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HomeMy WebLinkAbout20210910PAC to Staff Executed Version 2020 Protocol Agreement.pdf EXECUTION VERSION 2020 PacifiCorp Inter-Jurisdictional Allocation Protocol EXECUTION VERSION Contents 1. Introduction ........................................................................................................................................................... 1 2. Timeframes and Effective Periods ........................................................................................................................ 5 2.1. Effective Period of the 2020 Protocol .......................................................................................................... 5 2.2. Post-Interim Period ...................................................................................................................................... 5 2.2.1. Commission Approvals for Post-Interim Period Method Obtained Prior to December 31, 2023 ............ 5 2.2.2. Commission Approval Not Granted ......................................................................................................... 5 2.2.3. Post-Interim Period Method Agreement Not Reached ............................................................................. 6 2.2.4. Early Commission Approvals of Post-Interim Period Method ................................................................ 6 2.2.5. Regulatory Filings to Implement Post-Interim Period Method ................................................................ 6 3. Interim Period Allocation Method ........................................................................................................................ 6 3.1. Continuing Terms of the 2017 Protocol for the Five States Interim Period Allocation Methodology ......... 7 3.1.1. Classification of Interim Period Resources .............................................................................................. 7 3.1.2. Allocation of Interim Period Resource Costs and Wholesale Revenues .................................................. 7 3.1.3. Re-functionalization and Allocation of Transmission Costs and Revenues ............................................. 9 3.1.4. Allocation of Distribution Costs ............................................................................................................ 10 3.1.5. Allocation of Administrative and General Costs ................................................................................... 10 3.1.6. Allocation of Special Contracts ............................................................................................................. 10 3.1.7 Miscellaneous Costs and Taxes .............................................................................................................. 10 3.1.8. State Programs Regarding Access to Alternative Electricity Suppliers ................................................. 11 3.1.9. Loss or Increase in Load ........................................................................................................................ 13 3.1.10. Commission Regulation of Interim Period Resources ....................................................................... 13 3.2. Modifications to the 2017 Protocol During the Interim Period .................................................................. 13 3.2.1. Net Power Costs Filings ........................................................................................................................ 13 3.3.2. Embedded Cost Differential (“ECD”) and Equalization Adjustment .................................................... 14 3.3.3. Costs and Benefits of Qualifying Facilities ........................................................................................... 15 3.3.4. Allocation of Gain or Loss from Sale of Assets ..................................................................................... 15 3.3.5. Interpretation and Governance ............................................................................................................... 15 4. Implemented Issues ............................................................................................................................................. 15 4.1. States' Decisions to Exit Coal-Fueled Interim Period Resources ............................................................... 16 4.1.1. Allocation of Costs at Closure ............................................................................................................... 16 4.1.2 Exit Orders ............................................................................................................................................. 17 4.1.3 Oregon Exit Dates .................................................................................................................................. 19 4.1.4. Washington Exit Orders ......................................................................................................................... 22 4.1.5. Establishment of Exit Dates for Hayden Units 1 and 2.......................................................................... 23 4.2. Reassignment of Coal-Fueled Interim Period Resources ........................................................................... 23 4.2.1 Company Proposals for Reassignment .................................................................................................. 23 4.2.2 Process and Timing ................................................................................................................................ 24 4.2.3 Effects of Commission Decisions Regarding Assignment ..................................................................... 25 EXECUTION VERSION 4.3. Decommissioning Costs ............................................................................................................................. 26 4.3.1. Process for Determining Decommissioning Cost Allocation ................................................................. 26 4.3.2. Accounting for Decommissioning Costs Reserve Balances when All States Do Not Exit a Unit ......... 28 4.3.3. Accounting for Interim and Final Retirements ...................................................................................... 29 4.3.4. Individual State Review Process ............................................................................................................ 29 4.4. Qualifying Facilities ................................................................................................................................... 29 4.4.1. Existing QF PPAs .................................................................................................................................. 30 4.4.2. New QF PPAs ........................................................................................................................................ 30 5. Resolved Issues - Post-Interim Period Implementation ...................................................................................... 32 5.1. Generation Costs ........................................................................................................................................ 32 5.1.1. Interim Period Resources Fixed Allocation ........................................................................................... 32 5.1.2. New Resources Fixed Assignment ......................................................................................................... 34 5.2. Transmission Costs .................................................................................................................................... 34 5.3. Distribution Costs ...................................................................................................................................... 35 5.4. System Overhead Costs .............................................................................................................................. 35 5.5. Administrative and General Costs .............................................................................................................. 35 5.6. Other Allocation Issues .............................................................................................................................. 35 5.7. Demand-Side Management Programs ........................................................................................................ 37 5.8. State-Specific Initiatives ............................................................................................................................ 37 6. Framework Issues ............................................................................................................................................... 38 6.1. Resource Planning and New Resource Assignment ................................................................................... 38 6.2. Net Power Costs / Nodal Pricing Model (“NPM”) .................................................................................... 39 6.3. Special Contracts ........................................................................................................................................ 40 6.4. Limited Realignment .................................................................................................................................. 40 6.5. Post-Interim Period Capital Additions – Coal-Fueled Interim Period Resources ...................................... 40 6.5.1. PacifiCorp Straw Proposal - Post-Interim Period Capital Investment Allocation Exceptions ............... 41 6.5.2. PacifiCorp Straw Proposal - Incremental Capital Investments Made Between 2024 and the Exit Date Where Exit Date is On or Before December 31, 2027 ......................................................................................... 41 6.5.3. PacifiCorp Straw Proposal - Incremental Capital Investments Made in 2024 and 2025 Where Exit Date is After 2027 ........................................................................................................................................................ 42 6.5.4. PacifiCorp Straw Proposal - Incremental Capital Investments Made Between 2026 and the Exit Date Where the Exit Date is After 2027 ....................................................................................................................... 43 7. Allocation of Gain or Loss from Sale of Assets .................................................................................................. 43 8. Interpretation and Governance ............................................................................................................................ 43 8.1. Issues of Interpretation ............................................................................................................................... 43 8.2. Workgroups ................................................................................................................................................ 44 8.2.1. Framework Issues Workgroup ............................................................................................................... 44 8.2.2. Multi-State Process Workgroup ............................................................................................................. 44 8.3. Commissioner Forum ................................................................................................................................. 44 8.4. Proposals to Change the 2020 Protocol during the Interim Period ............................................................ 44 8.5. Replacement of the 2020 Protocol ............................................................................................................. 45 8.6. Interdependency Among Commission Approvals ...................................................................................... 45 9. Compliance with Resource Laws ........................................................................................................................ 46 10. Signatures of Parties to the 2020 Protocol .......................................................................................................... 46 EXECUTION VERSION 1 1. Introduction 1 This 2020 PacifiCorp Inter-Jurisdictional Allocation Protocol Agreement (the “2020 2 Protocol” or this “Agreement”) reflects the agreement among PacifiCorp (or the “Company”), 3 certain Commission1 staff members, State regulatory agencies, customers, consumer advocates, 4 conservation organizations, and other interested parties from California, Idaho, Oregon, Utah, 5 Washington, and Wyoming (collectively referred to as the “States” or individually as a “State”) 6 who have executed this Agreement (collectively referred to as the “Parties” or individually as a 7 “Party”) on an interim allocation and assignment method and a process for determining a long-8 term replacement of existing inter-jurisdictional allocation and assignment methodologies.2 The 9 2020 Protocol is intended to: (1) supersede the 2017 PacifiCorp Inter-Jurisdictional Allocation 10 Protocol (the "2017 Protocol") for California, Idaho, Oregon, Utah, and Wyoming; and (2) modify 11 the West Control Area Inter-jurisdictional Allocation Methodology ("WCA") for Washington. 12 However, as part of the 2020 Protocol, the 2017 Protocol and the WCA allocation methodologies 13 will continue to be used, with modifications explained herein, during an Interim Period, as defined 14 below. Subject to the provisions set forth below, and with the acknowledgment that only the 15 appropriate state body charged with issuing orders to establish rates can approve its use, the Parties 16 agree that the 2020 Protocol can be used to set just and reasonable rates and agree to support its 17 use in rate filings in California, Idaho, Oregon, Utah, Washington, and Wyoming during the Interim 18 Period. The 2020 Protocol includes: 19 • The allocation and assignment policies, procedures, and methods to be used during 20 the Interim Period (i.e., January 1, 2020 through December 31, 2023, as specified 21 1 Capitalized terms in the 2020 Protocol are defined herein, in Appendix A, or in Appendix C. 2 For purposes of this Agreement, use of the terms assign, assignment, and assigned generally refer to the generation, capacity, benefits, and risks associated with certain assets and use of the terms allocate, allocated, allocation generally refer to the treatment of costs associated with certain assets. EXECUTION VERSION 2 in Section 2). The 2020 Protocol describes the way all components of PacifiCorp’s 22 regulated service, including costs, revenues, and benefits associated with 23 generation, transmission, distribution, and wholesale transactions, should be 24 allocated and assigned among the six States during the Interim Period. During the 25 Interim Period, these inter-jurisdictional allocation policies, procedures, or 26 methods, if applied by each State as stated herein for rate proceedings filed during 27 the Interim Period, can provide PacifiCorp a reasonable opportunity to recover its 28 prudently incurred cost of service. 29 • An agreement on certain issues that are intended to be implemented during the 30 Interim Period and, assuming final resolution of all outstanding issues, incorporated 31 into a Post-Interim Period Method agreement ("Implemented Issues"). 32 • A conditional agreement on certain issues intended to be implemented following 33 the Interim Period, subject to final resolution of all outstanding issues ("Resolved 34 Issues"). 35 • A process and timeframe to address and attempt to resolve all outstanding issues 36 that the Parties intend to resolve after this 2020 Protocol has been filed with the 37 Commissions and during the Interim Period ("Framework"), including the 38 implementation or resolution of issues associated with a Nodal Pricing Model, 39 Resource planning and new Resource Assignment, Limited Realignment, Special 40 Contracts, post-Interim Period capital additions on coal-fueled Interim Period 41 Resources and other items ("Framework Issues"). The future resolution of 42 Framework Issues, combined with the Implemented Issues and the Resolved Issues, 43 would result in a new allocation methodology for PacifiCorp's six States ("Post-44 EXECUTION VERSION 3 Interim Period Method"). 45 The proposed allocation of a particular expense or investment to a State under the 2020 46 Protocol is not intended to and will not prejudge the prudence of that cost or the extent to which 47 any particular cost may be reflected in rates. Nothing in the 2020 Protocol is intended to abrogate 48 any Commission’s right or obligation to: (1) determine fair, just, and reasonable rates based upon 49 applicable laws and the record established in rate proceedings conducted by that Commission; (2) 50 consider the effect of changes in laws, regulations, or circumstances on inter-jurisdictional 51 allocation policies and procedures when determining fair, just, and reasonable rates; or (3) establish 52 different allocation policies and procedures for purposes of allocating costs and revenues within 53 that State to different customers or customer classes. 54 Parties support the 2020 Protocol, but their support will not, in any manner, affect or negate 55 their right to address changed or unforeseen circumstances, including changes in laws or 56 regulations. A Party’s support of the 2020 Protocol will not bind or be used against that Party if a 57 Party concludes that the 2020 Protocol no longer produces results that are just, reasonable, or in 58 the public interest, or does not provide the Company with a reasonable opportunity to recover its 59 prudently incurred cost of service; provided, however, that in raising an objection to the 2020 60 Protocol the Parties agree to first raise any such objection by following the provisions of Section 61 8.4. 62 Support of the 2020 Protocol does not constitute an acknowledgment by any Party of the 63 validity or invalidity of any particular method, theory, or principle of regulation, cost recovery, 64 cost of service, or rate design. No Party will be deemed to have agreed that any particular method, 65 theory, or principle of regulation, Resource acquisition or Reassignment, cost recovery, cost of 66 service, or rate design employed in or implied by the 2020 Protocol is appropriate for resolving 67 EXECUTION VERSION 4 any issues other than the inter-jurisdictional allocation of PacifiCorp’s cost of service. The Parties 68 have made no effort to address or consider intra-state cost allocation issues and agree that using 69 the 2020 Protocol for inter-jurisdictional cost allocation purposes does not suggest or require 70 similar treatment be applied to intra-state cost allocations for class cost-of-service purposes for 71 any State. Parties may propose such methods of intra-state class cost-of-service allocations as they 72 deem appropriate. 73 The 2020 Protocol includes the following appendices described briefly below: 74 • Terms that are capitalized in the 2020 Protocol are defined herein, in Appendix A, 75 or in Appendix C. 76 • Appendix B includes tables identifying the allocation factor to be applied to each 77 component of PacifiCorp’s revenue requirement calculation. 78 • Appendix C includes the definition and algebraic derivation of each allocation 79 factor, along with the FERC accounts to which the allocation factor will be applied. 80 • Appendix D is a Memorandum of Understanding among the Parties supporting the 81 Company's acquisition and implementation of a Nodal Pricing Model. 82 • Appendix E includes a table reflecting Commission-approved depreciable lives in 83 effect October 1, 2019, and the Company’s proposed depreciable lives for coal-84 fueled Interim Period Resources in pending depreciation dockets as filed in 85 September 2018. 86 • Appendix F is the Washington Inter-Jurisdictional Allocation Methodology 87 Memorandum of Understanding between the Company and the Washington Parties, 88 which modifies the WCA. 89 EXECUTION VERSION 5 • Appendix G includes a description and numeric example of how Special Contracts 90 and related issues will be treated during the Interim Period. 91 2. Timeframes and Effective Periods 92 2.1. Effective Period of the 2020 Protocol 93 For the Interim Period, January 1, 2020 through December 31, 2023, subject to Section 94 2.2.4, the Parties agree to support before their respective Commissions the use of the 2020 Protocol 95 in PacifiCorp regulatory proceedings or filings, subject to exceptions for deferred amounts 96 including, but not limited to, Net Power Costs as set forth in this Agreement. The 2020 Protocol 97 includes an agreed-upon approach for cost allocations to each State that will be used by PacifiCorp 98 in proceedings or filings commenced during the Interim Period, except as provided in Section 99 2.2.5. 100 2.2. Post-Interim Period 101 2.2.1. Commission Approvals for Post-Interim Period Method Obtained 102 Prior to December 31, 2023 103 If each State’s Commission approves a Post-Interim Period Method agreement on or before 104 December 31, 2023, or in the first general rate case after the Post-Interim Period Method agreement 105 is reached,3 the Interim Period will terminate on December 31, 2023, and the Post-Interim Period 106 Method will take effect, subject to Section 2.2.2. 107 2.2.2. Commission Approval Not Granted 108 If any Commission denies PacifiCorp’s request for approval of the Post-Interim Period 109 Method agreement, PacifiCorp will propose an alternative allocation method for the Post-Interim 110 Period for consideration by all the Commissions. Parties are free to take any position regarding 111 3 The Parties understand the California and Washington Commissions will likely consider the Post-Interim Period Method in the first general rate case filed in either State after an agreement has been reached on the Post-Interim Period Method, and approval may occur after December 31, 2023. EXECUTION VERSION 6 PacifiCorp’s proposal, including proposing alternative allocation methodologies, filing a 112 complaint, or requesting an investigation of PacifiCorp’s proposal. 113 2.2.3. Post-Interim Period Method Agreement Not Reached 114 If the Company determines that it is unlikely that a Post-Interim Period Method agreement 115 will be reached before the end of the Interim Period, then the Company will propose an allocation 116 method for the Post-Interim Period for consideration by the Commissions. Parties are free to take 117 any position regarding PacifiCorp’s proposal, including proposing alternative allocation 118 methodologies, or initiating a complaint or investigation of PacifiCorp’s proposal. 