,Inc. EVRG 4.59% 0.77 12.91% 8.31% 11.02% 11.49%
IDACORP,Inc. IDA 4.59% 0.79 12.91% 8.31% 11.13% 11.58%
NextEra Energy,Inc. NEE 4.59% 0.81 12.91% 8.31% 11.32% 11.72%
NorthWestem Corporation NWE 4.59% 0.86 12.91% 8.31% 11.75% 12.04%
OGE Energy Corporation OGE 4.59% 0.91 12.91% 8.31% 12.15% 12.34%
Pinnacle West Capital Corporation PNW 4.59% 0.81 12.91% 8.31% 11.33% 11.73%
Portland General Electric Company POR 4.59% 0.78 12.91% 8.31% 11.07% 11.53%
Southern Company SO 4.59% 0.77 12.91% 8.31% 11.00% 11.48%
Xcel Energy Inc. XEL 4.59% 0.73 12.91% 8.31% 10.62% 11.19%
Mean 11.14% 11.58%
Median 11.07% 11.53%
Notes:
[1]Bloomberg Professional 30-day average as of April 30,2024
[2]Bloomberg Professional
[3]Market Return
[4]Equals [3]-[1]
[5]Equals [1]+[2]x[4]
[6]Equals [1]+0.25 x([4])+0.75 x([2]x[4])

Rocky Mountain Power
Exhibit No.8 Page 5 of 9
Case No.PAC-E-24-04
CAPITAL ASSET PRICING MODEL Witness:Ann E.Bulkley
NEAR TERM PROJECTED RISK-FREE RATE AND BLOOMBERG BETA
K=Rf+0(Rm-Rf)
K=Rf+0.25 x(Rm-Rf)+0.75 x R x(Rm-Rf)
[1] [2] [3] [4] [5] [6]
Near-term Market
projected 30-year Risk
U.S.Treasury Market Premium
bond yield(Q3 Return (Rm- CAPM ECAPM
Company Ticker 2024-Q3 2025) Beta(P) (Rm) Rf) ROE(K) ROE(K)
ALLETE,Inc. ALE 4.32% 0.81 12.91% 8.59% 11.32% 11.71%
Alliant Energy Corporation LNT 4.32% 0.78 12.91% 8.59% 11.03% 11.50%
Ameren Corporation AEE 4.32% 0.74 12.91% 8.59% 10.69% 11.25%
American Electric Power Company,Inc. AEP 4.32% 0.75 12.91% 8.59% 10.79% 11.32%
Avista Corporation AVA 4.32% 0.75 12.91% 8.59% 10.79% 11.32%
CMS Energy Corporation CMS 4.32% 0.74 12.91% 8.59% 10.69% 11.25%
Duke Energy Corporation DUK 4.32% 0.71 12.91% 8.59% 10.44% 11.05%
Entergy Corporation ETR 4.32% 0.85 12.91% 8.59% 11.65% 11.96%
Evergy,Inc. EVRG 4.32% 0.77 12.91% 8.59% 10.96% 11.45%
IDACORP,Inc. IDA 4.32% 0.79 12.91% 8.59% 11.08% 11.53%
NextEra Energy,Inc. NEE 4.32% 0.81 12.91% 8.59% 11.27% 11.68%
NorthWestem Corporation NWE 4.32% 0.86 12.91% 8.59% 11.71% 12.01%
OGE Energy Corporation OGE 4.32% 0.91 12.91% 8.59% 12.12% 12.32%
Pinnacle West Capital Corporation PNW 4.32% 0.81 12.91% 8.59% 11.28% 11.69%
Portland General Electric Company POR 4.32% 0.78 12.91% 8.59% 11.01% 11.48%
Southern Company SO 4.32% 0.77 12.91% 8.59% 10.94% 11.43%
Xcel Energy Inc. XEL 4.32% 0.73 12.91% 8.59% 10.55% 11.14%
Mean 11.08% 11.53%
Median 11.01% 11.48%
Notes:
[1]Blue Chip Financial Forecasts,Vol.43,No.5,May 1,2024,at 2
[2]Bloomberg Professional
[3]Market Return
[4]Equals [3]-[1]
[5]Equals [1]+[2]x[4]
[6]Equals [1]+0.25 x([4])+0.75 x([2]x[4])

Rocky Mountain Power
Exhibit No.8 Page 6 of 9
Case No.PAC-E-24-04
CAPITAL ASSET PRICING MODEL Witness:Ann E.Bulkley
LONG-TERM PROJECTED RISK-FREE RATE AND BLOOMBERG BETA
K=Rf+0(Rm-Rf)
K=Rf+0.25 x(Rm-Rf)+0.75 x P x(Rm-Rf)
[1] [2] [3] [4] [5] [6]
Projected 30-year Risk
U.S.Treasury Market Premium
bond yield(2025 - Return (Rm- CAPM ECAPM
Company Ticker 2029) Beta(0) (Rm) Rf) ROE(K) ROE(K)
ALLETE,Inc. ALE 4.10% 0.81 12.91% 8.81% 11.28% 11.68%
Alliant Energy Corporation LNT 4.10% 0.78 12.91% 8.81% 10.98% 11.46%
Ameren Corporation AEE 4.10% 0.74 12.91% 8.81% 10.64% 11.20%
American Electric Power Company,Inc. AEP 4.10% 0.75 12.91% 8.81% 10.74% 11.28%
Avista Corporation AVA 4.10% 0.75 12.91% 8.81% 10.74% 11.28%
CMS Energy Corporation CMS 4.10% 0.74 12.91% 8.81% 10.64% 11.20%
Duke Energy Corporation DUK 4.10% 0.71 12.91% 8.81% 10.37% 11.01%
Entergy Corporation ETR 4.10% 0.85 12.91% 8.81% 11.61% 11.94%
Evergy,Inc. EVRG 4.10% 0.77 12.91% 8.81% 10.91% 11.41%
IDACORP,Inc. IDA 4.10% 0.79 12.91% 8.81% 11.03% 11.50%
NextEra Energy,Inc. NEE 4.10% 0.81 12.91% 8.81% 11.23% 11.65%
NorthWestem Corporation NWE 4.10% 0.86 12.91% 8.81% 11.68% 11.98%
OGE Energy Corporation OGE 4.10% 0.91 12.91% 8.81% 12.10% 12.30%
Pinnacle West Capital Corporation PNW 4.10% 0.81 12.91% 8.81% 11.24% 11.66%
Portland General Electric Company POR 4.10% 0.78 12.91% 8.81% 10.96% 11.45%
Southern Company SO 4.10% 0.77 12.91% 8.81% 10.89% 11.39%
Xcel Energy Inc. XEL 4.10% 0.73 12.91% 8.81% 10.49% 11.09%
Mean 11.03% 11.50%
Median 10.96% 11.45%
Notes:
[1]Blue Chip Financial Forecasts,Vol.42,No. 12,December 1,2023,at 14
[2]Bloomberg Professional
[3]Market Return
[4]Equals [3]-[1]
[5]Equals [1]+[2]x[4]
[6]Equals [1]+0.25 x([4])+0.75 x([2]x[4])

Rocky Mountain Power
Exhibit No.8 Page 7 of 9
Case No.PAC-E-24-04
CAPITAL ASSET PRICING MODEL Witness:Ann E.Bulkley
CURRENT RISK FREE RATE AND LONG-TERM VALUE LINE BETA
K=Rf+R(Rm-Rf)
K=Rf+0.25 x(Rm-Rf)+0.75 x R x(Rm-Rf)
[1] [2] [3] [4] [5] [6]
Current 30-day Market
average of 30- Risk
year U.S. Market Premium
Treasury bond Return (Rm- CAPM ECAPM
Company Ticker yield Beta((3) (Rm) Rf) ROE(K) ROE(K)
ALLETE,Inc. ALE 4.59% 0.80 12.91% 8.31% 11.21% 11.63%
Alliant Energy Corporation LNT 4.59% 0.76 12.91% 8.31% 10.94% 11.43%
Ameren Corporation AEE 4.59% 0.74 12.91% 8.31% 10.75% 11.29%
American Electric Power Company,Inc. AEP 4.59% 0.69 12.91% 8.31% 10.30% 10.95%
Avista Corporation AVA 4.59% 0.80 12.91% 8.31% 11.21% 11.63%
CMS Energy Corporation CMS 4.59% 0.70 12.91% 8.31% 10.45% 11.06%
Duke Energy Corporation DUK 4.59% 0.69 12.91% 8.31% 10.30% 10.95%
Entergy Corporation ETR 4.59% 0.76 12.91% 8.31% 10.94% 11.43%
Evergy,Inc. EVRG 4.59% 0.94 12.91% 8.31% 12.39% 12.52%
IDACORP,Inc. IDA 4.59% 0.74 12.91% 8.31% 10.75% 11.29%
NextEra Energy,Inc. NEE 4.59% 0.75 12.91% 8.31% 10.87% 11.38%
NorthWestem Corporation NWE 4.59% 0.76 12.91% 8.31% 10.94% 11.43%
OGE Energy Corporation OGE 4.59% 0.94 12.91% 8.31% 12.41% 12.54%
Pinnacle West Capital Corporation PNW 4.59% 0.75 12.91% 8.31% 10.87% 11.38%
Portland General Electric Company POR 4.59% 0.76 12.91% 8.31% 10.94% 11.43%
Southern Company SO 4.59% 0.68 12.91% 8.31% 10.26% 10.92%
Xcel Energy Inc. XEL 4.59% 0.67 12.91% 8.31% 10.18% 10.87%
Mean 10.92% 11.42%
Median 10.87% 11.38%
Notes:
[1]Bloomberg Professional 30-day average as of April 30,2024
[2] Source:LT Beta
[3]Market Return
[4]Equals [3]-[1]
[5]Equals [1]+[2]x[4]
[6]Equals [1]+0.25 x([4])+0.75 x([2]x[4])

Rocky Mountain Power
Exhibit No.8 Page 8 of 9
Case No.PAC-E-24-04
CAPITAL ASSET PRICING MODEL Witness:Ann E.Bulkley
NEAR-TERM PROJECTED RISK FREE RATE AND LONG-TERM VALUE LINE BETA
K=Rf+0(Rm-Rf)
K=Rf+0.25 x(Rm-Rf)+0.75 x R x(Rm-Rf)
[1] [2] [3] [4] [5] [6]
Near-term Market
projected 30-year Risk
U.S.Treasury Market Premium
bond yield(Q3 Return (Rm- CAPM ECAPM
Company Ticker 2024-Q3 2025) Beta(P) (Rm) Rf) ROE(K) ROE(K)
ALLETE,Inc. ALE 4.32% 0.80 12.91% 8.59% 11.15% 11.59%
Alliant Energy Corporation LNT 4.32% 0.76 12.91% 8.59% 10.88% 11.38%
Ameren Corporation AEE 4.32% 0.74 12.91% 8.59% 10.68% 11.24%
American Electric Power Company,Inc. AEP 4.32% 0.69 12.91% 8.59% 10.21% 10.89%
Avista Corporation AVA 4.32% 0.80 12.91% 8.59% 11.15% 11.59%
CMS Energy Corporation CMS 4.32% 0.70 12.91% 8.59% 10.37% 11.00%
Duke Energy Corporation DUK 4.32% 0.69 12.91% 8.59% 10.21% 10.89%
Entergy Corporation ETR 4.32% 0.76 12.91% 8.59% 10.88% 11.38%
Evergy,Inc. EVRG 4.32% 0.94 12.91% 8.59% 12.37% 12.50%
IDACORP,Inc. IDA 4.32% 0.74 12.91% 8.59% 10.68% 11.24%
NextEra Energy,Inc. NEE 4.32% 0.75 12.91% 8.59% 10.80% 11.33%
NorthWestem Corporation NWE 4.32% 0.76 12.91% 8.59% 10.88% 11.38%
OGE Energy Corporation OGE 4.32% 0.94 12.91% 8.59% 12.40% 12.53%
Pinnacle West Capital Corporation PNW 4.32% 0.75 12.91% 8.59% 10.80% 11.33%
Portland General Electric Company POR 4.32% 0.76 12.91% 8.59% 10.88% 11.38%
Southern Company SO 4.32% 0.68 12.91% 8.59% 10.17% 10.86%
Xcel Energy Inc. XEL 4.32% 0.67 12.91% 8.59% 10.10% 10.80%
Mean 10.86% 11.37%
Median 10.80% 11.33%
Notes:
[1]Blue Chip Financial Forecasts,Vol.43,No.5,May 1,2024,at 2
[2] Source:LT Beta
[3]Market Return
[4]Equals [3]-[1]
[5]Equals [1]+[2]x[4]
[6]Equals [1]+0.25 x([4])+0.75 x([2]x[4])

Rocky Mountain Power
Exhibit No.8 Page 9 of 9
Case No.PAC-E-24-04
CAPITAL ASSET PRICING MODEL Witness:Ann E.Bulkley
LONG-TERM PROJECTED RISK FREE RATE AND LONG-TERM VALUE LINE BETA
K=Rf+0(Rm-Rf)
K=Rf+0.25 x(Rm-Rf)+0.75 x P x(Rm-Rf)
[1] [2] [3] [4] [5] [6]
Projected 30-year Risk
U.S.Treasury Market Premium
bond yield(2025 - Return (Rm- CAPM ECAPM
Company Ticker 2029) Beta(0) (Rm) Rf) ROE(K) ROE(K)
ALLETE,Inc. ALE 4.10% 0.80 12.91% 8.81% 11.10% 11.56%
Alliant Energy Corporation LNT 4.10% 0.76 12.91% 8.81% 10.82% 11.34%
Ameren Corporation AEE 4.10% 0.74 12.91% 8.81% 10.62% 11.19%
American Electric Power Company,Inc. AEP 4.10% 0.69 12.91% 8.81% 10.14% 10.83%
Avista Corporation AVA 4.10% 0.80 12.91% 8.81% 11.10% 11.56%
CMS Energy Corporation CMS 4.10% 0.70 12.91% 8.81% 10.30% 10.95%
Duke Energy Corporation DUK 4.10% 0.69 12.91% 8.81% 10.14% 10.83%
Entergy Corporation ETR 4.10% 0.76 12.91% 8.81% 10.82% 11.34%
Evergy,Inc. EVRG 4.10% 0.94 12.91% 8.81% 12.36% 12.49%
IDACORP,Inc. IDA 4.10% 0.74 12.91% 8.81% 10.62% 11.19%
NextEra Energy,Inc. NEE 4.10% 0.75 12.91% 8.81% 10.74% 11.28%
NorthWestem Corporation NWE 4.10% 0.76 12.91% 8.81% 10.82% 11.34%
OGE Energy Corporation OGE 4.10% 0.94 12.91% 8.81% 12.39% 12.52%
Pinnacle West Capital Corporation PNW 4.10% 0.75 12.91% 8.81% 10.74% 11.28%
Portland General Electric Company POR 4.10% 0.76 12.91% 8.81% 10.82% 11.34%
Southern Company SO 4.10% 0.68 12.91% 8.81% 10.10% 10.80%
Xcel Energy Inc. XEL 4.10% 0.67 12.91% 8.81% 10.02% 10.74%
Mean 10.81% 11.33%
Median 10.74% 11.28%
Notes:
[1]Blue Chip Financial Forecasts,Vol.42,No. 12,December 1,2023,at 14
[2] Source:LT Beta
[3]Market Return
[4]Equals [3]-[1]
[5]Equals [1]+[2]x[4]
[6]Equals [1]+0.25 x([4])+0.75 x([2]x[4])

Case No. PAC-E-24-04
Exhibit No. 9
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Long-Term Beta Coefficient
May 2024

