20241106Direct Kimberly Loskot.pdf

RECEIVED
Wednesday, November 6, 2024 1:15:40 PM
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-24-07
COMPANY TO INCREASE RATES )
FOR ELECTRIC SERVICE TO )
RECOVER COSTS ASSOCIATED )
WITH INCREMENTAL CAPITAL )
INVESTMENTS AND CERTAIN )
ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES )
DIRECT TESTIMONY OF KIMBERLY LOSKOT
IDAHO PUBLIC UTILITIES COMMISSION
NOVEMBER 6, 2024

1 Q. Please state your name and business address .
2 A. My name is Kimberly Loskot . My business address
3 is 11331 W. Chinden Blvd. , BLDG 8, STE 201-A, Boise,
4 Idaho 83714 .
5 Q. By whom are you employed and in what capacity?
6 A. I am employed by the Idaho Public Utilities
7 Commission ("Commission") as a Utilities Analyst 2 in the
8 Technical Analysis team.
9 Q. Please describe your educational background and
10 professional experience .
11 A. I was hired by the Commission in 2022 . I
12 graduated from Boise State University with a Bachelor of
13 Business Administration degree in Business Economics and
14 a certificate in Business Analytics in 2022 . In addition
15 to formal education, I have attended the Northwest Public
16 Power Association' s Wildfires : What Utilities Need to
17 Know Conference and Western Interstate Energy Board' s
18 2023 and 2024 Winter Wildfire Meeting. I also attended
19 the National Association of Regulatory Utility
20 Commissioners Utility Rate School in May 2023 . I have
21 reviewed and provided recommendations in a range of cases
22 to the Commission. For example, I have done analyses and
23 provided recommendations in cases of utilities' deferrals
24 and conducted prudence reviews of capital investments in
25 general rate cases and Certificate for Public Convenience
CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 1
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I and Necessity cases .
2 Q. What is the purpose of your testimony in this
3 proceeding?
4 A. The purpose of my testimony is to present
5 several adjustments to Idaho Power Company' s ("Idaho
6 Power" or "Company") proposed revenue requirement for
7 specific capital projects . These adjustments were
8 provided to Staff Witness Chandler to incorporate into
9 his calculation of Staff' s proposed revenue requirement .
10 Q. What Capital Project adjustments are you
11 proposing?
12 A. I am proposing adjustments for the following
13 capital projects :
14 - Grid Modernization Pg. 3
15 - Itron Enterprise Edition License
16 Expansion 2024 Pg. 4
17 - Outage Alert Auto Enrollment Pg. 5
18 - SharePoint 2024 Development Pg. 6
19 - Non-Criteria Based Equipment Pg. 7
20 - CHQ - Upgrade Conference Rooms Pg. 8
21 - 2021 Keystone Retreat Destination
22 Trailer and Purchase Park Model Mobile
23 Housing Pg. 9
24 Q. Are you sponsoring any exhibits?
25 A. No .
CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 2
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I Grid Modernization
2 Q. Please provide a brief overview of the Grid
3 Modernization ("Grid Mod") project .
4 A. As stated in Company Witness Colburn Testimony
5 on page 28, Idaho Power leverages three stand-alone grid
6 control systems for managing the bulk electric system,
7 optimizing distribution assets, and responding to
8 customer outages . The systems are the (1) Energy
9 Management ("EMS") /Supervisory Control and Data
10 Acquisition ("SCADA") system, (2) the Outage Management
11 System ("OMS") , and (3) the Integrated Volt/Var Control
12 ("IVVC") , a Distribution Management System. The Grid Mod
13 project is a single vendor platform that consolidates all
14 three grid control systems into a single platform. The
15 IVVC phase was placed in-service in 2020 and is not in
16 the scope of this rate case . In this case, the Company is
17 seeking recovery of $11 . 5 million for the EMS/SCADA
18 phase, which will allow for the operation of the SCADA
19 devices for control that can also be used during a Public
20 Safety Power Shutoff. In its response to Staff Production
21 Request No . 32 (b) -Attachment 1, the Company estimated
22 that the EMS/SCADA phase will be placed in service in
23 December 2024 . Given the uncertainty of when this
24 project will be in service and the inability of Staff to
25 review the prudence of actual final cost, Staff made an
CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 3
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1 adjustment to remove it from the Company' s proposed
2 revenue requirement increase . Staff' s rationale is
3 explained further in Staff Witness Louis' testimony.
4 Q. Other than not being in-service before Staff s
5 proposed cutoff date of August 31, 2024, would you
6 recommend another adjustment for the Grid Mod project?
