20210223Final_Order_No_34927.pdf

ORDER NO. 34927 1
Office of the Secretary
Service Date
February 23, 2021
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF ROCKY MOUNTAIN
POWER’S APPLICATION FOR AN
ORDER EXTENDING ITS SHORT-TERM
DEBT AUTHORITY FOR FIVE YEARS.
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CASE NO. PAC-E-21-02

ORDER NO. 34927

On January 25, 2021, Rocky Mountain Power, a division of PacifiCorp (“Company”),
applied for a Commission order extending the Company’s short-term debt authority granted in
Order No. 33476 (Case No. PAC-E-16-03) for five years, through April 30, 2026. Based on our
review of the record, we approve the Application as noted below.
BACKGROUND
In February 2006, the Company applied to the Commission for authority to borrow up
to $1.5 billion aggregate principal in short-term debt through April 30, 2011. The Commission
granted the Company’s 2006 request in Order No. 29999. On March 9, 2011, the Company asked
the Commission to extend the authority for five more years. The Commission granted that request
on condition that the Company’s senior secured debt be rated “investment grade.” Order No. 32221
at 3-4. On January 26, 2016, the Company applied for extension of the authority granted in Order
No. 32221. The Commission granted the Company’s application on March 4, 2016. Order No.
33476.
THE APPLICATION
The Company requests the Commission extend its short-term debt authority for an
additional five years—through April 30, 2026. Specifically:
The Company respectfully requests that the Commission extend [the
Company’s short-term debt authority] an additional five years…by authorizing
the Company to issue, from time to time, unsecured short-term promissory
notes to and borrow from U.S. or foreign commercial banks (or their affiliates)
under the following facilities: (a) not more than $1.5 billion in aggregate
principal amount outstanding at any one time under one or more revolving
credit agreements (Agreements); and (b) not more than $1.5 billion in aggregate
principal amount outstanding at any one time under other borrowing
arrangements (Other Arrangements). The Company also respectfully request[s]
authorization to issue and sell its commercial paper (Paper) in the U.S. or
overseas, from time to time through April 30, 2026, in aggregate principal
amounts not to exceed $1.5 billion outstanding at any one time; provided that
ORDER NO. 34927 2
the aggregate principal amounts outstanding under the Agreements, Other
Arrangements and Paper not exceed $1.5 billion at any one time.

