20250514Reply Comments.pdf

_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
RECEIVED
M
May 14, 2025 May 14, 2025
IDAHO PUBLIC
VIA ELECTRONIC DELIVERY 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
Pursuant to Commission Order No. 36580 providing public notice of the Company's Application,
Notice of Modified Procedure, and establishing the procedural schedule please find Rocky
Mountain Power's Reply Comments in the above referenced matter.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313.
Very truly yours,
a'l-D
Joe Steward 9L
Senior Vice President, Regulation

Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallas(a)pacificorp.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. PAC-E-25-05
OF ROCKY MOUNTAIN POWER FOR A )
DEFERRED ACCOUNTING ORDER ) REPLY COMMENTS OF
RELATED TO CHEHALIS COMPLIANCE ) ROCKY MOUNTAIN POWER
COSTS )
Pursuant to Rule 202.01(d) of the Rules of Procedure of the Idaho Public Utilities
Commission("Commission") and the Commission's April 25, 2025,Notice of Application and of
Modified Procedure, Rocky Mountain Power a division of PacifiCorp (the "Company") hereby
submits reply comments in the above-referenced case.
I. BACKGROUND
On March 28, 2025, the Company applied for an accounting order authorizing the
Company to record a regulatory asset for 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. On April 25, 2024, Commission Order No. 36580 provided public notice of the
Company's Application, Notice of Modified Procedure, and established the procedural schedule
'RCW§ 70A.65.005-70A.65-901 (2024).
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allowing persons who would like to file written comments to have until May 8, 2025, and the
Company having until May 15, 2025, to file reply comments.
2. On May 8, 2025, Commission Staff("Staff') filed comments recommending the
Commission approve the Company's proposal and also recommending no carrying charge to be
applied to the deferral balance.
II. REPLY COMMENTS
3. The Company appreciates Staff s support for deferring the WCCA compliance costs
associated with the Chehalis Generating Facility. The only area of disagreement is whether a
carrying charge should be applied to the deferral balance. The Company respectfully requests that
the Commission allow a carrying charge consistent with how all other deferred net power costs are
treated.
4. It is a well-established regulatory principle that a carrying charge is appropriate to
compensate the Company for the time value of money when it incurs costs on behalf of customers
that are not immediately recovered in rates. Denying a carrying charge would mean that the
Company is providing interest-free financing for these WCCA compliance costs until a future
recovery decision is made, which is not an equitable outcome. Deferred costs are not included in
rates and carrying charges allows the recovery of prudent financing costs (i.e., loan interest) a
utility may incur.
5. Furthermore, allowing a carrying charge on the Chehalis deferral is consistent with
established Commission practice. The Commission currently allows the Company to accrue a
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carrying charge, set at the customer deposit rate, on its ECAM deferral balance.' Applying this
same principle to the WCCA deferral ensures consistency and fairness.
6. Staff suggests the Company benefits from cost savings by separating these WCCA
costs from the main ECAM filing but any administrative efficiencies through the establishment of
the deferral are difficult to quantify. The purpose of the deferral is to avoid seeking recovery of
costs associated with the WCCA in the pending 2024 ECAM proceeding in Docket No. PAC-E-
25-04. This approach provides administrative efficiency by removing these costs from the 2024
ECAM, thereby avoiding the need to relitigate and file any secondary appeal while the appeal in
Docket No. PAC-E-24-05 is pending. The WCCA costs sought to be deferred are net power costs,
to which the Commission routinely allows a carrying charge to regulated utilities. For the
Commission to only not allow carrying charges on deferred power costs that are subject to an
appeal, seems to be contrary to the public interest. Furthermore, any administrative efficiencies
that the Company does gain through the establishment of a deferral account does not directly
compensate the Company for losing the time value of money on the deferral account while the
costs are being disputed.
7. In summary, if the Company is ultimately allowed to recover the Chehalis
Compliance costs, it should be fully compensated by being able to include a carrying charge on
the approximately $2.33 million in deferred WCCA compliance costs now.
2 In the Matter of the Application of Rocky Mountain Power for Approval of an Energy Cost Adjustment Mechanism
("ECAM'), Case No.PAC-E-08-08,Order No. 30904 at p.4(September 29,2009).
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III. REQUEST FOR RELIEF
8. Based on the foregoing, the Company respectfully requests that the Commission
approve its application as filed and allow a carrying charge on the deferral balance equal to the
customer deposit rate.
DATED this 14th day of May 2025.
Respectfully submitted,
ROCKY MOUNTAIN POWER
Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email: joseph.dallas(&j2acificorp.com
Attorney for Rocky Mountain Power
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