20260821Staff Comments.pdf

RECEIVED
August 21, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
ERIKA K. MELANSON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11560
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )
POWERS'S APPLICATION FOR APPROVAL ) CASE NO. PAC-E-26-11
OF THE ASSET TRANSFER AGREEMENT )
BETWEEN ROCKY MOUNTAIN POWER )
AND THE CITY OF IDAHO FALLS-2970 ) COMMENTS OF THE
PIONEER DR. ) COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
BACKGROUND
On June 25, 2026, Rocky Mountain Power, a division of PacifiCorp ("Company") applied
to the Commission requesting approval of an Asset Transfer Agreement ("Agreement") between
the Company and the City of Idaho Falls ("City") for the City to purchase certain electric facilities
currently owned and used by the Company to supply electric service to a customer.
The Service Allocation Agreement, as approved by the Commission on December 5,2017,
and updated on March 2, 2026, authorizes the transfer of a customer's electric service from one
utility to another, provided that the acquiring utility compensates the serving utility for both lost
revenues and the distribution facilities used to provide service to that customer. Application at 2-
3. Under the terms of the Agreement,the Company and the City agreed that compensation for lost
revenues would be calculated as 167%of the customer's total electric billings during the preceding
12-month service period.Id. at 3. The Agreement further requires the acquiring utility to purchase
STAFF COMMENTS I AUGUST 21, 2026

any poles, wires, crossarms, insulators, guy wires, and other facilities that are no longer necessary
for the serving utility to provide electric service to that customer. Id.
One customer has requested their electric service be transferred to the City, and the
Company notified the customer that it had entered into an Agreement to facilitate the transfer. Id.
Per the terms of the Agreement, the Company and the City agreed to transfer the customer's
electric service to the City, and the City agreed to purchase the facilities identified in Exhibit A to
the Agreement, which was submitted as Confidential Attachment No. 1 to the Application.Id.
STAFF ANALYSIS
Staff reviewed the proposed transaction and believes that it supports the intent of the
Electric Supplier Stabilization Act ("ESSA") and is consistent with prior Commission orders. In
the Application,the Company explains how this transaction complies with Idaho Code§61-328(3)
by: (a)promoting the public interest;(b)fairly compensating the Company for its transferred assets
and that rates for supplying service will not be increased for existing customers; and (c) ensuring
that the transferred customers will continue to receive electric service from a provider (the City)
that has the bona fide intent and the financial ability to properly maintain this public service for
the transferred customers. Id. Staff believes that the request is consistent with Idaho Code § 61-
332(2) because it facilitates a harmonious transfer between electric suppliers. Additionally, Staff
believes the Company has demonstrated that proposed transaction meets all the necessary statutory
requirements and complies with the Commission's previous orders. Based on its review, Staff
recommends that the Commission approve the proposed transfer.
Sales Price and Accounting Treatment
Under the Agreement,the City would provide electric service to a customer on Pioneer Dr.
(exempt from public review under Idaho Code § 74-109(3) and Idaho Public Utilities Commission
Rule of Procedure 67), currently being supplied electric service by the Company.Id. The City will
purchase the electric facilities from the Company to serve the customer and compensate the
Company for the lost revenues arising from the customer's departure. Id. The agreement defines
"just compensation for lost revenues" as "an amount equal to 167 percent of the total of the
respective customers' electric bills from the prior twelve-month period of service."Id. The total
sale price for the transaction is $5,938 as shown in Table No. 1. Agreement at 2. Staff verified that
the sale price includes the replacement book value of the existing assets, separation costs, lost
STAFF COMMENTS 2 AUGUST 21, 2026

customer revenue, and legal and transaction costs. Staff also verified that the method used to
calculate these values is consistent with the method incorporated in the 2026 Service Allocation
Agreement. The Company's accounting treatment of the proceeds received from the sale of these
assets ensures other customers will not be affected by this transaction.
Table No. 1: Calculation of Transaction Price
Sale Components Totals
Asset Valuation $ 150.00
Separation costs $ 1,712.00
Lost Customer Revenue $ 3,963.00
Legal and Transaction Costs $ 113.00
Sales Price $ 5,938.00
The price of the existing assets was calculated using the replacement value of each asset
being sold, less depreciation. Depreciation was determined using the straight-line method,
consistent with prior Commission orders. The replacement value was determined using the
Company's Retail Construction Management System. The separation costs represent the costs
associated with the physical separation of the assets being sold from the Company's distribution
system. Legal and transaction costs include accounting, finance, regulation, and legal expenses
related to the sale.
The last component of the total transaction price reviewed by Staff was lost customer
revenue. The Company calculated lost customer revenue based on customer billing revenue for
the 12-month period from September 2024 through August 2025. Agreement at 9.
CUSTOMER NOTICE AND PUBLIC COMMENTS
In accordance with Rule 125 of the Commission's Rules of Procedure (IDAPA 31.01.01),
no customer notice is required. As of August 21, 2026, no public comments have been received.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Agreement and authorize the transfer
of electric service for the customer on Pioneer Dr., Idaho Falls, Idaho, between Rocky Mountain
Power, and the City of Idaho Falls.
STAFF COMMENTS 3 AUGUST 21, 2026

Respectfully submitted this 21 st day of August 2026.
Erika K. Melanson
Deputy Attorney General
Technical Staff. Leena Gilman
I:\Utility\UMISC\COMMENTS\PAC-E-26-11 Comments.docx
STAFF COMMENTS 4 AUGUST 21, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Is' DAY OF AUGUST 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-26-11, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
Rocky Mountain Power:
JANA SABA, DIRECTOR OF REGULATION, ROCKY
MOUNTAIN POWER
JOE DALLAS, SENIOR ATTORNEY, PACIFICORP
E-MAIL: jana.saba(d),pacificorp.com
joseph.dallasgpacificorp.com
datarequest(dpacificorp.com
City of Idaho Falls:
BEAR PRAIRIE
E-MAIL: bprairie&ifpower.org
4 i'�'t�
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE