20260406Application.pdf

_ROCKY MOUNTAIN 1407 West North Temple, Suite 330
POWER. Salt Lake City, Utah 84116
A DIVISION OF PACIFICOR=
REl,tivED
April 6, 2026 APRIL 6, 2026
IDAHO PUBLIC
VIA ELECTRONIC FILING UTILITIES COMMISSION
Commission Secretary
Idaho Public Utilities Commission
11331 W Chinden Blvd
Building 8 Suite 201A
Boise, Idaho 83714
RE: CASE NO. PAC-E-26-04 -IN THE MATTER OF THE APPLICATION OF
PACIFICORP D/B/A ROCKY MOUNTAIN POWER FOR APPROVAL OF SALE
OF WASHINGTON SERVICE AREA AND ACCOUNTING ORDER
Attention: Commission Secretary
Please find enclosed for filing Rocky Mountain Power's (the "Company") application for
authority to sell certain Washington-based generation and transmission assets to Gem Sub LLC
("Gem"), a Washington affiliate of Portland General Electric Company ("PGE"). The
Application is accompanied by confidential and public direct testimony, exhibits and
workpapers. Files containing all of the documents, testimony and exhibits as well as workpapers
will be uploaded to BOX.
All formal correspondence and data requests regarding this application should be addressed as
follows:
By E-mail (preferred): datarequestkpacificorp.com
jana.sabakpacificorp.com
adam&mrg-law.com
By regular mail: Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
Informal inquiries may be directed to Jana Saba, Director Regulation and Regulatory Operations,
at(801) 220-2823.
Sincerely,
oelle Steward
Senior Vice President of Regulation

Adam Lowney
McDowell Rackner Gibson PC
419 SW 1 Ith Ave, Suite 400
Portland, OR 97205
Email: [e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. PAC-E-26-04
APPLICATION OF PACIFICORP )
DB/A ROCKY MOUNTAIN POWER ) APPLICATION OF ROCKY
FOR APPROVAL OF SALE OF ) MOUNTAIN POWER
WASHINGTON SERVICE AREA AND )
ACCOUNTING ORDER
Comes now PacifiCorp, d/b/a Rocky Mountain Power ("PacifiCorp," "Rocky Mountain
Power" or "Company"), pursuant to Commitment I 16 in Case No. PAC-E-05-081 and the Idaho
Public Utilities Commission's ("Commission") Rule of Procedure 52, IDAPA 31.01.01.052,E
respectfully submits this application to the Commission requesting an order authorizing the
Company's sale of its Washington service area and select Washington-based assets to Gem Sub
LLC ("Gem"), a Washington affiliate of Portland General Electric Company ("PGE"). Gem will
be owned jointly by PGE and minority partner, Manulife Infrastructure Fund III, L.P., and its
affiliates including John Hancock Life Insurance Company (USA).
Under the proposed transaction, the Company will sell and Gem will purchase certain of
the Company's Washington-based generation, transmission, and distribution assets to serve
' In the Matter of the Joint Application of MidAmerican Energy Holdings Company (MEHC) and PacifiCorp dba
Utah Power&Light Company for an Order Authorizing MEHC to Acquire PacifiCorp,Case No.PAC-E-05-08,Order
No.29973 at 14(Feb. 13,2006)("MEHC and PacifiCorp will provide notification of and file for Commission approval
of the divestiture,spin-off,or sale of any integral PacifiCorp function.").
2 IDAPA 31.01.01.052 governs the requirements of Commission applications,whereby applications must state facts
fully, refer to applicable law, and request the desired action. The Company fully states the facts supporting the
Company's request in Section I. The applicable law is discussed in Section II and applied in Section III. Finally,the
Company requests Commission approval in Section IX.
APPLICATION OF ROCKY MOUNTAN POWER Page 1

