20241106Direct Steve Hubble.pdf

RECEIVED
Wednesday, November 6, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY TO INCREASE Case No. IPC-E-24-07
RATES FOR ELECTRIC SERVICE TO
RECOVER COSTS ASSOCIATED WITH
INCREMENTAL CAPITAL INVESTMENTS
AND CERTAIN ONGOING OPERATIONS AND
MAINTENANCE EXPENSES
CITY OF BOISE CITY
DIRECT TESTIMONY
OF
STEVE HUBBLE

I Q. Please state your name,business address, and present position with the City of Boise.
2 A. Steven Hubble, City of Boise—Department of Public Works, 150 N. Capitol Blvd, Boise, ID
3 83702. Climate Action, Senior Manager.
4 Q. Please describe your educational background.
5 A. I graduated from Radford University with a Bachelors of Science in Geography. I earned a
6 Masters in Public Administration from Virginia Commonwealth University.
7 Q. Please describe your professional background.
8 A. For the last nine years, I have worked for the City of Boise Department of Public Works and
9 since 2020 I have managed the City's climate programs including the City's Climate,Sustainability,Energy,
10 Geothermal,Water Resources,Materials Management and Environmental Education staff and programs. I
11 led the development of Boise's Energy Future and Boise's Climate Action Roadmap. Since 2018, I have
12 led or supported the City's energy regulatory and policy initiatives. In this role I have overseen City
13 participation in proceedings with this Commission and have participated as a member of the Idaho Power
14 Energy Efficiency Advisory Group and the Integrated Resource Plan Advisory Committee.
15 Over my career,I have twenty-two years of experience working in local government Public Works
16 and Planning positions.Prior to starting my position with the City of Boise in 2015,I worked for the County
17 of Stafford,Virginia, for thirteen years.
18 Q. What is the purpose of your testimony?
19 A. The purpose of my testimony is to provide the Commission with the City of Boise's perspective
20 on Idaho Power's rate case. As the largest municipality in Idaho Power's service territory, and the state of
21 Idaho,the City of Boise brings a multifaceted perspective to the discussion.As a city,we have constituents
22 in every rate class, we operate our own utility systems for wastewater renewal and geothermal, and are
23 Idaho Power customers with accounts in Schedules 7, 9, and 19. The City of Boise, like much of Idaho
24 Power's service territory,is experiencing rapid and sustained economic and population growth. Continued
25 development, and the jobs, opportunities, and vitality it brings, requires strategic planning, sound
26 infrastructure investments,prudent management, and equitable allocation of costs.As a city,we also have
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1 clean energy and carbon neutrality goals that will require coordination and collaboration with utilities and
2 regulators to achieve.My testimony will emphasize how the City's clean energy and carbon neutrality goals
3 are complementary to Idaho Power and the Commission's goals of developing a least-cost, least-risk
4 portfolio that provides dependable and affordable electricity to all customers in Idaho Power's service
5 territory.
6 Q. Please summarize your recommendations.
7 A. The City supports Idaho Power's investments in battery technology, the transmission costs
8 necessary to realize these investments, and the associated rate recovery for these investments. The City
9 believes these investments reduce customer exposure to fuel price fluctuations, create a more capable and
10 dynamic grid, and open more opportunities for the integration of renewable resources on the Company's
11 system,which will provide a number of long-term customer benefits. The City believes these investments
12 were prudently incurred. However,the City also believes the RFP process leading to the specific resource
13 selections could and should be improved in the future.See Order No. 35900.
14 The City does not make specific recommendations on methodology for test year or rate base
15 calculations such as end-of-period or 13 month average.Further,the City does not take a position on when
16 the appropriate cutoff date for determining used and useful is in this case. The City makes a general
17 observation that the Company's concern about regulatory lag and the Commission Staff's need to audit and
18 review the Company's expenditures before including them in rate base are both legitimate concerns that
19 need to be fairly reconciled.
20 Q. Is the City concerned about affordability for customers?
21 A. Yes.Affordability is a primary concern for the City, both for the City's own electric accounts
22 and for its citizens. The City understands the difficulty posed by near term cost increases on customers.
