20250904APPLICATION - Redacted.pdf

RECEIVED
September 4, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
September 4, 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-25-16
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR
APPROVAL TO PARTIALLY DECOMMISSION AND SELL CERTAIN FALL CREEK
HYDROELECTRIC DEVELOPMENT ASSETS
Attention: Commission Secretary
Pursuant to Idaho Code § 61-328, Rocky Mountain Power, a division of PacifiCorp, submits its
application to the Idaho Public Utilities Commission requesting approval of the partial
decommissioning and disposition of the Fall Creek Hydroelectric Development Assets.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313.
Very truly yours,
C-ID
Joe Steward 9�z
Senior Vice President, Regulation
Enclosures
CC: Donn English
Taylor Thomas

Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallas(ibpacifico1p.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. PAC-E-25-16
ROCKY MOUNTAIN POWER FOR APPROVAL )
TO PARTIALLY DECOMMISSION AND SELL ) APPLICATION OF
CERTAIN FALL CREEK HYDROELECTRIC ) ROCKY MOUNTAIN
DEVELOPMENT ASSETS ) POWER
Comes now PacifiCorp, d/b/a Rocky Mountain Power ("Rocky Mountain Power" or
"Company")pursuant to Idaho Code(I.C.) § 61-328 and IDAPA 31.01.01.052 hereby submits this
application to the Idaho Public Utilities Commission ("Commission"). Rocky Mountain Power
respectfully requests an order approving the partial decommissioning and sale of certain Fall Creek
Hydroelectric Development assets ("Fall Creek") and related real property to the City of Yreka,
California and determining that the decommissioning and property disposition is in the public
interest.
In support of this Application, Rocky Mountain Power states as follows:
I. NAME AND ADDRESS OF THE APPLICANT
1. Rocky Mountain Power, a division of PacifiCorp, an Oregon Corporation, whose
address is 1407 West North Temple, Suite 320 Salt Lake City,Utah 84116, is authorized to do and
is doing business in the state of Idaho. The Company provides retail electric service to
approximately 91,000 customers in the state and is subject to the jurisdiction of the Commission.
APPLICATION OF ROCKY MOUNTAIN POWER Page 1

The Company's retail certificated service territory encompasses portions of Fremont, Madison,
Teton, Clark, Jefferson, Lemhi, Oneida, Bannock, Franklin, Caribou, Butte, Bingham, Bear Lake
and Bonneville counties. Rocky Mountain Power is a public utility in the state pursuant to I.C. §
61-129.
2. Formal correspondence and requests for additional information regarding this
matter should be addressed to:
By email (preferred): datarequestkpacificorp.com
By regular mail:
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
With copies to:
Mark Alder
Idaho Regulatory Affairs Manager
1407 W. North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
Email: mark.alderkpacificorp.com
Joe Dallas
Assistant General Counsel
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Email:joseph.dallas&pacificorp.com
3. Informal inquiries related to this Application should be directed to Mark Alder,
Idaho Regulatory Affairs Manager, at(801) 220-2313.
II. BACKGROUND
4. PacifiCorp requests approval to partially decommission and sell certain facilities
and associated lands of Fall Creek, located in Jackson County, Oregon and Siskiyou County,
APPLICATION OF ROCKY MOUNTAIN POWER Page 2

California, to the City of Yreka. For the Commission's consideration, this section discusses the
Fall Creek facilities and relevant terms of the disposition.
A. Fall Creek Facilities
5. The Fall Creek Development is on Fall Creek, a tributary to the Klamath River at
River Mile 196.3, located about 0.4 miles south of the Oregon-California border.
6. The Fall Creek Development was originally constructed in 1903, prior to the 1935
amendment of the Federal Power Act which granted jurisdiction over the licensing of hydroelectric
power resources to the Federal Energy Regulatory Commission ("FERC"). Fall Creek was
subsequently included within the FERC license for PacifiCorp's Klamath Hydroelectric Project
("Project No. 2082") in 1954.1 The Klamath Hydroelectric Project license was transferred to
PacifiCorp in 1988,2 and expired on February 28, 2006.3 The Fall Creek Development has been
operating under annual FERC hydroelectric licenses since that time.4
7. In 2018, FERC amended PacifiCorp's license for Project No. 2082 to separate the
J.C. Boyle, Copco No. 1, Copco No. 2, and Iron Gate developments from the remaining Klamath
Hydroelectric Project developments and place them into a separate license as the Lower Klamath
Project (FERC Project No. 14803).5 The Lower Klamath Project license and associated
hydroelectric developments and real property were ultimately transferred to the Klamath River
Renewal Corporation and the states of California and Oregon as co-licensees6 and subsequently
1 In re Cal. Or.Power Co.Klamath Hydroelectric Project License, 13 F.P.C. 1 (1954); E.g., Pac.Power&Light Co.,
44 F.P.C. 1065 (1970).
'In re PP&L Klamath Hydroelectric Project License Transfer, 25 FPC 1154;In re PacifiCorp Klamath Hydroelectric
Project License Transfer,45 FERC¶62,146(November 23, 1988).
'In re PacifiCorp' Amendment of Klamath Hydroelectric Project License, 162 FERC¶61,236,¶4(Mar. 15,2018).
a E.g., 16 U.S.C. § 808(a)(1)(allowing annual license renewals under certain circumstances).
5 In re PacifiCorp's Amendment of Klamath Hydroelectric Project License, 162 FERC¶61,236,Ordering Paragraph
(C)(2018)the FERC subsequently amended Project No.2082 to also remove the Keno Development and associated
facilities).
'In re PacifiCorp' Transfer of Lower Klamath Project License, 175 FERC¶61,236(June 17,2021).
APPLICATION OF ROCKY MOUNTAIN POWER Page 3

