20241106Direct Laura Conilogue.pdf

RECEIVED
Wednesday, November 6, 2024 4.06.44 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 LAURA CONILOGUE
IDAHO PUBLIC UTILITIES COMMISSION
NOVEMBER 6, 2024

1 Q. Please state your name and business address for
2 the record.
3 A. My name is Laura Conilogue, and my business
4 address is 11331 W. Chinden Blvd, Suite 201-A, Boise ID,
5 83714 .
Q. By whom are you employed and in what capacity?
7 A. I am employed by the Idaho Public Utilities
8 Commission as an Auditor II .
9 Q. What is your educational and professional
10 background?
11 A. I graduated from Idaho State University in 2010
12 with a degree in International Business . I started at
13 the Public Utilities Commission in February 2022 as a
14 Financial Specialist on the Audit Team. In August 2022,
15 I was promoted to Auditor T, and in May 2023 I was
16 promoted to Auditor II . I have performed audits and made
17 recommendations to the Commission in several cases
18 regarding revenue requirement, fuel tracking mechanisms,
19 and energy efficiency reviews .
20 Q. What is the purpose of your testimony in this
21 proceeding?
22 A. The purpose of my testimony is to present an
23 adjustment to the labor expense included for recovery in
24 Idaho Power Company, Inc. ' s ("Company" or "Idaho Power")
25 rate case . This adjustment was provided to Staff Witness
CASE NO. IPC-E-24-07 Conilogue, L. (Di) 1
11/06/24 STAFF

1 Chandler to incorporate into his calculation of Staff' s
2 proposed revenue requirement . The amounts presented in
3 my testimony are system-wide amounts, however in Staff
4 Witness Chandler' s testimony, only the Idaho
5 jurisdictional amounts are included in Staff' s proposed
revenue requirement .
7 Q. Are you sponsoring any exhibits in this
8 proceeding?
9 A. Yes, I am sponsoring Exhibit No . 110 which
10 illustrates my calculated Company' s 0&M Labor Expense
11 that should be included in rates and compares it to the
12 Company' s calculation.
13 Q. What is the Company proposing for 2024 0&M
14 Labor Costs .
15 A. The Company forecasted its 2024 0&M Labor
16 Expense to be $207, 578, 204, and then included an
17 additional three percent increase to account for a
18 general wage adjustment ("GWA") to be awarded in 2025 .
19 The total 0&M included for recovery in the Company' s case
20 was $213, 480, 186 .
21 Q. How did Idaho Power calculate the forecasted
22 2024 0&M Labor Expense?
23 A. As stated in Company Witness Larkin' s Testimony
24 on page 18 : "Expected 2024 0&M Labor was calculated
25 utilizing the same general methodology applied in the
CASE NO. IPC-E-24-07 Conilogue, L. (Di) 2
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I Company' s 2023 GRC. First, the Company developed a
2 three-year history of the ratio between February year-to-
3 date O&M Labor expenses and full year 0&M Labor expenses .
4 This ratio was then applied to month-end February 2024
5 year-to-date 0&M Labor, to determine the expectation of
full year 2024 0&M Labor expenses . An annualizing
7 adjustment was then applied based on year-end 2023
8 levels, and a 2025 general wage adjustment ("GWA") of
9 three percent was added. "
10 Q. What issues do you have with the Company' s 0&M
11 Labor Expense?
12 A. While reviewing the Company' s calculations, I
13 found three areas to the calculation that should be
14 updated, removed, or modified.
15 The first adjustment I propose is to update the
16 Company' s forecast using actual Labor Expense through
17 August 2024 . The Company used payroll numbers from
18 February 2024 . At the time the Company filed the rate
19 case, February payroll was the most recent which could be
20 incorporated into the Company' s forecast; however, the
21 Company now has incurred six additional months of payroll
22 which should be considered because it will produce a more
23 accurate number for the projected 2024 0&M labor expense .
24 Second, the Company added a 2023 annualizing
25 adjustment of $1, 561, 952 to their projected labor
CASE NO. IPC-E-24-07 Conilogue, L. (Di) 3
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1 forecast . An annualizing adjustment takes payroll from
2 December of the previous year and annualizes it to find
3 what the total payroll for the following year should be .
4 However, since Idaho Power is already annualizing the
5 2024 payroll, there is no need to add a 2023 annualizing
adjustment . The 2023 annualization on top of the 2024
7 annualization could lead to a double counting of payroll
8 expense .
9 The third reason I believe Idaho Power' s 2024 labor
10 forecast is incorrect is because the Company added the
11 2025 three percent GWA.
12 Q. Please explain why Staff removed Idaho Power' s
13 2025 GWA.
14 A. The 2025 GWA is the forecasted increase the
15 Company is planning on giving its employees in 2025 . The
16 2025 GWA occurs well beyond Staff' s proposed cut-off date
17 of August 31, 2024, for inclusion of expenses and would
18 not take effect until several months after new rates will
19 be in effect from this case . It is not known and
20 measurable as the actual 2025 GWA has not been determined
21 or awarded, and 2025 Labor Expense cannot be accurately
22 calculated. Additionally, as the Company experiences
23 employee turnover, there could be savings because new
24 employees should be paid less than the experienced
25 employees they are replacing.
CASE NO. IPC-E-24-07 Conilogue, L. (Di) 4
11/06/24 STAFF

1 Q. How did you calculate a reasonable 2024 Labor
2 Expense?
3 A. I calculated a 2024 Labor Expense using a
4 similar methodology to the Company' s . I propose a total
5 Labor Expense to be included for recovery of
$203, 001, 857, which is $10, 478, 329 less than the
7 Company' s proposal . However, my proposal is still
8 $9, 079, 206 over the 2023 Payroll Settlement amount of
9 $193, 922, 651 . My calculated Labor Expense is an increase
10 of 4 . 5% above what was included for recovery in the
11 Company' s 2023 general rate case .
12 Q. How did you calculate this number?
13 A. First, I used 2024 payroll through August to
14 establish an updated 2024 projected base, instead of
15 February, like the Company used. August was the most
16 recent complete payroll information available before
17 preparation of my testimony. Using payroll through
18 August provides additional data which will provide a more
19 accurate annualized payroll for 2024 . Consistent with
20 the Company' s methodology, I then applied the three-year
21 historical ratio between January through August year-to-
22 date 0&M Labor expenses and full year 0&M Labor expense,
23 to annualize the 2024 Labor Expense .
24 Q. Please explain the difference in amounts
25 between the Company' s request using February numbers, and
CASE NO. IPC-E-24-07 Conilogue, L. (Di) 5
11/06/24 STAFF

1 Staffs proposal using August numbers .
2 A. The Company' s projected annualized base using
3 January and February payroll was $198, 678, 494 . Staff s
4 projected annualized base using January through August is
5 $195, 664, 099 for a difference of $3, 014, 395 .
Q. What other adjustments do you propose to the
7 Company' s forecasted 0&M Labor Expense?
8 A. As I previously mentioned, Staff is proposing
9 to remove the 2025 GWA from the Company' s forecast, which
10 reduces labor expense by an additional $5, 901, 982 .
11 Also mentioned earlier, I have removed the
12 $1, 561, 952 annualization of December 2023 payroll . The
13 total of the three adjustments I propose reduces the
14 Company' s 0&M Labor Expense recovery by $10, 478, 329 as
15 shown on my Exhibit No . 110
16 Q. Does this conclude your direct testimony in
17 this proceeding?
18 A. Yes, it does .
19
20
21
CASE NO. IPC-E-24-07 Conilogue, L. (Di) 6
11/06/24 STAFF

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS �&DAY OF NOVEMBER 2024,
SERVED THE FOREGOING DIRECT TESTIMONY OF LAURA CONILOGUE, 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: lnordstrom c idahopower.com E-MAIL: ttatum(iTidahopower.com
dwalker idahopower.com caschenbrenner 6tidahopower.com
mgoicoecheaallen(ctidahopower.com mlarkin ctidahopower.com
dockets(�idahopower.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: lanceLaegisinsi hg t.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 Lctmindspring coin
E-MAIL: peter..�richardsonadams.com
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
heusinkveldacidahoconservation.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�hq.doe.gov E-MAIL: Emily.medlyn�hq.doe.gov
i
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: jswiergmicron.com HOLLAND & HART LLP
555 17TH ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoff c,hollandhart.com
tnelson,hollandhart.com
awj ensen(cr�holl andhart.com
karoach cct hollandhart.com
acleena,hollandhart.com
mamcmillen(a,,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(cUcitvofboise.org
E-MAIL: ejewell atcityofboise.org
boisecityattorneya,cityofboise.org
F
P ICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE