20250806APPLICATION.pdf

RECEIVED
August 6, 2025
IDAHO PUBLIC
_ ROCKY MOUNTAIN 14o W.UTILITIES COMMISSION
330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
August 6, 2025
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
RE: CASE NO.PAC-E-25-14
IN THE MATTER OF THE APPLICATION FOR APPROVAL OF THE 2026 INTER-
JURISDICTIONAL COST ALLOCATION PROTOCOL
Attention: Commission Secretary
PacifiCorp d/b/a Rocky Mountain Power ("Rocky Mountain Power" or "Company") hereby
submits its Application for Approval of the 2026 PacifiCorp Inter-Jurisdictional Allocation
Protocol ("2026 Protocol") to the Idaho Public Utilities Commission in the above-referenced
matter. Included in support of this filing are non-confidential and confidential testimony, exhibits,
and workpapers.
The Company is proposing the 2026 Protocol to replace the 2020 PacifiCorp Inter-Jurisdictional
Allocation Protocol, approved on April 22, 2020, by Order No. 34640, and extended on
November 2, 2023, by Order No. 35984.
Informal inquiries regarding this filing may be directed to Mark Alder,Idaho Regulatory Manager,
at [phone].
Very truly yours,
a,1�0
Joe Steward 9L
Senior Vice President, Regulation
Enclosures

Adam Lowney
McDowell Rackner Gibson PC
419 SW I I�h Ave., Suite 400
Portland, Oregon 97205
Telephone No. [phone]
Email: adam(d),mrg-law.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. PAC-E-25-14
APPLICATION FOR APPROVAL OF )
THE 2026 INTER-JURISDICTIONAL ) APPLICATION OF ROCKY
COST ALLOCATION PROTOCOL ) MOUNTAIN POWER
PacifiCorp, d/b/a Rocky Mountain Power("Rocky Mountain Power" or the "Company"),
hereby respectfully submits this application("Application") in accordance with Idaho Code § 61-
502, § 61-503, and RP 052, to the Idaho Public Utilities Commission ("Commission") and
requests approval of the 2026 PacifiCorp Inter-Jurisdictional Cost Allocation Protocol (the "2026
Protocol"). The Company respectfully requests that the Commission complete its review and
issue an order with respect to this Application no later than December 31, 2025, for the reasons
discussed herein.
In support of this Application, Rocky Mountain Power states as follows:
1. Rocky Mountain Power is an electrical corporation and public utility in the state
of Idaho, providing electric service to retail customers as Rocky Mountain Power in Idaho, Utah,
and Wyoming, and as Pacific Power in California, Oregon, and Washington.
2. Rocky Mountain Power is authorized to do business in the state of Idaho as a
public utility providing retail electric service to approximately 91,000 customers. Rocky
Mountain Power is a public utility subject to the jurisdiction of the Commission under Idaho
Code § 61-129.
APPLICATION OF ROCKY MOUNTAIN POWER Page I

BACKGROUND
3. Rocky Mountain Power provides retail electric service to approximately two
million customers in six western states, including Idaho. Rocky Mountain Power owns
substantial generation, transmission, and distribution facilities.Augmented with wholesale power
purchases and long-term transmission contracts, these facilities have operated as a single system
on an integrated basis to provide service to all customers in a cost-effective manner. States,
however, are implementing energy policies that make it increasingly difficult for Rocky
Mountain Power to operate and maintain a single resource portfolio for customers across all
jurisdictions while meeting its legal obligations in each state. The 2026 Protocol implements an
initial phase toward a transition from a cost-allocation methodology that contemplates the
operation of a single resource portfolio to a cost-allocation methodology that acknowledges the
need for state or regional resource portfolios to meet load obligations on a least-cost basis, while
complying with state energy policies and preventing cross-subsidization among jurisdictions.
4. On April 22, 2020, the Commission issued its Order adopting the 2020 Protocol
(2020 Protocol).' Section 2 of the 2020 Protocol provided the effective period through December
31, 2023. On April 12, 2023, the Company filed for extension of the 2020 Protocol through
December 31, 2025. The Commission issued an Order authorizing the requested extension on
November 2, 2023.2
5. Parties negotiated the 2020 Protocol over the course of several years through the
Company's Multi-State Process. The 2020 Protocol, as extended, provided a cost-allocation
methodology for use in Rocky Mountain Power's rate filings from 2020 through 2025 along with
1 In the Matter of Rocky Mountain Power's Application for Approval of the 2020 PacifiCorp Inter-Jurisdictional
Allocation Protocol,Case No.PAC-E-19-20,Order No. 34640(Apr.22,2020).
2 In the Matter of Rocky Mountain Power's Petition for Approval of an Extension of the 2020 Inter-Jurisdictional
Allocation Protocol,Case No.PAC-E-23-13,Order No. 35984(Nov.2,2023).
APPLICATION OF ROCKY MOUNTAIN POWER Page 2

