20251217Final_Order_No_36868.pdf

Office of the Secretary
Service Date
December 17,2025
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP'S ) CASE NO. PAC-E-25-12
APPLICATION FOR )
ACKNOWLEDGEMENT OF THE 2025 )
INTEGRATED RESOURCE PLAN ) ORDER NO. 36868
On December 31, 2024, Rocky Mountain Power, a division of PacifiCorp ("Company"),
filed a draft version of its 2025 Integrated Resource Plan ("IRP") with the Idaho Public Utilities
Commission("Commission")in Case No. PAC-E-24-13.The Company indicated that it would file
the final version of the 2025 IRP on March 31,2025.The Company requested that the Commission
postpone issuing a public notice and setting a schedule until the final version was filed. On March
31,2025,the Company applied to the Commission requesting acknowledgment of the final version
of its 2025 IRP. On May 22,2025,the Commission closed Case No. PAC-E-24-13 and opened this
docket to consider the Company's request for acknowledgement of its 2025 IRP ("Application").
Order No. 36605.
On June 3, 2025, the Commission issued notice of the Company's Application and set a
deadline for interested persons to petition to intervene in the case. Order No. 36620. No third
parties sought to intervene. On July 22, 2025, the Commission issued notice that the Application
would be processed under modified procedure and established comment deadlines. Order No.
36683. Commission Staff ("Staff') filed comments to which the Company replied. The
Commission received no public comments.
Based on our review of the record, the Commission now issues this Final Order
acknowledging the Company's 2025 IRP.
THE 2025 IRP
The Company represented that it submitted the 2025 IRP filing in compliance with Order
No. 22299, Case No. U-1500-165,dated January 1989;whereby the Commission ordered biennial
filings of the electric IRP. 2025 IRP Vol. 2 at 22. The Company stated that its plan was also
submitted to the Commission as the Resource Management Report on the Company's resource
planning status. Id.
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The IRP consisted of approximately 317 pages, accompanied by approximately 536 pages
of appendices. The IRP was organized into 10 chapters with numerous subsections: (1) Executive
Summary; (2) Introduction; (3) Planning Environment; (4) Transmission; (5) Reliability and
Resiliency; (6) Load and Resource Balance; (7) Resource Options; (8) Modeling and Portfolio
Evaluation; (9) Modeling and Portfolio Selection Results; and(10)Action Plan.Id. at i—vii.
According to the Company, the 2025 IRP fulfills the Company's commitment to develop
a long-term resource plan that considers cost, risk, uncertainty, and the long-run public interest.
2025 IRP Vol. 1 at 19. The Company reported that regulatory staff, advocacy groups, and other
interested parties influenced the development of the 2025 IRP through a collaborative public input
process. Id.
The Company represented that the 2025 IRP enhances jurisdictional portfolio development
and reporting in recognition of the increased focus on individual state jurisdictional outcomes in
recent integrated resource planning cycles. 2025 IRP Vol. 1 at 19. The Company also stated that
the 2025 IRP describes the fundamental methodologies used to arrive at state-level initial
portfolios and how they are subsequently integrated into a single plan. Id.
The Company stated that its selection of the 2025 IRP preferred portfolio is supported by
comprehensive data analysis and an extensive public input process. Id. The Company also
represented that the 2025 IRP includes substantial new renewables, facilitated by incremental
transmission investments, demand-side management resources, significant storage resources, and
advanced nuclear.Id.
According to the Company, the 2025 IRP preferred portfolio is in addition to contracted
resources.Id. The Company also represented that the 100 megawatt("MW")Hornshadow I Solar
and 200 MW Hornshadow Solar II facilities are set to come online in 2025, while two facilities
combining solar and storage are set to come online in 2025 and 2026: Faraday with 525 MW solar
and 150 MW storage and Green River with 400 MW solar and 400 MW storage.Id. The Company
further represented that Oregon's Community Solar Program has 10 small-scale solar facilities
scheduled to come online in 2025 and 2026, totaling approximately 18 MW. Id.
The Company represented that the 2025 IRP preferred portfolio includes the 500 MW
advanced nuclear Natrium demonstration project, anticipated to achieve online status by summer
2030. Id. Additionally, the Company stated that over the 21-year planning horizon, the 2025 IRP
preferred portfolio includes 6,379 MW of new wind and 5,492 MW of new solar, and 7,668 MW
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of new storage resources. Id. The Company stated that the new storage includes five battery
facilities totaling 520 MW projected to come online ahead of the peak summer season in 2026:
Dominguez BESS (200 MW), Enterprise BESS (80 MW), Escalante BESS (80 MW), Granite
Mountain BESS (80 MW) and Iron Springs BESS (80 MW). Id. at 19-20. The Company also
reported that the 2025 IRP preferred portfolio provides details of various additional transmission
projects, including the transfer capability and estimated cost of each project. Id. at 6, 20, 79-97.
STAFF COMMENTS
Based on Staff's review of the Company's 2025 IRP and Staff's participation in the series
of 2025 IRP public input meetings, Staff believed that the 2025 IRP addresses the requirements
outlined in Commission Order No. 22299. Staff Comments at 2. Staff recommended that the
Commission acknowledge the 2025 IRP.Id. However, Staff also had numerous recommendations
for improvements for future IRPs.
Staff recommended the Company justify the selection of the preferred portfolio,
considering the superior performance of other portfolios in some modeling results. Staff believed
there were three portfolios that might have outperformed the Company's preferred portfolio across
the range of modeled price policy scenarios and that the preferred portfolio was the top performing
portfolio in only one scenario. Id. at 7. Staff believed the Company should provide further
explanation as to why it selected the preferred portfolio, while specifically addressing these
concerns. Id.
Staff also noted that the Company only applied end effects to one price policy scenario and
recommended the Company conduct additional tests applying end effects or similar conditions
under each price policy scenario for all competing portfolios in the future IRPs. Id. According to
Staff, such measures would make each of the competing portfolios "comparable on a relative
basis."Id.
Additionally, Staff recommended the Company review its practices for hedging natural gas
fuel supply to mitigate fuel supply risks and dependence on natural gas for dispatchable generation.
Id. at 9. Staff believed these steps would help ease concerns of customer exposure to natural gas
price volatility as the Company continues to move away from coal.Id.
Prior to the Company's next IRP, Staff recommended the Company collaborate with Staff
concerning multiple planning issues.Firstly, Staff would like to work with the Company to explore
the possibility of developing an Idaho-specific portfolio, as it does for other states. Id. at 17.
ORDER NO. 36868 3

