20260114Staff Comments.pdf

RECEIVED
January 14, 2026
JEFFREY R. LOLL IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11675
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-25-18
TO ALLOW PARENT COMPANY TO )
MAINTAIN A COMMON EQUITY )
PERCENTAGE OF LESS THAN 44 PERCENT ) SUPPLEMENTAL COMMENTS
OF THE COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Jeffrey R. Loll, Deputy Attorney
General, submits the following supplemental comments.
BACKGROUND
On September 24, 2025, Rocky Mountain Power, a division of PacifiCorp ("Company"),
applied to the Commission requesting authority to allow the Company's direct parent company,
PPW Holdings LLC ("PPW Holdings"), to maintain an equity percentage below the 44 percent
minimum threshold adopted by the Commission in Case No. PAC-E-05-08 ("Application")when
it approved the acquisition of the Company by MidAmerican Energy Holdings Company
("MEHC"). MEHC is now Berkshire Hathaway Energy Company ("Berkshire").
On January 9, 2026, Staff filed comments recommending the Commission deny the
Company's application. On January 12, 2026, Staff notified the Commission that it had begun
settlement negotiations with the Company.
STAFF SUPPLEMENTAL COMMENTS 1 JANUARY 14, 2026

STAFF ANALYSIS
After discussion with the Company, Staff now changes its recommendation that the
Commission deny the Company's Application to a recommendation that the Commission
approve the Application with certain modifications. Staff believes that these modifications will
put in place the appropriate safeguards to protect ratepayers, as well as simplify processes for the
Company, as it will have to comply with a substantially similar agreement with the Oregon
Public Utilities Commission("OPUC"). See OPUC Docket No. UM 2406.
Staff recommends the Commission impose the following conditions on its approval of the
Company's Application:
1. PPW Holdings may contain common equity capital below the 44 percent specified
in Idaho Commitment 21, but no lower than 35 percent, for a base period of three years starting
on the date of any order by the Commission approving the Application. PPW Holdings may
contain common equity capital below 44 percent, but no lower than 35 percent, for two
additional one-year periods beyond the base period,but each one-year extension is subject to
Commission approval prior to the expiration of the base period or the one-year extension, if
granted.
2. PPW Holdings will issue no debt, common or preferred stock, or other securities,
whether hybrid or otherwise, during the base period plus any extensions as discussed above.
3. The Company and PPW Holdings will not pay any dividends while PPW Holdings
has a common equity capital below 44 percent.
Staff reserves the right to challenge the Company's capital structure for ratemaking
purposes in the next general rate case.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's Application with the
modifications described above.
STAFF SUPPLEMENTAL COMMENTS 2 JANUARY 14, 2026

Respectfully submitted this 14t'day of January 2026.
Jeffrey R. Loll
Deputy Attorney General
Technical Staff. Joe Terry
STAFF SUPPLEMENTAL COMMENTS 3 JANUARY 14, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14th DAY OF JANUARY 2026,
SERVED THE FOREGOING SUPPLEMENTAL COMMENTS OF THE
COMMISSION STAFF, IN CASE NO. PAC-E-25-18, 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