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HomeMy WebLinkAbout20170728Compliance Filing.pdfxPncFlconp t\,,- '\i ,- I 'l- , , / i- I ILl-\':,-1, !-Ll iu;i .;t-i'- 23 F,li I' l0 Pecific Powr:r I Rocky l.lountrin Powcr 825 NE Mulmomah, Suitc 2000 Pordand, Orcgon 97232 July 28,2017 VA OVERNIGHT DELIVERY Idaho Public Utilities Commission 472West Washington Boise, ID 83702-5983 Attention: Ms. Diane Hanian 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.l CommitmentI20 of the Stipulation provides that PacifiCorp willprovide 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 CommitmentI20 of the Stipulation, please find the attached credit rating agency report related to PacifiCorp. Very truly yours, Weems Treasurer Enclosure 1 On April 30,2014, MidAmerican Energy Holdings Company changed its name to Berkshire Hathaway Energy Company. PacifiCorp Subsidiary of Berkshire Hathaway Energy Company Full Rating Report Ratings Foreign Currency Long-Term IDR Short-Term IOR Prefened Stock Senior Secured Senior Unsecured IDR - lssuer Default Rating. Rating Outlook Stable Financial Summary PacifiCorp ($ Mil.) BBB+ A- F2 A+ A Key Rating Drivers Strong Credit Metrics: PacifiCorp's (PPW)'A-' lssuer Default Rating (lDR) reflects the utility's strong credit metrics and generally supportive regulation across its six-state service territory. FFO fixed-charge coverage and FFO-adjusted leverage was 5.8x and 3.1x for LTM March 31, 2017, respectively. Fitch Ratings estimates 2017 and 2018 FFO coverage and leverage ratios will be better than 5.0x and 4.0x, respectively. The ratings and outlook also consider PPW's relatively low business risk, a competitive resource base and below-industry-average retail rates. Rising Capex Expectations: Fitch expects PPW's 2017-2019 capex to meaningfully exceed the $3.5 billion estimate disclosed by Berkshire Hathaway Energy (BHE; BBB+/Stable) earlier this year at its March 31,2017 fixed-income investors conference. This view reflects the utility's integrated resource plan, subsequently filed with state regulators, which included significant, new wind generating capacity. Notwithstanding significantly higher capex, Fitch believes PPW will not file its next base rate case until late this decade and that future rate increases will be modest. Constructive Regulation: Regulation across PPW's six-state service territory is generally balanced, in Fitch's view, supporting the utility's 'A-' IDR and Stable Outlook. PPW benefits from regulatory mechanisms and riders designed to recover large costs that are beyond its control, including fuel and purchase power. An unexpected, meaningful and sustained deterioration in regulatory oversight would likely trigger adverse rating actions. Rating Outlook: The Stable Rating Outlook considers PPW's strong credit metrics, relatively low business risk profile, competitive resource base, below-industry-average retail rates and management focus on cost control and rate stability. Rating Sensitivities Positive Rating Action: Sustained EBITDA and FFO leverage ratios of 3.25x and 3.5x, respectively, or better, along with continued efficient operating performance and balanced regulation could trigger future credit rating upgrades. Negative Rating Action: Unexpected deterioration across key regulatory jurisdictions and/or a prolonged plant outage or other event causing PPW's FFO-adjusted leverage to decline to 5.0x and EBITDA leverage to decline to 3.75x, or worse, on a sustained basis could trigger adverse rating actions. LTM 2017 2016 Adjusted Revenue Operating EBITDAR Cash Flow from Operations Tolal Adjusted Debt Total Capitalization Capex/ Depreciation (o/o) FFO Fixed-Charge Coverage (x) FFO-Adjusted Leverage (x) Total Adjusted DebVEBITDAR (x) Berkshire Company Hathaway, Related Research Fitch Affrms Berkshire Hathaway Energy Follo,ving Oncor Acquisition Announcement; Ou{ook Steble (July 2017) U.S. Corporates Spotight Series: 5,230 2,238 5,201 2,211 1,568 7,471 14,739 