20260407Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: JAMES CHANDLER,AUDITOR 3
KELSEA E. ROSS,DEPUTY ATTORNEY GENERAL
DATE: APRIL 7, 2026
RE: IN THE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION
FOR AN ORDER INCREASING AND EXTENDING THE SHORT-TERM
DEBT AUTHORITIES FIVE YEARS; CASE NO. PAC-E-26-03.
On March 17, 2026, Rocky Mountain Power, a division of PacifiCorp ("Company"), filed
an Application with the Idaho Public Utilities Commission ("Commission") requesting an Order
authorizing: (1)an extension of the short-term debt authorities granted in Order No. 36171 through
May 31, 2031, limited in combination to no more than$3.0 billion of total borrowing outstanding
at any one point in time; and(2) authorization of not more than$3.0 billion under other borrowing
arrangements("Other Arrangements").Prior authorities were granted in Order Nos.27457,28347,
28970,29374,29999,32221,33476,34927,35630,and 36171. The Company seeks a total of$6.0
billion in combined short-term debt authority, on the condition the Company's senior secured debt
(First Mortgage Bonds) be rated "investment grade" by Standard & Poor's Rating Service or
Moody's Investor Services, Inc. Staff calculated the filing fee to be $1,000, and the Commission
received payment on April 2, 2026.
Like previous filings of this type, PacifiCorp's senior debt must maintain an "investment
grade" credit rating by both Standard and Poor's Rating Services and Moody's Investor Services
Inc. The other terms and conditions will not be changed.
On April 5, 2024, the Company requested 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 (5) years, or through May 31, 2029, on the condition that:
(1) the Company's senior secured debt be rated at "investment grade"by both Standard & Poor's
DECISION MEMORANDUM - 1 - APRIL 7, 2026

Rating Service and Moody's Investor Services,Inc.;and(2)not more than$3.0 billion in aggregate
principal amount be outstanding at any one time under Other Arrangements such as letter of credit
facilities.
On May 6, 2024,the Commission granted the Company's application in Order No. 36171;
however, due to a Staff oversight in that case, the order only addressed the $3.0 billion in short-
term debt for five (5) years and not the additional $3.0 billion in Other Arrangements.
The Company is currently in the process of negotiating and executing a two (2) 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.
STAFF DISCUSSION AND RECOMMENDATIONS
Because the Application is requesting an increase to the limit and extension from the
previous Order approving the previous application and information on file, the Application
complies with Commission rules. The requested authority, if approved, will be continuous and
would remain in effect until May 31, 2031. As a condition of the continuous five (5) year term,
the Company must continue to maintain"investment grade"ratings by Standard and Poor' s Rating
Services, which is BBB- and a Baa3 or higher senior secured debt rating by Moody's Investors'
Service,Inc. The Company's current senior secured debt ratings are BBB-by Standard and Poor's,
and Baa2 by Moody's, which qualify as "investment grade."
Authorization of the request would not significantly impact the Company's capital
structure or result in changes to customer rates.
If the Company's senior secured debt ratings fall below "investment grade" level
("Downgrade"), it is recommended that PacifiCorp's authority not terminate. Instead, it is
recommended that such authority continue for a period of 180 days from the date of the Downgrade
("Continued Authorization Period") provided that the Company: (1) promptly notifies the
Commission in writing of the Downgrade; and (2) files a supplemental application with the
Commission within seven (7) days after the Downgrade requesting a supplemental order
("Supplemental Order") authorizing the Company to continue to incur debt as provided in this
Order, notwithstanding the Downgrade. Until the Company receives a Supplemental Order, any
DECISION MEMORANDUM - 2 - APRIL 7, 2026

debt incurred or issued during the Continued Authorization Period would become due or mature
no later than the final date of the Continued Authorization Period.
Staff recommends the Commission approve the Company's request to: (1) extend short-
term debt authorities through May 31, 2031; and(2) authorize 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 Arrangements. Staff further recommends that the Commission require the Company to
notify the Commission in writing if its secured debt credit ratings fall below investment grade and,
within seven(7)days of such Downgrade, file a supplemental application requesting Commission
authorization to continue to incur debt.
COMMISSION DECISION
Does the Commission wish to approve the Company's request to: (1) extend short-term
debt authorities through May,31,2031,and(2)authorize 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
Arrangements, subject to the reporting and filing requirements recommended by Staff?
u�
James Chandler
Auditor 3
IAUtility\UDMEMOSTAC-E-26-03 Decision Memo.docx
DECISION MEMORANDUM - 3 - APRIL 7, 2026