Washington customers ("Service Area Transfer"). Once the Service Area Transfer receives all
necessary regulatory approvals and is completed, the assets, as well as the Company's obligation
to serve Washington customers, will transfer to Gem, which will begin providing service as a
public utility in the state of Washington.
In support of this application, Rocky Mountain Power states as follows:
I. BACKGROUND
1. The Company provides retail electric service under the name Rocky Mountain
Power in the states of Idaho, Wyoming, and Utah, and under the name Pacific Power in the states
of Oregon, Washington, and California. Rocky Mountain Power is a public utility in the state of
Idaho subject to the jurisdiction of the Commission with regard to its electric service to over 90,700
retail customers in Idaho.
2. The Company proposes selling its entire Washington service area, with
approximately 137,000 customers located in Yakima, Walla Walla, Columbia, Garfield, and
Benton counties. The Washington service area covers approximately 2,730 square miles and
includes approximately 35 communities.The customer mix is approximately 84 percent residential
and 16 percent commercial and industrial.
3. The Service Area Transfer includes three generation assets located in Washington
state: the 477 megawatt ("MW") Chehalis combined cycle gas turbine power plant in Lewis
County, the 94 MW Goodnoe Hills Wind Farm located in Klickitat County, and the 234 MW
Marengo I and II Wind Farms located in Columbia County. It also includes certain Washington-
based transmission assets, specifically 393 miles of transmission lines, 10 substations (two of
which will be jointly owned), and approximately 6,220 structures; and certain Washington-based
APPLICATION OF ROCKY MOUNTAIN POWER Page 2

distribution assets, specifically around 4,100 miles of distribution lines, 34 substations, and
approximately 100,480 poles.
4. The assets the Company is proposing to sell comprise a relatively small portion of
its total operating facilities. Specifically, the Company will sell approximately 4,100 miles of its
approximately 66,900 miles of distribution lines system-wide and 393 miles of its approximately
17,700 miles of transmission lines system-wide. Further, the Goodnoe Hills Wind Farm, the
Marengo I and II Wind Farms,and the Chehalis combined cycle gas turbine power plant altogether
comprise 805 MW of the Company's approximately 15,452 MW of owned and contracted
generation capacity system-wide. The testimony accompanying this application demonstrates that
the transfer of the duty to serve the Washington service area and the sale of certain Washington-
based assets improves the Company's overall system load and resource balance and mitigates
future resource adequacy challenges.
5. The base purchase price for the Service Area Transfer at the time of signing,subject
to relevant adjustment, is $1.9 billion. In addition to the base purchase price, Gem will pay
additional cash consideration for the accounts receivable and regulatory assets(net of deposits) set
forth in Schedule 1.1-RA to the Asset Purchase and Service Area Transfer Agreement (the
"Agreement")' at closing, although Gem will only purchase the accounts receivable set forth in
Schedule 1.1-RA to the extent that the value of such accounts receivable exceeds the amount of
accounts receivable and accounts payable assumed to be in the normalized net working capital.
Together, the base purchase price and such additional cash consideration constitute the purchase
price. Following the closing, a post-closing determination of the actual net working capital and
actual value of the specified assets set forth in Schedule 1.1-RA to the Agreement will transpire.
3 See,Attachment No. 1 to the application.
APPLICATION OF ROCKY MOUNTAIN POWER Page 3

6. The net book value of all assets to be sold is approximately $1.36 billion with the
goodwill value of the business,net of taxes and other transaction costs, accounting for the balance
of the purchase price. The purchase price for the Service Area Transfer includes approximately
$504 million in goodwill value, before closing costs. The goodwill value is the amount received
in excess of the fair market value of the assets sold in this transaction. The Company proposes to
assign customers 68 percent of the Idaho-allocated portion of this goodwill, yielding an $8.9
million credit. The Company will provide this rate credit over three years in the Company's next
general rate case, resulting in an annual rate credit of approximately $3.0 million. As set forth in
the Company's supporting testimony, PacifiCorp's proposal to assign 68 percent of the goodwill
value to customers and 32 percent to the Company is supported by the benefits the Service Area
Transfer brings to the Company's customers, and better positions the Company to meet the
financial challenges associated with the rapidly changing utility landscape. In addition, the
generation assets included in the transfer are approximately 37 percent depreciated;the Company's
proposal to assign 68 percent of the goodwill value to customers is roughly twice current
depreciation levels in these assets.
7. The Company proposes selling certain Washington-based assets as part of the
Service Area Transfer for two overarching reasons: to manage risk and to improve its financial
position. First, the Service Area Transfer will help the Company manage risks associated with
operating an expansive, multi-state system. The Company provides retail electric service to over
two million customers across six states: Idaho, Utah, Wyoming, Washington, Oregon, and
California. Operating in and planning for six states can prove challenging, especially with states'
continued implementation of discrete energy policies. As an example, the Company's non-
Washington states (with the exception of California) have been unwilling to pay the costs of the
APPLICATION OF ROCKY MOUNTAIN POWER Page 4

