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HomeMy WebLinkAbout20241106Direct Don Reading.pdf RECEIVED Wednesday, November 6, 2024 IDAHO PUBLIC UTILITIES COMMISSION I 2 BEFORE THE IDAHO PUBLIC 3 4 UTILITIES COMMISSION 5 6 IN THE MATTER OF THE Case No.: IPC-E-24-07 7 APPLICATION OF IDAHO POWER 8 COMPANY FOR AUTHORITY TO 9 INCREASE RATES FOR ELECTRIC SERVICE TO RECOVER COSTS 10 ASSOCIATED WITH INCREMENTAL I I CAPITAL INVESTMENTS AND 12 CERTAIN ONGOING OPERATION 13 AND MAINTENANCE EXPENSES 14 15 16 17 INDUSTRIAL CUSTOMERS OF 18 IDAHO POWER 19 20 DIRECT TESTIMONY 21 of 22 DR. DON READING 23 24 25 26 27 READING, DI - I 28 INDUSTRIAL CUSTOMERS OF IDAHO POWER I TEST YEAR 2 Q. Please state your name, business address, and occupation. 3 A. My name is Don Reading. My business address is 280 South Silverwood Way, 4 5 Eagle Idaho. I am an independent consulting economist. 6 Q. Please describe your educational background and experience as a consulting 7 economist. My qualifications and background experience are described in attached Exhibit No. 8 301. 9 Q. Dr. Reading, do you support Idaho Power Company's ["Idaho Power" or the 10 II "Company"] proposal in this case that the Commission adopt the use of a year-end of plant 12 balances for purposes of calculating fair,just and reasonable rates for the Idaho Power 13 Company? 14 A. No. 15 Q. Please explain. 16 17 A. The Company's position is succinctly stated by Tim Tatum who is Idaho Power's 18 Vice President of Regulatory Affairs. Mr. Tatum states, at pages 20-21 of his direct testimony 19 that: 20 The use of year-end plant balances as opposed to a historical monthly average will 21 ensure that the rate base included in customer rates reflects plant investments placed in service up to the time rates to go into effect, thereby reducing, albeit not eliminating, 22 regulatory lag. 23 To hear a regulated state-sanctioned monopolist complain about regulatory lag is much like a 24 firm in a market economy complaining about competition, it is a business risk that, like many 25 26 others, comes with the territory. Regulatory lag is part of the bargain Idaho Power (and all 27 other regulated state-sanctioned monopolies) struck in order to legally prevent competition for it. 28 READING, DI -2 INDUSTRIAL CUSTOMERS OF IDAHO POWER I business or for its captive ratepayers. Regulatory lag is a simple, and unavoidable, fact of life 2 that investors in the power company are aware of when they invest in that company. 3 Q. It sounds like you are disapproving of the "state-sanctioned" monopoly construct. 4 Is that true? 5 6 A. Not at all, quite the contrary. I do not intend any pejorative intent in using the 7 phrase, "state-sanctioned monopolist." Some parts of the power company's business are best 8 provided under the state's protection as a monopoly business segment. This is often referred to 9 as a 'natural monopoly' where society as well as the company gains by having it in place. 10 II Q. Mr. Tatum provides the Commission with a definition of the phrase "regulatory 12 lag" on page 17 of his direct testimony. Do you agree with his definition? 13 A. Yes and no. 14 Q Please explain? 15 A. Quite appropriately Mr. Tatum references the definition of regulatory lag provide 16 17 in Bonbright's 1988 classic on utility regulation, "Principles of'Public Utility Rates, " which 18 provides at page 96 that regulatory lag is: 19 the quite usual delay between the time when reported rates of profit are above or below standard and the lime when an oJfselting rate decrease or increase may be put into effect 20 by commisslon Order... 21 I would have no issue with Mr. Tatum's regulatory lag definition had he stopped at that point. 22 However, he chose to recast the definition in a manner that benefits the company's shareholders 23 24 and not the company's ratepayers. According to Mr. Tatum on page 17 of his direct testimony, 25 regulatory lag has a more limited definition, to wit: 26 In the context of this particular proceeding, regulatory lag refers to the lime period 27 between when a capital investment is made by the Company and when the Company 28 READING, DI - 3 INDUSTRIAL CUSTOMERS OF IDAHO POWER I begins to recover that investment through customer rates. Further, the same concept is 2 applicable to O&Nf Labor costs in this instance. 3 Mr. Tatum's definition ignores a fundamental concept of regulatory lag. 4 Q. Please explain? 