20240830PAC to PIIC 19_24.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116

August 30, 2024

Ronald L. Williams
Brandon Helgeson
Attorneys For PIIC
[e-mail] (C)
[e-mail] (C)

Bradley Mullins
[e-mail] (C)

Val Steiner
[e-mail]

Kyle Williams
[e-mail]

RE: ID PAC -E-24-04
PIIC Set 1 (1-28)

Please find enclosed Rocky Mountain Power’s Responses to PIIC 1st Set Data Requests 19 and
24. Also provided are Attachments PIIC 19-1 and 19-3. Provided via BOX are Confidential
Attachments PIIC 10-2, 24-1, 24-2 and 24-3. Confidential information is provided subject to
protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities
Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and
further subject to the non-disclosure agreement (NDA) executed in this proceeding.

If you have any questions, please feel free to call me at [phone].

Sincerely,

____/s/____
Mark Alder
Manager, Regulation

Enclosures
C.c.: Monica Barrios-Sanchez/IPUC [e-mail] (C)
[e-mail]
Eric L. Olsen/IIPA [e-mail] (C)
Lance Kaufman/IIPA [e-mail] (C)
Matthew Nykiel/ICL [e-mail]
RECEIVED
Friday, August 30, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Brad Heusinkveld/ICL [e-mail]
Thomas J. Budge/Bayer [e-mail] (C)
Brian C. Collins/Bayer [e-mail]
Greg Meyer/Bayer [e-mail]
Kevin Higgins/Bayer [e-mail] (C)
Neal Townsend/Bayer [e-mail] (C)

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
PIIC Data Request 19

PIIC Data Request 19

Reference McCoy work paper “4.1 - Miscellaneous General Expense and
Revenue,” Tab “4.1.1:”

(a) Please provide an explanation for the item titled “Credit facility fees”.

(b) Please provide work papers supporting the adjustment of $2,431,425 with
respect to Credit facility fees, including details of each debt instrument, the
balance as of December 31, 2023, the total amount drawable, and the
expiration.

(c) Are the Credit facility fees annual charges or a one-time charge in connection
with a debt instrument. Please explain.

(d) Please explain why Credit facility fees are not already included in
PacifiCorp’s results of operations.

(e) Please provide an explanation of how Credit facility fees are considered under
FERC accounting rules.

(f) Please provide any correspondence between PacifiCorp and FERC regarding
the FERC accounting for Credit facility fees.

(g) Please identify all amounts in excess of $10 million drawn from a credit
facility over the period January 1, 2020 through July 31, 2024 and describe
the purpose for the withdrawal.

Response to PIIC Data Request 19

(a) PacifiCorp’s written agreement establishing commercial paper program
arrangements with lending institutions, for short-term liquidity demands, specifies
the requirement to have a current credit facility arrangement in place to participate
(b) Please refer to Attachment PIIC 19-1 which provides transaction details
associated with the credit facility fee in the base period. Please refer to
Confidential Attachment PIIC 19-2 which provides details on the credit facilities.

(c) Commitment fees are ongoing fees for the credit facility. The credit facility
agreement is renewed each year. The costs of the agreement are deferred and then
amortized over the life of the agreement in accordance with United States (U.S.)
generally accepted accounting principles (GAAP).
(d) These fees were previously included for recovery in the calculation of Allowance
for Funds Used During Construction (AFUDC), however, due to a Federal Energy
PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
PIIC Data Request 19

Regulatory Commission (FERC) audit it was determined these fees should not be
included in the calculation of AFUDC. Accordingly, the Company now books this
fees to FERC Account 431, interest expense. Since interest expense is normalized
in the calculation of a test period and these fees are not otherwise included in the
Company’s capital structure, an adjustment is made to move these fees to FERC
Account 921. This is consistent with the Company’s adjustment used in the
previous Idaho general rate case (GRC).

(e) Please refer to the Company’s response to subpart (d) above.

(f) Please refer to Attachment PIIC 19-3 which provides a copy of the 2017 FERC
audit report that references credit facility fees.

(g) Credit Facility Borrowing from January 1, 2020 through July 31, 2024:

March 13 - 24, 2020 $700M Cash liquidity in the event borrowing unavailable due to COVID
December 14, 2023 - January 5, 2024 $400M Capital spend; paid off with long term debt borrowing
December 19, 2023 - January 5, 2024 $400M Capital spend; paid off with long term debt borrowing

Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Nicholas Highsmith / Zack Muth / Kristi Olsen

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
August 30, 2024
PIIC Data Request 24

PIIC Data Request 24

Reference McCoy work paper “4.5 - Generation Overhaul Expense”: Please
provide detail of generation overhaul expenses detailed by plant and outage over
the period January 1, 2020 through December 31, 2023, including the following
information:

(a) A description of the major maintenance performed.

(b) The duration of the maintenance activities.

(c) The total cost of the maintenance activities.

(d) Amounts covered under a long-term service agreement.

Response to PIIC Data Request 24

(a) Please refer to Confidential Attachment PIIC 24-1.

(b) Please refer to Confidential Attachment PIIC 24-2.

(c) For total overhaul expense by plant for the period 2020 through 2023, please
refer to McCoy work paper 4.5.2

(d) Please refer to Confidential Attachment PIIC 24-3.

Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Gavin Mangelson

Sponsor: Brad Richards

1
Joe Dallas (ISB# 10330)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: [e-mail]

Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF ROCKY
MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS
RATES AND CHARGES IN IDAHO
AND APPROVAL OF PROPOSED
ELECTRIC SERVICE SCHEDULES
AND REGULATIONS

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CASE NO. PAC-E-24-04

ATTORNEY’S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES

I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a
attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its response, is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code Section 74-101, et seq. and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the response to PacifiCorp Idaho Industrial Customers Data Request Nos. 19 and 24
contains Company proprietary information that could be used to its commercial disadvantage.

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