20251020Application.pdf

_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
RECEIVED
October 20, 2025 OCTOBER 20, 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-25-20
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR A
WAIVER OF THE SOLICITATION REQUIREMENTS PROPOSED IN CASE NO. GNR-
E-25-01
Attention: Commission Secretary
Rocky Mountain Power hereby submits for filing with the Idaho Public Utilities Commission its
Application in the above-referenced matter.
Informal questions related to this matter may be directed to Mark Alder, Idaho Regulatory
Manager at(801) 220-2313.
Very truly yours,
)A - L 0-1-D
Joelle Steward
Senior Vice President, Regulation
Enclosures
CC: Donn English
Taylor Thomas

Joe Dallas (ISB# 10330)
Tiffanie A. Ellis-Burke
PacifiCorp
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallaskpacificorp.com
Tiffanie.ellis-burke(kpacificorp.com
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. PAC-E-25-20
ROCKY MOUNTAIN POWER FOR A WAIVER )
OF THE SOLICITATION REQUIREMENTS )
PROPOSED IN CASE NO. GNR-E-25-01 ) APPLICATION
Comes now PacifiCorp, d/b/a Rocky Mountain Power ("Rocky Mountain Power" or
"Company") hereby submits this application to the Idaho Public Utilities Commission
("Commission"). Rocky Mountain Power respectfully requests an order approving a waiver of the
solicitation requirements proposed in Commission Staff Case No. GNR-E-25-01. The KU1 project
and PPA constitute a unique time-sensitive commercial and technical opportunity to obtain cost-
effective generation that will provide benefits and value to Idaho customers.
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.
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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
Tiffanie A. Ellis-Burke
Attorney
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Email: joseph.dallas(cr�pacificorp.com
Tiffanie.ellis-burke(kpacificorp.com
Informal inquiries related to this Application should be directed to Mark Alder, Idaho
Regulatory Affairs Manager, at [phone].
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II. BACKGROUND
3. PacifiCorp is a multi jurisdictional utility providing retail electric service to
customers in California, Idaho, Oregon, Utah, Washington, and Wyoming.
4. The Company owns Lake Viva Naughton Reservoir in Lincoln County, Wyoming,
as well as certain water conveyance infrastructure facilities (the "Delivery System") that deliver
water to the Company's Naughton Power Plant ("Naughton"). The Company also holds certain
water rights under the Wyoming State Engineer's Office Permit Numbers 6418R and 7476R (the
"Storage Rights") to store water in Lake Viva Naughton Reservoir for beneficial uses related to
the operation of the Naughton Power Plant.
5. US SFR, a subsidiary of TerraPower, is permitting and plans to construct the KU1
project in proximity to Naughton. The KU1 project is a 345-megawatt sodium-cooled nuclear
steam electric generating plant coupled with a molten salt integrated energy storage system. The
Nuclear Regulatory Commission is the agency responsible for authorizing and licensing the KU1
project.
6. The Company is not seeking review or a prudence determination,or any ratemaking
treatment associated with the PPA or US SFR's permitting and construction of the KUl project.
However, due to the time-sensitive and unique nature of this beneficial arrangement, as more fully
described below, the Company is requesting a waiver pursuant to Staff s proposal in Case No.
GNR-E-25-01. One of the provisions of the PPA requires timely submission of regulatory
applications,therefore waiting for a final order in Case No. GNR-E-25-01 is not feasible. In order
to comply with the spirit of the rules as proposed in Case No. GNR-E-25-01 and also with the
provisions of the PPA, the Company submits this application now.
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III. REQUEST FOR APPROVAL OF SOLICITATION WAIVER
7. In Case No. GNR-E-25-01, Commission Staff("Staff') has submitted a proposal
for the approval of an oversight process for the acquisition of large supply-side resources electrical
resources.' Under Staffs proposal, utilities must issue a Request for Proposal ("RFP") when
soliciting large supply-side resources. The requirements apply "to any solicitation for electrical
supply-side generating or storage resources of 100 MW or greater for a duration of 10-years or
more that will be subject to recovery from Idaho ratepayers."2 However, a company may defer
Commission pre-approval of its RFP in accordance with a waiver process. Specifically, "[fJor
unsolicited economic-based or large-customer-funded opportunities outside of the RFP process":
the Company should "file an application for review and approval of the unique economic
opportunity" that provides "clear justification of why the normal RFP process should not apply"
and demonstrates "the need and/ or the economic value of the opportunity."3Although Staff s
proposal may not be in effect at the time of this filing,the Company nonetheless seeks a waiver as
the proposal likely will take effect in the near future.
A. The PPA Constitutes a Unique Economic Opportunity
8. The PPA is a unique economic opportunity. The PPA is unique due to the PPA's
dispatchability and operational flexibility, comprehensive risk management and safety provisions,
and cognizable long-term benefits.
i. Dispatchability and Operational Flexibility
9. The KUl project's dispatchability represents a significant advancement in nuclear
'In the Matter of Commission Staffs Application for Approval of an Oversight Process for the Acquisition of Large
Supply-Side Electrical Resources, Case No.GNR-E-25-01,(March 31,2025).
2 Id. Attachment A to Staff's Comments,p.2,(Sept 4,2025).
s Id. at pp.2-3.
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REDACTED