an outline for a subsequent allocation methodology to be negotiated by the Framework Issues
Workgroup, which included the original signatories of the 2020 Protocol and any stakeholder
committing to engage in discussions on the Framework Issues by subsequently signing the 2020
Protocol. The Company continued negotiations with stakeholders until it was clear that the
Framework Issues Workgroup would not reach consensus on the terms of a replacement cost-
allocation methodology in time to seek the required approvals before January 1, 2026. In July
2024, the Company informed its commissions that it was terminating the Framework Issues
Workgroup in accordance with Section 2.2.3 and would propose a new cost-allocation
methodology by December 31, 2025.
REQUEST FOR APPROVAL OF THE 2026 PROTOCOL
6. The 2026 Protocol is intended to supersede the 2020 Protocol for Idaho, Utah,
Wyoming, California, and Oregon, and align with the changes proposed in the Washington 2026
Protocol to ensure that all resources are 100 percent allocated. The 2026 Protocol is the first
phase in a multi-phase process to transition the Company's cost-allocation methodology to
accommodate diverging resource portfolios and changes to operations needed to address
individual state energy policies.
7. The 2026 Protocol maintains allocations from much of the 2020 Protocol, while
addressing developments in state energy policies and changes in the industry driving updates to
the allocation methodology that need to be addressed now. Accordingly, the Commission can use
the 2026 Protocol to set just and reasonable rates in the Company's rate filings in Idaho pending
further development of a replacement cost-allocation methodology in Phase 2. The Company
requests that upon approval by the Commission, the 2026 Protocol be effective for new
regulatory filings beginning January 1, 2026, and remain in effect until superseded by a future
amendment or new protocol approved by the Commission.
APPLICATION OF ROCKY MOUNTAIN POWER Page 3

8. The 2026 Protocol includes:
• An allocation of existing generation resources in line with prior Commission
decisions, allowing for dynamic allocation of a portfolio of generation resources
to Idaho, Utah, Wyoming, California, and Oregon;
• A proposal allowing for flexibility in allocating costs for new resources to allow
for state autonomy when procuring such new resources to achieve state-specific
policy objectives, by allowing Rocky Mountain Power to identify a specific
allocation factor for each new resources;
• A proposal for allocating costs associated with new large loads over
50 megawatts;
• Allocation of non-wildfire related insurance premiums for excess liability and
costs for non-wildfire liability not covered by insurance in line with historical
practice, with a commitment to address wildfire related insurance coverage and
liability on a state-by-state basis;
• A description of inter jurisdictional allocation policies, procedures, or methods
which, if applied by each state for rate proceedings, will provide the Company a
reasonable opportunity to recover its prudently incurred cost of service; and
• A description of the way costs and revenues associated with all components of the
Company's regulated service, including costs and revenues associated with
generation, transmission, distribution, and wholesale transactions, should be
assigned or allocated among states.
9. The proposed allocation of a particular expense or investment to a state under the
2026 Protocol is not intended to and will not prejudge the prudence of those costs or the extent to
APPLICATION OF ROCKY MOUNTAIN POWER Page 4

which any particular cost may be reflected in rates.
10. Nothing in the 2026 Protocol is intended to abrogate either or both of the
Commission's right and its obligation to: (1) determine fair, just, and reasonable rates based
upon applicable laws and the record established in rate proceedings conducted by that
commission; (2) consider the impact of changes in laws, regulations, or circumstances on inter-
jurisdictional allocation policies and procedures when determining fair, just, and reasonable
rates; or (3) establish different allocation policies and procedures for purposes of allocating costs
and revenues within that state to different customers or customer classes.
11. The 2026 Protocol does not address or consider intra-state cost-allocation issues
and using the 2026 Protocol for inter jurisdictional cost-allocation purposes does not suggest or
require similar treatment to be applied to intra jurisdictional cost allocations for class cost of
service purposes within any state.3
12. The 2026 Protocol, presented as an exhibit to the direct testimony of Joelle R.
Steward, also includes the following appendices:
• Capitalized terms in the 2026 Protocol are defined in Appendix A.
• Tables identifying the allocation factors to be applied to each component of the
Company's revenue requirement calculation are included as Appendix B.
• The definition and algebraic derivation of each allocation factor, along with
associated Federal Energy Regulatory Commission accounts, are contained in
Appendix C.
• An explanation of the treatment of certain legacy interruptible contracts for
allocation purposes is attached as Appendix D.
APPLICATION OF ROCKY MOUNTAIN POWER Page 5

