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VIA OVERNIGHT DELIVERY
Idaho Public Utilities Commission
472West Washington
Boise,ID 83702-5983
Attention: Ms. Jean D. Jewell
Commission Secretary
Re: Idaho Docket No. PAC-E-05-08 Compliance Filing
To the Idaho Public Utilities Commission:
PacifiCorp submits the attachment in compliance with the Commission's Order in this case
issued on February 13,2006 and amended on March 14,2006. The Order approved the
Stipulation supporting the acquisition of PacifiCorp by MidAmerican Energy Holdings
Company.
Commitment I20 of the Stipulation provides that PacifiCorp will provide to the Commission, on
an informational basis, credit rating agency news releases and final reports regarding PacifiCorp
when such reports are known to PacifiCorp and are available to the public.
Therefore, in compliance with Comminnentl20 of the Stipulation, please find the attached report
related to PacifiCorp.
Very truly yours,
\!- wll*
Bruce Williams
Vice President and Treasurer
Enclosure
Paclllc Forverl
Rocky Mountain Pover I
PaclflCorp Energy
Mooov's
INVESTORS SERVICE
Rating Action: Moody's upgrades MidAmerican Energy and its US utility
subsidiaries; outlooks stable
Global Credit Research - 30 Jan 2014
ApproximatelV 124 billion of debt affected
New York, January 30,2014 .- Moody's lnvestors Service upgraded the ratings of MidAmerican Energy Holdings
Co. (MEHC, including its senior unsecured to A3 from Baal ) and its subsidiaries PacifiCorp (including its lssuer
Rating to A3 from Baal ); MidAmerican Funding, LLC (its senior unsecured to A2 fom A3); MidAmerican Energy
Company (MEC, including its lssuer Rating to Al from A2); NV Energy lnc. (NVE, including its senior unsecured
loBaa2from Baa3); Nevada Power Company (NPC, including its lssuer Rating to Baal from Baa2); and Siena
Pacific Power Company (SPPC, including its lssuer Rating to Baal from Baa2). These rating actions completes
Moody's review of MEHC and its US utility subsidiaries initiated on November 8, 2013. The outlook for allthese
entities is stable.
RATING RATIONALE
The primary driver of today's rating action was Moody's more favorable view of the relative credit supportiveness
of the US regulatory environment, as detailed in our September 2013 Request for Comment tited "Proposed
Refinements to the Regulated Utilities Rating Methodology and our Evolving View of US Utility Regulation."
"MidAmerican Energy Holdings' credit quality has benefited from improvements in the regulatory environments
throughout its many jurisdictions," said Moody's senior vice president Mihoko Manabe.
MEHC's A3 rating befits one of the largest, diversified portfolio of regulated assets among US utility holding
companies. Moody's notes that just last month, MEHC closed on its $10 billion purchase of NVE, bolstering its
position as a leading owner of regulated utilities. This acquisition adds NVE as MEHC's second-largest subsidiary
(20Yo of pro forma EBITDA as of LTM September 30, 2013) behind PacifiCorp (33% of pro forma EBITDA) and
Nevada to an already long list of regulatory jurisdictions in which it operates. Leverage will spike from the
acquisition debt, but Moody's expects it will be managed back down over the next few years with the substantial
ftee cash flow and tax credits that will be generated by MEHC's nor expanded organization. This acquisition is
also positive for MEHC's business risk profile as the company has lately ficcused on renewable investments that
provide less durability than regulated assets. Still, unregulated businesses (8% of pro forma EBITDA) remain
minor in the scheme of MEHC's large balance sheet.
For NVE and its subsidiaries NPC and SPPC, this merger is a credit-positive event as they become a part of a
larger, well-capitalized organization that has a demonstrated track record within the regulated utility space of being
a longrterm investor, attentive to credit quality and able to strengthen regulatory and end-use customer
relationships. Moreover, given NVE's service tenitory and the reliance on the gaming and mining sectors which
can lead to boorn-or-bust cycles, being a part of a deeppocketed parent will be a favorable credit development.