decommissioned.FERC again amended the Project No.2082 license to remove the non-generating
Keno Development from the Klamath Hydroelectric Project.' Consistent with these decisions,
Project No. 2082 currently encompasses three developments: (1) the East Side Development; (2)
the West Side Development; and (3) the Fall Creek Development.8
8. Currently, the Fall Creek Development has an approximate 2.2 megawatt ("MW")
nameplate capacity,' and includes the following facilities: (a) a 127-foot-long, 7-foot-high
diversion dam composed of two earth embankment sections separated by a 32-foot-long, concrete
and timber flashboard spillway structure; (b) a 4,560-foot-long earthen and rock-cut power canal;
(c) 2,834 feet of steel penstock; (d) a powerhouse containing three horizontal shaft Pelton turbines
with a total of 2.2 MW of authorized capacity and a total rated discharge capacity of 60 cubic feet
per second; (e)three single phase, step-up transformers; and(f)two associated 69-kilovolt primary
transmission lines.'0
9. With the decommissioning of the Lower Klamath Project completed,the Fall Creek
Development is the only remaining hydroelectric development in PacifiCorp's Klamath
Hydroelectric Project currently operating.The Fall Creek Hatchery,located on land adjacent to the
Fall Creek Development,is not part of the Klamath Hydroelectric Project,and neither the hatchery
nor real property underlying the hatchery are included in, nor impacted by, the proposed sale of
the Fall Creek Development.
10. The Fall Creek Development must either be relicensed with the FERC, or removed
from the current FERC license through a license surrender or amendment process. When
7 In re PacifiCorp' Amendment of Klamath Hydroelectric Project License, 185 FERC¶61,207(Dec. 10,2023).
8 Id.
9 E.g.,In re PacifiCorp' 2025IRP, at 122(available here:
https://www.pacificorp.com/content/dgp/pcorp/documents/en/pacificorp/energy/grated-resource-plan/2025-
irp/2025_IRP_Vol_I.pd fl.
10 In re PacifiCorp' Amendment of Klamath Facility License, 185 FERC¶61,207,Ordering¶(B)(4).
APPLICATION OF ROCKY MOUNTAIN POWER Page 4

considering the limited generation produced by the facility, its lack of storage as a run-of-river
facility, the cost of implementing new relicensing requirements, and the fact that no other
hydroelectric developments remain in the local area, which increases the operational costs for the
remote facility, the Company has determined that the sale of the Fall Creek Development to the
City of Yreka is preferable to continuing to operate the development under a new FERC license.
Accordingly, PacifiCorp's request to remove all infrastructure, lands, and license articles related
to the Fall Creek Development from the Klamath Hydroelectric Project license will be filed shortly
with the FERC.
B. Disconnection of Fall Creek Generating Units
11. Following approval from the FERC, PacifiCorp plans to cease power generation,
disconnect the generating units from the power grid, drain the facilities of any fluids, and convey
certain facilities and associated lands to the City of Yreka upon closing of a purchase and sale
agreement with the City of Yreka. PacifiCorp's request to the FERC to disconnect the Fall Creek
Development from the grid and remove the Fall Creek Development from the Project No. 2082
license does not seek approval of any construction, development, or any other ground-disturbing
activities, nor does it involve any statutory or regulatory requirements of the State of California.
As a result, the transaction with the City of Yreka will only require a partial decommissioning of
the facility, and no reclamation costs.
12. Absent a potential sale of the facility, full decommissioning of the facilities would
be necessary, subject to approval and oversight from the FERC. PacifiCorp estimates that full
decommissioning, consistent with FERC standards, would cost approximately $5 million.
C. Disposition
13. The City of Yreka has agreed to purchase the following Fall Creek facilities: all
improvements and fixtures,including(i)a concrete flash-board diversion dam; (ii)intake structure
APPLICATION OF ROCKY MOUNTAIN POWER Page 5

