20241001Bayer 97-99 to Pac.pdf

RECEIVED
Tuesday, October 01, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Thomas J. Budge, ISB No. 7465
RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center St.
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 TENTH 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 tenth 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. 97: Insurance Expense. Has RMP conducted or commissioned an analysis
of the increases in the expense to obtain third-party insurance experienced by other utilities since
2018? If so, please provide a copy of the analysis.
Request No. 98: Insurance Expense. Has RMP conducted or commissioned an analysis
of the increases in the expense to obtain third-party insurance experienced by other utilities since
2018, specifically focusing on increases related to wildfire coverage? If so, please provide a copy
of the analysis.
BAYER'S TENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER I

Request No. 99: Excess Liability Insurance. Please refer to p. 5 in the direct testimony
of RMP witness Mariya Coleman, lines 19-24, in which Ms. Coleman states: "BHE's corporate
allocation calculates an average percentage of property,plant, and equipment; employee count;
loss history; overhead electric transmission and distribution lines; and transmission and
distribution pipeline miles." Please respond to the following:
a. Does BHE use the same corporate allocation for each type of insurance that BHE
acquires and allocates to its subsidiaries? If not,please explain how the allocations differ
for different types of insurance.
b. Please describe what weight the BHE corporate allocation gives to each allocation factor
identified in the referenced testimony.
c. For each of the corporate allocation factors listed in the referenced testimony,please
provide a spreadsheet showing the use of the factors to allocate insurance premium costs
to PacifiCorp for the years 2019 through 2024. In your response, please specify how
"loss history" impacted the calculation of the allocation and show in detail how the "loss
history" factor was calculated.
DATED this I"day of October, 2024.
RACINE OLSON, PLLP
By: / 9
THOMAS J. BUDGE
BAYER'S TENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this I st day of October, 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
secretarygpuc.Idaho.gov
Lance Kaufinan, Ph.D.
Adam Triplett lancegae_isg insi_hg t.com
Deputy Attorney General
Idaho Public Utilities Commission PIIC
adam.triplett(&,puc.idaho.gov Ronald L. Williams
Brandon Helgeson
Bayer: HA WLEY TROXELL
Brian C. Collins rwilliamsghawleytroxell.com
Greg Meyer bhel eg son(d),hawleytroxell.com
Brubaker&Associates
bcollins(d),consultbai.com Bradley Mullins
gmeyer(kconsultbai.com MW Analytics
brmullins(&,mwanaltyics.com
Kevin Higgins
Neal Townsend PIIC Electronic Service Only:
Energy Strategies LLC Val Steiner: Val.Steiner a,itafos.com
khiggins(&,energystrat.com Kyle Williams: williamskAbyui.edu
ntownsend(k energ_ystrat.com
Idaho Conservation League
PacifiCorp Matthew Nykiel
Data Request Response Center Attorney for Idaho Conservation League
datarequest(4 pacificorp.com matthew.n_ k�a gmail.com
Mark Alder Brad Heusinkveld
Idaho Regulatory Affairs Manager Idaho Conservation League
mark.alder(kpacificorp.com Regulatory Counsel
bheusinkveld(d),idahoconservation.org
Joe Dallas
Senior Attorney
Rocky Mountain Power
joseph.dallas(dpacificorp.com
THOMAS J. BUDGE
BAYER'S TENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3