NVE is an improving credit, having been upgraded three times over the last three years, the last time in May 2013
to investment-grade just before the merger with MEHC was announced. These upgrades were driven by a more
credit-supportive regulatory environment in Nevada accompanying the company's improving financial position.
The company generates healthy cash flovv, but the disparity between the utility subsidiary ratings at NVE (NPC
and SPPC both at Baal)and MEHC's other utility subsidiaries PacifiCorp (A3) and MEC (A1) reflects NVE's still
relatively high leverage. As of LTM September 2013, NPC and SPPC's cash flow pre-working capital-todebt
ratios were in the high 15olo range, distinctly weaker than 20o/o at both PacifiCorp and MEC.
PacifiCorp's A3 rating is supported by the geographically diverse and relatively constructive regulatory
environments in the six western states where it operates. ln the context of Moody's more favorable view of US
utility regulation, Moody's assesses PacifiCorp's overall regulatory treatment as average. Afthough PacifiCorp has
been filing rate cases every year or so in its largest jurisdictions and gefting reasonable outcomes, regulatory lag
remains an ongoing challenge. The company however has made strides in obtaining multi-year rate increases,
notably in Utah (by far its biggest jurisdiction comprising 44o/o of PacifiCorp's 2012 retail electricity volumes), and
energy cost adjustment mechanisms in all its jurisdictions no,r/ except Washington (a minor jurisdiction at 7% of
electricity volumes). Under MEHC's ownership since 2006, PacifiCorp's capital structure has strengthened
organically as a result of both retained earnings and substantial equity contributions from MEHC.
MidAmerican Funding (A2), MEHC's thirdJargest US utility platform (pro forma 14%lTM September 2013
EBITDA), is rated the highest arnong them. MidAmerican Funding's utility subsidiary MEC is the largest utility in
lowa, where Moody's views it receives above-average regulatory treatment compared to its peers. The features of
its regulatory scheme, such as an eamings sharing mechanism and pre-authorization of capital projects at higher
than industry-average ROEs result in stronger credit metrics than those of its sister companies. MEC is in midst of
its first base rate case in nearly 20 years, in which it has reached a twoyear settlement with most of its
intervenors, and which is expected be approved this quarter. This settlement, as proposed, will bring visibility to
future revenues during its term, maintain many of the positive features in its cunent regulatory scheme, and
importantly, introduce an energy adjustment clause which will be a significant improvement in its cost recovery
mechanism.
The ratings of intermediate holding companies MidAmerican Funding and NVE are notched off those of its
operating subsidiaries to reflect structural subordination.
WHAT COULD CHANGE RATINGS - UP
MEHC's ratings are unlikely to be upgraded again in the foreseeable future given that the holding company's
leverage has increased with the NVE acquisition. For its US utility subsidiaries, upgrades are possible if their
regulatory treatment improves much more, enabling them to sustain stronger credit metrics. For example, the
follouring levels of cash flow from operations pre-working capital-todebt ratios could indicate upgrades: around
20o/olor MEHC, above 18% for NVE and its subsidiaries, the mid-20% range for PacifiCorp, and the 30% range for
MEC.
WHAT COULD CHANGE MTING -- DOWN
MEHC's ratings could be downgraded if business risk increases materially; major investments are financed with
excessive leverage; and credit metrics sustain a decline. For example, the following levels of cash flo,v from
operations pre'working capital-todebt ratios could indicate downgrades: in the low teens for MEHC, below 15% for
NVE, the mid-teens for PacifiCorp, and the lw 20o/o range for MEC.
The principal methodology used in these ratings was Regulated Electric and Gas Utilities published in December
2013. Please see the Credit Policy page on www.moodys.com for a copy of this methodology.
Headquartered in Des Moines, lowa, MidAmerican Energy Holdings Co. is a diversified utility holding company
privately owned by Berkshire Hathaway lnc.