117.3 5.5 3.4 3.4 1,605 7,165 14,504 1 13.5 5.8 3.1 3.2 Hdhaway (Subsidiary of lnc.) (May 2017) Energy Berkshire Analysts Philip Smyth, CFA +1 212 908-0531 philip.smyth@fi tchratings.com Kevin Beicke, CFA +'l 212 908-0618 kevin. beicke@f itch ratings.com www.fitchratings.com July 20,2017 FitchRatings c orporates Utilities, Power & Gas / U.S.A. Financial Overview Liquidity and Debt Structure PPW's liquidity position as of March 31,2017 was $915 million, including $15 million in available cash and cash equivalents and a remaining borrowing capacity of $900 million under its credit facilities. PPW's stand-alone borrowing capacity under its revolving credit facilities totals $1 billion and consists of two separate facilities sized at $600 million and $400 million maturing in March 2018 and June 2019, respectively. Debt Maturities and Liquidity ($ Mil., As of March 31, 2017) 2017 2018 2019 2020 2021 Thereafter Cash and Cash Equivalents Undrawn Committed Facilities Total Debt and Leverage - Total Adjusted Debt (LHS) ($ Mir.) -DebuEBlTDAR (RHS) 8,000 7,000 6,000 5,000 4,000 3,000 2,000 1,000 0 586 350 38 420 5,675 15 900 (x) 4.0 3.5 3.0 2.5 2.0 '1.5 1.0 0.5 0.0 Source: Company data, Fitch. 2013 2014 2015 Source: Company data, Fitch. Cash Flow Analysis PPW was modestly FCF negative during 2013-2016, reflecting rising FFO, a declining trend in capex and higher dividends paid. PPW's capex declined 15% to $903 million in 2016 from $1 .1 billion in 2013. Meanwhile, PPW's utilig FFO averaged $1.6 billion per year in2013-2016. Factoring in dividends and capex, PPW's FCF deficit averaged $144 million per year or approximately 15% of average annual 2013-2016 capex. PPW's annual 2016-2018 capex run rate as disclosed at BHE's fixed-income analyst conference was estimated at approximately $1.2 billion per year on average, before considering proposed wind projects included in PPW's integrated resource plan filing with regulators. 2016 LTM 3t31t17 Gash Flow from Operations and Cash Use rCash Flow from Operations ($ Mil.) ! Capex r Dividends Related Criteria Non-Financial Corporatos Notchingand Recovery Ratings Critaria (June 2017) Criteria br Rating Non-Financial Corporates (March 2017) Parent and Subsidiary Rating Linkage (August 2016) Rating U.S. Utilities, Poiler and Gas Companies (Sector CFdit Factors) (tt/hrch 2014) 2,000 1,800 1,600 '1,400 1,200 1,000 800 600 400 200 0 20't3 Source: Company data, Fitch. 2014 2015 2016 ITM 3131117 PacifiCorp July 20, 2017 2 FitchRatings Gorporates _l Peer and Sector Analysis Peer Group Peer Group Analysis ($ Mil.)lssuer Country PacifiCorp Arizona Public Servico Co. Public Service Company of Colorado Southem Califomia Edbon CompanyA- Arizona Public Service Co. Public Service Company of Colorado Southern Califomia Edison Company Date lssuer Rating History LT IDR (Fc) As of IDR Outook Fundamental Ratios (x) Operating EBITDAR/ (Gross lnterest Expense + Rents) FFO Fixed-Charge Coverage Total Adjusted Debuoperating EBITDAR FFO/Total Adjusted Debt (o/o) FFO-Adjusted Leverage Common Dividend Payout (o/o) I ntemal Cash/Capex (o/o) Capex/Depreciation (%) Retum on Equity (%) Financial lnformation Revenue Revenue Growth (%) EBITDA Operating EBITDA Margin (%) FCF Total Adjusted Debt with Equity Credit Readily Available Cash Funds Flow from Operations Capex IDR - lssuer Default Raling. Source: Company data, Fitch. U,S. u.s. u.s. OutlooU Watch 3t31t17 A- Rating Outook Stable 3t3'.U',t7 A- Rating Oudook Stable 3t31t17 Rating Outlook Stable 3131117 A- Rating Outlook Stable Feb. 1,2017 A- Stable May 5, 2016 A- Stable Nov.24, 2015 A- Stable4pi124,2015 BBB+ Positive Oct. 3, 2014 BBB+ PositiveApdT,2014 BBB Stable Sept. 16,2013 BBB Stable Sept. 17,2012 BBB Stable Sept.29,2011 BBB Stable Oct. 1,2010 BBB StableOct.2,2009 BBB Stable Aug.13,2008 BBB Stable July 13,2007 BBB StableJan.31,2006 BBB StableDec.6,2005 BBB+ Stable May 24,2005 A- Stiable Oct.5,2004 A- Stable May24,1995 A- Stable LT IDR - Long-term lssuer Default Rating. FC - Foreign currency. Source: Fitch. 