Rocky Mountain Power
Exhibit No.9 Page 1 of 1
Case No.PAC-E-24-04
HISTORICAL VALUE LINE BETA Witness:Ann E.Bulkley
[1] [2] [3] [4] [5] [6] [7] [8] [9] [10] [11] [12]
Company Ticker 12/31/2013 12/31/2014 12/31/2015 12/31/2016 12/31/2017 12/31/2018 12/31/2019 12/31/2020 12/31/2021 12/31/2022 12/31/2023 Average
ALLETE,Inc. ALE 0.75 0.80 0.80 0.75 0.80 0.65 0.65 0.85 0.90 0.90 0.90 0.80
Alliant Energy Corporation LNT 0.75 0.80 0.80 0.70 0.70 0.60 0.60 0.85 0.85 0.85 0.90 0.76
Ameren Corporation AEE 0.80 0.75 0.75 0.65 0.70 0.55 0.55 0.85 0.80 0.85 0.90 0.74
American Electric Power Company,Inc. AEP 0.70 0.70 0.70 0.65 0.65 0.55 0.55 0.75 0.75 0.75 0.80 0.69
Avista Corporation AVA 0.75 0.80 0.80 0.70 0.75 0.65 0.60 0.95 0.95 0.90 0.90 0.80
CMS Energy Corporation CMS 0.70 0.70 0.75 0.65 0.65 0.55 0.50 0.80 0.80 0.80 0.85 0.70
Duke Energy Corporation DUK 0.65 0.60 0.65 0.60 0.60 0.50 0.50 0.85 0.85 0.85 0.90 0.69
Entergy Corporation ETR 0.70 0.70 0.70 0.65 0.65 0.60 0.60 0.95 0.95 0.95 0.95 0.76
Evergy,Inc. EVRG NMF NMF 1.00 0.95 0.90 0.90 0.94
IDACORP,Inc. IDA 0.75 0.80 0.80 0.75 0.70 0.55 0.55 0.80 0.80 0.80 0.85 0.74
NextEra Energy,Inc. NEE 0.70 0.70 0.75 0.65 0.65 0.55 0.55 0.90 0.90 0.95 1.00 0.75
NorthWestern Corporation NWE 0.70 0.70 0.70 0.70 0.70 0.55 0.60 0.95 0.95 0.90 0.95 0.76
OGE Energy Corporation OGE 0.85 0.90 0.95 0.90 0.95 0.85 0.75 1.10 1.05 1.00 1.05 0.94
Pinnacle West Capital Corporation PNW 0.75 0.70 0.75 0.70 0.70 0.55 0.50 0.90 0.90 0.90 0.95 0.75
Portland General Electric Company POR 0.75 0.80 0.80 0.70 0.70 0.60 0.55 0.85 0.90 0.85 0.90 0.76
Southern Company SO 0.55 0.55 0.60 0.55 0.55 0.50 0.50 0.90 0.95 0.90 0.95 0.68
Xcel Energy Inc. XEL 0.65 0.65 0.65 0.60 0.60 0.50 0.50 0.80 0.80 0.80 0.85 0.67
Mean 0.72 0.73 0.75 0.68 0.69 0.58 0.57 0.89 0.89 0.87 0.91 0.76
Notes:
[1]Value Line,December 26,2013
[2]Value Line,December 31,2014
[3]Value Line,December 30,2015
[4]Value Line,December 29,2016
[5]Value Line,December 28,2017
[6]Value Line,December 27,2018
[7]Value Line,December 26,2019
[8]Value Line,December 30,2020
[9]Value Line,December 29,2021
[10]Value Line,December 30,2022
[11]Value Line,December 29,2023
[11]Average([1]-[11])

Case No. PAC-E-24-04
Exhibit No. 10
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Market Return
May 2024

Rocky Mountain Power
Exhibit No.10 Page 1 of 7
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
MARKET RISK PREMIUM DERIVED FROM S&P 500 INDEX
[1]Estimate of the S&P 500 Dividend Yield 1.72%
[2]Estimate of the S&P 500 Growth Rate 11.09%
[3]S&P 500 Estimated Required Market Return 12.91%
[41 [5] [6] [7] [8] 191 [10] [11]
Bloomberg Cap-Weighted
Shares Market Weight in Estimated Cap-Weighted Long-Term Long-Term
Name Ticker Outsfg Price Capitalization Index Dividend Yield Dividend Yield Growth Est. Growth Est.
LyondellBasell Industries NV LYB 325.622 99.97 32,552.43 0.10% 5.00% 0.01% 8.00% 0.01%
American Express Co AXP 719.303 234.03 168,338.48 0.53% 1.20% 0.01% 15.22% 0.08%
Verizon Communications Inc VZ 4209.255 39.49 166,223.48 0.52% 6.74% 0.04% 1.22% 0.01%
Broadcom Inc AVGO 463.421 1300.27 602,572.42 1.89% 1.62% 0.03% 14.20% 0.27%
Boeing Co/The BA 613.884 167.84 103,034.29 74.41%
Solventum Corp SOLV 172.709 65.01 11,227.81 -4.00%
Caterpillar Inc CAT 489.053 334.57 163,622.46 0.51% 1.55% 0.01% 15.00% 0.08%
JPMorgan Chase&Co JPM 2872.091 191.74 550,694.73 1.73% 2.40% 0.04% 3.50% 0.06%
Chevron Corp CVX 1847.32 161.27 297,917.30 0.94% 4.04% 0.04% 7.00% 0.07%
Coca-Cola Co/The KO 4311.191 61.77 266,302.27 0.84% 3.14% 0.03% 6.36% 0.05%
AbbVie Inc ABBV 1770.647 162.64 287,978.03 0.90% 3.81% 0.03% 8.62% 0.08%
Walt Disney Co/The DIS 1834.329 111.1 203,793.95 0.81% 21.90%
Corpay Inc CPAY 71.854 302.14 21,709.97 0.07% 13.65% 0.01%
Extra Space Storage Inc EXR 211.62 134.28 28,416.33 0.09% 4.83% 0.00% 1.62% 0.00%
Exxon Mobil Corp XOM 3943.007 118.27 466,339.44 3.21% -12.00%
Phillips 66 PSX 423.952 143.21 60,714.17 3.21%
General Electric Co GE 1094.607 161.82 177,129.30 0.69% 23.50%
HP Inc HPQ 978.481 28.09 27,485.53 0.09% 3.92% 0.00% 0.50% 0.00%
Home Depot Inc/The HD 991.031 334.22 331,222.38 1.04% 2.69% 0.03% 4.31% 0.04%
Monolithic Power Systems Inc MPWR 48.661 669.33 32,570.27 0.10% 0.75% 0.00% 16.00% 0.02%
International Business Machines Corp IBM 918.603 166.2 152,671.82 0.48% 4.02% 0.02% 3.19% 0.02%
Johnson&Johnson JNJ 2409.783 144.59 348,430.52 1.09% 3.43% 0.04% 5.05% 0.06%
Lululemon Athletica Inc LULU 120.892 360.6 43,593.66
McDonald's Corp MCD 721.005 273.04 196,863.21 0.62% 2.45% 0.02% 7.79% 0.05%
Merck&Co Inc MRK 2533.028 129.22 327,317.88 2.38% 39.45%
3M Co MMM 553.361 96.51 53,404.87 6.26% 0.00%
American Water Works Co Inc AWK 194.755 122.32 23,822.43 0.07% 2.31% 0.00% 7.70% 0.01%
Bank of America Corp BAC 7820.37 37.01 289,431.89 2.59%
Pfizer Inc PEE 5646.778 25.62 144,670.45 0.45% 6.56% 0.03% 9.59% 0.04%
Procter&Gamble Co/The PG 2360.135 163.2 385,174.03 1.21% 2.47% 0.03% 8.09% 0.10%
AT&T Inc T 7170 16.89 121,101.30 0.38% 6.57% 0.02% 2.78% 0.01%
Travelers Cos Inc/The TRV 228.993 212.16 48,583.15 0.15% 1.98% 0.00% 18.24% 0.03%
RTX Corp RTX 1329.506 101.52 134,971.45 0.42% 2.32% 0.01% 10.21% 0.04%
Analog Devices Inc ADI 495.908 200.61 99,484.10 0.31% 1.83% 0.01% 4.50% 0.01%
Walmart Inc WMT 8058.049 59.35 478,245.21 1.50% 1.40% 0.02% 7.00% 0.11%
Cisco Systems Inc CSCO 4049.187 46.98 190,230.81 0.60% 3.41% 0.02% 7.50% 0.04%
Intel Corp INTC 4256.872 30.47 129,706.89 0.41% 1.64% 0.01% 0.41% 0.00%
General Motors Co GM 1140.395 44.53 50,781.79 0.16% 1.08% 0.00% 15.71% 0.03%
Microsoft Corp MSFT 7432.306 389.33 2,893,619.69 9.09% 0.77% 0.07% 16.54% 1.50%
Dollar General Corp DG 219.671 139.19 30,576.01 1.70% -1.47%
Cigna Group/The Cl 283.647 357.04 101,273.32 0.32% 1.57% 0.00% 11.62% 0.04%
Kinder Morgan Inc KMI 2219.384 18.28 40,570.34 0.13% 6.29% 0.01% 4.00% 0.01%
Citigroup Inc C 1911.367 61.33 117,224.14 0.37% 3.46% 0.01% 17.34% 0.06%
American International Group Inc AIG 674.032 75.31 50,761.35 0.16% 1.91% 0.00% 9.50% 0.02%
Altria Group Inc MO 1717.626 43.81 75,249.20 0.24% 8.95% 0.02% 4.00% 0.01%
HCA Healthcare Inc HCA 264.485 309.82 81,942.74 0.26% 0.85% 0.00% 9.57% 0.02%
International Paper Co IP 347.332 34.94 12,135.78 5.29% -2.00%
Hewlett Packard Enterprise Co HPE 1300 17 22,100.00 0.07% 3.06% 0.00% 2.86% 0.00%
Abbott Laboratories ABT 1735.184 105.97 183,877.45 0.58% 2.08% 0.01% 4.19% 0.02%
Aflac Inc AFL 575.408 83.65 48,132.88 0.15% 2.39% 0.00% 6.69% 0.01%
Air Products and Chemicals Inc APO 222.306 236.34 52,539.80 0.16% 3.00% 0.00% 9.40% 0.02%
Super Micro Computer Inc SMCI 58.55 858.8 50,282.74 54.91%
Royal Caribbean Cruises Ltd RCL 257.349 139.63 35,933.64 27.45%
Hess Corp HES 308.109 157.49 48,524.09 0.15% 1.11% 0.00% 18.00% 0.03%
Archer-Daniels-Midland Co ADM 494.438 58.66 29,003.73 3.41% -2.35%
Automatic Data Processing Inc ADP 410.791 241.89 99,366.23 0.31% 2.32% 0.01% 16.00% 0.05%
Verisk Analytics Inc VRSK 143.39 217.96 31,253.28 0.10% 0.72% 0.00% 11.97% 0.01%
AutoZone Inc AZO 17.303 2956.4 51,154.59 0.16% 14.75% 0.02%
Linde PLC LIN 481.576 440.96 212,355.75 0.67% 1.26% 0.01% 11.00% 0.07%
Avery Dennison Corp AVY 80.553 217.28 17,502.56 0.05% 1.62% 0.00% 7.00% 0.00%
Enphase Energy Inc ENPH 136.063 108.76 14,798.21 0.05% 19.27% 0.01%
MSCI Inc MSCI 79.224 465.79 36,901.75 0.12% 1.37% 0.00% 11.45% 0.01%
Ball Corp BALL 315.642 69.57 21,959.21 0.07% 1.15% 0.00% 9.50% 0.01%
Axon Enterprise Inc AXON 75.463 313.66 23,669.72
Dayf rrce Inc DAY 156.6 61.37 9,610.54
Carrier Global Corp CARR 901.012 61.49 55,403.23 0.17% 1.24% 0.00% 7.87% 0.01%
Bank of New York Mellon Corp/The BK 747.816 56.49 42,244.13 0.13% 2.97% 0.00% 10.00% 0.01%
Otis Worldwide Corp OTIS 404.323 91.2 36,874.26 0.12% 1.71% 0.00% 9.00% 0.01%
Baxter International Inc BAX 508 40.37 20,507.96 0.06% 2.87% 0.00% 2.73% 0.00%
Becton Dickinson&Co BDX 288.902 234.6 67,776.41 0.21% 1.62% 0.00% 8.36% 0.02%
Berkshire Hathaway Inc BRK/B 1310.995 396.73 520,111.05
Best Buy Co Inc BBY 215.381 73.64 15,860.66 0.05% 5.11% 0.00% 3.36% 0.00%
Boston Scientific Corp BSX 1469.895 71.87 105,641.35 0.33% 12.08% 0.04%

Rocky Mountain Power
Exhibit No.10 Page 2 of 7
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
[4] [5] [6] [7] [8] 191 [10] [11]
Bloomberg Cap-Weighted
Shares Market Weight in Estimated Cap-Weighted Long-Term Long-Term
Name Ticker Outst'g Price Capitalization Index Dividend Yield Dividend Yield Growth Est. Growth Est.
Bristol-Myers Squibb Co BMY 2027.1 43.94 89,070.77 5.46% -4.12%
Brown-Forman Corp BF/B 303.416 47.85 14,518.46 0.05% 1.82% 0.00% 2.73% 0.00%
Coterra Energy Inc CTRA 751.847 27.36 20,570.53 3.07%
Campbell Soup Co CPB 298.103 45.71 13,626.29 0.04% 3.24% 0.00% 4.87% 0.00%
Hilton Worldwide Holdings Inc HILT 250.046 197.28 49,329.07 0.15% 0.30% 0.00% 15.52% 0.02%
Carnival Corp CCL 1119.446 14.82 16,590.19
Qmvc,Inc QRVO 96.548 116.84 11,280.67 0.04% 17.72% 0.01%
Builders FirstSource Inc BLDR 121.94 182.82 22,293.07 0.07% 11.65% 0.01%
UDR Inc UDR 329.329 38.08 12,540.85 0.04% 4.46% 0.00% 6.06% 0.00%
CloroxCo/The CLX 124.188 147.87 18,363.68 0.06% 3.25% 0.00% 13.23% 0.01%
Paycom Software Inc PAYC 58.15 187.98 10,931.04 0.03% 0.80% 0.00% 5.50% 0.00%
CMS Energy Corp CMS 291.764 60.61 17,683.82 0.06% 3.40% 0.00% 7.36% 0.00%
Colgate-Palmolive Co CL 820.441 91.92 75,414.94 0.24% 2.18% 0.01% 8.18% 0.02%
EPAM Systems Inc EPAM 57.995 235.26 13,643.90 0.04% 2.97% 0.00%
Comerica Inc CMA 132.587 50.17 6,651.89 5.66%
Conagra Brands Inc CAG 478.063 30.78 14,714.78 0.05% 4.55% 0.00% 1.82% 0.00%
Airbnb Inc ABNB 438.087 158.57 69,467.46 0.22% 19.82% 0.04%
Consolidated Edison Inc ED 344.924 94.4 32,560.83 0.10% 3.52% 0.00% 5.70% 0.01%
Corning Inc GLW 855.352 33.38 28,551.65 0.09% 3.36% 0.00% 10.78% 0.01%
Cummins Inc CMI 141.857 282.49 40,073.18 0.13% 2.38% 0.00% 6.07% 0.01%
Caesars Entertainment Inc CZR 216.416 35.82 7,752.02 -28.24%
Danaher Corp DHR 740.687 246.62 182,668.23 0.44% -7.56%
Target Corp TOT 461.69 160.98 74,322.86 2.73% -2.13%
Deere&Co DE 278.358 391.41 108,952.10 1.50% -4.67%
Dominion Energy Inc D 837.593 50.98 42,700.49 0.13% 5.24% 0.01% 10.65% 0.01%
Dover Corp DOV 137.43 179.3 24,641.20 0.08% 1.14% 0.00% 9.50% 0.01%
Alliant Energy Corp LNT 252.719 49.8 12,585.41 0.04% 3.86% 0.00% 7.00% 0.00%
Steel Dynamics Inc STLD 160.018 130.12 20,821.54 1.41% -1.63%
Duke Energy Corp DUK 771 98.26 75,758.46 0.24% 4.17% 0.01% 6.65% 0.02%
Regency Centers Corp REG 184.581 59.22 10,930.89 0.03% 4.53% 0.00% 3.63% 0.00%
Eaton Corp PLC ETN 399.892 318.26 127,269.63 0.40% 1.18% 0.00% 15.00% 0.06%
Ecolab Inc ECL 285.912 226.15 64,659.00 0.20% 1.01% 0.00% 12.50% 0.03%
Revvity Inc RVTY 123.525 102.47 12,657.61 0.04% 0.27% 0.00% 8.26% 0.00%
Emerson Electric Co EMIR 571.7 107.78 61,617.83 0.19% 1.95% 0.00% 14.13% 0.03%
FOG Resources Inc EOG 580.002 132.13 76,635.66 0.24% 2.75% 0.01% 5.00% 0.01%
Aon PLC AON 217.431 282.01 61,317.72 0.19% 0.96% 0.00% 10.59% 0.02%
Entergy Corp ETR 213.273 105.54 22,508.83 0.07% 4.28% 0.00% 7.02% 0.00%
Equifax Inc EFX 123.611 220.19 27,217.91 0.09% 0.71% 0.00% 11.56% 0.01%
EQT Corp EQT 441.592 40.09 17,703.42 1.57% 31.59%
IQVIA Holdings Inc IQV 182.014 231.77 42,185.38 0.13% 8.92% 0.01%
Gartner Inc IT 77.63 412.59 32,029.36 0.10% 10.78% 0.01%
FedEx Corp FDX 246.081 261.78 64,419.08 0.20% 1.93% 0.00% 13.00% 0.03%
FMC Corp FMC 124.817 59.01 7,365.45 0.02% 3.93% 0.00% 8.00% 0.00%
Brown&Brown Inc BRO 285.249 81.54 23,259.20 0.07% 0.64% 0.00% 9.56% 0.01%
Ford Motor Co F 3921.485 12.15 47,646.04 0.15% 4.94% 0.01% 1.67% 0.00%
NextEra Energy Inc NEE 2023.714 66.97 135,528.13 0.43% 3.08% 0.01% 8.10% 0.03%
Franklin Resources Inc BEN 526.091 22.84 12,015.92 5.43%
Garmin Ltd GRMN 192.079 144.47 27,749.65 0.09% 2.08% 0.00% 5.60% 0.00%
Freeport-McMoRan Inc FCX 1434.409 49.94 71,634.39 0.22% 1.20% 0.00% 1.14% 0.00%
Dexcom Inc DXCM 397.684 127.39 50,660.96 30.31%
General Dynamics Corp GD 274.364 287.09 78,767.16 0.25% 1.98% 0.00% 12.64% 0.03%
General Mills Inc GIS 564.549 70.46 39,778.12 0.12% 3.35% 0.00% 4.00% 0.00%
Genuine Parts Cc GPC 139.299 157.21 21,899.20 2.54%
Atoms Energy Corp ATO 150.84 117.9 17,784.04 0.06% 2.73% 0.00% 7.00% 0.00%
WW Grainger Inc GWW 49.069 921.35 45,209.72 0.89%
HalliburtonCc HAL 885.301 37.47 33,172.23 0.10% 1.81% 0.00% 11.60% 0.01%
Healthpeak Properties Inc DOC 703.782 18.61 13,097.38 0.04% 6.45% 0.00% 2.24% 0.00%
L311arris Technologies Inc LHX 189.68 214.05 40,601.00 0.13% 2.17% 0.00% 7.29% 0.01%
Insulet Corp PODD 70.022 171.94 12,039.58 33.03%
Catalent Inc CTLT 180.974 55.85 10,107.40 35.27%
Fortive Corp FTV 352.029 75.27 26,497.22 0.08% 0.43% 0.00% 8.98% 0.01%
Hershey Co/The HSY 149.598 193.92 29,010.04 0.09% 2.83% 0.00% 5.50% 0.01%
Synchrony Financial SYF 401.544 43.98 17,659.91 2.27%
Hormel Foods Corp HRL 547.688 35.56 19,475.79 0.06% 3.18% 0.00% 6.59% 0.00%
Arthur J Gallagher&Cc AJG 216.8 234.69 50,880.79 0.16% 1.02% 0.00% 12.32% 0.02%
Mondelez International Inc MDLZ 1341.359 71.94 96,497.37 0.30% 2.36% 0.01% 8.55% 0.03%
CenterPoint Energy Inc CNP 633.032 29.14 18,446.55 0.06% 2.75% 0.00% 7.95% 0.00%
Humana Inc HUM 120.501 302.09 36,402.15 1.17% -6.15%
Willis Towers Watson PLC WTW 102.236 251.14 25,675.55 0.08% 1.40% 0.00% 12.37% 0.01%
Illinois Tool Works Inc ITW 298.745 244.11 72,926.64 0.23% 2.29% 0.01% 7.27% 0.02%
CDW Corp/DE CDW 134.368 241.86 32,498.24 0.10% 1.03% 0.00% 8.93% 0.01%
Trane Technologies PLC TT 226.352 317.34 71,830.54 0.23% 1.06% 0.00% 13.47% 0.03%
Interpublic Group of Cos Inc/The IPG 377.424 30.44 11,488.79 0.04% 4.34% 0.00% 4.94% 0.00%
International Flavors&Fragrances Inc IFF 255.319 84.65 21,612.75 1.89% -1.97%
Generac Holdings Inc GNRC 60.269 135.96 8,194.17 0.03% 6.00% 0.00%
NXP Semiconductors NV NXPI 255.684 256.19 65,503.68 0.21% 1.58% 0.00% 20.00% 0.04%
Kellanova K 340.678 57.86 19,711.63 0.06% 3.87% 0.00% 8.42% 0.01%
Broadridge Financial Solutions Inc BR 117.772 193.41 22,778.28 1.65%
Kimberly-ClarkCorp KMB 336.709 136.53 45,970.88 0.14% 3.57% 0.01% 7.72% 0.01%
Kimco Realty Corp KIM 674.133 18.63 12,559.10 0.04% 5.15% 0.00% 2.80% 0.00%
Oracle Corp ORCL 2748.514 113.75 312,643.47 0.98% 1.41% 0.01% 14.30% 0.14%
KrogerCo/The KR 721.688 55.38 39,967.08 0.13% 2.09% 0.00% 4.76% 0.01%
Lermw Corp LEN 245.036 151.62 37,152.36 0.12% 1.32% 0.00% 8.82% 0.01%

Rocky Mountain Power
Exhibit No.10 Page 3 of 7
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
[4] [5] [6] [7] [8] 191 [10] [11]
Bloomberg Cap-Weighted
Shares Market Weight in Estimated Cap-Weighted Long-Term Long-Term
Name Ticker Outst'g Price Capitalization Index Dividend Yield Dividend Yield Growth Est. Growth Est.
Eli Lilly&Co LLY 950.405 781.1 742,361.35 0.67% 40.63%
Bath&Body Works Inc BBWI 224.897 45.42 10,214.82 0.03% 1.76% 0.00% 13.65% 0.00%
Charter Communications Inc CHTR 144.386 255.94 36,954.15 0.12% 5.89% 0.01%
Loews Corp L 222.072 75.15 16,688.71 0.33%
Lowe's Cos Inc LOW 572.192 227.99 130,454.05 0.41% 1.93% 0.01% 2.12% 0.01%
Hubbell Inc HUBB 53.683 370.52 19,890.63 0.06% 1.32% 0.00% 18.00% 0.01%
IDEX Corp IEX 75.695 220.46 16,687.72 1.16%
Marsh&McLennan Cos Inc MMC 492.724 199.43 98,263.95 0.31% 1.42% 0.00% 6.90% 0.02%
Masco Corp MAS 220.244 68.45 15,075.70 0.05% 1.69% 0.00% 8.64% 0.00%
S&P Global Inc SPGI 320.257 415.83 133,172.47 0.42% 0.88% 0.00% 12.93% 0.05%
Medtronic PLC MDT 1327.823 80.24 106,544.52 0.33% 3.44% 0.01% 3.83% 0.01%
Viatris Inc VTRS 1187.569 11.57 13,740.17 4.15% -1.69%
CVS Health Corp CVS 1260.48 67.71 85,347.10 0.27% 3.93% 0.01% 7.62% 0.02%
DuPont de Nemours Inc DD 417.583 72.5 30,274.77 0.10% 2.10% 0.00% 6.72% 0.01%
Micron Technology Inc MU 1107.368 112.96 125,088.29 0.41% -4.00%
Motorola Solutions Inc MSI 166.123 339.15 56,340.62 0.18% 1.16% 0.00% 8.85% 0.02%
Cboe Global Markets Inc CBOE 105.582 181.15 19,126.18 0.06% 1.21% 0.00% 14.28% 0.01%
Laboratory Corp ofAmerica Holdings LH 84.294 201.37 16,974.28 0.05% 1.43% 0.00% 9.46% 0.01%
Newmont Corp NEM 1153.14 40.64 46,863.61 0.15% 2.46% 0.00% 18.15% 0.03%
NIKE Inc NKE 1211.462 92.26 111,769.48 0.35% 1.60% 0.01% 10.85% 0.04%
NiSource Inc NI 448.188 27.86 12,486.52 0.04% 3.80% 0.00% 7.00% 0.00%
Norfolk Southern Corp NSC 225.914 230.32 52,032.51 2.34%
Principal Financial Group Inc PFG 235.15 79.14 18,609.77 0.06% 3.59% 0.00% 11.79% 0.01%
Eversource Energy ES 350.727 60.62 21,261.07 4.72%
Northrop Grumman Corp NOC 147.99 485.03 71,779.59 0.23% 1.54% 0.00% 18.93% 0.04%
Wells Fargo&Co WFC 3501.7 59.32 207,720.84 0.65% 2.36% 0.02% 13.41% 0.09%
Nucor Corp NUE 239.98 168.53 40,443.83 0.13% 1.28% 0.00% 0.83% 0.00%
Occidental Petroleum Corp OXY 879.499 66.14 58,170.06 0.18% 1.33% 0.00% 20.00% 0.04%
Omnicom Group Inc OMC 195.834 92.84 18,181.23 0.06% 3.02% 0.00% 7.46% 0.00%
ONEOK Inc OKE 583.64 79.12 46,177.60 0.14% 5.01% 0.01% 1.56% 0.00%
Raymond James Financial Inc RJF 207.3 122 25,290.60 0.08% 1.48% 0.00% 15.38% 0.01%
PG&E Corp PCG 2133.508 17.11 36,504.32 0.11% 0.23% 0.00% 10.10% 0.01%
Parker-Hannifin Corp PH 128.411 544.91 69,972.44 0.22% 1.20% 0.00% 16.28% 0.04%
Rollins Inc ROL 484.23 44.56 21,577.29 0.07% 1.35% 0.00% 13.02% 0.01%
PPL Corp PPL 737.124 27.46 20,241.43 0.06% 3.75% 0.00% 7.22% 0.00%
ConocoPhillips COP 1171.101 125.62 147,113.71 2.48%
PulteGroupInc PHM 210.342 111.42 23,436.31 0.07% 0.72% 0.00% 7.65% 0.01%
Pinnacle West Capital Corp PNW 113.557 73.65 8,363.47 0.03% 4.78% 0.00% 7.28% 0.00%
PNC Financial Services Group Inc/The PNC 397.845 153.26 60,973.72 0.19% 4.05% 0.01% 15.32% 0.03%
PPG Industries Inc PPG 235.361 129 30,361.57 0.10% 2.02% 0.00% 7.82% 0.01%
Progressive Corp/The PGR 585.7 208.25 121,972.03 0.19% 32.49%
Veralto Corp VLTO 246.847 93.68 23,124.63 0.38%
Public Service Enterprise Group Inc PEG 498.587 69.08 34,442.39 0.11% 3.47% 0.00% 6.28% 0.01%
Robert Half Inc RHI 105.117 69.14 7,267.79 0.02% 3.07% 0.00% 7.15% 0.00%
Cooper Cos Inc/The COO 198.756 89.06 17,701.21 0.06% 11.77% 0.01%
Edison International EIX 383.925 71.06 27,281.71 0.09% 4.39% 0.00% 7.80% 0.01%
SchlumbergerNV SLB 1429.338 47.48 67,864.97 0.21% 2.32% 0.00% 14.81% 0.03%
Charles Schwab Corp/The SCHW 1773.475 73.95 131,148.48 0.41% 1.35% 0.01% 14.20% 0.06%
Sherwin-Williams Co/The SHW 253.549 299.61 75,965.82 0.24% 0.95% 0.00% 9.56% 0.02%
West Pharmaceutical Services Inc WST 72.843 357.48 26,039.92 0.08% 0.22% 0.00% 7.72% 0.01%
J M Smucker Co/The SJM 106.176 114.85 12,194.31 0.04% 3.69% 0.00% 7.04% 0.00%
Snap-on Inc SNA 52.719 267.96 14,126.58 0.04% 2.78% 0.00% 3.83% 0.00%
AMETEK Inc AME 231.211 174.66 40,383.31 0.13% 0.64% 0.00% 7.56% 0.01%
Uber Technologies Inc UBER 2081.544 66.27 137,943.92 51.75%
SouthernCo/The SO 1094.633 73.5 80,455.53 0.25% 3.92% 0.01% 7.10% 0.02%
Tmist Financial Corp TFC 1338.096 37.55 50,245.50 0.16% 5.54% 0.01% 10.30% 0.02%
Southwest Airlines Co LUV 598.456 25.94 15,523.95 2.78% 21.33%
W R Berkley Corp WRB 256.549 76.97 19,746.58 0.06% 0.57% 0.00% 11.50% 0.01%
Stanley Black&Decker Inc SWK 153.802 91.4 14,057.50 0.04% 3.54% 0.00% 10.00% 0.00%
Public Storage PSA 175.829 259.45 45,618.83 0.14% 4.63% 0.01% 3.51% 0.01%
Arista Networks Inc ANET 312.634 256.56 80,209.38 0.25% 15.67% 0.04%
Sysco Corp SYY 497.83 74.32 36,998.73 0.12% 2.74% 0.00% 14.00% 0.02%
Corteva Inc CTVA 687.797 54.13 37,230.45 0.12% 1.18% 0.00% 13.66% 0.02%
Texas Instruments Inc TXN 910.482 176.42 160,627.23 0.50% 2.95% 0.01% 10.00% 0.05%
Textron Inc TXT 190.699 84.59 16,131.23 0.05% 0.09% 0.00% 10.12% 0.01%
Thermo Fisher Scientific Inc TMO 381.312 568.72 216,859.76 0.27%
TJX Cos Inc/The TJX 1132.974 94.09 106,601.52 0.33% 1.59% 0.01% 10.00% 0.03%
Globe Life Inc GL 94.037 76.17 7,162.80 0.02% 1.26% 0.00% 7.00% 0.00%
Johnson Controls International plc JCI 681.477 65.07 44,343.71 0.14% 2.27% 0.00% 9.77% 0.01%
Ulta Beauty Inc ULTA 47.935 404.84 19,406.01 0.06% 6.90% 0.00%
Union Pacific Corp UNP 610.122 237.16 144,696.53 0.45% 2.19% 0.01% 11.00% 0.05%

