20240812Bayer to PAC 57-74 4th Set.pdf

Thomas J. Budge, ISB No. 7465 RECEIVED
RACINE OLSON, PLLP Monday, August 12, 2024
P.O. Box 1391; 201 E. Center St. IDAHO PUBLIC
UTILITIES COMMISSION
Pocatello, Idaho 83204-1391
[phone]
[e-mail]
Attorneys for P4 Production, L.L.C., an affiliate of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR CASE NO. PAC-E-24-04
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AND BAYER'S THIRD SET OF
APPROVAL OF PROPOSED ELECTRIC DISCOVERY REQUESTS TO
SERVICE SCHEDULES AND ROCKY MOUNTAIN POWER
REGULATIONS
P4 Production, L.L.C., an affiliate of Bayer Corporation ("Bayer"), by and through
counsel, submits this first set of discovery requests to Rocky Mountain Power("RMP")pursuant
to rules 221-225 of the Commission's Rules of Procedure, IDAPA 31.01.01.
These discovery requests are to be considered continuing; therefore, RMP should
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that are responsive to these requests.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please identify the name,job title, location, and telephone
number of the record holder. Please provide all Excel and other electronic files on a thumb drive
or via email or other electric communication with formulas intact and activated.
DISCOVERY REQUESTS
Request No. 57: To the extent not already provided, please provide all tables, figures,
schedules, exhibits, charts, and graphs supporting the testimony of Ms. Ann Bulkley and Nikki
Kobliha in executable electronic format with all formulas and links intact.
Request No.58: Please provide copies of all credit reports published by Standard&Poor's
("S&P"), Moody's and Fitch Ratings for the Company and its parent, issued over the last two
years. This is an ongoing request.
BAYER'S FOURTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER I

Request No. 59: Please provide complete copies of all credit reports issued by S&P,
Moody's and Fitch Ratings over the last two years that discuss the current regulated utility industry
as reviewed by any Company witness. If Company witnesses have not reviewed the material,
please so state. This is an ongoing request.
Request No. 60: Please provide copies of all correspondence, presentations and all other
materials that Company or its parent company provided to credit and equity analysts over the last
two years. This is an ongoing request.
Request No. 61: Please provide a projection of Company's capital expenditures out over
the next five years, and an estimate of the sources of cash available to fund these capital
expenditures broken out by external debt markets, external equity infusions from its parent
company, retained earnings, depreciation expense, deferred taxes and other sources (explain).
Please also include in this response the funding planned for debt maturity, retirements and/or
refinancing over this same time period.
Request No. 62: In electronic format with all formulas intact, please provide the monthly
average balances for construction work in progress and short-term debt for the most recent 13-
month period and the test year.
Request No. 63: Please provide the amount of capitalized interest estimated to be paid
during the test year related to construction projects for the test year.
Request No. 64: In electronic format with all formulas intact,please provide the five-year
projected and five-year historical capital structure,capital expenditures and capital funding. Please
include a breakdown of all sources of equity capital including retained earnings, paid-in capital,
and debt capital,both long-term and short-term debt, etc.
Request No. 65: In electronic format with all formulas intact, please identify the
Commission approved capital structure, authorized ROE, and overall rate of return in Company's
last three regulatory proceedings. Please identify the docket and order numbers.
Request No. 66: Please describe how the Company accesses external capital. If the
Company's external capital is provided by its parent or some other related company under a credit
agreement,please describe the terms of the credit agreement and the associated service fees.
Request No. 67: Please provide the most recent senior secured, unsecured and corporate
credit ratings of Company,assigned by S&P,Moody's and Fitch. Also,please provide Company's
S&P business and financial risk profiles and identify the benchmark volatility table (standard,
medial or low)used by S&P.
Request No. 68: To the extent not already provided, please provide in electronic format
with all formulas intact, Company's credit metric calculations relied on by S&P and Moody's for
the last five years and near-term projections if available. Please include all financial statements
used to derive these credit metrics. In addition, please provide S&P and Moody's benchmark
ranges for the credit metrics.
BAYER'S FOURTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2

Request No. 69: Please state whether Company's regulated retail operations have any off
balance sheet debt such as operating leases as categorized by S&P. If the answer is "yes,"provide
the amount of each off-balance sheet debt item and estimate the related imputed interest and
amortization expense associated with these off-balance sheet debt equivalents specific to
Company's jurisdictional regulated retail operations. If available, please provide this information
for the test year.
Request No. 70: Please provide the jurisdictional allocation for each of the Company's
jurisdictions for all balance sheet and income statement adjustments S&P makes in assessing the
Company's credit metrics.
Request No. 71: In electronic format with all formulas intact, please provide the
Company's jurisdictional statement of operating income at present and proposed rates for the test
year.
Request No. 72: Please describe the impact, if any, the ratings downgrades have had on
the Company's embedded cost of debt.
Request No. 73: Please describe the Company's embedded cost of debt immediately
before the ratings downgrades.
Request No. 74: What is Ms. Kobliha's estimate of the impact on the Company's cost of
debt as a result of the ratings downgrades already realized? Please provide a detailed explanation
and all workpapers with formulas intact supporting her estimate.
DATED this 121h day of August, 2024.
RACINE OLSON, PLLP
By....j--- -
THOMAS J. BUDGE tf�57—�
BAYER'S FOURTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 121h day of August, 2024, I caused a true and correct
copy of the above and foregoing document to be served via email to the following persons:
Idaho Public Utilities Commission Idaho Irrigation Pumpers Association
Commission Secretary Eric L. Olsen
P.O. Box 83720 ECHO HAWK& OLSEN, PLLC
Boise, ID 83720-0074 elogechohawk.com
secretary�ic,puc.idaho.gov
Lance Kaufman, Ph.D.
Adam Triplett lanceAae isg insi hg t.com
Deputy Attorney General
Idaho Public Utilities Commission PIIC
adam.triplettkpuc.idaho.gov Ronald L. Williams
Brandon Helgeson
Bayer: HAWLEY TROA-ELL
Brian C. Collins rwilliams(&,,hawleytroxell.com
Greg Meyer bhel e�(&�hawleytroxell.com
Brubaker&Associates
bcollins(kconsultbai.com Bradley Mullins
gmeyer(d),consultbai.com MW Analytics
brmullinskmwanaltyics.com
Kevin Higgins
Neal Townsend PIIC Electronic Service Only:
Energy Strategies LLC Val Steiner: Val.Steinergitafos.com
khiggins(kenergystrat.com Kyle Williams: williamskkbyui.edu
ntownsend(d),energystrat.com
Idaho Conservation League
PacifiCorp Matthew Nykiel
Data Request Response Center Attorney for Idaho Conservation League
datarequest(d),pacificorp.com matthew.n. k elAgmail.com
Mark Alder Brad Heusinkveld
Idaho Regulatory Affairs Manager Idaho Conservation League
mark.alder(d),pacificorp.com Regulatory Counsel
beusinkveld(&,idahoconservation.org
Joe Dallas
Senior Attorney
Rocky Mountain Power
joseph.dallas(kpacificorp.com
THOMAS J. BUDGE
BAYER'S FOURTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 4