5 A. Regulatory lag, to paraphrase Bonbright, is the time lag between when a utility's 6 profits are out of sync (either too high or too low) and the time necessary for the Commission to 7 8 raise or lower rates to bring the utility's profits back within a normal or appropriate range. Idaho 9 Power's definition ignores the utility's profits (or lack thereof), and only focuses on the limited 10 discreet question of whether a specific widget is included in rate base. Idaho Power hasn't asked I I the Commission to decide whether it is over earning or under earning only that these particular 12 widgets be added to the mix of its approved rate base. 13 14 Q. Idaho Power's most recent rate case, which was settled just last year, was the 15 power company's first general rate case in more than ten years. Are there any implications for 16 regulatory lag in the fact that Idaho Power waited ten years to file its most recent general rate 17 case? 18 A. Waiting ten years to file a general rate case suggests that the Company's earnings 19 20 (profits) were more than adequate to satisfy its investors for that long period of time. On the 21 surface, at least, it appears the Company is willing to allow its shareholders to receive benefits of 22 over decade's worth of regulatory lag when its earnings are robust, or to quote Bonbright, when 73 its earnings are "above standard." I say "appears" because we don't know whether the 24 company's earnings during the decade it Filed no general rate case were either above or below 25 26 "standard." We can assume, however, that the Company's investors would have pushed 27 management to File a general rate case if earnings were not, at a minimum, adequate. "Thus, it is 28 READING, DI -4 INDUSTRIAL CUSTOMERS OF IDAHO POWER I clear that regulatory lag can actually be beneficial to the company's investors at the expense of' its ratepayers. 3 Q. Are you obiecting to the Company's filing of a limited issue rate case? 4 5 A. No. But, as the adage goes, be careful what you wish for. The Company wanted 6 a limited issue rate case, and all of the parties acquiesced or agreed to proceed with such a case. 7 "thus, the issue of regulatory lag, at least the type of regulatory lag defined by Bonbright is not, 8 and should not be, on the table to influence the Commission's decision as to either when or 9 whether these particular widgets belong in the Company's rate base. 10 I I Q. You labeled your testimony, "test year." Flow do the issues of regulatory lag and 12 appropriate test year intersect'? 13 A. Idaho Power argues, via Mr. Tatum, that using a year-end partially forecast test 14 year will reduce regulatory lag. 15 Q. Do you agree? 16 17 A. No, for several reasons. 18 Q. Please explain'? 19 A. First is the foundational principle that the rate payer should only be charged for a 20 utilitycompany's assets that are used and use fill. This approach to ratemakin has practically.f pP g p Y 21 been a universally accepted principle by commissions throughout the country -- including Idaho. 22 33 Again, according to Bonbright: 24 In they fit,sl place, Ifin-f they commission's slaffrulc making parrhuses, only just and reasonable expenses am allo�re(l only use'cl and u1'e'frd proj)ei-q, ispCrmilletlIn rate hase. 25 In the seconct place, the commission musl have a basis fin. e'stinlatNd f ttui,e i,e'venae 26 Y'e'C uirements, This e'stinlale is one of the most. cliff/cull I7rohle'ms in a r'aie case, A commission is setting rales_for• thc,fulure hctt it has only,Imsl exl)erience (expenses, 27 revenue, demand conditions) to use as a guide. 28 RI ADING, DI - 5 - INDUSTRIM.CUSTOMERS OF IDAI10 POWLR 1 Hence the tension between test year and regulatory lag becomes a significant issue. Without an 3 earnings test the Commission is shooting in the dark as to the overall impact of inclusion of new 4 investment in rate base. 5 Q. You indicated that the Idaho Commission has adhered to the used and useful 6 principle in past general rate cases. Can you provide an example? 7 8 A. Yes. Just two years ago in a case involving a major water utility (VEO-W-22-02) 9 the Idaho Commission ruled: 10 The Commission continues to believe that including plant investment in the calculation o rate base as if it were in service the entire year creates a mismatch between test year I I revenue and expenses, and it is unreasonable to expect the Commission to allow full 12 recovery gfplanl investment as if'the plant has been in in operation the full year without a corresponding adjustment to revenues and expenses. 