20260406Direct Steward REDACTED.pdf

RECEIVED
APRIL 6, 2026
IDAHO PUBLIC
'ITILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. PAC-E-26-04
OF PACIFICORP D/B/A ROCKY )
MOUNTAIN POWER FOR APPROVAL OF ) DIRECT TESTIMONY OF
SALE OF WASHINGTON SERVICE AREA ) JOELLE R. STEWARD
AND ACCOUNTING ORDER ) REDACTED
ROCKY MOUNTAIN POWER
CASE NO. PAC-E-26-04
April 2026

1 I . INTRODUCTION
2 Q. Please state your name, business address , and present
3 position with PacifiCorp d/b/a Rocky Mountain Power.
4 A. My name is Joelle R. Steward, my business address is
5 1407 West North Temple, Salt Lake City, Utah 84116 . I am
6 currently employed as Senior Vice President, Regulation
7 for Rocky Mountain Power.
8 Q. Please summarize your education and professional
9 experience.
10 A. I have a Bachelor of Arts degree in Political Science
11 from the University of Oregon and an M.A. in Public
12 Affairs from the Hubert Humphrey Institute of Public
13 Policy at the University of Minnesota. Between 1999 and
14 March 2007, I was employed as a Regulatory Analyst with
15 the Washington Utilities and Transportation Commission.
16 I joined PacifiCorp in March 2007 as a Regulatory
17 Manager, responsible for all regulatory filings and
18 proceedings in Oregon. On February 14, 2012, I assumed
19 responsibilities overseeing cost of service and pricing
20 for PacifiCorp. In May 2015, I assumed broader oversight
21 over regulatory affairs in addition to the cost of
22 service and pricing responsibilities . In 2017, I assumed
23 the role as Vice President, Regulation for Rocky
24 Mountain Power; in November 2021, I assumed my current
25 role as Senior Vice President, Regulation.
Steward, Di 1
Rocky Mountain Power

1 Q. What is the purpose of your testimony?
2 A. My testimony provides detailed information on the sale
3 of PacifiCorp' s Washington service area and select
4 Washington-based assets ("Service Area Transfer") to a
5 newly formed affiliate of Portland General Electric
6 Company ("PGE") , Gem Sub LLC ("Gem") . My testimony
7 provides an overview of the Asset Purchase and Service
8 Area Transfer Agreement (the "Agreement") , which is
9 attached to the application as Attachment No . 1, and
10 explains how the Service Area Transfer serves the public
11 interest .
12 Q. Please summarize your testimony.
13 A. I recommend that the Idaho Public Utilities Commission
14 ("Commission") approve the sale of the Washington-based
15 generation and transmission assets included in the
16 Service Area Transfer. The transaction is in the public
17 interest because it will not adversely impact
18 PacifiCorp' s Idaho customers and will support the
19 financial health of PacifiCorp. PacifiCorp is proposing
20 to share 68 percent of the Idaho-allocated goodwill
21 value with customers through a rate credit, beginning
22 with the next general rate case . The rate credit, in
23 conjunction with other benefits identified by
24 PacifiCorp' s witnesses in this application and
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Rocky Mountain Power

1 summarized in my testimony, generally result in net
2 benefits to Idaho customers .
3 II . DESCRIPTION OF THE SERVICE AREA TRANSFER
4 Q. Please provide an overview of the Service Area Transfer.
5 A. In the proposed transaction, PacifiCorp will sell and
6 Gem will purchase PacifiCorp' s Washington service area
7 and certain Washington-based assets, including select
8 generation and transmission assets . Upon regulatory
9 approval and completion of the transaction, PacifiCorp
10 will no longer provide service as a public service
11 company in the state of Washington. Figure 1 below is a
12 map showing the service area that will transfer from
13 PacifiCorp to Gem.
Steward, Di 3
Rocky Mountain Power

Figure 1 : Service Area Transfer Map
0
■ Power Plants
Electric Service Area
Operating Transmission Lines
seattle
Marengo 11111
■ Wind Farm
QLewi
234 MW
Chehalis
Natural Gas Plant
477 MW on
Kennewick
alla Walla
Goodnoa Hills
Wind Farm
94 MW
1 The assets sold, as well as PacifiCorp' s obligation
2 to serve Washington customers, will transfer to Gem,which
3 is a special purpose entity formed for the Service Area
4 Transfer. Gem will be a Washington public service
5 company serving Washington customers .
6 Q. What are the general terms of the proposed transaction?
7 A. The base purchase price for the Service Area Transfer is
8 approximately $1 . 9 billion subject to certain
9 adjustments . In exchange for the purchase price,
10 PacifiCorp will sell its business of operating a public
11 service company in Washington, along with the
12 distribution assets and select generation and
13 transmission assets located in Washington. In total, the
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Rocky Mountain Power

1 Service Area Transfer will involve the transfer of 805
2 megawatts ("MW") of generation assets, 393 miles of
3 transmission lines, and approximately 4, 100 miles of
4 distribution lines from PacifiCorp to Gem.
5 Q. Please briefly describe the Washington service area.
6 A. In Washington, PacifiCorp serves approximately 137, 000
7 customers, 84 percent residential and 16 percent
8 commercial and industrial . PacifiCorp plans to sell Gem
9 this entire service area of over approximately 2, 730
10 square miles through the Service Area Transfer.
11 Q. How did PacifiCorp select the assets to sell to Gem as
12 a part of the Service Area Transfer?
13 A. To ensure Gem can provide excellent, uninterrupted
14 service, PacifiCorp included Washington-based assets
15 integral to serving customers in the Washington service
16 area, as detailed below.
17 Q. Can you describe these assets with more specificity?
18 A. Yes . First, PacifiCorp will sell Washington-based
19 generation assets, including the Goodnoe Hills Wind Farm
20 (94 MW) , the Marengo I and II Wind Farms (234 MW) , and
21 the Chehalis combined cycle gas turbine power plant (477
22 MW) , but excluding the Lewis River hydroelectric
23 facilities . Second, PacifiCorp will sell Washington-
24 based transmission assets, including 393 miles of
25 transmission lines, 10 substations (two will be jointly
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Rocky Mountain Power

1 owned) , and approximately 6, 220 structures,
2 predominantly located in and around Yakima, Washington
3 and from Kennewick, Washington to Lewiston, Idaho .
4 Third, PacifiCorp will sell Washington-based
5 distribution assets, including approximately 4, 100 miles
6 of distribution lines, 34 substations, and approximately
7 100, 480 poles .
8 Q. Beyond these assets, what else is PacifiCorp
9 transferring to Gem so that it can serve Washington
10 customers?
11 A. In its Washington service area, PacifiCorp will assign
12 or transfer to Gem permits and franchise, lease,
13 interconnection, license, transportation and other
14 agreements associated with the Service Area Transfer.
15 Additionally, PacifiCorp will assign certain Washington
16 qualifying facility agreements to Gem, as well as the
17 transmission rights necessary to effectively serve
18 Washington customers, which PacifiCorp witness Michael
19 G. Wilding further discusses .
20 Q. Please describe how PacifiCorp determined the value of
21 the assets being sold.
22 A. The value of the assets was determined by their net book
23 value on PacifiCorp' s books and records, which will be
24 updated to reflect the net book value of the assets
25 immediately before the transaction closes .
Steward, Di 6
Rocky Mountain Power

1 Q. How did PacifiCorp and Gem arrive at a $1 . 9 billion base
2 purchase price?
3 A. PacifiCorp and Gem agreed upon a base purchase price of
4 $1 . 9 billion reflecting the net book value of all assets
5 to be sold, approximately $1 . 36 billion, and the value
6 associated with the goodwill of PacifiCorp' s Washington
7 operations, as discussed by PacifiCorp witness Nikki L.
8 Kobliha.
9 III . ASSET PURCHASE AND SERVICE AREA TRANSFER AGREEMENT
10 Q. Who are the parties to the Agreement?
11 A. In the Agreement, PacifiCorp is the "Seller, " Gem is the
12 "Buyer, " and PGE is the "Buyer Parent . "
13 Q. When did the parties execute the Agreement?
14 A. The parties executed the Agreement on February 15, 2026 .
15 A copy of the Agreement is attached to the application
16 as Attachment No . 1 .
17 Q. Please provide a high-level overview of the Agreement.
18 A. The Agreement governs the terms and conditions of the
19 transaction between PacifiCorp and Gem, whereby
20 PacifiCorp will cease and Gem will begin operations as
21 a Washington-jurisdictional electrical company and
22 public service company with respect to the "Business . "
23 Q. What is the "Business"?
24 A. For purposes of the Agreement, the "Business" means (a)
25 the electric transmission and distribution business
Steward, Di 7
Rocky Mountain Power

