20241107Direct James Leyko - Redacted.pdf

RECEIVED
Wednesday, November 6, 2024
IDAHO PUBLIC
BEFORE THE UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE RATES FOR ) CASE NO. IPC-E-24-07
ELECTRIC SERVICE TO RECOVER )
COSTS ASSOCIATED WITH )
INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS )
AND MAINTENANCE EXPENSES. )
REDACTED VERSION
Direct Testimony and Exhibits of
James A. Leyko
On behalf of
Micron Technology, Inc.
November 6, 2024

Table of Contents to the
Direct Testimony of James A. Leyko
I. SUMMARY...................................................................................................................... 2
II. INCREMENTAL CAPITAL ADDITIONS AND RATE BASE METHODOLOGY................. 4
III. INCREMENTAL O&M LABOR........................................................................................11
IV. INCREMENTAL REVENUES.........................................................................................14
Appendix A: Qualifications of James A. Leyko
Declaration of James A. Leyko
Exhibits:
Confidential Exhibit No. 601 - Staff Request No. 62 (Rate Base Update)
Exhibit No. 602 — End of Year Rate Base Adjustment
Exhibit No. 603 — Micron Request No. 9 (Additional JSS Scenarios)
Confidential Exhibit No. 604 —Year End Adjustments
Confidential Exhibit No. 605 — O&M Labor Adjustment
Exhibit No. 606 — Staff Request No. 3 (Larkin Workpaper 7)
Confidential Exhibit No. 607 — Staff Request No. 36 (Actual kWh Sales)
Exhibit No. 608 — Revised Revenue Forecast
Leyko, Di i
Micron Technology, Inc.

1 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A James A. Leyko. My business address is 16690 Swingley Ridge Road, Suite 140,
3 Chesterfield, MO 63017.
4 Q WHAT IS YOUR OCCUPATION?
5 A I am a consultant in the field of public utility regulation with the firm of Brubaker &
6 Associates, Inc., energy, economic and regulatory consultants.
7 Q PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND EXPERIENCE.
8 A This information is included in Appendix A to my testimony.
9 Q ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING?
10 A I am appearing on behalf of Micron Technology, Inc., a large customer of Idaho Power
11 Company ("IPC" or "Company").
12 Q WHAT IS THE PURPOSE OF YOUR TESTIMONY?
13 A The purpose of my testimony is to address IPC's proposed revenue requirement and
14 revenue deficiency.
15 Q DOES THE FACT THAT YOU DID NOT ADDRESS EVERY ISSUE RAISED IN IPC'S
16 TESTIMONY MEAN THAT YOU AGREE WITH IPC'S TESTIMONY ON THOSE
17 ISSUES?
18 A No. It merely reflects that I chose not to address all those issues in my testimony. It
19 should not be read as an endorsement of, or agreement with, IPC's position on such
20 issues. In addition, other parties may offer reasonable adjustments to IPC's revenue
21 requirement.
Leyko, Di 1
Micron Technology, Inc.

I. SUMMARY
1 Q PLEASE SUMMARIZE YOUR CONCLUSIONS AND RECOMMENDATIONS.
2 A I recommend several adjustments to IPC's claimed revenue deficiency. As outlined in
3 Table JAL-1 below, I believe the Company's claimed revenue deficiency of $99.293
4 million is overstated by at least $43.612 million. I recommend rejecting IPC's use of a
5 year-end rate base methodology, IPC's 2024 O&M labor forecast, and IPC's 2024
6 revenue forecast.
TABLE JAL-1
Revenue Requirement Adjustments
($000)
Line Description Amount
1 Claimed Revenue Deficiency $ 99,293
Adjustments
2 Reject End of Year Rate Base $ 28,511
3 Corrected Incremental O&M Labor 9,631
4 Corrected Revenue Forecast 5,470
5 Total Adjustments $ 43,612
6 Revised Revenue Deficiency $ 55,681
7 In Sections 11 through IV of my direct testimony I will explain each of the adjustments
8 shown in the above table.
9 Q CAN YOU BRIEFLY DESCRIBE IPC'S REQUEST FOR A LIMITED ISSUE RATE
10 CASE?
11 A Yes. In this limited issue rate case, IPC's proposed rate increase is limited to
12 incremental plant additions to rate base, incremental labor costs, and incremental
Leyko, Di 2
Micron Technology, Inc.

1 revenues relative to the Company's last general rate case, Case No. IPC-E-23-11
2 ("2023 G RC").
3 Q PLEASE BRIEFLY DESCRIBE YOUR RECOMMENDED RATE BASE
4 ADJUSTMENT.
5 A I recommend that IPC's test year rate base be calculated using an Average of Monthly
6 Averages ("AMA") approach as the Commission has approved in prior dockets, rather
7 than the end of year approach proposed by IPC. My recommendation is consistent
8 with past Commission practice and eliminates the "mismatch" in how IPC measures
9 various revenue requirement components. For example, under IPC's approach,
10 incremental plant additions were estimated by comparing the forecasted year-end 2024
11 plant balances to plant balances in the 2023 GRC. ' IPC also calculated the
12 incremental depreciation expense based on the 2024 year-end plant balances and the
13 depreciation rates approved in Case No. IPC-E-21-18. However, IPC forecasted
14 accumulated depreciation using a mid-year average approach rather than using a year-
15 end value like the Company did for plant balances.2 Correcting this mismatch by using
16 the Commission-approved AMA approach reduces IPC's claimed revenue deficiency
17 by approximately $28.51 million. I will discuss other issues with IPC's rate base
18 methodology later in my direct testimony.
19 Q PLEASE BRIEFLY DESCRIBE YOUR RECOMMENDED LABOR COST
20 ADJUSTMENT.
Direct Testimony of Matthew T. Larkin at 14:14-23.
2 Id. at 16:13-16 ("The mid-year average was determined by adding the adjusted December
2023 balance and the forecasted December 2024 balance and dividing the total by two.").
Leyko, Di 3
Micron Technology, Inc.

1 A I recommend that the Commission both (1) use actual 2024 labor expense to the extent
2 that information is available, rather than the forecasted labor expense presented in
3 IPC's original application, which appear to have overstated O&M labor costs; and (2)
4 exclude the Company's proposed 2025 labor expense adjustment because that
5 adjustment is outside of the test year considered in this case. These two corrections
6 reduce IPC's claimed revenue deficiency by approximately $9.631 million.
7 Q PLEASE BRIEFLY DESCRIBE YOUR RECOMMENDED INCREMENTAL REVENUE
8 ADJUSTMENT.
9 A I recommend two adjustments to IPC's incremental revenue calculation. IPC is in a
10 period of load growth. As a result, incremental revenues are growing in 2024 compared
11 to 2023. That revenue growth will naturally offset some of IPC's growing costs in 2024
12 — costs that are needed to serve the growing load. I recommend the Commission
13 calculate incremental revenues by(1) using actual 2024 kWh sales figures to the extent
14 that information is available, rather than the forecasted sales presented in the
15 Company's original application which appear to have understated sales growth; and
16 (2) reject IPC's proposal to multiply incremental kWh sales by a "partial" cents-per-kWh
17 rate to derive the incremental revenues. This adjustment reduces IPC's claimed
18 revenue deficiency by approximately $5.470 million.
II. INCREMENTAL CAPITAL ADDITIONS
AND RATE BASE METHODOLOGY
19 Q HOW DOES IPC PROPOSE TO CALCULATE ITS RATE BASE IN THIS CASE?
20 A IPC generally proposes to calculate its rate base using a forecasted year-end rate base
21 methodology, meaning that it has developed its proposed rate increase based on a
22 forecasted level of rate base at the end of 2024. However, as discussed below, IPC
Leyko, Di 4
Micron Technology, Inc.

1 calculates accumulated depreciation as of mid-2024 yet uses other periods to estimate
2 customers and revenues.
3 Q DID IPC EXPLAIN WHY IT GENERALLY PROPOSES TO USE A FORECASTED
4 YEAR-END RATE BASE?
5 A Yes. IPC witness Timothy E. Tatum cites regulatory lag as a primary reason for
6 proposing a year-end rate base.
7 The use of year-end plant balances as opposed to a historical monthly
8 average will ensure that the rate base included in customer rates reflects
9 plant investments placed in service up to the time rates go into effect,
10 thereby reducing, albeit not eliminating, regulatory lag.'
11 Q DO YOU BELIEVE IT IS NECESSARY TO CALCULATE IPC'S REVENUE
12 REQUIREMENT USING A FORECASTED YEAR-END RATE BASE IN ORDER TO
13 ADDRESS REGULATORY LAG?
14 A No. First, the Commission has specifically endorsed using an AMA methodology for
15 rate base in recent decisions.
16 Second, IPC has not proven it is necessary to remove regulatory lag via a rate
17 base methodology the Commission has recently rejected nor has the Company taken
18 all potential steps to address regulatory lag in this rate case. As noted below, there are
19 instances where lag benefits IPC and the Company has not taken steps to address that
20 lag. While IPC uses a forecasted year end methodology for plant additions, it does not
21 use the year end value for other aspects of the Company's rate base or revenue
22 deficiency calculation. This creates a mismatch between costs and revenues.
23 Q WHAT IS REGULATORY LAG?
3 Direct Testimony of Timothy E. Tatum at 20:18—21:1.
Leyko, Di 5
Micron Technology, Inc.

1 A The term regulatory lag refers to the time interval between the occurrence of a cost or
2 revenue and the recognition of the same cost or revenue in customer rates.
3 Q IS REGULATORY LAG A BAD THING?
4 A No, not necessarily. The Company seeks to reduce regulatory lag as a means to
5 protect the Company against earnings attrition. Earnings attrition can certainly occur if
6 there is too great a time period between when a cost is incurred and when that cost is
7 reflected in rates, particularly if the cost increases at issue are not associated with
8 increased revenues. Nevertheless, regulatory lag is intended as an incentive-based
9 feature of cost of service/rate of return regulation and serves an important function.
10 Regulatory lag is intended to promote efficiency by encouraging economic sales growth
11 and cost-reducing behaviors by the utility. Specifically, regulatory lag provides the
12 utility with an incentive to become efficient and reduce costs because the utility has the
13 ability to retain earnings between rate cases, even if those earnings exceed authorized
14 returns. Thus, utilities have an incentive to manage or even reduce cost of service
15 between rate cases, since all of the cost savings that the utility is able to achieve go
16 directly to its bottom line.
17 Q HAS THE COMMISSION RECENTLY ISSUED A DECISION ON THE PREFERRED
18 METHOD TO CALCULATE A UTILITY'S RATE BASE?
19 A Yes. The Commission addressed this issue in the Veolia Water Idaho, Inc. ("Veolia")
20 rate case (Case No. VEO-W-22-02) in Order No. 35762 on April 28, 2023. In that rate
21 case the Commission used an AMA rate base to calculate Veolia's rate base.
22 The Commission finds it fair,just, and reasonable to establish a revenue
23 requirement for the Company using rate base levels based on the AMA
24 from December 31, 2021, through December 31, 2022. The
25 Commission continues to believe that including plant investment in the
26 calculation of rate base as if it were in service the entire year creates a
Leyko, Di 6
Micron Technology, Inc.

1 mismatch between test year revenue and expenses, and it is
2 unreasonable to expect the Commission to allow full recovery of plant
3 investment as if the plant has been in operation the full year without a
4 corresponding adjustment to revenues and expenses.4
5 1 believe the Commission should reach a similar conclusion in this case.
6 Q WERE VEOLIA'S REASONS FOR REQUESTING A YEAR-END RATE BASE
7 SIMILAR TO IPC'S REQUEST IN THIS PROCEEDING?
8 A I believe so. Mr. Tatum cites regulatory lag and the Company's significant capital
9 investment as reasons the Commission should use a year-end rate base.' The
10 Commission considered both of these factors in the Veolia case. Order No. 35762
11 summarized Veolia's arguments for using a year-end rate base.
12 The Company contends that in an environment where the Company is
13 making large capital investments, using the averaging of historical rate
14 base method omits capital additions in-service when new rates will be
15 in effect, and may decrease or deny the Company the opportunity to
16 recover the value of investments made during this period. The
17 Company recommends that the Commission reconsider the old Orders
18 relied on by Staff and consider the regulatory lag created, the mismatch
19 in revenues to rate base, rate base growth, inflation, from a holistic
20 standpoint and utilize a test year end rate base in this case.6
21 The Commission appears to have considered regulatory lag as a justification for a
22 year-end rate base and rejected it in the Veolia rate case. Therefore, I recommend the
23 Commission make the same decision in this rate case.
24 Q YOU STATED ABOVE THAT IPC'S APPROACH CREATES A MISMATCH
25 BETWEEN HOW COST AND REVENUE ITEMS ARE PRESENTED IN THE
26 REVENUE REQUIREMENT CALCULATION. PLEASE EXPLAIN.
4 Order No. 35762 at 23 (April 28, 2023).
5 Direct Testimony of Timothy E. Tatum at 20:13—21:1.
6 Order No. 35762 at 23 (April 28, 2023).
Leyko, Di 7
Micron Technology, Inc.

1 A Although IPC claims its proposal to use a year-end rate base addresses the negative
2 impacts of regulatory lag, it also creates a new problem in turn because IPC proposes
3 mismatched methodologies to develop different revenue requirement items. In
4 particular, IPC "cherry picks" how it measures revenue requirement items, recording
5 some items using a year-end value when it increases the Company's revenue
6 deficiency(such as using year-end plant balances) but does not take a similar approach
7 on other items when it would reduce the revenue deficiency. This approach is
8 unbalanced, only serves to increase the Company's revenues at the expense of
9 customers, and should be rejected.
10 Q CAN YOU EXPLAIN WHY IPC'S PROPOSAL IS UNBALANCED AND WHY A YEAR-
11 END RATE BASE IS INAPPROPRIATE?
12 A Yes. The mismatch in IPC's proposal can be seen in how it treats accumulated
13 depreciation and customer growth.
14 IPC proposes to roll forward forecasted plant balances to the end of 2024 but
15 does not properly offset this increase with accumulated depreciation. As plant ages it
16 is depreciated and that depreciation expense is paid by customers in rates. The sum
17 of the depreciation paid on plant is called accumulated depreciation. Normally an
18 analysis should measure plant-in-service and accumulated depreciation at the same
19 point in time. However in this case, IPC only rolls forward accumulated depreciation
20 halfway through the year. It is not fair to customers to increase their rates to capture
21 year-end plant balances but not include offsets to this increase such as the buildup of
22 accumulated depreciation throughout the year that will be paid by customers in
23 depreciation expense in customer rates.
24 Similarly, while IPC offsets its rate increase using sales growth in 2024 it does
25 not annualize these additional revenues to reflect the year-end number of customers.
Leyko, Di 8
Micron Technology, Inc.

