20260826Application.pdf

ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER, Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
August 26, 2026 RECEIVED
AUGUST 26, 2026
IDAHO PUBLIC
VIA ELECTRONIC FILING UTILITIES COMMISSION
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8 Suite 201A
Boise, ID 83714
Attn: Commission Secretary
RE: CASE NO. PAC-E-26-12
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
REQUESTING A PRUDENCY DETERMINATION ON DEMAND SIDE
MANAGEMENT EXPENDITURES.
Please find enclosed for filing in the above captioned matter Rocky Mountain Power's
Application requesting an order designating its demand side management expenses as prudently
incurred for 2024 and 2025 program years.
Informal questions related to this matter may be directed to me at(801) 220-4214.
Sincerely,
Michael S. Snow
Manager, Regulatory Affairs
Enclosures

Joseph M. Dallas, (ISB# 10330)
Senior Attorney
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Telephone: [phone]
Email: joseph.dallasgpacificorp.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER ) CASE NO. PAC-E-26-12
REQUESTING A PRUDENCY )
DETERMINATION ON DEMAND-SIDE ) APPLICATION
MANAGEMENT EXPENDITURES. )
COMES NOW, Rocky Mountain Power, a division of PacifiCorp (the "Company"), in
accordance with Order No. 32788 and Rules of Procedures 052 and 201, et seq., and hereby
respectfully applies to the Idaho Public Utilities Commission (the "Commission") for an order
designating Rocky Mountain Power's demand side management ("DSM") expenditures utilizing
collections from Schedule 191 for program years 2024 and 2025 in the amount of$9,867,600 as
prudently incurred("Application").
In support of this Application, Rocky Mountain Power states as follows:
1. Rocky Mountain Power is authorized to do and is doing business in the state of
Idaho as a public utility providing retail electric service to approximately 91,000 customers. Rocky
Mountain Power is a public utility subject to the jurisdiction of the Commission pursuant to Idaho
Code § 61-129.
APPLICATION OF Page 1
ROCKY MOUNTAIN POWER

2. The Company presents the 2024 and 2025 annual energy efficiency and peak
reduction reports("Annual Reports"),' results of program cost effective analyses,2 and third-party
program evaluations.3
BACKGROUND
3. The Company has offered a variety of DSM programs to its customers since the
1970s. All of the DSM programs offered by Rocky Mountain Power in Idaho have been designed
to be cost effective. On March 2, 2006, the Commission approved an enhanced set of DSM
programs and cost recovery of them through the Customer Efficiency Services Rate Adjustment
("Schedule 191"), which was applied to customers' bills beginning May 1, 2006.
4. This Application and the 2024 and 2025 Annual Reports are consistent with the
Memorandum of Understanding the Company entered into in Case No. GNR-E-12-01, approved
by Order No. 32788 ("MOU"). Pursuant to this MOU, Rocky Mountain Power filed energy
efficiency and peak reduction reports with the Commission for program years 2024 and 2025 under
Case No. PAC-E-05-10. These reports follow the format set forth in the MOU and evaluate DSM
program performance, including expenditures, savings, and cost effectiveness.
5. During 2024 and 2025, the Company's DSM portfolio, funded through Schedule
191, consisted of four energy efficiency programs and two load management programs, excluding
Irrigation Load Control. The DSM portfolio and Annual Reports also include an additional load
management program for Irrigation Load Control ("ILC"), however, the ILC program is not
funded through Schedule 191 and has accordingly been excluded from the expenditures contained
'The 2024 and 2025 Annual Reports were filed with the Commission on May 1,2025,and May 1,2026,respectively,
and are available on the Commission's website under Case No.PAC-E-05-10.
2 See Appendix A and Confidential Appendix B of the 2024 and 2025 Annual Reports.
3 Published program evaluations are available under the "Reports and Program Evaluations by State" section of the
Company's website at the following URL:hgps://www.pacificorp.com/environment/demand-side-management.html.
APPLICATION OF Page 2
ROCKY MOUNTAIN POWER

in this prudency Application. During the 2024-2025 period, the Company's DSM programs
offered incentives for a wide variety of energy efficiency measures to the Company's residential,
business and agricultural customers, as well as incentives for participating in load management
events. The Company continues to work with customers and the Commission to provide a
comprehensive suite of DSM programs that provide the greatest opportunity for participation by
all customer sectors.
6. DSM programs offered by the Company provide a wide range of services and
financial incentives to assist customers with energy efficiency projects they wish to pursue.During
the 2024-2025 period, the Company administered the following programs funded through
Schedule 191:
Energy Efficiency Programs:
• Schedule 21 —Low Income Weatherization/Low Income Education("LIW")
• Schedule 118—Residential Energy Efficiency("Wattsmart Homes")
• Schedule 140—Non-Residential Energy Efficiency("Wattsmart Business")
• Home Energy Reports ("HER") - not tariffed
Load Management Programs:
• Schedule 114—Wattsmart Battery Demand Response
• Schedule 114—Commercial and Industrial Demand Response
PROGRAM EXPENDITURES
7. The Company requests a Commission determination that the DSM expenditures
utilizing collections from Schedule 191 totaling$9,867,600,which represents$4,523,091 for 2024
and $5,344,509 for 2025, were prudent and in the public interest. The expenditures submitted in
this Application represent the activities that took place during program years 2024 and 2025
through a year-end cost true-up process and exclude the Company's Irrigation Load Control
("ILC") program expenditures given that ILC program expenditures are not recovered through
Schedule 191.
APPLICATION OF Page 3
ROCKY MOUNTAIN POWER

8. The Company reports its Schedule 191 balancing account quarterly to Commission
Staff. For added convenience, the 2024 and 2025 balancing account activity is provided in Tables
1 and 2 below.
Table 1 —2024 Schedule 191 Balancing Account Activity
Monthly Cash Basis Accrual Basis
Charge
Month Program Costs— Monthly net Rate Recovery Carrying Accumulated Accumulated
Fixed Assets Accrued Costs Balance Balance
Dec-23 $(2,355,038.65) $ 551,344.96
Jan-24 $ 401,471.95 $(2,587,590.72) $ (408,495.47) $ (9,827.00) $(2,371,889.17) $(2,053,096.28)
Feb-24 $ 422,209.53 $ (147,296.25) $ (377,360.19) $ (9,789.00) $(2,336,828.83) $(2,165,332.19)
Mar-24 $ 367,064.40 $ 7,780.39 $ (344,737.53) $ (9,690.00) $(2,324,191.96) $(2,144,914.93)
Apr-24 $ 302,045.72 $ 67,682.92 $ (328,548.30) $ (9,739.00) $(2,360,433.54) $(2,113,473.59)
May-24 $ 365,925.41 $ (103,345.00) $ (345,030.37) $ (9,792.00) $(2,349,330.50) $(2,205,715.55)
Jun-24 $ 268,002.74 $ 59,006.60 $ (619,693.51) $ (10,522.00) $(2,711,543.27) $(2,508,921.72)
Jul-24 $ 430,297.58 $ (4,621.80) $(1,000,995.07) $ (12,487.00) $(3,294,727.76) $(3,096,728.01)
Aug-24 $ 332,950.03 $ 21,121.00 $ (801,062.58) $ (14,703.00) $(3,777,543.31) $(3,558,422.56)
Sep-24 $ 498,143.55 $ 65,786.98 $ (661,740.37) $ (16,081.00) $(3,957,221.13) $(3,672,313.40)
Oct-24 $ 421,260.14 $ 6,738.77 $ (444,811.54) $ (16,537.00) $(3,997,309.53) $(3,705,663.03)
Nov-24 $ 425,588.46 $ (70,358.21) $ (404,555.91) $ (16,612.00) $(3,992,888.98) $(3,771,600.69)
Dec-24 1 $ 439,082.52 1 $ 96,320.07 1 $ (442,887.43) $ (16,645.00) $(4,013,338.89) $(3,695,730.53)
2024 Totals 1 $4,674,042.03 $(2,588,775.25) $(6,179,918.27) $(152,424.00)
Table 2—2025 Schedule 191 Balancing Account Activity
Monthly Cash Basis Accrual Basis
Accrued Costs Charge
Month Program Costs— Monthly net Rate Recovery Carrying Accumulated Accumulated
Fixed Assets Balance Balance
Dec-24 $(4,013,338.89) $(3,695,730.53)
Jan-25 $ 353,477.82 5 (14,904.50) $ (472,732.97) $ (16,971.00) $(4,149,565.04) $(3,846,861.18)
Feb-25 $ 257,491.68 $ (23,562.19) $ (467,953.93) $ (17,728.00) $(4,377,755.29) $(4,098,613.62)
Mar-25 $ 437,004.79 $ 8,246.58 $ (427,441.76) $ (18,221.00) $(4,386,413.26) $(4,099,025.01)
Apr-25 $ 379,944.60 $ 73,436.34 $ (385,994.19) $ (18,289.00) $(4,410,751.85) $(4,049,927.26)
May-25 $ 256,223.23 $ 98,403.81 $ (485,050.42) 5 (18,855.00) $(4,658,434.04) $(4,199,205.64)
Jun-25 $ 340,222.44 $ (201,038.34) $ (809,813.93) $ (20,388.00) $(5,148,413.53) $(4,890,223.47)
Jul-25 $ 530,248.53 $ (29,857.54) $(1,129,508.85) $ (22,700.00) $(5,770,373.85) $(5,542,041.33)
Aug-25 $ 433,399.50 $ 21,839.11 $ (916,422.76) $ (25,050.00) $(6,278,447.11) $(6,028,275.48)
Sep-25 $ 432,601.13 $ 74,364.52 $ (696,050.66) $ (26,709.00) $(6,568,605.64) $(6,244,069.49)
Oct-25 $ 527,989.30 $ (103,084.04) $ (488,964.27) $ (27,288.00) $(6,556,868.61) $(6,335,416.50)
Nov-25 $ 470,652.23 $ 97,979.05 $ (380,363.54) $ (27,132.00) $(6,493,711.92) $(6,174,280.76)
Dec-25 $ 939,678.98 1 $ 25,369.81 1 $ (380,969.36) $ (25,893.00) $(5,960,895.30) $(5,616,094.33)
2025 Totals $5,358,934.23 1 $ 27,192.61 $(7,041,266.64) $(265,224.00)
APPLICATION OF Page 4
ROCKY MOUNTAIN POWER

DSM SAVINGS AND COST EFFECTIVENESS
9. The annual DSM portfolio savings achieved through the Company's Schedule 191
DSM programs were 15,876 MWh in 2024 and 18,506 MWh in 2025 for energy efficiency, and
2,587 kW in 2024 and 3,746 kW in 2025 for load management, excluding ILC, measured at
generation and first-year savings.'
10. The Company examines its programs using cost-effectiveness tests, including the
PacifiCorp Total Resource Cost ("PTRC"), Total Resource Cost ("TRC"), Utility Cost Test
("UCT"), Ratepayer Impact Measure ("RIM"), and Participant Cost Test ("PCT") at the measure
category-, program-, sector-, and portfolio-levels. Pursuant to Commission Order No. 33766,
issued May 18,2017,the Company uses the UCT as the primary determinant for cost effectiveness.
However, the Low Income Weatherization program still uses the PTRC test authorized by
Commission Order No. 32788, issued April 12, 2013.
11. In 2024 and 2025, the DSM portfolio as a whole was cost effective from the UCT
perspective. Tables 3 and 4 below summarize the cost-effectiveness test results from the 2024-
2025 period. As avoided costs are considered proprietary, the cost effectiveness results for load
management programs are provided with a "pass" designation, which equates to a benefit to cost
ratio of 1.0 or better. Additional cost effectiveness details for the Company's DSM programs can
be found in Appendix A and Confidential Appendix B to the 2024 and 2025 Annual Reports.
4 Table 3 of the 2024 and 2025 Annual Reports list 16,070 MWh and 18,691 MWh, respectively, for total energy
efficiency due to the inclusion of load management savings. The load management savings have been removed from
the energy efficiency totals for this prudency application.
APPLICATION OF Page 5
ROCKY MOUNTAIN POWER

Table 3 -2024 Cost Effectiveness Results
Benefit/Cost Test
Program PTRC TRC UCT PCT RIM
EE and DR DSM Portfolio Inc.NEI 0.98 0.89 1.49 2.23 0.46
Irrigation Load Control Program Pass Pass Pass n/a Pass
Battery Control Program 20- ear NP Pass Pass Pass Pass Pass
C&I Demand Response Pass Pass Pass Pass Pass
Energy Efficiency Portfolio 0.95 0.86 1.41 2.20 0.45
Energy Efficiency Portfolio exc.LIW 0.97 0.89 1.49 2.23 0.46
Non-Residential Energy Efficiency Portfolio 1.06 0.97 1.56 2.51 0.45
Residential Energy Efficiency Portfolio inc.NEI 0.93 0.85 1.62 1.57 0.52
Residential Energy Efficiency Portfolio exc.NEI 0.89 0.81 1.62 1.57 0.52
Low Income Weatherization inc.NEI 0.49 0.47 0.13 1.48 0.09
Home Energy Reporting 6.91 6.28 6.28 n/a 0.79
Wattsmart Homes inc.NEI 0.67 0.61 1.54 1.15 0.50
Table 4-2025 Cost Effectiveness Results
�_
Program Benefit/Cost Test
PTR TRC UCT PCT RIM
EE and DR DSM Portfolio exc.NEBs 1.42 1.29 1.64 2.25 0.87
Irrigation Load Control Program Pass Pass Pass N/A Pass
Battery Control Program 20- ear NPV Pass Pass Pass N/A Pass
C&I Demand Response Pass Pass Pass N/A Pass
Energy Efficiency Portfolio 1.10 1.00 1.69 1.89 0.52
Non-Residential Energy Efficiency Portfolio 1.26 1.14 1.96 2.21 0.55
Residential Energy Efficiency Portfolio inc.NEBs 0.91 0.83 1.59 1.22 0.51
Residential Energy Efficiency Portfolio exc.NEBs 0.91 0.83 1.59 1.22 0.51
Low Income Weatherization inc.NEI 5 0.32 0.30 0.17 1.71 0.13
Home Energy Reporting 4.23 3.84 3.86 N/A 0.83
Wattsmart Homes inc.NEBs 0.69 0.63 1.27 1.00 0.44
DSM TARGETS
12. Tables 5 and 6 in the sections below provide a comparison of the Company's DSM
portfolio performance with the achievable technical potential identified in the Company's
conservation potential assessment ("CPA") and the Integrated Resource Plan ("IRP") selections
over the 2024-2025 period. Consistent with the Northwest Power and Conservation Council's
regional power plans,the Company's CPA uses acquisition ramp rates and assumes that 85 percent
of the technical potential is achievable over 20 years to account for real world constraints affecting
5 Funding for Low Income Weatherization conservation education is not considered in the program-level cost-effectiveness
testing.However,it is included in the cost effectiveness analyses for both the portfolio and residential sectors.
APPLICATION OF Page 6
ROCKY MOUNTAIN POWER

the acquisition of energy efficiency resources (the "Achievable Technical Potential"). Absent the
achievability assumption and ramp rates, all discretionary resources (those that can technically be
acquired at any time) would be available at the start of the planning period, which is unrealistic
from both a planning and acquisition standpoint. IRP savings are based on assumed typical
acquisition rates, whereas actual program performance can fluctuate from year to year based on
factors such as economic conditions and the timing of large project completions.
13. During the 2024-2025 period, as shown in Table 5, the Company achieved 22,756
MWh of energy efficiency savings in Idaho, excluding savings from HER, and 34,382 MWh
including HER. These savings numbers equate to 70 percent and 106 percent of the 32,488 MWh
selected by the IRP, respectively.
Table 5—Energy Efficiency,Achievable Technical Potential, & IRP Selections
Idaho First-Year Savings
Source of Savings MWh at generator
2024 2025 2024-2025
Total
Achievable Technical Potential 23,411 26,873 50,284
Integrated Resource Plan Selections 14,904 17,573 32,477
Energy Efficiency Results (excluding HER) 9,638 13,118 22,756
Energy Efficiency Results (including HER) 1 15,876 1 18,506 34,382
14. As shown in Table 6,the Company's maximum demand response potential was 2.6
MW in 2024 and 3.7 MW in 2025,excluding ILC.With ILC included,the maximum potential was
193.5 MW in 2024 and 185.7 MW in 2025. These results exceeded the IRP selections.
6 Achievable Technical Potential and IRP selections are from the 2023 CPA and 2023 IRP.
APPLICATION OF Page 7
ROCKY MOUNTAIN POWER

