20250806Direct Wilding - Redacted.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF ROCKY MOUNTAIN )
POWER FOR APPROVAL OF 2026 ) CASE NO. PAC-E-25-14
INTER-JURISDICTIONAL COST )
ALLOCATION PROTOCOL )
ROCKY MOUNTAIN POWER
REDACTED
Direct Testimony of Michael G. Wilding
August 2025

1 I . INTRODUCTION
2 Q. Please state your name, business address, and present
3 position with PacifiCorp d/b/a Rocky Mountain Power
4 ("Company") .
5 A. My name is Michael G. Wilding, and my business address
6 is 825 NE Multnomah Street, Suite 600, Portland,
7 Oregon 97232 . My title is Vice President, Energy
8 Supply Management .
9 Q. Please describe your education and professional
10 experience.
11 A. I received a Master of Accounting degree from Weber
12 State University and a Bachelor of Science degree in
13 accounting from Utah State University. As Vice
14 President, Energy Supply Management ("ESM") , my
15 responsibilities include directing the Company' s front
16 office organization in commercial and trading
17 activities . ESM is responsible for commercially
18 managing the Company' s diverse generation portfolio .
19 This includes electric and natural gas hedging, day-
20 ahead trading, real-time trading, and system
21 balancing. I am also responsible for the Company' s
22 carbon policy and reporting group. Before assuming my
23 current position in February 2021, I worked on various
24 regulatory projects including general rate cases, the
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1 multi-state process, and net power cost filings . I
2 have been employed by the Company since 2014 .
3 Q. Have you testified in previous regulatory
4 proceedings?
5 A. Yes . I have previously testified in front of the Idaho
6 Public Utilities Commission ("Commission") , and in
7 Utah, Wyoming, California, Oregon, and Washington. I
8 have also filed testimony at the Federal Energy
9 Regulatory Commission.
10 Q. What is the purpose of your testimony in this
11 proceeding?
12 A. The purpose of my testimony is to support the 2026
13 PacifiCorp Inter-Jurisdictional Allocation Protocol
14 ("2026 Protocol") for interjurisdictional cost
15 allocations . I show how Idaho customers will be
16 reasonably allocated resources under the 2026 Protocol
17 in terms of resource adequacy. Additionally, I
18 describe the impacts of having two separate generation
19 portfolios on the Company' s front-office operation and
20 the risk management policy. Finally, I explain how the
21 Extended Day-Ahead Market ("EDAM") settlements may be
22 used in the future to settle, or track, net power costs
23 once generation portfolios are fixed and generation
24 resources are no longer dynamically shared among
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I Idaho, Utah, Wyoming, California, and Oregon (the
2 "Five States") .
3 Q. Please describe how your testimony is organized.
4 A. First, my testimony describes how the 2026 Protocol
5 maintains a reasonable resource adequacy position and
6 market position for Idaho customers . Next, I describe
7 the changes to the hedging and risk management policy
8 that the Company is implementing. Finally, I explain
9 how the Company' s participation in organized markets
10 will impact the future allocations of net power costs .
11 II . THE 2026 PROTOCOL MAINTAINS RESOURCE
12 ADEQUACY FOR IDAHO CUSTOMERS
13 Q. Please briefly describe the limited realignment of
14 generation.
15 A. As described in the testimony of Company witness
16 Joelle R. Steward, the 2020 Inter-Jurisdictional
17 Allocation Protocol ("2020 Protocol") is expiring on
18 December 31, 2025, and the Company is now proposing a
19 new inter-jurisdictional cost-allocation methodology,
20 the 2026 Protocol . ' The 2026 Protocol is the first step
21 in a process to transition cost allocation and changes
22 in operations to accommodate diverging resource
23 portfolios required to comply with different state
24 energy policies . Most immediately, Washington' s Clean
Direct Testimony of Joelle R. Steward at 8-10 (Aug. 6, 2025) .
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1 Energy Transformation Act requires that the costs of
2 coal generation be excluded from Washington retail
3 rates after December 31, 2025 . Additionally, in light
4 of state disallowances of carbon costs under
5 Washington' s Climate Commitment Act, it is necessary
6 to situs assign all the costs and benefits of the
7 Chehalis natural gas plant to Washington. Notably,
8 this limited realignment was contemplated as a
9 potential future step in the 2020 Protocol . 2
10 Q. Please briefly describe the creation of two distinct
11 generation portfolios .
