The URL can be used to link to this page

Home My WebLink About20230412Petition.pdf April 12, 2023 VIA ELECTRONIC FILING Jan Noriyuki Commission Secretary Idaho Public Utilities Commission 11331 W Chinden Blvd. Building 8 Suite 201A Boise, ID 83714 Re: CASE NO. PAC-E-23-13 IN THE MATTER OF THE PETITION FOR APPROVAL OF AN EXTENSION TO THE 2020 PACIFICORP INTER-JURISDICTIONAL ALLOCATION PROTOCOL Dear Ms. Noriyuki: Rocky Mountain Power hereby submits for filing with the Idaho Public Utilities Commission its application in the above-referenced matter. Informal inquiries related to this Application should be directed to Mark Alder, Idaho Regulatory Affairs Manager, at (801) 220-2313. Very truly yours, Joelle Steward Senior Vice President, Regulation/Customer and Community Solutions Enclosures Cc: Service List – PAC-E-19-20 RECEIVED Wednesday, April 12, 2023 3:19:09 PM IDAHO PUBLIC UTILITIES COMMISSION PETITION FOR APPROVAL OF AN EXTENSION TO THE 2020 INTER-JURISDICTIONAL ALLOCATION PROTOCOL 1 Adam Lowney (ID #10456) McDowell Rackner Gibson PC 419 SW 11th Avenue, Suite 400 Portland, Oregon 97205 Tel. (503) 595-3926 adam@mrg-law.com Attorney for Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION FOR APPROVAL OF AN EXTENSION TO THE 2020 PACIFICORP INTER-JURISDICTIONAL ALLOCATION PROTOCOL ) CASE NO. PAC-E-23-13 ) PETITION OF ) ROCKY MOUNTAIN POWER ) Rocky Mountain Power, (the “Company” or “Rocky Mountain Power”), a division of PacifiCorp, hereby respectfully submits this petition (“Petition”) in accordance with Idaho Code §61-502, §61-503, and RP 053, to the Idaho Public Utilities Commission (“Commission”) and requests approval of an extension to the 2020 PacifiCorp Inter-Jurisdictional Allocation Protocol (the “2020 Protocol”). In support of this Petition, Rocky Mountain Power states as follows: 1. Rocky Mountain Power is a division of PacifiCorp. PacifiCorp is an Oregon corporation, which provides electric service to retail customers through its Rocky Mountain Power division in the states of Idaho, Utah, and Wyoming, and through its Pacific Power division in the states of California, Oregon, and Washington. 2. Rocky Mountain Power is a public utility authorized to do business in the state of Idaho. The Company is subject to the Commission’s jurisdiction with respect to its prices and terms of electric service to retail customers in Idaho. Rocky Mountain Power provides retail electric service to approximately 88,000 customers in the state. PETITION FOR APPROVAL OF AN EXTENSION TO THE 2020 INTER-JURISDICTIONAL ALLOCATION PROTOCOL 2 I. BACKGROUND 3. PacifiCorp provides retail electric service to more than 2.0 million customers in the western states of California, Idaho, Oregon, Utah, Washington, and Wyoming. PacifiCorp owns substantial generation and transmission facilities. Augmented with wholesale power purchases and long-term transmission contracts, these facilities operate as a single system on an integrated basis to provide service to customers in a cost-effective manner. PacifiCorp recovers costs of owning and operating its generation and transmission system in retail prices established from time to time in state regulatory proceedings. 4. In such state regulatory proceedings, it is customary to first determine what assets are used and useful in providing service to customers and the prudence of associated costs to be included in the Company’s revenue requirement in the state conducting the proceeding. Because the Company’s generation and transmission resources and other common or general functions are used to serve the Company’s customers in all of its state jurisdictions, it is necessary to determine what portion of these costs should be allocated to customers in the state for which prices are being established. If different state commissions make different decisions regarding what resources should be included in PacifiCorp’s rates or if different state commissions adopt different policies for allocating the costs of resources among states, the Company may not be afforded a reasonable opportunity to recover its full cost of providing electric service. 5. Each of PacifiCorp’s state regulatory commissions has the ability to pursue policies that it believes are in the public interest in its state. It is also important, however, for PacifiCorp to be able to make business decisions in an environment where differing state policies do not result in preemptively denying the Company a reasonable opportunity to recover its prudently incurred costs. This would create a disincentive for PacifiCorp to invest in its system. As a result, PacifiCorp PETITION FOR APPROVAL OF AN EXTENSION TO THE 2020 INTER-JURISDICTIONAL ALLOCATION PROTOCOL 3 uses an inter-jurisdictional allocation methodology to allocate costs. The current methodology is the 2020 Protocol. 