20231002PAC to Staff 1-10_Attorney Attestation.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 29, 2023 Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C) RE: ID PAC-E-23-18
IPUC Set 1 (1-10) Please find enclosed Rocky Mountain Power’s Responses to IPUC 1st Set Data Requests 1-10 and Attachment IPUC 3. Provided via BOX are Confidential Attachments IPUC 1-1, 1-2, and 10. 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 protective agreement 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 SEPTEMBER 29, 2023 4:33PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-18 / Rocky Mountain Power September 29, 2023 IPUC Data Request 1
IPUC Data Request 1 Please provide documentation supporting the Company's assertion that its estimated total costs for commercial insurance for the policy period beginning
August 15, 2023, or later are approximately $125 million (i.e., invoices and
emails). Response to IPUC Data Request 1

Please refer to Confidential Attachment IPUC 1-1 which provides the total cost of commercial insurance for the policy period beginning August 15, 2023. Please refer to Confidential Attachment IPUC 1-2 which provides copies of invoices covering 2018 through 2023.
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: Wendy Wallis Sponsor: Mariya Coleman

PAC-E-23-18 / Rocky Mountain Power September 29, 2023 IPUC Data Request 2
IPUC Data Request 2 Please explain what the Company expects to defer under Federal and State emergency declarations, providing specific examples to the extent possible.
Response to IPUC Data Request 2 The Company has not currently identified insurance costs for third-party claims
on PacifiCorp under Federal or State emergency declarations. To the extent that
any Federal or State emergency declarations are made within the Company’s territory, there may be third-party claims on PacifiCorp associated with events under Federal or State emergency declarations.
Recordholder: Counsel
Sponsor: Counsel

PAC-E-23-18 / Rocky Mountain Power September 29, 2023 IPUC Data Request 3
IPUC Data Request 3 Please explain how the Company calculated Idaho's allocated share of the insurance costs of $92.3 million above what is currently in rates. Please provide
the supporting work papers with formulas intact.
Response to IPUC Data Request 3
The Company calculated the $92.3 million above what is currently in rates as
follows: $125 million total company (1) -$32.7 million total company (2) $92.3 million

Notes: (1) The estimate for commercial insurance costs for the policy period beginning
August 15, 2023 or later (Application for Accounting Order Deferral related
to Insurance Costs, page 3, item 8). (2) The amount assumed by the Company to be reflected in current rates (Application for Accounting Order Deferral related to Insurance Costs page 3, item 8). The $32.7 million was included in general rate case (GRC), Case
PAC-E-21-07, in Exhibit No. 40 to the testimony of Company witness, Steven
R. McDougal, specifically the Insurance Expense Adjustment back up page 4.7.3. Please refer to Attachment IPUC 3 which provides the referenced page 4.7.3 in Microsoft Excel format. Note: the GRC proceeding was approved
under a stipulation which did not explicitly approve any amount in-rates for
insurance premium costs. As such, the Company assumes the filed amount as the amount in-rates for purposes of the deferral request in the Company’s Application for Accounting Order Deferral related to Insurance Costs.
Recordholder: Laura Miller
Sponsor: Nicholas L. Highsmith
PAC-E-23-18 / Rocky Mountain Power September 29, 2023 IPUC Data Request 4
IPUC Data Request 4 Please indicate whether the Company expects its commercial insurance premiums to increase, decrease, or stay relatively steady over the next 5 years. Please
explain the reasoning behind this expectation.
Response to IPUC Data Request 4
The Company does not predict or control the insurance market. If large claims
continue to be paid by insurers to the utility industry, the Company’s costs will increase. Recordholder: Wendy Wallis

Sponsor: Mariya Coleman

PAC-E-23-18 / Rocky Mountain Power September 29, 2023 IPUC Data Request 5
IPUC Data Request 5 Please explain the Company's understanding of the specific criteria that insurance companies use when assessing the risk of providing commercial insurance to an
electric utility.

Response to IPUC Data Request 5
Insurance markets assess the risk based on each individual insurer’s review of information similar to the following (this list is not exhaustive): property values, plant, and equipment; employee count; loss history; overhead electric
transmission and distribution lines; transmission and distribution pipeline miles the physical location of each asset, operational policies, and procedures; safety and loss prevention programs; quality and maintenance records of assets; plans for decarbonization.