1 serving customers (including the obligation to serve
2 customers) in the Washington service area as conducted
3 by the Seller as of the closing; and (b) the ownership
4 and operation of the following generation facilities,
5 including related interconnection and other facilities : '
6 Chehalis combined cycle gas turbine plant, Goodnoe Hills
7 wind plant, and Marengo I and Marengo II wind plant .
8 Q. By purchasing the Business, will Gem be replacing
9 PacifiCorp as the Washington electrical company and
10 public service company in the service area?
11 A. Yes, the Agreement will result in a direct change of
12 ownership of the electrical company providing service to
13 the Washington service area. Gem will become a
14 Washington-jurisdictional utility and PacifiCorp will no
15 longer operate as a public utility in Washington.
16 Q. What regulatory approvals are required as a condition to
17 closing?
18 A. In addition to approval from Commission, the Agreement
19 includes further regulatory approval conditions,
20 including the approval from the Federal Energy
21 Regulatory Commission ("FERC") and PacifiCorp' s other
22 state regulators .
' Disclosure Schedule 2.1 (a) in the Agreement (Attachment No. 1 to the
application) provides details on the assets and related facilities being
transferred.
Steward, Di 8
Rocky Mountain Power

1 Q. Which party is responsible for which approvals?
2 A. PacifiCorp and Gem are jointly responsible for
3 Washington Utilities and Transportation Commission
4 approval . Gem is responsible for approval from FERC
5 under Section 203 of the Federal Power Act and the Public
6 Utility Commission of Oregon ("Oregon Commission") for
7 the asset purchase . PacifiCorp is primarily responsible
8 for asset sale approval from the Commission and from the
9 California Public Utilities Commission, Oregon
10 Commission, Public Service Commission of Utah, and
11 Wyoming Public Service Commission.
12 Q. Does the Agreement include exhibits to implement the
13 Service Area Transfer?
14 A. Yes . Attached to the Agreement as exhibits are a Form of
15 Transition Services Agreement (Exhibit B) , 2 a Balancing
16 Authority Services Term Sheet (Exhibit I) , 3 and plans
17 for other ancillary agreements, including agreements
18 relating to generation capacity, natural gas
19 transportation, transmission service, and
20 interconnection.
2 The Form of Transition Services Agreement is provided in Attachment
No. 1 to the application.
3 The Balancing Authority Services Term Sheet is provided in Attachment
No. 1 to the application.
Steward, Di 9
Rocky Mountain Power

1 Q. Please describe the Form of Transition Services
2 Agreement at a high level .
3 A. PacifiCorp and Gem will execute a Transition Services
4 Agreement at the closing to ensure that the Service Area
5 Transfer will not disrupt service to customers or either
6 utility' s overall system. Under the Transition Services
7 Agreement, PacifiCorp will provide certain transitional
8 services to Gem for defined periods following the
9 closing, and Gem will pay PacifiCorp' s fully burdened
10 cost for those services on a monthly basis .
11 Q. Is the Transition Services Agreement finalized?
12 A. Not yet . A form of the Transition Services Agreement is
13 attached to the Agreement as Exhibit B. 4 As required by
14 Section 5 . 12 of the Agreement, PacifiCorp and Gem are
15 negotiating in good faith to finalize the Transition
16 Services Agreement' s specific service schedules, prior
17 to closing.
18 Q. What are some of the other noteworthy term sheets and
19 plans attached to the Agreement as exhibits?
20 A. Mr. Wilding provides further details on these exhibits,
21 which include a Power Purchase Agreement Term Sheet
22 (attached as Exhibit F to the Agreement) , an Electric
23 Transmission Service and Interconnection Plan (attached
24 as Exhibit G to the Agreement) , and a Balancing Authority
4 Attachment No. 1 to the application.
Steward, Di 10
Rocky Mountain Power

1 Services Term Sheet (attached as Exhibit I to the
2 Agreement) . 5
3 Q. Please provide a high-level overview of these exhibits .
4 A. Like the Transition Services Agreement, these other
5 noteworthy exhibits are designed to ensure a seamless
6 transition from PacifiCorp to Gem ownership. At a high
7 level, PacifiCorp will sell Gem energy, capacity, and
8 renewable energy credits ("RECs") during a transitional
9 period at contracted prices ("Bridge PPA") .
10 Additionally, PacifiCorp and Gem will execute binding
11 transmission service and interconnection agreements,
12 including point-to-point agreements across PacifiCorp' s
13 system, a construction funding agreement and joint
14 ownership, operating, and maintenance agreement for the
15 joint construction of an upgrade to the transmission
16 path from the Walla Walla substation to the Wallula
17 substation, and transmission service agreements over the
18 Bonneville Power Administration' s system. Further, Gem
19 will purchase the full suite of ancillary services and
20 certain balancing authority services for a transitional
21 period, unless extended on a year-to-year basis . I refer
22 to this as the BA Services Agreement ("BASA") later in
23 my testimony.
5 These agreements are all provided in Attachment No. 1 to the
application.
Steward, Di 11
Rocky Mountain Power

1 Q. Are these agreements finalized?
2 A. No, but as mentioned, term sheets and plans are attached
3 to the Agreement as exhibits . Before closing, PacifiCorp
4 and Gem will negotiate in good faith and use reasonable
5 best efforts to prepare and finalize these agreements .
6 IV. THE SERVICE AREA TRANSFER IS CONSISTENT WITH THE
7 PUBLIC INTEREST
8 Q. What is your understanding of the applicable law for the
9 Service Area Transfer?
10 A. My understanding is that as a condition of the
11 Commission' s approval of MidAmerican Energy Holding
12 Company' s acquisition of PacifiCorp, PacifiCorp
13 committed to requesting Commission approval of any
14 "divestiture, spin-off, or sale of any integral
15 PacifiCorp function" through an Idaho merger commitment
16 ("Commitment I 16") . 6 Considering Gem will not be
17 acquiring any property located in Idaho and will not be
18 merging with PacifiCorp, Idaho Code §61-328 does not
19 apply.
6 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) .
Steward, Di 12
Rocky Mountain Power

1 Q. What must PacifiCorp demonstrate for Commission approval
2 of the Service Area Transfer?
3 A. My understanding is that PacifiCorp has not previously
4 sought Commission approval of a sale pursuant to
5 Commitment I 16, and for that reason the Commission has
6 not yet identified an applicable legal standard for
7 considering PacifiCorp' s proposed Service Area Transfer.
8 However, it is my understanding that Idaho Code § 61-
9 328, applicable to property sales within Idaho, requires
10 a finding " (a) That the transaction is consistent with
11 the public interest; " and " (b) That the cost of and rates
12 for supplying service will not be increased by reason of
13 such transaction [ . ] "' While Idaho Code § 61-328 does not
14 apply to the Service Area Transfer because the assets
15 included in the Service Area Transfer are located
16 outside of Idaho, 8 PacifiCorp' s filing meets the
17 requirements of that statute .
7 Idaho Code § 61-328 (3) (a) - (b) .
8 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.") .
Steward, Di 13
Rocky Mountain Power

1 Q. Is the Service Area Transfer consistent with the
2 public interest?
3 A. Yes, the Service Area Transfer will benefit customers
4 and will help reduce risk. Therefore, the asset sale is
5 consistent with the public interest .
6 Q. Can you explain how the sale of certain Washington-based
7 assets will affect Idaho customers, given that
8 PacifiCorp currently operates as a single system?
9 A. Overall, the sale of the Washington-based assets will
10 not harm Idaho customers because the assets PacifiCorp
11 is proposing to sell are a relatively small portion of
12 its total, system-wide operating facilities . More
13 specifically, PacifiCorp will sell 393 miles of its
14 approximately 17, 700 miles of transmission lines system-
15 wide and 805 MW of its approximately 15, 452 MW in total
16 generation capacity system-wide . Additionally,
17 PacifiCorp will sell approximately 4, 100 miles of its
18 approximately 66, 900 miles of distribution lines system-
19 wide, none of which it uses to serve Idaho customers .
20 Q. Will rates for PacifiCorp' s Idaho customers increase
21 upon approval of the Service Area Transfer?
22 A. No, the rate impact should be neutral or positive for at
23 least the next three years . As a part of the application,
24 PacifiCorp proposes to provide approximately $8 . 9
25 million in rate credits to Idaho customers, funded by
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Rocky Mountain Power