Table 6—Demand Response,Achievable Technical Potential, & IRP Selections
Idaho Cumulative Capacity
Source of Savings MW atgenerator)
2024 2025
With ILC W/Out ILC With ILC W/Out ILC
Achievable Technical Potential 171.4 1.4 179.1 9.1
Integrated Resource Plan Selections 171.4 1.4 173.6 3.6
Demand Response Results 193.5 2.6 185.7 3.7
PROGRAM EVALUATIONS
15. Evaluations are conducted using best-practice approaches and techniques including
those outlined in the National Action Plan for Energy Efficiency Program Impact Evaluation and
the California Evaluation Framework guides. The Company conducts process and/or impact
evaluations to ensure the ongoing cost effectiveness of its energy efficiency programs through
validation of energy savings and to provide information to assist in program management.
16. Process evaluations assess program delivery, from design to implementation, in
order to identify efficiencies, including identifying what worked, what did not work, constraints,
and potential improvements. Identifying opportunities for improvement is essential to making
corrections along the way.
17. Impact evaluations determine the impacts (e.g. energy and demand savings) that
directly result from a program. They also support analyses of cost effectiveness aimed at
identifying relative program costs and benefits.
18. Evaluations are based on credible and transparent methods focused on successfully
capturing the savings created by the programs. Evaluations develop retrospective estimates of
Id.
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ROCKY MOUNTAIN POWER

energy savings attributable to a program. While retrospective in nature, the information obtained
will be used to inform future potential assessments,plans, forecasts and targets.
19. Process and impact evaluations for the Wattsmart Homes 2021-2024, Wattsmart
Business 2022-2023, Home Energy Reports 2022-2023, and Low Income Weatherization 2020-
2021 programs were published during the 2024-2025 prudency timeframe and included in the 2024
and 2025 Annual Reports.g
MODIFIED PROCEDURE
20. The Company believes that consideration of the proposals contained in this
Application does not require an evidentiary proceeding and accordingly requests that this
Application be processed under Modified Procedure pursuant to RP 201-204, which allows for
consideration of these issues by written submissions rather than by an evidentiary hearing. If,
however, the Commission determines that an evidentiary proceeding is required, the Company
stands ready to provide supporting testimony.
COMMUNICATIONS AND SERVICE OF PLEADINGS
21. Communications regarding this Application should be addressed to:
Anna DeMers
Michael Snow
1407 W.North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
[phone]
Email: anna.demers&pacificorp.com
michael.snow(crpacificorp.com
Joseph Dallas
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Telephone: [phone]
Email:joseph.dallaskpacificorp.com
$See Table 16 from the 2024 and 2025 Annual Reports.
APPLICATION OF Page 9
ROCKY MOUNTAIN POWER

In addition, the Company respectfully requests that all data requests regarding this matter be
addressed to one or more of the following:
By e-mail (preferred) datarequest(&,pacificorp.com
By regular mail Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
REQUEST FOR RELIEF
22. WHEREFORE,for the reasons set forth above Rocky Mountain Power respectfully
requests that the Commission approve this Application by: (1) issuing an order authorizing that
this matter be processed by Modified Procedure; and (2) issuing a final order designating Rocky
Mountain Power's 2024 and 2025 total DSM expenditures of$9,867,600 as prudently incurred.
DATED this 26th Day of August 2026.
Respectfully submitted,
By
Joseph M. Dallas
Senior Attorney
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Telephone: [phone]
Email:joseph.dallas&pacificorp.com
APPLICATION OF Page 10
ROCKY MOUNTAIN POWER