Stipulations and Settlement

Page 1 of 2
CERTIFICATE OF SERVICE
I hereby certify that on this day, I caused to be served, via email, a true and correct copy of Settlement Stipulation in Case No. PAC-E-25-14 to the following:

Service List
Commission Staff

Jeffrey R. Loll
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. No. 8
Suite 201- A 83714
PO Box 83720
Boise, ID 83720- 0074
[e-mail]

PacifiCorp, dba Rocky Mountain Power

Jana Saba
1407 West North Temple, Suite 310
Salt Lake City, UT 84116
[e-mail]
Ajay Kumar
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
[e-mail]

Adam Lowney
McDowell Rackner Gibson, PC
419 SW 11ffi Ave., Suite 400
Portland, OR 97205
[e-mail]

Data Request Response Center
PacifiCorp
[e-mail]
Anna DeMers
315 W. 27th St.
Cheyenne, WY 82001
[e-mail]

Idaho Irrigation Pumpers Association

Eric L. Olsen
Echo Hawk & Olsen, PLLC
P.O. Box 6119
505 Pershing Ave., Suite 100
Pocatello, ID 83205
[e-mail]

Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]

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Bayer Corporation

Ethan Waltermire
P4 Production, LLC
P.O. Box 816
Soda Springs, ID 83276
[e-mail]

Thomas J. Budge
Racine Olson, PLLP
P.O. Box 1391
201 E. Center
Pocatello, ID 83207
[e-mail]

Greg Meyer
Brubaker & Associates
16690 Swingley Ridge Rd # 140
Chesterfield, MO 63017
[e-mail]

Brian C. Collins
Brubaker & Associates
16690 Swingley Ridge Rd # 140
Chesterfield, MO 63017
[e-mail]

Dated this 13th day of October, 2026.

_____________________________
Anna Mills
Coordinator, Regulatory Operations
STIPULATION 1
STIPULATION RESOLVING ALL ISSUES RELATED TO APPROVAL OF THE 2026
PACIFICORP INTER-JURISDICTIONAL ALLOCATION PROTOCOL
I. INTRODUCTION 1
This Stipulation is entered into to resolve all issues between the parties related to 2
PacifiCorp’s, d/b/a Pacific Power and Rocky Mountain Power (PacifiCorp or Company), 3
applications for approval of the 2026 PacifiCorp Inter-Jurisdictional Allocation Protocol (2026 4
Protocol) in Idaho, Oregon, Utah, and Wyoming. 5
The parties to this Stipulation (collectively referred to as the “Stipulating Parties”) are 6
PacifiCorp and: 7
For Idaho1 – Staff of the Idaho Public Utilities Commission, Idaho Irrigation Pumpers 8
Association, and Bayer Corporation;2 9
For Oregon3 – Staff of the Public Utility Commission of Oregon, the Oregon Citizens’ 10
Utility Board, Alliance of Western Energy Consumers, and Sierra Club; 11
For Utah4 – Utah Division of Public Utilities, Utah Office of Consumer Services, Utah 12
Association of Energy Users, Utah Large Customer Group, Nucor Steel-Utah a Division of Nucor 13
Corporation, Utah Clean Energy, Western Resource Advocates, and Sierra Club; and 14
For Wyoming5 – Wyoming Office of Consumer Advocate, and Wyoming Industrial 15
Energy Consumers; 16
17