Recordholder: Wendy Wallis Sponsor: Mariya Coleman
PAC-E-23-18 / Rocky Mountain Power September 29, 2023 IPUC Data Request 6
IPUC Data Request 6 Please identify all the factors that the Company considered to be causing its insurance premiums to increase.
Response to IPUC Data Request 6 Each insurer chooses its pricing to sell its insurance and whether it wants to sell
insurance to each client. Insurers will use examples such as large losses paid by
insurers to the utility industry and each specific client, inflation, supply chain disruptions, natural disasters to explain increases in costs. The Company does not control the management choices of its insurers in pricing their offered insurance products. The insurance industry’s loss experience for utilities is amongst the key items causing insurance premiums to increase.

Recordholder: Wendy Wallis
Sponsor: Mariya Coleman
PAC-E-23-18 / Rocky Mountain Power September 29, 2023 IPUC Data Request 7
IPUC Data Request 7 Please explain how the Company is currently or is planning to mitigate factors that the Company or insurance companies deem to influence coverage risk or insurance
premiums.
Response to IPUC Data Request 7
The Company strives to mitigate insurance risk factors through the following
activities (including but not limited to):
• Continuously setting improvement targets for safety performance;
• Leverage technology to proactively identify and address vehicle accident risk,
including the use of telematics to drive improvement;
• Expand clean energy;
• Target zero workforce incidents/accidents;
• Keep costs stable and affordable through disciplined management;
• Enhance reliability and resiliency;
• Strive to achieve net zero greenhouse gas (GHG) emissions by 2050 in a
manner customers can afford;
• Annual environmental and climate-related disclosures are made in investor presentations and are publicly available;
• Supply chain advanced planning allows for capacity to be secured – actively
work with vendors, operations and standards to identify, approve and stock
alternates;
• Cybersecurity program in place;
• Dam safety program in place for performance monitoring; and
• Develop and update the wildfire and extreme weather mitigation plans in partnership with local and state-wide authorities and emergency services leaders and incorporates the use of state-of-the-art technology.
Recordholder: Wendy Wallis Sponsor: Mariya Coleman
PAC-E-23-18 / Rocky Mountain Power September 29, 2023 IPUC Data Request 8
IPUC Data Request 8 Please provide a map of the service territory that indicates areas that the Company and/or insurance companies deem to be at substantial risk for wildfires. Please
explain the reasoning for the determination of high risks and how the Company is
currently or planning to address these concerns. Response to IPUC Data Request 8

Rocky Mountain Power (RMP) is currently developing a map that identifies areas that are at substantial risk of a wildfire from a utility asset ignition. It is anticipated that the map will be completed and filed with the Idaho Public Utilities Commission (IPUC) by the end of 2023 as part of its Idaho Wildfire Mitigation Plan. RMP does not have insight into how insurers interpret areas at
risk of wildfire, however, the Company strives to inform insurers, but ultimately,
insurers do not share details about their interpretations of risk.
Recordholder: Bruce Dao
Sponsor: Megan Buckner
PAC-E-23-18 / Rocky Mountain Power September 29, 2023 IPUC Data Request 9
IPUC Data Request 9 Please provide invoices for the Company's commercial insurance for the years 2018-2023.
Response to IPUC Data Request 9 Please refer to the Company’s response to IPUC Data Request 1, specifically
Confidential Attachment IPUC 1-2.
Recordholder: Wendy Wallis Sponsor: Mariya Coleman

PAC-E-23-18 / Rocky Mountain Power September 29, 2023 IPUC Data Request 10
IPUC Data Request 10 Please provide copies of the commercial insurance contracts, including the policy terms and conditions, between the Company and insurance providers for policies
covering the years 2018-2023.
Response to IPUC Data Request 10
Please refer to Confidential Attachment IPUC 10 which provides copies of the
Company’s insurance policies covering insurance years 2018-2019, 2019-2020, 2020-2021, 2021-2022, 2022-2023 and 2023-2024. 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: Wendy Wallis
Sponsor: Mariya Coleman
1
Joe Dallas (ISB #10330) 825 NE Multnomah, Suite 2000 Portland, OR 97232 Telephone No. [phone]
Email: [e-mail] Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE

-E-23-18

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 the Company’s response to IPUC Data Requests Nos. 1 and 10 contain Company
proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned responses contain
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 29th day of September, 2023.

Respectfully submitted,

By__________________________
Joe Dallas Senior Attorney Rocky Mountain Power