technology through its integrated thermal storage design,enabling dispatch flexibility between 100
and 500 MW **[Begin Confidential]**
**[End Confidential]**. Since the technology
is designed with an integrated energy storage system, it can provide both firm and flexible
emissions-free energy at a reasonable cost to the Company's customers.
10. Nuclear generation has a proven track record of reliability with very high capacity
factors across all weather conditions and operational lifespans extending up to 80 years. This
reliability becomes increasingly valuable as the Company's system includes substantial portions
of renewable resources that depend on weather conditions, along with fossil fuel resources that
face supply chain vulnerabilities.
ii. Risk Management Protections
11. The PPA incorporates comprehensive risk mitigation strategies addressing the
unique challenges of first-of-kind nuclear technology. These include protections related to (1) the
financial protections as described above, (2) system independence protections, (3)unknown
performance risks, (4) contractual rigidity, and(5) safety.
12. The PPA provides significant financial protections to the Company and its
customers. **[Begin Confidential]**
**[End Confidential]**.
13. Additionally,the surplus interconnection structure provides fundamental protection
against first-of-kind technology risks by ensuring system independence. The KUl project
interconnects as a surplus resource, meaning any delays in achieving commercial operation or
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REDACTED
subsequent reliability issues do not result in additional costs to ratepayers. Because the Company
intends to continue operating its Naughton units to ensure system reliability, it will not be reliant
on the KU1 project's capacity.
14. There are significant protections for the unknown performance risks association
with the KU1 project. **[Begin Confidential]**
**[End Confidential]**.
15. Similarly, there is embedded in the PPA contractual flexibility. Specifically,
multiple contractual provisions work together to protect the Company and its customers through
flexible risk management tools. **[Begin Confidential]**
- **[End Confidential]**. US SFR must carry required insurance policies and
coverages per PPA specifications, providing additional financial protection layers. **[Begin
Confidential]
**[End Confidential]**.
16. Finally,there is significant oversight related to the safety of the KU1 project. Safety
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risks are managed through comprehensive regulatory oversight and design features. Specifically,
NRC federal oversight and approval authority, advanced safety design to minimize adverse
impacts, proven commercial nuclear operational history, and secure operation meeting all NRC
security regulations provide adequate protections related to safety risks.
iii. Long-Term Benefits
17. Over the long term, the KU1 project positions the Company and its customers to
capitalize on demonstrated advanced nuclear technology. The successful demonstration of
NatriumTM technology creates valuable operational knowledge that positions the Company to
negotiate more advantageous long-term contracts for the KU1 facility, potentially including
capacity, resource adequacy, and environmental attributes, or to procure additional NatriumTM
units elsewhere on the system with reduced technology risk. This knowledge transfer benefit
would be difficult or impossible for outside parties to obtain without incremental cost or
operational risk.
18. The KU1 project also advances critical national and industry-ride energy policy
objectives by supporting the ARDP, contributing to energy security and technological leadership
while enabling the transition to a more diverse, resilient, and clean energy portfolios that reduce
dependence on weather-variable renewable resources and volatile fossil fuel markets.
B. Forgoing the RFP Process for the PPA was in the Public Interest.
19. The opportunity to enter into the PPA necessitated forgoing the RFP and
solicitation process for several critical reasons. Specifically, federal funding requirements, the
first-of-its-kind commercial opportunity, the geographic and infrastructure constraints connected
to the use of Naughton, and lack of alternative options that take advantage of those benefits create
a time-limited opportunity making compliance with the competitive bidding rules meritless.
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20. Regarding the federal funding requirements, the KU1 project's dependence on
federal ARDP funding involves important timelines that make standard competitive bidding rule
processes impractical. The KU1 project operates within the parameters of the ARDP, which
provides federal funding support but requires specific commercial arrangements to be in place.
TerraPower needs a path to commercial operation that avoids limiting potential output, adding
costs, or increasing performance risks while retaining long-term value upon the successful
demonstration of the technology. The DOE's ARDP timeline and NRC financial qualification
requirements required the KU1 project to secure offtake. Accordingly, a delay in issuance or
rejection of the waiver request would be detrimental to the Company's customers' interests,
because it would jeopardize the federal funding and potentially terminate the project entirely. If
the opportunity related to the PPA lapses, the Company would lose access to this federally-
supported advanced nuclear demonstration project that provides customer benefits while
protecting against first-of-a-kind technology risks.
21. Similarly,this commercial opportunity exists only once as the inaugural NatriumTM
demonstration facility, making the PPA structure inherently unique and time limited. The
