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HomeMy WebLinkAbout20250924Reply Comments.pdf _ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330 POWER. Salt Lake City,UT 84116 A DIVISION OF PACIFICORP RECEIVED SEPTEMBER 24, 2025 September 24, 2025 IDAHO PUBLIC UTILITIES COMMISSION 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-25-02 IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AUTHORITY TO IMPLEMENT CHANGES TO NON-LEGACY CUSTOMER GENERATORS Attention: Commission Secretary Pursuant to Commission Order No. 36716 providing Amended Notice of Virtual Customer Hearing, Amended Notice of Modified Procedure, Notice of Suspension of Proposed Effective Date and establishing the procedural schedule please find Rocky Mountain Power's Reply Comments in the above referenced matter. Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313. Very truly yours, a"_D Joe Steward Senior Vice President, Regulation Cc: Service List CERTIFICATE OF SERVICE I hereby certify that on this day, I caused to be served, via email, a true and correct copy of Reply Comments in Case No. PAC-E-25-02 to the following: Service List Commission Staff Chris Burdin Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd.,Bldg No. 8, Suite 201-A Boise, ID 83720-0074 chris.burdin@puc.Idaho.gov PacifiCor , dba Rocky Mountain Power Mark Alder Joe Dallas PacifiCorp/dba Rocky Mountain Power PacifiCorp/dba Rocky Mountain Power 1407 West North Temple, Suite 330 825 NE Multnomah Street, Suite 2000 Salt Lake City,UT 84116 Portland, OR 97232 mark.alder@pacificorp.com joseph.dallas@pacificorp.com Data Request Response Center PacifiCorp datarequestkpacificolp.com Dated this 24th day of September, 2025. 1 , Carrie Meyer Manager, Discovery& Regulatory Operations Page 1 of 1 Joe Dallas (ISB# 10330) PacifiCorp, Senior Attorney 825 NE Multnomah Street, Suite 2000 Portland, OR 97232 Email:joseph.dallaskpacificorp.com Attorney for Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) CASE NO. PAC-E-25-02 OF ROCKY MOUNTAIN POWER FOR ) AUTHORITY TO IMPLEMENT CHANGES ) REPLY COMMENTS OF TO NON-LEGACY CUSTOMER ) ROCKY MOUNTAIN POWER GENERATORS ) Pursuant to Rule 202.01(d) of the Rules of Procedure of the Idaho Public Utilities Commission ("Commission") and the Commission's August 13, 2025, Amended Notice of Modified Procedure, Rocky Mountain Power a division of PacifiCorp (the "Company") hereby submits reply comments in the above-referenced case. I. BACKGROUND ]. On June 29, 2023, as required by Order No. 34753, the Company submitted an on- site generation study.On August 8,2024,the Commission issued Order No. 36286,acknowledging the Study and ordering the Company to file a new case, requesting changes to the structure and design of its proposed export credit rate within six months. On February 7, 2025, the Company filed an application("Application")with the Commission requesting the Commission approve the Company's proposed changes to its on-site self-generation Electric Service Schedule 136 ("Schedule 136")tariff in accordance with Order No. 36286 and approve the Company's proposed: (1) export credit rate for customers on Schedule 136 beginning October 1, 2025, (2) an increased REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page l cap for non-residential customers to 2,000 kW, (3) annual updates to the export credit rate, and(4) updated Schedule 136 tariff incorporating the changes reflected in its application. 2. On June 17, 2025, Commission Order No. 36642 provided Notice of Virtual Public Workshop, Notice of Virtual Customer Hearing, authorized processing of the Application by Modified Procedure, and established the procedural schedule allowing persons who would like to file written comments to have until August 14, 2025, and the Company having until September 3, 2025, to file reply comments. 3. On July 30, 2025, the Company filed an amended application (`Amended Application") with the Commission to update the inputs used to calculate the proposed export credit rate for Schedule 136 customers. On August 13, 2025, Commission Order No. 36716 provided an Amended Notice of Virtual Customer Hearing, an Amended Notice of Modified Procedure, and a Notice of Suspension of Proposed Effective Date, allowing persons who would like to file written comments to have until September 3, 2025, and the Company having until September 24, 2025, to file reply comments. 