5.7 5.8 3.2 31.8 3.'l 112.6 82.9 1 13.5 10.3 5,230 (0.1) 2,223 42.5 (151) 7,1 65 15 1,881 (881) 6.7 6.3 3.1 30.2 3.3 59.7 61.5 205.3 9.9 3,490 (0.2) 1,468 42.1 (4s1 ) 4,510 3 1,143 ('1,17't) 8.0 8.3 3.2 31.9 3-1 71.6 65.4 255.2 8.7 4,072 (0.4) 1,332 32.7 (3ss) 4,375 6 1,228 (1,1 s3) 20.4 1 1.6 3.0 30.2 54.2 75.5 171.5 '10.9 11,851 3.8 4,358 36.8 (886) 13,088 100 3,580 (3,612) PacifiCorp July 20,2017 3 Gorporates Key Rating Issues Oregon Coal Phase-Out ln Fitch's view, Senate Bill (S.B.) 1U7-B enacted in March 2016 phasing out coal-fired generation in Oregon by 2035 while sharply increasing Oregon's renewable standard is likely to result in higher costs for the utility. However, Fitch believes the higher costs associated with S.B. 1547-8 will be recovered from customers and the effects of the legislation will be manageable within PPW's current credit profile. The law sets firm milestones for the elimination of coal-fired generation for the state's two largest electric utilities, Portland General by 2035 and Pacific Power (which is a division of PPW) by Jan. 1,2030. S.B. 1547-8 also sets a significantly higher renewable portfolio standard (RPS), requiring that 35o/o ol retail load is sourced from qualifying renewables by 2030, 45o/o by 2035 and 50o/o by 2040. Oregon's 2007 RPS required thal20% of retail customer power needs be met by qualifying renewables, increasing to 25o/o in 2025. S.B. 1547-8 was the result of a collaborative process of stakeholders, including PPW and environmental groups, and will help the state achieve its ambitious carbon reduction goal of 75% below 1990 levels by 2050. PPW estimates that the legislation will save consumers up to $600 million compared with a proposed ballot initiative sponsored by Renew Oregon. While Oregon is PPW's secondJargest contributor to consolidated kilowatt-hour (kWh) sales ranked by state, it represented approximately one-quarter of PPWs annual sales, underscoring the geographic diversity of the utility's operations. Utah, Oregon and Wyoming accounted for 85% of total kWh sales during 2013-2016, with Washington, ldaho and California accounting for the remaining 15%. Constructive Regulation Regulatory outcomes across PPW's multistate service territory have been and are expected to remain balanced from a credit perspective, with the exception of Washington. Economic regulation by the Washington Utilities and Transportation Commission (WUTC), has turned more challenging, in Fitch's, Mew. General rate case decisions issued by the WUTC in 2013 and 2015 were disappointing from a creditworthiness point of view, with noticeable improvement in PPW's most recent GRC. Various riders are in place across PPW's service territory to facilitate recovery of certain costs outside of 'GRC proceedings, including fuel adjustment clauses that mitigate commodity price exposure in all of PPW's regulatory jurisdictions. GRC filings have slowed, reflecting management focus on rate stability and lower capex. No GRCs are currently pending across PPW's six-state service territory. PPW's retail electric rates are competitive regionally, based on weighted average rates. Pacific Power's and Rocky Mountain Power's weighted average retail rates are $0.095/kWh and $0.082/kwh, respectively, which compare with Pacific and Mountain regional average rates of $0.145/kwh and $0.095/kWh, respectively, based on Edison Electric lnstitute data. While year-over-year capex projections have risen meaningfully, Fitch believes PPW will be able to offset costs associated with wind and transmission investment via cost reductions, keeping rates flat through 2019. ln September 2016, WUTC authorized a $14 million, two-step rate increase. The rate increase is composed of a $6 million (1.7%) first-step rate increase effective October 2016 and an $8 million (2.3%) second-step rate increase effective September 2017. The rate increases are based on a 9.5o/o authorized ROE, the