1 In the Matter of the Application for Approval of the 2026 Inter-Jurisdictional Cost Allocation Protocol, Case No.
PAC-E-25-14, Application (Aug. 6, 2025).
2 Bayer Corporation is now Ruveon LLC.
3 In the Matter of PacifiCorp, d/b/a Pacific Power, Application for Approval of 2026 Inter-Jurisdictional Allocation
Protocol, Docket No. UM 2401, Application (Aug. 1, 2025).
4 Application of Rocky Mountain Power for Approval of the 2026 Inter-Jurisdictional Cost Allocation Protocol,
Docket No. 25-035-47, Application (Aug. 5, 2025).
5 In the Matter of the Application of Rocky Mountain Power for Approval of the 2026 Inter-Jurisdictional Cost
Allocation Protocol, Docket No. 20000-690-EA-25 (Record No. 17937), Application (Aug. 4, 2025).
STIPULATION 2
II. BACKGROUND 1
PacifiCorp provides retail electric service to approximately two million customers in six 2
western states, including California, Idaho, Oregon, Utah, Washington, and Wyoming. PacifiCorp 3
owns substantial generation, transmission, and distribution facilities. Augmented with wholesale 4
power purchases and long-term transmission contracts, these facilities have operated as a single 5
system on an integrated basis to provide service to all customers in a cost-effective manner. The 6
costs of these assets and services have been historically allocated under a set of terms and 7
calculations articulated in an inter-jurisdictional allocation protocol. 8
In August 2025, PacifiCorp filed requests in Idaho, Oregon, Utah, and Wyoming for 9
approval of the 2026 Protocol to replace the 2020 PacifiCorp Inter-Jurisdictional Allocation 10
Protocol (2020 Protocol). The 2020 Protocol had been approved by each of the Commissions 11
where this stipulation is being filed6 and subsequently extended for use in ratemaking through 12
December 31, 2025.7 13
The Stipulating Parties have been engaged in settlement discussions regarding PacifiCorp’s 14
cost allocation methodology. Through these discussions, the Stipulating Parties agreed to settle all 15

6 The Commissions are the Idaho Public Utilities Commission, the Public Utility Commission of Oregon, the Public
Service Commission of Utah, and the Wyoming Public Service Commission.
7 For Idaho – 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, Order No. 34640 (Apr. 22, 2020), extended in In the
Matter of Rocky Mountain Power’s Application for Approval of an Extension of the 2020 PacifiCorp Inter-
Jurisdictional Allocation Protocol, Case No. PAC-E-23-13, Order No. 35984 (Nov. 2, 2023); for Oregon – In the
Matter of PacifiCorp, dba Pacific Power, Request to Initiate an Investigation of the Multi-Jurisdictional Issues and
Approve an Inter-Jurisdictional Cost Allocation Protocol, Docket No. UM 1050, Order No. 20-024 (Jan. 23, 2020),
extended in Order No. 23-229; for Utah – Application of Rocky Mountain Power for Approval of the 2020 Inter-
Jurisdictional Cost Allocation Agreement, Docket No. 19-035-42, Order Approving 2020 Protocol (Apr. 15, 2020),
extended by Application of Rocky Mountain Power for Approval of an Extension to the 2020 Inter-Jurisdictional Cost
Allocation Agreement, Docket No. 23-035-20, Order Approving Extension of the 2020 Protocol (July 27, 2023); and
for Wyoming – In the Matter of the Application of Rocky Mountain Power for Approval of the 2020 Inter-
Jurisdictional Cost Allocation Agreement, Docket No. 20000-572-EA-19 (Record No. 15400), Order No. 36740 (Dec.
3, 2020), extended by In the Matter of the Application of Rocky Mountain Power for Authority to Extend the 2020
Inter-Jurisdictional Cost Allocation Agreement Through December 31, 2025, 20000-641-EA-23 (Record No. 17280),
Order (Feb. 6, 2024).
STIPULATION 3
remaining issues in the respective cost allocation proceedings before the Commissions. This 1
Stipulation memorializes the Stipulating Parties’ agreements. 2
III. PURPOSE 3
The purpose of this settlement is to temporarily extend certain elements of the 2020 4
Protocol for ratemaking proceedings with a rate effective date before January 1, 2029 and for any 5
rate mechanisms with true-up procedures involving costs incurred through December 31, 2028. 6
Additionally, the Stipulation allows the Stipulating Parties to develop arguments and take positions 7
on other elements of the 2020 Protocol in the individual proceedings regarding the sale of certain 8
PacifiCorp-owned Washington-based assets and PacifiCorp’s Washington service area 9
(Washington Service Area Transfer). The Washington Service Area Transfer includes the sale of 10
certain Washington-based generation (the Chehalis natural gas plant and the Marengo and 11
Goodnoe Hills wind facilities), transmission, and distribution assets to Gem Sub LLC, an affiliate 12
of Portland General Electric Company. Any cost allocation decisions related to the reallocation of 13
resources that would otherwise be unallocated if the Washington Service Area Transfer is 14
approved and the transaction closes will be made in the individual Washington Service Area 15
Transfer proceedings in Idaho, Utah, and Wyoming and will be used for ratemaking purposes 16
through December 31, 2028. Any cost allocation decisions related to the reallocation of resources 17
that would otherwise be unallocated if the Washington Service Area Transfer is approved and the 18
transaction closes will be made in the 2027 general rate case proceeding in Oregon and will be 19
used for ratemaking purposes through December 31, 2028. 20
This stipulation will allow the Stipulating Parties to proceed with a process to establish a 21
successor allocation methodology to be effective beginning January 1, 2029. The process by which 22
a successor allocation methodology will be established is included as part of this settlement 23
proposal. 24
STIPULATION 4
IV. TERMS OF AGREEMENT 1
This Stipulation resolves the issues addressed below: 2
1. The Stipulating Parties agree to the extension of portions of the 2020 Protocol for 3
all ratemaking proceedings filed by PacifiCorp on or before December 31, 2028, as provided in 4
Table 1: 5
Table 1 – Specific Treatment of Individual 2020 Protocol Sections 6
Section Name Extended/Not Extended
1 Introduction Extended with the exception of provisions
that are inconsistent with the modifications
in this table.
2 Timeframes and Effective
Periods
Extended in part consistent with the other
modifications to the subsections of section 2
in this table.
2.1 Effective Period of the 2020
Protocol
Extended and modified to extend the Interim
Period through December 31, 2028.
2.2 Post-Interim Period Not extended
3 Interim Period Allocation
Method
Extended in part consistent with the other
modifications to the subsections of section 3
in this table.
3.1 Continuing Terms of the 2017
Protocol for the Five States
Interim Period Allocation
Methodology
Extended
3.2 Modifications to the 2017
Protocol During the Interim
Period
Extended consistent with the modifications
to the subsections of section 3.2 in this table.
3.2.1 Net Power Cost Filings Extended, and applicable for all power cost
filings involving costs and revenues (power
costs, REC revenues, etc.) incurred through
December 31, 2028, even if filing is made
after December 31, 2028.
3.3.28 Embedded Cost Differential
(ECD) and Equalization
Adjustment
Extended, only for application to Oregon
3.3.3 Costs and Benefits of
Qualifying Facilities
Extended
3.3.4 Allocation of Gain or Loss
from Sale of Assets
Extended but modified as described in
Stipulation Paragraph 2.

