20260312Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: JEFFREY R. LOLL
DEPUTY ATTORNEY GENERAL
DATE: MARCH 12, 2026
SUBJECT: IN THE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION
FOR APPROVAL OF THE 2026 INTER-JURISDICTIONAL COST
ALLOCATION PROTOCOL; CASE NO. PAC-E-25-14.
On August 6, 2025, Rocky Mountain Power, a division of PacifiCorp ("Company"),
applied for approval of the 2026 PacifiCorp Inter-Jurisdictional Cost Allocation Protocol ("2026
Protocol"). The Company is proposing the 2026 Protocol to replace the 2020 PacifiCorp Inter-
Jurisdictional Allocation Protocol,which was approved on April 22,2020, extended on November
2, 2023, and expires on December 31, 2025. See Order Nos. 34640 and 35984.
On September 9, 2025, the Commission issued a Notice of Application and Notice of
Intervention Deadline,setting a deadline for interested parties to intervene. Order No. 36757.Idaho
Irrigation Pumpers Association, Inc. ("IIPA") and P4 Production, L.L.C., an affiliate of Bayer
Corporation ("Bayer") intervened. Order Nos. 36773 and 36796. On December 17, 2025, the
Commission issued a Notice of Modified Procedure setting a deadline for public comments and a
Company reply deadline. Order No. 36869.
On February 20, 2026, prior to any comment deadlines, the Company filed a Motion to
Vacate the Procedural Schedule and to Suspend Discovery("Motion").
THE COMPANY'S MOTION TO VACATE THE PROCEDURAL
SCHEDULE AND TO SUSPEND DISCOVERY
The Company requests that the Commission vacate the procedural schedule set in Order
No. 36869 and suspend discovery for an indefinite period. Motion at 1. The Company's request is
based on the uncertainty surrounding the 2026 Protocol following the February 17, 2026,
DECISION MEMORANDUM 1

announcement of a proposed transaction concerning the sale of the Company's Washington service
area. Id.
Staff does not oppose the Company's request to vacate the schedule.Id. at 2. The Company
was unable to confirm the positions of IIPA or Bayer prior to filing the Motion.'Id. The Company
represents it will work with the other parties to request a new procedural schedule once the parties
have had sufficient time to assess the impact of the proposed service area transaction on the 2026
Protocol. Id.
COMMISSION DECISION
Does the Commission wish to issue an order vacating the procedural schedule set in Order
No. 36869 and suspending discovery for an indefinite period?
Jeffrey R. Loll
Deputy Attorney General
IALegal\ELECTRIC\PAC-E-25-14_Protocol\memos\PACE2514_mot j I.docx
I On March 2,2026,Bayer filed a Non-Opposition to the Company's Motion.
DECISION MEMORANDUM 2