1 the gain on sale attributable to the goodwill value of
2 the Business . This rate credit assigns 68 percent of the
3 goodwill value to customers, an approach PacifiCorp is
4 proposing across all states . PacifiCorp will provide
5 this rate credit over three years, in the next general
6 rate case where the impacts of the sale are reflected in
7 rates, resulting in an annual rate credit of
8 approximately $3 . 0 million. Ms . Kobliha provides more
9 information on the calculation of the goodwill value of
10 the Business, and the proposed assignment of the
11 goodwill value to customers .
12 Q. Please explain how the cost increases and benefits
13 associated with the Service Area Transfer net to no
14 change or a net benefit.
15 A. There are various cost increases and cost savings
16 associated with the Service Area Transfer, which
17 generally net to no change or a net benefit, assuming
18 allocation changes consistent with the 2020 PacifiCorp
19 Inter-jurisdictional Cost Allocation Protocol ("2020
20 Protocol") . For purposes of analyzing and allocating the
21 costs and benefits of this transaction, PacifiCorp has
22 looked to the 2020 Protocol, as this was adopted by all
Steward, Di 15
Rocky Mountain Power

REDACTED
1 PacifiCorp states for allocating certain system costs
2 and is the basis for current rates . 9
3 The estimated impact to customer costs and benefits
4 is summarized over two periods . The first period, or
5 transition period, covers after
6 the transaction closes . In this timeframe, PacifiCorp
7 will sell energy, capacity and RECs to Gem in accordance
8 with the Bridge PPA and provide balancing authority
9 services to Gem in accordance with the BASA. For
10 simplicity, these impacts are estimated for calendar
11 year 2027 as a proxy for the annual impacts that would
12 be anticipated over the timeframe . The
13 second period, or post-transition period, covers the
14 first year after the Bridge PPA and the BASA are assumed
15 to terminate, which is estimated for
16 The impact of the Service Area Transfer is summarized
17 for both periods in Table 1 .
9 The allocations for 2030 and beyond are likely to be different due to
the need for Oregon to be out of coal resources and will be subject to
future multi-state negotiations and approvals.
Steward, Di 16
Rocky Mountain Power

REDACTED
Table 1 . Idaho-Allocated Annual Increase/ (Decrease) in
Cost to Customers ($ million)
ID-Allocated ID-Allocated Post System System Post-
Transition Period Transition Period Transition Period Transition Period
Non-Power Cost Revenue Requirement $4.2 $4.2 $65.6 $65.6
Net Power Costwith Production Tax Credits ($0.3) ($1.3) ($5.4) ($16.6)
Incremental Wheeling Revenue ($1.6) ($0.9) ($23.9) ($13.7)
Renewable Energy Credits ($0.0) ($0.3) ($0.3) ($4.9)
Resource Adequacy Value ($2.0) ($3.2) ($30.7) ($49.4)
Sub-Total(Before Annual Sale Credit) $0.2 ($1.5) $5.2 ($19.0)
Annual Sate Credit(3-year amortization) ($3.0) $0.0 ($47.0) $0.0
Total ($2.8) ($1.5) ($41.8) ($19.0)
1 As PacifiCorp witness Shelley E . McCoy explains,
2 PacifiCorp' s system costs are currently shared among six
3 states . After the Service Area Transfer these costs will
4 be shared among five states, causing an allocation
5 increase of non-power cost revenue requirement to Idaho
6 customers of approximately $4 .2 million (or $65 . 6
7 million for the remaining five-state system) .
8 ,
9 and so it does not change between the two time periods
10 summarized in Table 1 . Ms . McCoy also explains that
11 PacifiCorp will be collecting new wheeling revenues due
12 to changes in transmission service that are explained by
13 Mr. Wilding. The benefit of this incremental wheeling
14 revenue declines in the post-transition period when a
15 Walla Walla upgrade reduces the volume of wheeling that
16 Gem needs to purchase from PacifiCorp. During the
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Rocky Mountain Power

