20260225Staff Comments.pdf

RECEIVED
February 25, 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 AN ) CASE NO. PAC-E-25-23
ACCOUNTING ORDER RELATING TO THE )
2026 INTER-JURISDICTIONAL )
ALLOCATION PROTOCOL ) 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 comments.
BACKGROUND
On December 29, 2026, PacifiCorp, d/b/a Rocky Mountain Power("Company") applied
to the Commission requesting an order authorizing the recording of a regulatory asset for the
differences in costs and revenues between the expiring 2020 PacifiCorp Inter-Jurisdictional
Allocation Protocol ("2020 Protocol") and the pending 2026 PacifiCorp Inter-Jurisdictional
Allocation Protocol ("2026 Protocol") ("Application").
The 2020 Protocol expired on December 31, 2025, and the 2026 Protocol is currently
pending before the Commission, Case No. PAC-E-25-14. Application at 1.
The 2020 Protocol provided a framework for allocating costs among the states within the
Company's service territory to correspond with differing energy policies. Id. at 4. Through the
STAFF COMMENTS 1 FEBRUARY 25, 2026

2026 Protocol, the Company seeks to establish a cost-allocation methodology with state or
regional resource portfolios to prevent cross-subsidization among jurisdictions. Id.
The Washington Utilities and Transportation Commission ("WUTC") has already
approved the Washington 2026 PacifiCorp Inter-Jurisdictional Allocation Protocol, which
established a new allocation methodology effective January 1, 2026, and allowed the Company
to meet Washington-specific legal requirements. Id. According to the Company, the WUTC's
order coupled with the pendency of the 2026 Protocol "creates the potential for over-and/or
under-allocation of certain costs until"the Commission approves a new allocation methodology.
Id.
The Company requests authority to record a regulatory asset for the temporary
differences in costs and revenues due to the transition to a new allocation methodology. Id. The
requested deferral would match costs recovered from Idaho ratepayers with the revised allocation
of generation resources under the 2026 Protocol. Id. at 5.
STAFF ANALYSIS
As a preliminary matter, Staff notes that the analysis contained herein was completed
prior to the February 17, 2026, announcement regarding the Company's intention to sell its
Washington assets. It is currently unclear what effect this pending transaction might have on the
2026 Protocol.
Staff reviewed the Company's Application, supporting documents, and similar concluded
cases. The Company seeks an accounting order authorizing the deferral of differences in costs
and revenues resulting from(1) changes to the system generation factor calculations for resource
subsets identified in the proposed 2026 Protocol; (2) reassignment of the Chehalis natural gas
generation facility to Washington; and(3)modifications to the derivation of the system overhead
factor. Staff recommends that the Commission deny the Application. These expenses are not
unpredictable and are largely within the Company's control. As such, denial of the Application
will not harm the Company and is in the public interest.
Other than power costs, the differences between the 2020 Protocol and the proposed 2026
Protocol are reasonably predictable. The Company estimates an annual deferral of
approximately $1.6 million, demonstrating that the costs are measurable to the extent that the
STAFF COMMENTS 2 FFBRUARY 25, 2026

amount can be predicted. The 2020 Protocol was scheduled to expire at the end of 2025. See
Case No. PAC-E-23-13, Order No. 35984.
With the expiration of the 2020 Protocol, the Company should have been conscious of
the anticipated procedural schedules in the various jurisdictions when it filed its 2026 Protocol
Application. Accordingly, the timing differences between jurisdictions were foreseeable and
within the Company's control. These circumstances do not constitute unpredictable events and
do not warrant deferred accounting. When the Company seeks recovery of costs and revenues
associated with changes in resource allocation between the 2020 Protocol and the proposed 2026
Protocol, Staff recommends that such recovery be addressed in a general rate case.
If the accounting order is not approved, Staff does not believe the Company will be
unduly harmed. The Company estimates an annual deferral of approximately $1.6 million,
which represents approximately 0.49 percent of the Company's Idaho revenue requirement. In
Case No. PAC-E-24-04, the Company's Idaho revenue requirement was approximately $326
million. The Company has not demonstrated that denial of the requested deferral would impair
its financial position or operations.
Staff believes that deferring these costs and revenues is not in the public interest. The
case addressing the 2026 Protocol (Case No. PAC-E-25-14) is pending. The Commission has
not approved the 2026 Protocol in Idaho, nor has it established an effective date. Authorizing
deferred accounting tied to the proposed allocation methodology that remains subject to
Commission review would be premature.
If the accounting order were approved, the proposed accounting treatment would be
consistent with the National Association of Regulatory Utility Commissioners Uniform System
of Accounts, as the deferral would be recorded in Account 182.3 (Regulatory Assets). However,
Staff would oppose the Company's request to apply a carrying charge to the deferral balance.
Absent Commission approval, the Company is not entitled to recovery of these costs. Staff
believes that the proposed deferral would provide sufficient benefit to the Company without a
carrying charge and allowing it would result in an unwarranted financial benefit.
STAFF COMMENTS 3 FFBRUARY 25, 2026

STAFF RECOMMENDATION
Staff recommends that the Commission deny the Company's Application to defer the
costs and revenues allocated to customers under the 2020 Protocol compared to the revised
allocation of resources under the 2026 Protocol. Should the Commission approve the
Company's deferral request, Staff recommends that the approval state that no carrying charge
shall apply to the regulatory asset.
Respectfully submitted this 25th day of February 2026.
F- la/
Jeffrey R. Loll
Deputy Attorney General
Technical Staff. Steven Verdieck
I:\Utility\UMISC\COMMENTS\PAC-E-25-23 Comments.docx
STAFF COMMENTS 4 FFBRUARY 25, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF FEBRUARY 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-25-23, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
Rocky Mountain Power:
MARK ALDER, IDAHO REGULATORY
AFFAIRS MANAGER
JOE DALLAS, ATTORNEY
ROCKY MOUNTAIN POWER
E-MAIL: mark.alder&pacificorp.com
joseph.dallas(d),pacificorp.com
datarequest(kpacificorp.com
PATRICIA JORDA9, SECRETARY
CERTIFICATE OF SERVICE