and slide gates; (iii) a power canal; (iv) reinforced concrete forebay with trashrack,; (v) steel
penstock; (vi) a wood-framed metal clad powerhouse containing three generating units rated at a
total of 2.2 MW (will be inoperable) ; (vii) a tailrace; (viii) office trailer; and (ix) a residential
dwelling. In addition to the sale of the Fall Creek facilities,the proposed transaction also includes
the relevant items: real property located in Siskiyou County California; real property located in
Jackson County, Oregon; personal property, including various Fall Creek records and plant
equipment and inventory; and related Fall Creek contract rights and certain permitted
encumbrances.
14. As of June 2025, the Fall Creek assets had a total-Company net book value of
$286,000. If approved, PacifiCorp will record the disposition of the property in the following
FERC accounts: hydroelectric, account 33010, and transmission, account 35010.
15. The disposition does not require any construction, development, or any other
ground-disturbing activities that would otherwise impact the appropriation, diversion, and use of
water.
16. The transaction includes two conditions precedent that require PacifiCorp to
receive all necessary state and federal regulatory approvals, as well as approval from the FERC
regarding the amendment of the license for Project No. 2082 to remove the Fall Creek
Development, prior to closing.
17. Within 30 days of receiving FERC approval,Yreka and PacifiCorp will agree to a
process to transfer Fall Creek to the City of Yreka, and identify a specific closing date. The parties
specifically waive special, punitive, exemplary, consequential, incidental or indirect losses or
damages that could arise from the purchase and sale agreement.
18. The timing and sequencing of regulatory approval is important to protect parties'
APPLICATION OF ROCKY MOUNTAIN POWER Page 6

interests under a sales agreement and ensure orderly disposition of Fall Creek facilities and lands.
For these reasons, PacifiCorp respectfully requests the Commission approve the Application prior
to the City of Yreka taking title to the Fall Creek Development and related assets.
III. PARTIAL DECOMMISSIONING
19. PacifiCorp anticipates incurring approximately $500,000 in costs for the partial
decommissioning of the facility,and related administrative and legal fees to execute the agreement.
20. Regarding partial decommissioning,among other activities,PacifiCorp proposes to
leave the diversion and conduit infrastructure in-place as part of the transfer of ownership to
support the City of Yreka's intended use of the facility, but PacifiCorp will remove connections
between transmission and generation infrastructure and leave the hydroelectric generating units
incapable of generating electricity as the City of Yreka has no interest in generating electricity
from the remaining infrastructure. There is no ground-disturbing activity associated with
PacifiCorp's decommissioning plan.
21. Additionally, PacifiCorp will remove the 120-volt, direct current battery bank,
relays, meters, controls, and other assorted equipment for potential reuse in other non-Project
locations and additional isolation of potentially energized equipment. Conductors on the low-side
bushings will be removed,and the high-and low-side bushings will be grounded.The resistor bank
will be decommissioned in-place, grounded, and isolated from voltage. The main plant control
panel and switches will remain in-place. The powerhouse structure, associated water diversion
infrastructure within the powerhouse, and other equipment incapable of hydroelectric power
generation in the resulting,isolated state within the powerhouse will remain for the City of Yreka's
water supply purposes.
22. Absent a potential sale of Fall Creek, full decommissioning or relicensing of the
APPLICATION OF ROCKY MOUNTAIN POWER Page 7