23 While sensitive to the customer impact, the City believes smart investments in clean and adaptable
24 resources that create a better and more efficient grid will ultimately provide more value to Idaho Power
25 customers commensurate with the increased cost. The City understands that capital investments are
26 necessary for the Company's system to keep pace with load growth, deal with the reality of aging assets,
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1 create modern infrastructure, and respond to inflationary pressures in the economy, and that these
2 investments will be passed on to customers.
3 The City has electrification goals to help it achieve its clean energy and climate goals. As electricity
4 prices rise,these electrification goals will be more difficult to attain, as will City affordability goals.
5 The City will continue to explore and advocate for feasible measures customers can take to control
6 their own energy costs such as energy efficiency programs and funding,time of use rates, electric vehicle
7 integration, customer generation, and other programs or incentives.
8 Q. Does the City have a position on proposed rate spread between classes?
9 A. Yes. The City supports Idaho Power's proposed rate spread, as presented on page 6 of the
10 Company's application. The City's constituents include customers on every rate schedule served by Idaho
11 Power. Other intervenors in this proceeding represent commercial,industrial,irrigator,and special contract
12 customers, leaving residential, small commercial, and customer generator classes without a direct voice in
13 the discussions.As of the 2022 Census,there were approximately 97,826 residential households in the City
14 of Boise, which represent approximately 15% of Idaho Power's approximately 640,000 residential
15 accounts. In the interest of a fair and robust discussion taking all customer classes into account, the City
16 generally directs its participation and comments toward ensuring residential, small commercial, and
17 customer generators do not bear a disproportionate burden of costs.The City participated in Idaho Power's
18 2023 general rate case, IPC-E-23-11, and joined the settlement in that case and believes the rate spread
19 agreed upon there appropriately moves the rate spread toward class cost of service in an incremental and
20 thoughtful manner.The City believes the Company's proposal in this case continues to effectuate the intent
21 of the IPC-E-23-11 settlement.
22 Q. Does the City have a position on changes to rate design?
23 A. The City does not believe any changes to rate design are warranted in this proceeding. More
24 time is needed to implement and understand the changes to rate design from the 2023 general rate case and
25 the record is not adequately developed to justify changes to rate design in this proceeding.
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1 Q. Has the City identified any issues in this proceeding that it would like to bring to the
2 Commission's attention?
3 A. Yes. Idaho Power recently sought and received a judicial determination regarding the amount
4 of property taxes the Company must pay in Idaho.In Idaho Power Company v Idaho State Tax Commission,
5 172 Idaho 125 (2023),the Idaho Supreme Court determined the Idaho State Tax Commission was required
6 to lower the amount of property taxes owed by Idaho Power to fulfill the requirements of the Railroad
7 Revitalization and Reform Act and provisions of the Idaho Constitution.As a result, the Idaho State Tax
8 Commission sitting as the State Board of Equalization reduced the recommended value of Idaho Power's
9 taxable property from$2,313,365,106 to$1,976,539,147, for a 14.56%reduction in 2023. In the Matter of
10 the 2023 Operating Property Ad Valorem Valuation of Idaho Power,Petitioner Docket No. 0-781-853-696,
11 August 25, 2023. The City would like to ensure that this reduction in Idaho Power's expenses is
12 appropriately included in rate base calculations and that any benefit due to customers from this reduction
13 is recognized.
14 Q. How are the City's climate and clean energy goals relevant to the Company's application?
15 A. The City's climate and clean energy goals align with a more diverse resource portfolio that
16 reduces risk related to over-dependence on any one resource type and helps to minimize cost fluctuations.
17 For example, a hydro-dominant system is susceptible to drought. And, renewable resources such as solar
18 and wind do not have fuel costs.Compared to natural gas resources that have fuel costs that are volatile and
19 dependent on international markets, renewable resources have far less price risk. As wildfire, drought,
20 severe storms, heat waves, and cold snaps become more frequent and intense due to fossil fuel induced
21 climate change, a diversified and integrated resource portfolio will become more necessary to respond to
22 the greater variability of likely future conditions. The City believes the Company's investments for which
23 they are seeking cost recovery in this proceeding will create a more resilient grid with the opportunity to
24 integrate more non-fueled resources,indicating prudent resource decisions.
25 Q. Does the City have anything else to add?
26 A. No.
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CERTIFICATE OF SERVICE
I hereby certify that I have on this 6th day of November 2024, served the foregoing documents
on all parties of record as follows:
Monica Barrios-Sanchez ❑ U.S. Mail
Commission Secretary ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 W. Chinden Blvd., Ste. 201-A 0 Electronic
Boise, ID 83714 ❑ Other:
secretgakpuc.idaho._og_v
Chris Burdin ❑ U.S. Mail
Deputy Attorney General ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 W. Chinden Blvd., Ste. 201-A 0 Electronic
Boise, ID 83714 ❑ Other:
chris.burdingpuc.idaho.gov
Lisa Nordstrom ❑ U.S. Mail
Donovan Walker ❑ Personal Delivery
Megan Goicoechea Allen ❑ Facsimile
Idaho Power Company Q Electronic
PO Box 70 ❑ Other:
Boise, ID 83707
Inordstromkidahopower
dwalker(d),idahopower.com
m goicoecheaallen&idahopower.com
docketsgidahopower.com
Timothy Tatum ❑ U.S. Mail
Connie Aschenbrenner ❑ Personal Delivery
Matt Larkin ❑ Facsimile
Idaho Power Company Q Electronic
PO Box 70 ❑ Other:
Boise, ID 83707
ttatum(k idahopower.com
caschenbrennergidahopower.com
mlarkin&idahopower.com
Eric Olsen ❑ U.S. Mail
Echo Hawk& Olsen PLLC ❑ Personal Delivery
PO Box 6119 ❑ Facsimile
Pocatello, ID 83205 0 Electronic
elo(a,echohawk.com ❑ Other:
CERTIFICATE OF SERVICE

Peter J. Richardson ❑ U.S. Mail
Richardson Adams, PLLC ❑ Personal Delivery
515 N 27th Street ❑ Facsimile
Boise, ID 83702 Q Electronic
peter&richardsonadams.com ❑ Other:
Dr. Don Reading ❑ U.S. Mail
280 S Silverwood Way ❑ Personal Delivery
Eagle, ID 83616 ❑ Facsimile
dreadin mindsprin_.cgom Q Electronic
❑ Other:
Lance Kaufman PhD ❑ U.S. Mail
2623 NW Bluebell Place ❑ Personal Delivery
Corvallis, OR 97330 ❑ Facsimile
lance(d),ae isg insi hg t.com Q Electronic
❑ Other:
Brad Heusinkveld ❑ U.S. Mail
Idaho Conservation League ❑ Personal Delivery
710 N 6th Street ❑ Facsimile
Boise, ID 83702 Q Electronic
bheusinkveld(d),idahoconservation.org ❑ Other:
Austin Rueschhoff ❑ U.S. Mail
Thorvald A. Nelson ❑ Personal Delivery
Austin W. Jensen ❑ Facsimile
Kristine A.K. Roach Q Electronic
Holland&Hart LLP ❑ Other:
555 171h Street, Suite 3200
Denver, CO 80202
darueschhoff(a�hollandhart.com
tnels on&hollandhart.com
aw'enl sen(chollandhart.com
karoach(khollandhart.com
aclee(a,hollandhart.com
mamcmillenkhollandhart.com
Jim Swier ❑ U.S. Mail
Micron Technology, Inc. ❑ Personal Delivery
8000 S Federal Way ❑ Facsimile
Boise, ID 83707 Q Electronic
jswier(kmicron.com ❑ Other:
CERTIFICATE OF SERVICE

Peter Meier ❑ U.S. Mail
Emily W. Medlyn ❑ Personal Delivery
U.S. Department of Energy ❑ Facsimile
1000 Independence Ave, SW Q Electronic
Washington, DC 20585 ❑ Other:
Peter.meier(chq.doe.gov
Emily.medlynghq.doe.gov
A�g k--d'
Michelle Steel,
Paralegal
CERTIFICATE OF SERVICE