119 2.2.4. Early Commission Approvals of Post-Interim Period Method 120 If a Post-Interim Period Method agreement is reached on or before December 31, 2022, 121 any Post-Interim Period Method agreement will address whether and the degree to which the 122 Company will use the Post-Interim Period Method in regulatory proceedings or filings commenced 123 after December 31, 2022. 124 2.2.5. Regulatory Filings to Implement Post-Interim Period Method 125 Any Post-Interim Period Method agreement will address whether and the degree to which 126 the Company may use the Post-Interim Period Method in regulatory proceedings or filings 127 commenced during the Interim Period while Commission approvals of the Post-Interim Period 128 Method agreement are pending but to be effective after the end of the Interim Period. 129 3. Interim Period Allocation Method 130 The 2017 Protocol expires December 31, 2019.4 The Parties representing interests in the 131 States of California, Idaho, Oregon, Utah, and Wyoming (collectively referred to as the “Five State 132 Parties” and the "Five States") agree that the methodology outlined in the 2017 Protocol being 133 4 As proposed in PacifiCorp's 2019 California general rate case filing, the 2017 Protocol does not expire in California on December 31, 2019. EXECUTION VERSION 7 used by the Company in 2019 should continue, as outlined and modified in Section 3, during the 134 Interim Period while the Parties continue to negotiate the Framework Issues necessary to develop 135 the Post-Interim Period Method. The Washington Parties agree that the methodology outlined in 136 the WCA being used in 2019 should, subject to the terms included in Appendix F, continue during 137 the Interim Period while the Parties continue to negotiate the Framework Issues necessary to 138 develop the Post-Interim Period Method. 139 For the Five States, the terms of the 2017 Protocol that will be used during the Interim 140 Period under the 2020 Protocol are provided in Section 3.1. The 2017 Protocol terms that are 141 being modified by this Agreement are provided in Section 3.2. 142 3.1. Continuing Terms of the 2017 Protocol for the Five States Interim 143 Period Allocation Methodology5 144 Items included in the Company's results of operations will be allocated on the factors set 145 forth below. The FERC account and allocation factor combinations are included in Appendix B. 146 The algebraic derivation and factor definitions are included in Appendix C. 147 3.1.1. Classification of Interim Period Resources 148 All Fixed Costs of Interim Period Resources will be classified as 75 percent Demand-149 Related and 25 percent Energy-Related. All Non-Firm Purchases and Sales will be classified as 150 100 percent Energy-Related. 151 3.1.2. Allocation of Interim Period Resource Costs and Wholesale Revenues 152 Interim Period Resources will be allocated to one of two categories for inter-jurisdictional 153 allocation purposes: State Resources or System Resources. A complete description of allocation 154 factors to be used is set forth in Appendix B. 155 5 Terminology in Section 3.1 has been modified from the language in the 2017 Protocol to maintain consistency in the use of terms within the 2020 Protocol. EXECUTION VERSION 8 There are three types of State Resources. The remaining types of Interim Period Resources 156 are System Resources, which constitute the substantial majority of PacifiCorp’s Resources. 157 Benefits and costs associated with each category and type of Interim Period Resource will be 158 assigned or allocated to States on the following basis. 159 3.1.2.1. Interim Period State Resources 160 Benefits and costs associated with the three types of State Resources will be assigned or 161 allocated as follows: 162 • Demand-Side Management (“DSM”) Programs: Costs associated with DSM 163 Programs, including Class 1 DSM Programs, will be allocated on a situs basis to 164 the State in which the investment is made. Benefits from these programs, in the 165 form of reduced consumption and contribution to Coincident Peak, will be reflected 166 in the Load-Based Dynamic Allocation Factors. 167 • Portfolio Standards: The portion of costs associated with Interim Period Resources 168 acquired to comply with a State’s Portfolio Standard adopted, either through 169 legislative enactment or by a State’s Commission, that exceed the costs PacifiCorp 170 would have otherwise incurred, will be allocated on a situs basis to the Jurisdiction 171 adopting the Portfolio Standard. 172 • State-Specific Initiatives: Costs and benefits associated with Interim Period 173 Resources acquired in accordance with a State-specific initiative will be allocated 174 and assigned on a situs basis to the State adopting the initiative. State-specific 175 initiatives include, but are not limited to, the costs and benefits of incentive 176 programs, net-metering tariffs, feed-in tariffs, capacity standard programs, solar 177 EXECUTION VERSION 9 subscription programs, electric vehicle programs, and the acquisition of renewable 178 energy certificates. 179 3.1.2.2. Interim Period System Resources 180 All Interim Period Resources that are not State Resources are System Resources and will 181 be allocated as follows: 182 • Generally, all Fixed Costs associated with System Resources and all costs incurred 183 under Wholesale Contracts will be allocated based upon the System Generation 184 (“SG”) Factor. 185 • Generally, all Variable Costs associated with System Resources will be allocated 186 based upon the System Energy (“SE”) Factor. 187 • Revenues received by PacifiCorp under Wholesale Contracts will be allocated 188 based upon the SG Factor. 189 3.1.3. Re-functionalization and Allocation of Transmission Costs and 190 Revenues 191 Before filing any request to approve a reclassification of facilities as transmission or 192 distribution with FERC, PacifiCorp will submit filings seeking review and authorization of any 193 such reclassification with the Commissions. The cost responsibility for any assets reclassified 194 under FERC policy will be assigned or allocated consistent with other assets in the relevant 195 function. 196 Costs associated with transmission assets, and firm wheeling expenses and revenues, will 197 be classified as 75 percent Demand-Related, 25 percent Energy-Related, and allocated based upon 198 the SG Factor. Non-firm wheeling expenses and revenues will be allocated based upon the SE 199 Factor. In the event that PacifiCorp joins a regional independent system operator, the allocation 200 of transmission costs and revenues may be reevaluated and revised as provided for in Section 8.4. 201 EXECUTION VERSION 10 3.1.4. Allocation of Distribution Costs 202 All distribution-related expenses and investment that can be directly allocated will be 203 directly allocated to the State where they are located. Those costs that cannot be directly allocated 204 will be allocated consistent with the factors set forth in Appendix B. 205 3.1.5. Allocation of Administrative and General Costs 206 Administrative and General Costs, General Plant costs, and Intangible Plant costs will be 207 allocated consistent with the factors set forth in Appendix B. 208 3.1.6. Allocation of Special Contracts 209 Revenues associated with Special Contracts will be included in State revenues, and loads 210 of Special Contract customers will be included in Load-Based Dynamic Allocation Factors as 211 appropriate (see Appendix G). Special Contracts may or may not include Customer Ancillary 212 Service Contract attributes. Load curtailments and buy-through arrangements will be handled as 213 appropriate (see Appendix G). 214 3.1.7 Miscellaneous Costs and Taxes 215 Miscellaneous costs described below will be allocated as follows: 216 • Generation-related dispatch costs and associated plant will be allocated on the SG 217 Factor. 218 • Miscellaneous regulatory assets and liabilities, and miscellaneous deferred debits 219 will be allocated with the appropriate allocation factor depending on the related 220 assets or underlying costs. 221 Taxes and fees will be allocated as follows: 222 • Income taxes will be calculated using the federal tax rate and PacifiCorp’s 223 combined State effective tax rate. State-specific Schedule M and deferred income 224 tax amounts will be allocated using the Company’s tax software system. Consistent 225 EXECUTION VERSION 11 with prior system allocation methods, the Washington Public Utility Tax is 226 allocated using the SO Factor in lieu of a Washington income tax. 227 • Franchise taxes, revenue related taxes, Commission assessments and fees, and 228 usage related taxes are situs or a pass through. 229 • Property taxes are system allocated based on gross plant and allocated on a Gross 230 Plant System ("GPS") Factor. 231 • Generation and fuel-related taxes will be allocated using the SG Factor. 232 • Other taxes such as payroll taxes are embedded in expenses or capital costs. 233 Balances associated with the Trojan Decommissioning will be allocated using the Trojan 234 Decommissioning ("TROJD") Factor. This will not impact State-specific treatment of this item. 235 3.1.8. State Programs Regarding Access to Alternative Electricity Suppliers 236 3.1.8.1. Treatment of Oregon Direct Access Programs 237 This Section describes treatment of loads lost to Oregon Direct Access Programs during 238 the term of the 2020 Protocol. 239 3.1.8.1.1. Customers Electing PacifiCorp’s One- and 240 Three-Year Oregon Direct Access Programs 241 Customer loads electing to be served on PacifiCorp’s one- and three-year Oregon Direct 242 Access Programs will be included in the Load-Based Dynamic Allocation Factors for all Interim 243 Period Resources, and the transition cost payments from these customers will be situs assigned 244 and allocated to Oregon. 245 3.1.8.1.2. Customers Electing PacifiCorp’s Five Year Opt-246 Out Program Under the Oregon Direct Access 247 Program 248 The treatment will be consistent with Order No. 15-060, as clarified through Order No. 15-249 067, of the Oregon Public Utility Commission in Docket UE 267, and Oregon Schedule 296, which 250 EXECUTION VERSION 12 allow Oregon Direct Access Consumers to permanently opt-out of cost-of-service rates after 251 payment of ten years of transition costs in Oregon. If an Oregon Direct Access Consumer is paying 252 transition costs during the Interim Period, the Oregon Direct Access Consumer’s load(s) will be 253 included in Load-Based Dynamic Allocation Factors, and the transition cost payments from these 254 consumers will be situs-assigned to Oregon. If any Oregon Direct Access Consumer reaches the 255 end of the 10-year period covered by the transition cost payments during the Interim Period, the 256 load(s) for that Oregon Direct Access Consumer will be excluded from Load-Based Dynamic 257 Allocation Factors. Thereafter, if an Oregon Direct Access Consumer elects to return to Oregon 258 cost-of-service rates by providing four-years notice under Schedule 296, its load will be treated as 259 new load and incorporated in PacifiCorp’s Resource planning process. 260 3.1.8.1.3. New Laws or Regulations 261 To the extent Oregon adopts new laws or regulations regarding Oregon Direct Access 262 Programs, Oregon’s treatment of loads lost to Oregon Direct Access Programs may be re-263 determined in a manner consistent with the new laws and regulations. In the event Oregon adopts 264 such new laws or regulations, the Company will inform the Commissions and the Parties of the 265 same. 266 3.1.8.2. Utah Eligible Customer Program 267 If, pursuant to Utah Code Annotated Section 54-3-32, an eligible customer in Utah transfers 268 service to a non-utility energy supplier, the Public Service Commission of Utah will make 269 determinations under Utah law as contemplated therein. The Company will inform the 270 Commissions and the Parties of the Public Service Commission of Utah’s determinations. 271 3.1.8.3. Other State Actions 272 In the event any State adopts laws or regulations governing customer access to alternative 273 electricity suppliers, the Company will inform the Commissions and the Parties of the same. 274 EXECUTION VERSION 13 3.1.9. Loss or Increase in Load 275 Any loss or increase in retail load occurring as a result of condemnation or 276 municipalization, sale or acquisition of new service territory that involves less than five percent of 277 system load, realignment of service territories, changes in economic conditions, or gain or loss of 278 large customers will be reflected in changes in the Load-Based Dynamic Allocation Factors. The 279 allocation or assignment of costs and benefits arising from merger, sale, or acquisition transaction 280 proposed by the Company involving more than five percent of system load will be considered on 281 a case-by-case basis in the course of Commission approval proceedings. 282 3.1.10. Commission Regulation of Interim Period Resources 283 PacifiCorp will plan and acquire new Interim Period Resources on a system-wide risk-284 adjusted, least-cost basis. Prudently incurred investments in Interim Period Resources will be 285 reflected in rates consistent with the laws and regulations in each State, as approved by individual 286 Commissions. 287 3.2. Modifications to the 2017 Protocol During the Interim Period 288 3.2.1. Net Power Costs Filings 289 For Net Power Costs (“NPC”) filings, Parties agree to support use of the allocation 290 methodology in place when the NPC were or will be incurred, to align the timing of the actual 291 costs incurred with the applicable allocation method for cost recovery for that period. The table 292 below summarizes the transition from the 2017 Protocol to the 2020 Protocol for NPC filings. If 293 a Post-Interim Period Method agreement is reached between the Parties, a similar table will be 294 included to summarize the transition for NPC filings from the 2020 Protocol to the subsequent 295 agreement. 296 EXECUTION VERSION 14 Allocation Methodology Used for NPC Filings Filing 2017 Protocol 2020 Protocol Notes California ECAC 2021 ECAC for the 2022 ECAC for the California ECAC 2020 ECAC for the 2021 ECAC for the 2020 TAM for the CY2019 2021 TAM for the CY2020 2020 PCAM for the 2021 PCAM for the 2020 EBA for the CY2019 2021 EBA for the CY2020 2020 ECAM for the 2021 ECAM for the Net Power Costs included in General Rate Cases GRC with rate effective date on or after January 1, general rate case. The dates included in the table are subject to change based on the California general 2. Washington will use the modified WCA allocation methodology per Appendix F of the 2020 3.3.2. Embedded Cost Differential (“ECD”) and Equalization Adjustment 297 3.3.2.1. ECD 298 The Fixed ECD will continue for Idaho through the end of the Interim Period. The 299 Dynamic ECD for Oregon will continue through the end of the Interim Period, capped at 300 $11,000,000. No ECD adjustment exists for Utah or California. 301 The Wyoming ECD will terminate December 31, 2020. Beginning January 1, 2021, for 302 purposes of the Wyoming energy cost adjustment mechanism (“ECAM”), actual ECD will be zero 303 and the true-up of the Wyoming ECD will not be subject to sharing bands in the Wyoming ECAM. 304 This treatment will continue until the ECD is removed from base rates. 305 EXECUTION VERSION 15 3.3.2.2. Equalization Adjustment 306 The Equalization Adjustment addressed in Section XIV of the 2017 Protocol will terminate 307 on December 31, 2019, and no additional Equalization Adjustment amounts will be deferred after 308 that date. The method PacifiCorp will use to collect deferred Equalization Adjustment balances 309 and any related carrying charges has been or will be addressed in appropriate State regulatory 310 proceedings. 311 3.3.3. Costs and Benefits of Qualifying Facilities 312 Costs and benefits of Qualifying Facilities will be treated consistent with the provisions 313 specified in Section 4.4. 314 3.3.4. Allocation of Gain or Loss from Sale of Assets 315 The allocation of any gain or loss from the Company’s sale of assets will be treated 316 consistent with the provisions specified in Section 7. 317 3.3.5. Interpretation and Governance 318 This Agreement will be interpreted and PacifiCorp’s Multi-State Process ("MSP") will be 319 governed by the provisions specified in Section 8. 320 4. Implemented Issues 321 The Parties agree that the following items, described later in this Section 4, will be 322 implemented and effective during the Interim Period: 323 • The process and timing for States' decisions to exit coal-fueled Interim Period 324 Resources; 325 • The process for potential Reassignment of coal-fueled Interim Period Resources 326 among States without Exit Orders; 327 • The process for the allocation of Decommissioning Costs; and 328 • The allocation and assignment of Qualifying Facility Power Purchase Agreements 329 EXECUTION VERSION 16 ("QF PPAs"). 330 These issues are more thoroughly explained below. 331 4.1. States' Decisions to Exit Coal-Fueled Interim Period Resources 332 PacifiCorp will continue to conduct operational and economic analyses in accordance with 333 applicable regulatory requirements and good utility practice to maintain reliable service on a risk-334 adjusted, least-cost basis for its customers. PacifiCorp anticipates continuing to conduct integrated 335 resource planning, at least biennially. PacifiCorp also anticipates continuing to undertake 336 depreciation studies on a five-year cycle. If these analyses affect the depreciable lives or 337 operational lives of Interim Period Resources in the future, Parties may address such effects 338 through appropriate regulatory proceedings before the Commissions. Nothing in this Agreement 339 affects PacifiCorp’s rights and obligations to make prudent decisions regarding operation of its 340 assets and system in accordance with applicable law. The Parties further agree that PacifiCorp’s 341 coal-fueled Interim Period Resource Closure dates may be informed by new information that 342 becomes available as a result of other regulatory filings or actions, including integrated resource 343 plans or State and federal energy policies. Nothing in this Agreement affects or limits any Party’s 344 ability to raise any prudence issues with regards to PacifiCorp’s decisions regarding Closure of an 345 Interim Period Resource. 346 Subject to the possible effects of Limited Realignment, the Parties agree to the following 347 procedures for the Company's coal-fueled Interim Period Resources. 348 4.1.1. Allocation of Costs at Closure 349 Upon Closure of a coal-fueled Interim Period Resource, each State that is receiving benefits 350 and is allocated costs associated with the coal-fueled Interim Period Resource at the time of 351 Closure shall continue to be allocated its share of the remaining costs of the coal-fueled Interim 352 EXECUTION VERSION 17 Period Resource in accordance with this 2020 Protocol, which may include the remaining net book 353 value and Commission-approved Decommissioning Costs. The existence of an Exit Order does 354 not change this allocation, and all States assigned benefits and allocated costs from the coal-fueled 355 Interim Period Resource at the time of Closure will be allocated actual costs. Therefore, if every 356 State is being assigned benefits and allocated costs from a coal-fueled Interim Period Resource at 357 the time of Closure, every State will be allocated, in accordance with the method set forth in this 358 Agreement, all the actual costs associated with that coal-fueled Interim Period Resource and its 359 Closure. This can occur, for example, if every State (excepting Washington as discussed in Section 360 4.1.4) issues an Exit Order with the same Exit Date for a particular coal-fueled Interim Period 361 Resource. This can also occur, for example, if PacifiCorp pursues Closure of a coal-fueled Interim 362 Period Resource prior to a State Exit Date. No Party, by virtue of this Agreement, waives its right 363 to investigate and analyze whether the Company’s decision to continue operation or continue an 364 ownership interest is prudent, regardless of the anticipated Closure dates in the tables in Section 365 4.1.3. 366 4.1.2 Exit Orders 367 The Parties, representing diverse and varied interests, have worked in good faith to create 368 a process that allows for States to pursue differing resource portfolios in the future, including 369 decisions to transition out of coal-fueled Interim Period Resources while mitigating resulting 370 effects to the Company and other States. A Commission may issue an Exit Order specifying an 371 Exit Date in a proceeding for approval of this Agreement, a depreciation docket, a rate case, or any 372 other appropriate proceeding.6 A Commission Order or other determination that a coal-fueled 373 Interim Period Resource will reach the end of its depreciable life without a specific determination 374 6 An Exit Order is not required from a Commission if a coal-fueled Interim Period Resource is not included in PacifiCorp’s rates in that State. EXECUTION VERSION 18 that the State will exit the Interim Period Resource shall not constitute an Exit Order. Provided 375 PacifiCorp secures all applicable approvals, a Company decision to close a coal-fueled Interim 376 Period Resource earlier than previously anticipated does not require the issuance of an Exit Order. 377 An Exit Order does not, by itself, result in Reassignment of shares of a coal-fueled Interim Period 378 Resource to other States or affect an Exiting State’s responsibility for its share of the then-379 remaining net book value of the Interim Period Resource that is being exited. 380 To provide the Company and States without Exit Orders time to consider the options and 381 address the potential Reassignment of the coal-fueled Interim Period Resource, as set forth in 382 Section 4.2, under this Agreement an Exit Order should provide at least four-years of notice7 from 383 the date of the Exit Order to the Exit Date. After an Exit Date, the Exiting State will no longer be 384 allocated any new costs8 and will no longer be assigned any benefits associated with that coal-385 fueled Interim Period Resource, and no other State will be allocated the Exiting State’s share of 386 costs nor receive the Exiting State’s assigned benefits associated with that coal-fueled Interim 387 Period Resource, unless the costs and benefits are accepted through a Commission Order on 388 Reassignment. Until the Exit Date, an Exiting State shall continue to be assigned the benefits of 389 that coal-fueled Interim Period Resource and shall be allocated costs associated with that coal-390 fueled Interim Period Resource in accordance with this 2020 Protocol or as determined through 391 the Framework process, which may include costs associated with any remaining net book value, 392 prudently incurred capital additions, prudently incurred Operations and Maintenance ("O&M") 393 expense, and prudently incurred or reasonably estimated Decommissioning Costs. 