The Company states it has two revolving credit agreements totaling $1.2 billion. These
credit agreements are set to terminate on June 20, 2022. According to the Company, it needs the
requested extension so it can use these existing revolving credit agreements and preserve its ability
to issue commercial paper after April 30, 2021.
STAFF REVIEW
Staff recommended the Commission approve the Company’s requested shelf debt of
$1.5 billion through April 30, 2026. Staff also recommended the Commission continue to
condition its authorization on the Company maintaining a BBB- or higher senior secured debt
rating by Standard and Poor’s Rating Services, and a Baa3 or higher senior secured debt rating by
Moody’s Investor Services, Inc. (“investment grade”). Finally, Staff recommended continuing the
existing procedures should the Company’s senior secured debt ratings fall below the investment
grade levels.
Staff also observed that the Company’s prior commitments and obligations from other
cases shall remain in effect. Staff confirmed the Commission received a correctly calculated
application fee on February 3, 2021. See Idaho Code § 61-905.
COMMISSION FINDINGS AND DECISION
The Company is an electrical corporation within the definition of Idaho Code § 61-119
and a public utility within the definition of Idaho Code § 61-129. The Idaho Public Utilities
Commission has jurisdiction over this matter pursuant to Title 61 of the Idaho Code. See Idaho
Code §§ 61-901-902.
We find that an evidentiary hearing is unnecessary. The Application conforms to
Commission Rules 141-146 (IDAPA 31.01.01.141-.146), and the Company has paid all fees
required by Idaho Code § 61-905. Further, the proposed issuance is for a lawful purpose, is within
the Company’s corporate powers, and is compatible with the public interest. We therefore find
that the Company’s Application should be approved as conditioned below.
As with our previous extension of authority (Order No. 33476), the Commission
conditions this extension of debt authority upon the Company maintaining senior secured debt at
an investment grade credit rating. Should the Company’s senior secured debt be downgraded
below investment grade after the issuance of the debt securities authorized in this Order, the
ORDER NO. 34927 3
Company shall promptly notify the Commission in writing, and file a supplemental application
requesting that the Commission grant continuing authority to issue debt securities and incur debt
in the manner described in this Order. Finally, the Commission finds that the funds obtained
through the proposed extension of authority for debt issuances will be used for general utility
purposes including improvement or maintenance of service or facilities, construction purposes,
acquisition of utility property, discharge or refunding of existing issuances or to reimburse the
Company’s treasury.
The Commission’s approval of the extension is not a finding of fact or a conclusion of
law that the particular use of these funds is approved by this Order. Nor does this Order constitute
an agency determination or approval of the type of financing or the related costs for ratemaking
purposes. The Commission does not have before it for determination in this case, and therefore
does not determine, the effect of issuance on rates to be charged by the Company for electric
service to consumers in the State of Idaho.
O R D E R
IT IS HEREBY ORDERED that the Company’s Application for extension of the debt
authority granted in Order No. 33476 (Case No. PAC-E-16-03) for an additional five years,
through April 30, 2026, is approved. As requested in the Application, the Company is authorized
to issue and sell or exchange debt of up to $1.5 billion in aggregate principal, and to enter into
credit arrangements.
IT IS FURTHER ORDERED that the Company continue to maintain an investment
grade rating, BBB- or higher by Standard & Poor’s, and Baa3 or higher by Moody’s Investor
Services, for the Company’s senior secured debt.
IT IS FURTHER ORDERED that if the Company’s senior secured debt falls below
investment grade, the Company shall promptly notify the Commission in writing of the
downgrade.
IT IS FURTHER ORDERED that should such a downgrade occur, the Company shall
file a supplemental application with the Commission within seven (7) days after the downgrade
requesting a supplemental Order from the Commission authorizing the Company to continue to
incur debt as provided in this Order, notwithstanding the downgrade. Until such a supplemental
Order is issued, any debt incurred or issued by the Company during that period will become due
or mature no later than the final date of the Continued Authorization Period.
ORDER NO. 34927 4
IT IS FURTHER ORDERED that nothing in this Order or any act or deed performed
in connection with this Order 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 this Order.
IT IS FURTHER ORDERED that this authorization is without prejudice to the
regulatory authority of this Commission with respect to rates, service, accounts, evaluation
estimates or determination of costs or any other matter which may come before the Commission
pursuant to its jurisdiction and authority. For ratemaking purposes, the Commission shall reserve
judgment on the reasonableness of the Company’s capital costs, comparative underwriting analysis
and any associated commissions and expenses incurred for any or all security issuances. In its next
general rate case filing, the Company will be required to show that its capital cost, comparative
underwriting analysis, embedded expenses, and methods of securities marketing are just and
reasonable.
IT IS FURTHER ORDERED that the issuance of this Order does not constitute
acceptance of the Company’s exhibits or other material accompanying the Application for any
purpose other than the issuance of this Order.
THIS IS A FINAL ORDER. Any person interested in this Order (or in issues finally
decided by this Order) may petition for reconsideration within twenty-one (21) days of the service
date of this Order regarding any matter decided in this Order. Within seven (7) days after any
person has petitioned for reconsideration, any other person may cross-petition for reconsideration.
See Idaho Code §§ 61-626 and 62-619.
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ORDER NO. 34927 5
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 22nd
day of February 2021.

PAUL KJELLANDER, PRESIDENT

KRISTINE RAPER, COMMISSIONER

ERIC ANDERSON, COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

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