6. Negotiations on the 2020 Protocol began in 2017, and an agreement was executed by stakeholders in November of 2019. Through the negotiations leading up to the 2020 Protocol, the Multi-State Process Workgroup also worked on a more durable allocation methodology that would allow for greater flexibility among the states to integrate state energy policies while maintaining the benefits of operating as a single system. 7. On April 22, 2020, the Commission issued Order No. 346401 adopting the 2020 Protocol. The 2020 Protocol was designed as a temporary cost allocation methodology scheduled to expire on December 31, 2023. The 2020 Protocol has four main sections: the Interim Allocation Methodology and three sections that detail categories of issues for the development of a future allocation methodology. Those three categories are: Implemented Issues, Resolved Issues, and Framework Issues. 8. After the execution of the 2020 Protocol, the signatory parties to the 2020 Protocol (known as the “Framework Issues Workgroup”) began investigating and working through the Framework Issues to develop the successor to the 2020 Protocol. PacifiCorp and the Framework Issues Workgroup has been discussing and considering those issues in meetings every other month. These negotiations are confidential as the meetings involve analysis of proprietary company information and also promote the free-flow of discussion and compromise among stakeholders. 9. After approximately three years of discussions and negotiations, the Framework Issues Group needs additional time to complete the work on developing a successor to the 2020 Protocol, and as a result, the parties have entered into the First Amendment and Extension to the 1 Case No. PAC-E-19-20. PETITION FOR APPROVAL OF AN EXTENSION TO THE 2020 INTER-JURISDICTIONAL ALLOCATION PROTOCOL 4 2020 Protocol (“First Amendment”) to extend the 2020 Protocol to December 31, 2025. The First Amendment is included as Attachment A to this Petition. II. REQUEST FOR APPROVAL OF THE FIRST AMENDMENT TO THE 2020 PROTOCOL 10. As the negotiations to develop a successor to the 2020 Protocol have progressed, new regulatory actions from federal agencies, along with operational and market considerations, have impacted negotiations in the Framework Issues Workgroup. Specifically, new federal legislation and environmental rule changes are expected to impact the costs and benefits of PacifiCorp’s generation fleet. 11. At the same time, the Parties began considering alternative resource allocation methodologies, and the Parties would like to continue to explore these options. Accordingly, the Parties are requesting a two-year extension to the 2020 Protocol. 12. The First Amendment has been executed by nearly all the Idaho stakeholders that are signatories to the 2020 Protocol. These stakeholders are the Staff of the Idaho Public Utilities Commission, the Idaho Conservation League, Idaho Irrigation Pumpers Association, and P4 Production, L.L.C., an affiliate of Bayer Corporation (previously, the Monsanto Company). Rocky Mountain Power has contacted the PacifiCorp Idaho Industrial Customers, but the Company has not yet received any communication from this party. 13. In support of this Petition the Company provides a report developed by the Company that provides an update on the current status of these discussions and an explanation of the key provisions that amend the 2020 Protocol. This report is included as Attachment B to this Petition. PETITION FOR APPROVAL OF AN EXTENSION TO THE 2020 INTER-JURISDICTIONAL ALLOCATION PROTOCOL 5 III. COMMUNICATIONS 14. Communications regarding this filing should be addressed to: Mark Alder Idaho Regulatory Affairs Manager Rocky Mountain Power 1407 West North Temple, Suite 330 Salt Lake City, Utah 84116 Telephone: (801) 220-2313 Email: mark.alder@pacificorp.com Adam Lowney (ID #10456) McDowell Rackner Gibson PC 419 SW 11th Avenue, Suite 400 Portland, Oregon 97205 Telephone: (503) 595-3926 Email: adam@mrg-law.com In addition, Rocky Mountain Power requests that all data requests regarding this Petition be sent in Microsoft Word to the following: By email (preferred): datarequest@pacificorp.com By regular mail: Data Request Response Center PacifiCorp 825 Multnomah, Suite 2000 Portland, Oregon 97232 Informal questions may be directed to Mark Alder, Idaho Regulatory Affairs Manager at (801) 220-2313. IV. PROPOSED COMMISSION PROCESS 15. The 2020 Protocol and the First Amendment have been developed and negotiated by the Parties as an integrated, interdependent whole. Support by any Party of the 2020 Protocol and the First Amendment is expressly conditioned upon approval without material alteration of the 2020 Protocol or First Amendment by all commissions in the states that PacifiCorp has sought PETITION FOR APPROVAL OF AN EXTENSION TO THE 2020 INTER-JURISDICTIONAL ALLOCATION PROTOCOL 6 approval. The Parties recommend that the Commission approve the First Amendment to the 2020 Protocol and that the approval be conditioned on the other commissions approving the First Amendment to the 2020 Protocol without change. 