1 Just as plant is placed in service during the year so does the number of customers
2 increase during the year (and so does the revenues associated with those customers).
3 By not annualizing its revenue forecast for the year-end number of customers, IPC is
4 understating revenues relative to its rate base and overstating its revenue deficiency.
5 The plant placed in service at the end of the year will be used to serve the year-end
6 number of customers. It is unbalanced to reflect year-end plant balances but not year-
7 end customers.
8 Mr. Tatum argues a year-end rate base is reasonable because the Company
9 wants to include in rates all plant investments placed in service up to the time rates go
10 into effect.' This same logic applies to other aspects of IPC's cost of service. Under
11 Mr. Tatum's logic, rates should also reflect cost offsets and revenues up to the time
12 rates go into effect. But this is not the approach IPC took.
13 Furthermore,there are reasons to reject IPC's proposal fora year-end rate base
14 beyond the mismatch described above. IPC's use of a year-end rate base when
15 forecasting plant additions must be scrutinized because it is dependent on the accuracy
16 of IPC's forecast in order to develop cost of service. If IPC is overly optimistic in its
17 projections of plant-in-service toward the end of the year, it may be overstating
18 end-of-year rate base. IPC provided its actual electric plant-in-service through
19 July 2024 in response to a Staff data request.' Comparing the data response to IPC's
20 initial filing shows that IPC forecasted more plant additions than were actually placed
21 in service for the first 6 months of 2024.
7 Direct Testimony of Timothy E. Tatum at 20:18-22.
8 IPC Response to Staff Data Request No. 62, Confidential Attachment (provided as
Confidential Exhibit No. 601)
Leyko, Di 9
Micron Technology, Inc.

1 Finally, I will note that IPC's proposal for a limited issue rate case and quick
2 turnaround from the 2023 GRC both work to mitigate the Company's concerns about
3 regulatory lag.
4 Q WHAT DO YOU RECOMMEND TO CORRECT THE MISMATCH CAUSED BY IPC'S
5 RATE BASE PROPOSAL?
6 A I recommend the Commission follow the approach it took in the Veolia rate case and
7 calculate IPC's revenue requirement using an AMA rate base and require IPC to match
8 timing on the various aspects of its test year. This produces the most accurate and
9 reliable estimate of IPC's cost of service. Not only is my recommendation consistent
10 with the Commission's decision last year, it is also consistent with the settlement
11 approved in the 2023 GRC. This would also resolve the issue with IPC's plant balances
12 not aligning with other aspects of the Company's filing like the number of customers. 1
13 also recommend depreciation expense follow the plant balances.
14 Q PLEASE DESCRIBE YOUR ADJUSTMENT.
15 A My adjustment reduces IPC's revenue requirement downward by $28,511,230 as
16 shown in my summary in Exhibit No. 602. To derive this adjustment I utilized an
17 updated jurisdictional separation study ("JSS")that IPC provided in response to Micron
18 Data Request No. 9 (provided as Exhibit No. 603). The updated JSS shows plant
19 balances on a mid-year average basis, aligning the plant balances with IPC's approach
20 for accumulated depreciation. I used this as a proxy for the approximate impact of
21 using an AMA rate base because it is the Company's own calculation and it develops
22 IPC's average revenue requirement at the middle of the forecasted test year rather than
23 the end of the year.
Leyko, Di 10
Micron Technology, Inc.

1 Q IF THE COMMISSION DOES NOT ADOPT YOUR RECOMMENDATION AND
2 ALLOWS THE USE OF A YEAR-END RATE BASE, ARE THERE STEPS THE
3 COMMISSION CAN TAKE TO PROTECT CUSTOMERS?
4 A Yes. If the Commission decides to reject my recommendation and instead calculate
5 IPC's revenue requirement using a year-end rate base, then I recommend the
6 Commission at least offset the rate increase by using year-end accumulated
7 depreciation and the year-end number of customers (or annualize the test year
8 revenues for the year-end number of customers). I provide an estimated impact of
9 these adjustments as Exhibit No. 604. Page 1 shows the impact of stating accumulated
10 depreciation at year-end, which would reduce IPC's proposed revenue increase by
11 $2,908,225. Page 2 shows the impact of annualizing revenues for the year-end number
12 of customers based on my update to the revenue forecast IPC provided in discovery
13 which would increase revenues by $7,365,923 compared to IPC's estimate. The
14 exhibit shows the greatest impact is in January 2024 and that there is no impact in
15 December 2024 because the revenue forecast for that month is already stated at a
16 year-end number of customers. Combined, these adjustments reduce IPC's proposed
17 revenue increase by at least $10,274,148 when using a year-end rate base
18 methodology.
III. INCREMENTAL O&M LABOR
19 Q HOW DID IPC CALCULATE ITS INCREMENTAL LABOR EXPENSE IN THIS CASE?
20 A IPC compared its forecasted 2024 labor costs to the amount approved in the 2023 GRC
21 in order to calculate an incremental labor cost increase.' Labor costs include wages
22 and salaries, benefits, and short-term incentive for non-officers.10 IPC states the 2024
9 Direct Testimony of Matthew T. Larkin at 18:23— 19:1-2.
10 Id. at 17:24— 18:4.
Leyko, Di 11
Micron Technology, Inc.

1 labor forecast uses the same methodology the Company used in the 2023 GRC."
2 IPC's 2024 O&M labor forecast is based on the Company's actual labor expenses in
3 January and February 2024. Furthermore, IPC's labor expense is escalated for wage
4 increases in 2025.
5 Q DO YOU HAVE ANY CONCERNS WITH IPC'S FORECASTED LABOR EXPENSE?
6 A Yes. I have two concerns with IPC's forecasted labor expense. First, similar to my
7 concerns about the forecasted rate base discussed above and the revenue forecast
8 discussed below, IPC based its proposed rate increase on actual data for only January
9 and February 2024 while a review of IPC's actual labor expenses from January to June
10 2024 shows that IPC's initial calculation overstated the 2024 incremental increase in
11 labor expense. Second, IPC is proposing to include in its revenue requirement labor
12 costs from beyond the test year. IPC escalates its 2024 test year labor expense for
13 wage increases in 2025. To set reasonable rates it is important for the inputs to be as
14 accurate as possible and for the time periods being considered to match to the extent
15 possible.
16 Q HAS THE COMMISSION PREVIOUSLY ADDRESSED THE IMPORTANCE OF
17 MATCHING REVENUES AND EXPENSES FOR A SPECIFIED TIME PERIOD?
18 A Yes, in a prior Commission case related to IPC's Power Cost Adjustment Mechanism
19 ("PCA"), the Commission stated:
20 The ratemaking process is carefully designed and implemented to
21 match revenues and expenses for a specified time period, i.e., a test
22 year. This snapshot of a company's overall financial position allows the
23 matching of expenses and revenues. It is not appropriate to select and
24 adjust one part of that picture - for example, power supply costs
11 Id. at 18:7-9.
Leyko, Di 12
Micron Technology, Inc.

