20250508Staff Comments.pdf

RECEIVED
ADAM TRIPLETT Thursday, May 08, 2025
DEPUTY ATTORNEY GENERAL IDAHO PUBLIC
UTILITIES COMMISSION
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 THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR A ) CASE NO. PAC-E-25-05
DEFERRED ACCOUNTING ORDER )
RELATED TO CHEHALIS COMPLIANCE )
COSTS ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Adam Triplett, Deputy Attorney
General, submits the following comments.
BACKGROUND
On March 28, 2025, Rocky Mountain Power, a division of PacifiCorp, ("Company")
applied to the Commission requesting an accounting order authorizing the Company to record a
regulatory asset associated with the costs associated with the Company's 2024 Energy Cost
Adjustment Mechanism (`SCAM") rate adjustment of approximately $2.33 million, representing
the costs incurred by the Company to comply with the Washington Climate Commitment Act
("WCCA").
The Company's appeal of the Commission's Order Nos. 36207 and Order No. 36367, in
which the Commission disallowed recovery of$2.3 million in costs the Company incurred to
STAFF COMMENTS 1 MAY 8, 2025

comply with the WCCA in the Company's 2023 ECAM, is currently pending before the Idaho
Supreme Court.
The Company states it 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 will
allow that proceeding to conclude more efficiently.
The Company proposes tracking its 2024 WCCA compliance costs in a separate deferral
account. Once the Idaho Supreme Court issues its opinion in the appeal of Order Nos. 36207
and Order No. 36367, the Company will seek recovery of these costs if appropriate.
The Company estimates Idaho's share of the WCCA compliance costs it incurred during
the 2024 ECAM deferral period to be about $2.33 million.
STAFF ANALYSIS
Staff reviewed the Company's Application, including supporting testimony,
documentation of WCCA compliance costs, and the procedural context surrounding the
Company's pending appeal before the Idaho Supreme Court. Staff supports the Company's
proposal to defer WCCA related costs in a separate regulatory deferral account until the Idaho
Supreme Court issues a final decision. In addition to the Company's proposal, Staff
recommends that no carrying charge be applied to the deferral balance.
Removing the WCCA costs from the 2024 ECAM filing benefits all parties. If the
WCCA costs were included for recovery in the Company's ECAM Application, Staff believes
the Commission would likely deny recovery of these costs based on prior Commission directives
that prohibit recovery of WCCA related expenses'. Removing the WCCA costs simplifies the
case, reduces procedural complexity, and allows for a more efficient review process. Customers
also benefit because removing WCCA costs reduces the rates in the ECAM and minimizes the
Company's legal expenses by not having to appeal a second ECAM decision to the Idaho
Supreme Court.
Although not specifically addressed in the Company's Application, Staff would oppose
any carrying charge on the deferral balance that the Company may request. By removing
WCCA related costs from the ECAM, the Company benefits from cost savings by avoiding
1 Commission Order No. 36207
STAFF COMMENTS 2 MAY 8, 2025

certain administrative and regulatory expenses. Applying a carrying charge to the deferral
balance would result in unwarranted financial benefit to the Company.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's proposal to exclude
WCCA costs from the 2024 ECAM filing and to defer WCCA related costs in a separate
regulatory deferral account until a final decision is issued by the Idaho Supreme Court.
Additionally, Staff recommends that no carrying charge be applied to the deferral balance.
Respectfully submitted this 8th day of May 2025.
Adam Triplett
Deputy Attorney General
Technical Staff. Ty Johnson
L\Utility\UMISC\COMMENTS\PAC-E-25-05 Comments.docx
STAFF COMMENTS 3 MAY 8, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF MAY 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-25-05, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
MARK ALDER DATA REQUEST RESPONSE CENTER
ROCKY MOUNTAIN POWER E-MAIL ONLY:
1407 WEST NORTH TEMPLE STE 330 [e-mail]
SALT LAKE CITY UT 84116 carla.scarsella(aificorp.com
E-MAIL: mark.alder cr�pacificorp.com
JOE DALLAS
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH, SUITE 2000
PORTLAND, OR 97232
E-MAIL: joseph.dallasgpacificorp.com
PATRICIA JORDAN, S CRETARY
CERTIFICATE OF SERVICE