20251001Staff Comments.pdf

RECEIVED
October 01, 2025
ADAM TRIPLETT IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
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 FOR AUTHORITY ) CASE NO. PAC-E-25-13
TO DECREASE ELECTRIC SERVICE )
SCHEDULE 191 - CUSTOMER EFFICIENCY )
SERVICES RATE ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Adam Triplett, Deputy Attorney General,
submits the following comments.
BACKGROUND
On June 25, 2025, Rocky Mountain Power, a division of PacifiCorp ("Company"),
applied for authorization to lower the rate for Electric Service Schedule No. 191 ("Schedule
191")—Customer Efficiency Services Rate Adjustment ("Application").
The purpose of the Customer Efficiency Services Rate Adjustment under Schedule 191 is
to recover the costs the Company incurs associated with Commission-approved Demand-Side
Management("DSM") expenditures. To track Schedule 191 collections and DSM program
STAFF COMMENTS 1 OCTOBER 1, 2025

costs, the Company must annually report financial information to review account balances and
program cost-effectiveness.
The Company represents that, as of May 31, 2025, Schedule 191 carries an over-collected
balance of$4,658,434.
The Company expects DSM revenues to continue outpacing expenditures if rates are not
reduced.
The Company projects that, if Schedule 191 rates are unchanged, its DSM balancing
account will be over-collected by $7.4 million by the end of 2028.
The Company proposes decreasing the collection rate under Schedule 191 from 2.50% to
1.92%, effective November 1, 2025, to address this overcollection.
The Company represents that, under the proposed 1.92%rate, its DSM balancing account
will be over-collected by only $10,325 by the end of 2028.
The Company represents that a residential customer using 836 kilowatt-hour("kWh") a
month (about 10,000 kWh annually) will pay $8.40 less for electricity annually.
Previous Changes to Schedule 191
A review of the history of Schedule 191 shows that the Schedule 191 rate was established
in 2006 at a rate of 1.5%. Order No. 29976. In May 2008, the rate increased to 3.72%. Order
No. 30543. In June 2010, the rate increased further to 4.72%. Order No. 32023. In the 2010
General Rate case, the rate decreased to 3.4%. Order No. 32196. In July of 2012, the rate
decreased again to 2.1%. Order No. 32606. In March 2016, the rate increased to 2.7%. Order
No. 33491. Almost three years later, in February of 2019, the rate decreased to 2.25%. Order
No. 34255. The last change to Schedule 191 came when the Commission approved a rate
increase to the current level of2.5%. Order No. 35546.
STAFF ANALYSIS
Staff reviewed the Application and supports the Company's request to decrease the
Schedule 191 Customer Efficiency Service Rate. A Schedule 191 decrease is needed to reflect
actual energy efficiency program participation and expenditures. Staff anticipates that the new
proposed rate adjustment of 1.92%will align the Schedule 191 revenues with the Company's
projected DSM expenditures through 2028. In its Application, the Company provided a forecast
STAFF COMMENTS 2 OCTOBER 1, 2025

of the DSM revenues and expenditures for the next three years (2025-2028). See Attachments A
and B.
Balance and Proposal
As of May 31, 2025, the balance for Schedule 191 was over-funded by $4,658,434.
Application at 2. An over-funded balance means Schedule 191 has been collecting more
revenues than was being expensed. Without an adjustment to the Schedule 191 rate of 2.5%,
while maintaining current expenditures, the balance of the account will continue to grow, and the
Company expects an over-funded balance of approximately $7.4 million by the end of 2028. Id.
at 3.
Staff believes the proposed 1.92%rate will provide sufficient revenue to cover the
Company's forecasted expenses and address the over-funded balance. The lower rate may bring
the account balance to approximately $10,352 by December 31, 2028. Id. at 3. Staff reviewed
Attachments A and B to the Application and has confirmed that Schedule 191 is projected to be
approximately $10,000 by December 2028. By extending the collection period through 2028, the
Company will attempt to align the collection of revenue in Schedule 191 more closely with its
annual Energy Efficiency Program budget, while minimizing the future rate impact to customers.
Id. If the Company's proposal is approved as written, the rate adjustment will result in an
approximate $8.40 per year decrease for the average residential customer. Id. at 4.
During a meeting with the Company on August 19, 2025, the Company explained that the
primary reason for the over-funded balance was due to the planning and budgeting to hit its
Integrated Resource Plan("IRP")targets but then did not reach those goals for multiple years.
The Company planned its programs and budget as if participation levels would be high enough
to reach the IRP targets. The Company explained that over the last few years, there has been a
decrease in participation, and the Company did not hit the targeted participation levels. Because
the actual expenditure levels did not match the forecast budget, the Company has slowly
acquired an over-funded Schedule 191 balance. Further, the Company explained that a minimal
rate decrease now will be easier on customers than being hit with more frequent rate changes.
Staff believes the Company's proposed rate decrease to 1.92% should be approved and remain in
place until at least January 2028 to promote rate stability.
STAFF COMMENTS 3 OCTOBER 1, 2025

During a meeting with the Company on August 19, 2025, the Company explained that it
is forecasting to spend more than it collects and expects the over-funded balance of Schedule 191
to decrease. The Company is forecasting that program costs will increase to $7.3 million in
2025, $8.6 million in 2026, $9.3 million in 2027, and$9.8 million in 2028. See Attachment A.
Cost-effective DSM, including energy efficiency programs, is a significant resource that
helps customers control their utility bills, reduce the Company's need for higher-cost supply-side
resources, and increases system reliability. In Order No. 29952, the Commission stated"cost
effective DSM provides benefits to non-participants by reducing the overall cost of serving new
load. It also benefits all Idaho customers by reducing Idaho's allocation of system power supply
costs." Staff expects that the Company's DSM program costs will continue to be prudently
incurred and that the programs will remain cost-effective. It is not Staff s intent to either
validate or question the Company's DSM prudency or its actual cost-effectiveness calculations
for any of its programs at this time. Such validation and additional review were not requested in
this case.
CUSTOMER RELATIONS
Customer Notice and Press Release
The Company's press release and customer notice were included with its Application.
Staff reviewed the documents and determined that both meet the requirements of Rule 125 of the
Commission's Rules of Procedure. IDAPA 31.01.01.125. The notice was included with bills
mailed to customers in the July 2025 billing cycles, providing customers with a reasonable
opportunity to file timely comments with the Commission by the October 1, 2025, deadline. As
of October 1, 2025, no customer comments had been filed.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's Application and tariffs
as filed, decreasing the Schedule 191 Customer Efficiency Services Rate to 1.92%.
STAFF COMMENTS 4 OCTOBER 1, 2025

Respectfully submitted this 1 st day of October 2025.
A am Triplett
Deputy Attorney General
Technical Staff: Laura Conilogue, Jason Talford
1:\Utility\UMISC\COMMENTS\PAC-E-25-13 Comments.docx
STAFF COMMENTS 5 OCTOBER 1, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS Is'DAY OF OCTOBER 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-25-13, BY &MAILING A COPY THEREOF, TO THE
FOLLOWING:
MARK ALDER DATA REQUEST RESPONSE CENTER
MICHAEL SNOW E-MAIL ONLY:
ROCKY MOUNTAIN POWER [e-mail]
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: mark.alder&acifico .com
michael.snow&acificorp com
JOSEPH DALLAS
825 NE MULTNOMAH, SUITE 2000
PORTLAND, OREGON 97232
E-MAIL: josgph.dallas&acificoM.com
PATRICIA JORDAN, S C ETARY
CERTIFICATE OF SERVICE