same level authorized in PPW's last GRC. ln Fitch's PacifiCorp July 20,2017 4 a Corporates opinion, the outcome of this rate proceeding is more balanced from a PPW creditworthiness point of view than previous orders issued by the WUTC in 2015 and 2013. PPW filed its most recent rate case with the WUTC in November 2015, initially requesting a $20 million two-step rate increase. The company requested a first-step increase of $10 million effective May 1, 2016 and a second-step increase of $10.3 million effective May 1, 2017.The WUTC orders in the proceeding adopted PPW's proposed depreciation acceleration program and a decoupling mechanism. The new depreciation schedule is designed to recover all capital costs of the Bridger plant by 2025 and Colstrip Unit 4 by 2032. fhe WUTC-approved decoupling mechanism is effective for five years and includes triggering thresholds and caps in the interest of rate stability. The commission also denied PPW a return on emission control equipment installed at Jim Bridger Units 3 and 4. ln Fitch's opinion, rulings by the WUTC in GRCs issued March 2015 and December 2013 were unfavorable from a credit point of view. The WUTC orders disallowed costs related to purchased power from qualifying facilities located outside the state of Washington and authorized an ROE of 9.5%, below the industry average at the time the order was issued. PPW subsequently filed a petition for judicial review of certain findings in the WUTC's December 2013 order. ln April 2016, the Washington Court of Appeals affirmed the WUTC order, deferring to the commission's discretion in ratemaking and concluding that the commission did not abuse that discretion. Washington is a relatively small slice of PPW's operations, representing approximately 7% of consolidated 2016 kWh sales. Regulatory outcomes across the remainder of PPW's service territory have been and are expected to continue to be balanced. Capex PPW's 2017 IRP proposes the addition of 1,100 MW of new wind generation in Wyoming that will connect to a new 140-mile 500-kilovolt transmission line from a substation near Medicine Bow, WY to the Jim Bridger power plant. The transmission line will provide access to the new wind generation and relieve congestion. The IRP also includes 905 [4\ / of repowered wind generation and calls for retirement of 3,650 MW of coal-fired generation by 2036. The wind repowering projects incorporate federal production tax credit (PTC) benefits and are expected to be completed by 2020. PPW's most recent capex plan, disclosed at its March 2017 fixed income analyst meeting, included new wind development of 24O MW at an estimated cost of $377 million and repowering of 805 MW at an estimated cost of $917 million. PPW's current capital investment plan (disclosed in March 2017) is 37% higher than the prior capex plan and totals $3.5 billion during 2017-2019, compared with $2.5 billion in the prior plan. lf adopted, the IRP is likely to push capex meaningfully higher in 2018 and 2019. Galifornia ISO PPW is considering the feasibility, costs and benefits of joining the California lndependent System Operator (CAISO) as a participating transmission owner and has completed a comprehensive benefits study. The results of the study, showing net benefits to constituents, were released in October 2015, along with an extension of the nonbinding memorandum of understanding originally entered into by PPW in April 2015. The results of the study support further analysis. California S.B. 350 authorizes the California legislature to consider making changes to current laws that would create an independent governance structure for a regional independent system operator in the state's 2017 legislative session. Regulatory approvals PacifiCorp July 20,2017 5 a Corporates would be required if PPW decides to become a participating transmission owner in CAISO. ln that scenario, PPW would participate in the day-ahead market operated by the CAISO and the unified