20221028Application.pdf

Y ROCKY MOUNTAIN
Fo\'I|ER.
i{EC E IV ED
?ill? CCT 28 Ptt h: tr?
ti"i.'rii0 ftUBLlC
' , i i,-'r''i' I Es'c0 Hl'llssloN
1407 W. North Temple
Salt Lake City, UT 84116
October 28,2022
VA ELECTRONIC FILING
Idaho Public Utilities Commission
I1331 W. Chinden Blvd.
Building 8 Suite 20lA
Boise,ID 83714
Attn: Jan Noriyuki
Commission Secretary
RE: CASE NO. PAC-E-22-17
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AI\
ORDER TO INCREASE AI\[D EXTEND THE SHORT.TERM DEBT AUTHORITIES
FIVE YEARS
Dear Ms. Noriyuki:
Please find for filing with the Idaho Public Utilities Commission Rocky Mountain Power's
Application in the above referenced matter. Pursuant to Idaho Code$ 61-905 please note that the
Company's Application Fee in the amount of $1,000 is being submiued under separate cover.
Informal questions related to this matter may be directed to Ted Weston, tdaho Regulatory
Manager at [phone].
Sincerely,
SVP, Regulation and Customer/Community Solutions
Enclosures
Joe Dallas (lSB# 10330)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR97232
Telephone: (360) 560-l 937
Email: ioseph.dallas ificorn.com
Attorneyfor Roclqt Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOTINTAIN POWER FOR AI\
ORDER INCREASING AI\[D EXTENDING
THE SHORT-TERM DEBT AUTHORITIES
FIVE YEARS
APPLICATION
CASE NO. PAC.E.22.17
Rocky Mountain Power, a division of PacifiCorp (the "Company"), pursuant to Idaho
Codes $$ 61-901 through 6l-904 and Rules of Procedure l4l through 147 of the Idaho Public
Utility Commission (the "Commission"), respectfully submits this application to the Commission
for an order on or before December 15,2022, to increase the short-term debt authorities granted
in Case No. PAC-E-21-02I through November 30,2027, on the condition that the Company's
senior secured debt be rated at "investment grade" by both Standard & Poor's Rating Service and
Moody's Investor Services, Inc. In support ofthis Application, the Company represents as follows:
INTRODUCTION
l. Rocky Mountain Power is an electrical corporation and public utility in the state of
Idaho, subject to the jurisdiction of the Commission, with regard to its rates, service, and
accounting practices, $ 6l-129. PacifiCorp also provides retail electricity service in the states of
I In the Matter of the Application of Rocly Mountain Powerfor an Order Exlending the ShortTerm Debt
Authorities Five Years, Order No. 34927.
)
)
)
)
)
APPLICATION OF
ROCKY MOUNTAIN POWER
Page I
Califomia, Oregon, Utah, Washington, and Wyoming. Rocky Mountain Power's business address
is 1407 West North Temple, Salt Lake City, Utah 84116.
COMMT'NICATIONS
2. Communications regarding this Application should be addressed to:
Ted Weston
Manager, Regulation
Rocky Mountain Power
1407 WestNorth Temple, Rm 330
Salt Lake City, UT 841l6
Telephone: [phone]
E-mail : ted.weston@nacifi corp.com
Joe Dallas
Senior Attomey
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR97232
Telephone: [phone]
E-mail : i oseph.dal las@pacifi com.com
In addition, Rocky Mountain Power respectfully requests that all data requests regarding
this matter be addressed to:
By e-mail (prefened):
By regular mail:
datareo ue st@frac i fi corp.com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
Informal inquiries may be directed to Ted Weston, State Manager [phone]
APPLICATION OF
ROCKY MOUNTAIN POWER
PageZ
BACKGROUND
3. On February 24,2006, PacifiCorp filed an Application2 requesting authorization to
borrow not more than $1.5 billion aggregate principal amount in short-term debt through April 30,
2011. On March 14,2006, the Commission granted the Company's Application in Order No.
29999.
