20220218Notice.pdf

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ROCKY MOUNTAIN
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1407 West North Temple, Suite 330
Salt Lake City, UT 84116
February 18,2022
VA ELECTRONIC DELIYERY
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
I l33l W Chinden Blvd.
Building 8, Suite 20lA
Boise,ldaho 83714
Re:CASE NO. PAC.E-19-20
IN THE MATTER OF THE APPLICATION FOR APPROVAL OF THE
2O2O PACIFICORP INTER.JURISDICTIONAL ALLOCATION
PROTOCOL
Idaho Commissioners,
On December 3,2079, Rocky Mountain Power ("Company"), a division of PacifiCorp, applied to the
Idaho Public Utilities Commission ("Commission") for approval of the2020 PacifiCorp Inter-
Jurisdictional Allocation Protocol (*2020 Protocol"). On April 22,2020, the Commission issued
OrderNo. 34640, which approved the2020 Protocol as filed. On December 18,2020, the Public
Utility Commission of Oregon issued exit orders for certain coal-fueled resources.r
Section 4.1 (States' Decision to Exit Interim Period Resources) and Section 4.2 (Reassignment of
Coal-Fueled Interirn Period Resources) of the 2020 Protocol, outline the timeline and process that
will be followed for states to exit a resource and the possible reassignment of that resource to other
states. Specifically, Section 4.2.2 prov ides that:
1) PacifiCorp was to target filing, on or before February 1,2021, state-specific
recommendations to commissions for coal-fueled resources that have a commission-
approved Exit Date that would discontinue a state's allocation of costs and benefits
on or before December 31,2027. The filings would include the Company's analysis
and recommendations for potential reassignment of allocations for those resources.
1 In the matter of PaciJiCorp, dba Pacific Power, Request for a General Rate Revision, Order No. 20-473 at (Dec.
I 8, 2020X"We adopt exit orders for Cholla Unit 4, Jim Bridger Unit I , Craig Units I -2, Naughton Units I -2;
Colstrip Units 3-4; and Dave Johnston Units l-4 with the exit dates proposed by PacifiCorp.... While the2020
Protocol does not require exit orders for Cholla Unit 4, Craig Units l-2, and Colstrip Units 3-4, which are not
operated by PacifiCorp, we adopt exit orders for these units to provide other states with notice of Oregon's
anticipated exit based on the information currently available, but emphasize that we will continue to evaluate the
economics of these units.... We decline to issue exit orders for Jim Bridger Units 2-4 in this proceeding. The
December 31,2025 exit dates are earlier than the 2019 IRP, and are not supported by evidence in this case.").
Idaho Public Utilities Commission
February 18,2022
Page 2
2) To the extent a delay to these filings was necessary, the Company would provide
notice to the parties and commissions explaining the reason and expected filing dates.
On January 5,2021, PacifiCorp filed notice that it would be delaying the filing under Section 4.2.2
for the following reasons: I ) the signatories to the 2020 Protocol continue to work towards resolution
of the long-term planning and new resource assignment framework issue; 2) while the Public Utility
Commission of Oregon approved some exit dates it noted that it will continue to evaluate the
economics of PacifiCorp's coal fleet; 3) the Company is in the middle of updating its modeling tools
to better reflect the future allocation methodology envisioned in the 2020 Protocol; and 4) the
Company will file its 2021 Integrated Resource Plan ("lRP") in 2021 and the delay will allow for
consistent assumptions in both the IRP and the reassignment analysis.
On September 1,2021, PacifiCorp filed its 2021 IRP, which indicated a common closure for the
coal-fueled resources with exit orders prior to December 31,2027.2 Consistent with Section 4.2.3 of
the2020 Protocol, if a regulatory proceeding results in the common closure dates of a coal-fueled
resource then the process for common closure under section 4.1.1 will apply. As a result,
reassignment proceedings for those resources are no longer necessary.
Accordingly, the Company is respectfully providing this letter as notice to the Commission that the
Company does not anticipate filing reassignment cases as previously described in the January 5,2021
letter.
Informal inquiries may be directed to Steve McDougal, Managing Director Revenue Requirement, at
[phone].
Sincerely,
Senior Vice President, Regulation and Customer/Community Solutions
2 In the Matter of RoclE Mountain Power's Filingfor Acknowledgement of its 2021 Integrated Resource Plan,Case
No. PAC-E-21-19,2021 Integrated Resource Plan, Volume I at l5 (Sept. 1,2021).
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CERTIFICATE OF SERVICE
I hereby certifr that on this l8th day of February,2022,1caused to be served, via
electronic mail and/or ovemight delivery a true and correct copy of Rocky Mountain Power's
Notice in Case No. PAC-E-19-20 to the following:
Service List
Rockv Mountain Power
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 841l6
ted.weston@frac ifi corp.com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
datareq uest@pac ifi corp.com
Commission Staff
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
47 2 W . Washington (837 02)
PO Box 83720
Boise, lD 83720-0074
E-Mail : dayn.hardie@puc. idaho. gov
Idaho Conservation League
Benjamin Otto
Idaho Conservation League
710 N. 6th st
Boise,ldaho 83702
[e-mail]
Monsanto Company
Randall C. Budge
Thomas J. Budge
Racine Olsen, PLLP
PO Box 1391
201E. Center
Pocatello,ID 83204
randv@rac ineolsen.com
tj@,racineolsen.com
Brubaker & Associates
Brian C. Collins
Maurice Brubaker
16690 Swingley Ridge Rd., #140
Chesterfield, Missouri 63017
bcol I i ns@consu latbai.com
mbrubaker@consu ltbai.com
PIIC
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
Boise,lD 83701
ron@wi I liamsbradbury.com
[e-mail]
[e-mail]
[e-mail]
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Dated this lSth day of February,Z\2l.
Mary Penfield
Adviser, Regulatory Operations
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