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Home My WebLink About20241114PAC to Bayer 110-113.pdf RECEIVED Thursday, November 14, 2024 IDAHO PUBLIC _ ROCKY MOUNTAIN UTILITIES COMMISSION POWER A DIVISION OF PACIFICORP 1407 W North Temple, Suite 330 Salt Lake City, Utah 84116 November 14, 2024 Thomas J. Budge ti(&racineolson.com(C) Brian C. Collins bcollins(&consultbai.com(C) Greg Meyer gmeyerkconsultbai.com(C) Kevin Higgins khiggins(c�r�,energystrat.com(C) Neal Townsend ntownsendkenergystrat.com(C) RE: ID PAC-E-24-04 Bayer Set 14 (110-113) Please find enclosed Rocky Mountain Power's Redacted Responses to Bayer's 14th Set Data Requests 110-113. Provided via BOX are Confidential Attachments Bayer 110, 112-1, 112-2 and 113 and Confidential Responses Bayer 110-113. 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(801)220-2313. 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 rwilliams(c�hawlevtroxell.com(C) Brandon Helgeson/PIIC bhelgeson(&hawleytroxell.com(C) Bradley Mullins/PIIC brmullinskmwanalytics.com(C) 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 November 14, 2024 Bayer Data Request 110 Bayer Data Request 110 CONFIDENTIAL RE UEST — Response to Bayer Data Request 110 (a) Energy Insurance Mutual (EIM) is a non-admitted mutually owned insurance company that provides excess liability coverage for PacifiCorp. EIM applies a loss premium assessment when the paid loss ratio for all policy terms exceeds 150 percent. EIM paid a full limit loss of$127.5 million for PacifiCorp's 2020 Labor Day weekend wildfires. The loss payment made by EIM resulted in the $24,510,981 loss premium assessment, which is endorsed on the policy. All insurance proceeds from EIM were paid to PacifiCorp, therefore, the premium assessment was assigned 100 percent to PacifiCorp. (b) Please refer to Confidential Attachment Bayer 110. This is endorsement number 10 of the EIM policy showing the total amount of$24,510,981 was paid to EIM. (c) No comparable expenses. For EIM specifically, the paid loss ratio for all policy terms did not exceed 150 percent. 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 November 14, 2024 Bayer Data Request 111 Bayer Data Request 111 S ENTIAL RE UEST — Response to Bayer Data Request 111 (a) Since the Company's response to Bayer Data Request 101, PacifiCorp did not purchase the insurance policy effective November 1, 2024. (b) Please refer to the Company's response to subpart(a) above. (c) The new annualized premium is $185.7 million. (d) Please refer to the Company's response to subpart(a) above. (e) Please refer to the Company's response to subpart(a) above. PAC-E-24-04/Rocky Mountain Power November 14, 2024 Bayer Data Request 111 Recordholder: Jill Mingles /Wendy Wallis/Aaron Starr Sponsor: Mariya Coleman PAC-E-24-04/Rocky Mountain Power November 14, 2024 Bayer Data Request 112 Bayer Data Request 112 CONFIDENTIAL RE UEST — Response to Bayer Data Request 112 Since the Company's response to Bayer Data Request 101, the total annualized premium for the policies finalized on or after August 15, 2024, is now $185.7 million. Please refer to Confidential Attachment Bayer 112-1 which provides an updated summary. Please refer to Confidential Attachment Bayer 112-2 which provides copies of the policy binders. 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 November 14, 2024 Bayer Data Request 113 Bayer Data Request 113 Response to Bayer Data Request 113 Please refer to Confidential Attachment Bayer 113 which provides copies of the policy binders. Please refer to the Company's response to Bayer Data Request 102, specifically Confidential Attachment Bayer 102 which provides a summary of policy limits. 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: 3 60-5 60-193 7 Email:joseph.dallas@pacificorp.com 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 14 contains Company proprietary information that could be used to its commercial disadvantage. 1 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 14th day of November, 2024. Respectfully submitted, By Joe Dallas Attorney Rocky Mountain Power 2