16. PacifiCorp respectfully requests that the Commission approve the extension of the 2020 Protocol for inter-jurisdictional cost-allocation purposes effective January 1, 2024. The Company also proposes that within 30 days of receipt of the Petition, the Commission establish a schedule for further proceedings. V. CONCLUSION PacifiCorp respectfully requests that the Commission issue an order modifying Order No. 34640 and approving the First Amendment to the 2020 Protocol as included in Attachment A. DATED this 12th day of April, 2023. Respectfully submitted, __________________________ Adam Lowney (ID #10456) McDowell Rackner Gibson PC 419 SW 11th Avenue, Suite 400 Portland, Oregon 97205 Tel. (503) 595-3924 adam@mrg-law.com Attorney for Rocky Mountain Power Attachment A FINAL EXECUTION VERSION First Amendment and Extension to the 2020 PacifiCorp Inter- Jurisdictional Allocation Protocol 1. Introduction 1 On November 22, 2019, the 2020 PacifiCorp Inter-Jurisdictional Allocation Protocol 2 Agreement (the “2020 Protocol” or this “Agreement”) was executed. The 2020 Protocol reflects 3 the agreement among PacifiCorp (or the “Company”), state regulatory agencies, customers, 4 consumer advocates, conservation organizations, and other interested parties from California, 5 Idaho, Oregon, Utah, Washington, and Wyoming (collectively referred to as the “States” or 6 individually as a “State”) who have executed this Agreement (collectively referred to as the 7 “Parties” or individually as a “Party”) on an interim allocation and assignment method and a 8 process for determining a long-term replacement of existing inter-jurisdictional allocation and 9 assignment methodologies. The 2020 Protocol was approved and adopted by the Commissions1 as 10 identified in Table 1 below. 11 State Docket Numbe Order Date Californi A.22-05-006 TBD2 Idaho PAC-E-19-20 April 22, 2020 Ore on UM 1050 Januar 23, 2020 Utah 19-035-42 April 15, 2020 Washin to UE-191024 Decembe 14, 2020 W omin 20000-572-EA-19 (Record 15400) December 3, 2020 The 2020 Protocol defined certain unresolved issues as “Framework Issues”3 and established a 12 “Framework Issues Workgroup”4 to address these unresolved issues. The Parties have engaged in 13 negotiations of the Framework Issues under the Framework Issues Workgroup. As these 14 1 Capitalized terms in this First Amendment and Extension continue to be defined consistent with the definitions identified in the 2020 Protocol. 2 PacifiCorp has requested approval of the 2020 Protocol in the most recent ongoing general rate case and an order has yet to be issued. 3 2020 Protocol at 38:794-43:913. 4 2020 Protocol at 44:926-929. FINAL EXECUTION VERSION discussions have progressed, new regulatory actions from federal agencies, along with operational 15 and market considerations, have impacted discussions in the Framework Issues Workgroup. These 16 events have resulted in the consideration of alternative resource allocation methods, and the Parties 17 would like to continue to explore these options. As a result, the Parties have agreed to amend and 18 extend the 2020 Protocol an additional two years to resolve the outstanding Framework Issues and 19 finalize a Post-Interim Period Method that can be presented to the Commissions for approval. This 20 amendment is not a new inter-jurisdictional protocol, it simply presents the necessary changes to 21 extend the existing 2020 Protocol. 22 The Parties have entered into this First Amendment and Extension to the 2020 Protocol 23 (“First Amendment”). The modifications to the 2020 Protocol that are necessary to implement 24 these changes are identified below. Consistent with section 8.4 of the 2020 Protocol, the First 25 Amendment has been submitted to, discussed, and agreed to by the Parties participating in the 26 Framework Issues Workgroup. Unless modified in the manner identified below, the provisions of 27 the 2020 Protocol remain in force and will continue in effect for the extended duration of this 28 agreement until December 31, 2025. 29 2. Modifications to the 2020 Protocol 30 2.1. Extension of the Agreement 31 As identified in Section 1, 2.1, and 2.2.1 (lines 21, 94, 103, 105, and 106), the termination 32 date of the Interim Period will be extended from December 31, 2023 to December 31, 2025. The 33 date, December 31, 2023, located in footnote 3, page 5 shall also be revised to be December 31, 34 2025. 35 2.2. Clarification on Oregon Exit Dates 36 In section 4.1.3.2, a clarification will apply to Jim Bridger Units 1 and 2. For Jim Bridger 37 FINAL EXECUTION VERSION Unit 1, the 2020 Protocol will note that “Based on the settlement reached and adopted in Docket 38 No. UE 399 in Oregon, this Exit Order only applies to Jim Bridger 1 as a coal-fired Unit.5 To the 39 extent that Jim Bridger Unit 1 is not converted to natural gas, PacifiCorp will make appropriate 40 filings in Oregon to change the date of the Exit Order.” For Jim Bridger Unit 2, the 2020 41 Protocol will note that “PacifiCorp did not seek an Exit Order for Jim Bridger Unit 2 because of 42 the anticipated conversion to natural gas.” Section 4.1.3.3. shall be amended to revise the date 43 located on line 458 from December 31, 2023, to December 31, 2025. Section 4.2.2 shall be 44 amended to revise the dates located on lines 503-504 from June 30, 2024, and December 31, 45 2023, to June 30, 2026, and December 31, 2025. 