4. On September 3,2025 Staff filed comments.No other party has intervened however there have been over 150 public comments filed. II. REPLY COMMENTS 5. PacifiCorp appreciates the comments submitted by Staff. As a preliminary matter, the Company agrees with Staff's review of the export credit calculation, timing of the annual update, and a rate stability mechanism. The Company agrees to file the annual update before July 15t each year and is not opposed to a rate stability mechanism as proposed by Staff. In its response below, the Company will reply to recommendations made by Staff concerning on-peak hours and the project eligibility cap. REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page 2 A. On-Peak Hours 6. Staff,for the sake of simplicity,agreed with the Company's proposed on-peak hours but believed that 2-3pm should be considered as an on-peak hour in the future to send a better price signal to customers.The Company will continue to monitor its on-peak hours in an effort to balance price signals and ease of use for the customer over time.At this time, the Company believes that aligning with existing rate schedules is simplest for participants and that its proposed time of use periods are appropriate.An examination of Loss of Load Probability("LOLP")from the 2025 IRP presented in Figure 1 below shows that 2:00-3:00pm Mountain Time did not have any loss of load events, which would make it reasonable to classify as an off-peak hour.1 Figure 1 —2025 IRP Loss of Load Probability Month 2025-2028 Events(sums to 1001c) MPT PPT Beginning Beginning Hour 1 2 3 4 5 6 7 8 9 10 11 12 1:00 AM 12 AM 1 2:00 AM 1:00:00 AM 2 3:00 AM 2:00 AM 3 4:00 AM 3:00 AM 4 5:00 AM 4:00 AM 5 6:00 AM 5:00 AM 6 7:00 AM 6:00 AM 7 1% 8:00 AM 7:00 AM 8 3% 9:00 AM 8:00 AM 9 1% 10:00 AM 9:00 AM 10 11:00 AM 10:00 AM 11 12:00 PM 11:00 AM 12 1:00 PM 12:00 PM 13 2:00 PM 1:00 PM 14 3:00 PM 2:00 PM 15 4:00 PM 3:00 PM 16 1% 5:00 PM 4:00 PM 17 2% 1% 7% 6:00 PM 5:00 PM 18 1% 2% 1% 8% 7:00 PM 6:00 PM 19 1% 8% 1% 6% 8:00 PM 7:00 PM 20 1% = 1% 4% 9:00 PM 8:00 PM 21 1% 2% 1% 4% 10:00 PM 9:00 PM 22 2% 1% 4% 11:00 PM 10:00 PM 23 2% 3% 12:00 AM 11:00 PM 24 2% 2% 'Figure 1 is derived from the data underlying Figures K.1 and K.2 in the 2025 IRP. The Company is including the Confidential Workpapers used to develop this figure with these reply comments. REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page 3 B. Project Eligibility Cap 7. Staff recommends the cap for residential customers to stay at 25kW and for non- residential customers, the cap to be 100kW or each customer's maximum demand (defined as greatest monthly billing demand during the previous 12 months), whichever is greater. The Company supports making the cap simpler for smaller non-residential customers and allowing systems to be sized up to 100 kW without an examination of the customer's load. However, the Company is concerned with having no upper limit on non-residential customer generator system sizes that would be eligible for the Net Billing tariff.As noted in its initial filing,the Company has a 2 MW limit in other states in which it operates. The export credit price is intended to be for primarily smaller customer generation installations, not utility-scale solar. 8. The Company has found that it is more appropriate for customer generation systems larger than 2 MW to become a qualifying facility ("QF").Z The QF structure allows large generation facilities,that have a substantial impact on the company's system, to be integrated into the Company's long-term resource planning while providing a regulatory framework more appropriate for a large generation system. For these reasons, the Company agrees with a 25 kW cap for residential customers, but recommends that the non-residential cap be the greater of 100 kW or their peak demand, customer's peak demand, defined as the 15-minute period of the customer's greatest use during the previous 12 months, but not exceed 2 MW. C. Revised Tariffs 9. Staff recommends revising the Company's tariff to explicitly state that the costs of the reliability studies and systems upgrades are to be recovered from the customer who causes them. Currently, Schedule 136 already states that "At Customer's expense, the Company shall 2 See 18 C.F.R. §292.203,which defines a QF under the Public Utility Regulatory Policies Act of 1978 (PURPA). REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page 4 make reasonable modifications to the Company's system necessary to accommodate the Customer's facility". The Company believes this provision is already clear regarding the customer's responsibility for all costs related to integrating their generation into the system. Therefore, no further clarification on cost assignability is needed. 10. However, the Company has added the cost of reliability studies as a specific expense for which the customer is responsible. This revision, along with the project eligibility updates mentioned previously, has been included in the Company's proposed tariff, which is attached as Attachment A to these reply comments. D. Annual Customer Generation Report 11. In Case No. PAC-E-16-07, Order No. 335113 directed the Company to file an annual net metering report. The report's primary purpose was to keep the Commission informed on any cost shifting from on-site generators to non-participating customers.4 Since this case should largely resolve any cost shifting issues and because the annual report takes substantial Company resources to compile, the Company respectfully requests the Commission discontinue this reporting requirement. III. CONFIDENTIAL INFORMATION 12. This filing, specifically the Confidential Workpapers, includes confidential information exempt from public review under Idaho Code §§ 74-104-109 and Idaho Public Utilities Commission's Rule of Procedure 67. 3 In the Matter of the Application of Rocky Mountain Power Requesting Authority to Modify Electric Service Schedule 135—Net Metering Service,Case No.PAC-E-16-07.Order No. 33511. 4 Id at p.4: "while the current participation level in the net metering service and the resulting cost shifting are small, they are large enough to warrant routine monitoring by the Commission". REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page 5 IV. CONCLUSION 13. Based on the foregoing, the Company respectfully requests that the Commission approve the Company's proposed changes, as amended herein, to its on-site self-generation Schedule 136 tariff in accordance with Order No. 36286 and approve the Company's proposed: (1)export credit rate for customers on Schedule 136, (2) a cap for non-residential customers of the greater of 100 kW or their peak demand, customer's peak demand,defined as the 15-minute period of the customer's greatest use during the previous 12 months, but not to exceed 2 MW, (3) annual updates to the export credit rate, and(4)updated Schedule 136 tariff as updated and included with these reply comments. DATED this 24t'day of September 2025. Respectfully submitted, ROCKY MOUNTAIN POWER Joe Dallas (ISB# 10330) PacifiCorp, Senior Attorney 825 NE Multnomah Street, Suite 2000 Portland, OR 97232 Email:„joseph.dallasg]2acificor2.com Attorney for Rocky Mountain Power REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page 6 ATTACHMENT A PROPOSED TARIFFS ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP First Revision of Sheet No. 136.1 I.P.U.C.No. 1 Canceling Original Sheet No. 136.1 ROCKY MOUNTAIN POWER ELECTRIC SERVICE SCHEDULE NO. 136 STATE OF IDAHO Net Billing Service AVAILABILITY: At any point on the Company's interconnected system. APPLICATION: On a first-come, first-served basis to any customer that owns and operates an Eligible Generating Plant that is located on the Customer's premises, on the Customer's side of the Point of Delivery,is interconnected and operates in parallel with the Company's existing transmission and distribution facilities and is intended primarily to offset part or all of the Customer's own electrical requirements. DEFINITIONS: Net Billing: Charges for all electricity supplied by the Company and netted by the export credit for the electricity generated by an eligible Customer and fed back to the electric grid over the applicable billing period. Eligible Generating Plant: A facility that uses energy derived from the sun,wind,water,biomass or fuel cell technology to generate electricity. An Eligible Generating Plant may not have a generating capacity of more than twenty-five(25)kilowatts for customers taking service on Schedules 1;or 36, '�A,For all other customers, an Eligible Generating Plant may not have a generating capacity of more than or-the lessergreater of the customer's peak demand, defined as the 15-minute period of the customer's greatest use during the previous 12 months, or-one hundred(100)kilowatts,but shall not exceed enetwo ht (24-00)kilew#sme.aw�atts4 ~-���. To qualify, a Customer must maintain its retail electric service account for