8 Note that the 2020 Protocol inadvertently labeled these sections as 3.3.2-3.3.5 rather than 3.2.2 – 3.2.5.
STIPULATION 5
Section Name Extended/Not Extended
3.3.5 Interpretation and Governance Extended
4. Implemented issues Extended in part, consistent with the other
modifications to the subsections of section 4
in this table.
4.1 States' Decisions to Exit Coal-
Fueled Interim Period
Resources
Extended consistent with the modifications
to the subsections of section 4.1 in this table.
4.1.1-4.1.2 Allocation of Costs at Closure
and Exit Orders
Extended
4.1.3-4.1.4 Oregon Exit Dates and
Washington Exit Orders
Not extended
4.1.5 Establishment of Exit Dates
for Hayden Units 1 and 2
Extended
4.2 Reassignment of Coal-Fueled
Interim Period Resources
Extended
4.3 Decommissioning Costs Extended but modified as described in
Stipulation Paragraph 3.
4.4 Qualifying Facilities Extended consistent with the modifications
to the subsections of section 4.4 in this table.
4.4.1 Existing Qualifying Facilities
(QF) Power Purchase
Agreements (PPAs)
Extended
4.4.2 New QF PPAs Extended consistent with the modifications
to the subsections of section 4.4.2 in this
table.
4.4.2.1 Interim Period Treatment– Pre-
Nodal Pricing Model
Extended
4.4.2.2 Post-Interim Period Treatment Not extended
5 Resolved Issues - Post-Interim
Period Implementation
Not extended
6 Framework Issues Not extended
7 Allocation of Gain or Loss
from Sale of Assets
Extended but modified as described in
Stipulation Paragraph 2.
8 Interpretation and Governance Extended in part consistent with the other
modifications to the subsections of section 8
in this table.
8.1 Issues of Interpretation Extended
8.2 Workgroups Not extended
8.3 Commissioner Forum Not extended
8.4 Proposals to Change the 2020
Protocol during the Interim
Period
Extended but modified as described in
Stipulation Paragraph 4.
8.5 Replacement of the 2020
Protocol
Not extended
STIPULATION 6
Section Name Extended/Not Extended
8.6 Interdependency Among
Commission Approvals
Extended, but does not apply to pending
dockets seeking approval of the Washington
Service Area Transfer.
9 Compliance with Resource
Laws
Extended but modified as described in
Stipulation Paragraph 4.
Appendix A

Definitions Extended, to the extent necessary to interpret
the specific sections or appendices the
Stipulating Parties extend herein.
Appendix B Allocation Factors by Revenue
Requirement Components
Extended, for Columns 1-4 in Appendix B
only.
Appendix C Definitions of Allocation
Factors
Extended for all terms applicable to the
Interim Period.
Appendix D Nodal Pricing Model
Memorandum of
Understanding
Not extended9
Appendix E Coal-Fueled Interim Period
Resource Depreciation Lives
Not Extended
Appendix F Washington Inter-
Jurisdictional Allocation
Methodology
Memorandum of
Understanding
Not extended
Appendix G Special Contracts Extended
Utah Letter
Agreement
Extended with the note that the Utah Letter
Agreement does not apply to the Washington
Service Area Transfer and the provisions of
this Stipulation will apply to that proposed
transfer.
2. Washington Service Area Transfer: 1
(a) Stipulating Parties agree that the 2020 Protocol and the extension agreed to 2
in this Stipulation will not apply to any reassignment or reallocation of all or portions of any 3
generation and transmission facilities due to the Washington Service Area Transfer. Any 4
reassignment or reallocation of generation and transmission facilities due to the Washington 5
Service Area Transfer will be considered in each state separately and outside this proceeding, as 6

9 Not extending this MOU does not preclude a nodal pricing system as part of a future allocation methodology,
including nodal pricing through CAISO or other regional platform.
STIPULATION 7
stated in Stipulation Paragraph 2(b) below. This process is consistent with Section 3.1.9. of the 1
2020 Protocol, which leaves the reallocation of resources resulting from a change in load greater 2
than 5 percent to be determined on case-by-case basis by the respective Commissions. 3
(b) In Oregon, the reassignment or reallocation and rate impacts of PacifiCorp’s 4
Washington assets will be evaluated in the pending Oregon rate case.10 In Utah, Wyoming, and 5
Idaho, the reassignment or reallocation of unallocated assets (due to the sale) will be evaluated in 6
the pending Washington Service Area Transfer dockets.11 In Wyoming the rate implications of the 7
reassignment or reallocation of PacifiCorp’s Washington assets may be evaluated in the pending 8
rate case.12 In Utah and Idaho, the rate implications of the reassignment or reallocation of 9
PacifiCorp’s unallocated assets may be evaluated in the pending Washington Service Area 10
Transfer dockets with respect to potential deferrals and in subsequent rate and power cost 11
proceedings. 12
(c) PacifiCorp agrees to make a supplemental filing in the Washington Service 13
Area Transfer dockets in Utah, Wyoming, Oregon, and Idaho (the State Proceedings) that presents 14
a counterfactual analysis assuming that the unallocated costs and benefits for resources and 15
transmission subject to the Washington Service Area Transfer are not reassigned to the remaining 16
five states.13 The supplemental filing will include relevant workpapers and will be made 17

10 See In the Matter of PacifiCorp, dba Pacific Power, Request for a General Rate Revision, Docket No. UE 470,
Application (May 1, 2026).
11 For Idaho – In the Matter of the Application of PacifiCorp b/b/a Rocky Mountain Power for Approval of Sale of
Washington Service Area and Accounting Order, Case No. PAC-E-26-04, Application (Apr. 6, 2026); for Utah – In
the Matter of the Application of PacifiCorp d/b/a Rocky Mountain Power for Approval and Report of the Sale of
Washington Service Area and an Accounting Order, Docket No. 26-035-20, Application (Apr. 6, 2026); and Wyoming
– In the Matter of the Application of Rocky Mountain Power for Authority to Sell the Washington-Based Assets and
Accounting Order, Docket No. 20000-706-EA-26 (Record No. 18110), Application (Apr. 3, 2026).
12 In the Matter of the Application of Rocky Mountain Power for Authority to Increase its Retail Electric Service Rates
Overall by Approximately $70.5 Million Per Year or 8.8 Percent, to Modify Schedule 92 Insurance Cost Adjustment
Tariff, to Establish A New Schedule 96 Asset Sale Adjustment Tariff, and to Revise the Schedule 95 Energy Cost
Adjustment Mechanism, Docket No. 20000-708-ER-26 (Record No. 18134), Application (May 12, 2026).
13 In estimating revenue requirement for this counterfactual scenario, non-situs generation capacity and transmission
will be reduced to 92.6%. Situs generation that is not reduced to 92.6% includes the Black Cap and Old Mill solar
STIPULATION 8
concurrently with the filing of this settlement. PacifiCorp agrees to work with the Stipulating 1
Parties to develop a revised procedural schedule, as needed, in the State Proceedings to allow the 2
opportunity to respond to the supplemental filing. 3
(d) Nothing in this agreement limits any Stipulating Party’s ability to argue how 4
any proceeds from the sale of PacifiCorp’s assets involved in the Washington Service Area 5
Transfer should be treated in those other proceedings. 6
3. On or before June 30, 2027, PacifiCorp will file for approval in each state a 7
depreciation study which includes a contractor-assisted engineering study of decommissioning 8
costs. 9
4. Successor Allocation Methodology (SAM) Process: 10
(a) The Stipulating Parties agree to recommend that each Commission open 11
investigative or other appropriate dockets to serve as a repository for information and to provide 12
appropriate confidentiality provisions. Discovery and data sharing in those proceedings would be 13
governed by, and limited to the data and analyses identified in, Stipulation Paragraph 4(e) of this 14
agreement, unless otherwise agreed to. 15
(b) Stipulating Parties agree to provide each Commission in the appropriate 16
state periodic updates on discussions, no less frequently than every four months. 17
(c) PacifiCorp will schedule meetings monthly through 2027, beginning no 18
later than April 1, 2027, to discuss a SAM to become effective by January 1, 2029. 19
(d) Meeting participation will be open to all interested parties that participate 20
or intervene in any Commission investigative proceeding established pursuant to Section 4(a) 21
above. 22

resources, Utah Schedule 32 and 34 resources, Oregon community solar resources, and future Oregon situs proxy
resources needed to comply with Senate Bill 1547 and House Bill 2021.
STIPULATION 9
(e) The Company agrees to provide timely analysis of a reasonable number of 1
alternative allocation approaches upon request of the Stipulating Parties. In addition, PacifiCorp 2
agrees to provide the following analyses: 3
(i) By February 1, 2027, the Company agrees to provide data for the 4
system for the period of 2029 – 2038 and consistent with the 10-year forecast from the Company’s 5
2027 Draft Integrated Resource Plan (2027 Draft IRP) Preferred Portfolio, as applicable. This 6
information will be extracted from PacifiCorp’s PLEXOS model, unless noted otherwise, 7
recognizing that the PLEXOS model is not used for ratemaking purposes. The information 8
supplied should include at a minimum: 9
(a) Production Cost data for all shared (non-situs) existing and new 10
generation resources and, for new generation resources, 11
identification of any new or expanded transmission required. 12
(b) Cost data for all new or expanded transmission lines or segments. 13
(c) Forecast cost data for all existing thermal owned generation units 14
(limited to revenue requirement calculated from the most current net 15
book value (NBV) with forecast depreciation and inclusive of 16
forecast capital expenditures and operations and maintenance 17
(O&M). Revenue requirement calculated off of NBV data inclusive 18
of forecast capital will be estimated at the unit level by distributing 19
plant data proportionate to name plate capacity and will assume 20
perfect regulation (no rate case timing or lag). Data for these 21
calculations are not stored in PLEXOS, and will be pulled from 22
other systems. 23
STIPULATION 10
(d) Forecasted O&M for transmission will be provided in aggregate (not 1
on a line-by-line basis). O&M for existing transmission is not 2
included in PLEXOS and can only be provided outside of the model. 3
(e) Additional portfolio data will include: 4
(1) Market purchases and sales; 5
(2) Nameplate capacity and seasonal capacity contribution (by 6
unit); 7
(3) Energy output (by unit); 8
(4) Market Revenue (by unit), as calculated by the PLEXOS 9
model, which labels this data as Generator Pool Revenue; 10
and 11
(5) Emissions (by unit), as calculated by the PLEXOS model. 12
(f) Derived net cost, calculated using data provided under Stipulation 13
Paragraphs 4(e)(i)(a), and 4(e)(i)(c) for costs and data provided 14
under 4(e)(i)(e)(4) for revenue. The derived net cost will be 15
presented on a per megawatt-hour basis, on a per kilowatt (kW) 16
basis in which the kW is the summer capacity contribution value for 17
the resource, and on a per kW basis in which the kW represents the 18
nameplate capacity of the resource; 19
(g) Load and resource balance position by year; and 20
(h) Standard PLEXOS model results and consistent with data from 21
section 4(e)(i)(a)-(g) for the 2027 Draft Preferred Portfolio, 22
STIPULATION 11
including inputs, outputs, and workpapers for the Base MN14 case 1
and an additional sensitivity consistent with the major planning risks 2
at the time the 2027 Draft IRP Preferred Portfolio is developed. No 3
later than December 31, 2026, the Stipulating Parties will notify 4
PacifiCorp which of the sensitivities included in the 2027 Draft IRP 5
they want to use. 6
(ii) By April 1, 2027, and the commencement of the SAM working 7
group, the Company agrees to provide analysis of individual state summer and winter 8
load/capacity positions by year. This analysis shall include (a) an analysis reflecting load/capacity 9
positions that do not include any automatic reallocation of shares of resources that have been exited 10
by one or more states, are expected to be exited by one or more states, that have not historically 11
been financially supported by one or more states, or that are expected to not be financially 12
supported by one or more states in the future, (b) a separate analysis reflecting load/capacity 13
positions that includes the automatic reallocation of the shares of the resources discussed in 14
subsection (a) above, and (c) any other mix of reallocations of shares of resources that the 15
Company is proposing. Upon the provision of the analysis identified in paragraph 4(e)(ii), the 16
Company and Stipulating Parties will work to identify a discrete set of mutually agreeable 17
allocation approaches to analyze and determine a mutually agreeable timeline for developing data 18
on the agreed upon allocation approaches. The data should reflect a 10-year forecast otherwise 19
consistent with the 2027 Draft IRP Preferred Portfolio and forecasted embedded costs as identified 20
in Section 4(e)(i). 21

14 The Base MN case refers to the case with the medium gas price forecast and no assumed cost associated with
greenhouse gasses.
STIPULATION 12
(iii) Within the first six months of the commencement of the SAM 1
working group, the Company agrees to provide substantial analysis and workpapers on the 2
following topics: 3
(a) Portfolio Exposure and risk assessment during high-risk hours, 4
based on a one-year Aurora simulation of PacifiCorp’s system, 5
including: 6
(1) Exposure to market purchases; 7
(2) Resource adequacy position; and 8
(3) Differences under net power costs allocation (consistent 9
with the 2020 Protocol) and a market settlements-based 10
allocation. 11
(b) A current listing of large load requests with the amount of load 12
required (confidentially or anonymously). If possible, PacifiCorp 13
will provide how likely each large load is to happen on some type 14
of scale (e.g. 1 to 5, with 1 representing ‘not likely’ and 5 15
representing ‘definitely.’). 16
(c) State-level resource adequacy position by state, including: 17
(1) Resource adequacy program obligations; 18
(2) Coincident peak; 19
(3) Planning reserve requirements; 20
(4) Forecasted load growth; 21
(5) Capacity position by state; and 22
STIPULATION 13
(6) Accreditation assumptions including Western Resource 1
Adequacy Program accreditation, Effective Load Carrying 2
Capability, or other assumptions. 3
(d) Identification of capacity expansion drivers, including: 4
(1) Resource primarily added for state policy; 5
(2) Resource assumed to be situs assigned or dynamically 6
allocated; and 7
(3) All other resources. 8
(e) Forecast transfer capability between PacifiCorp East and PacifiCorp 9
West, including: 10
(1) PacifiCorp East-to-PacifiCorp West transfers; and 11
(2) PacifiCorp West-to-PacifiCorp East transfers. 12
5. This agreement does not resolve or address a method for evaluating or determining 13
an appropriate reallocation of resources. 14
6. No Stipulating Party, by agreeing to these factors or participating in this case, 15
concedes that the 2020 Protocol methodology is the appropriate basis for the SAM. The Stipulating 16
Parties reserve the right to propose an entirely different allocation framework in the future SAM 17
negotiations. 18
7. PacifiCorp shall file to withdraw its requests in Idaho, Oregon, Utah, and Wyoming 19
for deferred accounting treatment of allocation changes under the proposed 2026 Protocol.15 20

15 For Idaho – In the Matter of the Application of Rocky Mountain Power for an Accounting Order Relating to the
2026 Inter-Jurisdictional Allocation Protocol, Case No. PAC-E-25-23, Application (Dec. 29, 2025); for Oregon – In
the Matter of PacifiCorp d/b/a Pacific Power, Application for Deferred Accounting Order Relating to the 2026 Inter-
Jurisdictional Allocation Protocol, Docket No. UM 2425, Application (Dec. 31, 2025); for Utah – Rocky Mountain
Power’s Application for a Deferred Accounting Order Regarding the 2026 Inter-Jurisdictional Allocation Protocol,
Docket No. 25-035-69, Application (Dec. 31, 2025); for Wyoming – In the Matter of the Application of Rocky
STIPULATION 14
8. The Stipulating Parties recommend and request that the Commissions approve this 1
Stipulation. 2
9. The Stipulating Parties agree that this Stipulation is in the public interest and is 3
consistent with applicable standards in each respective state. 4
10. This Stipulation will be offered into the record as evidence by the Stipulating 5
Parties in the respective 2026 Protocol proceedings. The Stipulating Parties agree to support this 6
Stipulation in the proceeding applicable to the appropriate state, provide witnesses to sponsor this 7
Stipulation at hearing, and recommend that the Commissions issue an order adopting the 8
Stipulation. 9
11. If this Stipulation is challenged, the Stipulating Parties agree that they will continue 10
to support the Commissions’ adoption of the terms of this Stipulation applicable to the appropriate 11
state. The Stipulating Parties agree to cooperate in cross-examination and put on such a case as 12
they deem appropriate to respond fully to the issues presented applicable to the appropriate state, 13
which may include raising issues that are incorporated into the terms of this Stipulation. 14
12. The Stipulating Parties have negotiated this Stipulation as an integrated document. 15
If any Commission rejects all or any material portion of this Stipulation or imposes additional 16
material conditions in approving this Stipulation, the Stipulating Parties will meet in good faith 17
within ten days of the issuance of that order and discuss next steps. A Stipulating Party may 18
withdraw from the Stipulation after this meeting by providing written notice to the appropriate 19
Commission and to the other Stipulating Parties. 20
13. This Stipulation is not enforceable by any Stipulating Party unless and until adopted 21
by each Commission in a final order. Each Stipulating Party avers that it is signing this Stipulation 22