7 A. Yes . If the Commission allows recovery of the
8 EMS/SCADA phase, I recommend a corresponding adjustment
9 to reduce the Company' s Operations and Maintenance
10 Expense by $3 million.
11 Q. What is the basis for your recommendation?
12 A. As stated in the Company' s response to Staff
13 Production Request No . 58, the financial analysis results
14 in the project' s business case analysis indicate expected
15 revenue requirement savings of approximately $3 million
16 on a net present value basis . The Company has not shown
17 that it applied the expected savings of the project in
18 the previous rate case or in the current case . If
19 recovery of the EMS/SCADA phase is included in this case,
20 the savings should also be realized as two of the three
21 phases of the project will be completed.
22 Itron Enterprise Edition ("IEE") License Expansion 2024
23 Q. What is the IEE License Expansion 2024 project?
24 A. The Company included for recovery in this case
25 the cost of an additional 20, 000 software licenses for
CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 4
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1 the Company' s meter data management system.
2 Q. What is the reason for recommending an
3 adjustment for this project?
4 A. The Company placed this project in-service in
5 May 2024 . However, the business need indicates that the
6 additional purchased licenses are not needed and will not
7 be in use until September 2025 . The purchased licenses
8 will therefore not be used and useful by the August 31,
9 2024 cut-off date discussed in Staff Witness Louis'
10 testimony.
11 Q. What is the proposed adjustment for this
12 project?
13 A. Based on the information provided by the
14 Company, this project will not be used and useful until
15 September 2025; therefore, I recommend disallowing the
16 project cost of $22, 748 from base rate recovery.
17 Outage Alert Auto Enrollment
18 Q. Please describe the Outage Alert Auto
19 Enrollment capital included in the Company' s case .
20 A. The Company placed this project in-service in
21 March 2024 . The Company' s response to Staff Production
22 Request No . 125 expanded upon the business need of being
23 more proactive with customer notifications and clarified
24 that customers would be automatically enrolled to receive
25 email, text, and push notifications of outages and outage
CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 5
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1 related information.
2 Q. What is the reason for recommending an
3 adjustment for this project?
4 A. Outage-related notifications are currently
5 available through multiple systems, both as an auto-
6 enrollment and as a self-enrollment, making this new
7 system redundant and imprudent .
8 Auto-enrollment already takes place through: 1)
9 Enterprise Omni-Channel Notification System; 2) Automated
10 Dialer System; and 3) Grid Mod project (pending
11 implementation) .
12 Self-enrollment takes place through: 1)
13 MyAccount system; and 2) Outage Maps Notifications
14 system.
15 Q. What is the proposed adjustment for this
16 project?
17 A. As this project' s function is redundant with
18 similar functions carried out by multiple other systems,
19 I recommend disallowing the total project cost of
20 $1, 147, 600 from recovery in base rate .
21 SharePoint 2024 Development
22 Q. What is the reason for recommending an
23 adjustment for this project?
24 A. In its response to Staff Production Request No .
25 5-Attachment 1, the Company stated, "SharePoint 2016 goes
CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 6
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1 end of life in July 2026, and that the SharePoint 2024
2 Development Project will take over two years to
3 complete . " Based on this information, the project will
4 not be in-service or used and useful until after Staff' s
5 proposed cutoff date .
6 Q. What is the proposed adjustment for this
7 project?
8 A. As the existing SharePoint services are viable
9 and supported until after Staff' s proposed cutoff date, I
10 recommend disallowing the total project cost of $257, 485
11 from base rate recovery.
12 Non-Criteria Based Equipment
13 Q. Please describe the Non-Criteria Based
14 Equipment capital included in the Company' s case .
15 A. The Company' s response to Staff Production
16 Request No . 54 stated the project is for purchases of
17 equipment that are part of Idaho Power' s critical
18 business function and used in day-to-day operations .
19 A trailer-mounted four drum puller was
20 purchased to replace a comparable piece of equipment that
21 was destroyed. An additional zero-turn lawn mower was
22 purchased to provide a third lawn mower for use at the CJ
23 Strike parks complex. It was noted that currently there
24 are three full-time park employees and one seasonal
25 employee, and it takes approximately 25 hours per week to
CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 7
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1 mow the turf with two zero-turn mowers . The Company
2 stated the benefits of having an additional mower was to
3 have a backup unit for an additional staff member to
4 assist in managing mowing when other work is complete,
5 having the same model mower that has interchangeable
6 parts with others, and reducing the total mowing time by
7 30% .
8 Q. What is the proposed adjustment for this
9 project?
10 A. I recommend disallowing $19, 350 for the
11 recovery of the cost for the additional mower.
12 Q. What is the reason for recommending an
13 adjustment for this project?
14 A. The Company did not provide a cost-benefit
15 analysis to justify the additional expense, and I believe
16 that the current lawn care equipment is sufficient, and
17 an additional mower is unnecessary. The Company' s
18 rationale for time saving relies on an additional
19 employee to assist the other two workers, which is not
20 guaranteed. It is reasonable for lawn maintenance shared
21 between four staff members to be completed in
22 approximately 25 hours per week. Therefore, I do not
23 believe it was a necessary purchase .
