20251201Staff Comments.pdf

RECEIVED
December 01, 2025
ADAM TRIPLETT IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 10221
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )
POWER'S APPLICATION TO UPDATE ) CASE NO. PAC-E-25-19
LOAD AND GAS FORECASTS USED IN THE )
INTEGRATED RESOURCE PLAN AVOIDED )
COST MODEL ) 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 October 15, 2025, Rocky Mountain Power, a division of PacifiCorp ("Company"),
applied to the Commission for approval of an updated load forecast, an updated natural gas price
forecast, and contracts changes used as inputs in the Company's Integrated Resource Plan
("IRP") avoided cost model calculations for qualifying facilities ("QFs")under the Public Utility
Regulatory Policies Act of 1978 ("PURPA") as required by Order Nos. 32697 and 32802
("Application"), with an effective date of January 1, 2026.
STAFF COMMENTS 1 DECEMBER 1, 2025

STAFF ANALYSIS
Staff has reviewed the Application and recommends that the Commission approve the
proposed load forecast and the proposed natural gas price forecast with an effective date of
January 1, 2026.
Load Forecast
Staff compared the proposed load forecast to the approved load forecast in last year's
annual update case (Case No. PAC-E-24-12) in Figure No. 1 below and believes the proposed
load forecast is reasonable.
Figure No. 1: Load Forecast Comparison
Load Forecast Comparison
100000
90000
80000
70000
60000
50000
c 40000
c
Q 30000
20000
10000
0
W I, 00 01 O ci N M V Vl W r, 00 01 O ci N M �
N N N N M M M M M M M M M M V
O O O O O O O O O O O O O O O O O O O
N N N N N N N N N N N N N N N N N N N
2024 Load Forecast 2025 Load Forecast
The Company originally stated that the proposed load forecast was lower than last year's
load forecast primarily because of"exclusion of large new data center loads in Utah and Oregon,
as well as the exclusion of Kennecott load." Application at 3. Later, the Company corrected the
statement and explained that Kennecott load was excluded from both load forecasts. Response
to Staff Production Request No. 1 (d) and (e). Therefore, Kennecott load did not contribute to
the difference between the two forecasts. The Company further explained that the primary driver
of the change between the proposed load forecast and last year's load forecast was the exclusion
of the new large customers who were expected to provide the resources and transmission to
support their load. As a result of these customers acquiring their own resources, the Company
STAFF COMMENTS 2 DECEMBER 1, 2025

did not have to find resources to serve them. 2nd Supplemental Response to Staff Production
Request No. 1.
Staff believes it is reasonable to exclude these large customers from the load forecast, as
long as the resources they acquire are also excluded in the IRP model. Therefore, the Company
needs to ensure that the resources associated with these large customers are excluded in the IRP
model when determining avoided cost rates for the IRP-based contracts. For the purpose of this
case, Staff recommends that the Commission approve the proposed load forecast with an
effective date of January 1, 2026.
Natural Gas Price Forecast
The Company's natural gas price forecast is determined by forward market prices and
fundamentals-based forecasts. For months 0-36, the Company relies on forward market prices
only. For months 37-48, the Company blends the forward price of the prior year and the
fundamentals-based forecast for the next year. For months 48 and beyond, the Company uses a
fundamentals-based forecast only, which is developed by Siemens. Response to Staff Production
Request No. 2.
Staffs analysis focused on the near term of the proposed gas price forecast due to the
maximum contract length of two years for IRP-based PURPA contracts. Staff compared the
proposed Henry Hub price forecast in this case, the proposed Henry Hub price forecast in Case
No. AVU-E-25-13, and the NYMEX forward prices for Henry Hub published on October 15,
2025,provided in Response to Staff Production Request No. 3 in Case No. IPC-E-25-33. See
Figure No. 2 below. Since the near-term forecasts from all three sources are similar to each
other in the near term, Staff believes the proposed gas forecast is reasonable.
STAFF COMMENTS 3 DECEMBER 1, 2025

Figure No. 2: Comparison of Gas Price Forecasts
Comparison of Gas Price Forecasts
9.00
8.00
7.00
6.00
cO 5.00
2 4.00
3.00
2.00
1.00
0.00
tiro 1
1 l� toi ,�D ,� ,�° ,1
,ti0 ,ti0 ,ti0 ,ti0 ti0 ti0 ,ti0 f) ,ti0 ,LO ,ti0 ,ti0 ,0 ti0 ,ti0 ti0 ,ti0 ti0 ,ti0 ti0
Proposed Henry Hub Gas Forecast in Case No.AVU-E-25-13
Proposed Henry Hub Gas Forecast in Case No.PAC-E-25-19
ICE NYMEX Forward Market Prices on October 15,2025
Contract Changes
Since the filing of last year's annual update case, the Company has signed fifteen long-
term contracts for a total of 797 megawatts and has terminated one long-term contract for a total
of 280 megawatts. Staff believes that these contract changes are correct.
The Company states that"[i]f approved, the load forecast, natural gas forecast, and
contract information presented below will be incorporated into Rocky Mountain Power's IRP
avoided cost model." Application at 2. Staff would like to clarify that contract updates are
incorporated into the IRP model on a continuous basis,' and the annual filing provides an
opportunity for the Commission to review and monitor these updates.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the proposed load forecast and the
proposed natural gas price forecast with an effective date of January 1, 2026.
'Order No.32697 required that long-term contracts be considered in the IRP methodology at such time as contracts
were signed and when they had terminated or expired. Later,Order No.33357 found the"signed contract"language
in Order No 32697 did not achieve its intended result and required utilities to create a queue to track the order in
which QF projects have entered negotiations with a utility.
STAFF COMMENTS 4 DECEMBER 1, 2025

Respectfully submitted this 1 st day of December 2025.
Adam Triplett
Deputy Attorney General
Technical Staff. Yao Yin
I:\Utility\UMISC\COMMENTS\PAC-E-25-19 Comments.docx
STAFF COMMENTS 5 DECEMBER 1, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1 sT DAY OF DECEMBER 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-25-19, 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
ASSISTANT GENERAL COUNSEL
825 NE MULTNOMAH, SUITE 2000
PORTLAND, OR 97232
E-MAIL: joseph.dallaskpacificorp.com
14 i'�'t�
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE