20241011Bayer 101-106 to PAC.pdf

RECEIVED
Friday, October 11, 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 TWELFTH 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 twelfth 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. 101: Excess Liability Insurance. Please refer to the Direct Testimony of
Shelley E. McCoy,p. 22. Please provide a breakdown, in Excel format with intact formulas, of
the estimated Total Company liability insurance premiums of$183.9 million. Please supplement
this response for any subsequent updates to RMP's liability insurance premiums provided during
the pendency of this case. For the breakdown, please include the following information:
a. Type of policy (e.g., Excess Liability, California Wildfire);
b. Insurance company;
BAYER'S TWELFTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER I

c. Policy Holder(e.g., PacifiCorp, Berkshire Hathaway Energy, );
d. Policy limit;
e. Coverage type (e.g., Third Party Liability Losses, etc.);
f. Self-Insured retention amount;
g. Total policy premium;
h. Premium allocated to PacifiCorp. If the premium is allocated to PacifiCorp from another
entity (e.g., Berkshire Hathaway Energy), describe in detail how the portion allocated to
PacifiCorp was determined.
i. Please provide, in Excel format with formulas intact, the derivation of each applicable
corporate allocation factor or cite to where this information has been previously provided.
j. Applicable taxes allocated to PacifiCorp.
Request No. 102: Excess Liability Insurance. Please refer to Exhibit No. 52, page 2 of
5. Please provide a breakdown, in Excel format with intact formulas, of the actual 2023 Total
Company liability insurance premiums of$122,577,486.
a. Type of policy (e.g., Excess Liability, California Wildfire);
b. Insurance company;
c. Policy Holder(e.g., PacifiCorp, Berkshire Hathaway Energy, );
d. Policy limit;
e. Coverage type (e.g., Third Party Liability Losses, etc.);
f. Self-Insured retention amount;
g. Total policy premium;
h. Premium allocated to PacifiCorp. If the premium is allocated to PacifiCorp from another
entity (e.g., Berkshire Hathaway Energy), describe in detail how the portion allocated to
PacifiCorp was determined.
i. Please provide, in Excel format with formulas intact, the derivation of each applicable
corporate allocation factor or cite to where this information has been previously provided.
j. Applicable taxes allocated to PacifiCorp.
Request No. 103: Excess Liability Insurance. Please provide the workpaper, in Excel
format,named,"8.15 Insurance Premium Deferral-ID GRC 2024 V2,"that is linked to"20240503
Exhibit No. 52."
Request No. 104: Excess Liability Insurance. Please refer to the Direct Testimony of
Mariya V. Coleman,page 5, regarding the allocation of excess liability premiums to PacifiCorp,
and the Direct Testimony of Joelle R. Steward,page 29, regarding the 2020 Labor Day fires.
a. Please provide a detailed breakdown of the loss history that is incorporated in the derivation
of the corporate allocation factors used to calculate the actual 2023 PacifiCorp liability
insurance premiums of $122.6 million and the estimated PacifiCorp liability insurance
premiums of$183.9 million. Please supplement this response for any subsequent updates
to the corporate excess liability allocation factors provided during the pendency of this
BAYER'S TWELFTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2

case. For the breakdown, please provide the loss amount associated with each specific fire
that is included in the allocation factor determination and the payment date.
b. Please provide the amount of losses incurred by PacifiCorp or its insurers associated with
each of the 2020 Labor Day fires to-date, and indicate whether each amount is included or
excluded in the determination of the corporate allocation factors and/or insurance
premiums.
Request No. 105: Wildfire Claims. Please provide information on all litigation against
PacifiCorp or its operating companies seeking damages for losses caused by wildfires that were
filed since January 1, 2019. Please include:
a. The specific fire with which the claim is associated.
b. The date the claim was filed.
c. The court in which the claim was filed.
d. The claim's docket number assigned by that court.
e. The requested relief including specific monetary damages.
f. The litigation's current status.
Request No. 106: Wildfire Claims. Please provide information on any settlement or
damages paid by PacifiCorp, its operating companies, or insurers on any claims made by
plaintiffs related to any wildfires occurring since January 1, 2019. Please include:
a. The specific fire with which the claim is associated.
b. The date the claim was settled/paid.
c. The settlement and/or damages amount paid.
d. The state and county where the plaintiffs claim the loss occurred.
DATED this 1 lth day of October, 2024.
RACINE OLSON, PLLP
By:
�—j --- -
THOMAS J. BUDGE
BAYER'S TWELFTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 1 lth 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
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.co77
THOMAS J. BUDGE
BAYER'S TWELFTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 4