13 14 [Order No. 35762 at p. 23.] The Commission's stated position on this issue is unequivocal. 15 Q. Does it make a difference that the VEO-W rate case involved a water utility and 16 not an electric utility, like the Idaho Power Company? 17 A. No. The regulatory principle is the same whether one is dealing with a water 18 utility or an electric utility or a gas utility. The principle holds true also for both large and small 19 20 utilities. Simply put, rate payers should not be responsible to pay a return of, and a return on, 21 investments that are not proven to be used and useful in the provision of utility service. 22 Q. Dr. Reading, assume for a moment that Mr. Tatum's complaint about regulatory 23 lag is valid and that this Commission has an obligation to put plant investment into rates without 24 considering their impact on the utility's "rates of profit," as Bonbright characterizes the issue. 25 26 Does Mr. Tatum have a valid point? 27 READING, DI - 6 28 INDUSTRIAL CUSTOMERS OF IDAHO POWER I A. No. One of the primary causes of regulatory lag is when a commission takes an 2 unreasonably long time to prosecute a general rate case. Given the premise of your question, it i. 3 important to keep in mind, however, that a reasonable time period between a rate-case-tiling and 4 5 that rate-case-final order is not only normal, it is expected and accepted by all involved -- 6 including prospective investors in a state sanctioned regulated monopolies. That said, the Idaho 7 Commission has, in my experience been efficient and timely in prosecuting rate cases for the 8 regulated utilities under its jurisdiction — including Idaho Power. 9 Q. Has the Idaho Commission provided Idaho Power with additional mechanisms 10 II that mitigate the impact of regulatory lag? 12 A. Yes. Idaho Power has two annual cost adjustment mechanisms -- the Power Cost 13 Adjustment (PCA) and the Fixed Cost Adjustment (FCA). Every year these two mechanisms 14 work against a claim of regulatory lag by providing Idaho Power with what are essentially 15 annual automatic cost adjustments in its rates. These are timely and prompt regulatory responses 16 17 to the ever-changing cost and cost-recovery environment in which Idaho Power operates. 18 The PCA identities the annual differences between actual net Power Supply Expenses 19 ("NPSE") and the Commission approved a base level of NPSE this is recovered in the 20 Company's base rates. It is filed by the Company in the spring of each year with the change in 21 rates taking effect on June I of each year. The FCA intends to break the link between the power 22 23 a utility sells and the revenue it receives in order to provide insurance that some of its fixed costs 24 will be recovered. It essentially `decouples' revenues from sales. The FCA is also filed each 25 spring with the change in rates taking effect on June I of each year. 26 27 28 READING, DI - 7 INDUSTRIAL CUSTOMERS OF IDAHO POWER I Q. What is the impact of the FCA and the PCA on the Company's apparent position 2 about regulatory lag? 3 A. Both the PCA and FCA adjust the Company's rates on an annual basis. Each 4 5 mechanism is, in its own right, a major step in addressing regulatory lag. They help keep the 6 company's earnings (profits) within a reasonable range that has been approved by the 7 Commission in prior general rate cases. 8 Q. Can you identify recent examples of the Idaho Commission's prompt prosecution 9 of general rate cases for Idaho Power? 10 II A. One need took no further than this case as an example of the Idaho PUC's 12 efficient and speedy resolution of rate cases on behalf of Idaho Power. 13 Q. Please explain? 14 A. This case was filed by Idaho Power on the last day of May 2024. It is schedule t 15 go to hearing on December 6, 2024, and a final order is expected by January 1, 2025. The end 16 17 result is that there is only a seven-month span between the initial filing and the final rate order. 18 The last general rate case for Idaho Power was, likewise, resolved in just seven months. 19 Q. At page 21 of his direct testimony Mr. Tatum complains that the used of a 13- 20 month average rate base results in: 21 capital investment that Idaho Po",er vvill have made to serve its customers safely and 22 reliability by January 1, 2025, not being eligible to earn an authorized rate ofrelurn unli 23 some future rate case. 24 Mr. Tatum references "some future rate case" as if it is an external event outside of the 25 Company's control. This is not so. The timing of Idaho Power's future rate cases is wholly 26 within the control and discretion of Idaho Power. If Idaho Power so chooses, "Some future rate 27 28 READING, DI - 8 INDUSTRIAL CUSTOMERS OF IDAHO POWF,R I case" can take place as early as tomorrow, or January I" or it can wait another decade and File a 2 rate case ten years from now. It is up to Idaho Power when it initiates "some future rate case." 3 Q. In sum, the Company proposes to use year-end plant balances as opposed to 4 5 historical and justifies its position by saying to do otherwise will exacerbate regulatory lag. Do 6 you agree with the Company's rationale? 7 A, No. As discussed above, there are several reasons why the Company's concerns 8 about regulatory lag are unfounded. Regulatory lag is part of the trade-off in the regulatory 9 compact that legally allows the Company to be a monopolist. In the case of Idaho Power, the 10 II Company has Commission-approved automatic rate adjustment mechanisms in place for its some 12 of its variable costs (PCA) and some of its fixed costs (FCA). In addition, rate cases in Idaho 13 are resolved in an efficient and timely manner and the Company is not restricted from Filing a 14 general rate case whenever it chooses to do so. 15 RATE SPREAD 16 17 Q. Dr. Reading how does the Company propose to assign its recommended 18 incremental revenue requirement, or rate spread, among the various customer classes? 19 A. Keep in mind that typically, in a general rate case ("GRC"), the incremental 20 revenue requirement is spread among the various customer classes based on a contemporaneous 21 cost-of-service study (COSS). However, no new COSS has been prepared for, or filed in, this 22 23 case. Rather than update its COSS, the Company is using, as guidance, the old COSS from its 24 2023 GRC case (IPC-E-23-11). Also keep in mind that a COSS is rarely, if ever, adhered to 25 religiously as a requirement for instructing the Company's (or the Commission's) rate spread 26 decisions. Rather the Company tempers and adjusts the COSS results to arrive at a reasonable 27 28 READING, DI -9 INDUSTRIAL CUSTOMERS OF IDAHO POWER I rate spread recommendation without unduly shaking up established ratepayer-company- 2 Commission expectations. Thus, the Company recommends and the Commission typically 3 adopts a rate spread method that moves customers closer to `parity' or fully cost-based rates 4 5 without causing rate shock or major customer cost-responsibility dislocations. In this case the 6 Company asserts that it is not proposing any "structural changes" in rates. [Application p. 5] 7 Q. What method did Idaho Power use to spread incremental revenues to customer 8 classes in the 2023 GRC? 9 A. In its last general rate case the Company based its rate spread recommendation on 10 II the COSS that was developed specifically for that case. The Company then allocated its 12 incremental revenue requirement and expenses to the various customer classes. That is, it based 13 its recommended movement toward cost-based rates on a rate increase percentage ceiling and 14 percentage floor. This ceiling and floor methodology was agreed to in a stipulated settlement 15 that included all of the parties to the case. 16 17 Q. What were the ceiling and floor percentages in the settlement of the last general rate 18 case? 19 A. The ceiling was 130% of the overall average increase and the floor was 50% of the 20 overall average increase. [Tatum Direct, IPC-E-23-1 1, p. 29] Thus no customer class received an 21 increase greater that 130% of the overall average and conversely no customer class received less 22 than a 50% of the overall average increase. 23 Q. What was the rate impact of use of the ceiling/floor revenue allocation method in the 24 2023 GRC on your clients who are all Schedule 19 industrial customers? 25 A. The overall percentage increase Stipulated by the Parties and approved by the 26 Commission in the 2023 GRC was 4.25%. Schedule 19 customers were assessed slightly more 27 28 READING, DI - 10 INDUSTRIAL CUSTOMERS OF IDAHO POWER I than the 50% floor for a 2.78% increase. Their increase was less than average because the cost- 2 of-service study shows that the Schedule 19 class is paying more than it costs Idaho Power to 3 provide them with electric service. Schedule 19 ratepayers are subsidizing other customer 4 classes. 5 6 Q. How does the Commission approved settlement in the last rate case compare with 7 the Company's rate spread recommendation in this limited issue rate case? 8 A. In this case the Company proposes an overall increase of 7.31% with Schedule 19 9 customers recommended to receive an increase of 7.10% increase,just 0.21 percentage points 10 II lower than the recommended overall rate increase. Using the logic (and similar percentage 12 increases) from the Company's last case the industrial class increase should be just slightly 13 higher than the floor which is 3.65% and not subject to an increase just slightly lower than the 14 overall average of 7.10%. 15 Q. How do you account for significant difference in the recommended rate increase 16 17 for the Schedule 19 customers in this case with the much lower percentage increase in Idaho 18 Power's last rate case? 19 A. Without having an updated COSS I cannot pinpoint the exact cause, however 20 there are several factors that may have impacted the change between this case and the 2023 21 GRC. 22 23 Q. What are the main factors/problems you suspect that may account for the 74 difference in the recommended overall percentage increase in rates for Schedule 19 customers 25 between this case and the last rate case? 26 27 28 READING, DI - I I INDUSTRIAL CUSTOMERS OF IDAI-10 POWER I A. The first problem is that we don't have an updated, or new, cost-of-service study. 2 It is axiomatic that there have been changes both in the relationship among customer classes as 3 well as the Company's resource mix since the 2023 GRC. The magnitude of these unknown 4 5 changes will naturally impact the results of any prospective new COSS. Therefore, we have no 6 way of knowing how these changes impact the various customer classes' cost causation or their 7 current variance from the parity index of 1.0. (A parity index of 1.0 indicates the class is paying 8 rates exactly equal to its cost-of-service -- neither more nor less.) 9 Q. Are there other factors you feel may have affected changes in class cost 10 causation? II 12 A. Yes, for Schedule 19 the Company observed that; 13 While the 2024 sales,forecast included Simplot Caldwell (Schedule 32) 14 and Lamb Weston (Schedule 34) as individually,forecasted loads, because both were included as part gf'the .Schedule 19 customer class in the 2023 15 GRC', their torecasted sales were included in the Schedide 19 class, or purposes ol'developing the Schedule 19 class revenue spread. 16 17 [Tatum Direct, p. 31. Emphasis provided.] 18 In addition, special contract customer Brisbie's (Schedule 33) proposed rates were adjusted in 19 accordance with Schedule 19. [Tatum Direct, Footnote 6, p. 31.] This is important for rate 70 spread purposes because the revenues and the costs that the company has booked for these new 21 special contract customers have been lumped into Schedule 19. So apparently the Company's 22 23 rate spread proposal contains information not only for Schedule 19 customers but for those three 24 special contract customers. That means that Schedule 19 data isn't really limited to Schedule 19 25 customers' load and sales -- it is an amalgamation of Schedule 19 and the three special contract 26 customers. There is no individual rate increase proposed for these three special contract 27 READING, DI - 12 28 INDUSTRIAL CUSTOMERS OF IDAHO POWER 1 customers in the Company's filing. This creates a potential mismatch and out-of-sync rate sprea proposal for Schedule 19 and the three new special contract customers. 3 Q. Given the issues you described above do you have an alternative recommendation 4 5 for customer class rate increase spread'? 6 A. Yes. '['he differences discussed above confound the results of what an updated 7 COSS would have accomplished they are mixing apples and oranges. Therefore, instead of 8 what the Company has proposed, I recommend that the percentage difference between the 9 overall rate increase and each individual rate class's rate increase be the same percentage 10 difference that was used and approved by the commission in the last rate case. The 2023 GRC II 12 was litigated and settled among all parties and ultimately approved by the Commission. My 13 recommendation is not necessarily a long-term Fix. A more accurate customer class allocation 14 should then be developed when the Company Files its next full general rate case along with a 15 new and current COSS. 16 17 Q. Dr. Reading what are the rate spread percentage increases you are recommending in this 18 case`' 19 A A definitive answer can't be given until the revenue requirement increase is finally 20 determined by the Commission in this docket. As a proxy, the following table indicates the 21 impact of my proposal on each customer class at the Company's requested overall increase of 77 23 7.31%. Once the Commission issues its Final order on revenue requirement the following table 24 would have to be revised accordingly. 