Rocky Mountain Power
Exhibit No.10 Page 4 of 7
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
[4] [5] [6] [7] [8] 191 [10] [11]
Bloomberg Cap-Weighted
Shares Market Weight in Estimated Cap-Weighted Long-Term Long-Term
Name Ticker Outst'g Price Capitalization Index Dividend Yield Dividend Yield Growth Est. Growth Est.
Keysight Technologies Inc KEYS 174.556 147.94 25,823.81 -0.99%
UnitedHealth Group Inc UNH 920.08 483.7 445,042.70 1.40% 1.55% 0.02% 11.58% 0.16%
Blackstone Inc BX 722.263 116.61 84,223.09 2.85% 23.93%
Marathon Oil Corp MRO 571.477 26.85 15,344.16 0.05% 1.64% 0.00% 7.00% 0.00%
Bio-Rad Laboratories Inc BIO 23.423 269.75 6,318.35
Ventas Inc VTR 404.049 44.28 17,891.29 0.06% 4.07% 0.00% 5.78% 0.00%
Vulcan Materials Cc VMC 132.272 257.63 34,077.24 0.11% 0.71% 0.00% 15.78% 0.02%
Weyerhaeuser Cc WY 729.617 30.17 22,012.54 2.65%
Williams CosInc/The WMB 1218.425 38.36 46,738.78 0.15% 4.95% 0.01% 2.50% 0.00%
Constellation Energy Corp CEG 315.121 185.94 58,593.60 0.18% 0.76% 0.00% 9.00% 0.02%
WEC Energy Group Inc WEC 315.562 82.64 26,078.04 0.08% 4.04% 0.00% 6.85% 0.01%
Adobe Inc ADBE 448 462.83 207,347.84 0.65% 16.73% 0.11%
AES Corp/The AES 710.287 17.9 12,714.14 0.04% 3.85% 0.00% 7.85% 0.00%
Expeditors International of Washington Inc EXPD 143.899 111.31 16,017.40 0.05% 1.24% 0.00% 2.85% 0.00%
Amgen Inc AMGN 536.376 273.94 146,934.84 0.46% 3.29% 0.02% 4.49% 0.02%
Apple Inc AAPL 15441.881 170.33 2,630,215.59 8.26% 0.56% 0.05% 13.00% 1.07%
Autodesk Inc ADSK 213.915 212.85 45,531.81 0.14% 12.76% 0.02%
Cintas Corp CTAS 101.463 658.34 66,797.15 0.21% 0.82% 0.00% 10.83% 0.02%
Comcast Corp CMCSA 3914.182 38.11 149,169.48 0.47% 3.25% 0.02% 8.67% 0.04%
Molson Coors Beverage Cc TAP 197.551 57.26 11,311.77 0.04% 3.07% 0.00% 4.67% 0.00%
KLA Corp KLAC 134.64 689.29 92,806.01 0.29% 0.84% 0.00% 9.54% 0.03%
Marriott InternationalInc/MD MAR 288.259 236.13 68,066.60 0.21% 0.88% 0.00% 4.74% 0.01%
Fisery Inc FI 585.102 152.67 89,327.52 0.28% 15.47% 0.04%
McCormick&Co Inc/MD MKC 251.745 76.06 19,147.72 0.06% 2.21% 0.00% 5.96% 0.00%
PACCAR Inc PCAR 524.011 106.11 55,602.81 0.17% 1.13% 0.00% 12.00% 0.02%
Costco Wholesale Corp COST 443.504 722.9 320,609.04 1.01% 0.64% 0.01% 10.16% 0.10%
Stryker Corp SYK 380.47 336.5 128,028.16 0.40% 0.95% 0.00% 8.45% 0.03%
Tyson Foods Inc TSN 286.339 60.65 17,366.46 3.23% 53.81%
Lamb Weston Holdings Inc LW 144.391 83.34 12,033.55 0.04% 1.73% 0.00% 11.56% 0.00%
Applied Materials Inc AMAT 830.897 198.65 165,057.69 0.52% 0.81% 0.00% 14.23% 0.07%
American Airlines Group Inc AAL 653.541 13.51 8,829.34 -1.53%
Cardinal Health Inc CAH 243.233 103.04 25,062.73 0.08% 1.94% 0.00% 11.91% 0.01%
Cincinnati Financial Corp CINF 156.558 115.69 18,112.20 0.06% 2.80% 0.00% 7.35% 0.00%
Paramount Global PARA 625.776 11.39 7,127.59 1.76% 48.12%
DR Horton Inc DHI 329.312 142.1901 46,824.91 0.15% 0.84% 0.00% 4.37% 0.01%
Electronic Arts Inc EA 267.35 126.82 33,905.33 0.11% 0.60% 0.00% 12.50% 0.01%
Fair Isaac Corp FICO 24.711 1133.33 28,005.72
Fasten]Co FAST 572.547 67.94 38,898.84 2.30%
M&T Bank Corp MTB 166.724 144.39 24,073.28 0.08% 3.60% 0.00% 8.00% 0.01%
Xcel Energy Inc XEL 555.639 53.73 29,854.48 0.09% 4.08% 0.00% 6.71% 0.01%
Fifth Third Bancorp FITB 683.812 36.46 24,931.79 3.84% 25.00%
Gilead Sciences Inc GILD 1246.969 65.2 81,302.38 0.26% 4.72% 0.01% 13.35% 0.03%
Hasbro Inc HAS 138.791 61.3 8,507.89 0.03% 4.57% 0.00% 17.10% 0.00%
Huntington Bancshares Inc/OH HBAN 1449.254 13.47 19,521.45 0.06% 4.60% 0.00% 4.46% 0.00%
Welltower Inc WELL 597.916 95.28 56,969.44 0.18% 2.56% 0.00% 14.52% 0.03%
Biogen Inc BIIB 145.597 214.82 31,277.15 0.10% 4.62% 0.00%
Northern Trust Corp NTRS 204.592 82.39 16,856.33 0.05% 3.64% 0.00% 10.80% 0.01%
Packaging Corp of America PKG 89.755 172.98 15,525.82 0.05% 2.89% 0.00% 3.00% 0.00%
Paychexlnc PAYX 359.963 118.81 42,767.20 0.13% 3.00% 0.00% 7.00% 0.01%
QUALCOMM Inc QCOM 1116 165.85 185,088.60 0.58% 2.05% 0.01% 10.65% 0.06%
Ross Stores Inc ROST 335.174 129.55 43,421.79 0.14% 1.13% 0.00% 10.00% 0.01%
IDEXX Laboratories Inc IDXX 83.089 492.76 40,942.94 0.13% 11.51% 0.01%
Starbucks Corp SBUX 1132.2 88.49 100,188.38 0.31% 2.58% 0.01% 13.62% 0.04%
KeyCorp KEY 942.776 14.49 13,660.82 0.04% 5.66% 0.00% 9.83% 0.00%
Fox Corp FOXA 239.295 31.01 7,420.54 0.02% 1.68% 0.00% 6.24% 0.00%
Fox Corp FOX 235.581 28.68 6,756.46 0.02% 1.81% 0.00% 6.24% 0.00%
State Street Corp STT 301.504 72.49 21,856.02 0.07% 3.81% 0.00% 8.06% 0.01%
Norwegian Cruise Line Holdings Ltd NCLH 425.657 18.92 8,053.43 48.23%
US Bancorp USB 1558 40.63 63,301.54 0.20% 4.82% 0.01% 5.00% 0.01%
A O Smith Corp AOS 120.784 82.84 10,005.75 1.55%
Gen Digital Inc GEN 636.91 20.14 12,827.37 0.04% 2.48% 0.00% 11.51% 0.00%
T Rowe Price Group Inc TROW 223.3 109.57 24,466.98 0.08% 4.53% 0.00% 5.88% 0.00%
Waste Management Inc WM 401.083 208.02 83,433.29 0.26% 1.44% 0.00% 11.11% 0.03%
Constellation Brands Inc STZ 182.953 253.46 46,371.27 0.15% 1.59% 0.00% 11.01% 0.02%
Invesco Ltd IVZ 449.8 14.17 6,373.67 0.02% 5.79% 0.00% 8.71% 0.00%
Intuit Inc INTU 279.979 625.62 175,160.46 0.55% 0.58% 0.00% 18.76% 0.10%
Morgan Stanley MS 1627 90.84 147,796.68 0.46% 3.74% 0.02% 5.29% 0.02%
Microchip Technology Inc MCHP 540.388 91.98 49,704.89 0.16% 1.96% 0.00% 2.30% 0.00%
Chubb Ltd CB 406.061 248.64 100,963.01 0.32% 1.38% 0.00% 6.00% 0.02%
Hologic Inc HOLX 234.732 75.77 17,785.64 0.06% 8.68% 0.00%
Citizens Financial Group Inc CFG 458.485 34.11 15,638.92 4.93% -5.79%
Jabil Inc JBL 120.597 117.36 14,153.26 0.04% 0.27% 0.00% 12.00% 0.01%
O'Reilly Automotive Inc ORLY 58.982 1013.26 59,764.10 0.19% 10.51% 0.02%
Allstate Corp/The ALL 263.759 170.06 44,854.86 2.16% 53.70%
Equity Residential EQR 378.94 64.4 24,403.74 0.08% 4.19% 0.00% 4.75% 0.00%
BorgWamer Inc BWA 230.956 32.77 7,568.43 0.02% 1.34% 0.00% 5.67% 0.00%
Keurig Dr Pepper Inc KDP 1355.574 33.7 45,682.84 0.14% 2.55% 0.00% 7.12% 0.01%
Host Hotels&Resorts Inc HST 703.6 18.87 13,276.93 4.24%
Incyte Corp INCY 224.541 52.05 11,687.36 25.33%

Rocky Mountain Power
Exhibit No.10 Page 5 of 7
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
[4] [5] [6] [7] [8] 191 [10] [11]
Bloomberg Cap-Weighted
Shares Market Weight in Estimated Cap-Weighted Long-Term Long-Term
Name Ticker Outst'g Price Capitalization Index Dividend Yield Dividend Yield Growth Est. Growth Est.
Simon Property Group Inc SPG 325.766 140.53 45,779.90 0.14% 5.55% 0.01% 1.58% 0.00%
Eastman Chemical Co EMN 117.649 94.44 11,110.77 0.03% 3.43% 0.00% 6.19% 0.00%
AvalonBay Communities Inc AVB 142.025 189.57 26,923.68 0.08% 3.59% 0.00% 5.81% 0.00%
Prudential Financial Inc PRU 359.38 110.48 39,704.30 0.12% 4.71% 0.01% 10.08% 0.01%
United Parcel Service Inc UPS 727.842 147.48 107,342.14 0.34% 4.42% 0.01% 8.77% 0.03%
Walgreens Boots Alliance Inc WBA 862.713 17.73 15,295.90 5.64% -1.67%
STERIS PLC STE 98.814 204.56 20,213.39 1.02%
McKesson Corp MCK 131.408 537.21 70,593.69 0.22% 0.46% 0.00% 12.22% 0.03%
Lockheed Martin Corp LMT 239.938 464.93 111,554.37 0.35% 2.71% 0.01% 2.39% 0.01%
Cencom Inc COR 199.482 239.05 47,686.17 0.15% 0.85% 0.00% 10.10% 0.02%
Capital One Financial Corp COF 382.102 143.43 54,804.89 1.67% 50.10%
Waters Corp WAT 59.31 309.04 18,329.16 0.06% 7.23% 0.00%
Nordson Corp NDSN 57.192 258.19 14,766.40 1.05%
Dollar Tree Inc DLTR 217.983 118.25 25,776.49 0.08% 14.10% 0.01%
Darden Restaurants Inc DRI 119.359 153.41 18,310.86 0.06% 3.42% 0.00% 10.97% 0.01%
Evergy Inc EVRG 229.746 52.45 12,050.18 0.04% 4.90% 0.00% 5.00% 0.00%
Match Group Inc MTCH 268.012 30.82 8,260.13 36.66%
Domino's Pizza Inc DPZ 34.88 529.27 18,460.94 0.06% 1.14% 0.00% 12.99% 0.01%
NVR Inc NVR 3.168 7438.85 23,566.28 0.07% 4.87% 0.00%
NetApp Inc NTAP 206.377 102.21 21,093.79 0.07% 1.96% 0.00% 7.40% 0.00%
Old Dominion Freight Line Inc ODFL 217.674 181.71 39,553.54 0.12% 0.57% 0.00% 13.12% 0.02%
DaVita Inc DVA 87.7 139.01 12,191.18 0.04% 14.97% 0.01%
Hartford Financial Services Group Inc/The HIG 295.755 96.89 28,655.70 0.09% 1.94% 0.00% 7.00% 0.01%
Iron Mountain Inc IRM 293.096 77.52 22,720.80 3.35%
Estee Lauder Coslnc/fhe EL 232.931 146.71 34,173.31 0.11% 1.80% 0.00% 17.63% 0.02%
Cadence Design Systems Inc CDNS 272.134 275.63 75,008.29 0.24% 16.32% 0.04%
Tyler Technologies Inc TYL 42.455 461.55 19,595.11
Universal Health Services Inc UHS 60.083 170.43 10,239.95 0.03% 0.47% 0.00% 12.42% 0.00%
Skyworks Solutions Inc SWKS 160.444 106.59 17,101.73 0.05% 2.55% 0.00% 5.08% 0.00%
Quest Diagnostics Inc DGX 111.092 138.18 15,350.69 2.17% -0.82%
Rockwell Automation Inc ROK 114.592 270.96 31,049.85 0.10% 1.85% 0.00% 10.87% 0.01%
Kraft HeinzCo/The KHC 1215.638 38.61 46,935.78 0.15% 4.14% 0.01% 3.87% 0.01%
American Tower Corp AMT 466.975 171.56 80,114.23 0.25% 3.78% 0.01% 10.24% 0.03%
Regenemn Pharmaceuticals Inc REGN 107.944 890.66 96,141.40 0.30% 13.00% 0.04%
Amazon.com Inc AMZN 10387.381 175 1,817,791.68 24.94%
Jack Henry&Associates Inc JKHY 72.868 162.69 11,854.89 0.04% 1.35% 0.00% 7.69% 0.00%
Ralph Lauren Corp RL 39.044 163.64 6,389.16 0.02% 1.83% 0.00% 12.64% 0.00%
Boston Properties Inc BXP 157.049 61.89 9,719.76 0.03% 6.33% 0.00% 0.37% 0.00%
Amphenol Corp APH 600.604 120.77 72,534.95 0.23% 0.73% 0.00% 11.57% 0.03%
Howmet Aerospace Inc HWM 410.304 66.75 27,387.79 0.09% 0.30% 0.00% 14.19% 0.01%
Pioneer Natural Resources Co PXD 233.623 269.32 62,919.35 3.80% -13.00%
Valero Energy Corp VLO 326.996 159.87 52,276.85 2.68% -24.00%
Synopsys Inc SNPS 152.544 530.59 80,938.32 0.25% 18.70% 0.05%
Etsy Inc ETSY 117.064 68.67 8,038.78 0.03% 4.48% 0.00%
CH Robinson Worldwide Inc CHRW 115.712 71 8,215.55 0.03% 3.44% 0.00% 5.00% 0.00%
Accenture PLC ACN 670.422 300.91 201,736.68 0.63% 1.71% 0.01% 10.00% 0.06%
TransDigm Group Inc TDG 55.606 1248.03 69,397.96 0.22% 14.52% 0.03%
Yum!Brands Inc YUM 281.5 141.25 39,761.88 0.12% 1.90% 0.00% 8.59% 0.01%
Prologis Inc PLD 925.844 102.05 94,482.38 0.30% 3.76% 0.01% 8.70% 0.03%
FirstEnergy Corp FE 575.516 38.34 22,065.28 0.07% 4.43% 0.00% 6.65% 0.00%
VeriSign Inc VRSN 100.139 169.48 16,971.56
Quanta Services Inc PWR 145.749 258.56 37,684.86 0.12% 0.14% 0.00% 10.00% 0.01%
Henry Schein Inc HSIC 128.481 69.28 8,901.16 0.03% 9.38% 0.00%
Ameren Corp AEE 266.511 73.87 19,687.17 0.06% 3.63% 0.00% 6.00% 0.00%
ANSYS Inc ANSS 87.3 324.88 28,362.02 0.09% 8.63% 0.01%
FactSet Research Systems Inc FDS 38.116 416.89 15,890.18 0.05% 0.94% 0.00% 10.32% 0.01%
NVIDIA Corp NVDA 2500 864.02 2,160,050.00 0.02% 37.63%
Cognizant Technology Solutions Corp CTSH 497.199 65.68 32,656.03 0.10% 1.83% 0.00% 12.00% 0.01%
Intuitive Surgical Inc ISRG 354.706 370.62 131,461.14 0.41% 16.21% 0.07%
Take-Two Interactive Software Inc TTWO 170.746 142.81 24,384.24 22.73%
Republic Services Inc RSG 314.975 191.7 60,380.71 0.19% 1.12% 0.00% 9.04% 0.02%
eBay Inc EBAY 518 51.54 26,697.72 0.08% 2.10% 0.00% 1.99% 0.00%
Goldman Sachs Group Inc/The GS 324.527 426.71 138,478.92 0.43% 2.58% 0.01% 9.31% 0.04%
SBA Communications Corp SBAC 108.021 186.12 20,104.87 0.06% 2.11% 0.00% 8.00% 0.01%
Sempra SRE 632.15 71.63 45,280.90 0.14% 3.46% 0.00% 3.85% 0.01%
Moody's Corp MCO 182.5 370.33 67,585.23 0.21% 0.92% 0.00% 9.45% 0.02%
ON Semiconductor Corp ON 430.232 70.16 30,185.08 0.09% 3.32% 0.00%
Booking Holdings Inc BKNG 34.171 3452.03 117,959.32 1.01% 22.55%
FSInc FFIV 58.806 165.31 9,721.22 0.03% 7.81% 0.00%
Akamai Technologies Inc AKAM 153.211 100.93 15,463.59 0.05% 8.33% 0.00%
Charles River Laboratories International Inc CRL 51.35 229 11,759.15 0.04% 14.00% 0.01%
MarketAxess Holdings Inc MKTX 37.868 200.09 7,577.01 0.02% 1.48% 0.00% 5.09% 0.00%
Devon Energy Corp DVN 635 51.18 32,499.30 3.44%
Bio-Techne Corp TECH 157.192 63.21 9,936.11 0.03% 0.51% 0.00% 2.00% 0.00%
Alphabet Inc GOOGL 5874 162.78 956,169.72 3.00% 0.49% 0.01% 15.01% 0.45%
Teleflex Inc TFX 47.101 208.75 9,832.33 0.03% 0.65% 0.00% 7.21% 0.00%
Allegionplc ALLE 87.441 121.56 10,629.33 0.03% 1.58% 0.00% 7.25% 0.00%
NetflixInc NFLX 430.965 550.64 237,306.57 35.61%
Warner Bros Discovery Inc WBD 2450.13 7.36 18,032.96 35.28%

Rocky Mountain Power
Exhibit No.10 Page 6 of 7
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
[4] [5] [6] [7] [8] 191 [10] [11]
Bloomberg Cap-Weighted
Shares Market Weight in Estimated Cap-Weighted Long-Term Long-Term
Name Ticker Outst'g Price Capitalization Index Dividend Yield Dividend Yield Growth Est. Growth Est.
Agilent Technologies Inc A 293.055 137.04 40,160.26 0.69%
Trimble Inc TRMB 244.208 60.07 14,669.57
Elevance Health Inc ELV 232.418 528.58 122,851.51 0.39% 1.23% 0.00% 10.02% 0.04%
CME Group Inc CME 360.025 209.64 75,475.64 0.24% 2.19% 0.01% 4.90% 0.01%
Juniper Networks Inc JNPR 324.988 34.82 11,316.08 0.04% 2.53% 0.00% 4.78% 0.00%
B1ackRockInc BLK 148.76 754.64 112,260.25 0.35% 2.70% 0.01% 11.89% 0.04%
DTE Energy Co DTE 206.925 110.32 22,827.97 0.07% 3.70% 0.00% 6.50% 0.00%
Celanese Corp CE 108.906 153.61 16,729.05 0.05% 1.82% 0.00% 4.32% 0.00%
Nasdaq Inc NDAQ 575.207 59.85 34,426.14 0.11% 1.60% 0.00% 5.72% 0.01%
Philip Morris Intemational Inc PM 1554.557 94.94 147,589.64 0.46% 5.48% 0.03% 8.23% 0.04%
Ingersoll Rand Inc IR 403.436 93.32 37,648.65 0.09%
Salesforce Inc CRM 970 268.94 260,871.80 0.59% 22.50%
Roper Technologies Inc ROP 107.022 511.46 54,737.47 0.59%
Huntington Ingalls Industries Inc HII 39.609 276.93 10,968.92 1.88% 40.00%
MetLife Inc MET 723.02 71.08 51,392.26 0.16% 3.07% 0.00% 14.63% 0.02%
Tapestry Inc TPR 229.366 39.92 9,156.29 0.03% 3.51% 0.00% 11.00% 0.00%
CSX Corp CSX 1954.927 33.22 64,942.67 0.20% 1.44% 0.00% 10.76% 0.02%
Edwards Lifesciences Corp EW 601.3 84.67 50,912.07 0.16% 10.03% 0.02%
Ameriprise Financial Inc AMP 100.191 411.79 41,257.65 1.44%
Zebra Technologies Corp ZBRA 51.419 314.56 16,174.36
Zimmer Biomet Holdings Inc ZBH 2O5.084 120.28 24,667.50 0.08% 0.80% 0.00% 6.89% 0.01%
Camden Property Trust CPT 106.969 99.68 10,662.67 0.03% 4.13% 0.00% 5.93% 0.00%
CBRE Group Inc CBRE 305.696 86.89 26,561.93
Mastercard Inc MA 925.723 451.2 417,686.22 1.31% 0.59% 0.01% 16.78% 0.22%
CarMax Inc KMX 157.388 67.97 10,697.66 25.76%
Intercontinental Exchange Inc ICE 572.616 128.76 73,730.04 0.23% 1.40% 0.00% 10.83% 0.03%
Fidelity National Information Services Inc FIS 576.466 67.92 39,153.57 0.12% 2.12% 0.00% 16.00% 0.02%
Chipotle Mexican Grill Inc CMG 27.467 3159.6 86,784.73 22.81%
Wynn Resorts Ltd WYNN 112.067 91.65 10,270.94 1.09%
Live Nation Entertainment Inc LYV 230.798 88.91 20,520.25
Assonant Inc AIZ 51.978 174.4 9,064.96 0.03% 1.65% 0.00% 5.04% 0.00%
NRG Energy Inc NRG 208.021 72.67 15,116.89 0.05% 2.24% 0.00% 3.00% 0.00%
Monster Beverage Corp MNST 1040.636 53.45 55,621.99 0.17% 12.45% 0.02%
Regions Financial Corp RF 918.864 19.27 17,706.51 0.06% 4.98% 0.00% 1.71% 0.00%
Baker Hughes Co BKR 997.998 32.62 32,554.69 2.58% 27.93%
Mosaic Co/The MOS 321.689 31.39 10,097.82 0.03% 2.68% 0.00% 16.00% 0.01%
Expedia Group Inc EXPE 130.765 134.63 17,604.89 0.06% 19.47% 0.01%
CF Industries Holdings Inc CF 188.338 78.97 14,873.05 0.05% 2.53% 0.00% 2.50% 0.00%
APA Corp APA 370.888 31.44 11,660.72 3.18% -2.00%
Leidos Holdings Inc LDOS 135.212 140.22 18,959.43 0.06% 1.08% 0.00% 9.66% 0.01%
Alphabet Inc GOOG 5617 164.64 924,782.88 2.90% 0.49% 0.01% 15.01% 0.44%
First Solar Inc FSLR 107.026 176.3 18,868.68 29.52%
TE Connectivity Ltd TEL 306.228 141.48 43,325.14 0.14% 1.84% 0.00% 5.04% 0.01%
Discover Financial Services DES 251 126.73 31,809.23 2.21% 61.27%
Visa Inc V 1574.152 268.61 422,832.97 1.33% 0.77% 0.01% 13.53% 0.18%
Mid-America Apartment Communities Inc MAA 116.688 130 15,169.44 0.05% 4.52% 0.00% 2.99% 0.00%
Xylem Inc/NY XYL 241.77 130.7 31,599.34 1.10%
Marathon Petroleum Corp MPC 352.33 181.72 64,025.41 1.82% -12.00%
Tractor Supply Cc TSCO 107.932 273.08 29,474.07 0.09% 1.61% 0.00% 5.54% 0.01%
Advanced Micro Devices Inc AMD 1615.787 158.38 255,908.35 33.38%
ResMed Inc RMD 146.907 213.99 31,436.63 0.10% 0.90% 0.00% 8.30% 0.01%
Mettler-Toledo Intemational Inc MTD 21.388 1229.7 26,300.82 0.08% 9.18% 0.01%
VICI Properties Inc VICI 1043.137 28.55 29,781.56 0.09% 5.81% 0.01% 1.98% 0.00%
Copart Inc CPRT 961.462 54.31 52,217.00
Jacobs Solutions Inc J 125.651 143.53 18,034.69 0.06% 0.81% 0.00% 12.41% 0.01%
Albemarle Corp ALB 117.525 120.31 14,139.43 1.33% -19.50%
Fortinet Inc FTNT 763.031 63.18 48,208.30 0.15% 18.05% 0.03%
Moderns Inc MRNA 382.88 110.31 42,235.49 0.13% 17.62% 0.02%
Essex Property Trust Inc ESS 64.206 246.25 15,810.73 0.05% 3.98% 0.00% 4.48% 0.00%
Costar Group Inc CSGP 408.342 91.53 37,375.54 0.12% 20.00% 0.02%
Realty Income Corp O 861.15 53.54 46,105.97 0.14% 5.76% 0.01% 4.82% 0.01%
Westrock Co WRK 258.148 47.96 12,380.78 0.04% 2.52% 0.00% 5.28% 0.00%
Westinghouse Air Brake Technologies Corp WAB 176.385 161.08 28,412.10 0.09% 0.50% 0.00% 15.49% 0.01%
Pool Corp POOL 38.329 362.53 13,895.41 0.04% 1.21% 0.00% 4.73% 0.00%
Western Digital Corp WDC 326.525 70.83 23,127.77 -11.96%
PepsiCo Inc PEP 1374.786 175.91 241,838.61 0.76% 3.08% 0.02% 7.91% 0.06%
Diamondback Energy Inc FANG 178.34 201.13 35,869.52 0.11% 6.13% 0.01% 2.00% 0.00%
Palo Alto Networks Inc PANW 323.1 290.89 93,986.56 20.50%
ServiceNow Inc NOW 205.382 693.33 142,397.50 25.00%
Church&Dwight Co Inc CHD 243.905 107.89 26,314.91 0.08% 1.05% 0.00% 7.35% 0.01%
Federal Realty Investment Trust FRT 82.775 104.17 8,622.67 0.03% 4.19% 0.00% 5.18% 0.00%
MGM Resorts International MGM 317.016 39.44 12,503.11 0.04% 9.87% 0.00%
American Electric Power Cc Inc AEP 526.59 86.03 45,302.54 0.14% 4.09% 0.01% 5.93% 0.01%
Invitation Homes Inc INVH 611.958 34.2 20,928.96 0.07% 3.27% 0.00% 6.43% 0.00%
PTC Inc PTC 119.552 177.44 21,213.31 21.10%
JB Hunt Transport Services Inc JBHT 103.197 162.57 16,776.74 0.05% 1.06% 0.00% 12.00% 0.01%
Lam Research Corp LRCX 130.736 894.41 116,931.59 0.37% 0.89% 0.00% 11.92% 0.04%
Mohawk Industries Inc MHK 63.863 115.32 7,364.68 0.02% 2.74% 0.00%
GE HealthCare Technologies Inc GEHC 456.465 76.24 34,800.89 0.11% 0.16% 0.00% 11.53% 0.01%
Pentair PLC PNR 166.025 79.09 13,130.92 0.04% 1.16% 0.00% 13.13% 0.01%
Vertex Pharmaceuticals Inc VRTX 258.459 392.81 101,525.28 0.32% 16.71% 0.05%
Amcor PLC AMCR 1445.343 8.94 12,921.37 0.04% 5.59% 0.00% 2.63% 0.00%
Meta Platforms Inc META 2191.446 430.17 942,694.33 2.96% 0.46% 0.01% 18.58% 0.55%