12 A. The limited realignment that is being proposed under
13 the 2026 Protocol creates two distinct generation
14 portfolios—a Five-State portfolio ("Five-State
15 Portfolio") and the Washington fixed portfolio
16 ("Washington Fixed Portfolio") . The Five-State
17 Portfolio benefits from the diversity of the Company' s
18 system and includes a percentage of every resource on
19 the system except for the Chehalis natural gas plant
20 and Washington qualifying facilities (%Fs") , which
21 are situs assigned to Washington. There are four
22 different subsets of generation resources in the two
23 portfolios . The first subset includes those that are
24 allocated to both portfolios . The second subset is for
2 See 2020 Protocol, Section 6.4.
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1 generation resources that are fully allocated to the
2 Five-State Portfolio and not included in the
3 Washington Fixed Portfolio . The third subset is for
4 the Rolling Hills Wind facility, which is included in
5 the Five-State Portfolio, except for Oregon, and in
6 the Washington Fixed Portfolio . The fourth subset
7 includes Washington situs resources that are fully
8 allocated to the Washington Fixed Portfolio . The
9 subsets of resources included in the two portfolios
10 are summarized in the table below.
Five-State Washington
Plant Name/Resource Portfolio Fixed Total
Type (OR, CA, ID, portfolio
UT, WY)
Resource Subset 1
Jim Bridger 1 & 2 92 . 10% 7 . 90% 100%
Other Existing Non-
Emitting Resources 92 . 10% 7 . 90% 100%
(non-QFs)
Legacy
Interruptible 92 . 10% 7 . 90% 100%
Contracts
Resource Subset 2
Other Natural Gas 100% 0% 100%
and Coal (non-QFs)
Five State QFs 100% 0% 100%
Resource Subset 3
Rolling Hills Wind
65 . 13% 34 . 87% 100%
(excluding OR)
Resource Subset 4
WA QFs 0% 100% 100%
Chehalis 0% 100% 100%
11 Q. How will the generation costs within the Five-State
12 Portfolio be allocated?
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1 A. The generation costs within the Five-State Portfolio
2 will continue to be allocated on a dynamic basis, with
3 a few exceptions . First, Oregon does not participate
4 in the Rolling Hills Wind facility. Second, QF costs
5 continue under the same treatment as the 2020
6 Protocol . Any new or renewed QF contract as of January
7 1, 2020, is situs assigned to the state of origin.
8 Lastly, certain resources acquired for the purpose of
9 state-specific initiatives, such as community solar,
10 will continue to be situs assigned to the state of
11 origin .
12 Q. Did the Company analyze the resource adequacy and
13 energy position of the Five-State Portfolio?
14 A. Yes . The Company assessed the impact of the 2026
15 Protocol on the resource adequacy and energy position
16 of the Five-State Portfolio, and performed a separate
17 analysis for Idaho .
18 Q. Please describe the results of your assessment of
19 resource adequacy under the 2026 Protocol .
20 A. I found that when compared to the 2020 Protocol, the
21 Five-State Portfolio under the 2026 Protocol provides
22 a similar resource adequacy position. This is also
23 consistent with my findings when comparing resource
24 adequacy impacts separately for Idaho .
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1 Q. What is resource adequacy and how does it benefit
2 customers?
3 A. Resource adequacy is a measure, typically for the next
4 year or season, of a utility' s or load-serving
5 entity' s ability to serve load in a reliable manner.
6 This measure typically identifies an adequate amount
7 of both generation and transmission capacity needed to
8 reliably serve peak load plus a planning reserve to
9 account for uncertainty, such as outages,
10 underperformance of resources, and higher-than-
11 forecast loads . Customers benefit from the utility
12 being resource-adequate through reliable service and
13 more stable power costs .
14 Q. Does the Company have a formal resource adequacy
15 standard?