the loads served at the Point of Delivery adjacent to the Generation Interconnection Point as active and in good standing. Generation Interconnection Point: The point where the conductors installed to allow receipt of Customer's generation connect to the Company's facilities adjacent to the Customer's Point of Delivery. Exported Customer-Generated Energy: The amount of customer-generated Energy in excess of the customer's on-site consumption. MONTHLY BILL: The Electric Service Charge shall be computed in accordance with the charges for the Monthly Bill in the applicable standard service tariff and the Credits for Exported Customer-Generated (continued) Submitted Under Case No. PAC-E-49-"25-02 ISSUED: Oeteber- 12,202-OSeptember 24, 2025 EFFECTIVE: November- 1,October 1,2025 � ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP First Revision of Sheet No. 136.1 I.P.U.C.No. 1 Canceling Original Sheet No. 136.1 Energy, if any, shall be computed at the following rates subject to the Special Conditions in this tariff. Exported Customer-Generated Energy Credit Rates are subject to change, as approved by the Commission. (continued) Submitted Under Case No. PAC-E-49-"25-02 ISSUED: Oeteber- 12,202-OSeptember 24, 2025 EFFECTIVE: November- 1,October 1,2025 _ ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP FiFStSecond Revision of Sheet No. 136.2 I.P.U.C.No. 1 Canceling First RevisionOrigi-nal of Sheet No. 136.2 ELECTRIC SERVICE SCHEDULE NO. 136-Continued Exported Customer-Generated Energy Credit Rates: Within the monthly billing period, all energy exported from the customer's generating plant to the Company's system shall be financially credited at the following prices:^^ se applicable retail energy m4e. Any excess monthly or-p-dits slhall he carried forward and shall on the aeeeu+4, and may only be tised to ef&et the Gustemer-'s energy ehar-ges a4 the mete . . Pting the er-edit or-other-eligible meter-s as outlined under-Speeial Condition No. 11. taking retail service under Schedules 1,36,23 or 23A shall be financially eredite b. Custemer-s taking retail sefviee undef all other- Sehedules shall be finaneially er-edite excess monthly exported energy at the Net Billing Rate Credit specified in seeti 2. Net Billing Rate Credit eqttals 95 per-eent of the monthly weighted aver-age of the daily on peak and og peak Mid Columbia later-eontifiental Exehaage Eleet+ieit-y Pt4ee !nde* (Mid C; WE index) pfiees f6r- nen fifm enefgy. This rate is ealeulated based ttpefl the pr-eViEffis days, the aver-age of the immediately pt:eeediag a-ad�911owiag r-epo4ing per-iods or-days will be used. 1. E- �f.,A Ctistomer Generated Eaefgy Credit Rates for Customers taking serviee under any Time of Day Sehe"le will be ealettla4ed separately for-on peak and og peak tigage, Billing Months June Billing Months November through October,Inclusive through May, Inclusive On-Peak kWh 14.6660 5.5970 Off-Peak kWh 3.6640 1.2280 Time Periods: On-Peak: November through May inclusive 6:00 a.m. to 9:00 a.m. and 6:00 p.m. to 11:00 p.m., all dam June through October inclusive 3:00 p.m. to 11:00 p.m., all days. Off-Peak: All other times. 3 SPECIAL CONDITIONS: 1. Applications for service under this schedule will be subject to the following application fee: $85 per application. (continued) Submitted Under T.fig ^dvieo Case No. 224-2PAC-E-25-02 ISSUED: June 14,202 September 24, 2025 EFFECTIVE: Auger '202-2 ober 1,2025 _ ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP FiFStSecond Revision of Sheet No. 136.2 LP.U.C.No. 1 Canceling First Revisio-Origi-nal of Sheet No. 136.2 2. Energy charges for electricity supplied by the Company shall be computed in accordance with a Customer's applicable standard service tariff. 3. The credit value in dollars computed for the Exported Customer-Generated Energy will be applied against charges on the Customer's monthly bill. Excess credits will carry-over to the next monthly bill. Excess credits may only be used to offset charges at the meter originating the credit or other eligible meters as outlined under Special Condition No. 11. (continued) Submitted Under T.fig ^dvieo Case No. 224-2PAC-E-25-02 ISSUED: June 14,202 September 24, 2025 EFFECTIVE: Auger '202-2 ctober 1,2025 � ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP First Revision of Sheet No. 136.3 I.P.U.C.No. 1 Canceling Original Sheet No. 136.3 ELECTRIC SERVICE SCHEDULE NO. 136-Continued SPECIAL CONDITIONS: (continued) 4. The Customer shall execute an interconnection agreement with the Company prior to interconnection of the Eligible Generating Plant with the Company's system. The Customer shall provide the interconnection on Customer's side of the meter. The Customer is responsible for all costs associated with the Eligible Generating Plant and interconnection facilities,including additional metering necessary for service under this schedule and the cost of any reliability studies. At Customer's expense, the Company shall make reasonable modifications to the Company's system necessary to accommodate the Customer's facility. The payment for such modifications is due in advance of construction. The Customer shall provide at the Customer's expense all equipment that is necessary to meet applicable local, state and national standards regarding electrical and fire safety, power quality, and interconnection requirements established by the National Electrical Code, the Institute of Electrical and Electronics Engineers, American National Standards Institute, and Underwriters Laboratories. 5. The Company's written approval of the Customer's protection-isolation method to ensure generator disconnection in case of a power interruption from the Company is required before service is provided under this schedule. 6. The Company shall not be obligated to accept, and the Company may require the Customer to curtail, interrupt or reduce deliveries of energy if the Company, consistent with prudent electrical practices, determines that curtailment, interruption or reduction is necessary because of line construction or maintenance requirements, emergencies, or other critical operating conditions on its system. 7. If the Company is required by the Commission to institute curtailment of deliveries of electricity to its customers, the Company may require the Customer to curtail its consumption of electricity in the same manner and to the same degree as other Customers within the same customer class who do not receive service under this schedule. 8. The Customer shall never deliver or attempt to deliver energy to the Company's system when the Company's system serving the Customer's generation facility is de-energized for any reason. 9. The Company shall not be liable directly or indirectly for permitting or continuing to allow an attachment of a net metering facility, or for the acts or omissions of the Customer that cause loss or injury, including death,to Customer or any third party. (continued) Submitted Under Case No. PAC-E-49-"25-02 ISSUED: Oeteber- 12,202-OSeptember 24,2025 EFFECTIVE: November- 1,October 1,2025 � ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP First Revision of Sheet No. 136.4 I.P.U.C.No. 1 Canceling Original Sheet No. 136.4 ELECTRIC SERVICE SCHEDULE NO. 136-Continued SPECIAL CONDITIONS: (continued) 10. The Customer shall grant to the Company access to all Company equipment and facilities including adequate and continuing access rights to the property of the Customer for the purpose of installation, operation,maintenance,replacement or any other service required of said equipment. The Company may test and inspect an interconnection at times that it considers necessary to ensure the safety of electrical workers and to preserve the integrity of the electric power grid. 11. Transfer of excess credits: a. If excess credits exist at a meter at the end of the Customer's February billing period the Customer may request to transfer the unused excess credits to offset charges at the Customer's other eligible meters. Excess credits may be transferred to a meter or meters that following efitefia.� i) The meter-is leea4ed on, or-een4ipetts to,the Premises on whieh the meter-with exeess efedits afe loea4ed; and iii) The eleetfieit-y r-eeefded by the meter- is on the same fate sehedtile as the meter-with the exeess ems. b. Customers may submit written requests to transfer excess credits between the eligible meter(s)March 1 st through March 315t of each year. A $10 processing charge will apply to each meter receiving the transferred excess credits. c. All requests must be received by Rocky Mountain Power by midnight on March 31St ELECTRIC SERVICE REGULATIONS: Service under this Schedule will be in accordance with the terms of the Electric Service Agreement between the Customer and the Company. The Electric Service Regulations of the Company on file with and approved by the Idaho Public Utilities Commission, including