20240913Motion to Suspend Effective Date.pdf

RECEIVED
Friday,September 13,2024
IDAHO PUBLIC
ADAM TRIPLETT UTILITIES COMMISSION
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )
POWER'S APPLICATION FOR AUTHORITY ) CASE NO. PAC-E-24-04
TO INCREASE ITS RATES AND CHARGES IN )
IDAHO )
MOTION TO SUSPEND THE
EFFECTIVE DATE OF NEW
RATES
Staff of the Idaho Public Utilities Commission ("Staff'), by and through its attorney of
record, Adam Triplett, Deputy Attorney General, pursuant to Commission Rules of Procedure
("Rule") 056, 123, 256, and 322 IDAPA 31.01.01 et seq., does hereby move for an Order
suspending for 60 days the Company's proposed effective date of January 1, 2025 for new rates.
BACKGROUND
In this case, PacifiCorp dba Rocky Mountain Power ("Company") seeks authority to
increase its Idaho jurisdictional revenue requirement by $92.4 million, or approximately 26.8
percent. The Company proposes the first increase of$66.7 million, or 19.4 percent, take effect on
MOTION TO SUSPEND THE
EFFECTIVE DATE OF NEW RATES 1

January 1, 2025, and a second increase of$25.7 million, or 7.4 percent, take effect on January 1,
2026.
As described more thoroughly below,the Company's simultaneous pursuit of multiple rate
cases in states across its service territory has ostensibly stretched its resources, slowing the
discovery process. Additionally, attempting to accommodate the Company's scheduled rate case
hearings in other jurisdictions combined with the Commission's busy calendar has made
scheduling a technical hearing on a date for which the parties could adequately prepare while still
leaving the Commission sufficient time to issue an order before the current effective date of
January 1, 2025, has been very difficult. Accordingly, Staff requests that the Commission suspend
the proposed January 1, 2025, effective date for new rates for a period of 60 days. This would
ensure that there is sufficient time for the parties to complete discovery, hold a technical hearing,
and issue a written final order before the effective date of the proposed rate increases.
MOTION TO SUSPEND THE PROPOSED EFFECTIVE DATE OF NEW RATES
The Commission has authority to suspend the proposed effective date of any new rate. See
Idaho Code § 61-622. After initially suspending a new rate for 5 months and 30 days, the
Commission may extend the suspension by an additional 60 days for good cause shown.' Id. Any
further suspension must be with the written consent of the parry proposing the rate increase. Id.
To provide appropriate testimony and recommendations related to the Company's
Application to increase its rates, Staff must evaluate the proposed increases and determine whether
they are fair, just, and reasonable. This analysis requires Staff to review significant amounts of
information provided by the Company covering a wide range of topics,including financial records,
contracts, capital investments, and power cost forecasts. Despite diligent efforts and the
Company's general cooperativeness, Staff has been unable to complete its review of the
Company's financial records. Of the 256 Production Requests Staff has propounded (at the time
of this filing), the Company has requested extended response times for at least 38 of them.2
1 In this case,the Company requested an effective date of January 1,2025,but indicated this date was in anticipation
of suspension.Apparently,the Commission did not interpret this as an implicit request for an effective date in July of
2024,as the Commission did not expressly exercise its authority to suspend the Company's proposed effective date.
Staff asserts that it is unnecessary to determine whether the Commission may suspend the proposed January 1,2025,
effective date for five months and 30 days as,for the reasons stated in this motion,there is good cause for a suspension.
2 Five of these Production Requests had shortened 14-day response times for which the Company requested a one-
week extension. Staff began propounding production requests with this shortened response time in August of 2024 to
expedite the completion of discovery,develop testimony,and prepare for settlement negotiations.
MOTION TO SUSPEND THE
EFFECTIVE DATE OF NEW RATES 2

Additionally, considering the current progress of discovery, the only workable date in the
Commission's calendar to schedule a technical hearing is December 16, 2024, through December
18, 2024. However, the website of the Utah Public Service Commission ("UPSC") indicates that
the Company has hearings scheduled before the UPSC associated with a pending rate case there
on December 16th and 17th 3 For these reasons, Staff asserts that good cause exists for the
Commission to suspend the current January 1, 2025, effective date for new rates for an additional
60 days.4
Staff provided actual notice of the substance of this Motion to the Company by email on
September 12, 2024. Staff believes that pursuant to Rule of Procedure 256.03, IDAPA
31.01.01.256.03, the factual circumstances (including the Company's consent to the relief
requested herein)warrant immediate review of its Motion and enables the Commission to consider
this Motion and offer the relief requested on fewer than 14 days' notice.Accordingly, Staff request
that the Commission consider this motion during its September 24, 2024, decision meeting.
CONCLUSION
Staff respectfully requests that the Commission issue an order suspending the Company's
proposed effective date of January 1, 2025, for new rates for an additional period of 60 days.
DATED at Boise, Idaho, this 13ffi day of September 2024.
Adam Triplett
Deputy Attorney General
s A calendar of events can be found on the main page of the Utah Public Service Commission at https://psc.utah.zov/.
4 Staff notes that granting the additional 60-day suspension would not prevent the Commission issuing an order
approving and putting into effect new rates for the Company prior to expiration of the suspension period.
MOTION TO SUSPEND THE
EFFECTIVE DATE OF NEW RATES 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE ON THIS 13TH DAY OF SEPTEMBER 2024,
SERVED THE FOREGOING MOTION TO SUSPEND THE EFFECTIVE DATE OF NEW
RATES, IN CASE NO. PAC-E-24-04, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER CARLA SCARSELLA
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 825 NE Multnomah, Suite 2000
[e-mail] Portland, OR 97232
joseph.dallaskpacificorp.com
carla.scarsella@]2acificorp.com
DATA REQUEST RESPONSE CENTER
datarequestkpacificorp.c om
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 lance@ae ism hg t.com
elo&echohawk.com
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
[e-mail]
THOMAS J BUDGE BRIAN C COLLINS
RACINE OLSON PLLP GREG MEYER
PO BOX 1391 BRUBAKER&ASSOCIATES
POCATELLO ID 83204-1391 16690 SWINGLEY RIDGE RD#140
[e-mail] CHESTERFIELD MO 63017
[e-mail]
gme�(a),consultbai.com
KEVIN HIGGINS RONALD L WILLIAMS
NEAL TOWNSEND BRANDON HELGESON
ENERGY STRATEGIES LLC HAWLEY TROXELL ET AL
khiggins@energ_ystrat.com 877 W MAIN ST
ntownsend(aD,energystrat.com BOISE ID 83701
[e-mail]
bhel eg son(a),hawleytroxell.com
MOTION TO SUSPEND THE
EFFECTIVE DATE OF NEW RATES 4

BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITAFOS CONDA LLC
brmullinsgmwanalytics.com val.steinergitafos.com
KYLE WILLIAMS
BYU Idaho
williamskgbyui.edu
Keri J. Hawker
Assistant to Adam Triplett
I:U.egal\PAC-E-24-04\Motion to Suspend Effective Date.docx
MOTION TO SUSPEND THE
EFFECTIVE DATE OF NEW RATES 5