20250109Comments in Support of Settlement Stipulation.pdf

RECEIVED
2025 January 9
IDAHO PUBLIC
Thomas J. Budge, ISB No. 7465 UTILITIES COMMISSION
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 COMMENTS OF BAYER IN
APPROVAL OF PROPOSED ELECTRIC SUPPORT OF SETTLEMENT
SERVICE SCHEDULES AND STIPULATION
REGULATIONS
P4 Production, L.L.C., an affiliate of Bayer Corporation (referred to herein as "Bayer"),
submits the following comments in support of the Settlement Stipulation.
Comments
Bayer supports adoption of the Settlement Stipulation and recommends its approval by
the Commission as a complete package. In preparing for this proceeding, Bayer engaged experts
and reviewed the Application filed by Rocky Mountain Power("RMP"), as well as RMP's direct
testimony, exhibits, and work papers. Bayer also conducted extensive discovery, reviewed the
discovery of other parties, and participated in each of the rounds of settlement discussions that
were conducted among the parties. In Bayer's view, the Settlement Stipulation produces a
reasonable outcome that is the result of serious negotiation and compromise among the
signatories.
In its Application, RMP proposed a base rate increase of$92.4 million, or 26.8%, over
two years. The Settlement Stipulation reduces this increase by $34.46 million to $57.94 million,
amounting to a 16.8% increase effective January 1, 2025, with no additional base rate increase
for 2026. In addition, the Settlement Stipulation extends the recovery period for deferred ECAM
balances, which has the near-term effect of reducing ECAM recovery by$32.5 million, which
will occur simultaneously with the base rate increase, resulting a net increase of$25.44 million,
or 7.4%.
COMMENTS OF BAYER IN SUPPORT OF SETTLEMENT STIPULATION 1

In reducing RMP's proposed rate increase by $34.46 million, the signatories agreed to a
reduction in the rate of return from 7.69%to 7.25% ($6.9 million), removal of RMP's request for
a catastrophic fire fund($11.1 million), reduction in net power costs ($8.46 million), removal of
suspended and cancelled plant additions ($0.7 million), and an unspecified downward adjustment
of$7.3 million. Based on Bayer's review and analysis, this combination of adjustments, while
different from what Bayer would have advocated in a litigated case, produces a reasonable result.
The Settlement Stipulation also provides that the rate spread will be established using the
Company's proposed class cost of service study, subject to a cap of 110 percent of the overall
average base rate increase with a floor of zero percent price change for all classes. The cap and
floor percentage allocations will be applied to the base rate increase prior to the application of
the Insurance Cost Adjustment(which is included in the Settlement Stipulation) and ECAM rate
changes. Bayer believes this rate spread produces a reasonable result in this case, in that it moves
incrementally in the direction of cost of service, while mitigating the rate impact on any one
class of customers in the interest of gradualism.
In conclusion, Bayer respectfully requests that the Commission approve the Settlement
Stipulation in its entirety and find that it is just, reasonable, and in the public interest.
DATED this 91h day of January, 2025.
RACINE OLSON, PLLP
THOMAS J. BUDGE
COMMENTS OF BAYER IN SUPPORT OF SETTLEMENT STIPULATION 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 91h day of January, 2025, 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
secretM(&,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 Adrian Gallo, Climate Manager
Idaho Regulatory Affairs Manager Brad Smith, Program Director
mark.alder(d),pacificorp.com Idaho Conservation League
Regulatory Counsel
Joe Dallas agallo(& idahoconservation.org
Senior Attorney bsmith(kidahoconservation.org
Rocky Mountain Power
joseph.dallas(4pacificorp.com
carla.scarsella(&,pacificorp.com
THOMAS J. BUDGE
COMMENTS OF BAYER IN SUPPORT OF SETTLEMENT STIPULATION 3