394 7 Subject to the provisions in Sections 4.1.3 and 4.1.4. 8 New costs are costs incurred after the Exit Date to maintain or operate the coal-fueled Interim Period Resource beyond that date. Any costs associated with the operation of a coal-fueled Interim Period Resource and incurred prior to the Exit Date that are allocated to the Exiting State as determined through the 2020 Protocol and that have not yet been collected from customers in that State are still that State's responsibility. EXECUTION VERSION 19 An Exit Order establishes the Exit Date that PacifiCorp will use to propose the allocation 395 of Decommissioning Costs, allocation of capital additions costs, and any other associated costs 396 related to the exit from a coal-fueled Interim Period Resource as outlined in the 2020 Protocol. 397 PacifiCorp will timely propose to Parties from an Exiting State a method to address the treatment 398 of these costs for ratemaking, such that costs and benefits remain matched in customer rates. 399 Following receipt of an Exit Order, the Company will file in accordance with Section 4.2 400 to allow States without Exit Orders the opportunity to evaluate the potential Reassignment of the 401 coal-fueled Interim Period Resource. For regulatory efficiency, Section 4.1.3 establishes 402 timeframes for addressing Exit Orders from coal-fueled Interim Period Resources by Oregon and 403 the potential Reassignment of those resources to other States. 404 4.1.3 Oregon Exit Dates 405 The Oregon Parties and the Company agree to recommend that the dates shown in the 406 tables in this Section 4.1.3 be used in Oregon for service and depreciable lives, and for establishing 407 Oregon's Exit Dates for all coal-fueled Interim Period Resources. 408 4.1.3.1 Coal-Fueled Interim Period Resources Not Operated by 409 PacifiCorp Subject to Common Closure Dates, Oregon 410 Exit 2023-2027 411 PacifiCorp anticipates that Cholla Unit 4, Craig Unit 1, Craig Unit 2, Colstrip Unit 3, and 412 Colstrip Unit 4 will have common Closure dates for all States. If PacifiCorp effectuates Closure 413 at Cholla Unit 4, Craig Unit 1, Craig Unit 2, Colstrip Unit 3, or Colstrip Unit 4 on or before the 414 applicable dates identified in the table below, each State will be allocated its share of the costs and 415 benefits of that coal-fueled Interim Period Resource with no transfer of cost responsibility or 416 decommissioning liability among States, in accordance with Section 4.1.1. 417 PacifiCorp and the Oregon Parties agree to recommend to the Oregon Commission that the 418 dates shown in the table below be used for establishing Oregon's Exit Dates and Oregon 419 EXECUTION VERSION 20 depreciable lives for Cholla Unit 4, Craig Unit 1, Craig Unit 2, Colstrip Unit 3, and Colstrip Unit 420 4. 421 Coal-Fueled Interim Period Resource Name Anticipated Closure Date Cholla Unit 4 January 1, 2023 Craig Unit 1 December 31, 2025 Craig Unit 2 December 31, 2026 Colstrip Unit 3 December 31, 2027 Colstrip Unit 4 December 31, 2027 PacifiCorp and the Oregon Parties agree that PacifiCorp will make best efforts to effectuate 422 Closure of the units identified above by the anticipated Closure dates, but the Company may need 423 additional time for Closure of Craig Units 1 and 2 and Colstrip Units 3 and 4 due to its joint-owner 424 agreements, and Cholla Unit 4 due to other contractual requirements. 425 If PacifiCorp has received an Exit Order from Oregon for Craig Unit 1, Craig Unit 2, 426 Colstrip Unit 3, or Colstrip Unit 4 with the same Exit Date as the date set forth in the table above 427 and PacifiCorp does not effectuate Closure by such date, Oregon may elect, at its option, to: 428 • Continue to take an allocation and assignment of the costs and benefits of such unit 429 for one additional year following the specified Exit Date; or 430 • Discontinue taking an allocation and assignment of the costs and benefits of such 431 unit as of the specified Exit Date. 432 Under either election, Oregon will continue to be subject to an allocation of actual 433 Decommissioning Costs if Closure of the unit is effectuated within such one-year period. If 434 Closure of the unit is not effectuated within such one-year period, Oregon will be allocated 435 Decommissioning Costs based on the estimates established pursuant to Section 4.3. 436 EXECUTION VERSION 21 Oregon will be allocated actual Decommissioning Costs if Closure of Cholla Unit 4 occurs 437 on or before January 1, 2023. If Cholla Unit 4 operates beyond January 1, 2023, Oregon will be 438 allocated only estimated Decommissioning Costs as of January 1, 2023. 439 4.1.3.2. Coal-Fueled Interim Period Resources Operated by 440 PacifiCorp, Oregon Exit Through 2027 441 The Oregon Parties and the Company agree to recommend to the Oregon Commission that 442 the Exit Date for each coal-fueled Interim Period Resource shown in the following table should be 443 used in Oregon for establishing Oregon's Exit Dates and Oregon depreciable lives for these coal-444 fueled Interim Period Resources, subject to the other provisions of this Section 4.1. 445 Coal-Fueled Interim Period Resource Recommended Oregon Exit Date Jim Bridger 1 December 31, 2023 Jim Bridger 2 December 31, 2025 Jim Bridger 3 December 31, 2025 Jim Bridger 4 December 31, 2025 Naughton 1 December 31, 2025 Naughton 2 December 31, 2025 Dave Johnston 1 December 31, 2027 Dave Johnston 2 December 31, 2027 Dave Johnston 3 December 31, 2027 Dave Johnston 4 December 31, 2027 Oregon Parties and the Company will strive to have Exit Orders issued on or before 446 December 15, 2020, for the coal-fueled Interim Period Resources reflected in the table above to 447 allow the Company to make filings in the other States in accordance with Section 4.2. If 448 PacifiCorp effectuates Closure for any of the units no later than the dates in the table above, then 449 the provisions of 4.1.1 will apply. 450 EXECUTION VERSION 22 4.1.3.3. Coal-Fueled Interim Period Resources, Oregon Exit 451 Date 2028 - 2029 452 The Oregon Parties and the Company agree that the recommended Exit Dates for the coal-453 fueled Interim Period Resources shown in the following table should be used in Oregon for 454 establishing Oregon's Exit Dates and Oregon depreciable lives for these coal-fueled Interim Period 455 Resources for purposes of this Agreement, subject to the other provisions of this Section 4.1. 456 Coal-Fueled Interim Period Resource Name Recommended Oregon Exit Date Hunter 1 December 31, 2029 Hunter 2 December 31, 2029 Hunter 3 December 31, 2029 Huntington 1 December 31, 2029 Huntington 2 December 31, 2029 Wyodak December 31, 2029 Oregon Parties and the Company will strive to have Exit Orders issued by the Oregon 457 Commission issued by December 31, 2023, for the coal-fueled Interim Period Resources reflected 458 in the table above to allow the Company to make the necessary filings in other States in accordance 459 with Section 4.2. If PacifiCorp effectuates Closure for any of the units no later than the dates in 460 the table above, then the provisions of 4.1.1 will apply. 461 4.1.4. Washington Exit Orders 462 The Washington Clean Energy Transformation Act ("CETA") requires coal-fueled Interim 463 Period Resources to be out of Washington rates by December 31, 2025. Section 6.4 of the 464 Framework Issues addressing Limited Realignment is intended to facilitate the removal of coal-465 fueled Interim Period Resources from Washington rates and address the Washington-allocated 466 share, per the System Generation-Fixed (“SGF”) Factor, as defined in Appendix C, of all coal-467 fueled Interim Period Resources whether or not those resources are included in Washington rates. 468 Washington Commission approval of the 2020 Protocol will constitute an Exit Order for 469 EXECUTION VERSION 23 Washington, unless modified by Reassignment or Limited Realignment, with an Exit Date of 470 December 31, 2023, for Jim Bridger Unit 1, and December 31, 2025, for Jim Bridger Units 2-4 471 and Colstrip Unit 4. PacifiCorp and the Washington Parties agree that an Exit Order is not required 472 from the Washington Utilities and Transportation Commission for any coal-fueled Interim Period 473 Resources not currently in Washington rates, and PacifiCorp can evaluate seeking Reassignment 474 upon approval of the 2020 Protocol by the Washington Commission. 475 4.1.5. Establishment of Exit Dates for Hayden Units 1 and 2 476 On or before February 1, 2021, the Company will make State-specific recommendations 477 to Commissions for the treatment of Hayden Units 1 and 2. If PacifiCorp effectuates Closure for 478 Hayden Units 1 and 2, then the provisions of 4.1.1 will apply, subject to applicable legal 479 requirements. 480 4.2. Reassignment of Coal-Fueled Interim Period Resources 481 4.2.1 Company Proposals for Reassignment 482 After receipt of any Exit Order, PacifiCorp shall analyze whether it is reasonable to 483 continue to operate the affected coal-fueled Interim Period Resource for customers in one or more 484 of the States without Exit Orders. PacifiCorp may propose Reassignment of a greater share of the 485 coal-fueled Interim Period Resource to such State(s) to match State load and resource balance, or 486 request issuance of an Exit Order.9 PacifiCorp shall provide its analysis to Parties in each 487 applicable State and may make a filing with the Commission in each State that, as yet, has not 488 entered an Exit Order for such coal-fueled Interim Period Resource consistent with the timeframes 489 set forth in Sections 4.1 and this Section. If PacifiCorp seeks Reassignment, the analysis shall be 490 accompanied by recommendations as to an anticipated Closure date if Reassignment is accepted 491 9 Provided PacifiCorp secures all applicable approvals, PacifiCorp may effectuate Closure of a Resource without requesting issuance of any Exit Order. EXECUTION VERSION 24 for such coal-fueled Interim Period Resource. Recommended Reassignments, if proposed, should 492 include a range of options, including fallback options based on the potential that one Commission 493 may reject PacifiCorp's recommendation while another Commission may accept the primary 494 recommendation. Notwithstanding this Section 4.2.1, realignment of certain Interim Period 495 Resources serving Washington will be determined subject to resolution of the Limited Realignment 496 Framework Issue or Section 4.1.4 as applicable. 497 4.2.2 Process and Timing 498 Consistent with Section 4.1, for those coal-fueled Interim Period Resources, with an Exit 499 Date on or before December 31, 2027, the filings including the Company's analysis and 500 recommendations are targeted to occur by February 1, 2021. For those coal-fueled Interim Period 501 Resources with an Exit Date after December 31, 2027, and on or before December 31, 2029, the 502 filings including the Company's analysis and recommendations are targeted to occur by June 30, 503 2024, for Exit Orders that are received by December 31, 2023. Where possible, PacifiCorp will 504 make such filings concurrently in each State without an Exit Order so that each unit or plant can 505 be analyzed as a whole. To the extent a delay to these targeted filing dates is necessary, the 506 Company will provide notice to the Parties and Commissions explaining the reason and expected 507 filing dates. For coal-fueled Interim Period Resources with Exit Orders with different Exit Dates, 508 the Company will provide its analysis to the States without Exit Orders within six months after the 509 date any Exit Order is issued by any Commission, subject to the provisions of Section 4.1.4 for the 510 Washington Exit Orders. 511 If PacifiCorp makes filings pursuant to this Section in multiple States without Exit Orders, 512 then within 60 days from the date the last Commission issues an order pertaining to such filings, 513 PacifiCorp will submit a supplemental filing with each Commission in the State(s) without Exit 514 EXECUTION VERSION 25 Orders summarizing the decisions made by each Commission and PacifiCorp’s recommendations 515 regarding the implications. 516 4.2.3 Effects of Commission Decisions Regarding Assignment 517 If one or more Commissions have entered orders accepting, collectively, one-hundred 518 percent10 of the cost allocation of a coal-fueled Interim Period Resource beyond any Exit Date, the 519 costs and benefits of the coal-fueled Interim Period Resource after such Exit Date shall be 520 Reassigned to the States in accordance with the approved Reassignment as specified in the 521 applicable Commission Orders. Supplemental filings will reflect the final Reassignment of each 522 coal-fueled Interim Period Resource as a result of the Reassignment process and Commission 523 Orders. 524 If two or more Commissions have entered orders requesting, collectively, more than one-525 hundred percent11 of the cost allocation and associated benefits of a coal-fueled Interim Period 526 Resource beyond any Exit Date, the Company will recommend a pro-rata Reassignment up to one 527 hundred percent in accordance with the approved Reassignment as specified in the applicable 528 Commission Orders. Supplemental filings will reflect this pro-rata treatment of each coal-fueled 529 Interim Period Resource as a result of the pro-rata Reassignment process for further review and 530 approval by the Commissions. 531 If Commissions do not agree to accept one-hundred percent cost allocation, collectively, of 532 a coal-fueled Interim Period Resource beyond an Exit Date, as part of its supplemental filings, the 533 Company will provide its recommendations on the treatment of any shortfall in the Reassignment 534 10 Based on PacifiCorp’s ownership interest in the coal-fueled Interim Resource, whether wholly-owned or jointly-owned. 11 Based on PacifiCorp’s ownership interest in the coal-fueled Interim Resource, whether wholly-owned or jointly- owned. EXECUTION VERSION 26 of a coal-fueled Interim Period Resource or recommendations on capacity reductions through 535 Closures for further Commission consideration. 536 In the event of either common Exit Dates for all States or Closure as a result of the 537 Reassignment process or other appropriate regulatory proceedings, the provisions of Section 4.1.1 538 will apply. 539 4.3. Decommissioning Costs 540 4.3.1. Process for Determining Decommissioning Cost Allocation 541 4.3.1.1. Decommissioning Studies 542 The Company intends to undertake a contractor-assisted engineering study of 543 decommissioning costs and to make best efforts to complete the study by January 15, 2020, to 544 estimate appropriate Decommissioning Cost reserve requirements for the Jim Bridger, Dave 545 Johnston, Hunter, Huntington, Naughton, Wyodak, and Hayden coal-fueled Interim Period 546 Resources. Colstrip will also be included in the contractor-assisted engineering study of 547 decommissioning costs, and the Company will make best efforts to complete that portion of the 548 study by March 15, 2020. The Company will provide the information from the study to the States 549 as a supplemental filing in all applicable depreciation dockets. The study results will be used to 550 inform the Company’s recommendation on the amount of Decommissioning Cost responsibility 551 to be allocated to States for coal-fueled Interim Period Resources that States exit at different times. 552 The Company will retain and make available the Decommissioning Studies in future regulatory 553 proceedings. 554 4.3.1.2. Decommissioning Studies Update 555 The Company intends to undertake the same process to complete an update to the 556 Decommissioning Studies by no later than June 30, 2024, to estimate appropriate 557 Decommissioning Cost reserve requirements for the Craig, Hunter, Huntington, and Wyodak coal-558 EXECUTION VERSION 27 fueled Interim Period Resources (collectively with the studies discussed in the paragraph above 559 constituting the Decommissioning Studies), which will be incorporated into a Company-sponsored 560 depreciation study. The Company will retain and make available the Decommissioning Studies 561 update in future regulatory proceedings. 562 4.3.1.3. Commission Determination of Decommissioning Costs 563 No Party will be bound by the Decommissioning Cost estimates in the Decommissioning 564 Studies undertaken pursuant to Paragraphs 4.3.1.1 and 4.3.1.2, and final determination of each 565 State’s just and reasonable Decommissioning Cost allocation for each coal-fueled Interim Period 566 Resource will remain exclusively with each Commission and will be determined in the 567 depreciation dockets in which the Decommissioning Costs are included.12 568 4.3.1.4. Decommissioning Costs Allocation 569 For coal-fueled Interim Period Resources having a common operating life across all States, 570 each State shall be allocated its share of actual Decommissioning Costs based on either an SG 571 Factor (if closed during the Interim Period) or an Assigned Production ("AP") Factor, adjusted for 572 any Reassignment or Limited Realignment effects (if closed after the Interim Period). For coal-573 fueled Interim Period Resources that do not have a common operating life across all States, each 574 Exiting State shall be allocated, using either an SG Factor (if closed during the Interim Period) or 575 an AP Factor, adjusted for any Reassignment or Limited Realignment effects (if closed after the 576 Interim Period), that State’s share of estimated Decommissioning Costs based on the 577 Decommissioning Studies described in Sections 4.3.1.1 and 4.3.1.2. If the Decommissioning 578 Costs ordered to be included in the reserve balance established for an Exiting State are less than 579 the estimated Decommissioning Costs allocated to that Exiting State as specified above, such 580 12 For California, Decommissioning Costs will be addressed in PacifiCorp’s next general rate case. EXECUTION VERSION 28 difference shall not be allocated to any other State under any circumstance. If PacifiCorp 581 effectuates Closure of a coal-fueled Interim Period Resource after one or more States have exited 582 from the Resource, the Company may, with the burden of proof and subject to PacifiCorp 583 supporting its proposal in testimony,13 propose to allocate to and collect from each State that is 584 participating in that Resource at the time of Closure that State’s share, based on either an SG Factor 585 (if closed during the Interim Period) or an AP Factor, adjusted for any Reassignment or Limited 586 Realignment effects (if closed after the Interim Period), of actual Decommissioning Costs less the 587 regulatory liabilities for Exiting States including interest as described in Section 4.3.2 and less any 588 difference between the reserve balance established for each Exiting State and the estimated costs 589 allocated to each Exiting State as described above. Parties in such State(s) may take any position 590 regarding a Company request to recover Decommissioning Costs. 591 4.3.2. Accounting for Decommissioning Costs Reserve Balances when All 592 States Do Not Exit a Unit 593 After an Exit Date by some but not all States, the estimated Decommissioning Costs 594 reserves allocated to the Exiting State(s) associated with a coal-fueled Interim Period Resource 595 unit, from which that State is exiting, will be accounted for as a regulatory liability that is excluded 596 from rate base. Interest will be accrued on that regulatory liability at the Company’s then-597 authorized weighted average cost of capital14 for each State that continues to participate in that 598 coal-fueled Interim Period Resource after an Exit Date until the decommissioning work on that 599 unit is completed. 600 13 PacifiCorp’s testimony will identify and explain the variances between estimated and actual Decommissioning Costs. 14 Not to exceed the maximum carrying charge allowed by applicable law or Commission Order. EXECUTION VERSION 29 4.3.3. Accounting for Interim and Final Retirements 601 Before any State exits a coal-fueled Interim Period Resource, but no later than December 602 31, 2021, the Company shall propose to the Parties a process for separately accounting for removal 603 costs associated with interim retirements and final Decommissioning Costs in its accounting 604 system. Each State may determine the regulatory treatment for such removal costs in appropriate 605 proceedings. 606 4.3.4. Individual State Review Process 607 Any Party, at its discretion and cost, may pursue actions it deems necessary or appropriate 608 to review and evaluate the Decommissioning Studies or Decommissioning Costs and may take any 609 positions based on its review and findings. If a Commission issues an order identifying an 610 independent evaluator for the Decommission Studies, and the Commission Order provides for the 611 deferral and later recovery in rates of the cost of the independent evaluator, the Company agrees 612 to initially pay for this independent evaluation. 613 4.4. Qualifying Facilities 614 The allocation of QF PPAs shall be treated in accordance with Sections 4.4.1 and 4.4.2 of 615 this 2020 Protocol, superseding Section (IV)(A)(3) of the 2017 Protocol. For Washington, QF 616 PPAs will be assigned and allocated consistent with the terms of Appendix F during the Interim 617 Period. Other than addressing the allocation of the costs and assignment of benefits of QF PPAs 618 among the States, this 2020 Protocol does not restrict or affect any Commission's jurisdiction over 619 any agreement or interaction between QFs and the Company. QF PPAs shall be treated in the 620 following manner for allocation and assignment purposes. 621 EXECUTION VERSION 30 4.4.1. Existing QF PPAs 622 QF PPAs fully executed15 or as to which a legally enforceable obligation exists16 on or 623 before December 31, 2019 ("Existing QF PPAs") will remain system assigned and allocated, 624 subject to any Limited Realignment in Section 6.4, until the end of 2029, after which time they 625 will be situs assigned and allocated to the State having jurisdiction over the QF PPA for avoided 626 cost pricing (“State of Origin”). 627 4.4.1.1. Wyoming QF Adjustment 628 The Company agrees to include: (1) a $5 million adjustment, annually, to reduce Net Power 629 Costs in Wyoming customer rates17 beginning January 1, 2021, until December 31, 2022; and (2) 630 a $7.175 million adjustment, annually, to reduce Net Power Costs in Wyoming customer rates from 631 January 1, 2023, until December 31, 2029.18 This adjustment will terminate on or before 632 December 31, 2029, or upon issuance of any order by the Wyoming Commission that changes 633 Wyoming’s treatment of the Implemented Issues or the Resolved Issues from the terms of the 2020 634 Protocol. The adjustment shall be made solely at the Company’s expense and not allocated to any 635 other States. 636 4.4.2. New QF PPAs 637 QF PPAs fully executed or as to which a legally enforceable obligation exists after 638 December 31, 2019, (“New QF PPAs”) will be situs assigned and allocated for ratemaking 639 proceedings pertaining to periods beginning on or after January 1, 2020, to the State of Origin. 640 15 Fully executed means executed and delivered by each party to the other party. 16 Any such legally enforceable obligation date must be confirmed by an order from the applicable Commission issued prior to the end of the Interim Period. 17 The Wyoming QF adjustment will be included in the base ECAM costs forecasted in a general rate case with rates effective on or after January 1, 2021. The Wyoming QF adjustment will be trued up in the ECAM at 100% (sharing-bands do not apply). 18 The Wyoming QF adjustment shall be removed from base ECAM costs on December 31, 2029, or as otherwise specified in Section 4.4.1.1, so that no adjustment flows through to customers in rates after that date unless it was deferred in the ECAM prior to December 31, 2029. EXECUTION VERSION 31 4.4.2.1. Interim Period Treatment – Pre-Nodal Pricing Model 641 For the Interim Period, the energy output of New QF PPAs will be dynamically allocated 642 per this agreement using the SG Factor, priced at a forecasted reasonable energy price defined 643 below, and any cost of a New QF PPA above the forecasted reasonable energy price will be situs 644 assigned and allocated to the State of Origin. The forecasted reasonable energy price is a single 645 blended market price derived from the Company's Official Forward Price Curve ("OFPC"), scaled 646 for hourly prices, that was used for setting QF pricing for the New QF PPA. The single blended 647 market price is calculated by applying the appropriate weighting to the hourly scaled prices from 648 the OFPC for each market hub. The weightings per market hub are identified in the table below. 649 The weighting will be applied by month and by heavy load hours (“HLH”) and light load hours 650 (“LLH”). The forecasted reasonable energy price, used for allocation purposes, shall be 651 established at the time a QF PPA is fully executed. 652 4.4.2.2. Post-Interim Period Treatment 653 After the conclusion of the Interim Period, assuming resolution and Commission approval 654 of all Framework Issues, the Parties agree that New QF PPAs will be situs assigned and the costs 655 Market Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec COB 0.00% 0.55% 1.34% 0.82% 3.45% 4.01% 8.41% 3.69% 8.58% 0.97% 1.79% 1.20% Mid Columbia 24.42% 30.21% 55.74% 63.22% 70.84% 87.39% 81.05% 83.85% 75.88% 42.27% 34.30% 40.74% Palo Verde 1.52% 2.53% 1.07% 0.66% 0.54% 0.03% 0.76% 1.89% 1.85% 2.55% 3.45% 0.30% Four Corners 64.72% 58.68% 35.94% 27.40% 16.15% 5.75% 4.12% 2.17% 3.82% 45.79% 52.88% 44.47% Mead 0.18% 0.13% 1.23% 1.46% 1.52% 1.74% 1.95% 3.30% 6.64% 0.33% 0.12% 0.57% Mona 9.16% 7.90% 2.94% 2.03% 1.79% 0.74% 0.01% 0.18% 1.82% 7.82% 7.46% 2.18% NOB 0.00% 0.00% 1.75% 4.40% 5.72% 0.33% 3.70% 4.92% 1.41% 0.27% 0.00% 10.54% Total 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% Market Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec COB 0.00% 0.99% 5.17% 3.53% 15.50% 15.16% 5.97% 1.21% 0.31% 2.43% 3.44% 1.16% Mid Columbia 58.74% 60.10% 76.58% 66.36% 71.82% 80.41% 85.52% 92.26% 83.27% 62.78% 66.30% 59.09% Palo Verde 0.00% 1.12% 0.42% 0.04% 0.39% 0.40% 2.71% 3.04% 0.00% 0.92% 1.91% 2.30% Four Corners 33.45% 34.66% 13.63% 26.49% 10.44% 3.30% 5.35% 2.39% 11.60% 27.69% 26.36% 29.65% Mead 0.00% 0.06% 0.94% 0.44% 0.93% 0.47% 0.25% 0.00% 0.00% 0.57% 0.00% 0.00% Mona 7.81% 3.07% 1.54% 2.41% 0.92% 0.27% 0.00% 1.11% 4.82% 5.61% 1.99% 7.80% NOB 0.00% 0.00% 1.71% 0.73% 0.00% 0.00% 0.20% 0.00% 0.00% 0.00% 0.00% 0.00% Total 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% Market Hub Weighting by Month - LLH Market Hub Weighting by Month - HLH EXECUTION VERSION 32 and benefits will be allocated and assigned per the methodology developed through the Framework 656 process in Section 6.2. 657 5. Resolved Issues - Post-Interim Period Implementation 658 The Parties agree, conditioned upon reaching agreement on a Post-Interim Period Method 659 on the future allocation treatment described in this Section 5 for certain benefits, revenues, costs, 660 and investments. As stated in Section 2, these Resolved Issues of the 2020 Protocol are intended 661 to take effect with the implementation of the Post-Interim Period Method. Parties acknowledge 662 that conditions may change materially in unforeseen ways during the Interim Period and that it 663 may be necessary to re-evaluate Resolved Issues as part of the Post-Interim Period Method. The 664 Resolved Issues are identified below. 665 5.1. Generation Costs 666 Following the Interim Period, a fixed share of the Interim Period Resources will be 667 assigned to serve load in each State. The costs and benefits, including environmental attributes, 668 associated with each Interim Period Resource will be allocated and assigned in accordance with 669 the Interim Period Resources fixed allocation provisions (Section 5.1.1), Reassignment of coal-670 fueled Interim Period Resources (Section 4.2), and Limited Realignment (Section 6.4). 671 5.1.1. Interim Period Resources Fixed Allocation 672 Interim Period Resources will be assigned and allocated to States based on the SGF Factor 673 for each State as defined in Appendix C. The load information used to determine the SGF Factor 674 is subject to modification for the inclusion or exclusion of Special Contract loads as determined 675 through the Framework process for resolution of issues addressed in Section 6.3. The SGF Factor 676 is used to develop the AP Factor for each unit. Additionally, Interim Period Resources will be 677 subject to the Limited Realignment as outlined in Section 6.4 and the Reassignment of Interim 678 EXECUTION VERSION 33 Period Resources as outlined in Section 4.2. Any such Assignment of Interim Period Resources, 679 along with the Limited Realignment and the Reassignment of Interim Period Resources, will be 680 subject to the following: 681 • Accumulated depreciation for Interim Period Resources will be allocated per the 682 AP Factor. State-specific accumulated depreciation that has been tracked by the 683 Company due to increased depreciation expenses will be treated as situs to the State 684 and offset its Resource costs until that State exits from an Interim Period Resource. 685 • Accumulated deferred income taxes and excess deferred income taxes will be 686 allocated per the Company's tax software system, using the AP Factor. State-687 specific accumulated deferred income taxes and excess deferred income taxes that 688 have been tracked by the Company due to increased depreciation expense will be 689 treated as situs to the State and offset that State’s Resource costs until that State 690 exits from an Interim Period Resource. 691 • All O&M expenses that are associated with a specific Interim Period Resource will 692 be allocated per the AP Factor. 693 • All generation-related O&M expenses that cannot be allocated to a specific Interim 694 Period Resource through an AP Factor, such as general office generation 695 management expenses, will be allocated to States based on an Assigned Production 696 Operations and Maintenance (“APOM”) Factor, calculated as each States' relative 697 share of direct-allocated generation O&M expenses. There will be three separate 698 APOM factors based on FERC classifications, with the APOMS used for steam 699 generation (FERC accounts 500 - 514), APOMH used for hydro generation (FERC 700 accounts 535-545) and APOMO used for other generation (FERC accounts 546 - 701 EXECUTION VERSION 34 554). The APOM factor calculations are shown in Appendix C and also included 702 in Appendix B, Column 5. 703 • Property tax will continue to be allocated based on gross plant using the GPS Factor 704 as calculated in Appendix C and included in Appendix B, Column 5. 705 • All other rate-base items associated with Interim Period Resources will be allocated 706 consistent with the Interim Period Resource allocations using the AP Factor. 707 5.1.2. New Resources Fixed Assignment 708 New Resources include any Resources that are not in commercial operation before the end 709 of the Interim Period. All costs and benefits associated with new Resources, subject to the 710 qualification below, will be allocated and assigned to States based on a fixed assignment under the 711 process to be determined in Section 6.1 – Resource Planning and New Resource Assignment. The 712 Parties agree that a transitional period is necessary to change the cost allocation for future new 713 Resources that are planned for by the Company, and that any new Resource reaching commercial 714 operation before the end of the Interim Period will be treated the same as Interim Period Resources 715 for allocation purposes under the terms of this Agreement. 716 5.2. Transmission Costs 717 The costs associated with transmission assets, except as addressed in Section 6.1, will be 718 dynamically allocated among States on the System Transmission (“ST”) Factor, generally 719 calculated based on a classification of costs as 75 percent Demand-Related and 25 percent Energy-720 Related, and based on twelve monthly Coincident Peaks, using weather-normalized retail peak and 721 energy data, as more thoroughly defined in Appendix C. 722 All revenues recovered through PacifiCorp's Open Access Transmission Tariff or other 723 transmission rate schedules approved by the FERC will be allocated based on the ST Factor. 724 EXECUTION VERSION 35 The 2020 Protocol does not preclude PacifiCorp from participating in any independent 725 transmission organization, regional transmission organization, or other similar wholesale 726 transmission market subject to the jurisdiction and oversight of the FERC. 727 5.3. Distribution Costs 728 All distribution-related expenses and capital costs that can be directly allocated will be 729 directly allocated to the States where the related distribution facilities are located. Those 730 distribution expenses that cannot be directly allocated will be allocated among States on a System 731 Net Plant Distribution ("SNPD") factor, as shown in Appendix B. 732 5.4. System Overhead Costs 733 Costs that support more than one function, such as generation, transmission, or distribution 734 plant, will continue to be allocated on the System Overhead (“SO”) Factor after the Interim Period 735 but will be calculated based on an equal one-third weighting of the System Capacity (“SC”) Factor, 736 System Energy Factor, and System Gross Plant Distribution (“SGPD”) Factor, as shown in 737 Appendix B. 738 5.5. Administrative and General Costs 739 Administrative and General Costs, General Plant costs, and Intangible Plant costs, both 740 expenses and investments, which can be directly allocated will be directly allocated to the 741 appropriate State(s). Those costs that cannot be directly allocated will be allocated among States 742 consistent with the factors set forth in Appendix B. 743 5.6. Other Allocation Issues 744 Items included in the Company's results of operations, other than those that are specifically 745 called out herein, will continue to be allocated on the same factors used in the 2017 Protocol. The 746 EXECUTION VERSION 36 FERC account and allocation factor combinations are included in Appendix B. The algebraic 747 derivation and factor definitions are included in Appendix C. 748 The following miscellaneous changes will be made to be consistent with the other 749 allocation changes: 750 • Communication equipment allocated on the System Generation Factor during the 751 Interim Period will change to either the SE Factor (generation-related) or ST Factor 752 (transmission-related) depending on the nature of the equipment for which the 753 communication equipment is utilized. 754 • Contributions In Aid of Construction (“CIAC”) currently allocated on the SG 755 Factor will change to either the AP factor for generation-related CIAC or the ST 756 Factor for transmission related CIAC. 757 • Generation-related dispatch costs and associated plant will be allocated on the SE 758 Factor. 759 • Miscellaneous regulatory assets and liabilities, and miscellaneous deferred debits 760 will be allocated with the appropriate allocation factor depending on the related 761 assets or underlying costs. Miscellaneous regulatory assets and liabilities, and 762 miscellaneous deferred debits currently allocated on the SG Factor, will change to 763 the AP Factor for generation-related and ST Factor for transmission-related items. 764 Taxes and fees will be allocated as follows: 765 • Income taxes will be calculated using the federal tax rate and PacifiCorp’s 766 combined State effective tax rate. State specific Schedule M and deferred income 767 tax amounts will be allocated using the Company’s tax software system. Consistent 768 EXECUTION VERSION 37 with prior system allocation methods, the Washington Public Utility Tax is 769 allocated using the SO Factor in lieu of a Washington income tax. 770 • Franchise taxes, revenue related taxes, Commission assessments and fees, and 771 usage related taxes are situs or a pass through. 772 • Property taxes are system allocated based on gross plant and allocated on the GPS 773 Factor. 774 • Generation and fuel related taxes will follow the assignment of the Resource. 775 • Other taxes such as payroll taxes are embedded in the cost of expense or capital. 776 Balances associated with the Trojan Decommissioning will be allocated using the Trojan 777 Decommissioning Fixed ("TROJDF") Factor. This will not affect State-specific treatment of this 778 item. 779 5.7. Demand-Side Management Programs 780 Costs associated with DSM Programs, including Class 1 DSM Programs, will continue to 781 be allocated on a situs basis to the State in which the investment is made. The benefits from these 782 programs will flow back to the State through Net Power Costs or through reduced or delayed future 783 capacity needs that will be addressed in the development and implementation of the process 784 identified in Section 6.1. 785 5.8. State-Specific Initiatives 786 Costs and benefits resulting from a State-specific initiative will continue to be allocated 787 and assigned on a situs basis to the State adopting the initiative. Historically, these have included, 788 but are not limited to, programs such as incentive programs and customer and community energy 789 generation programs, but have not included local fees or taxes related to the ongoing operation of 790 existing transmission and generation facilities within a State. As new issues arise, PacifiCorp will 791 EXECUTION VERSION 38 bring each issue to the MSP Workgroup to discuss whether each issue is a State-specific initiative, 792 and, if not, whether a different allocation method is appropriate. 793 6. Framework Issues 794 The Parties acknowledge that certain components of the Post-Interim Period Method are 795 not resolved by this Agreement, including Resource Planning and new Resource Assignment, Net 796 Power Costs / Nodal Pricing Model, the treatment of Special Contracts, post-Interim Period capital 797 additions, and other issues related to the transition from a dynamically-allocated system generation 798 portfolio to fixed generation portfolios. As part of the 2020 Protocol, the Parties agree to the 799 following processes and timeframes to address remaining, unresolved Framework Issues and to 800 request approval of a new Post-Interim Period Method agreement by the Commissions. The 801 Company will file for Commission consideration and approval of a new Post-Interim Period 802 Method in accordance with Section 2. The general understanding reached by the Parties as to 803 process and timelines for Framework Issues is as follows. 804 6.1. Resource Planning and New Resource Assignment 805 Continued operation, planning, and dispatch of the Company's system as an integrated six-806 State system, to the greatest extent practicable, will likely be beneficial to PacifiCorp's customers. 807 However, because of differing State policies requiring or excluding certain generation resources, 808 it appears infeasible to continue serving customers with a common generation portfolio and 809 dynamically allocating system costs. Continued dynamic allocation of all system costs in this 810 environment could result in increased costs for some States, if not all. Accordingly, allocating 811 costs and assigning benefits associated with generation capacity will require assignment of specific 812 Resources, and potentially certain transmission assets, to a specific State or States. The goal is to 813 EXECUTION VERSION 39 allow PacifiCorp to meet its legal requirements as a public utility in each State in a risk-adjusted, 814 least-cost manner, while striving to mitigate cost impacts to other States. 815 PacifiCorp will continue to plan for capacity and operating needs, both for the entire 816 interstate system and for each State. PacifiCorp will work with Parties to develop: 817 • A planning process that optimizes risk-adjusted, least-cost resource portfolios on a 818 system basis to the extent practicable, while meeting individual State requirements 819 and maintaining system reliability; and 820 • A process that assigns benefits and allocates costs of specific new Resources added 821 in order to meet an individual State’s needs. 822 Parties will evaluate these processes in light of existing or new Commission regulatory 823 processes governing Resource planning, procurement, and investment approval. 824 6.2. Net Power Costs / Nodal Pricing Model (“NPM”) 825 A method to track the costs and benefits of Resource portfolios which may differ for each 826 State will be necessary in the future to maintain the benefits of system dispatch as much as 827 practicable. Specifically, after the Interim Period when States may no longer participate in a 828 common Resource portfolio, a NPM may be used to track cost causation and receipt of benefits by 829 each State for rate-making purposes. 830 Consistent with and in consideration of the Nodal Pricing Model Memorandum of 831 Understanding in Appendix D, the Company agreed to begin the development of an NPM with a 832 third-party vendor and will use best efforts to implement the NPM by the end of January 2021, for 833 purposes of total-Company day-ahead scheduling. Parties intend for this to provide some time and 834 EXECUTION VERSION 40 experience with the NPM before it may be used for rate making as part of the Post-Interim Period 835 Method.19 836 The Company will also use best efforts to implement a model that can forecast NPC based 837 on the NPM concept. During the Interim Period, this model may be used by the Company for 838 forecast analysis of NPC. After the Interim Period, the Company intends to propose the use of this 839 model for NPC forecasts in applicable rate-making proceedings. 840 6.3. Special Contracts 841 The Company will continue to work in good faith with the Special Contract customers to 842 develop one or more proposals for consideration by the Parties on the treatment of Special 843 Contracts’ loads, costs, and benefits as part of the Framework Issues and will make best efforts to 844 present a proposal to Parties by September 1, 2021, with the intention of incorporating such 845 proposal into the Post-Interim Period Method. 846 6.4. Limited Realignment 847 The Parties agree to investigate during the Interim Period the potential Limited 848 Realignment of Interim Period Resources among the States. Limited Realignment is intended to 849 address, among other potential issues, the transition of Washington retail customers away from 850 coal-fueled Interim Period Resource in compliance with the Washington CETA by realigning 851 Interim Period Resources, including natural gas-fueled Interim Period Resources. 852 6.5. Post-Interim Period Capital Additions – Coal-Fueled Interim 853 Period Resources 854 For a coal-fueled Interim Period Resource for which one or more States have an Exit Date 855 that differs from the depreciable life or Exit Date ordered in any other State, a process is needed 856 19 NPM is intended to be used for total Company system dispatch when it is fully functional and operational and will impact system Net Power Costs that flow through State NPC balancing accounts. EXECUTION VERSION 41 for determining the cost allocation for capital investments made in the Resources subsequent to 857 the Interim Period and prior to the Exit Date for each State. The Parties have agreed to evaluate, 858 but have not accepted, the following Company straw proposal for post-Interim Period capital 859 investments, information about which is provided here not for Commission approval but to inform 860 future discussions. 861 6.5.1. PacifiCorp Straw Proposal - Post-Interim Period Capital Investment 862 Allocation Exceptions 863 For post-Interim Period incremental capital investments that are made primarily for the 864 purpose of extending the life of a coal-fueled Interim Period Resource beyond a State’s Exit Date 865 for that Resource, including but not limited to those associated with achieving compliance with 866 environmental requirements or those necessitated by catastrophic failure, such investments would 867 not be allocated to States that have issued such Exit Orders and would be allocated based on the 868 percentage shares of the coal unit Reassignment process addressed in Section 4.2 or as otherwise 869 determined for States that continue to participate in the coal-fueled Interim Period Resource. 