REDACTED
1 transition period, the incremental wheeling benefit
2 provides a $1 . 6 million benefit to Idaho customers (or
3 $23 . 9 million for the remaining five-state system) .
4 During the post-transition period, the incremental
5 wheeling benefit provides a $0 . 9 million benefit to
6 Idaho customers (or $13 . 7 million for the remaining
7 five-state system) .
8 As PacifiCorp witness Ramon J. Mitchell explains,
9 net power costs decline slightly during the transition
10 period
11
12 The Idaho-
13 allocated benefit from net power costs is $0 . 3 million
14 during the transition period (or $5 . 4 million for the
15 remaining five-state system) and $1 . 3 million for the
16 post-transition period (or $16 . 6 million for the
17 remaining five-state system) . Mr. Mitchell also explains
18 that the volume of RECs increases in the post-transition
19 period and this contributes an additional $0 . 3 million
20 in benefits for Idaho customers (or $4 . 9 million for the
21 remaining five-state system) .
22 As Mr. Wilding testifies, the remaining five-state
23 system experiences an increase in resource adequacy
24 capacity that totals during
25 the transition period and
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Rocky Mountain Power

1 during the post-transition period. This increase in
2 capacity for the remaining five-state system is
3 estimated to provide an Idaho-allocated benefit totaling
4 $2 . 0 million per year during the transition period (or
5 $30 . 7 million per year for the remaining five-state
6 system) . During the post-transition period, the Idaho-
7 allocated benefit increases to $3 . 2 million per year (or
8 $49 . 4 million per year for the remaining five-state
9 system) .
10 Taken all together, inclusive of the annual sale
11 credit described by Ms . Kobliha, which is proposed to be
12 applied in the next general rate case in the transition
13 period, Idaho-allocated benefits total $2 . 8 million per
14 year ($41 . 8 million for the remaining five-state system)
15 and $1 . 5 million for the post-transition period (or
16 $19 . 0 million for the remaining five-state system) .
17 Additionally, the Service Area Transfer will
18 improve PacifiCorp' s overall system load and resource
19 balance, provide PacifiCorp the ability to better invest
20 in the system, and relieve PacifiCorp from the
21 obligation to make investments in Washington that would
22 otherwise be necessary to satisfy Washington' s climate
23 laws .
Steward, Di 19
Rocky Mountain Power

1 Q. Will the Service Area Transfer improve PacifiCorp' s
2 ability to manage risk for its remaining customers?
3 A. Yes . As PacifiCorp witness Richard J. Garlish testifies,
4 a primary reason PacifiCorp plans to sell the Washington
5 service area is to help manage the risks associated with
6 operating a utility with such a substantial footprint .
7 Q. Please explain how the Service Area Transfer allows
8 PacifiCorp to better support Idaho customers and the
9 financial health of PacifiCorp.
10 A. In addition to the cash equal to the net book value of
11 the assets sold in the Service Area Transfer, less cash
12 paid for applicable income taxes, PacifiCorp will also
13 receive cash equal to the goodwill value of the Business .
14 Although PacifiCorp proposes to give approximately
15 two-thirds of the goodwill value allocated to Idaho back
16 to Idaho customers through a $9 . 0 million rate credit,
17 PacifiCorp can use the remaining goodwill value to
18 strengthen its financial profile, which benefits Idaho
19 customers through decreased future borrowing costs and
20 provides liquidity needed to operate PacifiCorp' s
21 system. Ms . Kobliha estimates that absent this
22 transaction, PacifiCorp would incur about $95 million in
23 additional annual interest expense based on current
24 credit ratings . This avoided interest expense is not
25 reflected in Table 1 .
Steward, Di 20
Rocky Mountain Power

1 Further, as discussed by Mr. Mitchell, the
2 Service Area Transfer eliminates the need for the
3 company to absorb the cost of allowances from
4 Washington' s Climate Commitment Act, which have been
5 disallowed in Idaho and other states . lo
6 V. CONCLUSION
7 Q. What is your recommendation for the Commission?
8 A. I recommend that the Commission approve the Service Area
9 Transfer, whereby Gem will also purchase select
10 Washington-based generation, transmission, and
11 distribution assets . The Commission should approve the
12 Service Area Transfer because it will not harm
13 PacifiCorp' s Idaho customers and will provide customer
14 benefits and strengthen PacifiCorp' s financial health.
15 Therefore, the Service Area Transfer is consistent with
16 the public interest .
17 Q. Does this conclude your direct testimony?
18 A. Yes .
io In the Matter of Rocky Mountain Power's Application for Approval of
$62.4 Million SCAM Deferral, Case No. PAC-E-24-05, Order No. 36207 at 11
(May 31, 2024) .
Steward, Di 21
Rocky Mountain Power