20260415Final_Order_No_37003.pdf

Office of the Secretary
Service Date
April 15,2026
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN ) CASE NO. PAC-E-26-03
POWER'S APPLICATION FOR AN ORDER )
INCREASING AND EXTENDING THE )
SHORT-TERM DEBT AUTHORITIES FIVE ) ORDER NO. 37003
YEARS )
On March 17, 2026, Rocky Mountain Power, a division of PacifiCorp ("Company"),
applied under Idaho Code §§ 61-901 through 61-905 and Rules 141-147 of the Commission Rules
of Procedure, IDAPA 31.01.01.141-147, to the Idaho Public Utilities Commission
("Commission") requesting an Order authorizing: (1) an increase and extension of the short-term
debt authorities granted in Order No. 36171 through May 31,2031; and(2)authorization to borrow
not more than $3.0 billion under other borrowing arrangements ("Other Arrangements").
Application at 1.
At the Commission's April 7, 2026, Decision Meeting, Staff filed a memorandum
recommending that the Commission approve the requested authority to increase and extend the
Company's credit authority.
Based on our review of the record, we issue this Final Order approving the Application as
discussed below.
THE APPLICATION
The Company requested authority to borrow a total of $6.0 billion in combined debt
authorities through May 31, 2031.Id. Specifically,the Company requested authority to borrow up
to $3.0 billion in short-term debt and $3.0 billion in Other Arrangements. Id. The Company
represented that the Commission granted prior authorities in Order Nos. 29999, 32221, 33476,
34927, 35630, and 36171.Id. at 2-3.
The Commission's most recent order regarding the Company's securities issuance
authority, Order No. 36171, granted the Company authority to borrow up to $3.0 billion in short
term debt for five years so long as the Company's senior secured debt maintained an investment
grade rating with Standard & Poor's Rating Service ("S&P") or Moody's Investor Services, Inc.
ORDER NO. 37003 1

("Moody's"). Id. at 3. The Company did not believe it received authority in Order No. 36171 to
borrow an additional $3.0 billion in Other Arrangements which it sought then.Id.
The Company represented it is negotiating and executing a two-year syndicated letter of
credit facility designed to support appellate review of wildfire litigation in Oregon and secure
appeal bonds. Id. at 4. The Company represented the syndicated letter of credit facility would
establish a process for issuing letters of credit and count as an Other Arrangement. Id.
STAFF RECOMMENDATION
Staff recommended that the Commission approve the Company's Application subject to
the reporting and filing requirements recommended by Staff. Staff s Decision Memorandum at 3.
Staff believed that because the Application requested an increase to,and extension of,the authority
granted in Order No. 3 617 1, and relied on the Company's application from Case No. PAC-E-24-
07, that the Application complied with Commission rules.Id. at 2.
Staff recommended that the Company's authority to borrow be conditioned on the
Company maintaining an investment grade senior debt rating by S&P or higher senior debt rating
by Moody's.Id. Staff represented that the Company's current senior secured debt ratings are BBB-
by S&P and Baa2 by Moody's, which Staff believed qualified as investment grade ratings.Id.
If the Company's senior secured debt ratings fall below investment grade level
("Downgrade"), Staff recommended that the Company's authority continue for 180 days from the
date of the Downgrade ("Continued Authorization Period") so long as 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 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.
Id. at 2-3.
FINDINGS AND DECISION
The Company is an electrical corporation and a public utility in Idaho defined in Idaho
Code §§ 61-119 and 61-129. A public utility providing electric service in Idaho may "issue,
assume, or guarantee bonds or other securities," for purposes set forth in Idaho law, and the
Commission has jurisdiction to authorize a public utility to assume, issue, or guarantee securities.
ORDER NO. 37003 2

Idaho Code § 61-901. Public utilities are required to apply to the Commission for an order
authorizing the public utility to assume, issue, or guarantee securities. Idaho Code § 61-902. The
application must comply with the requirements set forth in Rules 141-150 of the Commission
Rules of Procedure, IDAPA 31.01.01.141-150. If the Commission finds that the proposed
transactions are in the public interest, it shall enter an order authorizing the transactions. Idaho
Code § 61-902. The Commission is required to process applications for securities within 30 days.
Idaho Code § 61-904.
In this case, with respect to the Company's concerns and requested clarification regarding
what authority was granted in Order No. 36171, we note that in Case No. PAC-E-24-07, the
Company applied for authority to borrow
not more than$3.0 billion in aggregate principal amount outstanding at any one time under
one or more revolving credit agreements (Agreements); and(b)not more than $3.0 billion
in aggregate principal amount outstanding at one time under other borrowing arrangements
(Other Arrangements).
Application in Case No. PAC-E-24-07 at 3. The Company requested"that the aggregate principal
amounts outstanding under the Agreements, [and] Other Arrangements...not exceed $3.0 billion
at any one time." Id. at 3-4. In Order No. 36171, the Commission granted the Company's
application to "increase and extend its current authority to borrow up to $3.0 billion through May
31, 2029" without specifying that the Company could borrow up to $3.0 billion in Agreements
AND $3.0 billion in Other Arrangements. Order No. 36171 at 3.
Having reviewed the Application and the record, we find that the proposed transaction is
in the public interest and a formal hearing on this matter is not required. Further, we find: (1) that
the proposed issuance comports with Idaho Code §61-901 and is within the Company's corporate
powers; (2)that the Application reasonably conforms to Rules 141-150 of the Commission Rules
of Procedure, IDAPA 31.01.01.141-150; and (3) that the Company has paid all fees due under
Idaho Code § 61-905.
Accordingly, we find it is fair,just, and reasonable to grant the Company's Application,
and to extend the authority granted in Order No. 36171 that provides for the Company to borrow
not more than$3.0 billion under Agreements and to borrow not more than$3.0 billion in aggregate
principal amount outstanding at any one time under Other Arrangements, for a total not to exceed
$6.0 billion in total short-term debt authorities, until May 31, 2031, all conditioned on the
ORDER NO. 37003 3

