~;liam R. Griffith . I.! PACIFIC POWER A DIVISION OF PACIFICORP. November 20, 2012 VIA ELECTRONIC FILING AND OVERNIGHT DELIVERY

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1 PACIFIC POWER A DIVISION OF PACIFICORP 5 NE Multnomah, Suite 000 Portland, Oregon 9 November 0, 0 VIA ELECTRONIC FILING AND OVERNIGHT DELIVERY Oregon Public Utility Commission 550 Capitol Street NE, Suite 5 Salem, OR Attn: RE: Filing Center Application ofpacificorp for a Deferred Accounting Order For Network Damage from November 0 Storm Enclosed for filing by PacifiCorp d.b.a. Pacific Power is an original and five copies of an Application for a Deferred Accounting Order for Network Damage from the November 0 storm. A copy of the enclosed Notice has been served on all parties in Docket UE 4 as indicated on the attached Certificate of Service. Informal inquiries may be directed to Bryce Dalley at (50) -9.. I.! Very truly yours, ~;liam R. Griffith Vice President, Regulation Enclosures cc: Service List UE 4

2 CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing document, in Docket UE 4, on the date indicated below by , addressed to said parties at his or her last-known address(es) indicated below. Kurt J. Boehm (W)(C) Boehm Kurtz & Lowry E. Seventh St., Suite 50 Cincinnati, OH 450 kboehm@bkllawfirm.com OPUC Dockets (W) Citizens' Utility Board of Oregon 0 SW Broadway, Suite 400 Portland, OR 905 dockets@oregoncub.org G. Catriona McCracken (W)(C) Citizens' Utility Board of Oregon 0 SW Broadway, Suite 400 Portland, OR 905 catriona@oregoncub.org Melinda J. Davison (W)(C) Davison Van Cleve PC SW Taylor, Suite 400 Michael T. Weirich (W)(C) Department of Justice Regulated Utility & Business Section Court St. NE Salem, OR Michael.weirch@doj.state.or.us Johanna Riemenschneider (W)(C) PUC Staff- Dept of Justice Business Activites Section Court St NE Salem, OR Jody Kyler (W)(C) Boehm Kurtz & Lowry E. Seventh St. Ste 5 0 Cincinnati, OH 450 jkyler@bkllawfirm.com Robert Jenks (W)(C) Citizens' Utility Board of Oregon 0 SW Broadway, Suite 400 Portland, OR 905 Bob@oregoncub.org Irion A Sanger (W)(C) Davison Van Cleve SW Taylor- Ste 400 mail@dvclaw.com Kevin Higgins (W)(C) Energy Strategies 5 State St., Suite 00 Salt Lake City, UT 4- Khiggins@energystrat. com John W. Stephens (W)(C) Esler Stephens & Buckley SW 5th Ave Ste 00-0 stephens@eslerstephens.com mec@eslerstephens.com Wendy Gerlitz (W)(C) NW Energy Coalition 05 SE Favel Portland, OR 90 wendy@nwenergy.org Jeremy Fisher (W)(C) Synapse Energy 45 Massachusetts Ave, Ste Cambridge, MA 09 Sarah Wallace (W)( C) Pacific Power 5 NE Multnomah St Ste 00 Bryce Dalley (W)(C) Pacific Power 5 NE Multnomah St., Suite 000 Bryce.dalley@pacificorp.com Oregon Dockets (W) Pacific Power 5 NE Multnomah St., Suite 000

3 Donald W Schoenbeck (W)(C) Regulatory & Cogeneration Services, Inc 900 Washington St, Ste 0 Vancouver, WA Gloria D. Smith (W)(C) Sierra Club Law Program 5 Second St San Francisco, CA 9405 Randall Dahlgren (W) Portland General Electric SW Salmon St., WTC00 Deborah Garcia (W)(C) Oregon Public Utility Commission PO Box4 Salem, OR 90-4 deborah. garcia@state. or. us Jimmy Lindsay (W)(C) Renewable Northwest Project 4 SW th Ave #5-9 jimmy@rnp.org Stuart Robertson (W) Robertson-Bryan, Inc 9 Kent Street Elk Grove, CA 954 William Ganong (W)(C) 54 Walnut Avenue Klamath Falls, OR 90 Douglas C. Tingey (W) Portland General Electric SW Salmon St., WTC doug.tingey@pgn.com Megan Walseth Decker (W)(C) Renewable Northwest Project 4 SW th Ave #5-9 megan@rnp.org Derek Nelson (W)(C) Sierra Club Law Program 5 Second St, nd Floor San Francisco, CA 9405 derek.nelson@sierraclub.org Kevin E. Parks (W) Parks Law Offices LLC 0 SW 4 h Ave. Ste 0 kevin@parks-law-offices.com Hollie Cannon (W)(C) Klamath Water and Power Agency 5 Commercial St Ste 4000 Klamath Falls, OR 90 Hollie.cannon@kwapa.org DATED: November 0, 0 Amy Eissler Coordinator, Regulatory Operations