870 For these incremental capital investments made primarily for the purpose of repairing a 871 coal-fueled Interim Period Resource following a catastrophic failure of the Interim Period 872 Resource, such investments would not be allocated to and no generation or benefits will be 873 assigned to States that have issued Exit Orders for that Resource. Parties in States not allocated 874 costs for such investments would support recovery of any remaining net book value and 875 Decommissioning Costs. 876 6.5.2. PacifiCorp Straw Proposal - Incremental Capital Investments Made 877 Between 2024 and the Exit Date Where Exit Date is On or Before 878 December 31, 2027 879 For States with Exit Orders for a coal-fueled Interim Period Resource specifying an Exit 880 Date on or before December 31, 2027, capital investments made in such Interim Period Resource 881 EXECUTION VERSION 42 after the Interim Period and prior to the Exit Date, would be allocated to an Exiting State based on 882 the AP Factor, adjusted for any Limited Realignment impacts agreed to, and pro-rated for the 883 number of years remaining based on the longest life ordered in any State's depreciation docket or 884 rate case by December 31, 2020, for such Interim Period Resource. States without Exit Orders in 885 such Interim Period Resource would be allocated the remaining amount of capital investment 886 based on proportional shares of the AP factor for the States that will be participating in the coal-887 fueled Interim Period Resource after an Exit Date. For example, if a State’s Exit Order establishes 888 an Exit Date four years from the date the capital investment is in-service, and the Interim Period 889 Resource has the longest remaining life in another State of ten years, the State with the Exit Order 890 would be allocated four-tenths of that State’s share of the cost of the qualifying capital investment. 891 Each State’s allocation of such capital investments would be subject to a prudence review based 892 on the cost to be allocated to each State consistent with this Section. 893 6.5.3. PacifiCorp Straw Proposal - Incremental Capital Investments Made 894 in 2024 and 2025 Where Exit Date is After 2027 895 For States with Exit Orders for a coal-fueled Interim Period Resource specifying an Exit 896 Date after 2027, capital investments made in such Interim Period Resource after the Interim Period 897 and through December 31, 2025, would be allocated to all States based on the AP Factor, adjusted 898 for any Limited Realignment impacts agreed to, and prudence of such capital investments for 899 States with Exit Orders would be determined based on the life established for such Interim Period 900 Resource in the Exit Order. This would allow for the reasonable allocation of capital and operating 901 costs for the Interim Period Resource during a period of time while PacifiCorp pursues the process 902 established in Section 4.2. 903 EXECUTION VERSION 43 6.5.4. PacifiCorp Straw Proposal - Incremental Capital Investments Made 904 Between 2026 and the Exit Date Where the Exit Date is After 2027 905 For States with Exit Orders for a coal-fueled Interim Period Resource specifying an Exit 906 Date after 2027, capital investments made in such Interim Period Resource after December 31, 907 2025, and until the Exit Date, would be allocated to an Exiting State based on the AP Factor, 908 adjusted for any Limited Realignment impacts agreed to, and pro-rated for the number of years 909 remaining based on the longest life ordered in any State's depreciation docket, Reassignment 910 proceeding, or rate case as of December 31, 2025. States that will be participating in the coal-911 fueled Interim Period Resource after an Exit Date would be allocated the remaining amount of any 912 capital investment based on the AP Factor calculated for that coal-fueled Interim Period Resource. 913 7. Allocation of Gain or Loss from Sale of Assets 914 Any gain or loss from the sale of Company-owned assets will be allocated among or to 915 States based upon the proportional allocation or assignment of the asset at the time of the execution 916 date of the sale agreement. Each Commission will determine the appropriate allocation of the gain 917 or loss allocated to that State as between PacifiCorp's customers and shareholders. For assets that 918 have been Reassigned for less than one calendar year as of the execution date of the sale agreement, 919 States will be allocated the gain or loss as if the asset had remained a System Resource. 920 8. Interpretation and Governance 921 8.1. Issues of Interpretation 922 Parties will attempt, consistent with their legal obligations, to resolve questions of 923 interpretation of the 2020 Protocol, in good faith in light of the language of the 2020 Protocol and 924 the intent of the Parties. 925 EXECUTION VERSION 44 8.2. Workgroups 926 8.2.1. Framework Issues Workgroup 927 PacifiCorp will schedule and convene meetings with Parties to continue negotiations of the 928 Framework Issues, which may occur in person or remotely. 929 8.2.2. Multi-State Process Workgroup 930 Consistent with Sections 8.4 or 8.5 of this Agreement, the Company will notify Parties and 931 other MSP participants if it determines a need exists to convene the MSP Workgroup to address 932 general allocation issues or complaints related to the 2020 Protocol. Any Party to this Agreement, 933 State utility regulatory agency, or other stakeholder can participate in the MSP Workgroup. The 934 MSP Workgroup may create sub-committees to investigate or evaluate or make recommendations 935 as to specified issues. MSP Workgroup meetings may be held in person or remotely. 936 8.3. Commissioner Forum 937 The 2017 Protocol included a mandatory requirement to hold an annual Commissioner 938 Forum each January during the pendency of that agreement. Under this 2020 Protocol, 939 Commission Forums are not required. A Commission or the MSP Workgroup may request such a 940 meeting of Commissioners. If a Commissioner Forum is requested, all seated commissioners from 941 each State will be invited to participate. Commissioner Forums will be public meetings, and all 942 interested parties will be allowed to attend. Before attending a Commissioner Forum, each 943 Commission can take such steps and provide such process for public input as the Commission 944 determines is necessary or appropriate under applicable State laws. 945 8.4. Proposals to Change the 2020 Protocol during the Interim Period 946 The Parties agree not to propose or support changes to the 2020 Protocol applicable to the 947 Interim Period based on a Party’s dissatisfaction with a reasonably foreseeable outcome from 948 implementation of the 2020 Protocol. Before proposing an alternative or modification to the 2020 949 EXECUTION VERSION 45 Protocol based primarily on changed or unforeseen circumstances, each Party agrees to first make 950 the proposal to the Parties and attempt in good faith to resolve the concern before asking a 951 Commission to change the 2020 Protocol. The provisions of this Section 8.4 will apply to any 952 State agency only to the extent consistent with the State agency’s statutory obligations. 953 Proposals for modifications to the 2020 Protocol may be submitted to the Company by any 954 Party. Proposals received by the Company shall be circulated in a timely manner to the other 955 Parties and the Company shall initiate discussions to attempt to address and resolve specific 956 concerns. 957 8.5. Replacement of the 2020 Protocol 958 If any stakeholder that is not a Party to this Agreement objects to the use of the 2020 959 Protocol after approval by the Commissions or proposes a new inter-jurisdictional allocation 960 procedure, PacifiCorp may convene the MSP Workgroup and hold discussions to attempt to 961 address and resolve the concerns at an MSP Workgroup meeting(s). 962 8.6. Interdependency Among Commission Approvals 963 The 2020 Protocol has been developed and negotiated by the Parties as an integrated, 964 interdependent whole. Support by any Party of the 2020 Protocol is expressly conditioned upon 965 approval without material alteration of the 2020 Protocol by all Commissions in the States that 966 PacifiCorp has sought approval.20 If any Commission disapproves, alters, or conditions approval 967 of the 2020 Protocol, Parties shall promptly meet and discuss the implications of that Commission's 968 action. PacifiCorp shall report to the Parties any Commission Order of another State concerning 969 the 2020 Protocol. Parties agree to recommend to each Commission that approval of the 2020 970 Protocol be conditioned on other Commissions approving the 2020 Protocol without change. 971 20 California has historically reviewed allocation methodologies in conjunction with a general rate case. PacifiCorp’s next regulatory-mandated general rate case will not be filed until 2021 at the earliest. EXECUTION VERSION 47 ASSOCIATION By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ POWER PRODUCERS By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ _____________________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ Attorney for Monsanto 11/26/2019 CONFIDENTIAL – SETTLEMENT NEGOTIATIONS 48 CUSTOMERS By: ________________________________ Title: ________________________________ Date: _______________________________ AMERICA By: ________________________________ Title: ________________________________ Date: _______________________________ COUNCIL By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ Staff Attorney November 26, 2019 EXECUTION VERSION UTAH INDUSTRIAL ENERGY CONSUMERS By: UTAH OFFICE OF CONSUMER SERVICES By: Title: Title: Date: Date: VOTE SOLAR By: WASHINGTON PUBLIC COUNSEL By: Title:Title: Date:Date: WASHINGTON UTILITIES & TRANSPORTATION CO MISSION STAFF By:/ ---.., WESTERN RESOURCE ADVOCATES By: Title: iar,za.eierz.72 -Cbt;i?' wx.-4.; A .?ek vat Title: Date: ft 11- JO ,20-2e5/ Date: WOLVERINE FUELS By: WYOMING INDUSTRIAL ENERGY CONSUMERS By: Title: Title: Date: Date: 49 EXECUTION VERSION 49 CONSUMERS By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ TRANSPORTATION COMMISSION STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ CONSUMERS By: ________________________________ Title: ________________________________ Date: _______________________________ Senior Staff Attorney November 27, 2019 EXECUTION VERSION 49 CONSUMERS By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ TRANSPORTATION COMMISSION STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ CONSUMERS By: ________________________________ Title: ________________________________ Date: _______________________________ Attorney for WIEC November 25, 2019 EXECUTION VERSION 50 WYOMING OFFICE OF CONSUMER ADVOCATE BY:a." Title: ' Date: ll/2G 201 WYOMING PUBLIC SERVICE COMMISSION STAFF By Title: N f4cy Date: / o-z co 2() By: Title: Date: By: Title: Date: By: Title: Date: By: Title: Date: By: Title: Date: By: Title: Date: EXECUTION VERSION 2020 Protocol - Appendix A 1 APPENDIX A Definitions For purposes of this Agreement, the following terms will have the following meanings: 1 • “2017 Protocol” refers to the 2017 PacifiCorp Inter-Jurisdictional Allocation Protocol. 2 • “2020 Protocol” refers to the 2020 PacifiCorp Inter-Jurisdictional Allocation Protocol. 3 • “Administrative and General Costs” means costs included in FERC accounts 920 through 935. 4 • “Assigned Production Factor” or “AP” means States' assigned share of a Resource (see Appendix 5 C for more details). 6 • “Assigned Production - Operations and Maintenance Factor” or “APOM Factor” means the 7 State allocated share of all generation related operating and maintenance expenses that cannot be 8 associated with a specific Resource, such as general office generation management expenses, that 9 will be allocated to States calculated as each State's relative share of directly allocated generation 10 operating and maintenance expenses for steam, hydro, and other generation functions (see Section 11 5.1.1 and Appendix C for more details). 12 • “Class 1 Demand-Side Management” or “Class 1 DSM” means dispatchable or scheduled firm 13 DSM resources, sometimes referred to as direct load control programs. 14 • “Closure” means either PacifiCorp’s termination of ownership interest in a Resource, permanent 15 cessation of operations of a Resource, permanent cessation of receipt of energy from a Resource, or 16 otherwise retirement of a Resource. 17 • “Coincident Peak” means the hour each month that the combined demand of all PacifiCorp retail 18 customers is greatest, adjusted for normal weather conditions. The hour of coincident peak is 19 calculated assuming weather normalized retail load, and as it relates to generation allocation factors, 20 it includes adjustments for Class 1 DSM and Special Contract curtailments. In calculating the 21 EXECUTION VERSION 2020 Protocol - Appendix A 2 coincident peak for the System Transmission Factor, the only adjustment will be for weather 22 normalization. 23 • “Commission” means a utility regulatory commission in a State. 24 • “Commissioner Forum” means the meeting of Commissioners from all States, the goal of which 25 is to provide an update from the MSP Workgroup. Such a forum is not required by the 2020 Protocol. 26 • “Commission Order” means a formal determination issued by a State Commission consistent with 27 its authority as provided by a State's statutes or administrative rules. 28 • “Company” means PacifiCorp. 29 • “Contributions in Aid of Construction” or “CIAC” means contributions from customers to pay 30 their share of a capital construction project above the amount their retail rates justify. CIAC is a 31 reduction to rate base, (see Appendix C for more detail). 32 • “Customer Ancillary Services” means products or services that may be provided by a customer to 33 the Company, such as in which the Company has the right to curtail electric service to the customer 34 so as to lower the costs of operating the Company’s system. 35 • “Customer Ancillary Service Contracts” means contracts between the Company and a retail 36 customer pursuant to which the Company pays the customer for Customer Ancillary Services 37 • “Decommissioning Costs” means the costs of removal and environmental remediation or 38 reclamation - net of any salvage value realized - required at the time a generation resource is 39 physically retired. 40 • “Decommissioning Studies” means the engineering studies carried out in advance of planned coal-41 fueled Interim Period Resource Reassignment filings in February of 2021 and June of 2024, in order 42 to identify the final Decommissioning Cost liabilities of Exiting States, as specifically identified in 43 Section 4.3.1. 44 • “Demand-Related” describes capital and other fixed costs incurred by the Company in order to be 45 prepared to meet the maximum demand imposed upon its system. 46 EXECUTION VERSION 2020 Protocol - Appendix A 3 • “Demand-Side Management Programs” or “DSM Programs” means programs intended to 47 reduce electricity use through activities or programs that promote electric energy efficiency or 48 conservation, more efficient management of electric energy loads, or reductions in peak demand. 49 • “Embedded Cost Differential” or “ECD” means the sum of PacifiCorp’s production costs of pre-50 2005 resources as defined in the 2010 Protocol, excluding west side hydro, Mid-Columbia Contracts, 51 and Qualified Facility contracts, referred to as "all other generation resources" expressed in dollars 52 per megawatt-hour compared to west hydro-electric resources production costs expressed in dollars 53 per megawatt-hour with the difference multiplied by the hydro-electric resources megawatt-hours 54 of production, and the differential between the all other generation resources dollars per megawatt-55 hour compared to Mid-Columbia Contracts costs dollars per megawatt-hour multiplied by the Mid-56 Columbia Contracts megawatt-hours. 57 ◦ “Dynamic Embedded Cost Differential” or “Dynamic ECD” means the ECD components 58 are updated to the test period utilized in the filing. 59 ◦ “Fixed Embedded Cost Differential” or “Fixed ECD” means the ECD amount for a State 60 is set at a point of time and not updated. 61 • “Energy Imbalance Market” or “EIM” means the multi-Balancing Authority Area (BAA) real-62 time market operated by the California Independent System Operator (CAISO) that balances 63 electricity supply and demand every five minutes by choosing the least-cost resource to serve system 64 load. 65 • “Energy-Related” means variable costs incurred by the Company in order to deliver the energy 66 required to serve customers. 67 • “Existing QF PPAs” is defined in Section 4.4.1 of the agreement. 68 69 EXECUTION VERSION 2020 Protocol - Appendix A 4 • “Exit Date” means the date, established in an Exit Order entered by a Commission, on which 70 PacifiCorp intends to discontinue the allocation of costs and assignment of benefits of a coal-fueled 71 Interim Period Resource to the State issuing the Exit Order. 72 • “Exiting State” means a State with a final order from a State Commission approving the exit from 73 a coal-fueled Interim Period Resource on a date certain. 74 • “Exit Order” means an order entered by a Commission establishing an Exit Date consistent with 75 the 2020 Protocol. 76 • “Extended Day-Ahead Market” or “EDAM” means a market currently still in development that 77 will address ramping needs between intervals and uncertainty that can occur between the day-ahead 78 and real-time markets. 79 • “FERC” means the Federal Energy Regulatory Commission. 80 • “Five States” means the States of California, Idaho, Oregon, Utah, and Wyoming. 81 • “Fixed Costs” means costs incurred by the Company that do not vary with the amount of energy 82 delivered by the Company to its customers during any hour. 83 • “Framework” is defined in Section 1 of the Agreement. 84 • “Framework Issue” is defined in Section 1 of the Agreement. 85 • “General Plant” means capital investment included in FERC accounts 389 through 399. 86 • “Implemented Issues” is defined in Section 1 of the Agreement. 87 • “Intangible Plant” means capital investment included in FERC accounts 301 through 303. 88 • “Interim Period” is defined in Section 2 of the Agreement. 89 • “Interim Period Resource” means Resource in commercial operation, or with a contract delivery 90 date, as applicable, during the Interim Period. 91 • “Limited Realignment” means the assignment of Interim Period Resources among PacifiCorp 92 States that differ from assignment using the SGF Factor. 93 EXECUTION VERSION 2020 Protocol - Appendix A 5 • “Load-Based Dynamic Allocation Factor” means an allocation factor that is calculated using 94 States’ monthly energy usage and/or States’ contribution to monthly system Coincident Peak. 95 • “Mid-Columbia Contracts” means the various power sales agreements between PacifiCorp and 96 Public Utility District No. 2 of Grant County, PacifiCorp and Douglas County Public Utility District, 97 and PacifiCorp and Chelan County Public Utility District, specifically: the Power Sales Contract 98 with Public Utility District No. 2 of Grant County dated May 22, 1956; the Power Sales Contract 99 with Public Utility District No. 2 of Grant County dated June 22, 1959; the Priest Rapids Project 100 Product Sales Contract with Public Utility District No. 2 of Grant County dated December 31, 2001; 101 the Additional Products Sales Agreement with Public Utility District No. 2 of Grant County dated 102 December 31, 2001; the Priest Rapids Project Reasonable Portion Power Sales Contract with Public 103 Utility District No. 2 of Grant County dated December 31, 2001; the Power Sales Contract with 104 Douglas County Public Utility District dated September 18, 1963; the Power Sales Contract with 105 Chelan County Public Utility District dated November 14, 1957, and all successor contracts thereto. 106 • “MSP Workgroup” means a group of regulators, the Company, and other interested stakeholders 107 that convenes to discuss the assignment or allocation of PacifiCorp revenues, costs, and investments 108 among the States. 109 • “Multi-State Process” or “MSP” means the ongoing Company-led convening of Parties from all 110 six States in which it operates to consider issues related to fair cost allocations among the States. 111 • “Net Power Costs” or “NPC” means PacifiCorp’s fuel and wheeling expenses and costs and 112 revenues associated with long-term Wholesale Contracts, Short-Term Purchases and Sales and Non-113 Firm Purchases and Sales. 114 “New QF PPA” is defined in Section 4.4.2 of the Agreement. 115 • “Nodal Pricing Model” or “NPM” means a method for pricing electricity proposed by the 116 Company that is based on the marginal cost ($/MWh) of serving the next increment of demand at a 117 EXECUTION VERSION 2020 Protocol - Appendix A 6 given pricing node consistent with existing transmission constraints and the performance 118 characteristics of resources. 119 • “Nodal Pricing Model Memorandum of Understanding” or “NPM MOU” means the agreement 120 among the Parties on the prudence of the Company's proceeding to implement the Nodal Pricing 121 Model that may be adopted for the calculation of net power costs (NPC) through a new inter-122 jurisdictional cost-allocation methodology. 123 • “Non-Firm Purchases and Sales” means transactions at wholesale that are not Wholesale Contracts 124 or Short-Term Purchases and Sales. 125 • “Open Access Transmission Tariff” means PacifiCorp's Open Access Transmission Tariff on file 126 with FERC. 127 • “Operations and Maintenance” or “O&M” means costs incurred by the Company to maintain its 128 assets that are expensed as defined by FERC. 129 • “Oregon Direct Access Consumer” means Oregon retail electricity consumers that procure 130 electricity from a supplier other than PacifiCorp under an Oregon Direct Access Program. 131 • “Oregon Direct Access Program” means Oregon laws, regulations, and orders that permit 132 PacifiCorp’s Oregon retail consumers to purchase electricity directly from a supplier other than 133 PacifiCorp. 134 • “Party” or “Parties” means certain State Commission staff members, regulatory agencies, 135 customers, consumer advocates, conservation organizations, and other interested parties from 136 California, Idaho, Oregon, Utah, Washington, and Wyoming who have executed this Agreement. 137 • “Portfolio Standard” means a law or regulation that requires PacifiCorp to acquire: (a) a particular 138 type of Resource, (b) a particular quantity of Resources, (c) Resources in a prescribed manner or (d) 139 Resources located in a particular geographic area. 140 EXECUTION VERSION 2020 Protocol - Appendix A 7 • “Post-Interim Period Method” means the resolution of the Framework Issues combined with the 141 Implemented Issues and the Resolved Issues are all intended to result in the new allocation 142 methodology for PacifiCorp's six States. 143 • “Post-Interim Period Resources” means Resources that begin commercial operation, or with a 144 contract or delivery date, as applicable, after the end of the Interim Period. 145 • “Qualifying Facility" or “QF” means small power production or cogeneration facilities developed 146 under the Public Utility Regulatory Policies Act of 1978 (PURPA) and related State laws and 147 regulations. 148 • “Qualifying Facility Power Purchase Agreement” or “QF PPA” means contracts to purchase the 149 output of a Qualifying Facility by the Company. 150 • “Reassignment”, “Reassign”, or “Reassigned” means assigning benefits from an Exiting State's 151 share of a coal-fueled Interim Period Resource to those States with Commission orders to accept the 152 cost responsibility allocation for the Exiting State’s portion of the coal-fueled Resource. 153 • “Resolved Issues” is defined in Section 1 of the Agreement. 154 • “Resource” means a Company-owned generating unit, plant, mine, long-term Wholesale Contract, 155 Short-Term Purchase and Sale, Non-firm Purchase and Sale, or QF contract. 156 • “Short-Term Firm Purchases and Firm Sales” means physical or financial contracts pursuant to 157 which PacifiCorp purchases, sells, or exchanges firm power at wholesale and Customer Ancillary 158 Service Contracts that are less than one year in duration. 159 • “Short-Term Purchases and Sales” means physical or financial contracts pursuant to which 160 PacifiCorp purchases, sells, or exchanges firm power at wholesale and Customer Ancillary Service 161 Contracts that are less than one year in duration. 162 • “Special Contract” means a contract entered into between PacifiCorp and one of its retail customers 163 with prices, terms, and conditions different from otherwise-applicable tariff rates. Special Contracts 164 EXECUTION VERSION 2020 Protocol - Appendix A 8 may provide for a value consideration to the customer to reflect attributes of Customer Ancillary 165 Service Contracts. 166 • “State” means California, Oregon, Idaho, Utah, Washington, or Wyoming. 167 • “State Resources” means Interim Period Resources whose costs are assigned to a single 168 jurisdiction to accommodate jurisdiction-specific policy preferences. 169 • “System Energy Factor” or “SE Factor” is defined in Appendix C. 170 • “System Generation-Fixed Factor” or “SGF Factor” is defined in Appendix C. 171 • “System Gross Plant Distribution Factor” or “SGPD Factor” is defined in Appendix C. 172 • “System Net Plant-Distribution Factor” or “SNPD Factor” is defined in Appendix C. 173 • “System Overhead Factor" or “SO Factor” is defined in Appendix C. 174 • “System Resources” means Interim Period Resources that are not State Resources and whose 175 associated costs and revenues are allocated among all States on a dynamic basis. 176 • “System Transmission Factor” or “ST Factor” is defined in Appendix C. 177 • “Trojan Decommissioning” means costs associated with decommissioning the Trojan Plant. 178 • “Trojan Decommissioning Fixed Factor” or (“TROJDF”) is defined in Appendix C. 179 • “Trojan Plant” means the now-decommissioned nuclear plant for which the Company is still 180 recovering costs. 181 • “Variable Costs” means costs incurred by the Company that vary with the amount of energy 182 delivered by the Company to its customers during any hour. 183 • “Washington Public Utility Tax” means a Washington tax on public service businesses, including 184 businesses that engage in transportation, communications, and the supply of energy, natural gas, and 185 water. The tax is in lieu of the business and occupation (B&O) tax. 186 • “West Control Area Inter-jurisdictional Allocation Methodology” or “WCA” means the 187 allocation protocol methodology used by Washington to allocate costs consistent with its Balancing 188 Area Authority-based principles governing the assets deemed to serve Washington. 189 EXECUTION VERSION 2020 Protocol - Appendix A 9 •“Wholesale Contracts” means physical or financial contracts pursuant to which PacifiCorp 190 purchases, sells, or exchanges firm power at wholesale and Customer Ancillary Service Contracts.191 EXECUTION VERSION APPENDIX B Allocation Factors by Account by Revenue Requirement Components 1 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 440 Retail Revenues Direct assigned - Jurisdiction S S Commercial & Industrial Sales Retail Revenues Direct assigned - Jurisdiction S S Public Street & Highway Lighting Retail Revenues Direct assigned - Jurisdiction S S Other Sales to Public Authority Retail Revenues Direct assigned - Jurisdiction S S Retail Revenues Direct assigned - Jurisdiction S S Wholesale Sales Direct assigned - Jurisdiction S S Non-Firm SE AP, NP Firm SG AP, NP Provision for Rate Refund Direct assigned - Jurisdiction S S Transmission SG ST Other Electric Operating Revenues 450 Forfeited Discounts & Interest Retail Revenues Direct assigned - Jurisdiction S S Misc Electric Revenue Retail Revenues Direct assigned - Jurisdiction S S Other - Common SO SO Retail Revenues Direct assigned - Jurisdiction SG AP Rent of Electric Property Retail Revenues Direct assigned - Jurisdiction S S Common SG ST Other - Common SO SO Other Electric Revenue Retail Revenues Direct assigned - Jurisdiction S S Wheeling Non-firm, Other SE ST Common SO SO Wheeling - Firm, Other SG ST Customer Related CN CN Interdepartmental Water Sales Allocation Factors by Account by Revenue Requirement Components 2020 Protocol - Appendix B 2020 Protocol - Appendix B 2 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 41160 Gain on Sale of Utility Plant - CR Distribution S S Production SG AP Transmission SG ST General Office SO SO Loss on Sale of Utility Plant Distribution S S Production SG AP Transmission SG ST General Office SO SO Gain from Emission Allowances SO2 Emission Allowance sales SE AP Gain from Disposition of NOX Credits NOX Emission Allowance sales SE AP (Gain) / Loss on Sale of Utility Plant Distribution S S Production SG AP Transmission SG ST General Office SO SO Customer Related CN CN Miscellaneous Expenses 4311 Interest on Customer Deposits Customer Service Deposits CN CN Direct assigned - Jurisdiction S S Steam Power Generation 500, 502, 504-514 Operation Supervision & Engineering Steam Plants O&M SG AP, APOMS Steam plants Fuel SE AP, APOMS Steam From Other Sources Steam Royalties SE AP, APOMS Nuclear Power Generation 517 - 532 Nuclear Plants O&M SG AP Hydraulic Power Generation 535 - 545 Pacific Hydro O&M SG AP, APOMH East Hydro O&M SG AP, APOMH Other Power Generation 546, 548-554 Operation Super & Engineering Other Production Plant SG AP, APOMO Other Fuel Expense SE AP, APOMO Fuel Related Nuclear Power O&M 2020 Protocol - Appendix B 3 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 555 Tracking Mechanisms S S Firm SG AP, NP Non-firm SE AP, NP System Control & Load Dispatch Other Expenses SG SE Direct assigned - Jurisdiction S S Other Expenses SE SE Other Expenses SG APOMS, APOMH, APOMO Cholla Transaction SGCT AP TRANSMISSION EXPENSE 560-564, 566-573 Transmission Plant O&M SG ST Transmission of Electricity by Others Firm Wheeling SG ST Non-Firm Wheeling SE ST GRID Management Charge SG SE DISTRIBUTION EXPENSE 580 - 598 Direct assigned - Jurisdiction S S Other Distribution SNPD SNPD CUSTOMER ACCOUNTS EXPENSE 901 - 905 Customer Accounts O&M Direct assigned - Jurisdiction S S Total System Customer Related CN CN CUSTOMER SERVICE EXPENSE 907 - 910 Customer Service O&M Direct assigned - Jurisdiction S S Total System Customer Related CN CN SALES EXPENSE 911 - 916 Direct assigned - Jurisdiction S S Total System Customer Related CN CN ADMINISTRATIVE & GEN EXPENSE 920-935 Administrative & General Expense Direct assigned - Jurisdiction S S Customer Related CN CN Mine SE AP FERC Regulatory Expense SG ST General SO SO Transmission O&M 2020 Protocol - Appendix B 4 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 403SP Steam Plants SG AP Nuclear Plant SG AP Pacific Hydro SG AP East Hydro SG AP Other Production Depreciation Other Production Plant SG AP Transmission Depreciation Transmission Plant SG ST Distribution Depreciation Direct assigned - Jurisdiction Land & Land Rights S S Structures S S Station Equipment S S Storage Battery Equipment S S Poles & Towers S S OH Conductors S S UG Conduit S S UG Conductor S S Line Trans S S Services S S Meters S S Inst Cust Prem S S Leased Property S S Street Lighting S S Distribution S S Steam Plants SG AP Mining SE AP Pacific Hydro SG AP East Hydro SG AP Transmission SG ST Customer Related CN CN General SO SO Mining Plant SE AP Hydro Depreciation General Depreciation Mining Depreciation 2020 Protocol - Appendix B 5 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 404GP Amort of LT Plant - Capital Lease Gen Direct assigned - Jurisdiction S S General SO SO Customer Related CN CN Amort of LT Plant - Cap Lease Steam Steam Production Plant SG AP Amort of LT Plant - Intangible Plant Distribution S S Production SG AP Transmission SG ST General SO SO Mining Plant SE AP Customer Related CN CN Amort of LT Plant - Mining Plant Mining Plant SE AP Amortization of Other Electric Plant Pacific Hydro SG AP East Hydro SG AP Amortization of Other Electric Plant Direct assigned - Jurisdiction S S Amortization of Plant Acquisition Adj Direct assigned - Jurisdiction S S Production Plant SG AP Amort of Prop Losses, Unrec Plant, etc. Direct assigned - Jurisdiction S S Production, SG AP Transmission SG ST Taxes Other Than Income 408 Taxes Other Than Income Direct assigned - Jurisdiction S S Property GPS GPS System Taxes SO SO Misc Energy SE AP Misc Production SG AP DEFERRED ITC 41140 Deferred Investment Tax Credit - Fed ITC DGU DGUF Deferred Investment Tax Credit - Idaho ITC DGU DGUF 2020 Protocol - Appendix B 6 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 427 Interest on Long-Term Debt Direct assigned - Jurisdiction S S Interest Expense SNP SNP Amortization of Debt Disc & Exp Interest Expense SNP SNP Amortization of Premium on Debt Interest Expense SNP SNP Other Interest Expense Interest Expense SNP SNP AFUDC SNP SNP Interest & Dividends 419 Interest & Dividends SNP SNP DEFERRED INCOME TAXES 41010 Deferred Income Tax - DR Direct assigned - Jurisdiction S S Non-Coal and Gas Production SG AP Coal and Gas Production SG AP Transmission SG ST Customer Related CN CN General SO SO Property Tax related GPS GPS Miscellaneous SNP SNP Trojan TROJD TROJDF Distribution SNPD SNPD Mining Plant SE AP Bad Debt BADDEBT BADDEBT Tax Depreciation TAXDEPR TAXDEPR Interest & Dividends 2020 Protocol - Appendix B 7 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 41110 Deferred Income Tax -CR Direct assigned - Jurisdiction S S Non-Coal and Gas Production SG AP Coal and Gas Production SG AP Transmission SG ST Customer Related CN CN General SO SO Property Tax related GPS GPS Miscellaneous SNP SNP Trojan TROJD TROJDF Distribution SNPD SNPD Mining Plant SE AP Contributions in Aid of Construction CIAC CIAC Production, Other SGCT AP Book Depreciation SCHMDEXP SCHMDEXP SCHEDULE - M ADDITIONS SCHMAF Additions - Flow Through Direct assigned - Jurisdiction S S Additions - Permanent Direct assigned - Jurisdiction S S Mining related SE AP General SO SO Non-Coal and Gas Production SG AP Coal and Gas Production SG AP Transmission SG ST Depreciation SCHMDEXP SCHMDEXP Additions - Temporary Direct assigned - Jurisdiction S S Bad Debt BADDEBT BADDEBT Contributions in Aid of Construction CIAC CIAC Miscellaneous SNP SNP Trojan TROJD TROJDF Non-Coal and Gas Production SG AP Mining Plant SE AP Coal and Gas Production SG AP Transmission SG ST Property Tax GPS GPS General SO SO Depreciation SCHMDEXP SCHMDEXP Distribution SNPD SNPD Production, Other SGCT AP 2020 Protocol - Appendix B 8 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR SCHMDF Deductions - Flow Through Direct Assigned - Jurisdiction S S Coal and Gas Production SG AP Transmission SG ST Non-Coal and Gas Production SG AP Deductions - Permanent Direct Assigned - Jurisdiction S S Mining Related SE AP Depreciation SCHMDEXP SCHMDEXP Miscellaneous SNP SNP General SO SO Deductions - Temporary Direct Assigned - Jurisdiction S S Bad Debt BADDEBT BADDEBT Miscellaneous SNP SNP Non-Coal and Gas Production SG AP Mining related SE AP Coal and Gas Production SG AP Transmission SG ST Property Tax GPS GPS General SO SO Depreciation TAXDEPR TAXDEPR Distribution SNPD SNPD Customer Related CN CN State Income Taxes 40911 40911 Income Before Taxes CALCULATED CALCULATED Renewable Energy Tax Credit SG AP FIT True-up S S Renewable Energy / Production Tax Credit SG AP PacifiCorp Minerals Inc.SE AP Foreign Tax Credit SO SO Steam Production Plant 310 - 316 Steam Plants SG AP Nuclear Production Plant 320-325 Nuclear Plant SG AP Hydraulic Plant 330-336 Pacific Hydro SG AP East Hydro SG AP Steam Plants Nuclear Plant 2020 Protocol - Appendix B 9 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 340-346 Other Production Plant Other Production Plant - Situs S S Other Production Plant SG AP TRANSMISSION PLANT 350-359 Transmission Plant SG ST DISTRIBUTION PLANT 360-373 Direct assigned - Jurisdiction S S GENERAL PLANT 389 - 398 Distribution S S Pacific Hydro SG AP East Hydro SG AP Production SG AP, SE Transmission SG ST Customer Related CN CN General SO SO Mining SE AP Mining Plant SE AP General Gas Line Capital Leases Capital Lease SG AP General Capital Leases Direct assigned - Jurisdiction S S General SO SO Generation SG AP Transmission SG ST INTANGIBLE PLANT 301 Direct assigned - Jurisdiction S S Direct assigned - Jurisdiction S S Production SG AP Transmission SG ST Miscellaneous Intangible Plant Distribution S S Pacific Hydro SG AP East Hydro SG AP Production SG AP Transmission SG ST Customer Related CN CN General SO SO Mining SE AP Other SG SGF Organization Franchise & Consent Distribution Plant 2020 Protocol - Appendix B 10 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 303 Direct assigned - Jurisdiction S S Rate Base Additions 105 Plant Held For Future Use Direct assigned - Jurisdiction S S Production SG AP Transmission SG ST Mining Plant SE AP Electric Plant Acquisition Adjustments Direct assigned - Jurisdiction S S Production Plant SG AP Transmission SG ST Accum Provision for Asset Acquisition Adjustments Direct assigned - Jurisdiction S S Production Plant SG AP Transmission SG ST Direct assigned - Jurisdiction S S General SO SO General SO SO Direct assigned - Jurisdiction S S Direct assigned - Jurisdiction S S Steam Production Plant SE AP Fuel Stock - Undistributed Steam Production Plant SE AP UAMPS Working Capital Deposit Mining Plant SE AP DG&T Working Capital Deposit Mining Plant SE AP Provo Working Capital Deposit Mining Plant SE AP Weatherization Pensions 2020 Protocol - Appendix B 11 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 154 Materials and Supplies Direct assigned - Jurisdiction S S Production, SG AP Transmission SG ST Mining SE AP Production - Common SG AP General SO SO Distribution SNPD SNPD Production, Other SG AP Stores Expense Undistributed General SO SO Provo Working Capital Deposit Provo Working Capital Deposit SG AP Direct assigned - Jurisdiction S S Property Tax GPS GPS Production SG AP Transmission SG ST Mining SE AP General SO SO Misc Regulatory Assets Direct assigned - Jurisdiction S S Production SG AP Transmission SG ST Mining SE AP General SO SO Production, Other SGCT AP Other SG SGF Direct assigned - Jurisdiction S S Production SG AP Transmission SG ST General SO SO Mining SE AP Production - Common SG AP Other SG SGF Working Capital CWC Direct assigned - Jurisdiction S S Cash SNP SNP Working Funds SG AP Notes Receivable SO SO Other Accounts Receivable SO SO Cash Working Capital Misc Deferred Debits 2020 Protocol - Appendix B 12 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 232 Accounts Payable SO SO Accounts Payable SE AP Accounts Payable SG ST, AP, SGF Other Deferred Credits - Misc SE AP Other Deferred Credits - Misc SE AP ARO Reg Liability SE AP Rate Base Deductions 235 Customer Service Deposits Direct assigned - Jurisdiction S S Prov for Property Insurance Prov for Property Insurance SO SO Prov for Injuries & Damages Prov for Injuries & Damages SO SO Prov for Pensions and Benefits Prov for Pensions and Benefits SO SO Accum Misc Oper Prov-Black Lung Other Production SG AP FAS 143 ARO Regulatory Liability ARO S S Trojan Plant TROJD TROJDF Asset Retirement Obligation Trojan Plant TROJD TROJDF Customer Advances for Construction Direct assigned - Jurisdiction S S Production SG AP Transmission SG ST Customer Related CN CN S02 Emissions SE AP Other Deferred Credits Direct assigned - Jurisdiction S S Production SG AP Transmission SG ST General SO SO Mining SE AP Insurance Provision SO SO 2020 Protocol - Appendix B 13 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 190 Accumulated Deferred Income Taxes Direct assigned - Jurisdiction S S Bad Debt BADDEBT BADDEBT Non-Coal and Gas Production SG AP Coal and Gas Production SG AP Transmission SG ST Customer Related CN CN General SO SO Miscellaneous SNP SNP Trojan TROJD TROJDF Distribution SNPD SNPD Mining Plant SE AP Accumulated Deferred Income Taxes Non-Coal and Gas Production SG AP Coal and Gas Production SG AP Transmission SG ST Accumulated Deferred Income Taxes Direct assigned - Jurisdiction S S Depreciation DITBAL DITBAL Non-Coal and Gas Production SG AP Coal and Gas Production SG AP Transmission SG ST Customer Related CN CN General SO SO Miscellaneous SNP SNP Depreciation TAXDEPR TAXDEPR Depreciation SCHMDEXP SCHMDEXP System Gross Plant GPS GPS Contribution in Aid of Construction CIAC CIAC Mining SE AP Accumulated Deferred Income Taxes Direct assigned - Jurisdiction S S Depreciation DITBAL DITBAL Non-Coal and Gas Production SG AP Coal and Gas Production SG AP Transmission SG ST Customer Related CN CN General SO SO Miscellaneous SNP SNP Trojan TROJD TROJDF Production, Other SGCT AP Property Tax GPS GPS Mining Plant SE AP Accumulated Investment Tax Credit Direct assigned - Jurisdiction S S Investment Tax Credits ITC84 ITC84 Investment Tax Credits ITC85 ITC85 Investment Tax Credits ITC86 ITC86 Investment Tax Credits ITC88 ITC88 Investment Tax Credits ITC89 ITC89 Investment Tax Credits ITC90 ITC90 Investment Tax Credits SG SGF 2020 Protocol - Appendix B 14 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 108SP Steam Prod Plant Accumulated Depr Steam Plants SG AP Nuclear Prod Plant Accumulated Depr Nuclear Plant SG AP Hydraulic Prod Plant Accum Depr Pacific Hydro SG AP East Hydro SG AP Other Production Plant - Accum Depr Other Production Plant SG AP TRANS PLANT ACCUM DEPR 108TP Transmission Plant Accumulated Depr Transmission Plant SG ST DISTRIBUTION PLANT ACCUM DEPR 108360 - 108373 Distribution Plant Accumulated Depr Direct assigned - Jurisdiction S S Unclassified Dist Plant - Acct 300 Direct assigned - Jurisdiction S S Unclassified Dist Sub Plant - Acct 300 Direct assigned - Jurisdiction S S Unclassified Dist Sub Plant - Acct 300 Direct assigned - Jurisdiction S S GENERAL PLANT ACCUM DEPR 108GP General Plant Accumulated Depr. Distribution S S Pacific Hydro SG AP East Hydro SG AP Production SG AP Transmission SG ST Customer Related CN CN General SO SO SO Mining Plant SE AP Mining Plant Accumulated Depr. Mining Plant SE AP Accum Depr - Capital Lease General SO SO Accum Depr - Capital Lease Direct assigned - Jurisdiction S S 2020 Protocol - Appendix B 15 1 2 3 4 5 INTERIM PERIOD POST INTERIM PERIOD ACCT NAME REVENUE REQUIREMENT COMPONENTS ASSIGNED TO FACTOR FACTOR FACTOR 111SP Accum Prov for Amort-Steam Steam Plants SG AP Accum Prov for Amort-General Distribution S S Pacific Hydro SG AP East Hydro SG AP Production SG AP Transmission SG ST Customer Related CN CN General SO SO SO Accum Prov for Amort-Hydro Pacific Hydro SG AP East Hydro SG AP Accum Prov for Amort-Intangible Plant Distribution S S Pacific Hydro SG AP Production SG AP Transmission SG ST General SO SO Mining SE AP Customer Related CN CN Direct assigned - Jurisdiction S S Accum Prov Amort - Capital Leases Distribution S S Production SG AP General SO SO 2020 Protocol - Appendix B EXECUTION VERSION 2020 Protocol - Appendix C 1 APPENDIX C Definitions of Allocation Factors Factors without an effective period will be used during and after the Interim Period. i denotes count of jurisdictions. j denotes count of month in a year. N is the number of regulatory jurisdictions that the Company operates in and allocates costs to. Assigned Production Factor (“AP”) – Effective after Interim Period 𝐴𝐴𝐴𝐴𝑖𝑖=𝑆𝑆𝑆𝑆𝑆𝑆𝑖𝑖∑𝑆𝑆𝑆𝑆𝑆𝑆𝑖𝑖𝑥𝑥𝑖𝑖=1 where: APi = Assigned Production Factor for jurisdiction i. SGFi = System Generation – Fixed Factor for jurisdiction i. x = Number of jurisdictions that are assigned the unit. The AP factor may be calculated by unit of Resources, group of Resources, or for specific periods of capital investments. The AP factor may change over time as allocations change due to jurisdictions accepting a larger or smaller assignment in units that lead to the change in the value of x. For example, 1. Assuming a unit is assigned to States A, B and C out of six jurisdictions in year 1, and theirSGF factors are SGFA = 25%, SGFB = 45%, and SGFC = 15%, respectively, then 𝐴𝐴𝐴𝐴𝐴𝐴=25%25%+45%+15%=29.4% 𝐴𝐴𝐴𝐴𝐵𝐵=45%25%+45%+15%=52.9% 𝐴𝐴𝐴𝐴𝐶𝐶=15%25%+45%+15%=17.6% 2.Assuming the unit is later assigned to States B and C only, then the AP factors will change to𝐴𝐴𝐴𝐴𝐴𝐴=0% 𝐴𝐴𝐴𝐴𝐵𝐵=45%45%+15%=75% 𝐴𝐴𝐴𝐴𝐶𝐶=15%45%+15%=25% EXECUTION VERSION 2020 Protocol - Appendix C 2 3.Assuming the unit is later assigned to C only, then the AP factors will change to𝐴𝐴𝐴𝐴𝐴𝐴=0% 𝐴𝐴𝐴𝐴𝐵𝐵=0% 𝐴𝐴𝐴𝐴𝐶𝐶=15%15%=100% Accounts using AP factor: Sales for Resale (447), Water Sales (453), Miscellaneous Revenue (41160, 41170, 4118, 41181, 421), Generation (500-555, 557), Administrative and General Expense (920-935), Depreciation Expense (403SP, 403NP, 403HP, 403OP, 403GP, 403MP) Amortization Expense (404SP, 404IP, 404HP, 404MP 406-407), Taxes Other Than Income (408), Deferred Income Tax Expense (41010, 41110), Schedule M, Income Taxes (40910, 40911), Generation Plant (310-346), General Plant (389-399), Intangible Plant (302-303), Plant Held for Future Use (105), Electric Plant Acquisition Adjustments (114- 115), Fuel Stock (151-152), Materials and Supplies (154), Mining Working Capital Deposits (25316-25319), Prepayments (165), Misc. Regulatory Assets (182M), Misc. Deferred Debits (186M), Working Capital (135, 232, 25330, 230, 245105), Accum Misc Oper Prov-Black Lung (22841), Customer Advances for Construction (252), SO2 Emissions (25398), Other Deferred Credits (25399), Regulatory Liabilities ARO Regulatory Liability (254105), Accumulated Deferred Income Taxes (190, 281-283), Accumulated Depreciation (108SP, 108NP, 108HP, 108OP, 108GP, 108MP), Accumulated Provision for Amortization (111SP, 111GP, 111HP, 111IP, 111390) Assigned Production Factor of New Resources – Effective after Interim Period Initial values of AP factors for all new resources will be addressed as part of the Framework discussions on Resource Planning. Assigned Production Hydro – O&M Factor (“APOMH”) – Effective after Interim Period 𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑖𝑖=𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑖𝑖∑𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑖𝑖𝑁𝑁𝑖𝑖=1where: APOMHi = Assigned Production Hydro O&M Factor for jurisdiction i. PPOMHi = Sum of all hydro production plant O&M costs allocated to jurisdiction i using the AP factors. N = Number of jurisdictions. The APOMH factor is used to allocate hydro generation related O&M costs that cannot be allocated to a specific hydro resource through an AP factor, calculated as each States’ relative share of direct-allocated hydro generation and maintenance expenses. Accounts using APOMH factor: Hydro (535-545, 557) Assigned Production Other – O&M Factor (“APOMO”) – Effective after Interim Period 𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑖𝑖=𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑖𝑖∑𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑖𝑖𝑁𝑁𝑖𝑖=1where: APOMOi = Assigned Production Other O&M Factor for jurisdiction i. EXECUTION VERSION 2020 Protocol - Appendix C 3 PPOMOi = Sum of all other production plant O&M costs allocated to jurisdiction i using the AP factors. N = Number of jurisdictions. The APOMO factor is used to allocate other generation related O&M costs that cannot be allocated to specific other production Resource through an AP factor, calculated as each States’ relative share of directly-allocated other production generation and maintenance expenses. Accounts using APOMO factor: Other Generation (546-554, 557) Assigned Production Steam – O&M Factor (“APOMS”) – Effective after Interim Period 𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑆𝑆𝑖𝑖=𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑆𝑆𝑖𝑖∑𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑆𝑆𝑖𝑖𝑁𝑁𝑖𝑖=1 where: APOMSi = Assigned Production Steam O&M Factor for jurisdiction i. PPOMSi = Sum of all steam production plant O&M costs allocated to jurisdiction i using the AP factors. N = Number of jurisdictions. The APOMS factor is used to allocate steam generation related O&M costs that cannot be allocated to specific steam resource through an AP factor, calculated as each States’ relative share of direct-allocated steam generation and maintenance expenses. Accounts using APOMS factor: Generation (500-514, 557) Bad Debt Expense Factor (“BADDEBT”) 𝐵𝐵𝐴𝐴𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝑖𝑖=𝐴𝐴𝐴𝐴𝐴𝐴𝐵𝐵904𝑖𝑖∑𝐴𝐴𝐴𝐴𝐴𝐴𝐵𝐵904𝑖𝑖𝑁𝑁𝑖𝑖=1 where: BADDEBTi = Bad Debt Expense Factor for jurisdiction i. ACCT904i = Balance in FERC Account 904 for jurisdiction i. N = Number of jurisdictions. The BADDEBT Factor is calculated by dividing the FERC account 904 Uncollectible Accounts amount for a jurisdiction by the total 904 amount for all jurisdictions. The factor allocates tax related costs for bad debt related expenses. Accounts using BADDEBT factor: Deferred Income Tax Expense (41010), Schedule M, Accumulated Deferred Income Taxes (190) Contributions in Aid of Construction Factor (“CIAC”) 𝐴𝐴𝐶𝐶𝐴𝐴𝐴𝐴𝑖𝑖=𝐴𝐴𝐶𝐶𝐴𝐴𝐴𝐴𝐶𝐶𝐴𝐴𝑖𝑖∑𝐴𝐴𝐶𝐶𝐴𝐴𝐴𝐴𝐶𝐶𝐴𝐴𝑖𝑖𝑁𝑁𝑖𝑖=1 where: CIACi = Contributions in Aid of Construction Factor for jurisdiction i. CIACNAi = Contributions in aid of construction – net additions for jurisdiction i. EXECUTION VERSION 2020 Protocol - Appendix C 4 N = Number of jurisdictions. The CIAC Factor is calculated by dividing the contribution in aid of construction net additions for a jurisdiction by the total contribution in aid of construction net additions for all jurisdictions. The factor allocates tax related costs for contributions in aid of construction. Accounts using CIAC factor: Deferred Income Tax Expense (41110), Schedule M, Accumulated Deferred Income Taxes (282) Customer Number Factor (“CN”) 𝐴𝐴𝐶𝐶𝑖𝑖=𝐴𝐴𝐶𝐶𝑆𝑆𝐵𝐵𝑖𝑖∑𝐴𝐴𝐶𝐶𝑆𝑆𝐵𝐵𝑖𝑖𝑁𝑁𝑖𝑖=1 where: CNi = Customer Number Factor for jurisdiction i. CUSTi = Total electric customers for jurisdiction i. N = Number of jurisdictions. The Customer Number Factor is calculated using the ratio of number of customers for a jurisdiction to the total number of electric customers for all jurisdictions. The factor is used to allocate customer related costs. Accounts using CN factor: Gain / Loss on Sale of Utility Plant (421), Customer Service Deposits (4311), Other Electric Revenue (456), Customer Account Expense (901-905), Customer Service Expense (907- 910), Sales Expense (911-916), Administrative and General Expense (920-935), General Plant Depreciation (403GP), Amortization Intangible Plant (404IP), Deferred Income Tax Expense (41010, 41110), Schedule M, General Plant (389-398), Intangible Plant (303), Customer Advances for Construction (252), Accumulated Deferred Income Taxes (190, 282-283), General Plant Accumulated Depreciation (108GP), Accumulated Provision for Amortization (111IP) Deferred Tax Balance Factor (“DITBAL”) 𝐵𝐵𝐶𝐶𝐵𝐵𝐵𝐵𝐴𝐴𝐷𝐷𝑖𝑖=𝐵𝐵𝐶𝐶𝐵𝐵𝐵𝐵𝐴𝐴𝐷𝐷𝐴𝐴𝑖𝑖∑𝐵𝐵𝐶𝐶𝐵𝐵𝐵𝐵𝐴𝐴𝐷𝐷𝐴𝐴𝑖𝑖𝑁𝑁𝑖𝑖=1 where: DITBALi = Deferred Tax Balance Factor for jurisdiction i. DITBALAi = Deferred tax balance allocated to jurisdiction i. (Deferred tax balance is allocated by a run of PowerTax based upon the above factors. PowerTax is a computer software package used to track deferred tax expense & deferred tax balance.) N = Number of jurisdictions. The DITBAL Factor is used to allocate deferred tax balances to jurisdictions. Accounts using DITBAL factor: Accumulated Deferred Income Taxes (282, 283) EXECUTION VERSION 2020 Protocol - Appendix C 5 Division Generation – Pacific Factor (“DGP”) 𝐵𝐵𝑆𝑆𝐴𝐴𝑖𝑖=𝑆𝑆𝑆𝑆∗𝑖𝑖∑𝑆𝑆𝑆𝑆∗𝑖𝑖𝑁𝑁𝑖𝑖=1 where: DGPi = Division Generation – Pacific Factor for jurisdiction i. SG*i = SGi if i is a pre-merger Pacific Power jurisdiction, otherwise 0. SGi = System Generation Factor for jurisdiction i. N = Number of jurisdictions. The DGP Factor is calculated as the ratio of the pre-merger Pacific Division’s SG factor for a jurisdiction divided by the sum of the pre-merger Pacific Division’s SG factors. The DGP factor is only used in calculating the dynamic ECD Division Generation – Utah Factor (“DGU”) 𝐵𝐵𝑆𝑆𝐶𝐶𝑖𝑖=𝑆𝑆𝑆𝑆∗𝑖𝑖∑𝑆𝑆𝑆𝑆∗𝑖𝑖𝑁𝑁𝑖𝑖=1 where: DGUi = Division Generation – Utah Factor for jurisdiction i. SG*i = SGi if i is a pre-merger Utah Power jurisdiction, otherwise 0. SGi = System Generation Factor for jurisdiction i. N = Number of jurisdictions. After the Interim Period, the factor is determined by the average of the four-year historical value from 2018 to 2021, or 2019 to 2022 if the Interim Period is extended. The DGU Factor is calculated as the ratio of the pre-merger Utah Power jurisdiction’s SG factor for a jurisdiction divided by the sum of the pre-merger Utah Power jurisdiction’s SG factors. The only accounts using DGU factor are Deferred Investment Tax Credits (41140, 41141) Gross Plant System Factor (“GPS”) 𝑆𝑆𝐴𝐴𝑆𝑆𝑖𝑖=𝐴𝐴𝐴𝐴𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝑆𝑆𝑖𝑖+𝐴𝐴𝐶𝐶𝑖𝑖∑(𝐴𝐴𝐴𝐴𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝑆𝑆𝑖𝑖+𝐴𝐴𝐶𝐶𝑖𝑖)𝑁𝑁𝑖𝑖=1 where: GPSi = Gross Plant System Factor for jurisdiction i. PPi = Production plant for jurisdiction i. PTi = Transmission plant for jurisdiction i. PDi = Distribution plant for jurisdiction i. PGi = General plant for jurisdiction i. PIi = Intangible plant for jurisdiction i. N = Number of jurisdictions. The GPS Factor is used to allocate property taxes. It is calculated using the ratio of gross plant for a jurisdiction divided by the total gross plant for all jurisdictions. EXECUTION VERSION 2020 Protocol - Appendix C 6 The accounts using GPS factor: Taxes Other Than Income Taxes (408), Deferred Income Tax Expense (41010, 41110), Schedule M, Prepayments (165), Accumulated Deferred Income Taxes (282, 283) Nodal Pricing Assignment of Net Power Costs (“NP”) Costs listed as allocated by NP in Appendix B are costs that will be allocated through the Nodal Pricing Model. Accounts using NP factor: Sales for Resale (447), Purchased Power (555) Schedule M – Depreciation Expense Factor (“SCHMDEXP”) 𝑆𝑆𝐴𝐴𝐴𝐴𝐴𝐴𝐵𝐵𝑖𝑖=𝐵𝐵𝐵𝐵𝐴𝐴𝐷𝐷𝐴𝐴𝑖𝑖∑𝐵𝐵𝐵𝐵𝐴𝐴𝐷𝐷𝐴𝐴𝑖𝑖𝑁𝑁𝑖𝑖=1where: SCHMDi = Schedule M – Depreciation Expense Factor for jurisdiction i. DEPRCi = Depreciation in FERC Accounts 403.1 - 403.9 for jurisdiction i. N = Number of jurisdictions. The SCHMDEXP factor is used to allocate Schedule M items related to depreciation expense. The accounts using SCHMDEXP factor: Deferred Income Tax Expense (41110), Schedule M, Accumulated Deferred Income Taxes (282) System Capacity Factor (“SC”) 𝑆𝑆𝐴𝐴𝑖𝑖=∑𝐵𝐵𝐴𝐴𝐴𝐴𝑖𝑖𝑖𝑖12𝑖𝑖=1∑ ∑𝐵𝐵𝐴𝐴𝐴𝐴𝑖𝑖𝑖𝑖12𝑖𝑖=1𝑁𝑁𝑖𝑖=1where: SCi = System Capacity Factor for jurisdiction i. TAPij = Weather-normalized peak load of jurisdiction i at the time of the system peak in month j. During the Interim Period, the peak load is further adjusted to exclude the peak load of Class 1 Demand Side Management programs and interruptible peak load of the special contracts as defined in the 2017 Protocol. N = Number of jurisdictions. The SC factor is calculated based on the relative capacity requirements of each State as determined based on 12 monthly Coincident Peaks that is used to calculate the System Generation and System Transmission factors System Energy Factor (“SE”) 𝑆𝑆𝐵𝐵𝑖𝑖=∑𝐵𝐵𝐴𝐴𝐵𝐵𝑖𝑖𝑖𝑖12𝑖𝑖=1∑ ∑𝐵𝐵𝐴𝐴𝐵𝐵𝑖𝑖𝑖𝑖12𝑖𝑖=1𝑁𝑁𝑖𝑖=1where: SEi = System Energy Factor for jurisdiction i. TAEij = Weather-normalized energy at input of jurisdiction i in month j. N = Number of jurisdictions. EXECUTION VERSION 2020 Protocol - Appendix C 7 The SE factor is used to allocate energy-related costs and is calculated as the ratio of the weather- normalized energy at input for a jurisdiction divided by the total weather-normalized energy at input for all jurisdictions. Accounts using SE factor for Interim period: Sales for Resale (447), Other Electric Revenue (456), Miscellaneous Revenue (4118, 41181), Steam Plants Fuel (501), Steam from Other Sources (503), Other Fuel Expense (547), Purchased Power (555), Transmission of Electricity by Others (565), Administrative and General Expense (920-935), Depreciation Expense (403MP), Amortization Expense (404IP, 404MP),Taxes Other Than Income (408), Deferred Income Tax Expense (41010, 41110), Schedule M, Federal Income Tax True-Up (40910), General Plant (389-399), Intangible Plant (303), Plant Held for Future Use (105), Fuel Stock (151, 152), Working Capital – Mining related (25316, 25317, 25319), Materials and Supplies (154), Prepayments – Mining related (165), Misc. Regulatory Assets – Mining Related (182M), Misc. Deferred Debits – Mining related (186M), Accounts Payable (232), Other Deferred Credits Misc. (25330, 230, 25399), ARO Regulatory Liability (254105), SO Emissions (25398), Regulatory Liabilities (254), Accumulated Deferred Income Taxes (190, 282-283), General Plant Accumulated Depreciation 108GP, Accumulated Provision for Amortization (111IP, 111MP) Accounts using SE factor after Interim period: System Control & Load Dispatch (556), Other Expenses (557), Transmission of Electricity by Others - GRID Management Charge (565) System Generation Factor (“SG”) – Effective during the Interim Period 𝑆𝑆𝑆𝑆𝑖𝑖= 0.75 ∗𝑆𝑆𝐴𝐴𝑖𝑖+ 0.25 ∗𝑆𝑆𝐵𝐵𝑖𝑖 where: SGi = System Generation Factor for jurisdiction i. SCi = System Capacity Factor for jurisdiction i. SEi = System Energy Factor for jurisdiction i. The SG factor is used to allocate generation and transmission costs. It is calculated using a weighting of 75% of the SC factor and 25% of the SE factor for a jurisdiction. Accounts using the SG factor: Sales for Resale (447), Provision for Rate Refund (449), Other Electric Operating Revenue (453, 454 ,456), Miscellaneous Revenue (41160, 41170, 421), Generation Expense (500, 502, 504-514, 517-532, 535-545, 546, 548-554, 555, 556, 557), Transmission Expense (560-564, 566-573, 565), Administrative and General Expense (920-935), Depreciation Expense (403SP, 403NP, 403HP, 403OP, 403TP, 403GP), Amortization Expense (404SP, 404HP, 404IP 406, 407), Taxes Other Than Income (408), Deferred Income Tax Expense, (41010, 41110), Schedule M, Renewable Energy Tax Credit (40911), Federal Income Tax True-Up (40910), Generation Plant (310-316, 320-325, 330-336, 340- 346), Transmission Plant (350-359), General Plant (389-398, 1011390), Intangible Plant (302-303), Plant Held for Future Use (105), Electric Plant Acquisition Adjustments (114-115), Materials and Supplies (154), Working Capital Deposit (25318), Prepayments (165), Misc. Regulatory Assets (182M), Misc. Deferred Debits (186M), Working Capital (135, 232), Accumulated Misc. Operating Provision Other (22841), Customer Advances for Construction (252), Other Deferred Debits (25399), Accumulated Deferred Income Taxes (190, 281-283), Accumulated Investment Tax Credit (255), Accumulated Depreciation (108SP, 108HP, 108OP, 108TP, 108GP), Accumulated Provision for Amortization (111SP, 111GP, 111HP, 111IP, 111390) EXECUTION VERSION 2020 Protocol - Appendix C 8 System Generation Factor – Fixed (“SGF”) – Effective after Interim Period Based on actual SG allocation factors for the most recent four calendar years available prior to the end of the Interim Period. The SGi factor is as defined above.) 𝑆𝑆𝑆𝑆𝑆𝑆𝑖𝑖=PY1𝑆𝑆𝑆𝑆𝑖𝑖+ PY2𝑆𝑆𝑆𝑆𝑖𝑖+ PY3𝑆𝑆𝑆𝑆𝑖𝑖+ PY4𝑆𝑆𝑆𝑆𝑖𝑖4where: SGFi = System Generation – Fixed Factor for jurisdiction i. Prior Year (PY) 1 SGi = PY1 System Generation Factor for jurisdiction i. Prior Year (PY) 2 SGi = PY2 System Generation Factor for jurisdiction i. Prior Year (PY) 3 SGi = PY3 System Generation Factor for jurisdiction i. Prior Year (PY) 4 SGi = PY4 System Generation Factor for jurisdiction i. For Example: If the Interim Period ends December 31, 2023, then (PY) 1 = calendar year 2022, (PY) 2 = calendar year 2021, (PY) 3 = calendar year 2020, and (PY) 4 = calendar year 2019. Accounts using SGF factor: Intangible Plant (303), Misc. Regulatory Assets (182M), Misc. Deferred Debits (186M), Working Capital (232), Accumulated Investment Tax Credit (255) System Gross Plant Distribution Factor (“SGPD”) – Effective after Interim Period 𝑆𝑆𝑆𝑆𝐴𝐴𝐵𝐵𝑖𝑖= 𝑆𝑆𝐴𝐴𝐵𝐵𝑖𝑖∑𝑆𝑆𝐴𝐴𝐵𝐵𝑖𝑖𝑁𝑁𝑖𝑖=1where: SGPDi = System Gross Plant Distribution Factor for jurisdiction i. GPDi = Gross plant distribution for jurisdiction i. N = Number of jurisdictions. This factor is calculated by taking the ratio of gross distribution plant for a jurisdiction by the total gross distribution plant for all jurisdictions. There are no accounts allocated using the SGPD factor. This factor is used to calculate the SO factor after the Interim period. System Net Plant - Distribution Factor (“SNPD”) 𝑆𝑆𝐶𝐶𝐴𝐴𝐵𝐵𝑖𝑖=𝐴𝐴𝐵𝐵𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝐵𝐵𝑖𝑖∑(𝐴𝐴𝐵𝐵𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝐵𝐵𝑖𝑖)𝑁𝑁𝑖𝑖=1where: SNPDi = System Net Plant – Distribution Factor for jurisdiction i. PDi = Distribution plant – for jurisdiction i. ADPDi = Accumulated depreciation distribution plant - for jurisdiction i. N = Number of jurisdictions. The SNPD factor is used to allocate non situs distribution costs. The factor is calculated as the ratio of net distribution plant for a jurisdiction by the total net distribution plant for all jurisdictions. EXECUTION VERSION 2020 Protocol - Appendix C 9 Accounts using the SNPD factor: Distribution O&M (580-598), Deferred Income Tax Expenses (41010, 41110), Schedule M, Materials and Supplies – Distribution (154), Accumulated Deferred Income Taxes (190) System Net Plant Factor (“SNP”) 𝑆𝑆𝐶𝐶𝐴𝐴𝑖𝑖=𝐴𝐴𝐴𝐴𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝑆𝑆𝑖𝑖+𝐴𝐴𝐶𝐶𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝐴𝐴𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝐵𝐵𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝐵𝐵𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝑆𝑆𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝐶𝐶𝑖𝑖∑(𝐴𝐴𝐴𝐴𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝑆𝑆𝑖𝑖+𝐴𝐴𝐶𝐶𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝐴𝐴𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝐵𝐵𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝐵𝐵𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝑆𝑆𝑖𝑖+ 𝐴𝐴𝐵𝐵𝐴𝐴𝐶𝐶𝑖𝑖)𝑁𝑁𝑖𝑖=1 where: SNPi = System Net Plant Factor for jurisdiction i. PPi = Production plant for jurisdiction i. PTi = Transmission plant for jurisdiction i. PDi = Distribution plant for jurisdiction i. PGi = General plant for jurisdiction i. PIi = Intangible plant for jurisdiction i. ADPPi = Accumulated depreciation production plant for jurisdiction i. ADPTi = Accumulated depreciation transmission plant for jurisdiction i. ADPDi = Accumulated depreciation distribution plant for jurisdiction i. ADPGi = Accumulated depreciation general plant for jurisdiction i. ADPIi = Accumulated depreciation intangible plant for jurisdiction i. N = Number of jurisdictions. The SNP factor is used to allocate interest expense and miscellaneous deferred tax treatment. The factor is calculated by taking the ratio of the system net plant balance for a jurisdiction divided by the total system net plant balance for all jurisdictions. Accounts using SNP factor: Interest Expense (427-429, 431, 432), Deferred Income Tax Expenses (41010, 41110), Schedule M, Working Capital – Cash (131), Accumulated Deferred Income Taxes (190, 282, 283) System Overhead Factor (“SO”) – Effective after Interim Period 𝑆𝑆𝐴𝐴𝑖𝑖= 𝑆𝑆𝐴𝐴𝑖𝑖+𝑆𝑆𝐵𝐵𝑖𝑖+𝑆𝑆𝑆𝑆𝐴𝐴𝐵𝐵𝑖𝑖3 where: SOi = System Overhead Factor for jurisdiction i. SCi = System Capacity Factor for jurisdiction i. SEi = System Energy Factor for jurisdiction i. SGPDi = System Gross Plant Distribution for jurisdiction i. The SO factor is used to allocate system overhead costs. The SO factor used after the Interim period is calculated by taking the sum of the SC, SE and SGPD factor for a jurisdiction and dividing by three. Accounts using SO factor after Interim period: Other Electric Operating Revenue (451, 454, 456), Miscellaneous Revenue (41160, 41170, 421), Administrative and General Expense (920-935), Depreciation Expense (403GP), Amortization Expense (404GP, 404IP), Deferred Income Tax Expenses (41010, 41110), Schedule M, Federal Income Tax True-Up (40910), General Plant (389-398, 1011390), Intangible Plant (303), Materials and Supplies (154), Stores Expense Undistributed (163), Prepayments (165), Misc. Regulatory Assets (182M), Misc. Deferred Debits (186M), Working Capital (141, 232), Rate Base Deduction Provisions (2281-2283), Other Deferred Credits (25399), Regulatory Liabilities (254), EXECUTION VERSION 2020 Protocol - Appendix C 10 Accumulated Deferred Income Taxes (190, 282, 283), Accumulated Depreciation (108GP, 1081390), Accumulated Provision for Amortization (111GP, 111IP) System Overhead Factor (“SO”) – Effective during the Interim Period 𝑆𝑆𝐴𝐴𝑖𝑖=𝐴𝐴𝐴𝐴𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝑆𝑆𝑖𝑖+𝐴𝐴𝐶𝐶𝑖𝑖−𝐴𝐴𝐴𝐴𝑜𝑜𝑖𝑖−𝐴𝐴𝐵𝐵𝑜𝑜𝑖𝑖−𝐴𝐴𝐵𝐵𝑜𝑜𝑖𝑖−𝐴𝐴𝑆𝑆𝑜𝑜𝑖𝑖−𝐴𝐴𝐶𝐶𝑜𝑜𝑖𝑖∑(𝐴𝐴𝐴𝐴𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝐵𝐵𝑖𝑖+𝐴𝐴𝑆𝑆𝑖𝑖+𝐴𝐴𝐶𝐶𝑖𝑖−𝐴𝐴𝐴𝐴𝑜𝑜𝑖𝑖−𝐴𝐴𝐵𝐵𝑜𝑜𝑖𝑖−𝐴𝐴𝐵𝐵𝑜𝑜𝑖𝑖−𝐴𝐴𝑆𝑆𝑜𝑜𝑖𝑖−𝐴𝐴𝐶𝐶𝑜𝑜𝑖𝑖)𝑁𝑁𝑖𝑖=1where: SOi = System Overhead Factor for jurisdiction i. PPi = Gross production plant for jurisdiction i. PTi = Gross transmission plant for jurisdiction i. PDi = Gross distribution plant for jurisdiction i. PGi = Gross general plant for jurisdiction i. PIi = Gross intangible plant for jurisdiction i. PPoi = Gross production plant for jurisdiction i allocated on a SO factor. PToi = Gross transmission plant for jurisdiction i allocated on a SO factor. PDoi = Gross distribution plant for jurisdiction i allocated on a SO factor. PGoi = Gross general plant for jurisdiction i allocated on a SO factor. PIoi = Gross intangible plant for jurisdiction i allocated on a SO factor. N = Number of jurisdictions. The SO factor is used to allocate system overhead costs. The SO factor used during the Interim period is calculated by taking the gross plant allocated to a jurisdiction, excluding the plant amounts allocated on SO, and dividing it by the total gross plant for all jurisdictions, excluding plant amounts allocated on SO, for all jurisdictions. Accounts using SO factor during the Interim period: Other Electric Operating Revenue (451, 454, 456), Miscellaneous Revenue (41160, 41170, 421), Administrative and General Expense (920-935), Depreciation Expense (403GP), Amortization Expense (404GP, 404IP), Deferred Income Tax Expenses (41010, 41110), Schedule M, Federal Income Tax True-Up (40910), General Plant (389-398, 1011390), Intangible Plant (303), Materials and Supplies (154), Stores Expense Undistributed (163), Prepayments (165), Misc. Regulatory Assets (182M), Misc. Deferred Debits (186M), Working Capital (141, 232), Rate Base Deduction Provisions (2281-2283), Other Deferred Credits (25399), Regulatory Liabilities (254), Accumulated Deferred Income Taxes (190, 282, 283), Accumulated Depreciation (108GP, 1081390), Accumulated Provision for Amortization (111GP, 111IP) System Transmission Factor (“ST”) – Effective after Interim Period 𝑆𝑆𝐵𝐵𝑖𝑖= 75%∗𝑆𝑆𝐴𝐴𝑖𝑖+25%∗𝑆𝑆𝐵𝐵𝑖𝑖 where: STi = System Transmission Factor for jurisdiction i. SCi = System Capacity Factor for jurisdiction i. SEi = System Energy Factor for jurisdiction i. The ST factor is used to allocate transmission related costs after the Interim period. It is calculated using a weighting of 75% of the SC factor and 25% of the SE factor for a jurisdiction. Accounts using ST factor: Provision for Rate Refund (449), Operating Revenue (454), Other Electric Revenue (456), Miscellaneous Revenue (41160, 41170, 421), Transmission Expense (560-564, 566-573), EXECUTION VERSION 2020 Protocol - Appendix C 11 Transmission of Electricity by Others (565), Administrative & General Expense (920-935), Depreciation Expense (403TP, 403GP), Amortization Expense (404IP, 407), Deferred Income Tax Expenses (41010, 41110), Schedule M, Transmission Plant (350-359), General Plant (389-398, 1011390), Intangible Plant (302, 303), Plant Held for Future Use (105), Electric Plant Acquisition Adjustments (114-115), Material and Supplies (154), Prepayments (165), Misc. Regulatory Assets (182M), Misc. Deferred Debits (186M), Working Capital (232), Customer Advances for Construction (252), Other Deferred Credits (25399), Accumulated Deferred Income Taxes (190, 281-283), Accumulated Depreciation (108TP, 108GP), Accumulated Provision for Amortization (111TP, 111GP, 111IP) Tax Depreciation Factor (“TAXDEPR”) 𝐵𝐵𝐴𝐴𝑇𝑇𝐵𝐵𝐵𝐵𝐴𝐴𝐷𝐷𝑖𝑖=𝐵𝐵𝐴𝐴𝑇𝑇𝐵𝐵𝐵𝐵𝐴𝐴𝐷𝐷𝐴𝐴𝑖𝑖∑𝐵𝐵𝐴𝐴𝑇𝑇𝐵𝐵𝐵𝐵𝐴𝐴𝐷𝐷𝐴𝐴𝑖𝑖𝑁𝑁𝑖𝑖=1 where: TAXDEPRi = Tax Depreciation Factor for jurisdiction i. TAXDEPRAi = Tax depreciation allocated to jurisdiction i. (Tax depreciation is allocated based on functional pre-merger and post-merger splits of plant using Divisional and System allocations from above. Each jurisdiction’s total allocated portion of tax depreciation is determined by its total allocated ratio of these functional pre- and post-merger splits to the total Company tax depreciation.) N = Number of jurisdictions. The TAXDEPR factor allocates depreciation related tax costs. Accounts using TAXDEPR: Deferred Income Tax Expense (41010) Schedule M, Accumulated Deferred Income Taxes (282) Trojan Decommissioning Factor (“TROJD”) 𝐵𝐵𝐷𝐷𝐴𝐴𝑇𝑇𝐵𝐵𝑖𝑖=𝐴𝐴𝐴𝐴𝐴𝐴𝐵𝐵22842𝑖𝑖∑𝐴𝐴𝐴𝐴𝐴𝐴𝐵𝐵22842𝑖𝑖𝑁𝑁𝑖𝑖=1 where: TROJDi = Trojan Decommissioning Factor for jurisdiction i. ACCT22842i = Allocated adjusted balance in FERC Account 228.42 (Accumulated Provision for Decommissioning Trojan) for jurisdiction i. N = Number of jurisdictions. The TROJD factor is used to allocate decommissioning related costs associated with the Trojan plant. Accounts using TROJD: Deferred Income Tax Expenses (41010, 41110), Schedule M, FAS 143 ARO Regulatory Liability – Trojan Plant (254105), Asset Retirement Obligation – Trojan Plant (230), Accumulated Deferred Income Taxes (190, 283) Trojan Decommissioning Fixed Factor (“TROJDF”) Effective after Interim Period Based on actual TROJD allocation factors for the most recent four calendar years available prior to the end of the Interim Period. (The TROJDi factor is as defined above.) EXECUTION VERSION 2020 Protocol - Appendix C 12 𝐵𝐵𝐷𝐷𝐴𝐴𝑇𝑇𝐵𝐵𝑆𝑆𝑖𝑖=PY1𝐵𝐵𝐷𝐷𝐴𝐴𝑇𝑇𝐵𝐵𝑖𝑖+ PY2𝐵𝐵𝐷𝐷𝐴𝐴𝑇𝑇𝐵𝐵𝑖𝑖+ PY3𝐵𝐵𝐷𝐷𝐴𝐴𝑇𝑇𝐵𝐵𝑖𝑖+ PY4𝐵𝐵𝐷𝐷𝐴𝐴𝑇𝑇𝐵𝐵𝑖𝑖4where: TROJDFi = Trojan Decommissioning– Fixed Factor for jurisdiction i. Prior Year (PY) 1 TROJDi = PY1 Trojan Decommissioning Factor for jurisdiction i. Prior Year (PY) 2 TROJDi = PY2 Trojan Decommissioning Factor for jurisdiction i. Prior Year (PY) 3 TROJDi = PY3 Trojan Decommissioning Factor for jurisdiction i. Prior Year (PY) 4 TROJDi = PY4 Trojan Decommissioning Factor for jurisdiction i. For Example: If the Interim Period ends December 31, 2023, then (PY) 1 = calendar year 2022, (PY) 2 = calendar year 2021, (PY) 3 = calendar year 2020, and (PY) 4 = calendar year 2019.The TROJDF factor is used to allocate decommissioning related costs associated with the Trojan plant. Accounts using TROJDF: Deferred Income Tax Expenses (41010, 41110), Schedule M, FAS 143 ARO Regulatory Liability – Trojan Plant (254105), Asset Retirement Obligation – Trojan Plant (230), Accumulated Deferred Income Taxes (190, 283) EXECUTION VERSION APPENDIX D Nodal Pricing Model Memorandum of Understanding EXECUTION VERSION 2020 Protocol - Appendix E 1 APPENDIX E Coal-Fueled Interim Period Resource Depreciation Lives Unit In Service Depreciation Depreciation Capacity (MW) Physical Location OR Other States PP States (1) RMP States Lives Addressed by Section 4.1.3.1 (1) The life of coal plants for Washington is addressed in Section 4.1.4. EXECUTION VERSION APPENDIX F Washington Inter-Jurisdictional Allocation Methodology Memorandum of Understanding The Washington Inter-Jurisdictional Allocation Methodology Memorandum of Understanding Introduction PacifiCorp d/b/a Pacific Power and Light Company (PacifiCorp or Company), Staff of the Washington and Utilities and Transportation Commission (Staff), Public Counsel Unit of the Washington State Attorney General’s Office (Public Counsel) and Packaging Corporation of America (PCA), have executed this agreement (the Parties or, individually, a Party) enter into this Memorandum of Understanding (Agreement) to acknowledge their support for certain adjustments to the West Control Area Inter-Jurisdictional Allocation Methodology (WCA). Background PacifiCorp is a multi-jurisdictional electric utility that provides services in six states (California, Idaho, Oregon, Utah, Wyoming, and Washington). Staff is participating in PacifiCorp’s Multi- State Process (MSP), working towards the Company’s goal of developing a common cost allocation methodology amongst these six states. Currently, Washington uses the WCA for determining which costs are eligible for recovery in rates from customers in Washington.1 As approved by the Washington Utilities and Transportation Commission (Commission), the WCA isolates the costs and revenues associated with assets located in the Company’s west “control area” or “PacifiCorp West Balancing Authority Area” (PACW), and allocates to Washington a proportionate share of the costs and revenues based primarily on Washington’s relative contribution to demand and energy requirements. The WCA includes loads, generation and transmission assets, and wholesale contracts for facilities located in California, Oregon, and Washington. It also includes transmission and generation assets located outside of California, Oregon, and Washington that are electrically located in PACW. The WCA excludes all loads and assets located within PacifiCorp’s East Balancing Authority Area (PACE). In the context of inter-jurisdictional cost allocation, the Commission will consider a resource to be used and useful to Washington customers2 if the resource “provides quantifiable direct or indirect benefits to Washington [ratepayers] commensurate with its costs.”3 To modify the WCA methodology, “any changes should be considered in the context of an overall review of that methodology.”4 Additionally, Parties must demonstrate that “any changes proposed more closely aligns with the allocation of costs based on causation[.]”5 Finally, “the party advocating for the change must make a detailed a persuasive showing demonstrating that the proposed change is appropriate.”6 1 Prior to the WCA methodology being approved in Docket UE-061546, PacifiCorp proposed the Revised Protocol as its cost allocation methodology in Docket UE-050684. The Revised Protocol presented costs as an integrated six-state system. The Commission rejected the Revised Protocol because there was not sufficient evidence in the record that the methodology complied with the legal requirements in RCW 80.04.250. See generally UE-050684, Order 04. 2 See RCW 80.04.250 3 Docket UE-050684, Order 04 ¶ 68. 4 Docket UE-130043, Order 05 ¶ 92–94. 5 Id. 6 Id. 2020 Protocol - Appendix F 1 The Washington Inter-Jurisdictional Allocation Methodology Memorandum of Understanding, Page 2 of 7 Foundation for this Agreement In this memorandum of understanding, the Parties agree to support certain modifications to the WCA in the Company’s forthcoming rate case provided the Company can demonstrate that the modifications within this agreement provide beneficial resources to Washington customers that are used and useful. In particular, the Parties agree to support these modifications if PacifiCorp can demonstrate these modifications provide quantifiable direct or indirect benefits to Washington customers, and that these benefits are commensurate with their costs.7 The Parties agree to work collaboratively with PacifiCorp as they make this demonstration. However, as the party advocating for these changes, PacifiCorp bears the legal and factual burden to sufficiently demonstrate that these modifications better align the cost allocation methodology with the principles described above in its forthcoming general rate case. This demonstration may include the following benefits: •A diverse generation portfolio, including an increase in high capacity renewablegeneration. •Over 170 interconnections with other BAAs and transmission operators providing accessto market hubs for wholesale energy transactions (e.g., Mid-C, COB, Mona, Four-Corners and Palo Verde). •Greater Energy Imbalance Market (EIM) benefits. •Efficiencies, such as retail load characteristics and variable resource diversity, whichminimize operational costs and reduce the need to build for reserves and blackstartcapability for each state. •Washington recently enacted Senate Bill 5116, the Clean Energy Transformation Act (CETA) which, among other things, requires the elimination of coal-fired resources fromPacifiCorp's electric rates by December 31, 2025. PacifiCorp’s proposed modification tothe WCA will facilitate a reasonable path towards PacifiCorp’s compliance with CETA.8 Based on this understanding, the Parties agree to the following: Agreement 1.Implementation. This Agreement includes modifications to the WCA subject to approval by the Commission. 7 The Commission has stated that one way the Company can demonstrate this is “through historical system operation or modeling of the system showing that Eastside plant costs added to Washington rates would be offset by reductions to other cost categories (e.g., power costs), such that overall costs to Washington ratepayers would be no more than without the Eastside resources.” Docket UE-050684, Order 04 ¶ 69 (emphasis added). 8 CETA also sets a policy of 100 percent clean energy by 2045. RCW 19.405.050. Additionally, CETA establishes an interim target of 100 percent greenhouse gas (GHG) neutral by 2030, and allows utilities to meet this requirement through 80 percent non-emitting energy and an alternative compliance option, including up to 20 percent unbundled renewable energy credits. RCW 19.405.040. 2020 Protocol - Appendix F 2 The Washington Inter-Jurisdictional Allocation Methodology Memorandum of Understanding, Page 3 of 7 1.1. PacifiCorp will file a rate case that allows for rates to go into effect (after suspension) on or before January 1, 2021. This rate case will use this MOU as the basis for any proposed modifications to the WCA. 2.Prudence. The proposed allocation of a particular expense or investment under thisAgreement is not intended to and will not prejudge, or prevent any party from taking aposition on, the prudence of those costs or the extent to which any particular cost may be reflected in rates. Nothing in this Agreement is intended to abrogate the Commission’s right or obligation to: (1) determine fair, just, and reasonable rates based upon applicablelaws and the record established in rate proceedings conducted by the Commission; (2)consider the impact of changes in laws, regulations, or circumstances on inter-jurisdictional allocation policies and procedures when determining fair, just, and reasonable rates; or (3) establish different allocation policies and procedures for purposesof allocating costs and revenues to different customers or customer classes. 3.Quantification and Analytical Support. The Parties agree to work collaboratively andin good faith to agree on the quantification and analytical support necessary for the Company to meet its legal and factual burden. 3.1. This analysis should be substantially completed before the filing of the general ratecase referenced in section 1.1 and with enough time to reasonably allow parties to review the analysis. 3.2. Before the general rate case referenced in section 1.1 is filed, if a Party determines that the Company’s quantification and analytical support does not demonstrate that the Company can meet its legal and factual burden, Parties have the option to withdraw their support from this agreement. 3.3. After the general rate case referenced in section 1.1 is filed, if a Party determines that this agreement does not result in fair, just and reasonable rates for Washington customers, a party may withdraw from this agreement. The withdrawing Party must provide testimony in the general rate case explaining why this agreement does not result in fair, just and reasonable rates for Washington Customers. 3.4. In the event of a Party’s withdrawal, the remaining Parties may continue to support this Agreement for approval in any proceeding before the Commission. 4.System Transmission. The Parties agree that all existing system transmission9 costs and benefits will be allocated using the System Generation (SG) factor as specified inAttachment 1. 4.1. Rate Impacts: To mitigate the immediate overall rate impact to Washington customers in the rate case referenced in Section 1.1, Parties agree to support the framework of the following phase-in approach: 9 Existing transmission includes any transmission asset that is in service as of December 31, 2019. 2020 Protocol - Appendix F 3 The Washington Inter-Jurisdictional Allocation Methodology Memorandum of Understanding, Page 4 of 7 4.1.1. An incremental allocation of one-third of existing transmission costs and benefits, which are not currently allocated to Washington under the current WCA methodology, will be included in the rate case referenced in Section 1.1. 4.1.2. An incremental allocation of an additional one-third of existing transmission costs and benefits, which are not currently allocated to Washington, will be included in a separate tariff rider with a rate effective date on or before January 1, 2022. 4.1.3. An incremental allocation of an additional one-third of existing transmission costs and benefits, which are not currently allocated to Washington, will be included in a general rate case or through an amendment to the separate tariff rider set forth in Section 4.1.2 with a rate effective date on or before January 1, 2023. 4.1.3.1. The incremental allocation in 4.1.3 will exclude the costs and benefits of all transmission-voltage, radial lines connecting resources not otherwise included in Washington rates to PacifiCorp’s interconnected, network transmission system. If PacifiCorp is required to include a portion of a transmission line in its interconnected, network transmission system for open access transmission service due to a subsequent generation or load interconnection, PacifiCorp may request to include such portion of the assets in a subsequent rate case. 4.1.4. The separate tariff rider described above will remain in place until the fully allocated cost of transmission costs as described in Section 4 is included in rates through a general rate case. 4.2. New Transmission. Any new transmission10 incremental to the existing transmission described and included in Section 3, will be system-allocated using the SG factor as specified in Attachment 1. 4.2.1. Similar to the methodology outlined in 4.1.3.1, Transmission which can be demonstrated to be used primarily for the transmission of power from generation assets which are not assigned to Washington under the WCA, as modified by this Agreement, will be excluded from this and any other allocation to Washington. 4.3. Analytical Support. As a part of the analytical support in Section 4, the Company will quantify the differences between total depreciation and ADIT balances using a WCA Allocation of transmission and the system allocation above. 10 “New” shall constitute assets used and useful for Washington customers after December 31, 2019. 2020 Protocol - Appendix F 4 The Washington Inter-Jurisdictional Allocation Methodology Memorandum of Understanding, Page 5 of 7 5.Non-Emitting Resources. The Parties agree that all existing and new non-emittingresources will be dynamically allocated using the SG Factor specified in Attachment 1. 5.1. Assignment. If by December 31, 2023, none of the Parties to this agreement have signed a new cost allocation methodology with the Company, then the Company agrees to engage in collaborative conversations with the Parties and other interested Washington stakeholders to explore the following: 5.1.1. An Assignment method for new resources for the purposes of the WCA; and, 5.1.2. A methodology to allocate fixed shares of existing non-emitting resources. 6.Net Power Costs (NPC). Forecasted NPC for ratemaking purposes will be consistentwith Sections 1,4,5,6, and 7 of this agreement. Additionally, Washington customers will receive all direct and indirect benefits associated with their proportional system-allocated share of existing transmission, including Energy Imbalance Market benefits. 6.1. Actual NPC. Actual NPC for ratemaking purposes will include only the generationresources included in Washington rates and will be calculated using a spreadsheet. 6.2. Qualifying Facilities. The costs and benefits of Power Purchase Agreements for Qualifying Facilities (QF PPAs) will continue to be situs assigned to the state having jurisdiction over the QF PPA for cost responsibility, renewable energy credit assignment and resource planning. 7.Accelerated Depreciation. PacifiCorp and Staff agree to support a final depreciationdate of December 31, 2023, for Bridger Units 1-4, Colstrip 4 and any transmission assetsassociated solely with the interconnection of these units to the transmission network. Thisdate does not represent a date of estimated closure, changes in operations, or the end of the assignment to Washington of either benefits or costs associated with these plants.Public Counsel and PCA reserve the right to make a recommendation on the depreciationfor Bridger Units 1-4, Colstrip, and any transmission assets associated solely with theinterconnection of these units to the transmission network in PacifiCorp’s forthcominggeneral rate case. 7.1. Capital Investments. Washington will continue to be allocated a WCA share ofongoing capital investments expenses for these plants, excluding incremental capital investments that are made primarily for the purpose of extending the life of these plants. Incremental capital investments that are made primarily for the purpose of extending the life of these plants includes, but is not limited to, those associated with achieving compliance with environmental requirements or those necessitated by catastrophic failure. 7.2. Deadline for Removal. Consistent with RCW 19.405.030, PacifiCorp will remove from Washington rates all costs and benefits associated with Bridger units 1-4 and Colstrip unit 4 no later than December 31, 2025. 2020 Protocol - Appendix F 5 The Washington Inter-Jurisdictional Allocation Methodology Memorandum of Understanding, Page 6 of 7 7.3. Resource Flexibility. The dates articulated in this section are agreed upon by parties to facilitate the removal of coal from Washington Rates by 2025, and provide the flexibility that may allow for early compliance with CETA. 8. Decommissioning Cost. Washington will continue to be allocated ongoing and expecteddecommissioning expenses for a WCA share of Jim Bridger Units 1-4 and Colstrip Unit4. 8.1. Colstrip Engineering Study. The Company will provide by March 30, 2020, an independent engineering study of estimated decommissioning costs for Colstrip. 8.2. Jim Bridger Engineering Study. The Company will provide by January 15, 2020, an independent engineering study of estimated decommissioning costs for Jim Bridger. 8.3. Cost Assignment. To facilitate the allocation of decommissioning costs, Parties agree to support a system allocation of the costs associated with an independent engineering study in 8.1 and 8.2. 9.This agreement proposes modifications to the WCA, which serves as the basis forallocating costs in Washington. PacifiCorp will allocate costs based on the WCAconsistent with the modifications in this Agreement for ratemaking purposes inWashington unless a different cost allocation method is approved by the Commission. 10.Each Party to this Agreement represents that they are signing this Agreement in goodfaith and that they intend to abide by the terms of this Agreement. 11.This Agreement may be executed in counterparts and each signed counterpart constitutes an original document. 12.Attachment 1 contains updated allocation factors consistent with this Agreement. 13.This Agreement is entered into by each Party on the date entered below such Party's signature. 2020 Protocol - Appendix F 6 The Washington Inter-Jurisdictional Allocation Methodology Memorandum of Understanding, Page 7 of 7 PACIFICORP By: Title: ____________________________ STAFF OF THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION By: Title: ____________________________ PUBLIC COUNSEL By: Title: ____________________________ Date: PACKAGING CORPORATION OF AMERICA By: Title: ____________________________ Date: 2020 Protocol - Appendix F 7 2020 Protocol - Appendix F 8 2020 Protocol - Appendix F 9 Assistant Attorney General 11/21/2019 EXECUTION VERSION 2020 Protocol - Appendix G 1 APPENDIX G Special Contracts Special Contracts without Ancillary Service Contract Attributes For allocation purposes, Special Contracts without identifiable Customer Ancillary Service attributes are viewed as one transaction. Loads of Special Contract customers will be included in all Load-Based Dynamic Allocation Factors. When interruptions of a Special Contract customer’s service occur, the reduction in load will be reflected in the host jurisdiction’s Load-Based Dynamic Allocation Factors. Actual revenues received from Special Contract customer will be assigned to the State where the Special Contract customer is located. See example in Table 1. Special Contracts with Customer Ancillary Service Attributes For allocation purposes, Special Contracts with Customer Ancillary Service attributes are viewed as two transactions. PacifiCorp sells the customer electricity at the retail service rate and then buys the electricity back during the interruption period at the Customer Ancillary Service Contract’s rate. Loads of Special Contract customers will be included in all Load-Based Dynamic Allocation Factors. When interruptions of a Special Contract customer’s service occur, the host jurisdiction’s Load-Based Dynamic Allocation Factors and the retail service revenue are calculated as though the interruption did not occur. Revenues received from Special Contract customer, before any discounts for Customer Ancillary Services attributes of the Special Contract, will be assigned to the State where the Special Contract customer is located. Discounts from tariff prices provided for in Special Contracts that recognize the Customer Ancillary Services attributes of the Contract, and payments to retail customers for Customer Ancillary Services will be allocated among States on the same basis as System Resources. See example in Table 2. EXECUTION VERSION 2020 Protocol - Appendix G 2 Buy-through of Economic Curtailment When a buy-through option is provided with economic curtailment, the load, costs, and revenue associated with a customer buying through economic curtailment will be excluded from the calculation of State revenue requirements. The cost associated with the buy- through will be removed from the calculation of net power costs, the Special Contract customer load associated with the buy-through will be not be included in the calculation of Load-Based Dynamic Allocation Factors, and the revenue associated with the buy-through will not be included in State revenues.