20241017PAC to Staff 97-99.pdf

RECEIVED
Thursday, October 17,2024
IDAHO PUBLIC
_ ROCKY MOUNTAIN UTILITIES COMMISSION
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 17, 2024
Thomas J. Budge
ti(&racineolson.com(C)
Brian C. Collins bcollins(&consultbai.com
Greg Meyer gmeyerkconsultbai.com
Kevin Higgins khiggins(c�r�,energystrat.com(C)
Neal Townsend ntownsendkenergystrat.com(C)
RE: ID PAC-E-24-04
Bayer Set 10 (97-99)
Please find enclosed Rocky Mountain Power's Responses to Bayer's 10t' Set Data Requests 97-
99. Also provided is Attachment Bayer 97-2. Provided via BOX are Confidential Attachments
Bayer 97-1 and 99. 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.: Eric L. Olsen/IIPA elo(&echohawk.com(C)
Lance Kaufman/IIPA lancena,ae isg insi hg t�(C)
Matthew Nykiel/ICL matthew.nykielkiamail.com
Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org
Ronald L. Williams/PIIC rwilliamsghawlevtroxell.com
Brandon Helgeson/PIIC bhelfzeson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinsgrawanalytics.com
Val Steiner/PIIC val.steinerkitafos.com
Kyle Williams/PIIC williamskkbvui.edu
Monica Barrios-Sanchez/IPUC monica.barriossanchez(),puc.idaho.gov
S ecretary(a),puc.idaho.gov

PAC-E-24-04/Rocky Mountain Power
October 17, 2024
Bayer Data Request 97
Bayer Data Request 97
Request No. 97: Insurance Expense. Has RMP conducted or commissioned an
analysis of the increases in the expense to obtain third-parry insurance
experienced by other utilities since 2018? If so, please provide a copy of the
analysis.
Response to Bayer Data Request 97
Please refer to Confidential Attachment Bayer 97-1 which provides examples of
benchmarking data.
1. 2024 Howden Utility Client Benchmarking CONF
2. 2024 Marsh Utility Benchmarking-BHE-email CONF
3. 2024 Marsh Utility Benchmarking-BHE CONF
Please refer to Attachment Bayer 97-2. In addition to benchmarking, the
following public resources indicate the market trends:
1. 2024 Howden—A-Turning-Point
2. Alliant 2024 Start of Year Report—Insurance Marketplace Insights
3. Chubb 2024 Liability Limit Benchmark& Large Loss Profile Report
4. EIM Final Status Update Wildfire Coverage for Utilities in 2024
5. MMC 2024 Social-Inflation
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: Jill Mingles /Wendy Wallis/Aaron Starr
Sponsor: Mariya Coleman

PAC-E-24-04/Rocky Mountain Power
October 17, 2024
Bayer Data Request 98
Bayer Data Request 98
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.
Response to Bayer Data Request 98
Please refer to the Company's response to Bayer Data Request 97.
Wildfire insurance coverage expense is contemplated within the analysis of the
benchmarking data examples provided with the Company's response to Bayer
Data Request 97.
Please also refer to the direct testimony of Company witness, Frank Graves,
specifically the following exhibits:
• Exhibit No. 21.
• Exhibit No. 22.
Recordholder: Jill Mingles
Sponsor: Mariya Coleman

PAC-E-24-04/Rocky Mountain Power
October 17, 2024
Bayer Data Request 99
Bayer Data Request 99
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.
Response to Bayer Data Request 99
(a) Berkshire Hathaway Energy Company (BHE) allocations of the premiums are
based on reasonable and objective factors depending on the type of coverage
with several of the major types of policies listed below:
• Excess Liability excluding wildfire: property/plant/equipment, operating
revenue, number of employees, loss history, miles of overhead
transmission and distribution lines and miles of transmission and
distribution pipeline.
• Wildfire Liability: miles of overhead electric transmission and distribution
lines and miles of transmission and distribution pipeline. In California,
also consider high fire threat district (HFTD)versus non-HFTD.
• Property: total insurable values of each company's plants, substations and
offices.
• Worker's Compensation: employee salary and headcount by business.
• Fiduciary/Crime: employee count.

PAC-E-24-04/Rocky Mountain Power
October 17, 2024
Bayer Data Request 99
(b) Please refer to Confidential Attachment Bayer 99 which provides information
for calendar years 2020 through 2024. The Company can only provide the
2019 allocation percentages (shown below). Note: the Company did not retain
a copy of the supporting workbook for 2019.
AEGIS/EIM: 41.56 percent
All other utility: 34.61 percent
Punitive damages: 10 percent
California wildfire: 79.82 percent
(c) The loss history component is reflective of insurance proceeds received by
PacifiCorp divided by all insurance proceeds received by all companies
participating in the shared insurance over the last 20 years. Please refer to
Confidential Attachment Bayer 99 which provides information for calendar
years 2020 through 2024. Note: the Company did not retain a copy of the
supporting workbook for 2019.
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: Jill Mingles /Wendy Wallis /Aaron Starr
Sponsor: Mariya Coleman

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
CASE NO. PAC-E-24-04
IN THE MATTER OF THE )
APPLICATION OF ROCKY ) ATTORNEY'S CERTIFICATE
MOUNTAIN POWER FOR ) CLAIM OF CONFIDENTIALITY
AUTHORITY TO INCREASE ITS ) RELATING TO DISCOVERY
RATES AND CHARGES IN IDAHO ) RESPONSES
AND APPROVAL OF PROPOSED )
ELECTRIC SERVICE SCHEDULES )
AND REGULATIONS )
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
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
Bayer Set 10 contains Company proprietary information that could be used to its commercial
disadvantage.
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Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential information that the information contains Company proprietary information.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
Protective Agreement in this proceeding.
DATED this 17ffi day of October, 2024.
Respectfully submitted,
Y \ \ - \
B \�J)
Joe Dallas
Attorney
Rocky Mountain Power
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