Actions Taken:
MidAmerican Energy Holdings Co.:
Senior Unsecured Rating to A3 from Baal
Senior Unsecured Bank Credit Facility to A3 from Baal
Outlook to Stable from Under Review for Upgrade
MidAmerican Funding, LLC :
Senior Unsecured Rating to 42 ftom A3
Outlook to Stable from Under Review for Upgrade
MidAmerican Energy Company:
Long Term lssuer Rating to A1 from A2
First Mortgage Bonds to Aa2 from Aa3
Senior Secured to Aa2 from Aa3
Senior Secured Shelf to (P)Aa2 from (P)Aa3
Senior Unsecured Shelf to (P)A1 from (P)A2
Subordinate Shelf to (P)A2 from (P)A3
Outlook to Stable from Under Review for Upgrade
PacifiCorp:
Long Term lssuer Rating to A3 from Baal
Senior Unsecured MTN to (P)A3 from (P)Baal
Senior Unsecured Bank Credit Facility to A3 from Baal
Preferred Stock to Baa2lromBaa3
First Mortgage Bonds to A1 from A2
Senior Secured to A1 from A2
Senior Secured MTN to (P)Al from (P)A2
Outlook to Stable from Under Review for Upgrade
NV Energy lnc. :
Long Term lssuer Rating toBaa2from Baa3
Senior Unsecured to Baa2ftomBaa3
Outlook to Stable from Under Review for Upgrade
Sierra Pacific Power Company:
Long Term lssuer Rating to Baal from Baa2
First Mortgage Bonds to 42 from A3
Outlook to Stable ftom Under Review for Upgrade
Nevada Power Company:
Long Term lssuer Rating to Baal from Baa2
First Mortgage Bonds to 42 from A3
Senior Secured to A2 from A3
Ouflook to Stable from Under Review for Upgrade
REGULATORY DISCLOSURES
For ratings issued on a program, series or category/class of debt, this announcement provides certain regulatory
disclosures in relation to each rating of a subsequently issued bond or note of the same series or category/class
of debt or pursuant to a program for which the ratings are derived exclusively from existing ratings in accordance
with Moody's rating practices. For ratings issued on a support provider, this announcement provides certain
regulatory disclosures in relation to the rating action on the support provider and in relation to each particular rating
action for securities that derive their credit ratings from the support provider's credit rating. For provisional ratings,
this announcement provides certain regulatory disclosures in relation to the provisional rating assigned, and in
relation to a definitive rating that may be assigned subsequent to the final issuance of the debt, in each case where
the transaction structure and terms have not changed prior to the assignment of the definitive rating in a manner
that would have affected the rating. For further information please see the ratings tab on the issuer/entity page for
the respective issuer on www.moodys.com.
For any affected securities or rated entities receiving direct credit support from the primary entity(ies) of this rating
action, and whose ratings may change as a result of this rating action, the associated regulatory disclosures will
be those of the guarantor entity. Exceptions to this approach exist for the following disclosures, if applicable to
jurisdiction: Ancillary Services, Disclosure to rated entity, Disclosure from rated entity.
Regulatory disclosures contained in this press release apply to the credit rating and, if applicable, the related rating
outlook or rating review.
Please see www.moodys.com for any updates on changes to the lead rating analyst and to the Moody's legal
entity that has issued the rating.
Please see the ratings tab on the issuer/entity page on www.rnoodys.com for additional regulatory disclosures for
each credit rating.
Mihoko Manabe
Senior Vice President
lnfrastructure Finance Group
Moody's lnvestors Service, lnc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 21 2-55&0376
SUBSCRIBERS: 212-55$1653
William L. Hess
MD - Utilities
lnfrastructure Finance Group
JOURNALISTS: 21 2-55&0376
SUBSCRIBERS: 212-55&1653
Releasing Office:
Moody's lnvestors Service, lnc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOU RNALISTS : 212-55}10376
SUBSCRIBERS: 212-55$1653
MooDY's
INVESTORS SERVICE
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