20251229Application.pdf

RECEIVED
DECEMBER 29, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
December 29, 2025
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-25-23
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AN
ACCOUNTING ORDER RELATING TO THE 2026 INTER-JURISDICTIONAL
ALLOCATION PROTOCOL
Attention: Commission Secretary
Please find Rocky Mountain Power's application in the above-referenced matter.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313.
Very truly yours,
aD
Joelle Steward
Senior Vice President, Regulation
Enclosures
CC: Donn English
Taylor Thomas

Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallas(a�pacificorp.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. PAC-E-25-23
ROCKY MOUNTAIN POWER FOR AN )
ACCOUNTING ORDER RELATING TO THE )
2026 INTER-JURISDICTIONAL ) APPLICATION
ALLOCATION PROTOCOL )
PacifiCorp, d/b/a Rocky Mountain Power ("Rocky Mountain Power" or "Company")
pursuant to Idaho Code (I.C.) § 61-524 and Idaho Public Utilities Commission Rule of Procedure
052 submits this application to the Idaho Public Utilities Commission ("Commission"). Rocky
Mountain Power respectfully requests an accounting order that would authorize the recording of a
regulatory asset for the differences in costs and revenues between the 2020 PacifiCorp Inter-
Jurisdictional Allocation Protocol ("2020 Protocol"), which expires on December 31, 2025, and
the 2026 PacifiCorp Inter-Jurisdictional Allocation Protocol ("2026 Protocol"), now pending in
Case No. PAC-E-25-14. Rocky Mountain Power requested a final order on or before December
31, 2025, in its 2026 Protocol filings in each state, seeking a uniform adoption date for a new cost
allocation methodology. The Washington Utilities and Transportation Commission ("WUTC")
approved the Washington 2026 PacifiCorp Inter-Jurisdictional Allocation Protocol ("Washington
2026 Protocol"), effective January 1, 2026, reallocating resources to Washington in a manner
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consistent with the 2026 Protocol.' However, the schedule in Case No. PAC-E-25-14 extends into
2026, as do the schedules for the concurrent filings in Utah and Wyoming, and the schedule in
Oregon is currently suspended to allow parties an opportunity to explore settlement. To address
the transition period from December 31, 2025,until the Commission adopts a new cost allocation
methodology in Case No. PAC-E-25-14 and that methodology is reflected in the Company's base
rates, Rocky Mountain Power respectfully requests this deferral to align costs and benefits, and
avoid any temporary over- and/or under-allocation of costs due to differing allocation methods.
The approval of the Accounting Order will allow the Company to track the differences in
costs and revenues resulting from temporary differences in the allocation methodologies approved
in different states and is in the public interest.
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.
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.
' Washington Utilities and Transportation Commission v PacifiCorp d/b/a/Pacific Power&Light Company,Docket
UE-250224,Order 08(Dec.22,2025).
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2. Formal correspondence and requests for additional information regarding this
matter should be addressed to:
By email (preferred): datarequest(a,pacificorp.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
Attorney
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Email:joseph.dallas&pacificorp.com
Informal inquiries related to this Application should be directed to Mark Alder, Idaho
Regulatory Affairs Manager, at(801) 220-2313.
II. BACKGROUND
3. The Company provides retail electric service to approximately two million
customers in six western states, including Idaho. The Company owns substantial generation,
transmission, and distribution facilities. Augmented with contracted and wholesale power
purchases and long-term transmission contracts, the Company has operated these facilities as a
single system on an integrated basis to provide service to all customers in a cost-effective manner.
The Commission has approved allocation to Idaho of system costs under various iterations of
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allocation methodologies based on load requirements of each state relative to the entire system.
4. The Company's 2020 Protocol identified a framework for changing allocations as
states implement energy policies that make it increasingly challenging for the Company to operate
and maintain a single resource portfolio for customers across all jurisdictions while meeting its
legal obligations in each state.2 The Company's 2026 Protocol is an initial phase toward a transition
from a cost-allocation methodology that contemplates the operation of a single resource portfolio
to a cost-allocation methodology that acknowledges the need for state or regional resource
portfolios to meet load obligations on a least-cost basis,while complying with state energy policies
and preventing cross-subsidization among jurisdictions. The 2026 Protocol allocation
methodology builds off the framework agreed to in the 2020 Protocol.
5. The WUTC's approval of the new allocation methodology effective January 1,2026
was necessary to meet the requirements of Washington's Clean Energy Transformation Act,'which
prohibited the use of coal-fueled resources to serve customers in Washington starting January 1,
2026. This order, coupled with the schedule in Case No. PAC-E-25-14, however, creates the
potential for over- and/or under- allocation of certain costs until a new allocation methodology is
approved in Case No. PAC-E-25-14 and costs are incorporated into rates. In this application, the
Company seeks to track through deferred accounting the temporary differences in costs and
revenues resulting from the transition to a new allocation methodology that positions the Company
to maintain safe,reliable,and affordable electric service to customers and provides for 100 percent
allocation of resources across all states.
2 In the Matter of Rocky Mountain Power's Application for Approval of the 2020 PacifiCorp Inter-Jurisdictional
Allocation Protocol,Case No.PAC-E-19-20,Order No.34640(Apr.22,2020)(approving 2020 Protocol).
3 RCW 19.405.030(l)(a).
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III. REQUEST FOR APPROVAL OF ACCOUNTING ORDER
6. In accordance with I.C. § 61-524, Rocky Mountain Power requests approval of an
accounting order that would authorize the recording of a regulatory asset for the differences in
costs and revenues allocated to Idaho customers under the 2020 Protocol compared to revised
allocations of resources under the 2026 Protocol. This deferral will match the costs recovered
from Idaho customers with the revised allocations of generation resources under the 2026
Protocol, ensuring matching of costs and benefits and that any over-allocation of resources does
not result in any potential over-recovery of costs.
A. Description of Utility Expense
7. The primary costs for deferral will relate to changes in the system generation(SG)
factor calculations for the resource subsets identified in the 2026 Protocol, the reassignment of
the Chehalis natural gas generation facility to Washington, and simplification of the formulaic
derivation of the system overhead(SO) factor.
8. Under the 2020 Protocol, Idaho customers are allocated the SG factor share of the
Company's entire resource portfolio. The proposed 2026 Protocol allocates generation resources
in a manner to allow the Company to meet its legal obligations in Washington while removing
historical over- and under-allocation of costs due to differences between the allocation methods
used in Washington and the Company's other jurisdictions.
B. Reasons for Deferral
9. The Company has proposed a phased approach for transitioning cost allocations
to state or regional portfolios to respond to state energy goals while meeting load obligations on
a least-cost basis. The first step in the Company's approach realigns certain resources to address
immediate legal requirements in Washington. The WUTC's approval of the new allocation
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methodology for Washington, starting January 1, 2026, would result in over-allocation and over-
recovery of costs associated with the Company's Chehalis generation facility and the under-
allocation of costs and benefits from other thermal resources until the new allocation
methodology is approved in Idaho and incorporated into rates. In this application, the Company
seeks to track, through deferred accounting, the differences in costs and revenues resulting from
these temporary allocation methodology differences.
10. For example, under the 2026 Protocol, 100 percent of the Chehalis generation
facility would be assigned to Washington. With the WUTC's approval of the new allocation
methodology, the Company's Washington rates would recover 100 percent of the costs for that
resource while the Company's rates in Idaho, Oregon, California, Utah, and Wyoming continue
to recover 92 percent of Chehalis costs under current rates. The Company requests deferred
accounting to avoid the over- and under-allocations due to different allocation methodologies
reflected in rates among the Company's jurisdictions.
11. As discussed in the Company's application in Case No. PAC-E-25-14, the
Company requests deferred accounting to track the costs and revenue that would be allocated to
Idaho pursuant to the 2026 Protocol until the 2026 Protocol takes effect in the Company's next
general rate case.'Moreover, these costs and benefits may represent a material impact to the
financial stability of the Company that resulted from unique circumstances that could not have
been included in the Company's last general rate case and granting deferred accounting would
promote rate stability.
4 In the Matter of the Application for Approval of the 2026 Inter-Jurisdictional Cost Allocation Protocol, Case No.
PAC-E-25-14,Application of Rocky Mountain Power at 9(filed Aug. 6,2025).
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12. The Company acknowledges that the Commission's approval of deferred
accounting treatment does not constitute a prudence determination or approval for any costs and
revenues allocated to Idaho under the 2026 Protocol. Recovery of any costs would be subject to a
prudence review and a final decision on rate recovery in a future regulatory filing.
C. Proposed Accounting
13. The Company requests to record the deferral in Account 182.3 (Regulatory
Assets). The Company seeks to defer the differences in costs between the 2020 Protocol and
2026 Protocol until the 2026 Protocol is approved and incorporated into rates in Idaho.
14. The Company estimates that approximately $1.6 million plus interest may be
deferred annually to appropriately match costs and benefits under the revised allocation
methodologies.' This account will accrue interest at the Commission-authorized rate for deferred
accounts.
IV. REQUEST FOR MODIFIED PROCEDURE
15. 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.
V. CONCLUSION
16. WHEREFORE, Rocky Mountain Power respectfully requests an order authorizing
it to record a regulatory asset to FERC Account 182.3 (Regulatory Assets)to account for any net
amounts associated with the temporary differences in costs and revenues between allocations
under the 2020 Protocol and the Company's proposed 2026 Protocol.
5 This excludes net power costs,which are addressed in other deferred accounting authorizations.
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Respectfully submitted this 29"' day of December 2025.
Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallas&pacificorp.com
Attorney for Rocky Mountain Power
Attorney for Rocky Mountain Power
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