20241025PAC to Bayer 101-106.pdf

RECEIVED
Friday, October 25, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 25, 2024
Thomas J. Budge
tina,racineolson.com(C)
Brian C. Collins bcollins(a,consultbai.com
Greg Meyer gmeyer(d),consultbai.com
Kevin Higgins khigginskenergystrat.com(C)
Neal Townsend ntownsend(a-,energystrat.com(C)
RE: ID PAC-E-24-04
Bayer Set 12 (101-106)
Please find enclosed Rocky Mountain Power's Responses to Bayer's 12th Set Data Requests 101-
106. Also provided is Attachment Bayer 103. Provided via BOX are Confidential Attachments
Bayer 101-1, 101-2, 102-1, 102-2 and 105. 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(a-,echohawk.com(C)
Lance Kaufman/IIPA lance(kae isg insi hg t�(C)
Matthew Nykiel/ICL matthew.nykielkjzmail.com
Brad Heusinkveld/ICL bheusinkveld(a),idahoconservation.org
Ronald L. Williams/PIIC rwilliams(a�hawleytroxell.com
Brandon Helgeson/PIIC bhel eg son(ahawle_ytroxell.com
Bradley Mullins/PIIC bnnullinskmwanalytics.com
Val Steiner/PIIC val.steiner(a,itafos.com
Kyle Williams/PIIC williamsk(a-,byui.edu
Monica Barrios-Sanchez/IPUC monica.barriossanchez(a)puc.idaho.gov
SecretM(kpuc.Idaho.gov

PAC-E-24-04/Rocky Mountain Power
October 25, 2024
Bayer Data Request 101
Bayer Data Request 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;
(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.
Response to Bayer Data Request 101
Please refer to the Company's response to subparts (a) through(h) and 0)below:
Please refer to Confidential Attachment Bayer 101-1 . The Company now
estimates that the annualized insurance premiums for the test period will be
approximately$189 million. This amount represents the annualized premium of
the policies that were finalized on or after August 15, 2024,which have an 18-
month term and an estimate of the policy Berkshire Hathaway Energy Company
(BHE) is renewing effective November 1, 2024.
(i) Please refer to Confidential Attachment Bayer 101-2 which provides the
calculation of the Company's allocations for the 2024-2026 renewal.
Allocations for other BHE affiliates are not included because they are not
included for recovery in this general rate case (GRC)proceeding.
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.

PAC-E-24-04/Rocky Mountain Power
October 25, 2024
Bayer Data Request 101
Recordholder: Jill Mingles/Wendy Wallis/Aaron Starr
Sponsor: Mariya Coleman

PAC-E-24-04/Rocky Mountain Power
October 25, 2024
Bayer Data Request 102
Bayer Data Request 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.
Response to Bayer Data Request 102
Please refer to the Company's response to subparts (a) through(h) and 0)below:
Please refer to Confidential Attachment Bayer 102-1.
(i) Please refer to Confidential Attachment Bayer 102-2 which provides the
calculation of the Company's allocations for the 2023-2024 renewal.
Allocations for other Berkshire Hathaway Energy Company(BHE) affiliates
are not included because they are not included for recovery in this general rate
case (GRC) proceeding.
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 25, 2024
Bayer Data Request 103
Bayer Data Request 103
Excess Liability Insurance -Please provide the work paper, in Excel format,
named, "8.15 Insurance Premium Deferral - ID GRC 2024 V2,"that is linked to
"20240503 Exhibit No. 52."
Response to Bayer Data Request 103
Please refer to Attachment Bayer 103 which provides a copy of file "8.15
Insurance Premium Deferral - ID GRC 2024 V2".
Recordholder: Laura Miller
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
October 25, 2024
Bayer Data Request 104
Bayer Data Request 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 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.
Response to Bayer Data Request 104
Please refer to the Company's response to Bayer Data Request 101, specifically
Confidential Attachment Bayer 101-2. Please also refer to the Company's
response to Bayer Data Request 102, specifically Confidential Attachment Bayer
102-2.
Please refer to tab "202x GL Loss Ratio" in each attachment. The insurance
recovery is used in the calculations and not PacifiCorp's incurred loss amount.
The insurance recovery is the compensation received from the insurance
companies for the wildfire damage covered under the insurance policies. The total
losses shown on tab "202x GL Loss Ratio" includes all of Berkshire Hathaway
Energy Company's (BHE)recoveries. Only those losses specific to the Company
are listed out because the losses that are not PacifiCorp are not included for
recovery.
Recordholder: Jill Mingles/Wendy Wallis/Aaron Starr
Sponsor: Mariya Coleman

PAC-E-24-04/Rocky Mountain Power
October 25, 2024
Bayer Data Request 105
Bayer Data Request 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.
Response to Bayer Data Request 105
PacifiCorp objects to the data request to the extent it seeks information that is
protected by attorney-client and/or attorney work product privileges. The
Company further objects to this data request to the extent it is overly broad and
unduly burdensome in seeking a compilation in a format not ordinarily
maintained by PacifiCorp. PacifiCorp objects to the extent that the term
"wildfires" is vague and ambiguous. PacifiCorp also objects to this data request to
the extent it requests information that is outside the scope of this proceeding.
Subject to and without waiving the foregoing objections, the Company responds
as follows:
Please refer to Confidential Attachment Bayer 105. With respect to subpart (e)
and"the requested relief including specific monetary damages", note that
PacifiCorp disputes the accuracy of amounts claimed as damages; PacifiCorp
includes in Confidential Attachment Bayer 105 claimed economic damages
(column F) and claimed non-economic damages (column G) where the complaint
includes such figures.
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: Counsel
Sponsor: Counsel

PAC-E-24-04/Rocky Mountain Power
October 25, 2024
Bayer Data Request 106
Bayer Data Request 10
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.
Response to Bayer Data Request 106
PacifiCorp objects to the data request to the extent that the request seeks
information obtained through mediation which is protected as confidential under
California and Oregon law. PacifiCorp objects to the data request to the extent it
seeks information that is protected by attorney-client and/or attorney work
product privileges. The Company further objects to this data request to the extent
it is overly broad and unduly burdensome. PacifiCorp also objects to this data
request to the extent it requests information that is outside the scope of this
proceeding. Subject to and without waiving the foregoing objections, the
Company responds as follows:
Please refer to the Notes to Financial Statements of PacifiCorp, specifically in the
section under the heading "Estimated Losses for and Settlements Associated with
the Wildfires" for details related to the wildfire-related liabilities, which is in Note
14 of Notes to Financial Statements in PacifiCorp's Federal Energy Regulatory
Commission(FERC) Form No. 1 for the year ended December 31, 2023 including
the liabilities recorded at December 31, 2023, and in Note 9 of Notes to Financial
Statements in PacifiCorp's FERC Form 3-Q for the quarter ended June 30, 2024,
copies of which are publicly available and can be accessed by using the following
website link: https://www.brkenergy.com/investors/re_ulatory filin sg ?c=pc
Recordholder: Counsel
Sponsor: Counsel

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 )
1, 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 12 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 25th day of October, 2024.
Respectfully submitted,
By
Joe Dallas
Attorney
Rocky Mountain Power
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