16 A. Yes . The Company currently participates in the non-
17 financially binding phase of the Western Resource
18 Adequacy Program ("WRAP") , which is a regional
19 reliability planning and compliance program developed
20 by the members of the Western Power Pool to address
21 the emerging reliability needs in the West . WRAP has
22 created a regional planning standard for which each
23 participant must comply. This planning compliance
24 occurs twice a year in what is called the "forward
25 showing. " Each WRAP participant must show it has
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1 adequate generation and transmission capacity to meet
2 its peak load plus a planning reserve margin ("PRM")
3 twice a year, once for the summer period (June through
4 September) and once for the winter period (November
5 through March) . The PRM is calculated monthly based on
6 a one-in-ten-year loss of load event . Currently, there
7 are no penalties for failing to comply with the WRAP
8 standard. However, once the program becomes
9 financially binding, WRAP participants who fail to
10 meet the WRAP standard in their forward showing will
11 face deficiency charges . Each WRAP participant must
12 decide whether to become part of the financially
13 binding WRAP by October 31, 2025 .
14 Q. Please explain how you evaluated the resource adequacy
15 of the Five-State Portfolio and Idaho' s share of the
16 Five-State Portfolio.
17 A. I used the WRAP methodology to evaluate the resource
18 adequacy of the Five-State Portfolio and Idaho' s share
19 of the Five-State Portfolio for 2026 under the 2026
20 Protocol and the 2020 Protocol . The monthly peak loads
21 for the 2026 winter and summer seasons are from the
22 most recent Company load forecast used in regulatory
23 proceedings . The WRAP monthly PRM, ranging from
24 13 . 7 percent to 21 . 9 percent, is added to the monthly
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REDACTED
1 peak load forecast . 3 The monthly peak load plus the
2 PRM is the amount of generation capacity that is needed
3 to comply with WRAP.
4 Each resource is assigned a qualified capacity
5 contribution ("QCC") , which is a measure of how much
6 of the generation capacity can be expected to be
7 available for dispatch during the peak load. The QCC
8 is calculated based on historical performance of the
9 resource or resource type, e .g. , wind and solar
10 resource QCCs are evaluated as a resource type in a
11 specific region. To be considered resource adequate,
12 the sum of the QCCs of all generation resources must
13 be greater than or equal to peak load plus the PRM
14 each month. 4
15 Q. Please show the resource adequacy comparison of the
16 Five-State Portfolio under the 2020 Protocol and the
17 2026 Protocol .
18 A. Confidential Figure 1 shows the capacity contribution
19 by resource type, based on the WRAP QCCs, attributed
20 to the Five-State Portfolio compared to the peak load
3 Note that April, May, and October do not have WRAP planning standards.
Since peak load is often driven by heating and cooling, these are
"s
mom
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REDACTED
1 and PRM for the 2026 WRAP seasons (winter and summer)
2 under the 2020 Protocol and the 2026 Protocol .
3 Confidential Figure 1 : Five-State Portfolio Resource
4 Adequacy Under the 2020 Protocol and 2026 Protocol
5 The "Load + PRM" lines are identical between
6 the 2020 Protocol and 2026 Protocol views, with only
7 the bars showing the QCC of generation resources
8 changing. Confidential Figure 1 shows that resource
9 adequacy from the Five-State Portfolio is similar
10 between the 2026 Protocol and the 2020 Protocol .
11 Q. Why does the 2026 Protocol not fully cover the peak
12 loads plus PRM in each month for the Five-State
13 Portfolio?
14 A. First, this is not surprising as the Company, as a
15 system, generally has an open position that it fills
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REDACTED
1 using near-term transactions such as market purchases .
2 My analysis only considers existing resources and does
3 not consider other actions the Company will take to
4 ensure reliability for its customers .
5 Q. Please show the resource adequacy comparison for
6 Idaho' s share of the Five-State Portfolio under the
7 2020 Protocol and the 2026 Protocol .
8 A. Confidential Figure 2 provides a resource adequacy
9 look for Idaho' s allocation of the Five-State
10 Portfolio under the 2020 Protocol and the 2026
11 Protocol . 5
12 Confidential Figure 2 : Idaho Resource Adequacy
13 Under the 2020 Protocol and the 2026 Protocol
s The Company has conducted similar analysis for each of the Five States,
as provided in Exhibit No. 6 to my testimony.