Rocky Mountain Power
Exhibit No.10 Page 7 of 7
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
[4] [5] [6] [7] [8] 191 [10] [11]
Bloomberg Cap-Weighted
Shares Market Weight in Estimated Cap-Weighted Long-Term Long-Term
Name Ticker Outst'g Price Capitalization Index Dividend Yield Dividend Yield Growth Est. Growth Est.
T-Mobile US Inc TMUS 1171.854 164.17 192,383.27 0.60% 1.58% 0.01% 5.00% 0.03%
United Rentals Inc URI 66.59 667.99 44,481.45 0.14% 0.98% 0.00% 5.27% 0.01%
Alexandria Real Estate Equities Inc ARE 174.883 115.87 20,263.69 0.06% 4.38% 0.00% 5.49% 0.00%
Honeywell International Inc HON 651.186 192.73 125,503.08 0.39% 2.24% 0.01% 8.50% 0.03%
Delta Air Lines Inc DAL 645.312 50.07 32,310.77 0.10% 0.80% 0.00% 12.00% 0.01%
United Airlines Holdings Inc UAL 328.803 51.46 16,920.20 0.05% 12.79% 0.01%
Seagate Technology Holdings PLC STX 209.989 85.91 18,040.15 0.06% 3.26% 0.00% 1.21% 0.00%
News Corp NWS 191.095 24.54 4,689.47 0.81%
Centene Corp CNC 534.906 73.06 39,080.23 0.12% 5.16% 0.01%
Martin Marietta Materials Inc MLM 61.64 587.07 36,186.99 0.11% 0.50% 0.00% 9.71% 0.01%
Teradyne Inc TER 152.974 116.32 17,793.94 0.41% -1.44%
PayPal Holdings Inc PYPL 1046.046 67.92 71,047.44 0.22% 6.02% 0.01%
Tesla Inc TSLA 3189.196 183.28 584,515.84 -11.00%
Arch Capital Group Ltd ACGL 374.151 93.54 34,998.08 0.11% 6.00% 0.01%
Dow Inc DOW 703.268 56.9 40,015.95 0.13% 4.92% 0.01% 2.46% 0.00%
Everest Group Ltd EG 43.382 366.41 15,895.60 0.05% 1.91% 0.00% 3.93% 0.00%
Teledyne Technologies Inc TDY 47.422 381.48 18,090.54 0.06% 7.49% 0.00%
GE Vemova Inc GEV 274.086 153.71 42,129.76
News Corp NWSA 380.024 23.8 9,044.57 0.84%
Exelon Corp EXC 999.735 37.58 37,570.04 0.12% 4.04% 0.00% 5.25% 0.01%
Global Payments Inc GPN 257.985 122.77 31,672.82 0.10% 0.81% 0.00% 11.98% 0.01%
Crown Castle Inc CCI 435 93.78 40,794.30 0.13% 6.68% 0.01% 7.00% 0.01%
Aptiv PLC APTV 272.679 71 19,360.21 0.06% 11.44% 0.01%
Align Technology Inc ALGN 75.279 282.38 21,257.28 0.07% 6.87% 0.00%
Illumina Inc ILMN 158.9 123.05 19,552.65 0.06% 3.00% 0.00%
Kenvue Inc KVUE 1914.648 18.82 36,033.68 0.11% 4.25% 0.00% 15.35% 0.02%
Targa Resources Corp TRGP 223.155 114.06 25,453.06 0.08% 2.63% 0.00% 9.00% 0.01%
Bunge Global SA BG 141.595 101.76 14,408.71 2.60% -8.30%
LKQ Corp LKQ 266.776 43.13 11,506.05 2.78%
Deckers Outdoor Corp DECK 25.668 818.47 21,008.49 0.07% 19.98% 0.01%
Zoetis Inc ZTS 456.947 159.24 72,764.24 0.23% 1.09% 0.00% 10.10% 0.02%
Equinix Inc EQIX 94.905 711.11 67,487.89 0.21% 2.40% 0.01% 12.49% 0.03%
Digital Realty Trust Inc DLR 311.608 138.78 43,244.96 0.14% 3.52% 0.00% 4.80% 0.01%
Molina Healthcare Inc MOH 59 342.1 20,183.90 0.06% 11.72% 0.01%
Las Vegas Sands Corp LVS 745.047 44.36 33,050.28 1.80%
Notes:
[1]Equals sum of Col.[9]
[2]Equals sum of Col.[11]
[3]Equals([1]x(1+(0.5 x[2])))+[2]
[4]Bloomberg Professional as of April 30,2024
[5]Bloomberg Professional as of April 30,2024
[6]Equals[4]x[5]
[7]Equals weight in S&P 500 based on market capitalization[6]if Growth Rate>0%and<20%
[8]Source:Bloomberg Professional,as of April 30,2024
[9]Equals[7]x[8]
[10]Value Line,as of April 30,2024
[11]Equals[7]x[10]

Case No. PAC-E-24-04
Exhibit No. 11
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Risk Premium Approach
May 2024

Rocky Mountain Power
Exhibit No.11 Page 1 of 4
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
BOND YIELD PLUS RISK PREMIUM
Ill [2] [3]
Average
Authorized VI U.S.Govt.30- Risk
Quarter Electric ROE year Treasury Premium
1980.1 13.97% 11.39% 2.58%
1980.2 14.25% 10.52% 3.73%
1980.3 14.30% 10.85% 3.45%
1980.4 14.32% 12.10% 2.23%
1981.1 14.82% 12.53% 2.28%
1981.2 15.05% 13.24% 1.81%
1981.3 15.31% 14.13% 1.17%
1981.4 15.59% 13.85% 1.74%
1982.1 15.71% 13.96% 1.75%
1982.2 15.60% 13.52% 2.08%
1982.3 15.85% 12.79% 3.06%
1982.4 16.03% 10.75% 5.28%
1983.1 15.54% 10.71% 4.83%
1983.2 15.13% 10.65% 4.48%
1983.3 15.39% 11.62% 3.77%
1983.4 15.37% 11.74% 3.63%
1984.1 15.06% 12.04% 3.02%
1984.2 15.18% 13.18% 2.00%
1984.3 15.38% 12.69% 2.69%
1984.4 15.69% 11.70% 3.99%
1985.1 15.48% 11.58% 3.90%
1985.2 15.27% 11.00% 4.27%
1985.3 14.84% 10.55% 4.29%
1985.4 15.11% 10.04% 5.07%
1986.1 14.42% 8.77% 5.65%
1986.2 14.27% 7.49% 6.78%
1986.3 13.26% 7.40% 5.86%
1986.4 13.52% 7.53% 5.99%
1987.1 12.90% 7.49% 5.40%
1987.2 13.17% 8.53% 4.64%
1987.3 13.14% 9.06% 4.08%
1987.4 12.76% 9.23% 3.53%
1988.1 12.74% 8.63% 4.11%
1988.2 12.70% 9.06% 3.63%
1988.3 12.78% 9.18% 3.60%
1988.4 12.97% 8.97% 4.00%
1989.1 13.02% 9.04% 3.99%
1989.2 13.22% 8.70% 4.52%
1989.3 12.38% 8.12% 4.26%
1989.4 12.83% 7.93% 4.90%
1990.1 12.62% 8.44% 4.19%
1990.2 12.85% 8.65% 4.20%
1990.3 12.54% 8.79% 3.75%
1990.4 12.68% 8.56% 4.12%
1991.1 12.66% 8.20% 4.46%
1991.2 12.67% 8.31% 4.36%
1991.3 12.49% 8.19% 4.30%
1991.4 12.42% 7.85% 4.57%
1992.1 12.38% 7.81% 4.58%
1992.2 11.83% 7.90% 3.93%
1992.3 12.03% 7.45% 4.59%
1992.4 12.14% 7.52% 4.62%
1993.1 11.84% 7.07% 4.76%
1993.2 11.64% 6.86% 4.78%
1993.3 11.15% 6.32% 4.84%
1993.4 11.04% 6.14% 4.91%
1994.1 11.07% 6.58% 4.49%
1994.2 11.13% 7.36% 3.77%

Rocky Mountain Power
Exhibit No.11 Page 2 of 4
Case No.PAC-E-24-04
1994.3 12.75% 7.59% 5.16% Witness:Ann E.Bulldey
1994.4 11.24% 7.96% 3.28%
1995.1 11.96% 7.63% 4.33%
1995.2 11.32% 6.94% 4.37%
1995.3 11.37% 6.72% 4.65%
1995.4 11.58% 6.24% 5.35%
1996.1 11.46% 6.29% 5.17%
1996.2 11.46% 6.92% 4.54%
1996.3 10.70% 6.97% 3.73%
1996.4 11.56% 6.62% 4.94%
1997.1 11.08% 6.82% 4.26%
1997.2 11.62% 6.94% 4.68%
1997.3 12.00% 6.53% 5.47%
1997.4 11.06% 6.15% 4.91%
1998.1 11.31% 5.88% 5.43%
1998.2 12.20% 5.85% 6.35%
1998.3 11.65% 5.48% 6.17%
1998.4 12.30% 5.11% 7.19%
1999.1 10.40% 5.37% 5.03%
1999.2 10.94% 5.80% 5.14%
1999.3 10.75% 6.04% 4.71%
1999.4 11.10% 6.26% 4.84%
2000.1 11.21% 6.30% 4.92%
2000.2 11.00% 5.98% 5.02%
2000.3 11.68% 5.79% 5.89%
2000.4 12.50% 5.69% 6.81%
2001.1 11.38% 5.45% 5.93%
2001.2 11.00% 5.70% 5.30%
2001.3 10.76% 5.53% 5.23%
2001.4 11.99% 5.30% 6.69%
2002.1 10.05% 5.52% 4.53%
2002.2 11.41% 5.62% 5.79%
2002.3 11.65% 5.09% 6.56%
2002.4 11.57% 4.93% 6.63%
2003.1 11.72% 4.85% 6.87%
2003.2 11.16% 4.60% 6.56%
2003.3 10.50% 5.11% 5.39%
2003.4 11.34% 5.11% 6.23%
2004.1 11.00% 4.88% 6.12%
2004.2 10.64% 5.34% 5.30%
2004.3 10.75% 5.11% 5.64%
2004.4 11.24% 4.93% 6.31%
2005.1 10.63% 4.71% 5.92%
2005.2 10.31% 4.47% 5.84%
2005.3 11.08% 4.42% 6.66%
2005.4 10.63% 4.65% 5.98%
2006.1 10.70% 4.63% 6.07%
2006.2 10.79% 5.14% 5.64%
2006.3 10.35% 5.00% 5.35%
2006.4 10.65% 4.74% 5.91%
2007.1 10.59% 4.80% 5.79%
2007.2 10.33% 4.99% 5.34%
2007.3 10.40% 4.95% 5.45%
2007.4 10.65% 4.61% 6.04%
2008.1 10.62% 4.41% 6.21%
2008.2 10.54% 4.57% 5.96%
2008.3 10.43% 4.45% 5.98%
2008.4 10.39% 3.64% 6.74%
2009.1 10.75% 3.44% 7.31%
2009.2 10.75% 4.17% 6.58%
2009.3 10.50% 4.32% 6.18%
2009.4 10.59% 4.34% 6.25%

Rocky Mountain Power
Exhibit No.11 Page 3 of 4
Case No.PAC-E-24-04
2010.1 10.59% 4.62% 5.97% Witness:Ann E.Bulldey
2010.2 10.18% 4.37% 5.81%
2010.3 10.40% 3.86% 6.55%
2010.4 10.38% 4.17% 6.20%
2011.1 10.09% 4.56% 5.53%
2011.2 10.26% 4.34% 5.92%
2011.3 10.57% 3.70% 6.88%
2011.4 10.39% 3.04% 7.35%
2012.1 10.30% 3.14% 7.17%
2012.2 9.95% 2.94% 7.01%
2012.3 9.90% 2.74% 7.16%
2012.4 10.16% 2.86% 7.30%
2013.1 9.85% 3.13% 6.72%
2013.2 9.86% 3.14% 6.72%
2013.3 10.12% 3.71% 6.41%
2013.4 9.97% 3.79% 6.18%
2014.1 9.86% 3.69% 6.16%
2014.2 10.10% 3.44% 6.66%
2014.3 9.90% 3.27% 6.63%
2014.4 9.94% 2.96% 6.98%
2015.1 9.64% 2.55% 7.08%
2015.2 9.83% 2.88% 6.94%
2015.3 9.40% 2.96% 6.44%
2015.4 9.86% 2.96% 6.90%
2016.1 9.70% 2.72% 6.98%
2016.2 9.48% 2.57% 6.91%
2016.3 9.74% 2.28% 7.46%
2016.4 9.83% 2.83% 7.00%
2017.1 9.72% 3.05% 6.67%
2017.2 9.64% 2.90% 6.75%
2017.3 10.00% 2.82% 7.18%
2017.4 9.91% 2.82% 7.09%
2018.1 9.69% 3.02% 6.66%
2018.2 9.75% 3.09% 6.66%
2018.3 9.69% 3.06% 6.63%
2018.4 9.52% 3.27% 6.25%
2019.1 9.72% 3.01% 6.70%
2019.2 9.58% 2.78% 6.79%
2019.3 9.53% 2.29% 7.25%
2019.4 9.89% 2.26% 7.63%
2020.1 9.72% 1.89% 7.83%
2020.2 9.58% 1.38% 8.19%
2020.3 9.30% 1.37% 7.93%
2020.4 9.56% 1.62% 7.94%
2021.1 9.45% 2.07% 7.38%
2021.2 9.47% 2.26% 7.21%
2021.3 9.27% 1.93% 7.34%
2021.4 9.69% 1.95% 7.74%
2022.1 9.45% 2.25% 7.20%
2022.2 9.50% 3.05% 6.45%
2022.3 9.14% 3.26% 5.88%
2022.4 9.94% 3.89% 6.04%
2023.1 9.72% 3.75% 5.97%
2023.2 9.67% 3.81% 5.86%
2023.3 9.79% 4.23% 5.55%
2023.4 9.85% 4.58% 5.27%
2024.1 9.67% 4.32% 5.35%
2024.2 9.90% 4.66% 5.24%
AVERAGE 11.51% 6.06% 5.45%
MEDIAN 11.02% 5.32% 5.64%

Rocky Mountain Power
Exhibit No.11 Page 4 of 4
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
8.50% -
♦� y=-0.431x+0.0806
7.50% RZ=0.8452
♦♦
j ♦♦N
6.50% ♦♦ ♦ ♦
Lz 5.50% ♦♦♦ �♦
a4.50% ♦ ♦ ♦♦ ♦♦ ♦
3.50% ♦ ♦ ♦ ♦M
2.50%
1.50%
♦ N
0.50%
1.00% 3.00% 5.00% 7.00% 9.00% 11.00% 13.00% 15.00%
U.S.Government 30-year Treasury Yield
SUMMARY OUTPUT
Regression Statistics
Multiple R 0.9193448
R Square 0.8451949
Adjusted R Square 0.8443153
Standard Error 0.0056521
Observations 178
ANOVA
df SS MS F Significance F
Regression 1 0.03070 0.03070 960.91360 0.00000
Residual 176 0.00562 0.00003
Total 177 0.03632
Coefficients Standard Error t Stat P-value Lower 95% Upper 95% Lower 95.0% Upper 95.0%
Intercept 0.0806 0.00 85.42 0.0000 0.0787 0.0825 0.0787 0.0825
U.S.Govt.30-year Treasury (0.4310) 0.01 (31.00) 0.0000 (0.4584) (0.4035) (0.4584) (0.4035)
[7] [8] [9]
U.S.Govt.
30-year Risk
Treasury Premium ROE
Current 30-day average of 30-year U.S.Treasury bond yield[4] 4.59% 6.08% 10.67%
Blue Chip Near-Term Projected Forecast(Q3 2024-Q3 2025)[5] 4.32% 6.20% 10.52%
Blue Chip Long-Term Projected Forecast(2025-2029)[6] 4.10% 6.29% 10.39%
AVERAGE 10.53%
Notes:
[1]Source:Regulatory Research Associates,rate cases through April 30,2024
[2]S&P Capital IQ Pro,quarterly bond yields are the average of each trading day in the quarter
[3]Equals Column[1]-Column[2]
[4]Source:S&P Capital IQ Pro,30-day average as of April 30,2024
[5]Source:Blue Chip Financial Forecasts,Vol.43,No.5,May 1,2024,at 2
[6]Source:Blue Chip Financial Forecasts,Vol.42,No.12,December 1,2023,at 14
[7]See notes[4],[5]&[6]
[8]Equals 0.079161+(-0.431626 x Column[7])
[9]Equals Column[7]+Column[8]

Case No. PAC-E-24-04
Exhibit No. 12
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Wildfire Risk Analysis
May 2024

