20250911Staff Comments.pdf

ERIKA K. MELANSON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11560
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )
POWER'S APPLICATION TO INCREASE ) CASE NO. PAC-E-25-17
THE BPA REP CREDIT EFFECTIVE )
OCTOBER 2025 THROUGH SEPTEMBER )
2028 ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
BACKGROUND
On August 27, 2025, Rocky Mountain Power, a division of PacifiCorp ("Company")
applied to the Commission requesting to increase the Bonneville Power Administration's
(`BPA") residential and small farm credit. The Company requested an October 1, 2025,
effective date.
The Company is requesting the Commission issue an order approving an update to
Electric Service Schedule No. 34—Pacific Northwest Electric Power Planning and Conservation
Act Residential and Farm Kilowatt-Hour("kWh") Credit("Schedule 34"). The proposed credit
STAFF COMMENTS 1 SEPTEMBER 11, 2025

would be $0.012545 per kWh for rate schedules 1, 6A, 7A, 10, 23A, 35A, and 36 effective
October 1, 2025, through September 30, 2028. Application at 6.
The current Schedule 34 credit is $0.007376 per kWh. Id. at 3-4.
STAFF ANALYSIS
Staff reviewed the methodology and calculation of the proposed Residential Exchange
Program ("REP") credit rate and confirmed that the approach is consistent with the terms and
conditions of Schedule 34. Staff verified the initial inputs and independently recalculated the
proposed credit rate. Staff believes the Company correctly calculated the credit rate of
$0.012545 per kWh and recommends the rate be approved.
The Residential and Small Farm Energy Credit Rate results from an agreement between
the Company and BPA regarding the REP. Under the REP, BPA provides a share of the benefits
of the federal Columbia River power system to the residential and small farm customers served
by six investor-owned utilities of the Pacific Northwest, including Rocky Mountain Power. The
benefit is calculated every two years and is implemented via a credit on qualifying customers'
bills. The Company's current residential and small farm credit rate is $0.007379 per kWh. The
proposed credit rate is $0.012545 per kWh. The Company's total allocation of the BPA REP
credit for fiscal years 2026 through 2028 increased by approximately $39.7 million, from $72.5
million to $112.2 million from October 1, 2025, through September 30, 2028. Idaho's share of
the Company's total REP allocated increased from 10.94%to 11.65%.
The BPA REP credit available to qualifying Idaho customers during fiscal years 2026
through 2028 is $13.1 million. The $13.1 million REP credit was divided by the calendar year
2023 usage level of the qualifying customers of approximately 1.04 GWh, to produce a Schedule
No. 34 rate of$0.012545 per kWh.
STAFF COMMENTS 2 SEPTEMBER 11, 2025

STAFF RECOMMENDATION
Staff recommends that the Commission approve the proposed Electric Service Schedule
No. 34, as filed, with an effective date of October 1, 2025.
Respectfully submitted this I Ith day of September 2025.
( Tiuf gz ( C-' -.—._..
Erika K. Melanson
Deputy Attorney General
Technical Staff. Donn English
I:\Utility\UMISC\COMMENTS\PAC-E-25-17 Comments.docx
STAFF COMMENTS 3 SEPTEMBER 11, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1 lth DAY OF SEPTEMBER 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-25-17, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
MARK ALDER DATA REQUEST RESPONSE CENTER
IDAHO REGULATORY AFFAIRS MGR. E-MAIL ONLY:
ROCKY MOUNTAIN POWER datarequest(d),pacificorp.com
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: mark.alderkpacificorp.com
JOE DALLAS
825 NE MULTNOMAH, SUITE 2000
PORTLAND, OR 97232
E-MAIL: [e-mail]
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE