20260220Motion to Suspend Procedural Schedule and to Suspend Discovery.pdf

_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
RECEIVED
February 20, 2026 FEBRUARY 20, 2026
IDAHO PUBLIC
VIA ELECTRONIC DELIVERY UTILITIES COMMISSION
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
RE: CASE NO.PAC-E-25-14
IN THE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION FOR
APPROVAL OF THE 2026 INTER-JURISDICTIONAL COST ALLOCATION
PROTOCOL
Attention: Commission Secretary
Attached for filing, please find Rocky Mountain Power's Motion to Suspend the Procedural
Schedule and Suspend Discovery in the above-referenced matter.
Informal inquiries regarding this filing may be directed to Mark Alder, Idaho Regulatory Manager
at(801) 220-2313.
Very truly yours,
9t__)a1__D
Joe teward
Senior Vice President, Regulation

Adam Lowney
McDowell Rackner Gibson PC
419 SW 1 Ith Ave, Suite 400
Portland, Oregon 97205
Telephone: [phone]
Email: [e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY CASE NO. PAC-E-25-14
MOUNTAIN POWER'S APPLICATION )
FOR APPROVAL OF THE 2026 INTER- ) ROCKY MOUNTAIN POWER'S
JURISDICTIONAL COST ) MOTION TO VACATE THE
ALLOCATION PROTOCOL ) PROCEDURAL SCHEDULE AND TO
SUSPEND DISCOVERY
Pursuant to Rule 56 of the Rules of Procedure of the Idaho Public Utilities Commission
(Commission), PacifiCorp d/b/a Rocky Mountain Power (Rocky Mountain Power or Company)
files this Motion to Suspend the Procedural Schedule and Suspend Discovery.Accordingly,Rocky
Mountain Power requests that the Commission vacate the procedural schedule and associated
discovery described in Order No. 36869—Notice of Modified Procedure.
On August 6, 2025, Rocky Mountain Power filed its Application for Approval of the 2026
Inter-Jurisdictional Protocol(2026 Protocol)with the Commission in this docket. On February 17,
2026, PacifiCorp and Portland General Electric Company (PGE) announced a proposed
transaction involving the Company's Washington service area. Under the proposed transaction,
the Company will sell and PGE will purchase PacifiCorp's Washington service area and certain of
the Company's Washington-based generation,transmission, and distribution assets. (Service Area
Transfer). The Service Area Transfer will affect the allocation of certain costs under the 2026
Protocol currently pending approval by the Commission. Accordingly, Rocky Mountain Power
requests that the Commission vacate the procedural schedule to provide adequate time for Rocky
Rocky Mountain Power's Motion to Suspend Procedural Schedule Page I

Mountain Power to assess the impact of the Service Area Transfer on the 2026 Protocol, confer
with parties, and file any potential modifications. Rocky Mountain Power can work with
Commission Staff and parties and file an appropriate motion for a procedural schedule once these
conversations have taken place. Suspension of discovery is necessary and appropriate to avoid
expanding the scope of this proceeding beyond the 2026 Protocol during preparation of filings for
the required Commission approval of the Service Area Transfer.
The Company contacted the parties in this proceeding immediately following the public
announcement of the Service Area Transfer. Commission Staff does not oppose vacating the
schedule, but the Company was unable to confirm positions of Idaho Irrigation Pumpers
Association and Bayer Corporation before filing this Motion.
For the reasons discussed above, the Company requests the Commission vacate the
procedural schedule in this docket.
Respectfully submitted this 20th day of February 2026.
MCDOWELL RACKNER GIBSON PC
Adam LowVVY
McDowell Rackner Gibson PC
419 SW 1 Ith Ave, Suite 400
Portland, Oregon 97205
Telephone: [phone]
Email: adamkmrg-law.com
Attorney for Rocky Mountain Power
Rocky Mountain Power's Motion to Suspend Procedural Schedule Page 2

CERTIFICATE OF SERVICE
I hereby certify that I have this 20th day of February 2026, served Rocky Mountain
Power's Motion to Vacate the Procedural Schedule and to Suspend Discovery to all parties in
Case No. PAC-E-25-14, by e-mailing a copy of the foregoing to the following:
Idaho Public Utilities Commission Staff
Adam Triplett
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. No. 8,
Suite 201-A(83714)
Boise, ID 83720-0074
Email: adam.triplett(d,puc.idaho.gov
Idaho Irrigation Pumpers Association
Eric L. Olsen Lance Kaufinan, Ph.D.
Echo Hawk& Olsen, PLLC 2623 NW Bluebell Place
P.O. Box 6119 Corvallis, OR 97330
505 Pershing Ave., Suite 100 Email: lance(aaegisinsight.com
Pocatello, ID 83205
Email: elo(a),echohawk.com
Bayer Corporation
Ethan Waltermire Thomas J. Budge
P4 Production, LLC Racine Olson, PLLP
P.O. Box 816 P.O. Box 1391
Soda Springs, ID 83276 201 E. Center
Email: ethan.waltermire(abayer.com Pocatello, ID 83207-1391
Email: tj(c�racineolson.com
Brian C. Collins
Greg Meyer
Brubaker Associates
16690 Swingley Ridge Rd. #140
Chesterfield, MO 63017
Email: bcollins(cr),consultbai.com
gmeyer(d),,consultbai.com
Mic ae ighfill
Paralegal
McDowell Rackner Gibson PC