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Home My WebLink About20260317Application.pdf _ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330 POWER. Salt Lake City,UT 84116 A DIVISION OF PACIFICORP March 17, 2026 RECEIVED MARCH 17, 2026 VIA ELECTRONIC DELIVERY IDAHO PUBLIC UTILITIES COMMISSION Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd Building 8 Suite 201A Boise, ID 83714 RE: CASE NO. PAC-E-26-03 IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AN ORDER INCREASING AND EXTENDING THE SHORT-TERM DEBT AUTHORITIES FIVE YEARS Attention: Commission Secretary Please find for filing with the Idaho Public Utilities Commission Rocky Mountain Power's Application in the above referenced matter. Pursuant to Idaho Code § 61-905 please note that the Company's Application Fee in the amount of$1,000 is being submitted under separate cover. Informal questions related to this matter may be directed to Jana Saba, Director of Regulation at Jana.S aba(&,pacificorp.com. Sincerely, Joe Steward Senior Vice President, Regulation Joe Dallas (ISB# 10330) Rocky Mountain Power 825 NE Multnomah, Suite 2000 Portland, OR 97232 Telephone: (360) 560-1937 Email:joseph.dallaskpacificorp.com Attorney for Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF ROCKY MOUNTAIN POWER FOR AN ) APPLICATION ORDER INCREASING AND EXTENDING ) THE SHORT-TERM DEBT AUTHORITIES ) CASE NO. PAC-E-26-03 FIVE YEARS ) Rocky Mountain Power, a division of PacifiCorp (the "Company"), pursuant to Idaho Codes §§ 61-901 through 61-904 and Rules of Procedure 141 through 147 of the Idaho Public Utility Commission (the "Commission"), respectfully makes this application (the "Application") to the Commission for an order within 30 days consistent with Idaho Code §61-904,to (1) extend the short-term debt authorities granted in Case No. PAC-E-24-071 through May 31, 2031, but limited in combination to no more than$3.0 billion of total borrowing outstanding at any one point in time, and to (2) authorize not more than$3.0 billion under other bank arrangements. PacifiCorp is seeking$6.0 billion in total short-term debt authority,on the condition that the Company's senior secured debt(First Mortgage Bonds)be rated at"investment grade"by Standard& Poor's Rating Service or Moody's Investor Services,Inc. In support of this Application,the Company represents as follows: 'In the Matter of the Application of Rocky Mountain Power for an Order Increasing and Extending the Short-Term Debt Authorities Five Years,Case No.PAC-E-24-07,Order No. 36171 (May 6.2024). APPLICATION OF ROCKY MOUNTAIN POWER Page 1 I. INTRODUCTION 1. PacifiCorp, doing business as Rocky Mountain Power, is an electrical corporation and public utility in the state of Idaho, subject to the jurisdiction of the Commission, with regard to its rates, service, and accounting practices, § 61-129. PacifiCorp also provides retail electricity service in the states of California, Oregon, Utah, Washington, and Wyoming. Rocky Mountain Power's business address is 1407 West North Temple, Salt Lake City, Utah 84116. II. BACKGROUND 2. On February 24, 2006, PacifiCorp filed an application requesting authorization to borrow not more than$1.5 billion aggregate principal amount in short-term debt through April 30, 2011. On March 14, 2006, the Commission granted the Company's application in Order No. 29999. 3. On March 9,2011,the Company requested' that the authorities granted under Case No. PAC-E-06-01 be extended for an additional five years, or through April 30, 2016. On April 8, 2011, the Commission granted the Company's application in Order No. 32221. 4. On January 26, 2016, the Company requested that the authorities granted under Case No. PAC-E-11-09 be extended for an additional five years, or through April 30,2021, on the condition that the Company's senior secured debt be rated at"investment grade"by both Standard &Poor's Rating Service and Moody's Investor Services, Inc. On March 4, 2016,the Commission granted the Company's application in Order No. 33476. 2 In the Matter of the Application of PacifiCorp for authority to (1) issue its promissory notes to and borrow from commercial banks for(a) not more than $1.5 billion under revolving credit agreements, and(b) not more than $1.5 billion under other borrowing arrangements;and(2) issue and sell its commercial paper in principal amounts not to exceed$1.5 billion outstanding at any one time. Case No.PAC-E-06-01. 3 Case No.PAC-E-11-09. 4 Case No.PAC-E-16-03. APPLICATION OF ROCKY MOUNTAIN POWER Page 2 5. On January 25, 2021, the Company requested that the authorities granted under Case No. PAC-E-16-03 be extended for an additional five years, or through April 30,2026, on the condition that the Company's senior secured debt be rated at"investment grade"by both Standard & Poor's Rating Service and Moody's Investor Services, Inc. On February 23, 2021, the Commission granted the Company's application in Order No. 34927. 6. On October 28, 2022, the Company requested that the authorization amount to borrow granted under Case No. PAC-E-21-02 be increased to not more than$2.0 billion aggregate principal amount in short-term debt for five years,or through November 30,2027,on the condition that the Company's senior secured debt be rated at"investment grade"by both Standard&Poor's Rating Service and Moody's Investor Services, Inc. On December 15, 2022, the Commission granted the Company's application in Order No. 35630. 