1 associated with load growth - in a process that does not include all other
2 parts that are impacted, such as revenues associated with growth.12
3 In that case, the Commission also determined that it wished to "maintain the integrity
4 of the rate case matching principle.1113 The Commission should continue to do so here.
5 Q TURNING TO YOUR FIRST CONCERN, HOW DOES IPC'S O&M LABOR
6 FORECAST CHANGE IF ACTUAL DATA FROM ADDITIONAL MONTHS ARE
7 USED?
8 A IPC provided its actual 2024 O&M labor expense in response to Staff Request No. 66,
9 Confidential Attachment. I updated IPC's incremental labor calculation on my
10 Confidential Exhibit No. 605, which uses the same methodology as the Company(other
11 than including 2025 labor costs). The impact of using actual 2024 payroll figures
12 through June instead of Idaho Power's forecast reduces labor expense by
13 $3,728,912.14
14 Q TURNING TO YOUR SECOND CONCERN, WHY IS IT INAPPROPRIATE FOR IPC
15 TO INCLUDE 2025 LABOR COSTS IN ITS 2024 TEST YEAR?
16 A IPC's proposal to include a 3% wage increase in 202515 is outside of the test year the
17 Company chose for its limited issue rate case. It is unreasonable, and a violation of
18 general ratemaking principles, for IPC to include cost increases from beyond the test
19 year but to ignore outside the test year offsets such as increased revenues from sales
20 growth in 2025. The proposed 2025 labor cost increase is, to my knowledge, the only
12 IPC-E-06-08, Order No. 30215 at 10 (January 9, 2007).
13 Id. at 11.
14 Confidential Exhibit No. 605, line 5 ($195,170,798— 191,441,886 = $3,728,912).
15 Direct Testimony of Matthew T. Larkin at 18:15-16.
Leyko, Di 13
Micron Technology, Inc.

1 component of IPC's proposed rate increase that reaches beyond the test year.
2 Therefore, I recommend the Commission disallow these costs.
3 Q WHAT IS THE TOTAL IMPACT OF YOUR O&M LABOR ADJUSTMENTS?
4 A Confidential Exhibit No. 605 includes both the actual 2024 O&M labor expenses
5 through June 2024 and my disallowance of the 2025 cost increases as adjustment to
6 IPC's O&M labor forecast. Reflecting both of these changes would lower IPC's
7 incremental labor costs by approximately $9.6 million.
IV. INCREMENTAL REVENUES
8 Q WHY IS IT IMPORTANT THAT IPC ACCURATELY FORECAST INCREASED SALES
9 SINCE THE 2023 GRC WHEN DEVELOPING ITS PROPOSED RATE INCREASE?
10 A In this case IPC states that a rate increase is required because of the revenue
11 deficiency caused by capital investments and increased labor expenses since its last
12 rate case. However, to determine an accurate and reasonable rate increase, the
13 Commission must also consider areas where IPC's revenues have increased since the
14 last GRC that offset increased costs. Indeed, as the Company experiences significant
15 load growth, it follows that the Company is serving more customers and selling more
16 electricity than it did in 2023, resulting in greater revenues that offset increased costs.
17 It is important that the Commission accurately track these incremental revenues to
18 ensure that it does not increase rates greater than necessary to meet IPC's revenue
19 deficiency.
Leyko, Di 14
Micron Technology, Inc.

1 Q PLEASE EXPLAIN HOW IPC CALCULATED ITS 2024 INCREMENTAL REVENUES.
2 A IPC's 2023 Idaho jurisdictional retail sales were 14,907,835,244 kWh.16 The Company
3 is forecasting 15,032,559,714 kWh of sales in 2024, for an incremental increase of
4 124,724,470 kWh. 17 To calculate the incremental revenues that result from
5 incremental kWh sales, IPC multiplies the incremental kWh sales increase by a"partial"
6 retail rate of$0.044055 per kWh that Idaho Power developed.'$ IPC explains that the
7 partial retail rate is derived from the amount"embedded in retail rates as a result of the
8 2023 GRC" only for the two issues in this limited rate case, capital-related items and
9 O&M labor. 11 The partial retail rate of $0.0440775 per kWh multiplied by the
10 incremental kWh equals a revenue offset of$5,497,548.20
11 Q IS IPC ACCURATELY MEASURING THE 2024 REVENUE INCREASES?
12 A No. I have two concerns with IPC's forecasted revenues. First, IPC uses an outdated
13 forecast. Looking at actual 2024 sales shows IPC understated the increase in revenues
14 due to sales growth. Second, the incremental revenues should not be developed using
15 a partial retail rate but rather the full retail rate that includes costs beyond the limited
16 issues IPC has presented in this proceeding. The incremental 2024 kWh sales will be
17 charged at rates to cover all of the Company's costs, not just the limited set of
18 investments and costs IPC has presented in this case. Just because IPC chose to
19 examine a limited set of issues in this rate case, there is no reason to calculate a partial
16 IPC response to Staff Request No. 3, Larkin Workpaper 7. Provided as Exhibit No. 606, at 3
line 39.
17 Id. at 3 line 45.
18 Id. at line 42.
19 Direct Testimony of Matthew T. Larkin at 20:20-24.
20 Id. at 21:1-5; Exhibit No. 606 at 3 line 48.
Leyko, Di 15
Micron Technology, Inc.

1 rate when customers are currently paying full rates based on the 2023 GRC which was
2 a comprehensive rate case.
3 Q WHAT IS THE IMPACT OF USING AN UPDATED FORECAST?
4 A IPC provided actual 2024 kWh sales through June 2024 in response to Staff Request
5 No. 36, Confidential Attachment 10 (provided as Confidential Exhibit No. 607). 1
6 compare IPC's initial forecast and its actual sales in my table below.
[BEGIN CONFIDENTIAL]
CONFIDENTIAL TABLE JAL-2
Updated Sales Forecast(kWh)
IPC Jan-Jun Updated
Line Description Forecast' Actuals2 Forecast
(1) (2) (3)
1 January
2 February
3 March
4 April
5 May
6 June
7 July
8 August
9 September
10 October
11 November
12 December
13 Total 15,032,559,714
14 Jan-Jun Percent Increase _
15 Change in Incremental Sales -
Sources
IPC response to Staff Request No 35, Confidential Attachment 10, kWh Forecast Summary tab_
IPC response to Staff Request No 36, Confidential Attachment, 2024 Normalized Energy tab
[END CONFIDENTIAL]
7 The table shows that IPC's actual sales were [BEGIN CONFIDENTIAL]
8
Leyko, Di 16
Micron Technology, Inc.