24 Upgrade Conference Rooms
25 Q. Please describe the Upgrade Conference Rooms
CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 8
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1 project .
2 A. In its response to Staff Production Request No .
3 5-Attachment 1, the Company stated that, "The conference
4 rooms are dark and have mismatched furniture, and that
5 updates will add cohesiveness and brightness to the rooms
6 through whatever means makes the most sense for that
7 conference room. Bringing in outside light if/when
8 possible . "
9 Q. What is the reason for recommending an
10 adjustment for this project?
11 A. Based on the information provided by the
12 Company, aesthetics are the only business need for the
13 conference room remodel, which I do not believe is
14 prudent .
15 Q. What is the proposed adjustment for this
16 project?
17 A. I propose to disallow the total work order cost
18 of $153, 419 associated with the project from base rate
19 recovery.
20 2021 Keystone Retreat Destination Trailer & Purchase Park
21 Model Mobile Housing for Seasonal Employees
22 Q. Please describe the Keystone Retreat
23 Destination Trailer and the Park Model Mobile Housing
24 projects .
25 A. In its response to Staff Production Request
CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 9
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1 Nos . 5 and 57, the Company indicated that parks cannot
2 keep seasonal workers due to the distance they have to
3 travel daily to Hells Canyon Complex. Therefore, the
4 Company purchased four trailers for seasonal housing for
5 retention of seasonal employees .
6 Q. What is the reason for recommending an
7 adjustment for these two projects?
8 A. The industry standard practice compensation for
9 campground hosts and on-site maintenance staff includes
10 the use of an RV site as part of their compensation.
11 There are three typical compensation arrangements for
12 campground hosts and on-site maintenance staff:
13 1 . Paid employee with a free RV site;
14 2 . Voluntary worker with free RV site; and
15 3 . Paid employee with no lodging.
16 Additionally, the Company does not charge rent to the
17 seasonal employees for the use of the trailers .
18 Q. What is the proposed adjustment for this
19 project?
20 A. As the expenditures extends beyond standard
21 industry practice, I propose to disallow the total
22 project cost of $58, 135 for the 2021 Keystone Retreat
23 Destination Trailer and the total project cost of
24 $254, 075 for the Park Model Mobile Housing for Seasonal
25 Employees for a total adjustment of $312, 210 from base
CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 10
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1 rate recovery. However, if the Commission decides to
2 include the costs of temporary employee housing for
3 recovery in this case, a corresponding adjustment to
4 impute rent revenue should be made . It would not be
5 reasonable for customers to pay for the costs of employee
6 housing through an increase in rates while also not
7 receiving the appropriate rent revenue the Company should
8 be charging for the housing units .
9 Q. Does this conclude your testimony?
10 A. Yes, it does .
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CASE NO. IPC-E-24-07 LOSKOT, K. (Di) 11
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS &DAY OF NOVEMBER 2024,
SERVED THE FOREGOING DIRECT TESTIMONY OF KIMBERLY LOSKOT, IN
CASE NO. IPC-E-24-07, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
LISA D. NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: lnordstromnidahopower.com E-MAIL: ttatum a,idahopower.coin
dwalker�uidahopower.com caschenbrenner,�idahopower.com
mgoicoecheaallen(cidahopower.com mlarkin(c�idahopower.com
dockets(ctidahopower.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance Lwae isinsight.com
E-MAIL: elo.c echohawk.com
PETER J RICHARDSON DR DON READING
RICARDSON ADAMS PLLC 280 S SILVERWOOD WAY
515 N 27TH STREET EAGLE ID 83616
BOISE ID 83702 E-MAIL: dreading,Lcbmindspring.com
E-MAIL: peter arichardsonadams.com
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
heusinkveld cr,idahoconservation.org
PETER MEIER EMILY W MEDLYN
US DEPT OF ENERGY US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW 1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585 WASHINGTON DC 20585
E-MAIL: peter.meier i hq.doe.gov E-MAIL: Emily.medlynLcvhq.doe.goov
CERTIFICATE OF SERVICE

JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 KRISTINE A.K. ROACH
E-MAIL: jswiernmicron.com HOLLAND &HART LLP
555 17TH ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoff c hollandhart.com
tnelson Lcthollandhart.com
aw�e�nsenchollandhart.com
karoach Labollandhart.com
acleechollandhart.com
mamcmillen�ic,hollandhart.com
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S PO BOX 500
PO BOX 500 BOISE ID 83701-0500
BOISE ID 83701-0500 E-MAIL: shubble��citvofboise.org
E-MAIL: ejewellLa cityofboise.org
boisecityattorney,c cityofboise.org
4PARICI&AJ�ORDAN, E RETARY
CERTIFICATE OF SERVICE