future applicable amendments,will be considered as forming a part of and incorporated in said Agreement. Submitted Under Case No. PAC-E-49-9925-02 ISSUED: Oeteber- 12,202-OSeptember 24,2025 EFFECTIVE: November- 1,October 1,2025 ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP First Revision of Sheet No. 136.1 I.P.U.C.No. 1 Canceling Original Sheet No. 136.1 ROCKY MOUNTAIN POWER ELECTRIC SERVICE SCHEDULE NO. 136 STATE OF IDAHO Net Billing Service AVAILABILITY: At any point on the Company's interconnected system. APPLICATION: On a first-come, first-served basis to any customer that owns and operates an Eligible Generating Plant that is located on the Customer's premises, on the Customer's side of the Point of Delivery,is interconnected and operates in parallel with the Company's existing transmission and distribution facilities and is intended primarily to offset part or all of the Customer's own electrical requirements. DEFINITIONS: Net Billing: Charges for all electricity supplied by the Company and netted by the export credit for the electricity generated by an eligible Customer and fed back to the electric grid over the applicable billing period. Eligible Generating Plant: A facility that uses energy derived from the sun,wind,water,biomass or fuel cell technology to generate electricity. An Eligible Generating Plant may not have a generating capacity of more than twenty-five (25) kilowatts for customers taking service on Schedules I or 36. For all other customers, an Eligible Generating Plant may not have a generating capacity of more than the greater of the customer's peak demand, defined as the 15-minute period of the customer's greatest use during the previous 12 months, or one hundred(100)kilowatts,but shall not exceed two (2)megawatts. To qualify, a Customer must maintain its retail electric service account for the loads served at the Point of Delivery adjacent to the Generation Interconnection Point as active and in good standing. Generation Interconnection Point: The point where the conductors installed to allow receipt of Customer's generation connect to the Company's facilities adjacent to the Customer's Point of Delivery. Exported Customer-Generated Energy: The amount of customer-generated Energy in excess of the customer's on-site consumption. MONTHLY BILL: The Electric Service Charge shall be computed in accordance with the charges for the Monthly Bill in the applicable standard service tariff and the Credits for Exported Customer-Generated Energy, if any, shall be computed at the following rates subject to the Special Conditions in this tariff. Exported Customer-Generated Energy Credit Rates are subject to change, as approved by the Commission. (continued) Submitted Under Case No. PAC-E-25-02 ISSUED: September 24, 2025 EFFECTIVE: October 1, 2025 ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP Second Revision of Sheet No. 136.2 I.P.U.C.No. I Canceling First Revision of Sheet No. 136.2 ELECTRIC SERVICE SCHEDULE NO. 136-Continued Exported Customer-Generated Energy Credit Rates: Within the monthly billing period, all energy exported from the customer's generating plant to the Company's system shall be financially credited at the following prices: Billing Months June Billing Months November through October,Inclusive through May,Inclusive On-Peak kWh 14.6660 5.597¢ Off-Peak kWh 3.664¢ 1.228¢ Time Periods: On-Peak: November through May inclusive 6:00 a.m.to 9:00 a.m. and 6:00 p.m.to 11:00 p.m., all days. June through October inclusive 3:00 p.m.to 11:00 p.m.,all days. Off-Peak: All other times. SPECIAL CONDITIONS: 1. Applications for service under this schedule will be subject to the following application fee: $85 per application. 2. Energy charges for electricity supplied by the Company shall be computed in accordance with a Customer's applicable standard service tariff. 3. The credit value in dollars computed for the Exported Customer-Generated Energy will be applied against charges on the Customer's monthly bill. Excess credits will carry-over to the next monthly bill. Excess credits may only be used to offset charges at the meter originating the credit or other eligible meters as outlined under Special Condition No. 11. (continued) Submitted Under Case No. PAC-E-25-02 ISSUED: September 24, 2025 EFFECTIVE: October 1, 2025 � ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP First Revision of Sheet No. 136.3 I.P.U.C.No. 1 Canceling Original Sheet No. 136.3 ELECTRIC SERVICE SCHEDULE NO. 136-Continued SPECIAL CONDITIONS: (continued) 4. The Customer shall execute an interconnection agreement with the Company prior to interconnection of the Eligible Generating Plant with the Company's system. The Customer shall provide the interconnection on Customer's side of the meter. The Customer is responsible for all costs associated with the Eligible Generating Plant and interconnection facilities,including additional metering necessary for service under this schedule and the cost of any reliability studies. At Customer's expense, the Company shall make reasonable modifications to the Company's system necessary to accommodate the Customer's facility. The payment for such modifications is due in advance of construction. The Customer shall provide at the Customer's expense all equipment that is necessary to meet applicable local, state and national standards regarding electrical and fire safety, power quality, and interconnection requirements established by the National Electrical Code, the Institute of Electrical and Electronics Engineers, American National Standards Institute, and Underwriters Laboratories. 5. The Company's written approval of the Customer's protection-isolation method to ensure generator disconnection in case of a power interruption from the Company is required before service is provided under this schedule. 6. The Company shall not be obligated to accept, and the Company may require the Customer to curtail, interrupt or reduce deliveries of energy if the Company, consistent with prudent electrical practices, determines that curtailment, interruption or reduction is necessary because of line construction or maintenance requirements, emergencies, or other critical operating conditions on its system. 7. If the Company is required by the Commission to institute curtailment of deliveries of electricity to its customers, the Company may require the Customer to curtail its consumption of electricity in the same manner and to the same degree as other Customers within the same customer class who do not receive service under this schedule. 8. The Customer shall never deliver or attempt to deliver energy to the Company's system when the Company's system serving the Customer's generation facility is de-energized for any reason. 9. The Company shall not be liable directly or indirectly for permitting or continuing to allow an attachment of a net metering facility, or for the acts or omissions of the Customer that cause loss or injury, including death,to Customer or any third party. (continued) Submitted Under Case No. PAC-E-25-02 ISSUED: September 24, 2025 EFFECTIVE: October 1, 2025 � ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP First Revision of Sheet No. 136.4 I.P.U.C.No. 1 Canceling Original Sheet No. 136.4 ELECTRIC SERVICE SCHEDULE NO. 136-Continued SPECIAL CONDITIONS: (continued) 10. The Customer shall grant to the Company access to all Company equipment and facilities including adequate and continuing access rights to the property of the Customer for the purpose of installation, operation,maintenance,replacement or any other service required of said equipment. The Company may test and inspect an interconnection at times that it considers necessary to ensure the safety of electrical workers and to preserve the integrity of the electric power grid. 11. Transfer of excess credits: a. If excess credits exist at a meter at the end of the Customer's February billing period the Customer may request to transfer the unused excess credits to offset charges at the Customer's other eligible meters. Excess credits may be transferred to a meter or meters. b. Customers may submit written requests to transfer excess credits between the eligible meter(s)March 1 st through March 315t of each year. A $10 processing charge will apply to each meter receiving the transferred excess credits. c. All requests must be received by Rocky Mountain Power by midnight on March 31 t ELECTRIC SERVICE REGULATIONS: Service under this Schedule will be in accordance with the terms of the Electric Service Agreement between the Customer and the Company. The Electric Service Regulations of the Company on file with and approved by the Idaho Public Utilities Commission, including future applicable amendments,will be considered as forming a part of and incorporated in said Agreement. Submitted Under Case No.PAC-E-25-02 ISSUED: September 24,2025 EFFECTIVE: October 1,2025