20230815PAC to Staff 1-13.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
August 15, 2023 Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C) RE: ID PAC-E-23-16
IPUC Set 1 (1-13) Please find enclosed Rocky Mountain Power’s Responses to IPUC 1st Set Data Requests 1-13. Also provided are Attachments IPUC 10, 12, and 13. Provided via BOX is Confidential Attachment IPUC 5. 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 [phone]. Sincerely, ____/s/____
Mark Alder
Manager, Regulation Enclosures
RECEIVED
2023 AUGUST 15, 2023 4:28PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 1
IPUC Data Request 1 Please provide the Company's current Wildfire Mitigation Plan (WMP) and any previous iterations of the WMP.
Response to IPUC Data Request 1 PacifiCorp does not have a finalized wildfire mitigation plan (WMP) for Idaho as
this time.
Recordholder: Megan Buckner Sponsor: Amy McCluskey

PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 2
IPUC Data Request 2 Please explain if the Company filed in other states for a similar deferral regarding wildfire claims.

(a) If so, please identify which state(s) and provide the case number(s) for each filing; and
(b) If not, why not.
Response to IPUC Data Request 2 Yes, the Company has filed similar deferral applications regarding wildfire claims in each of the Company’s jurisdictions, as well as in Idaho. Please refer to the
table below which lists each state and the relevant dockets:

State Docket

Recordholder: Mark Alder Sponsor: To Be Determined
PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 3
IPUC Data Request 3 Please explain how the Company will book expenses for its requested deferral (i.e., Multi-State Process inter-jurisdictional cost allocation methodology).
Response to IPUC Data Request 3 The Company will book expenses related to the damages in FERC Account 925
(Injuries and Damages) and in accordance with the approved 2020 Multi-State
Inter-Jurisdictional Cost Allocation Methodology, the 2020 Protocol as approved in Case No. PAC-E-19-20. The application filed in this docket is requesting approval to credit expenses recorded in FERC Account 925 (Injuries and Damages) and debit FERC Account 182.3 (Other Regulatory Assets). Due to the uncertainty of the expenses, the Company has no additional details regarding the
allocation of these expenses to provide at this time.
Recordholder: Nicholas Highsmith

Sponsor: To Be Determined
PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 4
IPUC Data Request 4 For each fire that the Company is accused of negligently causing, please answer the following:

(a) Please explain in detail the Company infrastructure associated with the cause of the fire (i.e., transmission or distribution line, conductor associated with distribution lines, substation, etc.). For any associated infrastructure for
transmission or distribution lines, please provide a list detailing the name of
the line, size of the line, and the impact of the line on the start of the fire; and (b) Please provide a map displaying the location of the start of the fire and the Company's infrastructure near the fire start area.
Response to IPUC Data Request 4
PacifiCorp objects to this request as requiring a legal or factual conclusion that is not available or in dispute, and is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving the foregoing objection,
PacifiCorp responds as follows: (a) Please refer to the descriptions provided below: South Obenchain Fire: The Obenchain Fire ignited September 8, 2020, near
Eagle Point, Oregon within an area covered by a United States (U.S.) Bureau
of Land Management (BLM) permit. Oregon Department of Forestry (ODF) investigators and plaintiffs believe the fire ignited when a tree located outside the right-of-way (ROW) fell into a PacifiCorp distribution line. The tree was
approximately 16 feet from the conductor, or approximately six feet outside of
the ROW. Records show that Trees Inc. performed distribution cycle work on the subject line in 2018. Records further show that PacifiCorp’s contractor, Washington Forestry Consultants, Inc., conducted audit work in 2018. The audit would have included an inspection of the entire circuit, including the area of interest. Interim work on the distribution line was scheduled to occur
in 2020, however, it was not completed before the Obenchain Fire ignited.
Beachie Creek Fire: The Beachie Creek Fire ignited August 16, 2020 in rugged terrain deep in Oregon’s Opal Creek Wilderness in Marion County, Oregon. While the cause of the ignition is listed as unknown, the Company’s external expert meteorologist detected four lightning strikes in the Opal Creek Wilderness in the early morning of August 16, 2020 and local radar data reflects that there was a storm with precipitation in the area. The United States Forest Service (USFS) monitored the fire until an extreme wind event September 7, 2020, created an environment in which the fire was able to
PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 4
accelerate rapidly at a growth rate of about 2.77 acres per second. This allowed the fire to grow to over 130,000 acres in one night. Echo Mountain Fire: The Echo Mountain Complex Fire ignited September
7, 2020, near Lincoln City, Oregon. There are two ignitions: the Echo
Mountain Fire and the Kimberling Fire. The Kimberling Fire was much smaller, burning only seven residences of the 293 residences destroyed in the Echo Mountain Complex Fire. The Lincoln County Sheriff’s Office released
an investigation report in which they conclude that a branch in the line at
Kimberling caused the fire. The report does not state how the Echo Mountain Fire began. PacifiCorp assisted ODF in removing several tree trunks and branches from about 17-18 feet from the transmission line. There was no clearance or other vegetation management issue and PacifiCorp has no reason to believe the trees were involved in starting the fire.
242 Fire: The 242 Fire ignited September 7, 2020, near Klamath, Oregon. The 242 Fire burned approximately 14,473 acres, damaged eight residences and 40 structures, and caused two injuries. The USFS is investigating and retained a
fallen tree located 45 feet from a PacifiCorp distribution line and outside the
ROW. (b) Please refer to the map provided below:

Recordholder: Counsel Sponsor: To Be Determined
PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 5
IPUC Data Request 5 Please provide all lawsuits pending against the Company due to the Oregon September 2020 wildfires, please include the following:

(a) Brief description of the case; (b) Which fire the lawsuit is associated with; (c) Case No;
(d) County filed in;
(e) Name of parties; (f) Case caption; (g) Date filed; and (h) Any other relevant information.
Response to IPUC Data Request 5
PacifiCorp objects to subpart (h) as overly broad and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the foregoing
objection, PacifiCorp responds as follows:
Please refer to Confidential Attachment IPUC 5. 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: Counsel
Sponsor: To Be Determined
PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 6
IPUC Data Request 6 Please provide all concluded lawsuits against the Company due to the Oregon September 2020 wildfires (including those resolved by settlement, final judgment,
or otherwise), please include the following:
(a) Brief description of the case; (b) Which fire the lawsuit is associated with;
(c) Case No;
(d) County filed in; (e) Name of parties; (f) Case caption; (g) Date filed; and (h) Any other relevant information.
Response to IPUC Data Request 6 PacifiCorp objects to subpart (h) as overly broad and not reasonably calculated to
lead to the discovery of admissible evidence. Without waiving the foregoing
objection, PacifiCorp responds as follows: Please refer to the Company’s response to IPUC Data Request 5.
Recordholder: Counsel
Sponsor: To Be Determined

PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 7
IPUC Data Request 7 Please provide all known potential lawsuits against the Company due to the Oregon September 2020 wildfires and include all known information about the
potential litigation including the associated fire.
Response to IPUC Data Request 7
PacifiCorp objects to this request as requesting information that is not in our
possession or control, and not reasonably calculated to lead to the discovery of admissible information. Without waiving the foregoing objection, PacifiCorp responds as follows: Please refer to the Company’s responses to IPUC Data Request 5 and IPUC Data
Request 6 which provide information about filed lawsuits. PacifiCorp is not aware
of other potential lawsuits at this time.
Recordholder: Counsel
Sponsor: To Be Determined
PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 8
IPUC Data Request 8 Please provide a supporting worksheet that details each cost associated with the Oregon September 2020 wildfire lawsuits to date. Please include item name, brief
description, actual spend, and which lawsuit each item is for, and date booked.
Response to IPUC Data Request 8
PacifiCorp objects to this request as overly broad, unduly burdensome and not
reasonably calculated to lead to the discovery of admissible evidence. Without waiving the foregoing objection, the Company responds as follows: Please refer to the Company’s response to IPUC Data Request 5, specifically Confidential Attachment IPUC Data Request 5 which provides a list of the
amounts claimed in the individual lawsuits.
Recordholder: Counsel

Sponsor: To Be Determined
PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 9
IPUC Data Request 9 Please explain if the Company's wildfire insurance is expected to cover any of the costs associated with the wildfire lawsuits and the expected coverage from the
insurance. Please explain why or why not.
Response to IPUC Data Request 9

PacifiCorp's receivable for expected insurance recoveries associated with the probable losses was $379 million and $246 million, respectively, as of June 30, 2023 and December 31, 2022. During the three-month and six-month periods ended June 30, 2023, PacifiCorp recognized probable losses net of expected insurance recoveries associated with the 2020 Wildfires of $49 million
and $408 million, respectively. During the three-month and six-month periods
ended June 30, 2022, PacifiCorp recognized probable losses net of expected insurance recoveries associated with the 2020 Wildfires of $64 million and $64 million, respectively. The net losses are included in operations and
maintenance (O&M) on the Consolidated Statements of Operations. No additional
insurance recoveries beyond those accrued to date are expected to be available for the 2020 Wildfires. Recordholder: Wendy Wallis

Sponsor: To Be Determined

PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 10
IPUC Data Request 10 The Company states that "[t]he costs identified in this application would account for and track the third-party claims that may exceed the Company's insurance
coverage currently in rates associated with the outcomes of this litigation due to
wildfires that occurred in September 2020." Application at 2-3. Please answer the following:
(a) Please provide the current amount of insurance coverage in rates by policy
year from 2019 to date; and (b) Please provide the amount that exceeds the insurance coverage in rates by policy year from 2019 to date.
Response to IPUC Data Request 10
(a) Please refer to Attachment IPUC 10 which provides insurance policy limits since 2019. Note: customer rates are set through general rate case (GRC)
proceedings and based on cost of insurance premiums, not insurance coverage
limits. The Company’s last GRC, Case No. PAC-E-21-07, was stipulated and did not stipulate the amount of any individual revenue requirement component, including insurance premium cost. (b) No additional amounts which exceed the coverage limits have been paid by
the Company from 2019 to date.
Recordholder: Nicholas Highsmith

Sponsor: To Be Determined
PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 11
IPUC Data Request 11 Please explain how the Company will update the Commission during this case with any new information and potential impacts to the Company following the
outcomes of lawsuits against the Company related to the Oregon September 2020
wildfires. Response to IPUC Data Request 11

PacifiCorp has not developed a proposal to update the Idaho Public Utilities Commission (IPUC) but is open to working with parties to develop a procedure to provide such information.
Recordholder: Mark Alder
Sponsor: To Be Determined

PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 12
IPUC Data Request 12 Please outline any contingent liabilities recorded to the financial statements regarding each wildfire.
Response to IPUC Data Request 12 For information on PacifiCorp’s recorded loss contingencies, please refer
Attachment IPUC 12 which provides a copy of PacifiCorp’s Securities and
Exchange Commission (SEC) 10-Q filing for the period ended June 30, 2023. Specifically refer to Note 9 of the Notes to the Consolidated Financial Statements. Recordholder: Brittney Davis-Smiley

Sponsor: To Be Determined

PAC-E-23-16 / Rocky Mountain Power August 15, 2023 IPUC Data Request 13
IPUC Data Request 13 According to the Company's 2023 Oregon WMP, Page 6, the first Oregon WMP was filed on Dec 30, 2021, and it became effective on April 28,
2022.
(a) Please explain what the Company had in place, such as vegetation management procedures, operational procedures, strategies, plans, policies,
etc. that could potentially mitigate hazards due to wildfire prior to filing the
first Oregon WMP. (b) Please provide copies of all documentation relative to the above that was in effect starting in 2019 through 2021.
Response to IPUC Data Request 13
(a) The Company’s Standard Operating Procedure (SOP) for vegetation management has been in place since 2019 and describes the strategy and
operational procedure to mitigate hazards due to wildfire.
(b) Please refer to Attachment IPUC 13 which provides a copy of PacifiCorp’s Transmission and Distribution (T&D) Vegetation Management Program SOP.
Recordholder: Megan Buckner
Sponsor: Amy McCluskey

1
Joe Dallas (ISB# 1033) Rocky Mountain Power 825 NE Multnomah, Suite 2000 Portland, OR 97232
Telephone: [phone] Email: [e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE

-E-23-16
DISCOVERY

I, Joe Dallas , represent Rocky Mountain Power in the above captioned matter. I am an
attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staff 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 Company’s response to IPUC data request 5 contains Company proprietary
information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned response contains
confidential in that the information contains Company proprietary information.
2
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 15th day of August, 2023.

Respectfully submitted,

By__________________________
Joe Dallas Senior Attorney Rocky Mountain Power