20200909Notice_of_Modified_Procedure_Order_No_34773.pdf

NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34773 1
Office of the Secretary
Service Date
September 9, 2020
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF ROCKY MOUNTAIN
POWER’S APPLICATION FOR
AUTHORIZATION TO CHANGE
DEPRECIATION RATES FOR ELECTRIC
PROPERTY
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CASE NO. PAC-E-18-08

NOTICE OF
MODIFIED PROCEDURE

ORDER NO. 34773

On September 11, 2018, Rocky Mountain Power, a division of PacifiCorp
(“Company”) asked the Commission to approve the Company’s proposed changes to depreciation
rates for its electric plant. The Commission approved the Company’s last depreciation request,
Case No. PAC-E-13-02, in 2013. See Order No. 32926.
On October 5, 2018, the Commission issued a Notice of Application and Notice of
Intervention Deadline directing Staff and parties to discuss scheduling.
Monsanto, PacifiCorp Idaho Industrial Customers (“PIIC”), Idaho Irrigation Pumpers
Association, Inc., (“IIPA”), Sierra Club, and Idaho Conservation League (“ICL”) (collectively the
“Parties”) intervened.
On April 18, 2019, a technical conference was held in Boise, followed by meetings and
conference calls where the Parties discussed settlement possibilities.
On January 17, 2020, the Company filed a supplemental confidential decommissioning
study pursuant to Section 4.3.1.1 of the 2020 PacifiCorp Inter-Jurisdictional Allocation Protocol.1
On March 16, 2020, the Company filed a second supplemental confidential
decommissioning study that included decommissioning costs for the Colstrip plant. (Collectively,
the supplemental decommissioning studies filed on January 17, 2020 and March 16, 2020 are
referred to as the “2020 Decommissioning Studies.”)
On June 15, 2020, the Company filed a proposed Settlement Stipulation (“Settlement
Stipulation”) for Phase I2 signed by the Company, Staff, Monsanto, PIIC, and IIPA (collectively
the “Stipulating Parties”)3. In the Settlement Stipulation, the Stipulating Parties also requested the

1 In Section 4.3.1.1 of the 2020 Inter-Jurisdictional Allocation Protocol, the Company agreed to file the results of the
contractor-assisted engineering study of decommissioning costs for the Jim Bridger, Dave Johnston, Hunter,
Huntington, Naughton, Wyodak, and Hayden coal plants in all applicable depreciation dockets.
2 Phase I resolved all depreciation issues except decommissioning costs.
3 ICL is not a Stipulating Party but does not oppose the Settlement Stipulation.

NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34773 2
Commission establish a Phase II to facilitate further review of the regulatory treatment of the
incremental decommissioning costs.4 The Stipulating Parties noted they would attempt to complete
Phase II in time to allow the Commission to issue a final order before December 31, 2020.
On August 18, 2020, the Commission issued a final order for Phase I, approving the
settlement stipulation which resolves all depreciation related issues except incremental
decommissioning costs and authorized Phase II. See Order No. 34754.
On August 19, 2020, the Parties met to discuss issues reserved for Phase II and
proposed scheduling. The Parties agreed to work towards a proposed settlement agreement on the
incremental decommissioning costs. The Parties agreed to discuss incremental decommissioning
costs at a September 22, 2020 settlement meeting. The Parties also agreed that if they do not settle,
they would submit comments on the Company’s proposed ratemaking treatment for incremental
decommissioning costs—which the Company filed subsequently on August 31, 2020—pursuant
to comment deadlines established by the Commission. The Parties further agreed Phase II should
be processed by Modified Procedure.
As noted above, on August 31, 2020, the Company proposed a ratemaking treatment
of the incremental decommissioning costs. The proposal summarized the differences between the
decommissioning costs in the 2018 depreciation study and the 2020 Decommissioning Studies.
The differences include scope, methodology, estimate class, assumptions for environmental
liabilities, owner’s costs, contractor indirect costs, and site reclamation costs. The Company
proposed to defer $2,291,178–Idaho’s allocation of incremental decommissioning costs during
calendar year 2021. The Company proposed to begin collecting the deferred amount on the
effective date of the Company’s next general rate case, within which the amortization period to
recover the deferral would be determined. The Company seeks to align the amortization of
incremental decommissioning costs with the new depreciation rates authorized by Order No.
34754. The Company’s proposal and the 2020 Decommissioning Studies will serve as a basis for
the Parties settlement discussions.

4 The incremental decommissioning costs are the decommissioning costs filed in the 2018 Depreciation Study
compared to the costs in the 2020 Decommissioning Studies.

NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34773 3
On September 1, 2020, at the Commission’s decision meeting, Staff informed the
Commission that, on September 22, 2020 Staff planned to discuss with the Parties the possible
settlement of Phase II incremental decommissioning costs.
At the same meeting, Staff asked the Commission to issue a Notice of Modified
Procedure establishing comment and reply deadlines. Staff also notified the Commission of the
Company’s proposal filed on August 31, 2020.
The Commission now issues this Notice of Modified Procedure establishing public
comment and reply deadlines.
NOTICE OF MODIFIED PROCEDURE
YOU ARE HEREBY NOTIFIED that the Commission has determined that the public
interest may not require a formal hearing in this matter and it will review Phase II through written
submissions under the Commission’s Rules of Modified Procedure. Rules 201 through 204 of the
Idaho Public Utilities Commission’s Rules of Procedure, IDAPA 31.01.01.201-204. The
Commission notes that Modified Procedure and written comments have proven to be an effective
means for obtaining public input and participation.
YOU ARE FURTHER NOTIFIED that persons desiring to state a position on this
matter may file a written comment explaining why the person supports or opposes the incremental
decommissioning costs proposed in Phase II. Persons who would like a hearing must specifically
request a hearing in their written comments. Persons shall have until October 14, 2020, to file
written comments. Comments must be filed by e-mail unless e-mail is unavailable. To comment
by e-mail, please access the Commission’s home page at www.puc.idaho.gov. Click the
“Consumers” tab and then “Case Comment Form” and complete the form using the case number
as it appears on the front of this document. Comments filed by e-mail must also be e-mailed to the
Company at the e-mail addresses listed below. If e-mail is unavailable, then comments may be
mailed to the Commission and Company at these addresses:
For the Idaho PUC:

Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

For Rocky Mountain Power:

Ted Weston
Emily Wegener
1407 W. North Temple, Suite 320
Salt Lake City, UT 84116
[e-mail]
[e-mail]

NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34773 4
Data Request Response Center
825 NE Multnomah, Suite 2000
Portland, OR 97232
[e-mail]
YOU ARE FURTHER NOTIFIED that the Company must file any reply comments
by October 28, 2020.
YOU ARE FURTHER NOTIFIED that if no written comments or protests are received
within the time limit set, the Commission will consider this matter on its merits and enter its order
without a formal hearing. If written comments are received within the time limit set, the
Commission will consider them and, in its discretion, may set the same for formal hearing.
O R D E R
IT IS HEREBY ORDERED that Phase II be processed by Modified Procedure, Rule
201-204 (IDAPA 31.01.01.201 - .204). Persons shall have until October 14, 2020, to file written
comments, and the Company shall have until October 28, 2020, to file a reply, if any.
IT IS FURTHER ORDERED that Parties continue to comply with Order No. 34602,
issued March 17, 2020. All pleadings should be filed with the Commission electronically and shall
be deemed timely filed when received by the Commission Secretary. See Rule 14.02. Service
between Parties should also be accomplished electronically. Voluminous discovery-related
documents may be filed and served on CD-ROM or a USB flash drive.
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NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34773 5
DONE by order of the Idaho Public Utilities Commission at Boise, Idaho this 9th
day of September 2020.

__________________________________________
PAUL KJELLANDER, PRESIDENT

__________________________________________
KRISTINE RAPER, COMMISSIONER

__________________________________________
ERIC ANDERSON, COMMISSIONER

ATTEST:

_________________________________
Jan Noriyuki
Commission Secretary

I:\Legal\ELECTRIC\PAC-E-18-08\orders\PACE1808_Ntc Mod2_dh.docx