25 26 27 READING, DI - 13 28 INDUSTRIAL CUS I-OMFRS OF IDAHO POWLR I Final Final 2 Percent Percent New Rate 3 IPC-E-23-11 IPC-E-24-7 IPC-E-24-7 4 Combined Residential 5.52% 7.25% 9.49% 5 Combined Small General Service 5.52% 7.30% 9.49% 6 Large General Service - Prim. & Trans. 2.12% 6.74% 3.65% 7 Large General Service - Secondary 2.12% 6.86% 3.65% 8 Dusk/Dawn Lighting 0.00% 3.65% 0.00% 9 Large Power Service 2.78% 7.10% 4.78% 10 Irrigation Service 5.52% 9.50% 9.49% 11 Unmetered Service 0.21% 7.46% 0.36% 12 Municipal Street Lighting 0.00% 5.96% 0.00% 13 Traffic Control Lighting 5.52% 9.50% 9.49% Micron 3.65% 5.53% 6.28% 14 Simplot 2.12% 4.58% 3.65% 15 DOE/IN L 3.67% 3.84% 6.31% 16 17 Total Idaho Retail Sales (Excluding CEYW) 4.25% 7.31 /o° 7.31% 18 19 Q. Thank you Dr. Reading. Does this conclude your pre-filed direct testimony? 20 A. Yes, it does. 21 22 Dated this day 6"' day of November 2024. 23 24 25 26 27 28 READING, DI - 14 INDUSTRIAL CUSTOMERS OF IDAHO POWER I CERTIFICATE OF SERVICE 2 I hereby certify that on this 6"' day of November 2024, I caused to be delivered via 3 electronic mail only the foregoing Direct Testimony of Dr. Don Reading in Docket No. IPC-E- 07-24 on the following parties: 4 IDAHO PUBLIC UTILITIES COMMISSION 5 6 Monica Barrios-Sanchez, secretary mon ica.barriossanchez(c7puc.idaho.gov 7 secretary gpue.idaho.g-ov 8 Chris Burdin, Deputy Attorney General 9 chris.burdin@puc.idaho.gov 10 I IDAHO POWER COMPANY I 12 Lisa D. Nordstrom Donovan E. Walker 13 Megan Goicoechea Allen lnordstroiil@idahopower.com 14 dwalker(u},idahopower.com 15 mgoicoecheaallen@idahopower.com 16 Tim Tatum Connie Aschenbrenner 17 Matt Larkin 18 ttatum ci idahopower.com caschenbrenner a idahopower.com 19 mlarkin@idahopower.com 20 21 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. 22 Eric L. Olson Lance Kaufman 23 elo(iDechohawk.com 24 lance@aegisinsight.com 25 26 27 28 READING, DI - 15 INDUSTRIAL CUSTOMERS OF IDAHO POWER I IDAHO CONSERVATION LEAGUE 2 Matthew Nykiel 3 Brad Heusinkveld matthew.nykiel(cugmail.com 4 bheusinkveld(' idahoconservation.org 5 FEDERAL EXECUTIVE AGENCIES 6 Peter Meier 7 Emily W. Medlyn peter.meier(rDhq.doe.gov s emil .ny �edlync hq;doe.gov 9 MICRON TECHNOLOGY, INC. 10 Austin Rueshhoff I I Thorvald A. Nelson 12 Austin W. Jensen Kristine A.K. Roach 13 darueschhoff�,chollandhart.com tnelson cr,hollandhart.com I4 awiensen(a,hollandhart.com 15 aclee dhollandhart.com mamemillenAhollandhart.com 16 CITY OF BOISE 17 18 Ed Jewell Steven Hubble 19 ejewellg..cityofboise.org boisecityattorney cacityolboise.org 20 shubble&cityofboise.org 21 22 Vdo 41-&4� 23 Peter J. Richardson, ISB#3195 24 25 26 27 28 READING, DI - 16 INDUSTRIAL CUSTOMERS OF IDAHO POWER 1 2 BEFORE THE 3 IDAHO PUBLIC UTILITIES COMMISSION 4 5 IN THE MATTER OF THE APPLICATION OF Idaho Case No.: IPE-E-07-24 POWER COMPANY FOR AUTHORITY TO 6 INCREASE RATES FOR ELECTRIC SERVICE TO RECOVER COSTS ASSOCIATED WITH 7 INCREMENTAL CAPITAL INVESTMENTS AND EXHIBIT 301 CERTAIN ONGOING OPERATIONS AND 8 MAINTENANCE EXPENSES. 9 10 INDUSTRIAL CUSTOMERS I of 12 IDAHO POWER COMPANY 13 Dr. Don Reading's Statement of Qualificaitons 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT 301 - 1 Don Reading, PhD. Consulting Economist Education B.S., Economics: Utah State University M.S., Economics: University of Oregon PhD., Economics: Utah State University Honors and awards Omicron Delta Epsilon NSF Fellowship Profession and business history Teaching: 1980-81 Associate Professor, University of Hawaii-Hio 1970-80 Associate and Assistant Professor, Idaho State University 1968-70 Assistant Professor, Middle Tennessee State University Idaho Public Unities Commission: 1981-86 Economist/Director of Policy and Administration Ben Johnson Associates, Inc.: 1986 ---- Consulting Economist 1989 ---- Vice President Private Consulting Economist 2023 Experience Dr. Reading provides expert testimony concern economic and regulatory issues. He has testified on more than 40 occasions before utility regulatory commissions in Alaska, California, Colorado, the District of Columbia, Hawaii, Idaho, Nevada, North Carolina, North