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1 The "Load + PRM" lines are identical between
2 the 2020 Protocol and the 2026 Protocol views, with
3 only the bars showing the QCC of generation resources
4 changing. Confidential Figure 2 shows that, based on
5 Idaho' s share of the Five-State Portfolio, resource
6 adequacy is similar under the 2026 Protocol and the
7 2020 Protocol .
8 Q. Please explain how you evaluated the ability of the
9 Five-State Portfolio to meet the energy needs of
10 customers .
11 A. First, I looked at two months : January 2026, to capture
12 the winter peak; and July 2026, to capture the summer
13 peak. Using the same load forecast as the resource
14 adequacy analysis, an hourly load profile was created
15 for each month based on the average hourly load for
16 the Five States . The average hourly energy output of
17 the Five-State Portfolio was created for different
18 types of resources .
19 For run-of-river hydroelectric and geothermal
20 resources, a flat generation profile was used based on
21 the WRAP QCCs . For wind and solar resources, hourly
22 generation profiles were sourced from developer-
23 provided forecasts . For natural gas, hourly energy
24 schedules were created based on actual generation data
25 from January 2025 and July 2024 . Storage resource
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1 schedules were created from the Company' s production
2 cost model outputs to determine the optimal use of
3 battery charging and discharging across an average day
4 in January and July. Finally, dispatchable
5 hydroelectric resource schedules were created by
6 determining optimal schedules to minimize the single-
7 hour short position for the Five States based on a
8 normal water year. Once the hourly energy schedules
9 were created, I applied the resource-specific
10 allocation percentage for each of the Five States
11 under the 2020 Protocol and the 2026 Protocol .
12 Q. Please show the energy comparison of the Five-State
13 Portfolio under the 2020 Protocol and the 2026
14 Protocol .
15 A. The results of the analysis show that the 2026 Protocol
16 slightly improves the Five-State energy position
17 compared to the 2020 Protocol . Confidential Figure 3
18 compares the 2020 Protocol average energy profile to
19 the 2026 Protocol and the average load for the Five
20 States in January 2026 .
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REDACTED
1 Confidential Figure 3 : System Energy Comparison of
2 the 2026 Protocol and the 2020 Protocol - January 2026
3 Confidential Figure 3 shows that the 2026
4 Protocol slightly increases the energy sufficiency
5 quantity for customers for all hours compared to the
6 2020 Protocol .
7 Confidential Figure 4 compares the 2020
8 Protocol average energy profile to the 2026 Protocol
9 average energy profile, against the average load for
10 the Five States in July 2026 .
11 Confidential Figure 4 : System Energy Comparison of
12 the 2026 Protocol and the 2020 Protocol - July 2026
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REDACTED
1 When the Company analyzed average energy needs
2 in July 2026, the energy shortfall decreased for all
3 hours except hours ending 2 through 6 under the 2026
4 Protocol compared to the 2020 Protocol . Although some
5 hours showed a decreased energy position in July under
6 the 2026 Protocol, the overall energy position
7 improved.
8
9
10 The 2026 Protocol reduces the system energy shortfall
11 over these critical hours, thereby reducing reliance
12 on market purchases .
13 Q. Why does the 2026 Protocol not fully cover the energy
14 needs of customers in the Five-States during July?
15 A. Like the resource adequacy results, this is not
16 surprising as the Company, as a system, generally has
17 an open position that it fills using near-term
18 transactions such as market purchases . While
19 Confidential Figure 4 shows that neither allocation
20 method leads to customers being able to meet 100
21 percent energy needs with existing resources during
22 July 2026, the Company will take near-term actions,
23 such as making market purchases, to ensure there is
24 enough energy to meet system load.
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1 Q. Please explain how you evaluated the ability of
2 Idaho' s share of the Five-State Portfolio to meet the
3 energy needs of Idaho customers .
4 A. First, I looked at two months : January 2026, to capture
5 the winter peak; and July 2026, to capture the summer
6 peak. Using the same load forecast, an hourly load
7 profile was created for each month based on the average
8 hourly load for Idaho. The average hourly energy
9 output is the same as the data that was used in the
10 analysis of the Five-State Portfolio . I applied
11 resource-specific Idaho allocation percentages under
12 the 2020 Protocol and the 2026 Protocol to the energy
13 schedules to arrive at Idaho-allocated energy totals .