7. On April 5, 2024, the Company requested that the authorization amount to borrow granted under Case No. PAC-E-24-07 be increased to not more than $3.0 billion aggregate principal amount in the short-term debt for five years, or through May 31, 2029, on the condition that the Company's senior secured debt be rated at"investment grade"by both Standard&Poor's Rating Service and Moody's Investor Services, Inc. and not more than $3.0 billion in aggregate principal amount outstanding at any one time under other borrowing arrangements (Other Arrangements) such as letter of credit facilities. On May 6, 2024, the Commission granted the Company's application in Order No. 36171, however it only addressed the $3.0 billion in short- term debt for five years and not the additional $3.0 billion in Other Arrangements. 5 Case No.PAC-E-21-02. 6 Case No.PAC-E-22-17. APPLICATION OF ROCKY MOUNTAIN POWER Page 3 III. REQUEST FOR RELIEF 8. The Company respectfully requests that the Commission authorize short term debt authorities through May 31, 2031, by authorizing the Company to issue, from time to time, not more than $3.0 billion in aggregate principal amount outstanding at any one time under other borrowing arrangements (Other Arrangements) such as letter of credit facilities. 9. The Company currently has a $2 billion revolving credit agreement expiring June 30,2026,with an unlimited number of maturity extension options subject to lender consent.Under the terms of the agreements, the Company may borrow up to the full amount or have letters of credit issued in an amount up to $300 million or a combination of these amounts. 10. The Company is specifically seeking to clarify that it may also enter into $3 billion in Other Arrangements, including specific letter of credit facilities detailed in this Application. 11. As noted above, the Company's authority to enter into these revolving credit agreements has been in place since 2006. Through the growth of the Company's load and customer base and the continued investment that is necessary to support its operations, the Company is seeking to clarify its ability to issue $3.0 billion in Other Arrangements, including letter of credit facilities. The Company is currently in the process of negotiating and executing a two-year syndicated letter of credit facility (the "Letter of Credit Facility") with certain banks in PacifiCorp's bank group that establishes a process for issuing Letters of Credit that would constitute an Other Arrangement. The Letter of Credit Facility is designed to support obligations primarily related to appellate review of wildfire litigation in Oregon, including securing appeal bonds. Under the currently contemplated structure, Issuing Banks agree to issue letters of credit up to their Commitments, with total letters of credit outstanding not exceeding the Aggregate Commitment, in favor of a surety provider that, in turn, would issue supersedeas bonds securing APPLICATION OF ROCKY MOUNTAIN POWER Page 4 the appealed judgments. The Letter of Credit Facility will have an Administrative Agent, coordinating on behalf of multiple Issuing Banks and the Lead Arranger. IV. STATEMENT OF PUBLIC NOTICE APPLICATION 12. Notice of this Application will be published within seven (7) days of this Application in those newspapers in general circulation in the Company's service area as explained in Section 8, Rule 141 of the Rules of Procedure of the Idaho Public Utilities Commission. V. COMMUNICATIONS 13. Communications regarding this Application should be addressed to: Jana Saba Director of Regulation Rocky Mountain Power 1407 West North Temple, Suite 310 Salt Lake City, UT 84116 E-mail: Jana.Sabakpacificorp.com Joe Dallas Assistant General Counsel Rocky Mountain Power 825 NE Multnomah, Suite 2000 Portland, OR 92732 Telephone: (360) 560-1937 E-mail: Joseph.Dallas(&,pacificorp.com In addition, Rocky Mountain Power respectfully requests that all data requests regarding this matter be addressed to: By e-mail (preferred): datarequest(&,pacificorp.com By regular mail: Data Request Response Center PacifiCorp 825 NE Multnomah, Suite 2000 Portland, OR 97232 Informal inquiries may be directed to Jana Saba Jana.Saba&pacificorp.com. APPLICATION OF ROCKY MOUNTAIN POWER Page 5 VI. MODIFIED PROCEDURE 14. Rocky Mountain Power believes that consideration of the proposals contained in this Application do not require an evidentiary proceeding, and accordingly the Company requests that this Application be processed under RP 201 allowing for consideration of issues under Modified Procedure, i.e., by written submissions rather than by an evidentiary hearing. WHEREFORE, Rocky Mountain Power respectfully requests that the Commission issue an order on this matter within 30 days consistent with Idaho Code §61-904, increasing the short- term debt authorities described herein through May 31,2031, on the condition that the Company's senior secured debt (First Mortgage Bonds) be rated at "investment grade"by Standard & Poor's Rating Service or Moody's Investor Services, Inc. DATED: March 17, 2026 Respectfully submitted, Joe Dallas Attorney for Rocky Mountain Power APPLICATION OF ROCKY MOUNTAIN POWER Page 6