Dakota, Texas, Utah, Wyoming, and Washington. Dr. Reading has more than 50 years experience in the field of economics. He has participated in the development of indices reflecting economic trends, GNP growth rates, foreign exchange markets, the money supply, stock market levels, and inflation. Ile has analyzed such public policy issues as the minimum wage, federal spending and taxation, and import/export balances. Dr. Reading was one of seven economists providing yearly forecasts of statewide personal income to the State of Idaho for purposes of establishing the state of Idaho budget estimates. In the field of telecommunications, Dr. Reading has provided expert testimony on the issues of marginal cost, price elasticity, and measured service. Dr. Reading prepared a state-specific study of the price elasticity of demand for local telephone service in Idaho and conducted research for, and directed the preparation of, a report to the Idaho legislature regarding the status of telecommunications competition in that state. Dr. Reading's areas of expertise in the field of electric power include demand forecasting, long-range planning, price elasticity, marginal and average cost pricing, production-simulation modeling, and econometric modeling. Dr. Reading was affiliated with the Climate Impact Group (CIG) at the University of Washington. His work with the CIG has involved an analysis of it impact of Global Warming on the hydro power facilities on the Snake River. It also includes an investigation into water markets in the Northwest and Florida. In addition he has analyzed the economics of snowmakig for ski area's impacted by Global Warming. Among Dr. Reading's projects was a FERC hydropower re-licensing study (for the Skokomish Indian Tribe) and an analysis of Northern States Power's North Dakota rate design proposals affecting large industrial customers (for J.R. Simplot Company). Dr. Reading has also performed analysis for the Idaho Governor's Office of the impact on the Northwest Power Grid of various plans to increase salmon runs in the Columbia River Basin. Dr. Reading has prepared econometric forecasts for the Southeast Idaho Council of Governments and the Revenue Projection Committee of the Idaho State Legislature. He was also a member of several Northwest Power Planning Council Statistical Advisory Committees and was vice chairman of the Governor's Economic Research Council in Idaho While at Idaho State University, Dr. Reading performed demographic studies using cohort/survival model and several economic impact studies using input/output analysis. He has also provided expert testimony in cases concerning loss of income insulting from wrongful death, injury, or employment discrimination. Publications "Energizing Idaho", Idaho Issues Online, Boise State University, Fall 2006. www. boisestate.edu/history/issuesonline/fa[1006_issues/ ndex.html. The Economic Impact of the 2001 Salmon Season In Idaho, Idaho Fish and Wildlife Foundation, April 2003. The Economic Impact of a Restored Salmon Fishery in Idaho, Idaho Fish and Wildlife Foundation, April, 1999. The Economic Impact of Steelhead Fishing and the Return of Salmon Fishing in Idaho, Idaho Fish and Wildlife Foundation, September, 1997. A Cost Savings from Nuclear Resources Reform: An Econometric Model (with E. Ray Canterbery and Ben Johnson) Southern Economic Journal, Spring 1996. A Visitor Analysis for a Birds of Prey Public Attraction, Peregrine Fund, Inc., November, 1988. Investigation of a Capitalization Rate for Idaho Hydroelectric Projects, Idaho State Tax Commission, June, 1988. "Post-PURPA Views," In Proceedings of the NARUC Biennial Regulatory Conference, 1983. An Input-Output Analysis of the Impact from Proposed Mining in the Challis Area (with R. Davies). Public Policy Research Center, Idaho State University, February 1980. Phosphate and Southeast: A Sociology Economic Analysis (with J. Eyre, et al). Government Research Institute of Idaho State University and the Southeast Idaho Council of Governments,August 1975. Estimating General Fund Revenues of the State of Idaho (with S. Ghazanfar and D. Holley). Center for Business and Economic Research, Boise State University, June 1975. "A Note on the Distribution of Federal Expenditures: An Interstate Comparison, 1933-1939 and 1961-1965." The American Economist, 01. XVIII, No.2 (Fall 1974), pp. 125-128. "New Deal Activity and the States, 1933-1939." Journal of Economic History, Vol. XXXII, December 1973, pp. 792-810. I