46 2.3. Changes to Appendix C 47 The Division Generation – Utah Factor located on page 5 of Appendix C shall be 48 modified to note that after the Interim Period, the factor is fixed by the average of the four-year 49 historical value immediately preceding the end of the Interim Period. 50 5 In the Matter of PacifiCorp, d/b/a Pacific Power, Request for a General Rate Revision, Docket No. UE 399, Order No. 22-491 (Dec. 16, 2022). FINAL EXECUTION VERSION 3. Signatures of the Parties to the First Amendment and Extension to the 2020 Protocol 51 This First Amendment and Extension to the 2020 Protocol is entered into by each Party on 52 the date entered below such Party's signature. 53 PACIFICORP By: Senior Vice President, Regulation Title: and Customer/Community Solutions Date: ALLIANCE OF WESTERN ENERGY CONSUMERS By: ________________________________ Title: ________________________________ Date: _______________________________ IDAHO CONSERVATION LEAGUE By: ________________________________ Title: ________________________________ Date: _______________________________ IDAHO PUBLIC UTILITIES COMMISSION STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ IDAHO IRRIGATION PUMPERS ASSOCIATION By: ________________________________ Title: ________________________________ Date: _______________________________ INTERWEST ENERGY ALLIANCE By: Title: Executive Director Date: March 31, 2023 FINAL EXECUTION VERSION MONSANTO COMPANY By: ________________________________ Title: ________________________________ Date: _______________________________ NORTHWEST & INTERMOUNTAIN POWER PRODUCERS By: ________________________________ Title: ________________________________ Date: _______________________________ NORTHWEST ENERGY COALITION By: ________________________________ Title: ________________________________ Date: _______________________________ NUCOR By: ________________________________ Title: ________________________________ Date: _______________________________ OREGON CITIZENS’ UTILITY BOARD By: ________________________________ Title: __General Counsel____ ___________ Date: ___3/27/2023____________________ OREGON PUBLIC UTILITY COMMISSION STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ PACIFICORP IDAHO INDUSTRIAL CUSTOMERS By: ________________________________ Title: ________________________________ Date: _______________________________ PACKAGING CORPORATION OF AMERICA By: ________________________________ Title: ________________________________ Date: _______________________________ FINAL EXECUTION VERSION MONSANTO COMPANY By: ________________________________ Title: ________________________________ Date: _______________________________ NORTHWEST & INTERMOUNTAIN POWER PRODUCERS By: ________________________________ Title: ________________________________ Date: _______________________________ NORTHWEST ENERGY COALITION By: ________________________________ Title: ________________________________ Date: _______________________________ NUCOR By: ________________________________ Title: ________________________________ Date: _______________________________ OREGON CITIZENS’ UTILITY BOARD By: ________________________________ Title: ________________________________ Date: _______________________________ OREGON PUBLIC UTILITY COMMISSION STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ PACIFICORP IDAHO INDUSTRIAL CUSTOMERS By: ________________________________ Title: ________________________________ Date: _______________________________ PACKAGING CORPORATION OF AMERICA By: ________________________________ Title: ________________________________ Date: _______________________________ FINAL EXECUTION VERSION MONSANTO COMPANY By: ________________________________ Title: ________________________________ Date: _______________________________ NORTHWEST & INTERMOUNTAIN POWER PRODUCERS By: ________________________________ Title: ________________________________ Date: _______________________________ NORTHWEST ENERGY COALITION By: ________________________________ Title: ________________________________ Date: _______________________________ NUCOR By: ________________________________ Title: ________________________________ Date: _______________________________ OREGON CITIZENS’ UTILITY BOARD By: ________________________________ Title: ________________________________ Date: _______________________________ OREGON PUBLIC UTILITY COMMISSION STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ PACIFICORP IDAHO INDUSTRIAL CUSTOMERS By: ________________________________ Title: ________________________________ Date: _______________________________ PACKAGING CORPORATION OF AMERICA By: ________________________________ Title: ________________________________ Date: _______________________________ Attorney 3/24/23 FINAL EXECUTION VERSION POWDER RIVER BASIN RESOURCE COUNCIL By: ________________________________ Title: ________________________________ Date: _______________________________ RENEWABLE NORTHWEST By: ________________________________ Title: ________________________________ Date: _______________________________ SIERRA CLUB By: ________________________________ Title: ________________________________ Date: _______________________________ UTAH ASSOCIATION OF ENERGY USERS By: ________________________________ Title: ________________________________ Date: _______________________________ UTAH CLEAN ENERGY By: ________________________________ Title: ________________________________ Date: _______________________________ UTAH DIVISION OF PUBLIC UTILITIES By: ________________________________ Title: ________________________________ Date: _______________________________ UTAH INDUSTRIAL ENERGY CONSUMERS By: ________________________________ Title: ________________________________ Date: _______________________________ UTAH OFFICE OF CONSUMER SERVICES By: ________________________________ Title: ________________________________ Date: _______________________________ FINAL EXECUTION VERSION POWDER RIVER BASIN RESOURCE COUNCIL By: ________________________________ Title: ________________________________ Date: _______________________________ RENEWABLE NORTHWEST By: ________________________________ Title: ________________________________ Date: _______________________________ SIERRA CLUB By: ________________________________ Title: ________________________________ Date: _______________________________ UTAH ASSOCIATION OF ENERGY USERS By: Title: Attorney Date: March 22, 2023 UTAH CLEAN ENERGY By: ________________________________ Title: ________________________________ Date: _______________________________ UTAH DIVISION OF PUBLIC UTILITIES By: ________________________________ Title: ________________________________ Date: _______________________________ UTAH INDUSTRIAL ENERGY CONSUMERS By: ________________________________ Title: ________________________________ Date: _______________________________ UTAH OFFICE OF CONSUMER SERVICES By: ________________________________ Title: ________________________________ Date: _______________________________ FINAL EXECUTION VERSION VOTE SOLAR By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ TRANSPORTATION COMMISSION STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: Sophie Hayes, Senior Staff Attorney_ Date: March 21, 2023__________________ By: ________________________________ Title: ________________________________ Date: _______________________________ CONSUMERS By: ________________________________ Title: ________________________________ Date: _______________________________ ADVOCATE By: ________________________________ Title: ________________________________ Date: _______________________________ COMMISSION STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ FINAL EXECUTION VERSION VOTE SOLAR By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ TRANSPORTATION COMMISSION STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ By: ________________________________ Title: ________________________________ Date: _______________________________ CONSUMERS By: ________________________________ Title: ________________________________ Date: _______________________________ ADVOCATE By: ________________________________ Title: ________________________________ Date: _______________________________ COMMISSION STAFF By: ________________________________ Title: ________________________________ Date: _______________________________ Attorney March 24, 2023 FINAL EXECUTION VERSION VOTE SOLAR By: Title: Date: WASHINGTON PUBLIC COUNSEL By: Title: Date: WASHINGTON UTILITIES & TRANSPORTATION COMMISSION STAFF By: Title: Date: WESTERN RESOURCE ADVOCATES By: Title: Date: WOLVERINE FUELS By: Title: Date: WYOMING INDUSTRIAL ENERGY CONSUMERS By: Title: Date: WYOMING OFFICE OF CONSUMER ADVOCATE By: Title: Date: WYOMING PUBLIC SERVICE COMMISSION STAFF. r/3By:fc«/• Title: -^/<^»y ^ ^r<f ^^/jy] Date: ^<3/-^2A23 Attachment B Report on the Amendment and Extension to the 2020 Protocol – Page 1 PacifiCorp Report on the First Amendment and Extension of the 2020 Protocol Background: PacifiCorp (or the Company) is a multi-jurisdictional electric utility operating in six states: California, Idaho, Oregon, Utah, Washington, and Wyoming. PacifiCorp serves its customers in all six of these states as a single system, and can access resources across the West and multiple trading hubs to minimize off-system wheeling costs to provide value to our customers. To maximize these system efficiencies, however, a single agreement must govern the allocation of the costs and benefits of shared generation and transmission resources among the states to realize the benefits of planning and operating as one system. PacifiCorp