planning and operation of PPW's transmission network. PPW and affiliate NV Energy, lnc. (NVE) have participated in CAISO's Energy lmbalance Market (ElM) since 2014 and 2015, respectively, reducing the companies' costs to serve customers. EIM provides benefits through more efficient dispatch from a larger, more diverse pool of resources, more effective integration of renewable resources and enhanced reliability through greater situational awareness and responsiveness. Strong Corporate Parent PPW is a wholly owned indirect subsidiary of Berkshire Hathaway Energy Company (BHE), which in turn is majority-owned by Berkshire Hathaway lnc. (BRK; IDR AA-/Outlook Stable). Ownership of BHE by BRK is viewed favorably by Fitch as dividend retention affords BHE greater flexibility in managing operating company growth, dividends and capital structure compared with other investor-owned utilities. Ring-fence provisions at PPW, including a special purpose entity, are designed to preserve credit quality and limit PPW exposure to BHE liabilities. Organizational Structure - Berkshire Hathaway Energy Company ($ Mil., As of March 31,2017) IDR - lssuer Default Rating. Source: Company filings, Fitch. MidAmerican Energy Company IDR - A-/Stable Total AdJustedDebt 4.926 Berkshire Hathaway lnc IDR - AA-/Stable 39,304Total AdJusted Debt Berkshire Hathaway Energy Company IDR - BBB+/Stable BHE Renewables NV Energy, lnc. IDR - BBB-/Positive 4,622 AltaLink, L.P HomeServices of America Nevada Power Company d/b/a NV Energy IDR - BBB/Positive Total Adjusted Debt 3.086 Sierra Pacific Power Company d/b/a NV Energy IDR - BBB/Positive Total AdJustedDebt 1.223 Northern Powergrid (Northeast) Ltd. IDR - A-/Stable Northern Powergrid (Yorkshire) plc IDR - A-lstable BHE U.S. Transmission Northern Powergrid IDR _ BBB+/ StableTotal Adlusted Debt Northern Natural Gas company IDR - A/Stable Total AdjustedDebt 828 PacifiCorp IDR - A-/Stable Total AdjustedDebt 7,'165 PacifiCorp July 20,2017 6 a Gorporates Kern River Funding Corp. MidAmerican Funding LLC IDR - BBB+/SIAbIC Total Adjusted Debt 5.291 Definitions . Total Adjusted DebUOp EBITDAR: Total balance sheet adjusted for equity credit and off-balance sheet debt divided by operating EBITDAR. . FFO Fixed-Charge Coverage: FFO plus gross interest minus interest received plus preferred dividends plus rental payments divided by gross interest plus preferred dividends plus rental payments. . FFo-Adjusted Leverage: Gross debt plus lease adjustment minus equity credit for hybrid instruments plus preferred stock divided by FFO plus gross interest paid plus preferred dividends plus rental expense. Key Metrics Tota! Adjusted DebUOp. EBITDAR -Pacificorp -lUC Median (x) 4.0 - 2.0 1.0 FFO Fixed-Charge Coverage -PacifiCorp -lUC Median (x) 8.0 6.0 4.0 2.0 3.0 (x) 4.0 3.0 2.0 't.0 2016 LTM 3t31t17 LTM 3131117 2013 2014 2015 2016 IUC - lntegrated utility companies. Source: Company data, Fitch. Capex/Depreciation -PacifiCorp -lUC Median 2016 LTM 3t31t17 LTM 3t31117 2013 2014 2015 IUC - lntegrated utility companies. Source: Company data, Fitch. FFO-Adjusted Leverage -PacifiCorp -lUC Median : (o/o) 250 200 150 100 50 Company Profile Acquired by BHE in March 2006, PPW provides integrated electric utility service to 1.8 million retail customers in six Western U.S. states. Through its Rocky Mountain Power division, PPW serves customers in parts of Utah, Wyoming and ldaho. lts Pacific Power division oversees its Western service territory operations serving customers in parts of Oregon, Washington and California. Combined, Utah, Oregon and Wyoming accounted lor 85o/o of PPW's total retail electricity sales in 2014-2016. 2013 2014 2015 2016 IUC - lntegrated utility companies. Source: Company data, Fitch. Business Trends Revenue Dynamics - Net Revenues (LHS) -Net Revenue Growth (RHS) ($ Mil.) 4,000 3,500 3,000 2,500 2,000 1,500 1,000 500 0 2013 2014 2015 20't3 2014 2015 IUC - lntegrated utility companies. Source: Company data, Fitch. (v") 43 42 41 40 39 38 37 36 35 (Yo) 6.0 5.0 4.0 3.0 2.0 1.0 0.0 EBITDA Dynamics TEBITDA(LHS) -E$|1DA Margin (RHS) ($ Mil.) 2,500 2,000 1,500 'I,000 500 0 2013 2014 2015 Source: Company data, Fitch. 