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Home My WebLink About20250714Staff Comments.pdf RECEIVED July 14, 2025 JEFFREY R. LOLL IDAHO PUBLIC DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0357 IDAHO BAR NO. 11675 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 ) FOR APPROVAL OF THE ASSET ) CASE NO. PAC-E-25-10 TRANSFER AGREEMENT BETWEEN ) ROCKY MOUNTAIN POWER AND THE ) CITY OF IDAHO FALLS—49TH N. ) COMMENTS OF THE COMMISSION STAFF COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission ("Commission"), by and through its attorney of record, Jeffrey R. Loll, Deputy Attorney General, submits the following comments. BACKGROUND On May 12, 2025, Rocky Mountain Power("Company"), a division of PacifiCorp, filed an application with the Commission requesting approval of an Asset Transfer Agreement ("Agreement")between the Company and the City of Idaho Falls ("City") for the City to purchase certain electric facilities currently owned and used by the Company to supply electric service to a customer("Customer"). The Company represents that the Customer has requested that the Customer's electric service be transferred from the Company to the City, and the Customer has been notified that the STAFF COMMENTS 1 JULY 14, 2025 Company has entered into the Agreement to transfer service. Application at 3. The Company and the City have agreed to transfer the electric service, and the City has agreed to purchase the facilities described in the Agreement. Id. STAFF ANALYSIS Staff reviewed the proposed transaction and believes that it supports the intent of the Electric Supplier Stabilization Act and is consistent with prior Commission orders. In the Application, the Company explains how this transaction complies with Idaho Code § 61-328(3) by: (a)promoting the public interest; (b) fairly compensating the Company for its transferred assets and that rates for supplying service will not be increased for existing customers; and(c) ensuring that the transferred customers will continue to receive electric service from a provider (the City)that has the bona fide intent and the financial ability to properly maintain this public service for the customer. Id. at 2-3. Staff also believes that the request is consistent with Idaho Code § 61-332(2) in that it is facilitating a harmonious transfer between electric suppliers. Staff believes the proposed transaction meets all the necessary statutory requirements and complies with the Commission's previous orders. Sales Price and Accounting Treatment Under the Agreement, the City would provide electric service to a residential Customer on E. 49th N. (exempt from public review under Idaho Code § 74-109(3) and Idaho Public Utilities Commission's Rule of Procedure 67), currently being supplied electric service by the Company. Id. at 1-4. The City will purchase electric facilities from the Company to serve the Customer and also compensate the Company for the lost revenues arising from the Customer's departure. Id. at 2-3. The Agreement defines "just compensation for lost revenues" as "an amount equal to 167 percent of the total of the respective Customers' electric bills from the prior twelve-month period of service." Id. The total sale price for the transaction is $24,317 as shown in Table No. 1. Agreement at 9. Staff verified that the sale price listed in the Agreement includes the replacement book value of the existing assets, the separation costs, the lost Customer's revenue, and the legal and transaction costs. The method used to generate the values is consistent with the method incorporated in the 2017 Service Allocation Agreement. The STAFF COMMENTS 2 JULY 14, 2025 Company's accounting treatment of the proceeds received from the sale of these assets assures other customers will not be affected by this transaction. Table No. 1: Calculation of Transaction Price Sale Components Totals Asset Valuation $ 3,716.00 Separation costs $ 1,825.00 Lost Customer's Revenue $ 17,276.00 Legal and Transaction Costs $ 1,500.00 Sales Price $ 24,317.00 The price of the existing assets was calculated by using the replacement value of each asset being sold, less depreciation. Depreciation was determined using straight-line methodology, consistent with prior Commission orders. The replacement value was determined using the Company's Retail Construction Management System. The separation costs are expenses incurred during the physical separation of the assets being sold from the Company's distribution system. Legal and transaction costs include the costs of accounting, finance, regulation, and legal expenses related to the sale. The last component of the total transaction price that Staff reviewed was the lost Customer's revenue. The Company presented the Customer's billing revenue for the 12-month period of February 2024 through January 2025. Agreement at 9-11. CUSTOMER NOTICE AND PUBLIC COMMENTS In accordance with Rule 125 of the Commission's Rules of Procedure (IDAPA 31.01.01), no Customer notice is required. As of July 14, 2025, no public comments have been received. STAFF RECOMMENDATION Staff recommends the Commission approve the Asset Transfer Agreement and authorize the transfer of electric service for the residential Customer on E. 49th N., Idaho Falls, Idaho between Rocky Mountain Power and the City of Idaho Falls. STAFF COMMENTS 3 JULY 14, 2025 Respectfully submitted this 14th day of July 2025. / 7;?�� Jeffrey R. Loll Deputy Attorney General Technical Staff: Leena Gilman 1:\Utility\UM1SC\COMMENTS\PAC-E-25-10 Comments.docx STAFF COMMENTS 4 JULY 14, 2025 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS DAY OF JULY 2025, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. PAC-E-25-10, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING: MARK ALDER DATA REQUEST RESPONSE CENTER JOE DALLAS E-MAIL ONLY: ROCKY MOUNTAIN POWER datarequestgpacificolp.com 1407 WEST NORTH TEMPLE STE 330 SALT LAKE CITY UT 84116 E-MAIL: mark.alderkpacificorp.com joseph.dallasgpacificorp.com IDAHO FALLS CITY POWER BEAR PRAIRIE 140 SOUTH CAPITAL AVENUE P.O. BOX 50220 IDAHO FALLS, ID 83405 EMAIL: bprairiegifpower.org PATRICIA JORDA , SECRETARY CERTIFICATE OF SERVICE