4 BEFORE THE PUBLIC UTILITY COMMISSION OF OREGON UM 4 In the Matter of the Application of P ACIFICORP for a Deferred Accounting 5 Order For Network Damage from November 0 Storm PACIFIC POWER'S APPLICATION FOR DEFERRED ACCOUNTING I. INTRODUCTION 9 Under ORS 5.59 and OAR , PacifiCorp dba Pacific Power (or the 0 Company) applies to the Commission for an order authorizing the Company to defer from November 0, 0 forward the costs associated with network damage from a severe rain and windstorm on the Oregon coast beginning on November 9,0. II. NOTICE 4 Communications regarding this application should be addressed to: 5 Oregon Dockets PacifiCorp 5 NE Multnomah, Suite 000 Telephone: (50) -9 oregondockets@pacificorp.com Ryan Flynn General Counsel Pacific Power 5 NE Multnomah, Suite 000 Telephone: (50) ryan.flynn@pacificorp.com 9 In addition, PacifiCorp respectfully requests that all data requests regarding this 0 matter be addressed to: 4 5 By (preferred) By regular mail By facsimile datarequest@pacificorp.com Data Request Response Center PacifiCorp 5 NE Multnomah, Suite 000 (50) -00 Page PACIFICORP'S APPLICATION FOR DEFERRED ACCOUNTING

5 III. DEFERRED ACCOUNTING RULE REQUIREMENTS The following information is provided pursuant to the requirements set forth in OAR (). 4 A. 5 Description of Utility Expense. Beginning on November 9, 0, parts of the Company's Oregon service area experienced a severe rain and windstorm that caused extensive outages. An estimated 0,000 customers had service interruptions throughout the Pacific Power service territory stretching from Astoria to Bandon, Central Oregon and the southern Willamette Valley. 9 Pacific Power activated its Virtual Emergency Action Center at approximately 0:45 a.m. 0 on November 9, 0 to mobilize personnel to respond to the event. Pacific Power's first priority has been customer safety and power restoration so a complete assessment of the damages is not yet available. B. Reasons for Deferral. 4 Pacific Power's request for deferral results from damage caused by a severe storm. In 5 establishing generic guidelines for deferred accounting in UM 4, the Commission made clear that deferred accounting was designed to cover costs associated with this type of unanticipated and undeniably serious triggering event. See In re Investigation Related to Deferred Accounting, Order No , Docket UM 4 (005). 9 This Application for deferred accounting permits the Commission to support Pacific 0 Power's efforts to respond responsibly to the November 0 storm by immediately addressing all safety and service concerns, and conducting subsequent assessment of damage and repairs costs and options. In UM 4, the Commission made clear that it had discretion and flexibility to allow deferred accounting to encourage utility behavior 4 consistent with good regulatory policy. Order No at. 5 ORS 5.59()(e) allows the deferral of utility expenses or revenues where necessary to match appropriately the costs borne by and the benefits received by customers. Page PACIFICORP'S APPLICATION FOR DEFERRED ACCOUNTING

6 This standard requires flexibility and an examination of the facts of the case. Order No at 4-5. This request seeks to align the costs of Pacific Power's network service with the benefits customers receive from such service. 4 C. Proposed Accounting. 5 During the period of deferral, Pacific Power proposes to account for the deferred costs of the storm by recording the deferral in Account., Other Regulatory Assets. Pacific Power requests that in accordance with ORS 5.59(), it be allowed to accrue interest on the unamortized balance at a rate equal to its weighted average cost of capital 9 most recently approved by the Commission. Amortization of the balance would be 0 considered in a subsequent proceeding coincident with inclusion in rates. D. Estimate of Amounts. Pacific Power will supplement this Application with an estimate of the costs of the storm damage as soon as these are available. In the event the costs are fully covered by the 4 Company's self-insurance reserves, Pacific Power will withdraw this Application. 5 E. Notice. A copy of the Notice of Application and a list of persons served with the Notice are attached to this Application as Exhibit A On Aprill, 0, the Company began using self-insurance accruals and associated reserve balances for transmission and distribution property losses, non-transmission and distribution property losses, and third-party 5 liability insurance. In paragraph 5 of the stipulation in Docket UE, the parties agreed that the Company may file deferrals for property and liability costs in excess of the self-insured reserve balances. The Commission approved the stipulation in Order No. 0-4 on December 4, 00. Page PACIFICORP' S APPLICATION FOR DEFERRED ACCOUNTING

7 4 5 IV. CONCLUSION Pacific Power respectfully requests that, in accordance with ORS 5.59, the Commission authorize the Company to defer the costs described in this Application. DATED: November 0, Page 4 PACIFICORP'S APPLICATION FOR DEFERRED ACCOUNTING

8 4 5 EXHIBIT A

9 BEFORE THE PUBLIC UTILITY COMMISSION OF OREGON UM In the Matter of Application of 4 P ACIFICORP for a Deferred Accounting NOTICE OF APPLICATION Order For Network Damage from November 5 0 Storm On November 0, 0, Applicant PacifiCorp dba Pacific Power applied to the Public Utility Commission of Oregon (the "Commission") for authorization to use deferred 9 accounting. Pursuant to ORS 5.59, Pacific Power proposes to defer for later recovery 0 costs associated with network damage from a severe rain and windstorm that struck Oregon beginning on November 9, 0. The granting of the Application will not authorize a change in rates, but will permit the Commission to consider allowing such deferred accounts in rates in a subsequent 4 proceeding. 5 9 Interested persons can obtain a copy of the Application by contacting: Bryce Dalley PacifiCorp 5 NE Multnomah St., Ste. 000 Telephone: (50) -9 0 Any person may submit to the Commission written comment on the Application, in accordance with procedures prescribed by the Commission. The deadline for comments on the Application is December, 0. 4 DATED this 0th day ofnovember 0. 5 Page NOTICE OF APPLICATION

UM XXXX- PGE's Application for the Deferral Accounting of Storm-Related Restoration Costs

UM XXXX- PGE's Application for the Deferral Accounting of Storm-Related Restoration Costs Portland General Electric Company 121 SW Salmon Street Portland, Oregon 97204 Portland General.com January 11, 2017 E-Mail puc.filingcenter@state.or.us Public Utility Commission of Oregon 201 High St.,