20250813Semi-Annual Report.pdf

RECEIVED
August 13, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER 1407 W.North Temple,Suite 330
Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
August 13, 2025
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
1131 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
Re: CASE NO. PAC-E-21-01
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
FOR APPROVAL OF THE TRANSFER OF THE LOWER KLAMATH
HYDROELECTRIC PROJECT GENERATING FACILITIES
I. BACKGROUND
On January 14, 2021, PacifiCorp, (the "Company"), filed an application with the Idaho
Public Utilities Commission("Commission"),requesting an order approving the Property Transfer
Agreement ("Transfer Agreement"), between the Company and the Klamath River Renewal
Corporation ("Renewal Corporation"), with a determination that the property disposition is in the
public interest. The Transfer Agreement provided for the transfer of four hydroelectric dams; J.C.
Boyle, Copco No. 1, Copco No. 2, and Iron Gate, (collectively the "Lower Klamath Project"), as
well as approximately 8,000 acres of real and personal property associated with the dams from
PacifiCorp to the Renewal Corporation.
On July 8, 2021, the Commission issued Order No. 35097; approving the Transfer
Agreement, authorizing the Company to create a regulatory asset for any remaining plant balances
after the transfer and requiring PacifiCorp to file bi-annual reports with the Commission on the
status of the license transfer with the Federal Energy Regulatory Commission ("FERC") and any
additional capital investments on the Lower Klamath Project.

Pursuant to Order No. 35097, PacifiCorp hereby submits its semi-annual status report on
the license transfer,along with additional capital investments,and the June 30,2025,plant balance
of the Lower Klamath Project. The report covers the period of January 1, 2025, through June 30,
2025.
II. BI-ANNUAL REPORT
As previously reported, on June 17, 2021, FERC issued an orders approving PacifiCorp's
application to transfer the license for the Lower Klamath Project, FERC Project No. 14803, to the
Renewal Corporation, the State of Oregon, and the State of California (the "Co-Licensees").
Transfer of the license was to be effective upon transfer of the title of the properties under the
Lower Klamath Project to the Co-Licensees and the acceptance by the Co-Licensees of a FERC
license surrender order for the project.
FERC approved the license surrender application at its regular meeting on November 17,
2022, and issued the license surrender order on the same date. Following FERC's action, the Co-
Licensees formally accepted the FERC surrender order and executed the necessary steps with
PacifiCorp to complete transfer of the project license and real property, which was effective on
December 1, 2022.
PacifiCorp was obligated under the terms of the Klamath Hydroelectric Settlement
Agreement to continue to operate and maintain the Lower Klamath Project in compliance with the
existing FERC license and other regulatory requirements until the Lower Klamath Project was
disconnected from the electrical grid and no longer benefitting customers with generation
produced from the facilities. This operation and maintenance obligation was formalized in an
amended and restated Operation and Maintenance Agreement between PacifiCorp and the
I PacifiCorp,Order Approving Transfer of License, 175 FERC¶61,236(2021),Issued June 17,2021,Project Nos.
2082-062, 14803-000, 14803-004,FERC Accession#:20210617-3060.
2 PacifiCorp,Order Modifying and Approving Surrender of License and Removal of Project Facilities, 181 FERC¶
61,122(2022),Issued November 17,2022,Project Nos.2082-063, 14803-001,FERC Accession#: 20221117-3021.

Co-licensees that went into effect on December 1,2022, concurrent with the transfer of the license.
This contract was effective with respect to each facility in the Lower Klamath Project until
generation from the facility ceased,which occurred in May 2023 for the Copco No.2 development,
and January 2024 for the other facilities.
Removal of the Copco No. 2 development was completed in September 2023, and removal
of the Iron Gate, Copco No. 1, and J.C.Boyle developments was completed in early October 2024.
During this reporting period, Renewal Corporation continued implementation and monitoring of
the various resource management plans required by FERC pursuant to the license surrender order
and other permit requirements, assessed the progress of revegetation of the formerly inundated
reservoir areas, tributary connectivity, continued cultural resource monitoring, and continued
ongoing water quality and terrestrial and aquatic wildlife monitoring and reporting. In January
2025,the Renewal Corporation submitted its Final Construction Report to FERC,marking the end
of the deconstruction phase of the project. Ongoing implementation activities will focus on
monitoring and adaptive management.
III. REGULATORY ASSET BALANCE
The Lower Klamath Project's regulatory asset balance as of June 30, 2025 is summarized
in Table 1 and is being amortized through the end of 2027. While amortization of the legacy
regulatory asset was completed, a new regulatory asset balance was established in 2023 as a result
of the FERC's reply to the Company's proposed accounting entries associated with the disposition
of the Lower Klamath Project assets.3 Originally, the Company retained the net book value of the
Lower Klamath Project assets in the plant accounts due to its continuing to operate and benefit
from the output of the facilities with the intent to transfer the net book value to a regulatory asset
upon cessation of operations. However, the FERC did not accept this accounting and directed the
3 FERC Docket No.AC23-26-000 dated May 5,2023.

Company to transfer the net book value directly to a regulatory asset. As a result, the Company
transferred the net book value to a regulatory asset in 2023 upon receiving the FERC's reply.
Table 1. Lower Klamath Project Regulatory Asset Balance as of June 30, 2025
Description Total Idaho
Regulatory Asset $ 3,235,158 $ 195,519
Amortization Expense January to
June 2025 $ 662,483 $ 40,038
As the Company no longer has operational responsibilities for the Lower Klamath Project,
the license transfer to the Co-Licensees has been effective for almost three years, dam removal
and deconstruction activities are complete,and no further material additions to the Lower Klamath
Project Regulatory Asset Balance are anticipated, the Company expects that this report will be its
final report submission pursuant to Commission Order No. 35097.
Any informal inquiries related to this report may be directed to Mark Alder, Idaho
Regulatory Manager at mark.alderkpacifiCorp.com or by phone at(801) 220-2313.
Very truly yours,
Joelle R. Steward
Senior Vice President, Regulation