Rocky Mountain Power
Exhibit No.12 Page 1 of 1
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
COMPARISON OF OG&E AND PROXY GROUP COMPANIES
WILDFIRE EXPECTED ANNUAL LOSS RANKINGS
[1] [2]
Wildfire Risk
Ultimate Parent Jurisdiction Rank Numeric Rank
RRA Commission Ranking
ALLETE,Inc. Minnesota Relatively Low 2 Legend
Alliant Energy Corporation Iowa Very Low I Description Value
Wisconsin Very Low 1 Very High 5
Ameren Corporation Illinois Very Low 1 Relatively High 4
Missouri Relatively Low 2 Relatively Moderate 3
American Electric Power Company,Inc. Arkansas Relatively Low 2 Relatively Low 2
Indiana Very Low 1 Very Low 1
Kentucky Relatively Low 2
Louisiana Relatively Low 2
Michigan Very Low 1
Ohio Very Low 1
Oklahoma Relatively Moderate 3
Tennessee Very Low I
Texas Relatively High 4
Virginia Relatively Low 2
West Virginia Very Low 1
Avista Corporation Alaska Relatively Low 2
Idaho Relatively Moderate 3
Oregon Relatively Moderate 3
Washington Relatively Moderate 3
CMS Energy Corporation Michigan Very Low I
Duke Energy Corporation Florida Relatively High 4
Indiana Very Low 1
Kentucky Relatively Low 2
North Carolina Relatively Low 2
Ohio Very Low 1
South Carolina Relatively Low 2
Tennessee Very Low I
Entergy Corporation Arkansas Relatively Low 2
Louisiana Relatively Low 2
Mississippi Relatively Low 2
Texas Relatively High 4
Kansas Relatively Low 2
Evergy,Inc. Missouri Relatively Low 2
Idaho Relatively Moderate 3
IDACORP,Inc. Oregon Relatively Moderate 3
Florida Relatively High 4
NextEra Energy,Inc. Texas Relatively High 4
Montana Relatively Moderate 3
NorthWestern Corporation Nebraska Very Low 1
South Dakota Relatively Low 2
Arkansas Relatively Low 2
OGE Energy Corporation Oklahoma Relatively Moderate 3
Arizona Relatively High 4
Pinnacle West Capital Corporation Oregon Relatively Moderate 3
Portland General Electric Company Alabama Very Low 1
Southern Company Georgia Relatively Low 2
Illinois Very Low I
Mississippi Relatively Low 2
Tennessee Very Low I
Virginia Relatively Low 2
Colorado Relatively Moderate 3
Xcel Energy Inc. Minnesota Relatively Low 2
New Mexico Relatively Moderate 3
North Dakota Relatively Low 2
South Dakota Relatively Low 2
Texas Relatively High 4
Wisconsin Very Low 1
Proxy Group Average Relatively Low 2.14
PacifiCorp Idaho Relatively Moderate 3
Notes
[1]FEMA National Risk Index,States and Territories-Expected Annual Loss(Table);
hftps://hazards.fema.gov/nri/data-resources#csvDownload
[2]Very Low=1,Relatively Low=2,Relatively Moderate=3,Relatively High=4,Very High=5

Case No. PAC-E-24-04
Exhibit No. 13
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Capital Expenditures Analysis
May 2024

Rocky Mountain Power
Exhibit No.13 Page 1 of 3
Case No.PAC-E-24-04
PROJECTED CAPITAL EXPENDITURES AS A PERCENT OF 2023 NET PLANT witness:Ann E.Bulkley
($Millions)
[1] [2] [3] [4] [5] [6] [7]
Projected
Cap.Ex./
2023
2023 2024 2025 2026 2027 2028 Net Plant Rank
ALLETE,Inc. ALE
Capital Spending per Share $5.95 $6.20 $6.73 $7.25 $7.25
Common Shares Outstanding 59.00 59.00 $60.00 61.00 61.00
Capital Expenditures $351.1 $365.8 $403.5 $442.3 $442.3 40.0% 1
Net Plant $5,013.0
Alliant Energy Corporation LNT
Capital Spending per Share $5.80 $5.60 $5.50 $5.40 $5.40
Common Shares Outstanding 256.70 256.70 $256.85 257.00 257.00
Capital Expenditures $1,488.9 $1,437.5 $1,412.7 $1,387.8 $1,387.8 41.5% 3
Net Plant $17,157.0
Ameren Corporation AEE
Capital Spending per Share $12.55 $12.80 $12.90 $13.00 $13.00
Common Shares Outstanding 269.00 272.00 $278.50 285.00 285.00
Capital Expenditures $3,376.0 $3,481.6 $3,592.7 $3,705.0 $3,705.0 54.0% 12
Net Plant $33,050.0
American Electric Power Company AEP
Capital Spending per Share $14.15 $14.10 $14.05 $14.00 $14.00
Common Shares Outstanding 530.00 535.00 $542.50 550.00 550.00
Capital Expenditures $7,499.5 $7,543.5 $7,622.1 $7,700.0 $7,700.0 51.0% 7
Net Plant $74,600.0
Avista Corporation AVA
Capital Spending per Share $6.95 $7.15 $7.33 $7.50 $7.50
Common Shares Outstanding 79.00 81.00 $83.00 85.00 85.00
Capital Expenditures $549.1 $579.2 $608.0 $637.5 $637.5 52.8% 9
Net Plant $5,700.1
CMS Energy Corporation CMS
Capital Spending per Share $9.00 $9.80 $9.78 $9.75 $9.75
Common Shares Outstanding 295.00 295.50 $297.75 300.00 300.00
Capital Expenditures $2,655.0 $2,895.9 $2,910.5 $2,925.0 $2,925.0 57.1% 13
Net Plant $25,072.0
Duke Energy Corporation DUK
Capital Spending per Share $17.60 $17.75 $17.25 $16.75 $16.75
Common Shares Outstanding 770.00 770.00 $770.00 770.00 770.00
Capital Expenditures $13,552.0 $13,667.5 $13,282.5 $12,897.5 $12,897.5 53.3% 11
Net Plant $124,375.0
Entergy Corporation ETR
Capital Spending per Share $21.00 $22.00 $20.88 $19.75 $19.75
Common Shares Outstanding 218.00 222.00 $226.00 230.00 230.00
Capital Expenditures $4,578.0 $4,884.0 $4,717.8 $4,542.5 $4,542.5 53.1% 10
Net Plant $43,834.0
Evergy,Inc. EVRG
Capital Spending per Share $9.25 $9.30 $9.40 $9.50 $9.50
Common Shares Outstanding 230.00 230.00 $230.00 230.00 230.00
Capital Expenditures $2,127.5 $2,139.0 $2,162.0 $2,185.0 $2,185.0 46.6% 6
Net Plant $23,150.0
IDACORP,Inc. IDA
Capital Spending per Share $17.00 $14.00 $13.00 $12.00 $12.00
Common Shares Outstanding 51.00 51.50 $52.25 53.00 53.00
Capital Expenditures $867.0 $721.0 $679.3 $636.0 $636.0 61.6% 15
Net Plant $5,745.2

Rocky Mountain Power
Exhibit No.13 Page 2 of 3
Case No.PAC-E-24-04
[1] [2] [3] [4] [5] [6] �7tJtress:Ann E.Bulkley
Projected
Cap.Ex./
2023
2023 2024 2025 2026 2027 2028 Net Plant Rank
NextEra Energy,Inc. NEE
Capital Spending per Share $9.35 $9.20 $9.23 $9.25 $9.25
Common Shares Outstanding 2,055.00 2,065.00 $2,107.50 2,150.00 2,150.00
Capital Expenditures $19,214.3 $18,998.0 $19,441.7 $19,887.5 $19,887.5 77.5% 18
Net Plant $125,776.0
NorthWestem Corporation NWE
Capital Spending per Share $8.15 $8.15 $8.20 $8.25 $8.25
Common Shares Outstanding 61.50 62.00 $63.00 64.00 64.00
Capital Expenditures $501.2 $505.3 $516.6 $528.0 $528.0 42.7% 4
Net Plant $6,039.8
OGE Energy Corporation OGE
Capital Spending per Share $4.75 $4.75 $4.75 $4.75 $4.75
Common Shares Outstanding 200.20 200.20 $200.20 200.20 200.20
Capital Expenditures $951.0 $951.0 $951.0 $951.0 $951.0 43.9% 5
Net Plant $10,830.0
Pinnacle West Capital Corporation PNW
Capital Spending per Share $16.80 $16.80 $17.00 $17.20 $17.20
Common Shares Outstanding 116.00 119.00 $122.00 125.00 125.00
Capital Expenditures $1,948.8 $1,999.2 $2,074.0 $2,150.0 $2,150.0 57.4% 14
Net Plant $17,980.0
Portland General Electric Company POR
Capital Spending per Share $12.90 $11.75 $11.38 $11.00 $11.00
Common Shares Outstanding 101.50 102.00 $104.00 106.00 106.00
Capital Expenditures $1,309.4 $1,198.5 $1,183.0 $1,166.0 $1,166.0 63.1% 16
Net Plant $9,546.0
Southern Company SO
Capital Spending per Share $7.85 $7.75 $7.63 $7.50 $7.50
Common Shares Outstanding 1,070.00 1,070.00 $1,070.00 1,070.00 1,070.00
Capital Expenditures $8,399.5 $8,292.5 $8,158.8 $8,025.0 $8,025.0 41.2% 2
Net Plant $99,350.0
Xcel Energy Inc. XEL
Capital Spending per Share $13.25 $16.40 $14.03 $11.65 $11.65
Common Shares Outstanding 560.00 565.00 $572.50 580.00 580.00
Capital Expenditures $7,420.0 $9,266.0 $8,029.3 $6,757.0 $6,757.0 74.0% 17
Net Plant $51,642.0
PacifiCorp PacificCorp
Capital Expenditures[8] $3,214.00 $2,814.00 $3,119.00 $2,656.00 $2,306.00 52.2% 8
Net Rate Base[9] $27,051.0
Notes:
[1]-[6]Value Line,dated February 9,2024,March 8,2024,and April 19,2024
[7]Equals(Column[2]+[3]+[4]+[5]+[6])/ Column[1]
[8]Company Provided Data
[9]Company Provided Data

Rocky Mountain Power
Exhibit No.13 Page 3 of 3
Case No.PAC-E-24-04
PROJECTED CAPITAL EXPENDITURES AS A PERCENT OF 2023 NET PLANT Witness:Ann E.Bulkley
90%
80%
70% Proxy Group Median=53.1%
60%
————— — — — — — — — — — —— — — — — — — — — — —
50%
40%
30%
20%
10%
0%
Pv� CIO ��� �y�`� 000 �J�� P�Q 4GocQ PJP ��Q OJT P�� 00 1#
Projected CAPEX/2022 Net Plant
Rank Company Percent
1 ALLETE,Inc. ALE 40.0%
2 Southern Company SO 41.2%
3 Alliant Energy Corporation LNT 41.5%
4 NorthWestern Corporation NWE 42.7%
5 OGE Energy Corporation OGE 43.9%
6 Evergy,Inc. EVRG 46.6%
7 American Electric Power Company AEP 51.0%
8 PacifiCorp PacificCorp 52.2%
9 Avista Corporation AVA 52.8%
10 Entergy Corporation ETR 53.1%
11 Duke Energy Corporation DUK 53.3%
12 Ameren Corporation AEE 54.0%
13 CMS Energy Corporation CMS 57.1%
14 Pinnacle West Capital Corporation PNW 57.4%
15 IDACORP,Inc. IDA 61.6%
16 Portland General Electric Company POR 63.1%
17 Xcel Energy Inc. XEL 74.0%
18 NextEra Energy,Inc. NEE 77.5%
Proxy Group Median 53.1%
Pacificorp as%of Median 0.98
Notes:
Exhibit No.X,pp. 1-2 col.[7]

Case No. PAC-E-24-04
Exhibit No. 14
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Regulatory Risk Analysis
May 2024

Rocky Mountain Power
Exhibit No.l4 Page 1 of 2
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
COMPARISON OF
REGULATORY RISK ASSESSMENT
Ill [2] [3] [4] [5] [6] h1 181 191 [10]
Decoupling/Revenue Stabilization Capital Cost Recovery
Proxy Group Company Operating Subsidiary Jurisdiction Service Test Year Revenue Formula-Based Straight Traditional Renewables/Non-
Delivery Environmental
Decoupling Rates Fixed- Total Generation Traditional Infrastructure Compliance Total
V.r nhlo C-—th-
ALLETE,Inc. ALLETE(Minnesota Power) Minnesota Electric Fully Forecast No No No No No Yes No No Yes
Alliant Energy Corporation Interstate Power&Light Co. Iowa Electric Historical No No No No No Yes No Yes Yes
Interstate Power&Light Co. Iowa Gas Historical No No No No No No No No No
Wisconsin Power&Light Co. Wisconsin Electric Fully Forecast No No No No No No No No No
Wisconsin Power&Light Co. Wisconsin Gas Fully Forecast No No No No No No No No No
Ameren Corporation Ameren Illinois Co. Illinois Electric Historical Partial Yes No Yes No Yes No Yes Yes
Ameren Illinois Co. Illinois Gas Fully Forecast Partial No No Yes No No Yes Yes Yes
Union Electric Co. Missouri Electric Historical Partial No No Yes No Yes Yes No Yes
Union Electric Co. Missouri Gas Historical Partial No No Yes No No Yes No Yes
American Electric Power Company,Inc. Southwestern Electric Power Co. Arkansas Electric Historical Partial Yes No Yes Yes No No Yes Yes
Indiana Michigan Power Co. Indiana Electric Fully Forecast Full No No Yes No Yes Yes Yes Yes
Kentucky Power Co. Kentucky Electric Fully Forecast Partial No No Yes No No Yes No Yes
Southwestern Electric Power Co. Louisiana Electric Historical Partial Yes No Yes No No No No No
Indiana Michigan Power Co. Michigan Electric Fully Forecast Partial No No Yes No Yes No No Yes
Ohio Power Co. Ohio Electric Partially Forecast Partial No No Yes No Yes Yes No Yes
Public Service Co.of Oklahoma Oklahoma Electric Historical Partial No No Yes No Yes Yes No Yes
Kingsport Power Co. Tennessee Electric Fully Forecast No No No No No No No No No
AEP Texas Inc. Texas Electric Historical No No No No No No Yes No Yes
Southwestern Electric Power Co. Texas Electric Historical No No No No No No Yes No Yes
Appalachian Power Co. Virginia Electric Historical No No No No Yes No No Yes Yes
Appalachian Power Co./Wheeling Power Co. West Virginia Electric Historical No No No No No No No Yes Yes
Avista Corporation Alaska Electric Light&Power Co. Alaska Electric Historical No No No No No No No No No
Avista Corp. Idaho Electric Historical Full No No Yes No No No No No
Avista Corp. Idaho Gas Historical Full No No Yes No No No No No
Avista Corp. Oregon Gas Fully Forecast Partial No No Yes No No No No No
Avista Corp. Washington Electric Historical Full No No Yes No No No No No
Avista Corp. Washington Gas Historical Full No No Yes No No No No No
CMS Energy Corporation Consumers Energy Co. Michigan Electric Fully Forecast No No No No No Yes No No Yes
Consumers Energy Co. Michigan Gas Fully Forecast Partial No No Yes No No No No No
Duke Energy Corporation Duke Energy Florida LLC Florida Electric Fully Forecast No No No No Yes Yes No Yes Yes
Duke Energy Indiana LLC Indiana Electric Historical Partial No No Yes No Yes Yes Yes Yes
Duke Energy Kentucky Inc. Kentucky Electric Fully Forecast Partial No No Yes No No No Yes Yes
Duke Energy Kentucky Inc. Kentucky Gas Fully Forecast Partial No No Yes No No Yes No Yes
Duke Energy Carolinas LLC/Duke Energy Progress LLC North Carolina Electric Historical No No No No No Yes No Yes Yes
Piedmont Natural Gas Co.Inc. North Carolina Gas Historical Full No No Yes No No Yes No Yes
Duke Energy Ohio Inc. Ohio Electric Partially Forecast Partial No No Yes No Yes Yes No Yes
Duke Energy Ohio Inc. Ohio Gas Partially Forecast No No Yes Yes No No Yes Yes Yes
Duke Energy Carolinas LLC/Duke Energy Progress LLC South Carolina Electric Historical No No No No No Yes No Yes Yes
Piedmont Natural Gas Co.Inc. South Carolina Gas Historical Partial No No Yes No No No No No
Piedmont Natural Gas Co.Inc. Tennessee Gas Fully Forecast Partial No No Yes No No Yes No Yes
Entergy,Corporation Entergy Arkansas LLC Arkansas Electric Fully Forecast Partial Yes No Yes Yes Yes Yes No Yes
Entergy New Orleans LLC Louisiana-NOCC Electric Partially Forecast No Yes No Yes No Yes No Yes Yes
Entergy New Orleans LLC Louisiana-NOCC Gas Partially Forecast No Yes No Yes No No No No No
Entergy Louisiana LLC Louisiana Electric Historical Partial Yes No Yes No No No Yes Yes
Entergy Louisiana LLC Louisiana Gas Historical No Yes No Yes No No Yes No Yes
Entergy Mississippi LLC Mississippi Electric Fully Forecast Partial Yes No Yes No No No No No
Entergy Texas Inc. Texas Electric Historical No No No No Yes No Yes No Yes
Evergy,Inc. Evergy Kansas Central Inc Kansas Electric Historical Partial No No Yes No Yes No Yes Yes
Evergy Metro Inc. Kansas Electric Historical No No No No No No Yes No Yes
Evergy Metro Inc Missouri Electric Historical Partial No No Yes No No Yes No Yes
Evergy Missouri West Inc. Missouri Electric Historical Partial No No Yes No Yes Yes No Yes
IDACORP,hic. Idaho Power Co. Idaho Electric Partially Forecast Full No No Yes No No No No No
Idaho Power Co. Oregon Electric Partially Forecast No No No No No No No No No
NextEra Energy,Inc. Florida Power&Light Co. Florida Electric Fully Forecast No No No No Yes Yes No Yes Yes
Pivotal Utility Holdings Inc. Florida Gas Fully Forecast No No No No No No Yes Yes Yes
Lone Star Transmission LLC Texas Electric Historical No No No No No No Yes No Yes