facilities would be necessary. Given the difference in forecasted cost burdens for customers as
shown in Confidential Attachment A, PacifiCorp would likely pursue full decommissioning of the
development if the sale of these facilities is not approved.
IV. STANDARD OF DECISION
23. I.C. § 61-328(1) requires the Company to obtain Commission approval before
transferring property used in the generation of electric power to the public. As relevant here, in
order to approve a property transfer, I.C. § 61-328(3) requires that the Commission determine:
"(a) That the transaction is consistent with the public interest; (b) That the cost of and rates for
supplying service will not be increased by reason of such transaction; and (c) That the applicant
for such acquisition or transfer has the bona fide intent and financial ability to operate and
maintain said property in the public service."
V. APPLICATION
A. Public Interest
24. The partial decommissioning and sale of the relevant Fall Creek facilities to the
City of Yreka serves the public interest because it represents the best balance of cost and risk for
customers as it is lower cost and lower risk than continued operations as shown in the present
value revenue requirement("PVRR") analyses summarized in Confidential Attachment A to this
Application. Further, the sale of certain Fall Creek facilities will not adversely affect retail or
wholesale customers and will have no material effect on the Company's generation capacity.
These issues are detailed below.
25. Fall Creek, with a generation capacity of 2.2 MW, has averaged 8,100 megawatt-
hours ("MWh") of annual generation from 2009 through 2023, and has generated electricity for
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PacifiCorp customers for over 100 years.As the Company intends to remove the generation units
from Fall Creek prior to the disposition to the City of Yreka, this resource will no longer serve
electric customers. However,this 2.2 MW of generation capacity represents a de minimis amount
of PacifiCorp's overall generation portfolio, which consists of more than 11,800 MW of
Company-owned hydroelectric,wind, natural gas, coal, solar, and geothermal resources.
26. The loss of generation from Fall Creek nonetheless provides customer benefits, as
the Company's PVRR analyses summarized in Confidential Attachment A and the supporting
confidential workpaper used increased thermal generation and wholesale market purchases to
replace this lost generation. Said another way: the Fall Creek transaction, even considering
replacement power costs,provides benefit to customers through increased thermal generation and
wholesale market purchases, compared to the full decommissioning,or relicensing and continued
operation of the facility.
27. Following transfer of ownership, the City of Yreka intends to use the existing
infrastructure of the Fall Creek Development for non-power, water supply purposes to continue
the delivery of water to the City of Yreka's municipal water supply intake located immediately
downstream of the Fall Creek powerhouse tailrace, consistent with the city's historic and current
operations.
B. Economic Analysis
28. The Company's decision was based on a financial analysis to evaluate the best
alternative for customers. The analysis considered three options for the Fall Creek Development:
sale,relicense, or 2027 decommissioning. The results indicate that a sale of the facility consistent
with the terms being negotiated with the City of Yreka would provide a PVRR benefit to
customers,as compared to the full decommissioning alternative and the relicensing and continued
APPLICATION OF ROCKY MOUNTAIN POWER Page 9

operation alternative. The results of the financial analyses are summarized in Confidential
Attachment A and the supporting confidential workpaper filed with this Application.
29. The approval of this transfer will not impact current rates. The Company's present
Application seeks authorization for the partial decommissioning and sale of Fall Creek with a
PVRR lower than the alternatives considered Therefore, the transfer proposed in this proceeding
will not affect current rates.
C. Maintain in the Public Service
30. As shown in current draft of the purchase and sale agreement,provided as
Confidential Attachment B, the City of Yreka intends to purchase this property. Further,based on
Rocky Mountain Power's current knowledge,because the City intends to utilize the facilities to
meet its water needs, the City will operate and maintain the property, to the extent applicable, in
the public service for its citizens.
VI. REQUEST FOR MODIFIED PROCEDURE
31. Rocky Mountain Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be processed under
Modified Procedure,i.e.,by written submissions rather than by hearing, in accordance with Idaho
Public Utilities Commission Rules of Procedure 201 —204.
VII. CONFIDENTIAL INFORMATION
32. This filing, specifically Confidential Attachment A and the supporting confidential
workpaper and the purchase and sale agreement included with Confidential Attachment B,
includes trade secrets and confidential information exempt from public review under Idaho Code
§§ 74-104-109 and Idaho Public Utilities Commission's Rule of Procedure 67.
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VIII. CONCLUSION
33. WHEREFORE, Rocky Mountain Power respectfully requests an order approving
the sale of certain Fall Creek facilities to the City of Yreka pursuant to I.C. § 61-328 and
determining that the property disposition is in the public interest.
Respectfully submitted this 4th day of September 2025.
Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email: joseph.dallasg]2acificorp.com
Attorney for Rocky Mountain Power
APPLICATION OF ROCKY MOUNTAIN POWER Page 11

ATTACHMENT A

REDACTED Attachment A
Page 1 of 1
As shown in the Confidential Figure above, the sale of Fall Creek would result in a
present value revenue requirement ("PVRR") benefit to customers, compared to either a
_ PVRR cost for the decommissioning of the facility, or a PVRR cost for
relicensing and continued operation of the facility. In other words, there is a cost to
customers if the Company decided to relicense and continue operating the facility, and a
_ cost to customers if the Company fully decommissioned the facility.

Attachment B is Confidential in its entirety and
is Provided under Separate Cover