Mountain Power for Approval of a Deferred Accounting Order Relating to the 2026 Inter-Jurisdictional Allocation
Protocol, Docket No. 20000-699-EA-25 (Record No. 18030), Application (Dec. 31, 2025).
October 12, 2026
10/12/2026
10/9/26
STIPULATION 16
UTAH DIVISION OF PUBLIC
UTILITIES

By:
Date:
UTAH OFFICE OF CONSUMER
SERVICES

By:
Date:
UTAH ASSOCIATION OF ENERGY
USERS

By:
Date: 10/10/2026
UTAH LARGE CUSTOMER GROUP

By:
Date:
NUCOR STEEL-UTAH, A DIVISION
OF NUCOR CORPORATION

By:
Date:
UTAH CLEAN ENERGY

By:
Date:
WESTERN RESOURCE
ADVOCATES

By:
Date:

WYOMING OFFICE OF CONSUMER
ADVOCATE

By:
Date:
WYOMING INDUSTRIAL ENERGY
CONSUMERS

By:
Date:

STIPULATION 16
UTAH DIVISION OF PUBLIC
UTILITIES
By:
Date:
UTAH OFFICE OF CONSUMER
SERVICES
By:
Date:
UTAH ASSOCIATION OF ENERGY
USERS
By:
Date:
UTAH LARGE CUSTOMER GROUP
By:
Date: October 12, 2026
NUCOR STEEL-UTAH, A DIVISION
OF NUCOR CORPORATION
By:
Date:
UTAH CLEAN ENERGY
By:
Date:
WESTERN RESOURCE
ADVOCATES
By:
Date:
WYOMING OFFICE OF CONSUMER
ADVOCATE
By:
Date:
WYOMING INDUSTRIAL ENERGY
CONSUMERS
By:
Date: October 12, 2026
STIPULATION 16
UTAH DIVISION OF PUBLIC
UTILITIES
By:
Date:
UTAH OFFICE OF CONSUMER
SERVICES
By:
Date:
UTAH ASSOCIATION OF ENERGY
USERS
By:
Date:
UTAH LARGE CUSTOMER GROUP
By:
Date:
NUCOR STEEL-UTAH, A DIVISION
OF NUCOR CORPORATION
By:
Date:
UTAH CLEAN ENERGY
By:
Date:
WESTERN RESOURCE
ADVOCATES
By:
Date: October 12, 2026
WYOMING OFFICE OF CONSUMER
ADVOCATE
By:
Date:
WYOMING INDUSTRIAL ENERGY
CONSUMERS
By:
Date:
October 12, 2026
STIPULATION 16
UTAH DIVISION OF PUBLIC
UTILITIES
By:
Date:
UTAH OFFICE OF CONSUMER
SERVICES
By:
Date:
UTAH ASSOCIATION OF ENERGY
USERS
By:
Date:
UTAH LARGE CUSTOMER GROUP
By:
Date:
NUCOR STEEL-UTAH, A DIVISION
OF NUCOR CORPORATION
By:
Date:
UTAH CLEAN ENERGY
By:
Date:
WESTERN RESOURCE
ADVOCATES
By:
Date: October 12, 2026
WYOMING OFFICE OF CONSUMER
ADVOCATE
By:
Date:
WYOMING INDUSTRIAL ENERGY
CONSUMERS
By:
Date:
STIPULATION 16
UTAH DIVISION OF PUBLIC
UTILITIES

By:
Date:
UTAH OFFICE OF CONSUMER
SERVICES

By:
Date:
UTAH ASSOCIATION OF ENERGY
USERS

By:
Date:
UTAH LARGE CUSTOMER GROUP

By:
Date:
NUCOR STEEL-UTAH, A DIVISION
OF NUCOR CORPORATION

By:
Date:
UTAH CLEAN ENERGY

By:
Date:
WESTERN RESOURCE
ADVOCATES

By:
Date:

WYOMING OFFICE OF CONSUMER
ADVOCATE

By:
Date: ____October 12, 2026
WYOMING INDUSTRIAL ENERGY
CONSUMERS

By:
Date: