20230907Notice_of_Application_Order_No_35913.pdf

NOTICE OF APPLICATION NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35913 1
Service Date September 7, 2023
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF ROCKY MOUNTAIN POWER’S APPLICATION FOR A DEFERRED ACCOUNTING ORDER RELATED TO INSURANCE COSTS
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NOTICE OF APPLICATION NOTICE OF MODIFIED PROCEDURE

On August 21, 2023, Rocky Mountain Power, a division of PacifiCorp (“Company”),
applied for authority to defer incremental costs associated with the Company’s commercial
insurance coverage. The Company proposes to defer Idaho’s allocated share of the incremental
costs for insurance coverage. The Company estimates the incremental cost to be $92.3 million—
the difference between the $32.7 million already included in rates and estimated insurance costs
of $125 million for policy period beginning August 15, 2023, or later. The Company would record
the incremental costs as a regulatory asset in Federal Energy Regulatory Commission (“FERC”)
Account 182.3-Other Regulatory Assets.
The Commission now provides this Notice of Application and establishes comment
deadlines for interested persons and the Company’s reply.
NOTICE OF APPLICATION
YOU ARE HEREBY NOTIFIED that the Company represents that commercial
liability insurance, including wildfire liability insurance, is a prudent business expense that
protects both the Company and customers against financial losses from third-party claims.
YOU ARE FURTHER NOTIFIED that the Company represents that its current rates
were approved to reflect a reasonable level of commercial insurance covering third-party claims.
YOU ARE FURTHER NOTIFIED that the Company represents that wildfire risks for
utilities in the western United States have radically changed in the last few years, leaving it unable
to obtain such insurance at past premiums due to increasing costs resulting from such fires.
YOU ARE FURTHER NOTIFIED that the Company represents that its current utility
rates already include $32.7 million for commercial liability insurance. However, the Company
NOTICE OF APPLICATION NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35913 2
estimates that commercial insurance coverage for a policy period beginning August 15, 2023, or
later will cost approximately $125 million.
YOU ARE FURTHER NOTIFIED that the Company proposes recording Idaho’s
allocable share of the $92.3 million difference between the new cost and the amount currently in
rates a regulatory asset in FERC Account 182.3 until the Company proposes recovery of the costs
in its next general rate case.
YOU ARE FURTHER NOTIFIED that the Company acknowledges that approval of
the requested deferral does not constitute approval of the recovery of those costs, which would
occur (if at all) in a future case after careful review of whether such recovery is fair, just, and
reasonable.
YOU ARE FURTHER NOTIFIED that the Application and Attachments are available
for public inspection during regular business hours at the Commission’s office. These documents
are also available on the Commission’s website at www.puc.idaho.gov. Click on the “ELECTRIC”
icon, select “Open Cases,” and click on the case number as shown on the front of this document.
YOU ARE FURTHER NOTIFIED that all proceedings in this case will be held
pursuant to the Commission’s jurisdiction under Title 61 of the Idaho Code.
YOU ARE FURTHER NOTIFIED that all proceedings in this matter will be conducted
pursuant to the Commission’s Rules of Procedure, IDAPA 31.01.01.000 et seq.
NOTICE OF MODIFIED PROCEDURE
YOU ARE FURTHER NOTIFIED that the Commission has determined that the public
interest may not require a formal hearing in this matter, and it will review the case through written
submissions under the Commission’s Rules of Modified Procedure Rules 201-204 of the Idaho
Public Utilities Commission’s Rules of Procedure, IDAPA 31.01.01.201-204. The Commission
notes that Modified Procedure and written comments have proven to be an effective means for
obtaining public input and participation.
YOU ARE FURTHER NOTIFIED that persons desiring to state a position on this
Application may file a written comment explaining why they support or oppose the Application.
Persons who would like a hearing must specifically request a hearing in their written comments.
Persons shall have until November 9, 2023, to file written comments. Comments must be filed
through the Commission’s website or by e-mail unless computer access is unavailable. To
NOTICE OF APPLICATION NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35913 3
comment electronically, please access the Commission’s website at www.puc.idaho.gov. Click the
“Case Comment Form” and complete the form using the case number as it appears on the front of
this document. To file by e-mail, the customer must e-mail the comments to the Commission
Secretary and the Company at the e-mail addresses listed below. If computer access is unavailable,
then comments may be mailed to the Commission and Company at these addresses:

YOU ARE FURTHER NOTIFIED that the Company must file any reply comments by
November 30, 2023.
YOU ARE FURTHER NOTIFIED that if no written comments or protests are received
within the time limit set, the Commission will consider this matter on its merits and enter its order
without a formal hearing. If written comments are received within the time limit set, the
Commission will consider them and, in its discretion, may set the same for formal hearing.
O R D E R
IT IS HEREBY ORDERED that the Company’s Application be processed by Modified
Procedure, Rules 201-204. Persons interested in submitting written comments must do so by
November 9, 2023. The Company must file any reply comments by November 30, 2023.
IT IS FURTHER ORDERED that parties comply with Order No. 35375, issued April
21, 2022. Generally, all pleadings should be filed with the Commission electronically and will be
deemed timely filed when received by the Commission Secretary. See Rule 14.02. Service between
For the Idaho PUC: Commission Secretary Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074 [e-mail] Street Address for Express Mail:

11331 W. Chinden Blvd. Building 8, Suite 201-A Boise, ID 83714
For Rocky Mountain Power: Mark Alder Rocky Mountain Power
1407 W. North Temple, Suite 330
Salt Lake City, UT 84116 [e-mail] [e-mail] [e-mail]

Data Request Response Center Rocky Mountain Power 825 NE Multnomah St., Suite 2000 Portland, OR 97232
[e-mail]
NOTICE OF APPLICATION NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35913 4
parties should continue to be accomplished electronically when possible. However, voluminous
discovery-related documents may be filed and served on CD-ROM or a USB flash drive.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 7th day
of September 2023.

ERIC ANDERSON, PRESIDENT

JOHN R. HAMMOND JR., COMMISSIONER

EDWARD LODGE, COMMISSIONER

ATTEST:
Jan Noriyuki
Commission Secretary
I:\Legal\ELECTRIC\PAC-E-23-18\orders\PACE2318_Ntc of App_Mod_at.docx