20240920Answer to Motion.pdf

RECEIVED
Friday, September 20, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
September 20, 2024
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
RE: CASE NO. PAC-E-24-04
IN THE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES AND CHARGES IN IDAHO
Attention: Commission Secretary
Pursuant to Rule 57.03 of the Rules of Procedure of the Idaho Public Utilities Commission and
staff of the Idaho Public Utilities Commission motion to suspend the effective date of new rates
dated September 13, 2024, please find Rocky Mountain Power's answer to staff s motion in the
above referenced matter.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313.
Very truly yours,
a,--D
Joe Steward
Senior Vice President, Regulation
Cc: Service List Case No. PAC-E-24-04

CERTIFICATE OF SERVICE
I hereby certify that on this day, I caused to be served, via email, a true and correct copy
of Answer to Motion to Suspend the Effective Date of New Rates in Case No. PAC-E-24-04 to
the following:
Service List
Commission Staff
Adam Triplett(C)
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A
Boise, ID 83720-0074
adam.triplett&puc.Idaho.gov
Idaho Irrigation Pumpers Association,Inc
Eric L. Olsen(C) Lance Kaufman, Ph.D. (C)
Echo Hawk& Olsen PLLC 2623 NW Bluebell Place
505 Pershing Ave., Suite 100 Corvallis, OR 97330
PO Box 6119 lancegae isg insi h
Pocatello, ID 83205
elo&echohawk.com
Idaho Conservation League
Matthew Nykiel Brad Heusinkveld
Idaho Conservation League Idaho Conservation League
710 N. 6tt,Street 710 N. 6tn Street
Boise, ID 83702 Boise, ID 83702
matthew.nykielgamail.com bheusinkveld(&idahoconservation.org
Bayer Corporation
Thomas J. Budge (C) Brian C. Collins (C)
Racine, Olson PLLP Greg Meyer(C)
201 E. Center Brubaker&Associates
Pocatello, ID 83204-1391 16690 Swingley Ridge Rd., #140
tj&racineolson.com Chesterfield, MO 63017
bcollinsgconsultbai.com
gme er&consultbai.com
Kevin Higgins (C)
Neal Townsend(C)
Energy Strategies LLC
khi ggins&energystrat.com
ntownsend&energystrat.com
Page 1 of 2

PacifiCorp Idaho Industrial Customers
Ronald L. Williams (C) Bradley Mullins (C)
Brandon Helgeson(C) MW Analytics
Hawley Troxell Ennis &Hawley LLP Teitotie 2, Suite 208
PO Box 1617 Oulunsalo Finland, FI 90460
Boise, ID 83701 brmullins@mwanal . ics.com
rwilliams(aD,hawleytroxell.com
bhel eg [e-mail]
Val Steiner Kyle Williams
Itafos Conda LLC BYU Idaho
val.steiner(a-)itafos.com [e-mail]
PacifiCor , dba Rocky Mountain Power
Mark Alder Joe Dallas
Michael Snow PacifiCorp/dba Rocky Mountain Power
PacifiCorp/dba Rocky Mountain Power 825 NE Multnomah Street, Suite 2000
1407 West North Temple, Suite 330 Portland, OR 97232
Salt Lake City,UT 84116 [e-mail]
mark.alder@pacificoi p.com
[e-mail]
Data Request Response Center
PacifiCorp
[e-mail]
Dated this 201h day of September, 2024.
Carrie Meyer
Adviser, Regulatory Operations
Page 2 of 2

Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallas(a�pacificorp.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN ) CASE NO. PAC-E-24-04
POWER'S APPLICATION FOR ) ROCKY MOUNTAIN POWER'S ANSWER
AUTHORITY TO INCREASE ITS RATES ) TO MOTION TO SUSPEND EFFECTIVE
AND CHARGES IN IDAHO ) DATE OF NEW RATES
Pursuant to Rule 57.03 of the Rules of Procedure of the Idaho Public Utilities Commission
("Commission"), Rocky Mountain Power a division of PacifiCorp (the "Company") hereby
respectfully submits its response to Commission Staff's September 13, 2024, Motion to Suspend
the Effective Date of New Rates ("Motion") in the above-referenced case.
I. BACKGROUND
1. On March 15, 2024,the Company filed a notice of intent to file a general rate case.
On May 31, 2024, the Company filed its application requesting authority to increase its retail rates
and approval of proposed changed to the Company's electric service schedule.
2. On July 17, 2024, the Commission issued a notice of parties with Commission
Staff, Bayer Corporation ("Bayer"), PacifiCorp Idaho Industrial Customers ("PIIC"), Idaho
Irrigation Pumpers Association ("IIPA"), and Idaho Conservation League ("ICL") cited as parties
in the case.
Rocky Mountain Power's Answer Page 1