Rocky Mountain Power
Exhibit No.l4 Page 2 of 2
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
Ill [2] [3] [4] [5] [6] [7] [8] [9] [10]
Decoupling/Revenue Stabilization Capital Cost Recovery
Renewables Non-
Proxy Group Company Operating Subsidiary Jurisdiction Service Teat Year Revenue Formula-Based Straight Traditional Delivery Environmental
Decoupling Rates Fixed- Total Generation Traditional Infrastructure Compliance Total
Vnri nhle G-erntinn
NorthWestem r Corporation NorthWeste Corporation Montana Electric Historical No No No No No No No No No
NorthWestem Corporation Montana Gas Historical No No No No No No No No No
NorthWestem Corporation Nebraska Gas Historical No No No No No No No No No
NorthWestem Corporation South Dakota Electric Historical No No No No No No No No No
NorthWestem Corporation South Dakota Gas Historical No No No No No No No No No
DOE Energy Corporation Oklahoma Gas&Electric Arkansas Electric Historical Partial No Yes Yes No No Yes No Yes
Oklahoma Gas&Electric Oklahoma Electric Historical Partial No Yes Yes No No Yes Yes Yes
Pinnacle West Capital Corporation Arizona Public Service Co. Arizona Electric Historical Partial No No Yes No Yes No Yes Yes
Portland General Electric Company Portland General Electric Co. Oregon Electric Fully Forecast No No No No Yes Yes No Yes Yes
Southern Company Alabama Power Co. Alabama Electric Historical No Yes No Yes Yes Yes No Yes Yes
Atlanta Gas Light Co. Georgia Electric Fully Forecast No Yes No Yes No No Yes Yes Yes
Georgia Power Co. Georgia Gas Fully Forecast No Yes Yes Yes Yes No No Yes Yes
Northern Illinois Gas Co. Illinois Gas Fully Forecast Partial No No Yes No No Yes Yes Yes
Mississippi Power Co. Mississippi Electric Fully Forecast Partial Yes No Yes No No No Yes Yes
Chattanooga Gas Co. Tennessee Gas Historical Partial Yes No Yes No No No No No
Virginia Natural Gas Inc. Virginia Gas Historical Partial No No Yes No No Yes No Yes
Xcel Energy Inc. Public Service Co.of Colorado Colorado Electric Historical Partial No No Yes No Yes No No Yes
Public Service Co.of Colorado Colorado Gas Historical Partial No No Yes No No Yes No Yes
Northern States Power Co.-Minnesota Minnesota Electric Fully Forecast Partial Yes No Yes No Yes No Yes Yes
Northern States Power Co.-Minnesota Minnesota Gas Fully Forecast No No No No No No Yes No Yes
Southwestern Public Service Co. New Mexico Electric Historical No No No No No Yes No No Yes
Northern States Power Co.-Minnesota North Dakota Electric Fully Forecast No No No No No Yes Yes No Yes
Northern States Power Co:Minnesota North Dakota Gas Fully Forecast No No Yes Yes No No No No No
Northern States Power Co.-Minnesota South Dakota Electric Historical Partial No No Yes Yes No Yes Yes Yes
Southwestern Public Service Co. Texas Electric Historical No No No No No No No No No
Northern States Power Co.-Wisconsin Wisconsin Electric Fully Forecast No No No No No No No No No
Northern States Power Co.-Wisconsin Wisconsin Gas Fully Forecast No No No No No No No No No
Proxy Group Average Fully Forecast 30 Yes 50 Yes 56
Partially Forecast 7 No 33 No 27
Historical 46
%with Form of %with Form of
%with Historical Test Year: 55.4% Revenue Stabilization 60.2% Capital Cost Recovery 67.5%
PacifiCorp(Idaho)[l l] Historical No No No No Yes Yes No Yes Yes
Notes:
[1]Regulatory Research Associates,effective as of February 29,2024.
[2]S&P Global Market Intelligence,Regulatory Focus:Adjustment Clauses,dated July 18,2022.Operating subsidiaries not covered in this report were excluded from this exhibit.
[3]Company Form 10-K,Company Tariffs,S&P Capital IQ Pro
[4]S&P Global Market Intelligence,Regulatory Focus:Adjustment Clauses,dated July 18,2022.
[5]Equals IF(AND([2]=No,[3]=No,[4]=No),No,Yes)
[6]-[9]S&P Global Market Intelligence,Regulatory Focus:Adjustment Clauses,dated July 18,2022.
[10]Equals IF(AND([6]=No,[7]=No,[8]=No,[9]=No),No,Yes)
[11]Company Provided Data.

Case No. PAC-E-24-04
Exhibit No. 15
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
RRA Ranking Analysis
May 2024

Rocky Mountain Power
Exhibit No.15 Page 1 of 1
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
COMPARISON OF
RRA JURISDICTIONAL RANKINGS
[1] [2]
RRA
Ultimate Parent Company Jurisdiction Rank Numeric Rank
RRA Commission Ranking
ALLETE,Inc. Minnesota Average/2 5 Legend
Alliant Energy Corporation Iowa Above Average/3 3 Description Value
Wisconsin Above Average/3 3 Below Average/3 9
Ameren Corporation Illinois Average/3 6 Below Average/2 8
Missouri Average/3 6 Below Average/1 7
American Electric Power Company,Inc.Arkansas Average/1 4 Average/3 6
Indiana Average/1 4 Average/2 5
Kentucky Average/2 5 Average/1 4
Louisiana(PSC) Average/2 5 Above Average/3 3
Michigan Above Average/3 3 Above Average/2 2
Ohio Average/2 5 lAbove Average/1 1
Oklahoma Average/3 6
Tennessee Above Average/3 3
Texas(PUC) Average/3 6
Virginia Average/1 4
West Virginia Below Average/1 7
Avista Corporation Alaska Below Average/1 7
Idaho Average/2 5
Oregon Average/2 5
Washington Average/3 6
CMS Michigan Above Average/3 3
Duke Energy Corporation Florida Above Average/2 2
Indiana Average/1 4
Kentucky Average/2 5
North Carolina Above Average/3 3
Ohio Average/2 5
South Carolina Average/3 6
Tennessee Above Average/3 3
Entergy Corporation Arkansas Average/1 4
Louisiana(NOCC) Average/3 6
Louisiana(PSC) Average/2 5
Mississippi Above Average/3 3
Texas(RRC) Average/1 4
Evergy,Inc. Kansas Below Average/1 7
Missouri Average/3 6
IDACORP,Inc. Idaho Average/2 5
Oregon Average/2 5
NextEra Energy,Inc. Florida Above Average/2 2
Texas(RRC) Average/1 4
NorthWestern Corporation Montana Below Average/1 7
Nebraska Average/1 4
South Dakota Average/2 5
OGE Energy Corporation Arkansas Average/1 4
Oklahoma Average/3 6
Pinnacle West Capital Corporation Arizona Below Average/3 9
Portland General Electric Company Oregon Average/2 5
Southern Company Alabama Above Average/1 1
Georgia Above Average/2 2
Illinois Average/3 6
Mississippi Above Average/3 3
Tennessee Above Average/3 3
Virginia Average/1 4
Xcel Energy Inc. Colorado Average/1 4
Minnesota Average/2 5
New Mexico Below Average/1 7
North Dakota Average/1 4
South Dakota Average/2 5
Texas(RRC) Average/1 4
Wisconsin Above Average/3 3
Proxy Group Average Average 1-
4.59
Average/2
PacifiCorp Idaho Average/2 5
Notes
[1]State Regulatory Evaluations,Regulatory Research Associates,March 1,2024.
[2]AA/l=1,AA/2=2,AA/3=3,A/1=4,A/2=5,A/3=6,BA/l=7,BA/2=8,BA/3=9

Case No. PAC-E-24-04
Exhibit No. 16
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
S&P Credit Supportiveness Ranking Analysis
May 2024

Rocky Mountain Power
Exhibit No.16 Page 1 of 1
Case No.PAC-E-24-04
Witness:Ann E.Bulkley
COMPARISON OF
S&P JURISDICTIONAL RANKINGS
[1] [2]
S&P
Ultimate Parent Company Jurisdiction Rank Numeric Rank
ALLETE,Inc. Minnesota Highly credit supportive 2 S&P Ranking Legend
Alliant Energy Corporation Iowa Most credit supportive 1 Description Value
Wisconsin Most credit supportive 1 Most credit supportive 1
Ameren Corporation Illinois Very credit supportive 3 Highly credit supportive 2
Missouri Very credit supportive 3 Very credit supportive 3
American Electric Power Company,Inc. Arkansas Highly credit supportive 2 More credit supportive 4
Indiana Highly credit supportive 2 Credit supportive 5
Kentucky Most credit supportive 1
Louisiana Highly credit supportive 2
Michigan Most credit supportive 1
Ohio Very credit supportive 3
Oklahoma Very credit supportive 3
Tennessee Highly credit supportive 2
Texas Very credit supportive 3
Virginia Highly credit supportive 2
West Virginia Very credit supportive 3
Avista Corporation Alaska More credit supportive 4
Idaho Very credit supportive 3
Oregon More credit supportive 4
Washington Very credit supportive 3
CMS Michigan Most credit supportive 1
Duke Energy Corporation Florida Most credit supportive 1
Indiana Highly credit supportive 2
Kentucky Most credit supportive 1
North Carolina Highly credit supportive 2
Ohio Very credit supportive 3
South Carolina More credit supportive 4
Tennessee Highly credit supportive 2
Entergy Corporation Arkansas Highly credit supportive 2
Louisiana Highly credit supportive 2
Mississippi Very credit supportive 3
Texas(RRC) Highly credit supportive 2
Kansas Highly credit supportive 2
Evergy,Inc. Missouri Very credit supportive 3
Idaho Very credit supportive 3
IDACORP,Inc. Oregon More credit supportive 4
Florida Most credit supportive 1
NextEra Energy,Inc. Texas(RRC) Highly credit supportive 2
Montana More credit supportive 4
NorthWestem Corporation Nebraska Very credit supportive 3
South Dakota Very credit supportive 3
Arkansas Highly credit supportive 2
OGE Energy Corporation Oklahoma Very credit supportive 3
Arizona More credit supportive 4
Pinnacle West Capital Corporation Oregon More credit supportive 4
Portland General Electric Company Alabama Most credit supportive 1
Southern Company Georgia Highly credit supportive 2
Illinois Very credit supportive 3
Mississippi Very credit supportive 3
Tennessee Highly credit supportive 2
Virginia Highly credit supportive 2
Colorado Very credit supportive 3
Xcel Energy Inc. Minnesota Highly credit supportive 2
New Mexico Credit supportive 5
North Dakota Highly credit supportive 2
South Dakota Very credit supportive 3
Texas(RRC) Highly credit supportive 2
Wisconsin Most credit supportive 1
Proxy Group Average Highly credit supportive- 2.45
Very credit supportive
PacifiCorp Idaho Very credit supportive 3
Notes
(itobal Ratings,"North American Utility Regulatory Jurisdictions Update:Ontario Remains
Unchanged,Notable Developments Elsewhere,"March 11,2024.
[2]Most Credit Supp.=1,Highly Credit Supp.=2,Very Credit Supp.=3,More Credit Supp.=4,Credit Supp.=5

Case No. PAC-E-24-04
Exhibit No. 17
Witness : Ann E . Bulkley
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Ann E. Bulkley
Capital Structure Analysis
May 2024

Rocky Mountain Power
Exhibit No. 17 Page 1 of 1
Case No.PAC-E-24-04
CAPITAL STRUCTURE ANALYSIS Witness:Ann E.Bulkley
Most Recent 8 Quarters(2022Q1 -2023Q4)
Common Long-Term Preferred
Equity Debt Equity Total
Proxy Group Company Ticker Ratio Ratio Ratio Capitalization
ALLETE,Inc. ALE 60.20% 39.80% 0.00% 100.00%
Alliant Energy Corporation LNT 52.23% 47.77% 0.00% 100.00%
Ameren Corporation AEE 53.26% 46.19% 0.55% 100.00%
American Electric Power Company,Inc. AEP 48.17% 51.83% 0.00% 100.00%
Avista Corporation AVA 49.60% 50.40% 0.00% 100.00%
CMS Energy Corporation CMS 50.95% 48.87% 0.19% 100.00%
Duke Energy Corporation DUK 52.61% 47.39% 0.00% 100.00%
Entergy Corporation ETR 48.56% 51.34% 0.10% 100.00%
Evergy,Inc. EVRG 61.11% 38.89% 0.00% 100.00%
IDACORP,Inc. IDA 52.26% 47.74% 0.00% 100.00%
MGE Energy,Inc. MGEE 60.38% 39.62% 0.00% 100.00%
NextEra Energy,Inc. NEE 60.28% 39.72% 0.00% 100.00%
NorthWestern Corporation NWE 49.94% 50.06% 0.00% 100.00%
OGE Energy Corporation OGE 54.02% 45.98% 0.00% 100.00%
Otter Tail Corporation OTTR 55.04% 44.96% 0.00% 100.00%
Pinnacle West Capital Corporation PNW 50.68% 49.32% 0.00% 100.00%
Portland General Electric Company POR 45.77% 54.23% 0.00% 100.00%
Southern Company SO 55.70% 44.17% 0.13% 100.00%
Xcel Energy Inc. XEL 54.41% 45.59% 0.00% 100.00%
Average 53.43% 46.52% 0.05%
Median 52.61% 47.39% 0.00%
Maximum 61.11% 54.23% 0.55%
Minimum 45.77% 38.89% 0.00%
Notes:
[1]Ratios are weighted by actual common capital,preferred capital,and long-term debt of the operating subsidiaries.
[2]Electric operating subsidiaries with data listed as N/A from S&P Capital IQ Pro have been excluded from the analysis.