14 Q. What did the analysis show at the state-level view?
15 A. The results of the state-level energy analysis are
16 similar to the Five-State Portfolio view. Confidential
17 Figure 5 compares the 2020 Protocol average energy
18 profile with the 2026 Protocol average energy profile,
19 against the average load for Idaho in January 2026 .
20 The figure shows that the 2026 Protocol slightly
21 increases the energy sufficiency quantity for Idaho
22 customers for all hours compared to 2020 Protocol .
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REDACTED
1 Confidential Figure 5 : Idaho Energy Comparison of
2 the 2026 Protocol and the 2020 Protocol - January 2026
3 The July 2026 results for Idaho shown in
4 Confidential Figure 6 differ slightly from the Five-
5 State Portfolio results . The 2026 Protocol improves
6 the Idaho energy position for all hours compared to
7 the 2020 Protocol .
8 Confidential Figure 6: Idaho Energy Comparison of
9 the 2026 Protocol and the 2020 Protocol - July 2026
10 Q. What conclusions do you draw from your energy
11 analysis?
12 A. Under the 2026 Protocol, the Company' s Idaho customers
13 are in a more favorable position than under the 2020
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1 Protocol . On average, both the Five-State Portfolio
2 and Idaho' s share of the Five-State Portfolio produce
3 slightly more energy every hour under the 2026
4 Protocol . This results in less market reliance and
5 more price stability.
6 III . IMPACTS TO THE RISK MANAGEMENT POLICY
7 Q. In light of creating the two resource portfolios, did
8 the Company evaluate its risk management policy?
9 A. Yes . The Company routinely evaluates its risk
10 management policy to ensure risks are being adequately
11 addressed, and changes in the market (e .g. , price,
12 product availability, etc . ) or the regulatory
13 landscape are considered. The creation of the two
14 generation portfolios, the Five-State Portfolio and
15 the Washington Fixed Portfolio also caused the Company
16 to evaluate its risk management policy. The risk
17 management policy was reviewed to specifically address
18 two risks : resource adequacy risk and price volatility
19 risk.
20 Q. Are the regulatory changes in the states that the
21 Company serves contributing to changes to the risk
22 management policy?
23 A. Yes . Changes in state energy policy where the Company
24 operates are driving the need to manage resource
25 adequacy and price risk across the Company' s system in
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1 different ways . As an example, compliance with
2 Washington law requires coal to be out of Washington
3 customer rates effective January 1, 2026, and places
4 restrictions on the types of market purchases that the
5 Company can use to address the risks identified above .
6 Additionally, the 2026 Protocol creates two distinct
7 resource portfolios and includes situs assignment of
8 resources . These changes require that forward market
9 transactions, including hedges, be accounted for
10 separately for each of the resource portfolios .
11 Q. Please describe the changes that the Company will make
12 to its current risk management policy and hedging
13 program and practices if the 2026 Protocol is
14 approved.
15 A. The Company will create two separate power and gas
16 hedge books, one for the Five-State Portfolio and one
17 for the Washington Fixed Portfolio . This will allow
18 the Company to manage risk to net power costs ("NPC")
19 on behalf of customers, while ensuring compliance with
20 all relevant state laws .
21 Q. Once the changes to the risk management policy are in
22 place, how will forward market transactions and hedges
23 be allocated?
24 A. Once the changes to the risk management policy are in
25 place, all forward transactions and hedges will be
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1 executed either for the Five-State book or for the
2 Washington book. Any forward market transactions
3 greater than balance of month will be tracked
4 specifically for the relevant book.
5 Q. How will existing hedges made for 2026 be allocated?
6 A. The Company has already made market transactions for
7 delivery in 2026 and has no desire for any state to
8 "start from zero" when the change is made, so there
9 will be an allocation of existing hedges to the two
10 books . Once the 2026 Protocol is approved, the Company
11 will assign the existing hedges to either the Five-
12 State book or the Washington book considering supply
13 risk, price risk, and compliance obligations .
14 IV. ORGANIZED MARKET PARTICIPATION
15 Q. Please explain the Company' s experience with organized
16 market participation.
