20241106Direct Larry Blank.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 RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ) CASE NO. IPC-E-24-07
ASSOCIATED WITH INCREMENTAL )
CAPITAL INVESTMENTS AND CERTAIN )
ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES )
THE FEDERAL EXECUTIVE AGENCIES
DIRECT TESTIMONY
OF
LARRY BLANK
NOVEMBER 6, 2024
1

TABLE OF CONTENTS
Page
I. IDENTIFICATION................................................................................................................ 3
II. PURPOSE AND SUMMARY............................................................................................... 5
III. THE 2023 GRC CLASS COST OF SERVICE STUDY....................................................... 7
IV. RECOMMENDED CLASS REVENUE SPREAD............................................................. 18
EXHIBIT 501 (LB-1)—RESUME OF LARRY BLANK
2

1 I. IDENTIFICATION
2 Q. DR. BLANK, PLEASE STATE YOUR NAME AND BUSINESS ADDRESS
3 FOR THE RECORD.
4 A. My name is Larry Blank. My business address is TAHOEconomics, LLC, 6061
5 Montgomery Road, Midlothian, TX 76065. My email address is
6 LB&tahoeconomics.com.
7 Q. WHERE ARE YOU EMPLOYED?
8 A. I am the principal of TAHOEconomics, LLC ("Tahoe"), a Texas-registered consulting
9 firm I founded in August 1999 (originally in Nevada), specializing in most policy and
10 ratemaking facets of regulated utility industries. I am also a Professor of Economics in
11 the College of Business at New Mexico State University("NMSU"). For the purposes
12 of this proceeding, I have been engaged through Tahoe, the expert opinions expressed
13 herein are my own, and nothing in this testimony necessarily reflects the opinions of
14 NMSU.
15 Q. PLEASE PROVIDE A BRIEF SUMMARY OF YOUR BACKGROUND AS IT
16 IS RELEVANT TO THIS TESTIMONY.
17 A. I have served the public in various capacities for 40 years. In 1994, 1 received a Ph.D.
18 in Economics from The University of Tennessee, specializing in Industrial
19 Organization & Public Policy (including regulatory policy), Econometrics, and
20 Finance. I previously served as an Economist with the National Regulatory Research
21 Institute("NRRI") at the Ohio State University and later as the Manager of Regulatory
22 Policy & Market Analysis with the Regulatory Operations Staff of the Nevada Public
23 Utilities Commission. As a consultant, I have served a variety of clients including
24 government agencies, utility customers, and utility companies as an expert witness
25 and/or advisor in over 150 rate cases and rulemakings of various types. My written
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I testimony has been filed in the following utility regulatory commission jurisdictions:
2 Alaska, Arizona, Arkansas, Colorado, Delaware, Georgia, Kansas, Kentucky,
3 Montana, Nevada, New Hampshire, New Mexico, New York, North Carolina,
4 Oklahoma, South Carolina, Texas, and the Federal Energy Regulatory Commission. I
5 have not previously testified before the Idaho Public Utilities Commission
6 ("Commission" or "IPUC"). At NMSU, I direct a professional Graduate Certificate
7 Program in Public Utility Regulation& Economics, a Masters of Economics program,
8 and help deliver nationally-recognized rate case training programs,which are attended
9 each year by hundreds of regulatory professionals from across the United States and
10 are endorsed by the National Association of Regulatory Utility Commissioners
11 ("NARUC"). My resume is attached as Exhibit No. 501 (LB_1).
12 Q. ON WHOSE BEHALF ARE YOU TESTIFYING?
13 A. I am testifying on behalf of the Federal Executive Agencies ("FEA"). Idaho Power
14 Company ("IPC" or "Company") provides electric service to the U.S. Department of
15 Energy ("DOE") for DOE's Idaho National Laboratory ("INL"), a large industrial
16 customer served at transmission voltage under IPC's Schedule 30 and one of IPC's
17 "special contract" customers. Special contract customers have aggregate power
18 requirements exceeding 20 megawatts ("MW"). IPC also provides electric service to
19 the U.S. Department of Defense ("DoD") for DoD's Mountain Home Air Force Base,
20 another of IPC's large industrial customers, under IPC's Schedule 19, Large Power
21 Service, and at rates for primary voltage service.
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1 II. PURPOSE AND SUMMARY
2 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
3 A. I address class cost-of-service ("CCOS") study issues and proposed allocation of base
4 rate revenue("revenue spread") found in the Application of the Company for authority
5 to adjust its retail electric rate schedules.
6 Q. PLEASE SUMMARIZE YOUR REVIEW OF THE IPC APPLICATION.
7 A. IPC describes this case as a limited revenue requirement case in which the CCOS study
8 from the last general rate case("GRC")in 2023 ("2023 GRC")is used by the Company
9 as guidance for a cap and floor revenue spread. IPC proposes an overall average
10 increase of 7.31%with a rate class cap of 130%of the average(i.e., 9.50%) and a floor
11 of 50% (i.e., 3.65%).1 This approach follows parameters used in the Stipulation filed
12 in the 2023 GRC, which are not binding on the parties in this case.
13 The underlying methods used in the 2023 GRC CCOS study are out of step with
14 methods that are more in line with cost causation principles and more widely used in
15 other jurisdictions. An average and excess demand("AED")method is better suited to
16 capture the customer and system load characteristics causing the generation capacity
17 costs for IPC. When we incorporate the AED method commonly used in other
18 jurisdictions into the 2023 GRC CCOS model, we see that the cost-of-service targets
19 for the rate classes are actually farther from current revenues than the differences found
20 using the IPC CCOS study. This evidence suggests that the IPC CCOS study may not
21 give the Commission complete information as to the full range of rate class cost of
22 service for consideration prior to adoption of a cap and floor methodology. This
23 evidence was missing from the record in the 2023 GRC. Furthermore, the cap and
24 floor parameters used in the 2023 Stipulation are narrower than those adopted in past
'IPC Tatum Direct at p. 29.
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I cases. For these reasons, I recommend that the Commission alter the revenue spread to
2 incorporate a 190% — 0% cap and floor band. Because the parties in this present case
3 are not bound to the parameters used in the Stipulation of the last case and IPC proposes
4 a limited revenue requirement increase in this case, the Commission should move
5 toward cost of service.
6 Q. PLEASE SUMMARIZE YOUR RECOMMENDATIONS FOR THE
7 COMMISSION.
8 A. Based on my review of the cost of service methods, I recommend that the Commission
9 alter the revenue spread to incorporate a 190% — 0% cap and floor band. Because the
10 cost-based rate increases derived by the IPC CCOS study fall within this cap and floor
11 band, my recommendation is to approve revenue increases based on the updated 2023
12 GRC CCOS study as sponsored by Company Witness Mr. Timothy E. Tatum's Direct
13 Testimony. I do not agree with these CCOS study results as I explain more fully below,
14 but full consideration of the IPC methods can occur in the next general rate case.
15 Furthermore, I recommend that the Commission make clear in its decision that IPC is
16 to perform a new CCOS study for its next rate case.
17 I also suggest that the Commission consider this case with caution and make
18 clear that any rate relief provided in this case does not constitute precedent for future
19 limited-issue cases and to discourage these types of cases in the future. It is not good
20 practice to allow for single-issue or piecemeal rate-making because a general rate case
21 is the best approach to ensure proper adjustments are made to all revenue, rate base,
22 and expense accounts. For example, investments in more advanced distribution and
23 transmission infrastructure should result in operations and maintenance expense
24 reductions. Without holistic general rate cases, these offsetting benefits may not be
25 captured in the determination of the revenue requirement.
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1 III. THE 2023 GRC CLASS COST OF SERVICE STUDY
2 Q. HAVE YOU REVIEWED THE 2023 GRC CCOS STUDY AND IPC'S
3 PROPOSED USE OF THAT STUDY IN THIS CASE?
4 A. Yes. I recognize that this case is a limited revenue requirement case with IPC's
5 proposed use of the 2023 GRC CCOS study and a proposed 130%-50%cap, floor rate
6 class revenue spread, and I am not looking to open this up to a full consideration of
7 CCOS study methods. However, there are concerns with the 2023 GRC CCOS study
8 that deserve some attention and could guide the Commission's decision for a more
9 appropriate rate class revenue spread than that proposed by IPC. My final
10 recommendation using the Company's proposed revenue requirement is to simply use
11 the IPC CCOS results for the revenue spread. However, it is important to understand
12 that alternative, industry-accepted CCOS methods produce very different CCOS
13 results,and even when given a little weight,bring balance back to the IPC CCOS results
14 for a reasonable decision for the purposes of this limited revenue requirement case. I
15 would expect a fully litigated CCOS study in the next GRC.
16 Q. PLEASE EXPLAIN YOUR CONCERNS WITH THE 2023 GRC CCOS
17 STUDY.
18 A. The methods used by IPC in its 2023 GRC CCOS study to allocate its demand-related
19 production costs to the rate classes are outdated and not reasonable for the purpose of
20 achieving a cost-based retail rate design that is fair and equitable among IPC's retail
21 rate classes. That is because the various underlying allocation factors in that CCOS
22 study do not reasonably allocate IPC's demand-related production costs to customers'
23 summer month peak usage for reasons I explain later in my testimony. FEA supports
24 cost-based rates for all customers including federal facilities,and changes are necessary
25 to IPC's CCOS study to set reasonable targets for cost-based revenue allocations
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I among IPC's retail rate classes. A preferable method for allocating demand-related
2 production costs among the rate classes results from use of the Average and Excess