commercial structure of the PPA allows TerraPower to prove its first-of-a-kind asset without
passing construction cost overruns or technology performance risks to the Company's customers.
Future NatriumTM reactor plants may require more traditional acquisition or ownership structures.
The innovative PPA structure creates a flexible baseline agreement meeting immediate needs of
both parties while providing exit strategies and preserving long-term interests.
22. Additionally, with regard to geographic and infrastructure constraints, the KUl
project's strategic location in Wyoming adjacent to existing Company infrastructure creates site-
specific benefits that are geographically constrained and time sensitive. TerraPower's selection of
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Wyoming as the proving grounds for NatriumTM technology, combined with the KU1 project
location in proximity to the Company's Naughton Plant, creates a unique opportunity to use
existing infrastructure that cannot currently be replicated elsewhere.
23. Furthermore, regarding a lack of viable alternatives, the Company is not aware of
any other technology developers located near the Company's thermal generating assets,
sufficiently advanced in design, development, and licensing stages to compete. While the
Company remains open to further proposals that leverage and enhance its thermal dispatchable
generating assets, any benefit of a solicitation would not outweigh the detriment of not being able
to procure this time-limited project that provides benefits to customers.
24. If the Company had conducted a competitive solicitation for resources with the
characteristics of the KU1 project,US SFR would have been the only qualified applicant. The time
required to complete a solicitation process under the RFP rules would make it improbable to meet
timelines required by the ARDP program, resulting in the potential loss of federal funding and
termination of this unique opportunity.
C. The PPA Responds to Resource Needs and Provides Economic Value to the
Company's Customers.
i. Consistency with Integrated Resource Planning
25. The Company has included the KU1 project in its preferred portfolio in the 2021
IRP, 2023 IRP, and 2025 IRP, demonstrating its consistency with long-term resource planning.
The KU1 project and PPA are consistent with the analysis and modeling in the Company's 2025
IRP, also demonstrating that it is part of the least-cost, least-risk portfolio of options. The
Company's 2025 IRP is designed to ensure, on a long-term basis, an adequate and reliable
electricity supply at a reasonable cost and in a manner that is consistent with the long-term public
interest.
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REDACTED
26. When included in the PLEXOS model alongside the rest of the 2025 IRP preferred
portfolio, the PPA provides present value net benefits of**[Begin Confidential]**
**[End Confidential]** between fall of 2031 and 2045, total-Company. The economic analysis
presented provides sufficient grounds to establish good cause for the Commission to grant the
waiver requested in this Application. The KU1 PPA offers unique value to customers and will fill
an identified need from the Company's integrated resource planning process.
ii. Economic Benefits
27. The PPA is projected to reduce the net power cost component of revenue
requirement for the system by approximately **[Begin Confidential]**
**[End Confidential]**, starting in fall 2031 when the KU1 project reaches commercial
operation. The total expected notional value of the PPA for the entirety of the 40-year term is
approximately **[Begin Confidential]**
**[End Confidential]**.
28. The Company's PLEXOS production cost modeling demonstrates that the KU1
PPA provides customer benefits through three key mechanisms: **[Begin Confidential]**
**[End
Confidential]**.
29. The PPA's compensation mechanism is designed to ensure that **[Begin
Confidential]**
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REDACTED
]**[End Confidential]**. Compensation is calculated as the **[Begin
Confidential]**
_**[End Confidential]**.
30. The PPA is expected to deliver meaningful customer savings, as described in this
Application. This is done **[Begin Confidential]**
] **[End Confidential]**. This pricing structure provides comprehensive
financial protection for customers and automatically reflects other available alternatives,including
Naughton dispatch, other marginal generators, or market purchases, ensuring customers receive
optimal value regardless of market conditions.
IV. 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.
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V. CONFIDENTIAL INFORMATION
32. This filing, including the PPA, Water Rights Agreement, PacifiCorp Internal
Governance Memorandum attached as Confidential Attachments A,B, and C,and the confidential
workpapers, contain 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.
VI. CONCLUSION
33. WHEREFORE,Rocky Mountain Power respectfully requests an order granting the
Company's request for a waiver of the solicitation process.
Respectfully submitted this 20th day of October, 2025.
Joe Dallas (ISB# 10330)
PacifiCorp,Assistant General Counsel
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallaskpacificorp.com
Attorney for Rocky Mountain Power
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CONFIDENTIAL
ATTACHMENT A
Power Purchase Agreement

THIS ATTACHMENT IS
CONFIDENTIAL IN ITS ENTIRETY
AND IS PROVIDED UNDER
SEPARATE COVER

CONFIDENTIAL
ATTACHMENT B
Water Use Agreement

THIS ATTACHMENT IS
CONFIDENTIAL IN ITS ENTIRETY
AND IS PROVIDED UNDER
SEPARATE COVER

CONFIDENTIAL
ATTACHMENT C
Governance Memorandum

THIS ATTACHMENT IS
CONFIDENTIAL IN ITS ENTIRETY
AND IS PROVIDED UNDER
SEPARATE COVER