Chehalis plant's compliance with Washington's Climate Commitment Act ("CCA"),' costing the
Company approximately $45 million annually. The Company has sought to solve this problem
through a new multi-state cost allocation protocol. While the Washington Utilities and
Transportation Commission ("Washington Commission") recently approved the Washington
version of this protocol,5 the uniform adoption of a new multi-state cost allocation protocol in the
Company's other states is uncertain. Sale of the Washington service area resolves this CCA issue,
scales down the Company's overall system load by eight percent, and helps address other multi-
state cost allocation challenges, allowing the Company to streamline planning, financing, and
operations of its multi-state system.
8. Second, the Service Area Transfer will better position the Company to meet the
financial challenges associated with providing safe and reliable service. This is especially crucial
now given that the Company is under significant financial pressure as a result of wildfire litigation
and adverse regulatory outcomes.PacifiCorp was recently downgraded by S&P to the lowest credit
rating level that is still considered investment grade, and both S&P and Moody's have placed
PacifiCorp on Negative Outlook. As a result of these downgraded ratings, the Company's cost of
debt has increased and its access to capital has decreased, both of which impede the Company's
near-term ability to make the capital investments that are necessary to reliably operate the system.
The Service Area Transfer supports stabilization of the Company's financial position and builds
investor confidence by resolving the Company's CCA losses from Chehalis and relieving the
4 The Commission denied recovery of CCA costs in the Company's 2024 Energy Cost Adjustment Mechanism docket.
In the Matter of Rocky Mountain Power's Application for Approval of $62.4 Million ECAM Deferral, Case
No.PAC-E-24-05,Order No. 36207 at 11-12(May 31,2024).
5 Wash. Utils. &Transp. Conan n v.PaciftCorp,d/b/a Pac.Power&Light Co.,Washington Commission Docket No.
UE-250224,Order 08 at¶ 18(Dec.22,2025).
APPLICATION OF ROCKY MOUNTAIN POWER Page 5

Company's financial obligation to make additional capital expenditures necessary for compliance
with the Clean Energy Transformation Act ("CETA") in Washington.
9. The primary transaction document is the Agreement, with attached exhibits
containing term sheets and plans addressing energy and capacity and electric transmission rights.
The Agreement is attached to the application as Attachment No. 1. Another notable exhibit to the
Agreement is the Form of Transition Services Agreement,which will cover a schedule of services
to be provided over an agreed-upon transition period to ensure the continuity of the operation of
the assets and service to Washington customers. The Company, PGE, and Gem executed the
Agreement on February 15, 2026.
10. The closing of the Service Area Transfer is subject to regulatory approvals,
including the Commission's approval of the sale in this proceeding. The Company, Gem,and PGE
are seeking all other approvals necessary to complete the Service Area Transfer. The Company,
PGE, and Gem are jointly seeking regulatory approval from the Washington Commission for the
purchase and sale of assets. PGE is seeking regulatory approval from the Public Utility
Commission of Oregon ("Oregon Commission") for the purchase of assets. Additionally, the
Company, PGE, and Gem are seeking approval from the Federal Energy Regulatory Commission
("FERC"). The Company is also seeking regulatory approval for the sale of assets from the Oregon
Commission,the California Public Utilities Commission,the Public Service Commission of Utah,
and the Wyoming Public Service Commission. The waiting period under the Hart-Scott-Rodino
Antitrust Improvements Act of 1976 for this transaction has expired and the Company and PGE
have provided the required notice pursuant to the Washington Uniform Antitrust Premerger
Notification Act.
APPLICATION OF ROCKY MOUNTAIN POWER Page 6

II. LEGAL STANDARD
11. The proposed Service Area Transfer involves the sale of certain Washington-based
Company assets and its Washington service area but does not involve a merger or sale of interest
in Rocky Mountain Power, an Idaho public utility. While Idaho Code § 61-328 requires an electric
public utility owning property located in Idaho to receive authorization from the Commission
before selling utility property,the Commission has interpreted that statute to apply only to the sale
of utility property located within Idaho.6 Because the Service Area Transfer does not consist of
the sale of any property located in Idaho, Idaho Code §61-328 does not require approval of the
Service Area Transfer.
12. However, in the 2006 Commission order approving MidAmerican Energy Holding
Company's acquisition of the Company, the Company committed to requesting Commission
approval of any "divestiture, spin-off, or sale of any integral PacifiCorp function" through Idaho
Commitment I 16.' With this Service Area Transfer, the Company will sell its entire Washington
service area, 805 MW of generation assets, approximately 4,100 miles of distribution lines, and
393 miles of transmission lines. Because this consists of most of its assets in Washington, the
Company considers these assets integral to its function. Therefore, here, Rocky Mountain Power
requests Commission authorization of the Service Area Transfer pursuant to Commitment 116.
13. Since the adoption of Commitment 116, the Company has not sought Commission
approval of proposed sales under this Idaho merger commitment. The Commission has therefore
not yet identified an applicable legal standard for considering the Company's proposed Service
6 See In the Matter of Rocky Mountain Power's Application for Approval of the Transfer of Portions of the North
Temple Property and Accounting Order, Case No. PAC-E-24-06, Order No. 36336 at 5 (Sep. 30, 2024) ("[T]he
Company is not required to obtain approval from this Commission to dispose of[its assets] because they are not
located in Idaho.").
Case No.PAC-E-05-08,Order No.29973,Attachment No. 1 at 14.
APPLICATION OF ROCKY MOUNTAIN POWER Page 7

Area Transfer. Despite its inapplicability to the sale of assets located outside Idaho, the Company
requests the Commission apply a standard similar to Idaho Code § 61-328 in assessing the Service
Area Transfer;$ namely, that"before authorizing the transaction, the [Commission] shall find: (a)
That the transaction is consistent with the public interest;" and "(b) That the cost of and rates for
supplying service will not be increased by reason of such transaction[.]"' Regarding the public
interest criterion,the Commission has found previous asset sales consistent with the public interest
when such sales reduce costs, increase efficiency, and enhance reliability."
III. THE SERVICE AREA TRANSFER IS CONSISTENT WITH THE PUBLIC
INTEREST AND WILL NOT INCREASE RATES
14. The Service Area Transfer is consistent with the public interest and will provide
benefits to the Company's remaining customers, including those in Idaho.
15. For purposes of analyzing and allocating the costs and benefits of this transaction,
the Company has looked to the 2020 PacifiCorp Inter jurisdictional Cost Allocation Protocol
("2020 Protocol") for guidance, as this was adopted by all Company states for allocating certain
system costs,is the basis for current rates,and many stakeholders have advocated for its use during
a The Commission has previously applied the standards in Idaho Code§ 61-328 when considering the sale of out-of-
state assets. See, e.g.,In the Matter of the Application of Avista Corporation for an Order Approving the Sale of Its
Interest in the Skookumchuck Hydroelectric Plant and for EWG Determinations, Case No.AVU-E-04-2, Order
No.29484 at 8 (Apr.28, 2004) (concluding that the proposed sale of a facility in Washington "complies with the
intent and meets the standards of Idaho Code§61-328).
9Idaho Code§61-328(3)(a)-(b).Idaho Code§61-328(3)(c)requires a finding that"the applicant for such acquisition
or transfer has the bona fide intent and financial ability to operate and maintain said property in the public service."
As presented in the Agreement,Gem is a bona fide purchaser and PacifiCorp represents that PGE,an affiliate of Gem,
is an electric public utility with the financial ability to operate and maintain the assets included in the Service Area
Transfer for public benefit.
"See, e.g.,In the Matter of the Agreement for Purchase and Sale of the Cheney and Four Lakes Tap Lines and the
Transfer of Ownership Agreement between Avista and Bonneville Power Administration, Case No. AVU-E-18-09,
Order No.34214 at 2(Dec. 17,2018)(approving asset sale that would"result in a more efficient use of resources and
reduced costs" for utilities, "enhance reliability to meet future load growth"); In the Matter of the Application of
PacifiCorp dba Rocky Mountain Power and Idaho Power Company for an Order Authorizing the Exchange of Certain
Transmission Assets, Case Nos. IPC-E-14-41 and PAC E-14-11, Order No. 33313 at 12 (June 5, 2015) (approving
asset sale that would"ensure more efficient management,""facilitate service of expected load growth,"and"improve
reliability for customers").
APPLICATION OF ROCKY MOUNTAIN POWER Page 8

this transitional period to a new inter jurisdictional cost allocation methodology. Application of
the 2020 Protocol here guides both the assignment of the goodwill value of the Service Area
Transfer, which the Company proposes be based on allocation of the underlying resources,11 and
the treatment of changes in the loads and resources from the sale of service area on other states,
which the Company proposes be reflected through operation of dynamic allocation factors.12
Rocky Mountain Power requests that the Commission approve utilizing the 2020 Protocol as
proposed in this application.
16. First, the Service Area Transfer will not increase rates for the Company's Idaho
customers. The testimony accompanying this application demonstrates that the net effect of the
transfer of the duty to serve customers in the Washington service area to Gem and the sale of
certain Washington-based assets is no change or a net benefit. The Company will fund a rate credit
of$8.9 million. Because the Company anticipates the transition period to last approximately three
years, Rocky Mountain Power proposes amortizing this rate credit over three years providing
approximately$3.0 million annually.The rate credit,along with other quantifiable benefits,offsets
the incremental costs of the transaction. Even after the rate credits expires, other benefits continue
to offset transaction costs.
17. As discussed above in Section I, the purchase price for the Service Area Transfer
includes approximately$504 million in goodwill,before closing costs,and the Company proposes
"Under Section 7 of the 2020 Protocol,"[a]ny gain or loss from the sale of Company-owned assets will be
allocated among or to States based upon the proportional allocation or assignment of the asset at the time of the
execution date of the sale agreement."11 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, Steward Exhibit No. 1 at 43
(filed Dec. 3,2019).This section then permits each commission to allocate their share of the gain or loss between
customers and shareholders.
'Z Under Section 3.1.9 of the 2020 Protocol,the allocation of costs and benefits from load changes associated with a
service area sale is treated through application of dynamic allocation factors(for changes in load under 5 percent)or
on a case-by-case basis(for changes in load over 5 percent).Id. at 13.While Washington constitutes approximately
eight percent of PacifiCorp's load,PacifiCorp is proposing in this case to follow the standard approach using
dynamic allocation factors to address the changes in load and resources associated with the Service Area Transfer.
APPLICATION OF ROCKY MOUNTAIN POWER Page 9

to assign customers 68 percent of the Idaho allocation of this goodwill value. As set forth in the
Company's supporting testimony, this assignment is supported by the benefits the Service Area
Transfer brings to the Company's customers, and better positions the Company to meet the
financial challenges associated with providing safe and reliable service.
18. The Commission has previously approved applying the depreciation reserve
method for assigning gains resulting from the sale of utility assets, which shares gains between
customers and the utility according to the ratio of accumulated depreciation to gross plant.13
Although this standard is not directly applicable here because the gain is associated with intangible
and non-depreciable goodwill, as a comparison,the generation assets included in the Service Area
Transfer are approximately 37 percent depreciated,meaning approximately two-thirds of the value
of the transferred assets has not yet been recovered through customers' rates. The Company's
proposal to assign 68 percent of the regulatory gain on the sale to customers represents roughly
twice the percentage that would be assigned to customers using the depreciation reserve method."
19. Second,the testimony accompanying this application demonstrates that the Service
Area Transfer improves the Company's overall system load and resource balance and mitigates
future resource adequacy challenges.
20. Third, the Service Area Transfer will provide long-term financial benefits by
relieving the Company from its obligation to make the required capital expenditures necessary for
13 In the Matter of the Application of PacifiCorp for an Order Approving the Sale of its Interest in (1) The Centralia
Steam Electric Generating Plant, (2) The Rate Based Portion of its Centralia Coal Mine, and(3)Related Facilities;
For a Determination of the Amount of and the Proper Ratemaking Treatment of the Gain Associated with the Sale;
and(4) an EWG Determination,Case No.PAC-E-99-2,Order No. 28296 at*21-22(Mar. 1,2000); Case No.AVU-
E-04-2,Order No.29484 at 8.
14 The Company provides this comparison to the depreciation reserve methodology solely to further demonstrate that
the Company's proposal is in the public interest.The regulatory gain that the Company proposes sharing between the
Company and customers is associated with the goodwill value of the business,an intangible value attributable to the
Company's long-time service in Washington state, rather than a gain on the assets included in the Service Area
Transfer.
APPLICATION OF ROCKY MOUNTAIN POWER Page 10

compliance with Washington climate laws because, by selling its Washington service area, the
Company will no longer operate as a Washington jurisdictional utility.
21. Because the proposed Service Area Transfer will provide benefits to Idaho
customers and the Company, the Commission should conclude that the Service Area Transfer is
in the public interest and should approve the Service Area Transfer.
IV. REQUEST FOR APPROVAL OF ACCOUNTING ORDER
22. In accordance with Idaho Code § 61-524, PacifiCorp also requests approval of an
accounting order that would authorize the recording of a regulatory liability for Idaho-allocated
goodwill value from the sale, which PacifiCorp proposes sharing with customers. As discussed
above in Section III, PacifiCorp proposes to share the goodwill value with customers by funding
an annual rate credit of$3.0 million. PacifiCorp proposes recording these rate credits by crediting
FERC Account 254-Other Regulatory Liabilities. PacifiCorp requests that the goodwill value
recorded in this account be amortized over three years in PacifiCorp's next general rate case.
V. REQUESTED APPROVAL DATE
23. The Company respectfully requests approval of the Service Area Transfer as
expeditiously as possible but no later than March 1, 2027, to allow the Service Area Transfer to
close soon thereafter. The Service Area Transfer is important for the customers, communities,
employees, and shareholders of the Company, Gem, and PGE. These stakeholders are subject to
uncertainty during the pendency of the application. Processing this application expeditiously will
mitigate this uncertainty and serve the public interest.
VI. CONFIDENTIAL INFORMATION
24. This filing, specifically portions of the Agreement, the testimony and certain
exhibits of Joelle R. Steward, Michael G. Wilding, and Ramon J. Mitchell, include confidential
APPLICATION OF ROCKY MOUNTAIN POWER Page 11

information exempt from public review under Idaho Code §§ 74-104-109 and Idaho Public
Utilities Commission's Rule of Procedure 67.
VII. REQUEST FOR MODIFIED PROCEDURE
25. 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 Commission
Rules of Procedure 201 through 204."
VIII. COMMUNICATIONS
26. Communications regarding this filing should be addressed to:
Jana Saba
Director, Regulatory Affairs
1407 West North Temple, Suite 310
Salt Lake City, UT 84116
Telephone: [phone]
E-mail:jana.sabakpacificorp.com
Adam Lowney
McDowell Rackner Gibson PC
419 SW 1 Ith Ave, Suite 400
Portland, OR 97205
Telephone: [phone]
Email: adam( rare-law.com
15 IDAPA 31.01.01.201-204.
APPLICATION OF ROCKY MOUNTAIN POWER Page 12

27. In addition, Rocky Mountain Power requests that all data requests regarding this
application be sent in Microsoft Word or plain text format to the following:
By email (preferred): datarequestkpacificorp.com
By regular mail: Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
28. Informal inquiries may be directed to Jana Saba, Director of Regulatory Affairs, at
[phone].
IX. DESCRIPTION OF SUPPORTING TESTIMONY
29. This application is supported by testimony from the following witnesses:
• Richard J. Garlish,President of Rocky Mountain Power,provides an overview of
the Company, including its utility services in Idaho and Washington, briefly
describes the Service Area Transfer, and explains why the Company seeks to
transfer the Washington service area and certain Washington-based assets to Gem.
• Joelle R. Steward, Senior Vice President,Regulation,provides information on the
Service Area Transfer, explains how the Service Area Transfer is consistent with
the public interest, and discusses key aspects of the transaction documents.
• Nikki L. Kobliha, Senior Vice President of Finance, provides the Company's
financial information relevant to the proposed Service Area Transfer and discusses
the calculation of the regulatory gain attributable to the goodwill value of the
business, the proposed assignment of goodwill value to customers, and the
calculation of customer rate credits.
APPLICATION OF ROCKY MOUNTAIN POWER Page 13

• Michael G. Wilding, Vice President of Energy Supply Management ("ESM"),
explains how PacifiCorp and Gem will transition service in Washington, and
demonstrates that the Service Area Transfer does not harm resource adequacy and
reliability for Idaho customers.
• Ramon J. Mitchell, Managing Director of ESM Finance and Net Power Costs
("NPC"), presents the Company's forecast NPC incorporating the Service Area
Transfer.
• Shelley E. McCoy, Director of Revenue Requirement, presents the Company's
revenue requirement incorporating the Service Area Transfer, and addresses cost
allocation issues.
X. CONCLUSION
WHEREFORE, for all the reasons stated in this application, the Company respectfully
requests that the Commission issue an order approving the Service Area Transfer, by which the
Company will sell to Gem its Washington service area and certain Washington-based assets, as
expeditiously as possible. Rocky Mountain Power also requests that the Commission approve the
Company's proposed application of the 2020 Protocol to analyze and allocate the costs and
benefits of the Service Area Transfer, including the resulting changes in load and resources.
APPLICATION OF ROCKY MOUNTAIN POWER Page 14

DATED this 6th day of April 2026.
Respectfully submitted,
-1 4
Adam Lowne
McDowell Rackner Gibson PC
419 SW 1 Ith Ave, Suite 400
Portland, OR 97205
Attorney for Rocky Mountain Power
APPLICATION OF ROCKY MOUNTAIN POWER Page 15