1
2
3
4 [END CONFIDENTIAL] Even using IPC's proposed $0.0440775 partial
5 rate would increase revenues by approximately $2.0 million compared to IPC's initial
6 projection after accounting for the updated forecast. At minimum, the Commission
7 should reflect this more accurate forecast of incremental sales and revenue when
8 determining IPC's revenue deficiency in this proceeding.
9 Q IF THE COMMISSION REJECTS IPC'S PROPOSED USE OF A PARTIAL RATE TO
10 CALCULATE INCREMENTAL REVENUES, WHAT ENERGY RATE DO YOU
11 RECOMMEND THE COMMISSION USE TO FORECAST THE INCREMENTAL
12 REVENUES IN 2024?
13 A I recommend a rate of approximately $0.0647 per kWh. IPC's response to Staff
14 Request No. 3, Larkin Workpaper 7 (provided as Exhibit No. 606) shows the
15 development of IPC's proposed $0.0440775 partial rate. The workpaper shows that
16 IPC excluded a significant amount of expenses such as all the O&M expenses IPC
17 decided to not address in this rate case. As an alternative, I updated IPC's jurisdictional
18 separation study from the 2023 GRC (Case No. IPC-E-23-11, Exhibit No. 35) to (1)
19 remove fuel and net power costs, (2) update the rate of return to match the Commission
20 authorized rate of return, and (3) add an additional line to reflect the revenue
21 requirement impact of all non-rate of return items in the 2023 GRC settlement that were
22 not reflected in the JSS that IPC filed in Case No. IPC-E-23-11. My adjustment was
23 designed to add back in the costs IPC decided to not address in this proceeding but
24 that are still reflected in the rates customers are currently paying. Following the same
Leyko, Di 17
Micron Technology, Inc.

1 process as Mr. Larkin, but using higher required revenues, results in a rate of
2 approximately $0.0647 per kWh.
3 Q WHAT IS THE IMPACT OF YOUR PROPOSED ADJUSTMENTS?
4 A Adjusting IPC's revenues to include an updated forecast and using a $0.0647 per kWh
5 rate would increase IPC's forecasted revenues by approximately $5.5 million which
6 offsets IPC's claimed revenue deficiency. My calculation is provided in Exhibit No. 608.
7 Q DOES THIS CONCLUDE YOUR DIRECT TESTIMONY?
8 A Yes, it does.
Leyko, Di 18
Micron Technology, Inc.

Qualifications of James Leyko
1 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A James A. Leyko. My business address is 16690 Swingley Ridge Road, Suite 140,
3 Chesterfield, MO 63017.
4 Q PLEASE STATE YOUR OCCUPATION.
5 A I am a Consultant in the field of public utility regulation with the firm of Brubaker &
6 Associates, Inc. ("BAI"), energy, economic and regulatory consultants.
7 Q PLEASE SUMMARIZE YOUR EDUCATIONAL BACKGROUND AND EXPERIENCE.
8 A I received a Bachelor of Arts Degree in History from Tulane University in 2007. I
9 attended Saint Louis University and received a Master of Business Administration
10 Degree in 2011. I joined BAI and served in the analyst department until 2012. Prior to
11 rejoining BAI as a Consultant in 2018, 1 worked as a Regulatory Economist for the
12 Maryland Public Service Commission and as the Regulatory Affairs Manager for the
13 Efficiency Maine Trust.
14 1 have written testimony and appeared as an expert witness before the Illinois
15 Commerce Commission, the Maine Public Utilities Commission, the Maryland Public
16 Service Commission, and the Oklahoma Corporation Commission, and have supported
17 filings for several regulated utility matters as a Consultant for BAI. These assignments
18 included revenue requirement issues such as incentive compensation and vegetation
19 management, income taxes, the impact of the Tax Cuts and Jobs Act of 2017, and
20 resource planning.
21 BAI was formed in April 1995. BAI and its predecessor firm have participated
22 in more than 700 regulatory proceedings in 40 states and Canada.
Appendix A
Leyko, Di 1
Micron Technology, Inc.

1 BAI provides consulting services in the economic, technical, accounting, and
2 financial aspects of public utility rates and in the acquisition of utility and energy
3 services through RFPs and negotiations, in both regulated and unregulated markets.
4 Our clients include large industrial and institutional customers, state regulatory
5 agencies, and some utilities. We also prepare special studies and reports, forecasts,
6 surveys and siting studies, and present seminars on utility-related issues.
7 In general, we are engaged in energy and regulatory consulting, economic
8 analysis and contract negotiation. In addition to our main office in St. Louis, the firm
9 also has branch offices in Corpus Christi, Texas; Louisville, Kentucky and Phoenix,
10 Arizona.
Appendix A
Leyko, Di 2
Micron Technology, Inc.

DECLARATION OF JAMES A. LEYKO
1 I, James A. Leyko, declare under penalty of perjury under the laws of the state of Idaho:
2 1. My name is James A. Leyko. I am employed by Brubaker &
3 Associates, Inc. ("BAI") as a consultant in the field of public utility regulation.
4 2. On behalf of Micron Technology, Inc., I present this pre-filed
5 Confidential Direct Testimony and Exhibit Nos. 601 through 608 in this matter.
6 3. To the best of my knowledge, my pre-filed Confidential Direct
7 Testimony and Exhibits are true and accurate.
8 I hereby declare that the above statement is true to the best of my knowledge
9 and belief, and that I understand it is made for use as evidence before the
10 Idaho Public Utilities Commission and is subject to penalty for perjury.
11 SIGNED this 611 day of November, 2024, at Chesterfield, Missouri.
Signed:
511630 ✓/
Declaration
Leyko, Di 1
Micron Technology, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. IPC-E-24-07
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ASSOCIATED )
WITH INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES. )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
REDACTED EXHIBIT NO. 601 TO ACCOMPANY THE
DIRECT TESTIMONY OF JAMES A. LEYKO
THIS EXHIBIT IS CONFIDENTIAL IN ITS ENTIRETY.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. IPC-E-24-07
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ASSOCIATED )
WITH INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES. )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
EXHIBIT NO. 602 TO ACCOMPANY THE
DIRECT TESTIMONY OF JAMES A. LEYKO

Idaho Power Company
End of Year Rate Base Adjustment
Line Description Amount
(1)
1 IPC Proposed Revenue Increase' $ 99,293,220
2 Revenue Increase per IPC response to Micron Request No. 92 $ 70,781,990
3 Difference $ (28,511,230)
Sources:
' Larkin Exhibit No. 10, Line 43.
2 IPC response to Micron Request No. 9, Attachment 1, Line 43 (Mid Year Plant
tab).
Exhibit No.602
Case No.IPC-E-24-07
Leyko,Micron Technology,Inc.
Page 1 of 1

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. IPC-E-24-07
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ASSOCIATED )
WITH INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES. )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
EXHIBIT NO. 603 TO ACCOMPANY THE
DIRECT TESTIMONY OF JAMES A. LEYKO

REQUEST NO. 9: Please explain why the Company is forecasting plant balances
at year-end but calculating accumulated depreciation using a mid-year convention.
Please provide workpapers calculating the Company's revenue requirement if plant
balances were also forecasted using a mid-year approach as the Company has proposed
for accumulated depreciation. Please also provide workpapers calculating the Company's
revenue requirement if accumulated depreciation is forecasted at year-end as the
Company has proposed for plant balances.
RESPONSE TO REQUEST NO. 9: The Company used the mid-year convention
for accumulated depreciation because it assumes that assets are acquired and placed
into service evenly throughout the year, rather than assuming all assets are placed in
service at the beginning of the test year.
The Excel workpaper labeled "Attachment 1 — Response to Micron's Request No.
9_2024 JSS Scenarios" contains two tabs labeled "2024 — Year-End Accum Depr," and
"2024 — Mid Year Plant" which contains the requested revenue requirement scenarios.
Attachments 2 and 3 are the accompanying workpapers calculating the incremental year-
end Accumulated Depreciation and the incremental 2024 mid-year plant values used in
the revenue requirement scenarios.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION
REQUESTS TO IDAHO POWER- 10
Exhibit No.603
Case No.IPC-E-24-07
Leyko, Micron Technology, Inc.
Page 1 of 3