Company maintaining the investment grade requirements. The Commission adds that the approval
for the Other Arrangements is limited to lines of credit and issuances to support wildfire litigation,
and not for other purposes. If the Company wishes to use these Other Arrangements for different
purposes it will have to file for new approval.
The Commission also finds it reasonable that in the event of a Downgrade,the Company's
authority to borrow shall continue for 180 days under the condition that the Company file a
supplemental application with the Commission within seven days of the Downgrade requesting a
Supplemental Order authorizing the Company to continue to incur debt as provided in this Order.
Until the Company receives a Supplemental Order, any debt incurred or issued by the Company
during the Continued Authorization Period will become due or mature no later than the final date
of the Continued Authorization Period.
The Commission's Order approving the proposed financing and the general purpose to
which the proceeds may be used is not a determination of Commission approval of the particular
use of these funds will be put. This Order is not a Commission determination or approval of the
type of financing or the related costs for ratemaking purposes. The Commission does not have
before it for determination, and so does not determine, the effect of the proposed transaction on
rates the Company will charge for electric service.
ORDER
IT IS HEREBY ORDERED that the Commission grants the Company's Application and
extends the authority granted in Order No. 36171 that provides for the Company to borrow not
more than $3.0 billion under Agreements and to borrow not more than $3.0 billion in aggregate
principal amount outstanding at any one time under Other Arrangements, for a total authority not
to exceed $6.0 billion in total short-term debt issuances, through May 31, 2031.
IT IS FURTHER ORDERED that the Company continue to maintain investment grade
ratings by S&P and Moody's for the Company's senior secured debt. So long as it does so, the
authority approved by this Order shall remain in effect through May 31, 2031.
IT IS FURTHER ORDERED that if the Company's senior secured debt falls below
investment grade, that the Company shall promptly notify the Commission in writing of the
Downgrade.
ORDER NO. 37003 4

IT IS FURTHER ORDERED that should such a Downgrade occur, the Company's
authority shall continue for 180 days under the condition that the Company file a supplemental
application with the Commission within seven days of the Downgrade requesting a Supplemental
Order authorizing the Company to continue to incur debt as provided in this Order. Until the
Company receives a Supplemental Order, any debt incurred or issued by the Company during the
Continued Authorization Period will become due or mature no later than the final date of the
Continued Authorization Period.
IT IS FURTHER ORDERED that the Company must continue to file quarterly reports with
the Commission setting forth the date of issuance,principal amount, interest rate, date of maturity,
and identity of payee for all promissory notes issued during the quarter. The Company must
continue to file its capitalization ratios with the quarterly reports.
IT IS FURTHER ORDERED that the foregoing authorization is without prejudice to the
regulatory authority of the Commission with respect to rates, utility capital structure, service
accounts, valuation, estimates for determination of cost, or any other matter which may come
before this Commission pursuant to its jurisdiction and authority as provided by law.
IT IS FURTHER ORDERED that nothing in this Order and no provisions of Chapter 9,
Title 61, Idaho Code, or any act or deed done or performed in connection therewith shall be
construed to obligate the State of Idaho to pay or guarantee in any manner whatsoever any security
authorized,issued,assumed,or guaranteed under the provisions of Chapter 9,Title 61,Idaho Code.
IT IS FURTHER ORDERED that issuance of this Order does not constitute acceptance of
the Company's exhibits or other materials accompanying the Application for any purpose other
than the issuance of this Order.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within 21 days of the service date of this Order regarding any matter decided in
this Order.Within seven days after any person has petitioned for reconsideration, any other person
may cross-petition for reconsideration.Idaho Code § 61-626.
ORDER NO. 37003 5

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 15th day of
April 2026.
G
EDWARD LODGE PR c DENT
Ir-IL
JO R. HAMMOND JR., COMMISSIONER
1
DAYN HAKDIE, COMMISSIONER
ATTEST:
I JjQst,
Monic a o nchez
Commission Secretary
BLegahELECTRICFAC-E-26-03_securitiesTACE2603_FO_kr.docx
ORDER NO. 37003 6