20250724Comments.pdf

_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP RECEIVED
July 24, 2025
July 24, 2025 IDAHO PUBLIC
UTILITIES COMMISSION
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
RE: CASE NO. GNR-E-25-01
IN THE MATTER OF COMMISSION STAFF'S APPLICATION FOR APPROVAL OF
AN OVEERSIGHT PROCESS FOR THE ACQUISITION OF LARGE SUPPLY-SIDE
ELECTRICAL RESOURCES
Attention: Commission Secretary
Pursuant to Commission Order No. 36662, authorizing Idaho Public Utilities Commission Staff s
Application to be processed by Modified Procedure and establishing the procedural schedule,
please find Rocky Mountain Power's 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 9LO-1-D
Joelle Steward
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 COMMISSION ) CASE NO. GNR-E-25-01
STAFF'S APPLICATION FOR APPROVAL )
OF AN OVEERSIGHT PROCESS FOR THE ) COMMENTS OF ROCKY MOUNTAIN
ACQUISITION OF LARGE SUPPLY-SIDE ) POWER
ELECTRICAL RESOURCES )
Pursuant to Rule 202.01(d) of the Rules of Procedure of the Idaho Public Utilities
Commission("Commission") and the Commission's July 1, 2025,Notice of Modified Procedure,
PacifiCorp d/b/a Rocky Mountain Power ("Rocky Mountain Power" or the "Company") hereby
submits comments in the above-referenced case.
I. BACKGROUND
1. On March 31, 2025, Idaho Public Utilities Commission Staff("Staff') applied for
the Commission to issue an order directing each utility to apply for and receive Commission
approval for each new request for proposal ("RFP") prior to issuing it for the acquisition of large
supply-side resources. Staff supported its application with an attachment that outlined the
requirements for utility RFP.
2. On April 16, 2025, Commission Order No. 36549 provided public notice of the
Company's Application and also provided notice of intervention deadline. On May 13, 2025,
Notice of Parties was issued with Northwest & Intermountain Power Producers Coalition, Idaho
Power Company, Rocky Mountain Power, and Avista Utilities identified as parties to the case. On
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June 23, 2025, Commission Order No. 36649, conditionally granted Micron Technology, Inc's
petition to intervene. On July 1, 2025, Commission Order No. 36662 authorized processing of the
Application by Modified Procedure,and established the procedural schedule allowing persons who
would like to file written comments to have until July 24, 2025, response parties from all parties
due August 21, 2025, and Staff reply comments due by September 4, 2025
II. ROCKY MOUNTAIN POWER COMMENTS
3. Prior to Staff's application, the Company and Staff met, and the Company shared
its recommendations based on its experience with RFP oversight in other states in which it
operates. PacifiCorp appreciates Staff's outreach prior to the application as well as the opportunity
to provide comments on the application.
4. Overall, the Company is supportive of Staff's application and proposed RFP
oversight process. PacifiCorp believes that these rules strike a reasonable balance of allowing
opportunity for Commission oversight of RFPs prior to issuance while not imposing undue
restriction and transaction costs. The Company has additional suggestions for the Commission's
consideration based on prior experience:
5. For the waiver process described in section 2(a)of page two of Attachment A to the
Application, staff allows for a waiver process to be for "rare situations." The Company believes
that the language pertaining to the waiver process should be evaluated on a case-by-case basis in
order to facilitate situations such as time-limited, economic opportunities that are incompatible
with a RFP process.Accordingly,PacifiCorp would recommend a slight revision that removes the
language referencing"rare situations."
6. In addition, section 2(c) of the waiver process on page two, limits the waiver
process to "unsolicited" economic-based opportunities. The Company believes that there may be
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economic-based opportunities that could stem from bilateral outreach.In these cases,the Company
would like the opportunity to pursue a waiver to avoid missing the opportunity to pursue such an
opportunity that could result in benefits to customers. Accordingly, PacifiCorp would strongly
recommend that the reference to the term "unsolicited"be removed from this section.
7. Section I(d) provides that the Commission retains discretion to require the use of
an Independent Evaluator("IE"). PacifiCorp supports this provision, as it allows the Commission
to determine on a case-by-case basis whether the nature of a specific RFP justifies retention of an
IE. Furthermore, in instances where an IE is required, the provision allows the scope of the IE's
involvement to be tailored to the specific characteristics of the RFR However, when an IE is
required, the associated costs may be unrecoverable by the utility. These costs may be considered
unforeseeable and therefore cannot predicted in a general rate case test year. Additionally, they
may not qualify for traditional regulatory deferral treatment. To address this concern, PacifiCorp
recommends that the rule include a mechanism for cost recovery of IE expenses. One potential
approach would be to authorize utilities to file for deferral of IE-related costs, subject to a
subsequent prudence review and recovery in a future proceeding.
III. REOUEST FOR RELIEF
8. The Company appreciates the effort and outreach Staff has taken to put together
this proposal. In particular, PacifiCorp greatly appreciates the efforts undertaken by Staff to
proactively meet with the Company and other stakeholders. PacifiCorp respectfully requests that
Staff and the Commission consider the proposed revision submitted above.
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DATED this 24th day of July 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&pacificorp.com
Attorney for Rocky Mountain Power
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