utilizes an inter- jurisdictional cost allocation methodology to allocate these system costs and benefits. This methodology is negotiated among a diverse array of stakeholders representing interests in PacifiCorp’s service territory. The currently approved methodology is the 2020 PacifiCorp Inter- Jurisdictional Allocation Protocol (2020 Protocol). The 2020 Protocol was executed by stakeholders in November of 2019. Through the negotiations leading to the 2020 Protocol, the Multi-State Process Workgroup worked on a more durable allocation methodology that would allow for greater flexibility among the states to integrate state energy policies while maintaining the benefits of operating as a single system. During the negotiations for the 2020 Protocol, the Company and stakeholders investigated many approaches to address divergent state interests including: • Restructuring PacifiCorp through a legal separation • One-time Reassignment of all coal generation resources • Limited Realignment of resources to address individual states • Alternatives proposed by parties such as green tariffs or east-side assignment of all coal assets • Phased-in approaches to assigning existing generation resources The result of the negotiations was the 2020 Protocol. The 2020 Protocol was designed as a temporary cost allocation methodology that would expire on December 31, 2023, and it has four main sections: the Interim Allocation Methodology and three sections that detail categories of issues for the development of a future allocation methodology. Those three categories are: Implemented Issues, Resolved Issues, and Framework Issues. The Implemented Issues are matters to be implemented during the Interim Period and cover the following topics: • The process for states’ decisions to exclude costs and benefits of coal-fueled resources from their respective retail rates (i.e., exit); • The Reassignment of coal-fueled resources through an approval process; • Decommissioning costs; and • Power Purchase Agreements with Qualifying Facilities. Report on the Amendment and Extension to the 2020 Protocol – Page 2 Resolved Issues are issues that were agreed to and were expected to be implemented as part of the new allocation methodology. These include: •Allocation of generation costs;•Assignment of costs of new resources; •Transmission costs; •System overhead costs; and •Allocation of distribution resources, demand-side management programs, and state-specific initiatives. Framework Issues are issues actively being discussed by the Framework Issues Workgroup, a workgroup consisting of all signatories to the 2020 Protocol. These include: •Resource planning and new resource assignment;•Net Power Costs (NPC)/Nodal Pricing Model (NPM);•Special contracts with large industrial customers;•Limited Realignment; and •Allocation and recovery of Post-Interim Period capital additions to coal-fueled generationresources. After the execution of the 2020 Protocol, the Framework Issues Workgroup beganinvestigating and working through the Framework Issues to develop the successor to the 2020 Protocol (identified as the Post-Interim Protocol Methodology). The Framework Issues Workgroup has been discussing and considering those issues in meetings every other month. These negotiations are confidential as the meetings involve analysis of proprietary company information and also promote the free-flow of discussion and compromise among stakeholders. As these discussions have progressed, new regulatory actions from federal agencies, along with operational and market considerations are impacting the costs and benefits of PacifiCorp’s generation fleet. At the same time, the Framework Issues Workgroup has identified potenial alternative resource allocation methodologies, and the Parties would like to continue to explore these options. As a result, the Parties are requesting a two-year extension to the 2020 Protocol, and this report provides an update on the status of these discussions and an explanation of the key provisions that amend the 2020 Protocol. Update on the Current Status of Negotiations: This update represents the current status of negotiations and updates, but does not represent any agreed upon positions. The proposals that are discussed in this report could change when presented for approval to the utility commissions in the six states where PacifiCorp serves retail customers. Additionally, the topics below do not represent every topic that has been discussed, but provide an overview and update on some of the progress that has been made. This report presents the Company’s view of the current status of negotiations and does not necessarily reflect the positions or opinions of any other individual stakeholder in the process. The Move to a Partial Dynamic Allocation Methodology: Report on the Amendment and Extension to the 2020 Protocol – Page 3 The 2020 Protocol contemplated fixing the allocation factors for all of PacifiCorp’s existing and future generation assets. However, as discussions progressed, some stakeholders expressed concerns that this could create disparities in the cost and type of resources used to serve customers based on when an individual state’s resource need arose, and add unnecessary complexity to the resource procurement process. Currently, stakeholders have been evaluating a partial dynamic allocation methodology, in which future resources would fall into one of three categories: System resources (shared by all six states), partially shared resources (resources shared by fewer than six states), and state-specific or situs resources. The distinctions between these categories could be drawn by state specific depreciable lives, fuel type, or other manner. However, these distinctions would need to fairly allocate costs and benefits so as not to disadvantage some states over others and continue to ensure reliability of the system and load service. Based on these three categories, certain stakeholders proposed a process by which system and partially shared resources would remain dynamically allocated based on the loads in individual states. Under this approach, the allocation of shared system resources would dynamically change with each state’s actual load in proportion to system load. This partial dynamic allocation concept is intended retain the ability for states to share the costs and benefits of resources, when possible. Certain stakeholders identified this as a method to smooth out the disparities in cost and type of resource used to serve customers that occur solely based on the timing of an individual state’s resource need. The Company and stakeholders are continuing to analyze data about various options and evaluating how such a methodology would be structured. Under this potential allocation methodology, it is contemplated that PacifiCorp will continue to maintain a long-term resource planning approach that optimizes PacifiCorp’s system for customers and the region. Planning would also incorporate analysis of customer choice initiatives, specific resource requirements, and state-specific policies and compliance to meet the needs and policies of all states. Extended Day-Ahead Market (EDAM) and the NPM: The NPM is a potential allocation methodology to be used for the inter-jurisdictional allocation of NPC that has been proposed by the Company, and is included as a Framework Issue in the 2020 Protocol. The 2020 Protocol defines the NPM as “a method for pricing electricity proposed by the Company that is based on the marginal cost ($/MWh) of serving the next increment of demand at a given pricing node consistent with existing transmission constraints and the performance characteristics of resources.” To have the information necessary (i.e., day-ahead, hourly locational marginal price) to allocate actual NPC using the NPM, the Company contracted with the California Indendent System Operator (CAISO) to receive optimized day-ahead advisory schedules that are used to inform the Company’s day-ahead dispatch schedules. In other words, the NPM consists of two components: (1) the operational, “dispatch”, or day-ahead schedules from the CAISO; and (2) the allocation methodology. In January of 2021, PacifiCorp began receiving the operational “dispatch” schedules from the CAISO and incorporating them into the dispatch process used by PacifiCorp’s energy supply management team. Meanwhile, PacifiCorp has been using the information provided through that process to inform ongoing discussions for the allocation of NPC. Report on the Amendment and Extension to the 2020 Protocol – Page 4 On December 7, 2022, PacifiCorp announced its plan to join the EDAM to be operated by the CAISO, which builds on the current Energy Imbalance Market. Much of the work that has been completed for the implementation of the NPM will be leveraged for entrance into the EDAM. Additionally, the implementation of the EDAM is expected to replace the NPM as the EDAM would provide the necessary settlement information to facilitate the net power cost allocation that was envisioned as part of the NPM. Stakeholders are in the process of evaluating how, or if, the EDAM might be used to allocate actual NPC. Limited Realignment: Stakeholders are still considering Limited Realignment as described in the 2020 Protocol. The Limited Realignment of certain thermal resources in Washington and Oregon rates could present an opportunity to support the policy objectives in those states. However, significant analysis and work remains to assess these options. Overview of the First Amendment and Extension to the 2020 Protocol: The First Amendment and Extension to the 2020 Protocol contains three substantive sections: the Extension of the Agreement, Updated Exit Order Dates, and certain changes to Appendix C. Extension of the Agreement: This section simply extends the sunset date of the agreement from December 31, 2023, to December 31, 2025. The Framework Issues Workgroup anticipates that a filing will be