20241031Bayer to PAC 110-113 (Redacted).pdf

RECEIVED
Thursday, October 31, 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 CONFIDENTIAL BAYER'S
APPROVAL OF PROPOSED ELECTRIC FOURTEENTH SET OF
SERVICE SCHEDULES AND DISCOVERY REQUESTS TO
REGULATIONS ROCKY MOUNTAIN POWER
(REDACTED)
P4 Production, L.L.C., an affiliate of Bayer Corporation("Bayer"),by and through
counsel, submits this fourteenth 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. 110: Liability Insurance- CONFIDENTIAL Follow-Up to RMP
Response to Bayer Data Request 101. In the CONFIDENTIAL Attachment Bayer 101-1,
RMP lists
a. Please define and provide a full description of it.
Why is it directly assigned to PacifiCorp?
CONFIDENTIAL BAYER'S FOURTEENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN
POWER(REDACTED) 1

b. Please provide any insurance policy documentation supporting
-amount included in the response to the referenced data request.
c. Please provide comparable amounts, if any, for each of the last four years that
were included in the PacifiCorp allocated share of insurance expenses. If there
was no comparable expense, please explain why there was no such expense for
these years.
Request No. 111: Liability Insurance- CONFIDENTIAL Follow-Up to RMP
Response to Bayer Data Request 101. In the CONFIDENTIAL Attachment Bayer 101-1,
RMP lists a
d. Please identify the policy associated with the
including the type of policy, insurance company and policy holder.
e. Was the cost of this premium directly assigned to PacifiCorp? If so,please
explain why. If not,please provide the derivation of the corporate allocation of
this item.
f. Has the actual premium for this item been determined? If so,please provide the
total actual cost and the amount allocated to PacifiCorp, on both a 15-month and
annualized basis. Please also provide an update of the annualized$189.2 million
[total PacifiCorp] cost including the actual cost for this item.
g. Please provide any insurance policy documentation for this item, including the
policy binders and endorsements. For each policy binder, please include a
summary of the policy including, but not limited to, policy limits, self-insurance
retention, policy exclusions, pre-existing event exclusions, requirements for
maintaining policy coverage, etc.
h. Please provide comparable amounts, if any, for each of the last four years that
were included in the PacifiCorp allocated share of insurance expenses. If there
was no comparable expense, please explain why there was no such expense for
these years.
Request No. 112: Liability Insurance-Follow-Up to RMP Response to Bayer Data
Request 101. Please provide the policy binders, including endorsements, for the requested test
year insurance amount(i.e., included in the annualized $189.2 million [total PacifiCorp] cost for
the policy period beginning August 15, 2024 as identified in RMP Response to Bayer Data
Request 101). For each policy binder,please include a summary of the policy including, but not
limited to, policy limits, self-insurance retention,policy exclusions, pre-existing event
exclusions, requirements for maintaining policy coverage, etc.
CONFIDENTIAL BAYER'S FOURTEENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN
POWER(REDACTED) 2

Request No. 113: Liability Insurance-Follow-Up to RMP Response to Bayer Data
Request 102. Please provide the policy binders, including endorsements, for the deferred
insurance amount(i.e., included in the $122.6 million [total Company] cost for the policy period
beginning August 15, 2023). For each policy binder, please include a summary of the policy
including, but not limited to,policy limits, self-insurance retention, policy exclusions, pre-
existing event exclusions, requirements for maintaining policy coverage, etc.
DATED this 31 st day of October, 2024.
RACINE OLSON, PLLP
By: /
THOMAS J. BUDGE
CONFIDENTIAL BAYER'S FOURTEENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN
POWER(REDACTED) 3

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 31"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@,pacificorp.com
carla.scarsella(&,pacificorp.com
THOMAS J. BUDGE
CONFIDENTIAL BAYER'S FOURTEENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN
POWER(REDACTED) 4