20250328Application.pdf

_ ROCKY MOUNTAIN 1407 W. North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
March 28, 2025
RECEIVED
VIA ELECTRONIC FILING March 28, 2025IDAHO PUBLIC
UTILITIES COMMISSION
Commission Secretary
Idaho Public Utilities Commission
11331 W Chinden Blvd.
Building 8 Suite 201A
Boise, ID 83714
Re: CASE NO. PAC-E-25-05
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
FOR A DEFERRED ACCOUNTING ORDER RELATED TO CHEHALIS
COMPLIANCE COSTS
Attention: Commission Secretary
Please find Rocky Mountain Power's electronic filing of this Application in the above referenced
matter.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Affairs Manager at
[phone].
Sincerely,
Joelle R. Steward
Senior Vice President, Regulation
Enclosures
CC: Chris McEwan

Joseph Dallas (ISB#10330)
825 NE Multnomah St., Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: joseph.dallaskpacificorp.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC SERVICE COMMISSION
IN THE MATTER OF THE ) CASE NO. PAC-E-25-05
APPLICATION OF ROCKY )
MOUNTAIN POWER FOR A )
DEFERRED ACCOUNTING ORDER ) APPLICATION FOR ACCOUNTING
RELATED TO CHEHALIS ) ORDER
COMPLIANCE COSTS )
Pursuant to I.C. § 61-524 and IDAPA 31.01.01.052, Rocky Mountain Power, a division of
PacifiCorp, ("Rocky Mountain Power" or the "Company"), applies to the Idaho Public Utilities
Commission ("Commission") for an accounting order authorizing the Company to record a
regulatory asset associated with the costs associated with Company's 2024 Energy Cost
Adjustment Mechanism ("2024 ECAM") rate adjustment of approximately $2.33 million,
representing the costs incurred by the Company to comply with the Washington Climate
Commitment Act ("WCCA").1
In support of this Application, Rocky Mountain Power states as follows:
I. Rocky Mountain Power is a public utility in the state of Idaho and is subject to the
jurisdiction of the Commission with regard to its rates and service. Rocky Mountain Power also
provides retail electric service in the states of Utah and Wyoming.
i RCW§70A.65.005-70A.65-901 (2024).
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2. Communications regarding this Application should be addressed to:
By e-mail (preferred): datarequest(&,pacificorp.com
mark.alderkpacific orp.com
j o seph.dallas(apacificorp.com
carla.scarsella(kpacificorp.com
By mail: Data Request Response Center
Rocky Mountain Power
825 NE Multnomah St., Suite 2000
Portland, OR 97232
Mark Alder
Rocky Mountain Power
1407 W. North Temple, Suite 330
Salt Lake City, UT 84116
Telephone: [phone]
3. On April 1, 2024,the Company filed its 2023 Energy Cost Adjustment Mechanism
("2023 ECAM")application for Commission authorization to adjust its rates under the ECAM and
requested approval of approximately $62.4 million in deferred costs from the deferral period
beginning January 1, 2023, through December 31, 2023, with a 10.5 percent overall increase to
Electric Service Schedule No. 94, Energy Cost Adjustment("Schedule 94").
4. On May 31, 2024, the Commission issued Order No. 36207 approving the
Company's application for recovery of the 2023 deferred costs with the exception of costs incurred
to comply with the WCCA. On June 21, 2024, the Company submitted a Petition for
Reconsideration requesting the Commission reconsider its decision to situs assign WCCA
compliance costs to Washington State and instead, apply the 2020 Protocol provisions as written,
and find that Chehalis remains a"System Resource" for cost allocation purposes.
5. The Commission granted the Company's Petition in Order No. 36274, and ordered
the parties to provide additional evidence and written comments regarding the disallowance from
the Company's 2023 ECAM rate adjustment of approximately$2.3 million,representing the costs
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incurred by the Company to comply with the WCCA. On September 6, 2024, Commission Staff
submitted comments on the Company's Petition and on September 20, 2024, the Company
submitted reply comments in response to Staff comments. On October 18, 2024 the Commission
issued Order No. 36367 Denying the Company's Petition for Reconsideration. On November 27,
2024, the Company filed a Notice of Appeal against Order No. 36207 and Order No. 36367 with
the Idaho Supreme Court.2 That case is currently pending with the Idaho Supreme Court.
6. On March 27, 2025, the Company filed its 2024 ECAM and excluded WCCA
compliance costs from its filing since the outcome of the appeal with the Idaho Supreme Court is
unknown. This approach allows the compliance costs to be removed from the 2024 SCAM,
allowing that proceeding to more efficiently administered, while having these costs tracked in a
separate deferral. The Company would be unfairly burdened if it is unable to track and potentially
recover the 2024 ECAM WCCA compliance costs if the Idaho Supreme Court finds these costs
justified.
7. These costs are prudently incurred expenses for generation from its natural gas
plant located in Chehalis, Washington that provides electric services to PacifiCorp customers in
Idaho. Failure to pay the compliance costs would have risked significant financial penalties for the
Company.
8. The WCCA compliance costs will remain in FERC Account 555-Purchased Power
whether this application is approved or denied. The Company may seek recovery of these costs in
a future ECAM filing once the outcome of all existing appeals is known.
9. PacifiCorp estimates that the WCCA compliance costs at $2.33 million (Idaho-
allocated) for the deferral period included in the 2024 ECAM.
Z Idaho Supreme Court Case No. 52508-2024
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10. The Company acknowledges that the Commission's approval of deferred
accounting treatment for these increased insurance costs will not, in itself, constitute approval of
ultimate recovery of those costs. Recovery of the costs would be subject to a prudence review and
a final decision on rate recovery in a future ECAM or general rate case filing.
11. Rocky Mountain Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be processed under Modified
Procedure, i.e.,by written submissions rather than by hearing, in accordance with RP 201 et seq.
WHEREFORE, Rocky Mountain Power respectfully requests an accounting order
authorizing it to record a regulatory asset to FERC Account 555 (Purchased Power). Recovery of
the WCCA compliance costs that will only be authorized through a subsequent regulatory filing.
DATED: March 28, 2025
Respectfully submitted,
z
Joseph Dallas (ISB#10330)
825 NE Multnomah St., Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: joseph.dallaskpacificorp.com
Attorney for Rocky Mountain Power
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