13. In support of this Application the Company provides the direct testimony and
exhibits of the following Company witnesses:
• Cindy A. Crane, Chief Executive Officer and Board Chair of PacifiCorp,
provides an overview of the Company and a summary of the process that led to
this filing;
• Joelle R. Steward, Senior Vice President, Regulation, describes and supports the
Company's new inter jurisdictional cost allocation methodology for Idaho;
• Ramon J. Mitchell, Director of Net Power Costs, presents the impact of the 2026
Protocol on the Company's NPC forecast;
• Shelley E. McCoy, Director of Revenue Requirement, calculates impacts to the
Company's revenue requirements from the 2026 Protocol; and
• Michael G. Wilding, Vice President, Energy Supply Management, explains how
the 2026 Protocol supports resource adequacy for customers, describes the
Company's proposed changes to its hedging program and Western Resource
Adequacy Program compliance, and explains the Company's participation in
organized markets.
COMMUNICATIONS
14. Communications regarding this filing should be addressed to:
Mark Alder
Idaho Regulatory Affairs Manager
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
Telephone: [phone]
Email: mark.alder(&,pacificorp.com
s Section 13.0 of the 2026 Protocol identifies that the Company will work within the regulatory framework (i.e., a
special contract or tariff) within that state to assign the costs to the New Large Load customer. See 2026 Protocol
at 14(Exhibit No. 3 at 14).
APPLICATION OF ROCKY MOUNTAIN POWER Page 6

Aj ay Kumar
Chief Regulatory Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
Email: aiay.kumarkpacificorp.com
In addition, Rocky Mountain Power requests that all data requests regarding this
application be sent in Microsoft Word or plain text format to the following:
By email (preferred): datarequest&pacificorp.com
By regular mail: Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Informal questions regarding this filing may be directed to Mark Alder, Idaho Regulatory
Affairs Manager at(801) 220-2313.
PROPOSED COMMISSION PROCESS
15. The 2026 Protocol has been developed as an integrated, interdependent whole. In
any state commission disapproves, alters, or conditions approval of the 2026 Protocol, Rocky
Mountain Power reserves its right to petition for an amendment to revise the 2026 Protocol.4
Accordingly, the Company recommends that the Commission approve the 2026 Protocol without
modification and that the approval be conditioned on the other commissions approving the 2026
Protocol without change.
16. Rocky Mountain Power respectfully requests that the Commission approve the
use of the 2026 Protocol for inter jurisdictional cost-allocation purposes effective January 1,
2026. Absent approval by December 31, 2025, the Company will be without an approved
4 California has historically reviewed allocation methodologies in conjunction with a general rate case. The
Company's next regulatory-mandated general rate case in California will not be filed until 2026 at the earliest.
APPLICATION OF ROCKY MOUNTAIN POWER Page 7

allocation methodology for use in determining the appropriate costs for Idaho customers and will
be forced to seek temporary extensions of the 2020 Protocol in individual rate proceedings
starting January 1, 2026. The Company also proposes that within 30 days of receipt of the
Application, the Commission establish a schedule for further proceedings.
17. Rocky Mountain Power plans to implement any rate changes resulting from the
2026 Protocol in its next general rate case. In the interim, the Company will seek to track any
differences in costs and revenues through deferred accounting.
CONFIDENTIAL INFORMATION
18. This filing, specifically the testimony and workpapers of Michael G. Wilding and
Ramon J. Mitchell, includes confidential information exempt from public review under Idaho
Code §§ 74-104-109 and Commission Rule of Procedure 67.
CONCLUSION
WHEREFORE, by this Application, the Company respectfully requests that the
Commission issue an order approving the 2026 Protocol as described in the direct testimony of
Ms. Steward, and supported by the direct testimonies of Ms. Crane, Mr. Mitchell, Ms. McCoy,
and Mr. Wilding.
DATED this 61h day of August 2025.
Respectfully submitted,
;4-�
Adam LoNUey
McDowell Rackner Gibson PC
419 SW 1 Ith Ave., Suite 400
Portland, OR 97205
Telephone No. [phone]
Email: adam&mrg-law.com
Attorney for Rocky Mountain Power
APPLICATION OF ROCKY MOUNTAIN POWER Page 8