Attachment 1-Response to Micron's Request No.9 IDAHO POWER COMPANY
JURISDICTIONAL SEPARATION STUDY
IDAHO REVENUE REQUIREMENT-INCREMENTAL 2024 RATEBASE AND LABOR
FOR THE TEST YEAR ENDING DECEMBER 31,2024
1
2 ALLOCI TOTAL IDAHO
3 DESCRIPTION SOURCE SYSTEM RETAIL OTHER
4 SUMMARY OF RESULTS
5 RATE OF RETURN UNDER PRESENT RATES
6 TOTAL COMBINED RATE BASE 732,182,435 700,977,897 31,204,538
7
8 OPERATING REVENUES
9 FIRM JURISDICTIONAL SALES 5,497,548 5,497,548 0
10 SYSTEM OPPORTUNITY SALES 0 0 0
11 OTHER OPERATING REVENUES 0 0 0
12 TOTAL OPERATING REVENUES 5,497,548 5,497,548 0
13 OPERATING EXPENSES
14 OPERATION&MAINTENANCE EXPENSES 19,557,535 18,759,267 798,267
15 DEPRECIATION EXPENSE 21,088,273 20,210,085 878,189
16 AMORTIZATION OF LIMITED TERM PLANT 2,265,315 2,169,836 95,479
17 TAXES OTHER THAN INCOME 0 0 0
18 REGULATORY DEBITS/CREDITS 0 0 0
19 PROVISION FOR DEFERRED INCOME TAXES 3,173,455 3,039,028 134,427
20 INVESTMENT TAX CREDIT ADJUSTMENT 73,978,000 70,844,300 3,133,700
21 FEDERAL INCOME TAXES (82,058,780) (78,544,547) (3,514,233)
22 STATE INCOME TAXES (10,668,322) (10,204,793) (463,530)
23 TOTAL OPERATING EXPENSES 27,335,476 26,273,176 1,062,300
24 OPERATING INCOME (21,837,928) (20,775,628) (1,062,300)
25 ADD: IERCO OPERATING INCOME 0 0 0
26 CONSOLIDATED OPERATING INCOME (21,837,928) (20,775,628) (1,062,300)
27 RATE OF RETURN UNDER PRESENT RATES -2.98% -2.96% -3.40%
28
29 DEVELOPMENT OF REVENUE REQUIREMENTS
30 RATE OF RETURN @ 9.6%ROE 7.247% 7.247% 7.247%
31
32 RETURN 53,061,261 50,799,868 2,261,393
33 EARNINGS DEFICIENCY 74,899,189 71,575,496 3,323,693
34 ADD:CWIP(HELLS CANYON RELICENSING) D10 0 0 0
35 EARNINGS DEFICIENCY WITH CWIP 74,899,189 71,575,496 3,323,693
36
37 NET-TO-GROSS TAX MULTIPLIER 1.347 1.347 1.347
38 REVENUE DEFICIENCY 100,860,745 96,384,995 4,475,751
39
40 ADD:VALMY REVENUE REQUIREMENT CIDA 0 0 0
41 ADD:BRIDGER REVENUE REQUIREMENT CIDA 0 0 0
42 LESS:BATTERYADITC MITIGATION CIDA 0 0 0
43 REVENUE DEFICIENCY LESS ADJUSTMENTS 100,860,745 96,384,995 4,475,751
44
45
46
47
48
Exhibit No.10
Case No.IPC-E-24-07
M.Larkin,[PC
2024-End of Year Accum Depr Page 1 of2
Exhibit No.603
Case No.IPC-E-24-07
Leyko, Micron Technology, Inc.
Page 2 of 3

IDAHO POWER COMPANY
JURISDICTIONAL SEPARATION STUDY
IDAHO REVENUE REQUIREMENT-INCREMENTAL 2024 RATEBASE AND LABOR
FOR THE TEST YEAR ENDING DECEMBER 31,2024
1
2 ALLOC/ TOTAL IDAHO
3 DESCRIPTION SOURCE SYSTEM RETAIL OTHER
4 SUMMARY OF RESULTS
5 RATE OF RETURN UNDER PRESENT RATES
6 TOTAL COMBINED RATE BASE 458,225,678 438,627,605 19,598,072
7
8 OPERATING REVENUES
9 FIRM JURISDICTIONAL SALES 5,497,548 5,497,548 0
10 SYSTEM OPPORTUNITY SALES 0 0 0
11 OTHER OPERATING REVENUES 0 0 0
12 TOTAL OPERATING REVENUES 5,497,548 5,497,548 0
13 OPERATING EXPENSES
14 OPERATION&MAINTENANCE EXPENSES 19,557,535 18,758,400 799,134
15 DEPRECIATION EXPENSE 21,088,273 20,209,776 878,497
16 AMORTIZATION OF LIMITED TERM PLANT 2,265,315 2,169,474 95,841
17 TAXES OTHER THAN INCOME 0 0 0
18 REGULATORY DEBITS/CREDITS 0 0 0
19 PROVISION FOR DEFERRED INCOME TAXES 3,173,455 3,038,441 135,014
20 INVESTMENT TAX CREDIT ADJUSTMENT 73,978,000 70,830,625 3,147,375
21 FEDERAL INCOME TAXES (82,058,780) (78,530,610) (3,528,170)
22 STATE INCOME TAXES (10,668,322) (10,203,195) (465,127)
23 TOTAL OPERATING EXPENSES 27,335,476 26,272,911 1,062,565
24 OPERATING INCOME (21,837,928) (20,775,363) (1,062,565)
25 ADD: IERCO OPERATING INCOME 0 0 0
26 CONSOLIDATED OPERATING INCOME (21,837,928) (20,775,363) (1,062,565)
27 RATE OF RETURN UNDER PRESENT RATES -4.77% -4.74% -5.42%
28
29 DEVELOPMENT OF REVENUE REQUIREMENTS
30 RATE OF RETURN @ 9.6%ROE 7.247% 7.247% 7.247%
31
32 RETURN 33,207,615 31,787,343 1,420,272
33 EARNINGS DEFICIENCY 55,045,542 52,562,705 Z48ZB37
34 ADD:CWIP(HELLS CANYON RELICENSING) D10 0 0 0
35 EARNINGS DEFICIENCY WITH CWIP 55,045,542 52,562,705 2,482,837
36
37 NET-TO-GROSS TAX MULTIPLIER 1.347 1.347 1.347
38 REVENUE DEFICIENCY 74,125,428 70,781,990 3,343,438
39
40 ADD:VALMY REVENUE REQUIREMENT CIDA 0 0 0
41 ADD:BRIDGER REVENUE REQUIREMENT CIDA 0 0 0
42 LESS:BATTERY ADITC MITIGATION CIDA 0 0 0
43 REVENUE DEFICIENCY LESS ADJUSTMENTS 74,125,428 70,781,990 3,343,438
44
45
46
47
48
Exbtbit No.10
Case No.0'C-E-24-07
M Lark.,IPC
2024-Mid Year Plant Page 2 of2
Exhibit No.603
Case No.IPC-E-24-07
Leyko, Micron Technology, Inc.
Page 3 of 3

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. IPC-E-24-07
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ASSOCIATED )
WITH INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES. )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
REDACTED EXHIBIT NO. 604 TO ACCOMPANY THE
DIRECT TESTIMONY OF JAMES A. LEYKO

Idaho Power Company
Year End Adjustments
(Year End Accumulated Depreciation Adjustment)
Line Description Amount
(1)
1 IPC Proposed Revenue Increase' $ 99,293,220
2 Revenue Increase per IPC response to Micron Request No. 92 $ 96,384,995
3 Difference $ (2,908,225)
Sources:
' Larkin Exhibit No. 10, Line 43.
2 IPC response to Micron Request No. 9, Attachment 1, Line 43 (End of Year
Accum. Depr. tab).
Exhibit No. 604
Case No. IPC-E-24-07
Leyko, Micron Technology, Inc.
Page 1 of 2

Idaho Power Company
Year End Adjustments
(Year End Customers Adjustment)
IPC Adjusted
Revenues Revenues
Line Description Forecast' Forecast2 Difference
(2) (3)
1 January
2 February
3 March
4 April
5 May
6 June
7 July
8 August
9 September
10 October
11 November
12 December
13 Total $ 7,365,923
Sources:
1 IPC response to Staff Request No. 35, Confidential Attachment 10.
2 Revised version of Confidential Attachment 10 from IPC response to Staff
Request No. 35.
Exhibit No. 604
Case No. IPC-E-24-07
Leyko, Micron Technology, Inc.
Page 2 of 2

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. IPC-E-24-07
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE RATES FOR ELECTRIC SERVICE )
TO RECOVER COSTS ASSOCIATED WITH )
INCREMENTAL CAPITAL INVESTMENTS AND )
CERTAIN ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES. )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
REDACTED EXHIBIT NO. 605 TO ACCOMPANY THE
DIRECT TESTIMONY OF JAMES A. LEYKO

Idaho Power Company
O&M Labor Adjustment
IPC
Line Description Forecast' Revised
(1) (2)
1 Year to Date Payroll
2 Percent of Three Year Average
3 Forecasted 2024 Payroll $ 198,678,494 $ 194,949,582
4 Less 2022 Mid Year 2% GWA (3,507,696) (3,507,696)
5 2024 Labor Forecast $ 195,170,798 $ 191,441,886
6 Annualizing Adjustment $ 1,561,952 $ 1,561,952
7 2025 3% GWA 5,901,982 -
8 Incentive Compensation 10,845,454 10,845,454
9 Total O&M Labor Forecast $ 213,480,186 $ 203,849,291
10 Difference $ (9,630,895)
Sources:
1 IPC response to Staff Request No. 3, Larkin Workpaper 5.
2 IPC response to Staff Request No. 66, Confidential Attachment.
Exhibit No. 605
Case No. IPC-E-24-07
Leyko, Micron Technology, Inc.
Page 1 of 1

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. IPC-E-24-07
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ASSOCIATED )
WITH INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES. )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
EXHIBIT NO. 606 TO ACCOMPANY THE
DIRECT TESTIMONY OF JAMES A. LEYKO

REQUEST FOR PRODUCTION NO. 3: Please provide all workpapers and exhibits
in Excel format with formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Please see the attached
Excel files labeled:
• "Attachment 1 - Response to Staff Request No. 3 — Larkin Workpaper 1
• "Attachment 2 - Response to Staff Request No. 3 — Larkin Workpaper 2",
• "Attachment 3 - Response to Staff Request No. 3 — Larkin Workpaper 3",
• "Attachment 4 - Response to Staff Request No. 3 — Larkin Workpaper 4",
• "Attachment 5 - Response to Staff Request No. 3 — Larkin Workpaper 5",
• "Attachment 6 - Response to Staff Request No. 3 — Larkin Workpaper 6",
• "Attachment 7 - Response to Staff Request No. 3 — Larkin Workpaper 7",
• "Attachment 8 - Response to Staff Request No. 3 — Larkin Workpaper 8",
• "Attachment 9 Response to Staff Request No. 3 — Application Attachment
3"
• "Attachment 10 - Response to Staff Request No. 3 — Tatum Exhibit No. 4",
• "Attachment 11 - Response to Staff Request No. 3 — Larkin Exhibit No. 6",
• "Attachment 12 - Response to Staff Request No. 3 — Larkin Exhibit No. 7",
• "Attachment 13 - Response to Staff Request No. 3 — Larkin Exhibit No. 8",
• "Attachment 14 - Response to Staff Request No. 3 — Larkin Exhibit No. 9",
• "Attachment 15 - Response to Staff Request No. 3 — Larkin Exhibit No. 10".
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER-4
Exhibit No.606
Case No.IPC-E-24-07
Leyko, Micron Technology,Inc.
Page 1 of 3

IDAHO POWER COMPANY
INCREMENTAL REVENUE ASSOCIATED WITH LOAD GROWTH
2023 ID kWh Sales
14,907,835,244
Mill Rate (Rate Base and Labor Only Rev Reg/Sales)
0.0440775
Incremental 2024 ID kWh Sales
124,724,470
Incremental 2024 Revenues
$ 5,497,548
Exhibit No.606
Case No.IPC-E-24-07
Leyko, Micron Technology,Inc.
Page 2 of 3

IDAHO POWER COMPANY
JURISDICTIONAL SEPARATION STUDY
IDAHO REVENUE REQUIREMENT-SETTLED 2023 GRC RATE BASE AND LABOR ONLY
FOR THE TEST YEAR ENDING DECEMBER 31,2023
1
2 ALLOC/ TOTAL IDAHO
3 DESCRIPTION SOURCE SYSTEM RETAIL OTHER
4 SUMMARY OF RESULTS
5 RATE OF RETURN UNDER PRESENT RATES
6 TOTAL COMBINED RATE BASE 3,814,724,493 3,648,879,611 165,844,882
7
8 OPERATING REVENUES
9 FIRM JURISDICTIONAL SALES 0 0 0
10 SYSTEM OPPORTUNITY SALES 0 0 0
11 OTHER OPERATING REVENUES 0 0 0
12 TOTAL OPERATING REVENUES 0 0 0
13 OPERATING EXPENSES
14 OPERATION&MAINTENANCE EXPENSES 229,857,514 221,465,558 8,391,956
15 DEPRECIATION EXPENSE 157,725,966 150,906,642 6,819,324
16 AMORTIZATION OF LIMITED TERM PLANT 5,981,316 5,724,796 256,520
17 TAXES OTHER THAN INCOME 0 0 0
18 REGULATORY DEBITS/CREDITS 0 0 0
19 PROVISION FOR DEFERRED INCOME TAXES (17,873,223) (17,099,076) (774,147)
20 INVESTMENT TAX CREDIT ADJUSTMENT 25,014,178 23,923,064 1,091,114
21 FEDERAL INCOME TAXES (104,708,343) (100,471,089) (4,237,254)
22 STATE INCOME TAXES (47,188,876) (45,230,974) (1,957,902)
23 TOTAL OPERATING EXPENSES 248,808,533 239,218,920 9,589,612
24 OPERATING INCOME (248,808,533) (239,218,920) (9,589,612)
25 ADD: IERCO OPERATING INCOME 0 0 0
26 CONSOLIDATED OPERATING INCOME (248,808,533) (239,218,920) (9,589,612)
27 RATE OF RETURN UNDER PRESENT RATES -6.52% -6.56% -5.78%
28
29 DEVELOPMENT OF REVENUE REQUIREMENTS
30 RATE OF RETURN 7.247% 7.247% 7.247%
31
32 RETURN 276,469,471 264,449,980 12,019,491
33 EARNINGS DEFICIENCY 525,278,003 503,668,900 21,609,103
34 ADD:CWIP (HELLS CANYON RELICENSING) D10 0 0 0
35 EARNINGS DEFICIENCY WITH CWIP 525,278,003 503,668,900 21,609,103
36
37 NET-TO-GROSS TAX MULTIPLIER 1.347 1.347 1.347
38 REVENUE DEFICIENCY 707,349,865 678,250,614 29,099,250 2023 ID kWh Sales
39 14,907,835,244
40 ADD:VALMY REVENUE REQUIREMENT CIDA 36,957,501 0 0
41 ADD:BRIDGER REVENUE REQUIREMENT CIDA 67,579,174 0 0 Mill Rate(Rev Rea/Sales)
42 LESS:BATTERY ADITC MITIGATION CIDA 21,149,854 21,149,854 0 0.0440775
43 REVENUE DEFICIENCY WITH VALMY AND BRIDGER 790,736,685 657,100,760 29,099,250
44 Incremental 2024 ID kWh Sales
45 FIRM JURISDICTIONAL RETAIL REVENUES 0 0 0 124,724,470
46 PERCENT INCREASE REQUIRED
47 Incremental 2024 Revenues for RB/Labor
48 SALES AND WHEELING REVENUES REQUIRED 686,200,010 657,100,760 29,099,250 $ 5,497,548
Exhibit No.606
Case No.IPC-E-24-07
Leyko,Micron Technology,Inc.
2 of 2 Settled RB&Labor Page 3 of 3

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. IPC-E-24-07
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ASSOCIATED )
WITH INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES. )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
REDACTED EXHIBIT NO. 607 TO ACCOMPANY THE
DIRECT TESTIMONY OF JAMES A. LEYKO
THIS EXHIBIT IS CONFIDENTIAL IN ITS ENTIRETY.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. IPC-E-24-07
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ASSOCIATED )
WITH INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES. )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
EXHIBIT NO. 608 TO ACCOMPANY THE
DIRECT TESTIMONY OF JAMES A. LEYKO

Idaho Power Company
Revised Revenue Forecast
Line Description Amount Source
(1) (2)
IPC Proposed
1 2023 ID Sales (kWh) 14,907,835,244 Staff Request No. 3, Larkin Workpaper 7
2 Capital-Related & O&M Labor in Rates $ 657,100,760 Staff Request No. 3, Larkin Workpaper 7
3 Mill Rate $ 0.0441 Line 2/Line 1
4 2024 Forecast of ID Sales (kWh) 15,032,559,714 Leyko Direct, Table JAL-2
5 Incremental 2024 ID Sales (kWh) 124,724,470 Line 4 - Line 1
6 Incremental 2024 Revenues $ 5,497,548 Line 3 * Line 5
Revised Forecast
7 2023 ID Sales (kWh) 14,907,835,244 Staff Request No. 3, Larkin Workpaper 7
8 Adjusted Jurisdictional Retail Revenues $ 963,799,543 Case No. IPC-E-23-11, Exhibit No. 35
9 Mill Rate $ 0.0647 Line 8/Line 7
10 Updated 2024 Forecast of ID Sales (kWh) 15,077,473,357 Leyko Direct, Table JAL-2
11 Revised Incremental 2024 ID Sales (kWh) 169,638,113 Line 10 - Line 1
12 Revised Incremental 2024 Revenues $ 10,967,195 Line 9 * Line 11
13 Difference $ 5,469,647 Line 13 - Line 6
Exhibit No.608
Case No.IPC-E-24-07
Leyko,Micron Technology,Inc.
Page 1 of 1

CERTIFICATE OF SERVICE
I hereby certify that on November 6, 2024, a true and correct copy of the within and
foregoing NON-CONFIDENTIAL DIRECT TESTIMONY AND EXHIBITS OF JAMES
A. LEYKO ON BEHALF OF MICRON TECHNOLOGY, INC. IN CASE NO. IPC-E-24-07
was served in the manner shown to:
Electronic Mail
Idaho Power Company
Lisa D. Nordstrom Timothy E. Tatum
Donovan E. Walker Connie Aschenbrenner
Megan Goicoecha Allen Matt Larkin
Idaho Power Company Idaho Power Company
1221 W. Idaho Street(83702) 1221 West Idaho Street(83702)
PO Box 70 P.O. Box 70
Boise, ID 83707-0070 Boise, Idaho 83707
lnordstromkidahopower.com Telephone: [phone]
dwalker(ib,idahopower.com Facsimile: [phone]
maoicoecheaallengidahopower.com ttatum&idahopower.com
dockets(& idahopower.com caschenbrenner(&,idahopower.com
mlarkinkidahopower.com
Commission Staff Federal Executive Agencies
Monica Barrios-Sanchez Peter Meier
Commission Secretary Emily W. Medlyn
Idaho Public Utilities Commission U.S. Department of Energy
11331 W. Chinden Blvd., Building 8, 1000 Independence Ave., S.W.
Suite 201-A Washington, D.C. 20585
Boise, ID 83714 peter.meierkhq.doe. og_v
secretary(a�puc.idaho.gov emilyn(&,hq.doe.gov
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen Lance Kaufman, Ph.D.
Echo Hawk& Olsen, PLLC 2623 NW Bluebell Place
505 Pershing Ave., Suite 100 Corvallis, OR 97330
P.O. Box 6119 lanceAae isinsi hg t.com
Pocatello, ID 83205
eloAechohawk.com

Industrial Customers of Idaho Power
Peter J. Richardson Dr. Don Reading
Richardson Adams, PLLC 280 S. Silverwood Way
515 N. 27th Street Eagle, ID 83616
P.O. Box 7218 dreadinagmindsprina.com
Boise, ID 83702
peter@.richardsonadams.com
Idaho Conservation League City of Boise City
Brad Heusinkveld Ed Jewell
Idaho Conservation League Steven Hubble
Regulatory Counsel Boise City Attorney's Office
710 N. 6th Street 150 N. Capitol Blvd.
Boise, ID 83702 P.O. Box 500
bheusinkveldgidahoconservation.org Boise, ID 83701-0500
BoiseCityAttomey(a,cityofboise.org
ejewell(a,cityofboise.org
shubble(acityofboise.org
Micron Technology, Inc.
Jim Swier Austin Rueschhoff
Micron Technology, Inc. Thorvald A. Nelson
8000 South Federal Way Austin W. Jensen
Boise, ID 83707 Kristine A.K. Roach
jswierkmicron.com John W. Sherry
Holland&Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
darueschhoff(ahollandhart.com
tnelson(ahollandhart.com
awj ensen(a,hollandhart.c om
karoach(ahollandhart.com
aclee(ahollandhart.com
mamcmillen(aho llandhart.com
s/Adele Lee
324015040
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