3. On September 13,2024, Staff filed the Motion to suspend the effective date of new
rates for 60 days for good cause as defined in Idaho Code § 61-622.1 Staff advances two reasons
to establish why good cause exists to suspend the effective date: (1) delays in providing certain
responses to data requests on the part of the Company; and(2) claimed scheduling difficulties for
the technical conference in this proceeding.
II. COMPANY ANSWER
4. The Company appreciates the collaboration and good faith discussion with Staff
throughout this proceeding. However,the Commission should deny Staff's Motion to suspend the
effective date of new rates because good cause has not been shown. In addition, a delay to new
rates will result in financial harm to the Company. In the alternative, if granted, the Commission
should authorize the Company to record a regulatory asset for the delayed recovery of the final
authorized increase between the statutory suspension period and new rate effective date, from
January 1, 2025 to March 2, 2025.
i. Good Cause for Extension Not Shown
5. Staff supports their Motion by arguing that good cause is established in part by
delays in the Company's responses to discovery. The Company acknowledges that there were
delays in some of its responses to Staff's discovery requests.However,focusing solely on a limited
number of delays does not present a complete picture of the discovery process.From June 14,2024
to August 16, 2024, Staff submitted 11 sets of production requests to the Company, totaling of 208
requests, without counting subparts. With subparts, the Company was asked to respond to over
1,000 production requests from Staff alone without accounting for discovery from other
'Hereinafter("Staff Motion.").
Rocky Mountain Power's Answer Page 2

intervenors in this proceeding. The three-week period from August 9, 2024 to August 30, 2024,
just prior to Staff filing their Motion, was particularly challenging for the Company with 997
responses, counting subparts, due from Staff.' As Staff also explains in its motion, many data
requests sought expedited responses—totally 59 data requests with 353 subparts.3 During this
time, the Company had to request extensions for several responses to ensure adherence to
confidentiality controls and to provide complete and accurate answers.Additionally,the Company
made efforts to respond to as many subparts as possible on time, requesting extensions only for
those that required more time to complete.
6. In addition to the delay in discovery responses, Staff notes difficulties with the
Company's scheduling. The Company recognizes that it has had preferences for specific dates in
order to ensure its witnesses have availability and sufficient opportunity to prepare for a hearing.
The Company has responded to three suggested dates by Staff with ranked choices for the technical
hearing date, which should theoretically make the scheduling of the dates possible. The Company
never indicated that it could not make any of the three proposed dates work, and only
communicated there was a potential conflict with the proposed December 16-18 date for the
technical hearing. The Company understands that Staff is coordinating several dates with multiple
parties, as well as the Commission's schedule, and is sympathetic to the inherit challenge of the
process but the Company does not believe it should be financially penalized for the difficulties in
finding suitable dates for all parties.
2 Beginning on August 91,with IPUC set 9,Staff shortened the requested time for response from 3 weeks to 2 weeks.
To date, Staff has issued 14 Data Request Sets totally 256 data requests,not including subparts.
3 Staff Motion at fn.2(Sept. 13,2024).
Rocky Mountain Power's Answer Page 3

ii. The Company is Financially Harmed if Motion is Granted
7. Extending the effective date of the proceeding will result in financial harm to the
Company. Any delay in implementing new rates for investments prudently expended by the
Company will result in the Company not having a fair opportunity to earn its authorized return on
those investments in a timely manner. As shown on Attachment A, the Company estimates a
monthly cost of$2 million,or 27 basis points of return, for every month delay in the effective date.
A 60-day delay would result in nearly 60 basis points under-earning for the rate effective period in
this case. This is an important consideration for the Company in terms of liquidity for operations,
as well as maintaining its credit metrics, which directly impact its ability to secure favorable
interest rates on debt. Indeed,the Company has already suspended dividend payments from 2024-
28 to retain any earnings to support ongoing electric service operations and necessary capital
prof ects.4
8. The Company has worked cooperatively and in good faith with Staff to try to
establish a schedule and provide discovery in a timely manner. The Company appreciates Staff's
efforts. While the Company acknowledges there have been delays in providing some discovery
responses,limited availability of schedules or delayed responses to a certain number of production
requests does not constitute good cause.
9. Even though good cause has not been shown, the Commission may find otherwise
and grant Staff's Motion. The Company should be held neutral and not financially harmed given
the circumstances underlying Staff's request. Therefore, if the Commission grants the Motion,the
Company respectfully requests that it authorize the Company to record a regulatory asset for the
revenue requirement increase granted by the Commission in its final order in this case for the delay
4 See Direct Testimony of Nikki Kobliha at 12,23.
Rocky Mountain Power's Answer Page 4

period in implementing new rates beginning January 1, 2025 until new rates go into effect, i.e.,
March 2, 2025 if the 60-day extension is granted. Given that the complete financial impact to the
Company will not be known until the Commission issues an order with new rates, the final
regulatory asset balance is unknown. To calculate the regulatory asset balance, the Company will
determine the annual price increase associated with all net power cost("NPC") and non-net power
cost items. Since the Company is authorized recovery of NPC and other items such as production
tax credits through the Energy Cost Recovery Mechanism, only the 10 percent that is otherwise
subjected to a 90/10 sharing band will be deferred. Combining the financial impact of both the
non-NPC and NPC impacts, on an annual basis and equally dividing for the delayed period,would
be the final regulatory asset balance. Given the uncertainty in the amount, the Company would
seek recovery of this balance with the compliance filing in this case.
III. REQUEST FOR RELIEF
10. Based on the foregoing, the Company respectfully requests that the Commission
deny Staff's motion to suspend the effective date of new rates because good cause has not been
shown. However, if the Commission finds good cause to approve the motion, the Company
alternatively requests that the Commission issue an order authorizing the Company to record a
regulatory asset for the lost incremental revenues due to the delay in implementing new rates from
January 1,2025 to March 2, 2025. Based on the foregoing, it would be "fair,just, and reasonable"
to order the establishment of a deferral account if the Commission grants Staff's motion.5
5 See In the Matter of Application ofldaho Power Company, Case No. IPC-E-16-19, Order No. 33706 (January 31,
2017) ("Bade on our review of the record, we find it fair,just and reasonable to allow the Company to establish a
deferral account in which to track the incremental O&M expenses associated within joining the EIM, as described
further below.");see also In the Matter of Idaho Power Company's Application for An Accounting Order, Case No.
IPC-E-21-02,Order No. 35077 at 7(June 17,2021)("We find it reasonable to allow the Company to defer its Idaho
jurisdictional share of incremental wildfire insurance costs above 2019 levels.").
Rocky Mountain Power's Answer Page 5

DATED this 20th day of September 2024.
Respectfully submitted,
ROCKY MOUNTAIN POWER
Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallaskpacificorp.com
Attorney for Rocky Mountain Power
Rocky Mountain Power's Answer Page 6

ATTACHMENT A

Attachment A
Page 1 of 1
GRC Drivers from 2021 GRC Impacted by Delay Annual Impact Monthly Impact
Net Power Cost $ 50.1 Yes-ECAM Sharing Band $ 5.0 $ 0.4
Capital Investments $ 13.5 Yes $ 13.5 $ 1.1
Cat Fund $ 11.1 No-Separate Tariff Schedule $ - $ -
Insurance Cost Adjustment $ 9.8 No-Separate Tariff Schedule $ - $ -
Insurance Premium Deferral(3 Yrs.) $ 2.6 No-Separate Tariff Schedule $ - $ -
Other $ 5.3 Yes $ 5.3 $ 0.4
$ 92.4 $ 23.8 1 $ 2.0
100 Basis Points ROE $ 7.5 ROE Impact
Present Revenues $ 280.5 3.19% 0.27%
Present Revenues w/ECAM $ 345.4
Percentage Increase 26.8%
1AM Price Change $ 68.9