20'16 LTM2016 LTM 3131t17 Source: Company data, Fitch.3t31t17 PacifiCorp July 20,2017 7 F aa Corporates Financial Summary - PacifiCorp ($ Mil., As of Mar 31, 2017, IDR - A-lRating Outook Stable) Fundamental Ratios Operating EBITDAR/(Gross lnterest Expense + Rents) (x) FFO Fixed-Charge Coverage (x) Total Adjusted DebilOperating EBITDAR (x) FFO/Total Adjusted Debt (o/o) FFo-Adjusted Leverage (x) Common Dividend Payout (o/o) lntemal Cash/Capex (%) Cape)dOepreciation (%) Retum on Equity (0/6) Profltability Revenues Revenue Growth (o/o) Net Revenues Operating and Maintenance Epense Op€rating EBITDA Operating EBITDAR Dopreciation and Amortization Expense Operating EBIT Grqss lntersst Epense Net lncome for Common Operating Maintenancs $eome 0/6 of Net Re\6nues Operating EBIT o/o of Net Revenues Caeh Flow Cash Flow ftom Operations Change in Working Capital FFO Dividends Capex FCF Net Ofier lnveshent Cash Flow Net Change in Debt Net Equity Proceeds Capital Structure Short-Term Debt Total Long-Term Debt Total Debt with Equity Credit TotalAdjusted Debt with Equity Credit Total Common Shareholde/s Equity Total Capital Total DebuTotal Capital (%) Common Equity/Total Capital (%) IOR - lssuer Default Rating. Source: Company data, Fitch. 2013 4.9 4.8 3.6 27.3 3.7 73.3 98.7 157.8 8.8 6,877 6,878 7,006 7,787 14,663 47 53 2014 5.2 5.0 3.5 27.4 3.6 103.9 79.3 146.8 9.0 20 7,053 7,074 7,202 7,756 14,828 48 52 2015 5.4 5.2 3.5 28.2 3.5 136.7 85.6 't2't.0 9.1 20 7,146 7,167 7,287 7,503 14,668 49 5't 5.6 5.5 3.4 29.1 3.4 114.7 76.7 117.3 10.2 5.7 5.8 3.2 31.8 3.1 112.6 114.2 113.5 10.3 2016 LTM 3/31/17 5,147 5.4 3,223 (1,1 14) 1,939 1,955 (67s) 1,264 (37e) 682 (34.6) 39.2 1,551 34 1,517 (s00) (1,065) (14) 12 15 (40) 5,252 2.0 3,255 (1,057) 2,026 2,042 (726) 1,300 (37s) 698 (32.5) 39.9 1,570 (10) 1,580 (725) (1,066) (22',t) (16) 207 5,201 (0.6) 3,450 (1,064) 2,196 2,211 (770) 1,426 (380) 763 (30.8) 41.3 1,568 (20e) 1,777 (87s) (e03) (21 0) 33 182 270 7,O79 7,351 7,47',1 7,390 14,739 50 50 5,230 (0.1) 3,465 (1,049) 2,223 2,238 (776) 1,447 (380) 777 (30.3) 4'1.8 1,605 (276) 1,881 (875) (881) (1s1) 55 (56) 8 7,O27 7,037 7,1 65 7,469 14,504 49 51 5,232 (0.4) 3,364 (1,082) 2,097 2,'t12 (757) 1,340 (37s) 695 (32.2) 39.8 1,734 74 1,660 (e50) (e16) (132) (3) 124 PacifiCorp July 20,2017 I a Gorporates Ratings The ratings above were solicited by, or on behalf ol the issuer, and therefore, Fitch has been compensated forthe provision of the ratings. 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Such ftes gerEralv vary frorn US$1,000 to US$750,000 (or tle applicable orrency eqdvalent) per issue. ln stain c6es, ffidr will rate all or a iunber of issrcs issued by a panhiar is$rer, or irstred or guaranteed by a pafiiolar irsurcr or grarantor, br a sirgle anntal fue. Sxh fues ae epeded to vary fiom US$10,m0 to US$1,500,m0 (o he apflizble orrency equivalent). The assignnent, pudicalion, or dissernindion of a rating by Fitdr shan nc{ corsttue a coflsent by Fitch to we its nane as an epert in connedion wih arry registration statenEnt filed under the United Stales securities larc, tle Finarrcial Services and Markeb Ad of 2m0 of fle Urited l(rEdqn, or he seolities laivs of any partiorlar jurMidirn. Drc to the rdative e,trdency of eledrmic pr"blistirU and dbtdbution, Frtdr research rnay be a\railaHe to decboric subscribes up to hree days eadier han to print sdscribers. For Amfdh, Ner^, Zealand, Taiwan and Souh Koea only: Htch A,rsfdia Pty Ud hdds an Australian fnancial services license (AFS li:ense no. 337123) which auhorizes it to provide credit ratirEs to urhohsale dients only. Credil ratirgs informalion published by Fitch is not intended to be used by persons who are rHail dienb within the meaning of tle Corporatiors Acl 2001. PacifiCorp July 20,2017 I Gorporates