made in early to mid-2025 to ensure that a new allocation protocol is in place when this agreement expires. Updated Exit Order Dates: While not specifically addressed in this Amendment, there have been updates to certain common coal plant closure dates based on revised information regarding certain jointly owned plants. Many of the units that had been anticipated for state Exit and Reassignment in the Interim Period now have common closure dates. As a result, no Reassignment filings have been necessary to this point. Attached to this Report as Exhibit 1 is a revised table that provides PacifiCorp’s latest information on depreciable lives, closure dates, and Exit order dates. Based on more recent economics and environmental requirements, the 2023 Integrated Resource Plan is evaluating other potential changes to current system resources, including closure or fuel conversion dates. Additionally, with regards to the Colstrip generating facility, PacifiCorp is in discussions with the joint owners to modify the participation agreement and exit the project on January 1, 2030. PacifiCorp will still remove all costs and benefits associated with coal-fired resources from Washington rates by December 31, 2025.1 Once an agreement is reached through those discussions, PacifiCorp will work with Oregon parties to determine if any revisions to the Exit order are necessary. Additionally, based on the settlement agreement that has been reached and adopted by the Public Utility Commission of Oregon in PacifiCorp’s 2022 general rate case in Oregon (Docket UE 399), PacifiCorp has clarified that the Exit order for Jim Bridger Unit 1 only applies to that unit 1 See §7.2 of Appendix F of the 2020 Protocol; RCW 19.405.030. Report on the Amendment and Extension to the 2020 Protocol – Page 5 as a coal-fired unit (and not as a gas-fired unit), and that PacifiCorp will not be seeking an exit order for Jim Bridger Unit 2 because of the anticipated conversion to natural gas. Finally, this section extends the dates for the Reassignment process for coal-fired units based on the overall extension of this agreement. Changes to Appendix C: This change updates the definition of the Division Generation – Utah Factor to revise the calculation of that factor so that it is no longer dependent on specific dates and can be appropriately calculated based on the extension of this agreement. Unit 2018 Depr Study Lives OR Adj Life – 2018 Depr Study 2019 IRP Lives (P-45CNW) 2021 IRP Lives OR Exit Dates Capacities (MW)Comments Colstrip - 3 2027 2027 2025 2027 74 See Report Colstrip - 4 2027 2027 2025 2027 74 See Report Craig - 1 2025 2025 2025 2025 82 Common Closure Craig - 2 2026 2026 2028 September 2028 79 Joint owner closure in Sept 2028 Dave Johnston - 1 2027 2027 2027 2027 93 Common Closure Dave Johnston - 2 2027 2027 2027 2027 102 Common Closure Dave Johnston - 3 2027 2027 2027 2027 220 Common Closure Dave Johnston - 4 2027 2027 2027 2027 330 Common Closure Hayden - 1 2030 2023 2030 2028 2028 44 Joint owner closure in 2028 Hayden - 2 2030 2023 2030 2027 2027 33 Joint owner closure in 2027 Hunter - 1 2042 2029 2042 2042 418 Hunter - 2 2042 2029 2042 2042 269 Hunter - 3 2042 2029 2042 2042 471 Huntington - 1 2036 2029 2036 2036 459 Huntington - 2 2036 2029 2036 2036 450 Jim Bridger - 1 2028 2023 2023 2037 2023 (if coal) 354 Convert to gas in 2023 Jim Bridger - 2 2032 2025 2028 2037 359 Convert to gas in 2023 Jim Bridger - 3 2037 2025 2037 2037 349 Jim Bridger - 4 2037 2025 2037 2037 351 Naughton - 1 2029 2025 2025 2025 2025 156 Common Closure Naughton - 2 2029 2025 2025 2025 2025 201 Common Closure Wyodak - 1 2039 2029 2039 2039 266 Exhibit 1 to the Report on the Amendment and Extension to the 2020 Protocol Page 1 of 2 CERTIFICATE OF SERVICE I hereby certify that on this 12th day of April, 2023, I caused to be served, via electronic mail and/or overnight delivery a true and correct copy of Rocky Mountain Power’s PETITION FOR APPROVAL in Case No. PAC-E-19-20 to the following: Service List Mark Alder Rocky Mountain Power 1407 West North Temple, Suite 330 Salt Lake City, Utah 84116 mark.alder@pacificorp.com PacifiCorp 825 NE Multnomah, Suite 2000 Portland, OR 97232 datarequest@pacificorp.com Commission Staff Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington (83702) PO Box 83720 Boise, ID 83720-0074 E-Mail: dayn.hardie@puc.idaho.gov Idaho Conservation League Idaho Conservation League 710 N. 6th St Boise, Idaho 83702 Monsanto Company Thomas J. Budge Racine Olsen, PLLP PO Box 1391 201 E. Center Pocatello, ID 83204 randy@racineolsen.com tj@racineolsen.com Brian C. Collins Maurice Brubaker 16690 Swingley Ridge Rd., #140 Chesterfield, Missouri 63017 bcollins@consulatbai.com mbrubaker@consultbai.com PIIC Williams Bradbury, P.C. P.O. Box 388 Boise, ID 83701 ron@williamsbradbury.com jduke@idahoan.com williamsk@byui.edu Page 2 of 2 Dated this 12th day of April, 2023. __________________________________ Santiago Gutierrez Coordinator, Regulatory Operations