4. On March 9,201l, the Company requested3 that the authorities granted under Case
No. PAC-E-06-01 be extended for an additional five years, or through April 30, 2016, on the
condition that the Company's senior secured debt be rated at "investment grade" by both Standard
& Poor's Rating Service and Moody's Investor Services, Inc. On April 8, 2011 the Commission
granted the Company's application in Order No.32221.
5. On January 26,2016, the Company requesteda that the authorities granted under
Case No. PAC-E- I I -09 be extended for an additional five years, or through April 30, 2021 , on the
condition that the Company's senior secured debt be rated at "investment grade" by both Standard
& Poor's Rating Service and Moody's Investor Services, Inc. On March 4,2016 the Commission
granted the Company's application in Order No. 33476.
6. On January 25,2021, the Company requesteds that the authorities granted under
Case No. PAC-E-16-03 be extended for an additional five years, or through April 30, 2026, onthe
condition that the Company's senior secured debt be rated at ooinvestment grade" by both Standard
& Poor's Rating Service and Moody's Investor Services, Inc. On February 23, 2021 the
Commission granted the Company's application in Order No. 34927.
2 In the Matter of the Application of PacifiCorp for authority to (l) issue its promissory notes to and boruow from
commercial bonl<s for (a) not more than $l .5 billion under revolving credit agreements, and (b) not more than $1.5
billion under other boruowing aruangements; and (2) issue and sell ils commercial paper in principal amounls not lo
exceed $1.5 billion outstanding at any one time. Case No. PAC-E-06-01.
3 Case No. PAC-E-I l-09.
a Case No. PAC-E-16-03.
5 Case No. PAC-E-21-02.
APPLICATION OF
ROCKY MOUNTATN POWER
Page 3
REQUEST
7. The Company respectfully requests that the Commission increase these short term
debt authorities through November 30,2027, by authorizing the Company to issue, from time to
time, its 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 $2.0 billion in aggregate
principal amount outstanding at any one time under one or more revolving credit agreements
("Agreements"); and (b) not more than $2.0 billion in aggregate principal amount outstanding at
any one time under other borrowing arrangements ("Other Arrangements"). The Company also
respectfully request authorization to issue and sell its commercial paper ("Paper") in the U.S. or
overseas, from time to time through November 30, 2027, in aggregate principal amounts not to
exceed $2.0 billion outstanding at any one time; provided that the aggregate principal amounts
outstanding under the Agreements, Other Arrangements and Paper not exceed $2.0 billion at any
one time.
8. The Company currently has a $1.2 billion revolving credit agreement expiring June
30,2025 with one remaining one-year extension option subject to lender consent. Under the terms
of the agreement, the Company may borrow up to the full amount or have letters of credit issued
in an amount up to $300 million or a combination thereof.
9. As noted above, Rocky Mountain Power's authority to enter into these revolving
credit agreements has been in place since 2006. Through the growth of the Company's load and
customer base and the continued investment that is necessary to support Company operations,
Rocky Mountain Power is seeking to increase its ability to issue commercial paper, which will in
turn be backed by these revolving debt agreements. PacifiCorp's capital expenditure program has
grown significantly in size recently due to adding new renewable generation resources, associated
APPLICATION OF
ROCKY MOLI'NTAIN POWER
Page 4
transmission and investments wildfire mitigation assets to meet the needs of PacifiCorp's
customers and the policy objectives of PacifiCorp's state regulatory commissions. PacifiCorp
expects that these new or amended facilities will have terms comparable to the existing credit
agreement and reflective of then-current market conditions.
MODIFIED PROCEDTIRE
10. Rocky Mountain Power believes that consideration of the proposals contained in
this Application do not require an evidentiary proceeding, and accordingly the Company requests
that this Application be processed under RP 201 allowing for consideration of issues under
Modified Procedure, i.e., by written submissions rather than by an evidentiary hearing.
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission issue
an order on this matter on or before December 15,2022, increasing the short-term debt authorities
described herein through November 30,2027, on the condition that the Company's senior secured
debt be rated at "investment grade" by both Standard & Poor's Rating Service and Moody's
Investor Services, Inc. The Company also respectfully requests twenty (20) certified copies of the
Commission's final order in this matter.
DATED: October 28,2022
Respectfully submitted,
J-
Joe Dallas
Attorney for Rocky Mountain Power
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 5