17 A. In 2014, the Company partnered with the California
18 Independent System Operator to launch the Western
19 Energy Imbalance Market ("WEIM") , a real-time
20 organized market. The WEIM is a real-time imbalance
21 market that operates on 15-minute and 5-minute
22 intervals, optimizing imbalances by using available
23 transmission and generation from market participants
24 through an economic dispatch mechanism. Since its
25 inception, the WEIM participation has grown into a
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1 diverse footprint that currently has approximately
2 80 percent of the Western Electricity Coordinating
3 Council load participating. WEIM participants have
4 realized significant economic benefits in the form of
5 $7 . 41 billion through the second quarter of 2025 . The
6 Company has achieved approximately $1 . 02 billion in
7 savings, which has benefited customers through reduced
8 NPC. 6 The Company has also announced its intention to
9 join the EDAM and is currently working on
10 implementation with an expected go-live date of May
11 2026 .
12 Q. Please explain the EDAM.
13 A. The EDAM is a voluntary day-ahead market that
14 encompasses the foundation of the WEIM design . The
15 WEIM is designed to optimize generation in the real-
16 time timeframe by economically dispatching resources
17 to meet demand fluctuations across the WEIM footprint
18 while considering transmission constraints and
19 congestion. Before the operating hour, the WEIM
20 examines whether a balancing authority area can meet
21 its own native resource-load balance by testing the
22 resource plan against the feasibility of
23 deliverability to its own native load, this is called
6 See Western Energy Markest, "Benefits,"
https://www.westerneim.com/Pages/About/QuarterlyBenefits.aspx (last
accessed (July 31, 2025) .
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1 the resource sufficiency evaluation. This uniform
2 assessment ensures there is no leaning on the
3 footprint thereby creating reliability issues . The
4 EDAM extends this framework to the day-ahead
5 timeframe, optimizing all load, transmission, and
6 generation resources .
7 Q. How might future EDAM participation impact NPC
8 allocations in Phase 2 of the 2026 Protocol?
9 A. As part of the 2020 Protocol, the Company introduced
10 the concept of the nodal pricing model ("NPM") . This
11 was a method to track NPC once state generation
12 portfolios become static or fixed. EDAM settlements
13 will replace the need for the NPM. At this time, only
14 Washington will have a static generation portfolio,
15 and EDAM will not be live until May 2026 . However, in
16 the future, EDAM settlements will enable the Company
17 to track NPC per unique generation portfolios . For
18 example, Idaho would be allocated the fuel costs,
19 purchased power costs, and wholesale sale revenues
20 associated with its generation portfolio . Idaho would
21 pay the market price for its load and would receive
22 the market revenues from its generation resources . The
23 sum of the load costs and the generation revenues would
24 net to zero on a system basis but would result in
25 either a credit or cost to each unique generation
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1 portfolio on the Company' s system. This cost or credit
2 for Idaho would be added to the allocated fuel costs,
3 purchased power costs, and wholesale sale revenues to
4 arrive at the total NPC. This will be based on the
5 actual market settlements received from EDAM. The
6 Company is not asking the Commission to consider using
7 EDAM to track NPC for Idaho at this time . I anticipate
8 multiple workshops on this subject and more robust
9 testimony will accompany any filing asking to
10 implement this method.
11 V. CONCLUSION
12 Q. Please summarize and conclude your testimony.
13 A. In summary, the 2026 Protocol provides Idaho customers
14 with a generation portfolio that results in similar
15 resource adequacy and market reliance as under the
16 2020 Protocol . I recommend that the Commission approve
17 the 2026 Protocol as just and reasonable for Idaho
18 customers .
19 Q. Does this conclude your testimony?
20 A. Yes .
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REDACTED
Rocky Mountain Power
Exhibit No . 6
Case No . PAC-E-25-14
Witness : Michael G. Wilding
BEFORE THE IDAHO PUBLIC UTILITIES
COMMISSION
ROCKY MOUNTAIN POWER
REDACTED
Exhibit Accompanying Direct Testimony of Michael G. Wilding
State Capacity and Energy Positions Comparison
of the 2020 Protocol and 2026 Protocol
August 2025

THIS EXHIBIT IS CONFIDENTIAL IN
ITS ENTIRETY AND IS PROVIDED
UNDER SEPARATE COVER .