Additionally, Staff would like to work with the Company to find a balance between meeting the
Western Resource Adequacy Program("WRAP")resource adequacy compliance requirements and
avoiding overbuilding resources.Id. at 15.
Staff had concerns about the Company's transmission resources related to large load
customers. Id. at 12. To alleviate these concerns, Staff recommended that before the next IRP, the
Company provide the Commission with: (1) the Company's re-evaluation study concerning the
Boardman-to-Hemingway (`B21­1") transmission line; and (2) information regarding removal of
new large customer loads, customer plans to serve their own loads, and the impact on the
Company's system and on its Idaho customers. Id. at 12.
According to Staff, the Company evaluated assumptions for supply-side resources under
the policies of the previous presidential administration. Id. at 13. However, Staff was concerned
that recent changes in federal policy may have invalidated some of the results of the 2025 IRP
regarding advanced technology, environmental factors, and costs. Id. Staff recommended the
Company provide an analysis demonstrating how its resources would change because of some of
the most recent federal policies.Id.
Finally, Staff believed the Company's preferred portfolio selection analysis should include
an additional verification step of a"feedback loop"to confirm that the selected preferred portfolio
meets the defined loss of load expectation target.Id. at 16. Staff stated that this step would provide
greater clarity in future IRPs as to whether the defined reliability target is achieved by the
developed integrated preferred portfolios. Id.
COMPANY REPLY COMMENTS
The Company was amenable to the majority of Staffs recommendations, agreeing to: (1)
apply end effects to all price-policy scenarios; (2) meet with Staff to discuss balancing the costs
and risks of building new resources and relying on front office transactions; (3) provide greater
clarity in future IRPs as to whether the defined reliability target is achieved by the developed
integrated preferred portfolios; (4) review its hedging practices to mitigate exposure; (5) provide
an incremental analysis accounting for recent changes in federal tax credit policy; (6) provide an
evaluation of the impacts of large loads; (7) provide updates and further modeling regarding the
132H transmission line project; (8) provide the Commission with annual or semi-annual reports
regarding the status of the Natrium Nuclear demonstration project; and (9) meet with Staff prior
to its next IRP to discuss developing an Idaho-specific portfolio. Company Reply Comments at 6—
ORDER NO. 36868 4

13. The Company stated it would address these issues either in future IRPs or in the 2025 IRP
Update, which it plans to distribute on March 31, 2026.Id. at 6, 11.
The Company also responded to Staff s recommendation that it justify the selection of the
preferred portfolio despite other portfolios performing better in certain price-policy scenarios. Id.
at 5. According to the Company, the preferred portfolio was selected because of its performance
in the expected price-policy scenario and not its performance in other, less likely price-policy
scenarios. Id. The Company added that a stochastic analysis and end effects were completed only
for the expected price-policy scenario,rendering more robust results than modeling for other price-
policy scenarios.Id.
COMMISSION FINDINGS AND DECISION
The Company is a public utility as defined in Idaho Code §§ 61-119 and -129, and the
Commission has jurisdiction over it and the issues in this case under Title 61 of the Idaho Code,
including Idaho Code § 61-501. Having reviewed the record, the Commission finds that the
Company's 2025 IRP satisfies the requirements in the Commission's prior orders, and the
Commission acknowledges the 2025 IRP. We appreciate the Company's commitment, as
expressed in its Reply Comments, to work collaboratively with Staff to improve the IRP planning
process. We anticipate the Company's next IRP will incorporate much of Staffs feedback from
this case.
In acknowledging the 2025 IRP, the Commission once again reiterates that an IRP is a
working document that incorporates many assumptions and projections at a specific point in time.
An IRP is a plan,not a blueprint,and by issuing this Order we merely acknowledge the Company's
ongoing planning process, not the conclusions or results reached through that process.
The Commission does not approve the 2025 IRP, or any resource acquisitions referenced
in it, endorse any particular element in it, opine on the Company's prudence in selecting the 2025
IRP's preferred resource portfolio,nor allow or approve any form of cost recovery.The appropriate
place to determine the prudency of the Company's decisions to follow or not follow the 2025 IRP,
and the validation of predicted performance under the 2025 IRP, is a general rate case or other
proceeding where the issue is noticed.
ORDER
IT IS HEREBY ORDERED that the Company's 2025 IRP is acknowledged.
ORDER NO. 36868 5

THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date upon this Order regarding any
matter decided in this Order. Within seven (7) days after any person has petitioned for
reconsideration, any other person may cross-petition for reconsideration. See Idaho Code §§ 61-
626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 171h day of
December 2025.
Gv� Q
EDWARD LODGE,/RE ENT
HN R. HAMMOND JR., COMMISSIONER
DAYN HARDI , COMMISSIONER
ATTEST
Lau a Calderon Robles
Interim Commission Secretary
IALegal\ELECTRIC\PAC-E-25-12_IRP\orders\PACE2512_final jl.doex
ORDER NO. 36868 6