3 Demand ("AED") cost allocation method.z The AED method addresses class summer
4 peak month usage while also considering class annual average usage. It is also accepted
5 for many electric utilities as a reasonable, equitable, and reliable method for allocating
6 demand-related production costs. I recommend that the Commission give some weight
7 in this proceeding to the AED cost allocation results when considering an appropriate
8 cap and floor revenue spread. The AED approach for IPC's demand-related costs is
9 supported by IPC's current production cost structure and system load profile for
10 reasons I also explain later in my testimony.
11 Q. WHICH WITNESS SPONSORS IPC'S CCOS STUDY?
12 A. IPC Witness Tatum explains that the Company proposes to rely upon the CCOS
13 methodology filed by the Company in IPC's previous 2023 GRC for purposes of this
14 limited-scope rate case. In the 2023 GRC, IPC Witness Pawel P. Goralski sponsored
15 IPC's CCOS study.3 Witness Tatum presents the updated results for the CCOS study
16 to support IPC's proposed revenue spread in this case.4
17 Q. IS IPC'S 2023 CCOS STUDY FILED IN THE 2023 GRC CONSISTENT WITH
18 THE COMMISSION'S DECISION ON PRODUCTION COST ALLOCATION
19 IN IPC'S 2008 GRC?
20 A. No. IPC made two material changes in its CCOS study filed in the 2023 GRC that
21 deviate from the Commission's decision in IPC's 2008 GRC. First, IPC proposed the
22 elimination of the use of the Idaho jurisdictional load factor for classifying production
23 plant and purchased power expenses as being either energy- or demand-related costs.
2 NARUC Electric Utility Cost Allocation Manual(1992),pp. 49-52.
3 Goralski Direct,Case No.IPC-E-23-11,Exhibit No. 36.
4 Tatum Direct at p.29.
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I Instead, IPC proposed classifying its baseload and intermediate plant costs as 100%
2 demand-related costs, allocated based on twelve coincident peaks ("12CP"), and
3 classification of its purchased power costs as 100%energy-related costs.5 Second, IPC
4 proposed the addition of September as a summer month and the corresponding change
5 to a four coincident peak ("4CP") allocator for demand-related peaking production
6 plant costs.
7 Q. DO YOU HAVE ANY COMMENTS ON IPC'S PROPOSED CHANGES TO
8 ITS CLASSIFICATION OF PURCHASED POWER COSTS AS 100%
9 ENERGY-RELATED COSTS?
10 A. Yes. The importance of this topic is in the setting of the base purchased power rates.
11 Except for economy energy transactions, purchased power costs typically reflect a
12 combination of capacity and energy costs embedded in the prices for those purchases.
13 Stated another way, IPC receives both capacity and energy benefits from most power
14 purchases that are included in its power supply portfolio, including purchases from
15 renewable energy generators. Therefore, I cannot support a blanket classification that
16 all purchased power costs can be reasonably classified as energy-related costs.
17 Consider the following statement made by IPC in its 2023 Integrated Resource
18 Plan ("2023 IRP"):
19 Idaho Power relies on regional power markets to supply a
20 significant portion of energy and capacity needs during
21 certain times of the year. Idaho Power leverages the regional
22 power market to make purchases during peak-load periods.
23 The existing transmission system is used to import these
24 power purchases. Regional power markets benefit Idaho
25 Power customers through decreased energy costs and
26 increased reliability.6
s See Case No.IPC-E-23-11,Direct Testimony of Pawel P.Goralski,p. 11 (June 1,2023).IPC also proposed
classifying water lease expenses that represent a minimal level of IPC's costs as 100%energy-related costs.
6 Case No.IPC-E-23-23,IPC's 2023 Integrated Resource Plan,"Building Our Future,"p. 55 (September 2023).
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I IPC's proposal to classify purchased power costs as 100% energy-related costs in its
2 2023 GRC CCOS study conflicts with its own statement in its 2023 IRP.
3 Q. IS THERE OTHER EVIDENCE THAT IPC RELIES ON PURCHASED
4 POWER TO MEET ITS CAPACITY NEEDS?
5 A. Yes. In its 2021 Integrated Resource Plan ("2021 IRP"), IPC lists purchased power
6 and transmission as a source for 30% of its existing capacity resources for purposes of
7 meeting its projected July 2024 peak-hour requirements. (See 2021 IRP, p. 142.) It is
8 unreasonable for IPC to ignore the capacity value it places on power purchases for
9 planning purposes when developing its CCOS study.
10 Q. DO YOU HAVE ANY COMMENTS ON IPC'S PROPOSAL TO USE FOUR
11 SUMMER MONTHS FOR THE PURPOSE OF ALLOCATING PEAKING
12 PRODUCTION PLANT COSTS?
13 A. Yes. It is clear to me that that IPC's power supply portfolio is primarily tailored to
14 meeting customers' summer peak month usage. IPC plans capacity positions with a
15 target threshold of 0.1 event-days per year of loss of load expectation ("LOLE"). IPC
16 presents monthly LOLE percentage projections in its 2023 IRP. Those monthly
17 projections show a concentration of LOLE of 77.8%in July and August, and 84.2%for
18 the four summer months of June through September when June and September at 2.8%
19 and 3.6%LOLE,respectively,are added to the July and August total. I can reasonably
20 conclude from this data that IPC has a reasonable foundational argument for including
21 September as a summer month for CCOS study and rate design purposes.
22 However, my position that it is reasonable for IPC to include September as a
23 summer month from a resource planning perspective does not translate into support for
7 See IPC's 2023 IRP,Technical Appendix C,p. 96.
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I IPC's 4CP/12CP production cost allocation methodology that it employed in its 2023
2 GRC CCOS study.
3 Q. DO YOU HAVE OTHER EVIDENCE TO SUPPORT WEIGHTING THE
4 SUMMER MONTHS HEAVIER IN THE CHOICE OF ALLOCATION
5 METHOD?
6 A. Yes. IPC's monthly system peak demands are presented in Table 1, below. One
7 criterion used in the determination of an appropriate allocation method for production
8 and for transmission is to assess the annual system load profile of the electric utility.
9 Specifically, I look at the monthly system peak demands for all 12 months to identify
10 which months fall within a close range of the maximum month, which in the case of
11 IPC occurred in June.
Table 1. IPC Monthly System Peak Demands
of Peak
January 63.5% 2,219,506
February 60.9% 2,128,273
March 61.6% 2,153,910
April 49.0% 1,714,832
May 70.2% 2,455,950
June 100.0% 3,496,120
July 92.2% 3,224,178
August 87.9% 3,071,846
September 85.7% 2,995,520
October 53.0% 1,851,866
November 58.5% 2,043,833
December 68.7% 2,402,388
12 Here we see that the four summer months of June, July,August, and September
13 are within 15%of highest demand in June. The next highest demand outside of the four
14 summer months occurred in May, which was almost 30% less than the system peak in
15 June. Therefore, for this electric utility,these four summer months seem to be a natural
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I grouping of the peak demands that drive the generation capacity and transmission
2 capacity requirements for IPC, and an allocation method giving greater weight to 4CP
3 is justified. The use of a 12CP method is not justified when we look at the magnitude
4 of the other months of the year such as December and January with peak demands that
5 are only 68.7% and 63.5% of the June system peak, respectively. The use of this type
6 of monthly peak demand comparisons is supported in the 1992 NARUC Electric Utility
7 Cost Allocation Manual.s
8 Q. WHAT OTHER CONCERNS DO YOU HAVE REGARDING IPC'S 4CP/12CP
9 METHODOLOGY?
10 A. My primary criticism of IPC's 4CP/12CP methodology is that it is no longer relevant
11 to IPC's current resource planning framework and power supply portfolio cost
12 structure. In other words, it is a legacy method of cost allocation that may have been
13 relevant to IPC in the 2008 time frame when the Commission last opined on that
14 methodology, but it is no longer relevant to IPC today.
15 My second criticism of IPC's 4CP/12CP methodology is that it does not
16 represent a holistic view of IPC's power supply portfolio where all resources are
17 integrated for a single purpose of cost-effectively achieving IPC's resource adequacy
18 requirements and supplying customers' energy requirements throughout the year. This
19 is particularly concerning as IPC's power supply portfolio evolves with the planned
20 retirement of its coal-fired plants and additions of significant amounts of renewable
21 energy. Choosing how to classify plants among baseload, intermediate, and peaking
22 plants, and how to allocate the associated costs of plant additions produces unnecessary
23 uncertainty into the CCOS process going forward.
$For example,the note on p.48 of the 1992 NARUC manual.
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I My third criticism of IPC's 4CP/12CP methodology for allocating demand-
2 related production plant costs is that it grossly over-allocates costs to customers' non-
3 summer month usage. That result is counter to IPC's clear resource adequacy
4 requirements that are concentrated in the months of July and August, and to a much
5 lesser extent in June and September or selected non-summer months depending upon
6 IPC's resource mix in any given year.
7 Q. WHY DO YOU TAKE THE POSITION THAT IPC'S 4CP/12CP
8 METHODOLOGY IS A LEGACY METHOD OF COST ALLOCATION?
9 A. IPC is a low-cost energy provider; however, far more so at the time of the 2008 GRC
10 than it is today. The legacy trade-off in IPC's retail rate design is that energy-intensive
11 industrial customers with elevated levels of year-round usage, who disproportionately
12 benefited from IPC's low 2008 cost structure and large proportion of off-system sales
13 revenues, should pay a disproportionate amount of IPC's low-cost baseload hydro and
14 coal-fueled demand-related production costs. IPC added the Langley Gulch Power
15 Plant, a natural gas-fired combined cycle gas turbine ("CCGT")plant, to that baseload
16 category of costs in the 2023 GRC, so the trade-off from the 2008 GRC extended to
17 that plant and IPC's associated demand-related production costs for that plant.
18 However, IPC's off-system sales revenue has been much lower than levels that existed
19 at the time of the 2008 GRC, or even the 2007 GRC when IPC conceived of its current
20 3CP/12CP methodology for allocating demand-related production costs.9 Therefore, a
21 key underlying reason that could be used to support the 4CP/12CP methodology
22 embedded in IPC's CCOS study in the 2023 GRC and in this case no longer exists.
9 Compare Sterling Direct(Staff)Exhibit No. 104,Case No.IPC-E-08-10 Net Power Supply levels to 2023
GRC Stipulation Exhibit 3.
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I Q. PLEASE EXPLAIN YOUR CRITICISM OF IPC'S 4CP/12CP
2 METHODOLOGY AS IT RELATES TO THE CONCEPT OF TAKING A
3 HOLISTIC VIEW OF IPC'S POWER SUPPLY PORTFOLIO.
4 A. Although the system demands throughout the year are important to choices made in the
5 development of the portfolio, it is important to realize that all generation capacity is
6 part of the whole intended to meet the maximum peak demand period of the year.
7 Average demand drives the need for base and some intermediate capacity, while the
8 excess demands during peak months drive the need for more intermediate and peak
9 demand capacity. For this reason, the AED method has been widely accepted in many
10 state jurisdictions.
11 Q. WHAT IS YOUR RECOMMENDATION FOR ESTABLISHING AN
12 EQUITABLE ALLOCATION OF IPC'S PRODUCTION COSTS AMONG
13 THE RATE CLASSES?
14 A. I recommend that the Commissioners consider the AED-4CP method results when
15 considering the range of revenue spread for rate-making in this case. In the next rate
16 case, the Commission can consider the appropriate methods that should be adopted
17 within the detailed cost modeling.
18 Q. PLEASE EXPLAIN THE AED METHOD.
19 A. The AED-4CP cost allocation method recognizes that production costs are driven by
20 the need for a mix of generation resources, some capacity for baseload demand and
21 intermediate demand (captured by average demand), and some capacity for the excess
22 customer demand that occurs during system peak demand times during the year. The
23 AED-4CP begins by utilizing the system load factor as a weight for the average demand
24 and one minus the system load factor as the weight for the excess demand. Excess
25 demand is the difference between the 4CP demand and the average demand. Average
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I demand ratios for each rate class are derived based on total system average demand,
2 and excess demand ratios for each rate class are derived based on total system 4CP
3 excess demand. The system load factor is multiplied by each of the rate class average
4 demand ratios. One minus the system load factor is multiplied by each of the rate class
5 excess demand ratios. These rate class weighted ratios are then summed together to
6 derive the total AED-4CP allocation ratios.10
7 Q. PLEASE EXPLAIN WHY THE AED METHOD IS WIDELY ACCEPTED IN
8 MANY STATE JURISDICTIONS.
9 A. The AED method is widely accepted because it recognizes that the portfolio of
10 generation capacity necessary to meet the seasonal, daily, and hourly variations in
11 customer demand throughout the year is a primary driver of total production costs.
12 Utilizing a 4CP demand measure for the calculation of excess demand for each rate
13 class recognizes the diversity in customer demand that may exist during the highest
14 peak demand months of the year and the excess capacity and power needed to meet
15 those peak demand times of the year. Utilizing average demand throughout the year
16 recognizes the baseload and,to some extent, intermediate load generation capacity and
17 power needs required throughout the year.
18 Q. WHY IS THE AED-4CP METHOD SUPERIOR TO THE 4CP/12CP METHOD
19 PROPOSED BY THE COMPANY?
20 A. It has long been accepted that average demand rather than 12CP demand is a better
21 measure to capture baseload production capacity requirements. Excess demand
22 calculated as the difference between 4CP and average demand better captures the need
23 for excess power during peak demand times rather than 4CP ratios. That is, it is not the
24 total 4CP that causes the need for excess power, but the excess demand (in excess of
10The AED method is described on pp.49-52 of the 1992 NARUC Electric Utility Cost Allocation Manual.
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I baseload demand) that causes the excess power costs. Furthermore, the recognition of
2 excess demand as the primary driver of additional capacity costs will better serve
3 economic development in Idaho as commercial customers consider siting alternatives
4 across the nation.
5 Q. WHY IS THE AED-4CP METHOD YOU RECOMMEND APPROPRIATE
6 FOR IPC'S POWER SUPPLY PORTFOLIO?
7 A. As I already stated, the AED-4CP method is well designed to recognize the power
8 supply portfolio adopted to meet the variations in customer system demand throughout
9 the year. As the sources and technologies that comprise the power supply portfolio
10 evolve through time, the underlying customer demand characteristics do not radically
11 change and, therefore, cost causation captured by the AED-4CP method also does not
12 change. In other words, customer demand and system load profile cause the need for
13 generation capacity,and the mix of generation capacity does not change this underlying
14 cost causation relationship.
15 Q. DO YOU HAVE RESULTS UTILIZING THE IPC 2023 COST STUDY IN
16 WHICH THE AED-4CP ALLOCATOR IS UTILIZED?
17 A. Yes, these results of using the AED-4CP within the 2023 IPC CCOS study in
18 comparison to the IPC results are reflected in Table 2, below.
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Table 2. Cost-Based Base Revenue Changes by Rate Class with IPC's 4CP/12CP Study
and FEA's AED-4CP Study using 2023 GRC values
I PC's F EA's
4CP/12CP AED-4CP
Cost-Based Cost-Based
Revenue Revenue
Rate Class Change Change Difference(')
Residential 10.49% 9.54% -0.9%
Residential On-Site Generation 51.56% 46.77% -4.8%
Small General Service 13.27% 8.63% -4.6%
Small General Service On-Site 110.64% °
Generation 94.26/° -16.4/°
Large General Service Secondary 0.33% -8.03% -8.4%
Large General Service Primary and Trans. -2.57% -11.21% -8.6%
Area Lighting -44.41% -36.68% 7.7%
Large Power Service 5.82% -5.29% -11.1%
Irrigation 19.59% 53.97% 34.4%
Unmetered Service 2.48% -3.11% -5.6%
Street Lighting -24.67% -13.96% 10.7%
Traffic Control Lighting 117.51% 102.61% -14.9%
DOE 7.02% -11.34% -18.4%
Simplot -0.30% 11.02% 11.3%
Micron 7.14% -7.65% -14.8%
Total Idaho Retail Jurisdictional Change 8.61% 8.61%
(1) Case No. IPC-E-23-11, Exhibit No.42,adjusted to use AED-4CP for demand-related
production costs.
(2) Presents IPC's rate-of-return at present base rates.
(3) Shows the class rate-of-return relative to the Idaho retail jurisdictional rate-of-return.
(4) Presents the changes in base revenues by rate class required to reach the CCOS study's cost-based base
revenue levels.
1 As reflected in Table 2, there are large differences in the cost of service once average
2 demand is used instead of 12CP and excess demand is used during the summer months, rather
3 than 4CP. The excess demand measure captures the additional capacity needed to meet the
4 peak summer demands, and thereby gives greater weight to the customer loads causing the
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I summer peaks. Therefore, if given some weight in this case, this serves to justify a broader
2 cap-floor band for determination of the class revenue spread.
3
4 IV. RECOMMENDED CLASS REVENUE SPREAD
5 Q. HOW HAS THE COMPANY PROPOSED TO SPREAD THE REVENUE
6 REQUIREMENT ACROSS CUSTOMER CLASSES?
7 A. IPC has proposed to use a cap and floor methodology in which rate classes with cost
8 of service results above the system average increase will be increased above the system
9 average increase, but no more than 130% above the system average, and rate classes
10 with cost of service below the system average increase will not have an increase that is
11 less than 50% of the system average. These cap and floor parameters are consistent
12 with the Stipulation in the 2023 GRC. The Stipulation among the parties is limited to
13 resolution of the issues in that rate case and do not set precedent nor bind the parties
14 from making alternative recommendations in this case.
15 Q. IS THE CAP AND FLOOR METHOD PROPOSED IN THIS CASE
16 CONSISTENT WITH PAST RATE CASE DECISIONS?
17 A. No. For example, the Commission's decision in Case No. IPC-E-08-10 resulted in
18 increases for many rate classes that were 193% above the system average and as low
19 as 0%. Therefore, IPC's proposal to use a 130-50 cap-floor band is not based on
20 anything but a settlement in which give and take between the parties on many issues
21 unique to that case were resolved. The effect of the decision in Case No. IPC-E-08-10
22 on revenue spread is summarized in Table 3, below.
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Table 3. Percentage Change in Base Revenue by Rate Class in
Case No. IPC-E-08-10
Approved Change Effective
Percent Relative to Cap and
Rate Class Change(') Total(Z) Floor
Residential 1.61% 52%
Small General Service 0.42% 14%
Large General Service 3.35% 108%
Dusk to Dawn Lighting 0.00% 0% 0%
Large Power Service 5.62% 181%
Irrigation 6.00% 194% 194%
Unmetered Service 0.00% 0% 0%
Street Lighting 0.00% 0% 0%
Traffic Control Lighting 6.00% 194% 194%
DOE 6.00% 194% 194%
Simplot 6.00% 194% 194%
Micron 6.00% 194% 194%
Total Idaho Retail
Jurisdictional Change 3.10% 100%
Case No. IPC-E-08-10, Order No. 30722, pp. 37-38 (January 30,
2009).
(2) Represents the class base revenue percentage change divided by the total Idaho
retail jurisdictional percentage change.
1 Q. WHAT IS YOUR RECOMMENDATION IN THIS CASE?
2 A. I recommend that the Commission incorporate a 190% — 0% cap and floor band to
3 allocate any approved rate increase across the customer classes. Because the cost-based
4 rate increases derived by IPC fall within this cap and floor band at the proposed revenue
5 requirement, my recommendation would be to approve the cost-based revenue
6 increases based on the updated 2023 GRC CCOS study even though I disagree with the
7 methods used in that study. If the Commission approves a lower revenue requirement
8 in this case, then the 2023 GRC CCOS study results by rate class need to be updated
9 as part of the IPC compliance filing and the 190% — 0% cap and floor band I am
10 recommending may become effective.
L. BLANK, DI 19
Federal Executive Agencies

I I also recommend the Commission direct the Company to prepare a CCOS
2 study for the next rate case to achieve a new baseline for the consideration of CCOS
3 methods and revenue spread.
4 Q. CAN YOU SHARE YOUR RECOMMENDED REVENUE SPREAD AT THE
5 IPC PROPOSED REVENUE REQUIREMENT?
6 A. Yes. Table 4,below, provides the cost-based results produced by IPC.
Table 4. Percentage Change in Base Revenue by Rate Class - FEA Proposal with IPC
Study
Proposed Change Effective
Percent Relative to Cap and
Rate Class Change(') Total(2) Floor(')
Residential 7.16% 98%
Small General Service 7.21% 99%
Large General Service Secondary 6.77% 93%
Large General Service Primary and Trans. 6.65% 91%
Area Lighting 0.06% 1%
Large Power Service 7.01% 96%
Irrigation 10.17% 139%
Unmetered Service 7.37% 101%
Street Lighting 5.87% 80%
Traffic Control Lighting 11.18% 153%
DOE 3.75% 51%
Simplot 4.49% 61%
Micron 5.44% 74%
Total Idaho Retail Jurisdictional
7.31% 100%
Change
(1) Case No. IPC-E-24-07, Exhibit No. 4 (May 31, 2024), IPC CCOS results.
(2) Represents the class base revenue percentage change divided by the total Idaho retail
jurisdictional percentage change.
0) No class reached either the 190%cap nor 0%floor.
7 Q. WHAT IS THE EFFECT OF YOUR RECOMMENDED CAP-FLOOR BAND
8 FOR THE REVENUE SPREAD IN THIS CASE?
L. BLANK, DI 20
Federal Executive Agencies

I A. Because the IPC CCOS results fall within my recommended cap-floor of 190% and
2 0%, the recommendation is to simply approve the IPC CCOS results as the revenue
3 spread in this case.
4 Q. DOES THIS CONCLUDE YOUR DIRECT TESTIMONY?
5 A. Yes.
L. BLANK, DI 21
Federal Executive Agencies

EXHIBIT 501 (LB-1)
RESUME OF LARRY BALNK

Larry Blank
Education
Ph.D. in Economics, The University of Tennessee, Knoxville, August 1994.
B.S. in Economics(major),Mathematics(minor),Bemidji State University,Minnesota,May 1989.
Ph.D. Fields of Concentration
Industrial Organization& Public Policy(including utility rates and regulation)
Econometrics
Finance
Professional Experience
Principal Consultant, TAHOEconomics, LLC, August 1999 - Present. Clients have included
Government Agencies, Utility Customers, and Utility Companies focusing on most aspects of
regulatory policy development and rate regulation for public utilities.
Professor of Economics,Department of Economics, Applied Statistics, &International Business,
New Mexico State University(NMSU), August 2021 —Present. Currently teaching graduate-level
public utility regulation, business and government, antitrust policy/economics, and applied
microeconomics.
Associate Professor of Economics,Department of Economics, Applied Statistics,&International
Business,New Mexico State University(NMSU), August 2009—July 2021.
Associate Director,Center for Public Utilities,NMSU,January 2011 —Present. Electric Utility and
Natural Gas Distribution ratemaking training. The Center's training is endorsed by the National
Association of Regulatory Utility Commissioners (NARUC).
Senior Associate, Center for Public Utilities, NMSU, August 2003 December 2010.
Assistant Professor of Economics, Department of Economics & International Business, New
Mexico State University(NMSU), August 2003 —July 2009.
Manager of Regulatory Policy and Market Analysis,Regulatory Operations Staff,Public Utilities
Commission of Nevada, October 1997- August 1999.
Responsibilities: Directed a ten-person division with duties covering most aspects of utility
regulation and competitive restructuring across all industries(primarily telecommunications,
electric,and natural gas);implementation ofthe Telecommunications Act of 1996; division
management of all rates and tariffs; lead management of staff s electric and natural gas
restructuring activities. Close coordination with legal division in litigated case preparation
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
1

including lead negotiation experience.
Supervising Economist, Regulatory Operations Staff, Public Service Commission of Nevada,
March 1996 - October 1997. Duties similar to those above.
Research Economist, National Regulatory Research Institute, The Ohio State University and the
National Association of Regulatory Utility Commissioners (NARUC), September 1994 - March
1996.
Lecturer, School of Public Policy and Management, The Ohio State University(taught Graduate
Public Finance).
Published Papers and Reports
"Assessing the Impact of Selected Determinants on Renewable Energy Sources in the
Electricity Mix," (with Khezri, Karimi, Mamkhezri, and Ghazal). Energies, 15 (2022).
"Do Residential Net Metering Customers Pay Their Fair Share of Electricity Costs?
Evidence from New Mexico Ltilities," Utilities Policy Journal, Volume 61, (December 2019).
"An Enhanced Two-Part Tariff Methodology When Demand Charges Are Not Used,"
(with Doug Gegax). The Electricity Journal, Volume 29, No. 3 (2016).
"Residential Winners and Losers behind the Energy versus Customer Charge Debate,"
(with Doug Gegax). The Electricity Journal, Vol. 27, No. 4(2014).
"Benchmarking Electric Distribution Utilities in the Philippines," (with Doug Gegax and
Ben Widner).Asian Social Science, Vol. 8, No. 3 (2012).
"Objectively Designing Shared Savings Incentive Mechanisms: An Opportunity Cost
Model for Electric Utility Efficiency Programs," (with Doug Gegax). The Electricity Journal,
Vol. 24, No. 9 (2011), pp. 31-40.
"Endogenous Regulatory Constraints and The Emergence of Hybrid Regulation," (with
John Mayo).Review of Industrial Organization, Vol. 35 (2009), pp. 233-255.
"Promotions as Coopetition in the Soft Drink Industry," (with Mike Hyman and Michael
Meade).Academy ofMarketing Studies Journal, September, 2009.
"A Dynamic Model of Insurgency: The Case of the War in Iraq," (with C.E. Enomoto, D.
Gegax, T. McGuckin, and C. Simmons),Peace Economics, Peace Science and Public Policy,
Vol. 14, No. 2, 2008.
"The Role of Regulation in Expanding Access to Electricity: Reform in the Philippines,"
(with Mk Shean),Energy Update, Issue No. 4, 2005.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
2

"Open Entry and Local Telephone Rates: The Economics of IntraLATA Toll Competition,"
(with David Kaserman,John Mayo,and Simran Kahai),Review oflndustrial Organization,Vol. 14,
No. 4, June 2000,pp. 303-319.
"Dominant Firm Pricing with Competitive Entry and Regulation: The Case of IntraLATA
Toll," (with David Kaserman and John Mayo),Journal ofRegulatory Economics,Vol. 14, 1998,pp.
35-53.
"Concavity Assumptions in Regulatory Models and the Capital Waste Controversy,"Journal
ofRegulatory Economics, Vol. 9, 1996, pp. 95-100.
"Key Antitrust Pricing Issues for Regulated Industries with Emerging Competition," NRRI
Quarterly Bulletin, Vol. 17, No. 2, 1996, pp. 279-298.
"Telephone Vouchers:Experiences in Other Markets,"NRRI QuarterlyBulletin,Vol. 16,No.4,
1995,pp. 537-547.
Selected Reports:
Telecommunications Service Quality (with V.W. Davis, D. Landsbergen, R.W. Lawton, N.
Zearfoss, and J. Hoag), National Regulatory Research Institute, The Ohio State University,
Columbus, March 1996.
Telecommunication Infrastructure Investments and State Regulatory Reform: A Preliminary
Look at the Data (with Vivian Davis and Catherine Reed), The National Regulatory Research
Institute, The Ohio State University, Columbus, December 1994.
Considerations in Preparing and Reviewing Socioeconomic Impact Assessments for Low-Level
Waste Disposal Facilities (with Mary English, Matthew Murray, and Zoe Hoyle), for the U.S.
Department of Energy. National Low-Level Waste Management Program,EG&G Idaho,Inc.,Idaho
Falls, Idaho: August 1992.
Economic Impact of Chem-Nuclear Systems, Inc. on Barnwell County, South Carolina (with
Matthew Murray),for the U.S. Department of Energy. Energy,Environment and Resources Center,
The University of Tennessee, Knoxville, November 1990.
Grants
U.S. Department of Energy, Technical Assistance to the Energy Regulatory Commission of the
Philippines, January 2002—January 2005.
U.S.Department of Energy, Sustainable Energy Development Program(Philippines),January 2005
— August 2005. Completed the Open Access Distribution Service Rules governing 140 electric
distribution utilities.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
3

Presentations and Conference Participation
"Utility Finance 101: A Discussion of Basics for Commissioners," Utility Commissioners Wall
Street Dialogue, organized by Gee Strategies Group and Edison Electric Institute, May 2022.
"ERCOT and the week of February 14,2021,"technical presentation to the Lubbock Economics
Council, March 4, 2021.
Lead speaker at the Edison Electric Institute's Advanced Ratemaking Course, University of
Wisconsin, every July since 2011.
"Statistically Determining Proper Recovery of Demand-Related Costs through the Energy
Charge," and Discussant: CRRI University Advanced Workshop in Regulation and Competition,
Monterey, CA, June 2013.
"The FERC's Vintage and Original Purpose Doctrine for Transmission Pricing:
Distorted Economics and Economic Distortions," and Discussant: CRRI University Advanced
Workshop in Regulation and Competition, Monterey, CA, June 2012.
"Objectively Designing Shared Savings Incentive Mechanisms: An Opportunity Cost
Model for Electric Utility Efficiency Programs," and Discussant: CRRI Rutgers University
Advanced Workshop in Regulation and Competition, Sky Top, PA, May 2011.
Presentation: "Can Regulators Stop the Tax Bleeding of the Universal Service Fund?" and
Discussant: CRRI Rutgers University Advanced Workshop in Regulation and Competition, Sky
Top, PA, May 2008.
Presentation: "Endogenous Regulatory Constraints and the Emergence of Hybrid Regulation,"
Western Economic Association Meetings, Seattle, WA, July 2007.
Presentation: "PUHCA Uncertainty...States," Western Governors'Association Energy Summit,
Albuquerque, NM, April 15, 2004.
Discussant,Advanced Workshop in Regulation and Competition, Monterey, CA, July 6, 2000.
Presentation: "Nevada Electric Restructuring,"Western RiskManagement&Claims Workshop,
Western Electric Power Institute, San Diego, CA, July 8, 1999.
Discussant,Advanced Workshop in Regulation and Competition, San Diego, CA, July 7-9, 1999.
Participant,Danish Ministry Workshop on Telecommunications Interconnection, Special invitation
by the Danish Ministry of Research and Information Technology, London,UK, December 14-15,
1998.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
4

Presentation: "Regulatory Choice: Constraints and Inefficiency," Advanced Workshop in
Regulation and Competition, Monterey, CA, July 10, 1998.
Presentation: "Regulatory Choice: Constraints and Inefficiency," The 73rd Annual Western
Economic Association Conference, June 29, 1998.
Discussant,The 25thAnnual Telecommunications Policy Research Conference(TPRC), Alexandria,
VA, September 27-29, 1997.
Presentation: "Electricity Restructuring Issues," two presentations before the Nevada State
Senate Committee on Commerce and Labor, February 1997.
Presentation: "Regulating Market Penetration:A Higher-Powered Incentive Scheme for Local
Exchange Companies," The Tenth NAR UC Biennial Regulatory Information Conference,Hosted
by the National Regulatory Research Institute at The Ohio State University, Columbus, September
11, 1996.
Presentation: "Regulating Market Penetration:A Higher-Powered Incentive Scheme for Local
Telephone Companies," The Advanced Workshop in Regulation and Public Utility Economics,
Hosted by the Center for Research in Regulated Industries at Rutgers University,Lake George,NY,
May 30, 1996.
Presentation: "Balancing Seemingly Conflicting Goals through a Minimum Subscribership
Plan:Economic Efficiency and the Risks Borne by Regulators," The 27thAnnual Conference of
the Institute of Public Utilities, Williamsburg, VA, December 12, 1995.
Presentation: "The Minunum Subscribership Plan (MSP): Quality, Prices, and Current
Policy," The 23rd Annual Telecommunications Policy Research Conference (TPRC), Solomons,
MD, October 2, 1995.
Presentation: "A Positive Theory of Price-Cap and Rate-of-Return Regulation: Substitutes or
Complements?" Southern Economic Association Meetings, Orlando, FL, November 22, 1994.
Journal Referee
Peace Economics, Peace Science and Public Policy, July 2011.
The American Economic Review, April 1995.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
5

Case Participation
Electricity:
Regulatory Commission of Alaska, Docket No. U-23-047, "In the Matter of Tariff Revision
Designated as TA544-8 Filed by CHUGACH ELECTRIC ASSOCIATION, INC." Expert
witness testimony filed on behalf of the City of Seward, March 14, 2024.
KY PSC Case No. 2023-00312, "In the Matter of Electronic Tariff Filing of Big Rivers
Electric Corporation and Kenergy Corp. to Revise the Large Industrial Customer Standby
Service Tariff." Expert witness testimony filed on behalf of Kimberly-Clark Corporation,
December 4, 2023.
KS State Corporation Commission Docket No. 23-EKCE-775-RTS, "In the Matter of the
Application of Evergy Kansas Metro, Inc., Evergy Kansas South, Inc. and Evergy Kansas
Central, Inc. to make Certain Changes in their Charges for Electric Service Pursuant to
K.S.A 66-117." Expert witness testimony filed on behalf of U.S. Department of Defense and
all other Federal Executive Agencies. August 29, 2023 (Direct), September 5, 2023 (Cross-
Answer).
DE PSC Docket No. 23-0601 , "In the Matter of the Application OF ARTESIAN WATER
COMPANY, INC. FORA REVISION OF RATES." Expert witness testimony filed on behalf
of Delaware Public Service Commission Staff, March 1 , 2024.
DE PSC Docket No. 22-0897, "In the MATTER OF THE APPLICATION OF DELMARVA
POWER & LIGHT COMPANY FOR AN INCREASE IN ELECTRIC BASE RATES AND
OTHER MISCELLANEOUS TARIFF CHANGES." Expert witness testimony filed on behalf
of Delaware Public Service Commission Staff, August 18, 2023.
NC Utilities Commission Docket No. E-2, SUB 1300, "In the Matter of Application of Duke
Energy Progress, LLC For Adjustment of Rates and Charges Applicable to Electric Service
in North Carolina and Performance-Based Regulation." Expert witness testimony filed on
behalf of U.S. Department of Defense and all other Federal Executive Agencies, March 27,
2023.
NV PUC Docket No. 23-06007, "Application of Nevada Power Company d/b/a NV Energy
for authority to adjust its annual revenue requirement for general rates charged to all
classes of electric customers and for relief properly related thereto." Expert witness
testimony filed on behalf of the Southern Nevada Gaming Group, September 25, 2023.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
6

NV PUC Docket No. 23-02010, "Application of Nevada Power Company d/b/a NV Energy
under Advice Letter No. 535 to revise Tariff No. 1-B to revise the Large Customer Market
Price Entergy Schedule No. LCMPE to set forth when an Energy Supply Agreement must
be filed with an Integrated Resource Plan or Integrated Resource Plan amendment, a
requirement for a true-up or adjustment and a requirement for a short form statement O,
pursuant to the Order issued in Docket No. 22-03025." Expert witness testimony filed on
behalf of the Southern Nevada Gaming Group, July 14, 2023.
NV PUC Docket No. 23-09012, "Application of Southwest Gas Corporation for authority to
increase its retail natural gas utility service rates for Southern and Northern Nevada."
Expert witness testimony filed on behalf of the Southern Nevada Gaming Group, February
2, 2024.
NM PRC Case No. 22-00058-UT, "In the matter of Public Service Company of New
Mexico's Application for Authorization to implement Grid Modernization Components
including Advanced Metering Infrastructure." Expert witness testimony on behalf of the City
of Albuquerque, 2023.
GA PSC Docket No. 44280, "Georgia Power Company's 2022 Rate Case." Expert witness
testimony on behalf of the United States Department of Defense, 2022.
NV PUC Docket No. 22-06014, "Application of Sierra Pacific Power Company for Authority
to Adjust is annual Revenue Requirement." Expert witness testimony on behalf of
Peppermill Casinos Inc., 2022.
NV PUC Docket No. 22-03028, "Joint Application of Nevada Power Company and Sierra
Pacific Power Company for Approval to Merge." Expert witness testimony on behalf of the
Southern Nevada Gaming Group, 2022.
WY PSC Docket No. 2003-214-ER-22, "In the matter of the Application of Cheyenne Light,
Fuel and Power Company d/b/a Black Hills Energy for a General Rate Increase." Expert
witness testimony on behalf of Microsoft Corporation, 2022.
AR PSC Docket No. 22-001-TF, "In the matter of Entergy Arkansas, LLC's Request for
Tariff Changes to Rate Schedule No. 41 ." Expert witness testimony on behalf of Arkansas
Electric Energy Consumers, Inc. and the Hospitals and Higher Education Group, 2022.
NM PRC Case No. 19-00018-UT, "In the matter of Public Service Company of New
Mexico's Abandonment of San Juan Generating Station Units 1 and 4." Expert witness
testimony on behalf of Western Resource Advocates, 2022.
NH PUC Docket No. DE-21-030, "Unitil Energy Systems, Inc. Request for Change in
Rates." Expert witness testimony on behalf of the New Hampshire Department of Energy
(Staff), 2021 .
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
7

TX PUC Docket No. 52195, "Application of El Paso Electric Company to Change Rates."
Expert witness testimony on behalf of the U.S. Department of Defense, 2021 .
TX PUC, Docket No. 51802, "Application of Southwestern Public Service Company for
Authority to Change Rates." Expert witness testimony on behalf of the Federal Executive
Agencies and Orion Engineered Carbons, 2021 .
CO PUC, Proceeding No. 20-AL-0432E, "In the matter of Advice Letter...by Public Service
Company of Colorado to revise its Colorado Electric Tariff," Phase II cost allocation and
rate design expert witness testimony on behalf of the Federal Executive Agencies (DOE),
2021 .
DE PSC, Docket No. 20-0149, "In the matter of the Application of Delmarva Power& Light
Company for an Increase in Electric Base Rates." Expert witness testimony on behalf of the
Public Service Commission Staff, 2020-21 .
NM PRC Case No. 20-00222-UT, "In the matter of the Joint Application of Avangrid, Inc,
Avangrid Networks, Inc, NM Green Holdings, Inc, Public Service Company of New Mexico
and PNM Resources, Inc. for approval of the Merger..." Expert Witness testimony on behalf
of the City of Albuquerque, 2021 .
NM PRC Case No. 20-00237-UT, "In the matter of Public Service Company of New
Mexico's Application for Approval of its 2022-2023 Transportation Electrification Program."
Expert witness testimony on behalf of the City of Albuquerque, 2021 .
NM PRC, Docket No. 20-00121-UT, "In the matter of the Petition of Public Service
Company of New Mexico, Pursuant to the Efficient Use of Energy Act and the Public Utility
Act, for Approval of a Rate Adjustment Mechanism to Remove Regulatory Disincentives
and Original Rider No. 5." Expert witness testimony on behalf of the City of Albuquerque,
2020.
AR PSC, Docket No. 16-036-FR, "In the matter of the Formula Rate Plan filings of Entergy
Arkansas, Inc. pursuant to APSC Docket No. 15-015-U." Expert witness testimony on
behalf of the Hospitals and Higher Education Group, 2020.
NV PUC, Docket No. 20-06003, "Nevada Power Application to adjust revenue
requirement." Expert witness testimony on behalf of the Southern Nevada Gaming Group,
2020.
TX PUC, Docket No. 49831 , "Application of Southwestern Public Service Company for
Authority to Change Rates." Expert witness testimony on behalf of the United States
Department of Energy, 2020.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
8

AZ CC, Docket No. E-01933A-19-0028, "In the matter of the Application of Tucson Electric
Power Company for the Establishment of Just and Reasonable Rates..." Expert witness
testimony on behalf of the United States Department of Defense and all other Federal
Executive Agencies, 2020.
GA PSC, Docket No. 42516, "In RE: Georgia Power Company's 2019 Rate Case." Expert
witness testimony on behalf of the United States Department of Defense and all other
Federal Executive Agencies, 2019.
DE PSC, Docket 17-0977, "In the matter of the Application of Delmarva Power & Light
Company for an Increase in Electric Base Rates." Expert witness testimony on behalf of the
Public Service Commission Staff, 2019 (Phase II- State Jurisdictional Allocation).
NM PRC, Case No. 19-00158-UT, "In the matter of the Application of Public Service
Company of New Mexico for Approval of PNM Solar Direct Voluntary Renewable Energy
Program, Power Purchase Agreement, and Advice Notice Nos. 560 and 561 ." Expert
witness testimony on behalf of the City of Albuquerque, 2019.
AR PSC, Docket No. 19-008-U, "In the matter of the Application of Southwestern Electric
Power Company for Approval of a General Change in Rates and Tariff." Expert witness
testimony on behalf of the Board of Trustees of the University of Arkansas, 2019.
NM PRC, Case No. 18-00383-UT, "In the matter of the filing of Advice Notice No. 69 by
Socorro Electric Cooperative, Inc.." Expert witness testimony on behalf of the City of
Socorro and New Mexico Institute of Mining and Technology, 2019.
AR PSC, Docket No. 16-036-FR, "In the matter of the Formula Rate Plan filings of Entergy
Arkansas, Inc. pursuant to APSC Docket No. 15-015-U."Expert witness testimony on behalf of the
Hospitals and Higher Education Group, 201 S.
NM PRC, Case No. 17-00255-UT, "In the matter of Southwestern Public Service Company's
Application for revision of its Retail Electric Rates under Advice Notice No. 272."Expert witness
testimony on behalf of the City of Albuquerque, 20IS.
KS CC, Docket No. 18-WSEE-328-RTS, "In the matter of the Joint Application of Westar Energy,
Inc. and Kansas Gas and Electric Company for Approval to make certain changes to their Charges
for Electric Service." Expert witness testimony on behalf of the United States Department of
Defense and all other Federal Executive Agencies, 2018.
DE PSC, Docket 17-0977, "In the matter of the Application of Delmarva Power& Light Company
for an Increase in Electric Base Rates." Expert witness testimony on behalf of the Public Service
Commission Staff, 2018.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
9

AK RCA, Docket No. U-17-008, "In the Matter of the Tariff Revision Designated as TA326-121
Filed by the Municipality of Anchorage DB/A Municipal Light and Power Department." Expert
witness testimony on behalf of the Federal Executive Agencies, Dec. 2017.
NM PRC,Case No. 16-00276-UT, "In the matter of the Application of Public Service Company of
NM for revision of its Retail Electric Rates." Expert witness testimony on behalf of the City of
Albuquerque, 2017.
OK Corporation Commission, Cause No. PUD 201700151, "In the matter of Public Service
Company of OK Application for Adjustment in Rates."Expert witness testimony on behalf of the
Department of Defense, 2017.
AR PSC, Docket 16-052-U, "In the matter of the Application of Oklahoma Gas and Electric
Company for a General Change in Rates,Charges and Tariffs."Expert witness testimony on behalf
of the Arkansas River Valley Energy Consumers, 2017.
DE PSC,Docket 16-0649,"In the matter of the Application of Delmarva Power&Light Company
for an Increase in Electric Base Rates." Expert witness testimony on behalf of the Public Service
Commission Staff, 2016.
OK Corporation Commission, Cause No. PUD 201500208, "In the matter of Public Service
Company of OK Application for Adjustment in Rates."Expert witness testimony on behalf of the
Department of Defense, 2015.
AR PSC, Docket 15-015-U, "In the Matter of the Application of Entergy Arkansas, Inc. for
Approval of Changes in Rates for Retail Electric Service."Expert witness testimony on behalf ofthe
Hospitals and Higher Education Group, 2015.
CO PUC, Docket 14AL-0660E, "In the Matter of Advice Letter NO 1672-Electric Filed by Public
Service Company of Colorado PUC No. 7-Electric Tariff to Implement a General Rate Schedule
Adjustment and Other Rate Changes Effective July 18,2014."Expert witness testimony on behalf of
the Federal Executive Agencies, November 2014.
AK RCA, Docket No. U-13-184, "In the Matter of the Tariff Revision Designated as TA332-121
Filed by the Municipality of Anchorage DB/A Municipal Light and Power Department." Expert
witness testimony on behalf of the Federal Executive Agencies, May 2014.
AK RCA, Docket No. U-13-006, "In the Matter of the Tariff Revision Designated as TA326-121
Filed by the Municipality of Anchorage D/B/A Municipal Light and Power Department." Expert
witness testimony on behalf of the Federal Executive Agencies, October 2013.
AR PSC, Docket No. 13-028-U, "In the matter of the application of Entergy Arkansas, Inc. for
approval of changes in rates for retail electric service," expert witness testimony on behalf of
Hospitals and Higher Education Group, August 2013.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
10

AZ ACC, Docket No. E-01345A-11-0224, "In the matter of the application of Arizona Public
Service Company for a hearing to determine the fair value ofthe utility property ofthe company for
ratemaking purposes,to fix a just and reasonable rate of return thereon, to approve rate schedules
designed to develop such return," expert witness testimony on behalf of the Federal Executive
Agencies, January 2012.
NM PRC, Case No. 11-00265-UT, "In the matter of Public Service Company of NM's Renewable
Energy Portfolio Procurement Plan for 2012," direct and rebuttal testimony on renewable cost
threshold and related matters,on behalf of Public Service Company of New Mexico,October 2011.
AK RCA, Docket No. U-10-31, "In the Matter of the Revenue Requirement and Cost-of-Service
Studies Designated as TA304-121 and the Tariff Filing Designated as
TA306-121 and TA309-121 Filed by the MUNICIPALITY OF ANCHORAGE D/B/A
MUNICIPAL LIGHTAND POWER,"expert witness testimony on behalf ofthe Federal Executive
Agencies, prepared December 2010.
AR PSC, Docket No. 08-137-U, "In the Matter of the Consideration of Innovative Approaches to
Ratebase Rate of Return Ratemaking Including, but not Limited to, Annual Earnings Reviews,
Formula Rates, and Incentive Rates for Jurisdictional Electric and Natural Gas Utilities," expert
witness testimony responding to the mechanisms related to this docket, 2010.
CO PSC, Docket No. 1OM-245E, "In the Matter of Commission Consideration of Public Service
Company of Colorado Plan in Compliance with House Bill 10-1365, `Clean Air-Clean Jobs Act',"
expert witness testimony responding to the fundamental ratemaking issues regarding compliance
with the Clean Air-Clean Jobs Act, September 2010.
AR PSC, Docket No. 09-084-U, "In the Matter of the Application of Entergy Arkansas, Inc. for
Approval of Changes in Rates for Retail Electric Service,"expert witness testimony responding to
certain aspects of revenue requirement, cost-of-service, and rate design. Also, responding to the
proposed Formula Rate Plan,Lost Contributions to Fixed Costs,and the Shared Savings mechanism,
2010.
CO PSC, Docket No. 09AL-299E, "In the Matter of Advice Letter No. 1535 by Public Service
Company of Colorado to Revise Its Colorado PUC No. 7 Electric Tariff to Reflect Revised Rates
and Rate Schedules to be Effective on June 5, 2009," expert witness testimony responding to the
Phase II issues contained in the revised rate design on behalf of the Federal Executive Agencies,
December 2009.
CO PSC, Docket No. 09AL-299E, "In the Matter of Advice Letter No. 1535 by Public Service
Company of Colorado to Revise Its Colorado PUC No. 7 Electric Tariff to Reflect Revised Rates
and Rate Schedules to be Effective on June 5, 2009," expert witness testimony responding to the
Phase I issues contained in the proposed revenue requirements on behalf of the Federal Executive
Agencies, September 2009.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
11

NV PUC,Docket No. 08-12002,"Application of Nevada Power Company for authority to increase
its annual revenue requirement for general rates charged to all classes of customers to recover costs
of acquiring the Bighorn Power Plant, constructing the Clark Peakers, environmental retrofits, and
other generating,transmission,and distribution plant additions;to reflect changes in cost of service;
and for relief properly related thereto,"expert witness testimony responding to certain aspects of the
cost of service and rate design on behalf of The Board of Regents of the Nevada System of Higher
Education, April 2009.
AZ ACC, Docket No. E-01345A-08-0172, "In the Matter of the Application of Arizona Public
Service Company for a Hearing to Determine the Fair Value of the Utility Property ofthe Company
for Ratemaking Purposes,to Fix a Just and Reasonable Rate of Return Thereon, to Approve Rate
Schedules Designed to Develop Such Return," expert witness testimony responding to certain
aspects of the cost of service and rate design on behalf of the Federal Executive Agencies, January
2009.
FERC, Docket No. EL07-10 1-000, expert witness testimony assessing transmission rate design on
behalf of American Electric Power Service Corporation, August 2007.
MD PSC, Case No. 9092, "In the Matter of the Application of PEPCO for Authority to Revise
Rates," conducted training and provided advisory services to the Maryland Commissioners and
advisory staff(2007).
AR PSC, Docket No. 06-101-U, "In the Matter of the Application of Entergy Arkansas, Inc. for
Approval of Changes in Rates for Retail Electric Service," expert witness surrebuttal testimony
responding to the cost of service study used by EAI, Staff, and interveners on behalf of the Federal
Executive Agencies, March 2007.
Vermont Department of Public Service,Cost of Service analysis related to Green Mountain Power
Corp.
Philippines ERC, design of Open Access Distribution Services Rules, 2005.
Philippines Energy Regulatory Commission,Project Director and key advisor for over three years on
policy development related to industry restructuring and over 140 rate unbundling cases,2001-2005.
Philippines Department of Energy and Energy Regulatory Board, Electricity Ratemaking Training
and Rulemaking for Restructured Wholesale and Retail Electricity Industry(July 2000—February
2001).
TX PUC, Docket No. 22349, Application of TX-NM Power Company for approval of unbundled
cost of service rates (testimony filed). 1999-2000.
NV PUC,Docket No. 99-10049,Petition for Advisory Opinion,Rules that may or may not apply to
master-metered mobile home parks after restructuring of electric and natural gas markets,
(testimony), 1999.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
12

NV PUC,Docket No. 99-4019,Utility.com, Inc.,Application for Licensing as an Alternative Seller
(testimony), 1999.
NV PUC, Docket No.s 98-12007 and 12009, Sierra Pacific Power Co. And Nevada Power Co.
Applications for authorization to provide potentially competitive services through affiliates
(testimony), 1998.
NV PUC,Docket No. 98-7023, Sierra Pacific Power Company and Nevada Power Company,Joint
Application for Approval of Merger(testimony), 1998.
NV PUC, Docket No. 98-9038,Regulatory Operations Staff, Application to Designate Unbundled
Services as Potentially Competitive (testimony), 1998.
NV PUC, Docket No. 98-8034, Nevada Power Company, Application to Designate Unbundled
Services as Potentially Competitive (testimony), 1998.
NV PUC,Docket No. 97-10004,Nevada Power Company's Green Power Tariff(testimony), 1997.
NV PUC, Docket Nos. 97-11018 and 97-11028, Proposed Unbundling Methodologies of Sierra
Pacific Power Co. and Nevada Power Co. (testimonies), 1997.
NV PUC,Docket No. 97-8001,Investigation of issues to be considered as a result of restructuring of
electric industry (extensive comments and testimony on all restructuring issues including the
development of new regulations), 1997- 1999.
NV PUC, Docket No. 97-6008, Nevada Power Company's Resource Plan (evaluation of load
forecasting), 1997.
NV PUC, Docket No. 97-5034, Rulemaking to establish standards of conduct and related
requirements for distribution companies and affiliates, 1997.
NV PUC,Docket No. 96-7020,Nevada Power Company Deferred Energy Case(testimony), 1996.
NV PUC, Docket No. 96-6013 and 96-6014, Sierra Pacific Power Company tariff filing to allow
negotiated contracts (testimony), 1996.
NV PUC, Docket No. 95-9022, Nevada Electric Restructuring Investigation (several extensive
comments), 1996.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
13

:1 aturtil Gras and Water Distribution:
CT PURA,Docket No. 23-11-02, "Application of Connecticut Natural Gas Corporation to Amend
its Rate Schedules." Staff consultant advisor including delivery of discovery,cross examination,and
review of the record for decision making.
CT PURA,Docket No. 23-08-32, "Application of Connecticut Water Company to Amend its Rate
Schedules." Staff consultant advisor including delivery of discovery,cross examination,and review
of the record for decision making.
DE PSC Docket No. 23-0601, "IN THE MATTER OF THE APPLICATION OF ARTESIAN
WATER COMPANY, INC. FOR A REVISION OF RATES."Testimony on behalf of PSC Staff.
2024.
CT PURA, Docket No. 22-07-01, "Application of Aquarion Water Company of Connecticut to
Amend its Rate Schedules." Staff consultant advisor including discovery, delivery of cross
examination and review of the record for decision making.
Dvorak v. City of St. Paul, State of MN District Court, 2nd Judicial District, Court File No. 62-CV-
18-2356. Affidavits and Declarations on behalf ofthe plaintiff on matters pertaining to water utility
rate design and undue price discrimination, 2018-2019.
NM PRC,Case No. 18-00124-UT,"In the Matter ofthe Petition by EPCOR Water New Mexico Inc.
for Adjustment of Water Rates for its Clovis District."Expert witness work on behalf of the City of
Clovis, 2019.
AR PSC,Docket No. 15-098-U,"In the Matter ofthe Application of Centerpoint Energy Resources
Corp., d/b/a Centerpoint Energy Arkansas Gas,for a General Change or Modification in its Rates,
Charges and Tariffs."Expert witness testimony on behalf of the University of Arkansas, 2015-16.
AR PSC,Docket No. 15-011-U, "In the Matter of the Application of SourceGas Arkansas, Inc. for
Approval of a General Change in Rates and Tariffs." Expert witness testimony on behalf of the
University of Arkansas, 2015.
AR PSC, Docket No. 13-079-U, "In the Matter of the Application of SourceGas Arkansas Inc. for
Approval of a General Change in Rates."Expert witness testimony on behalf of the University of
Arkansas, May 2014.
NV PUC,Docket No. 12-11010,"Investigation and rulemaking to address a recovery mechanism for
the accelerated replacement of gas infrastructure."Expert witness testimony on behalf ofthe Federal
Executive Agencies, December 2012.
NM PRC, Case No. 11-00196-UT, "In the matter of the petition by New Mexico-American Water
Co.for adjustment of waxer razes for its Clovis District." Expert witness testimony on behalf of the
City of Clovis, November 2011.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
14

NM PRC, Case Nos. 11-00085-UT and 11-00293-UT,Acquisition and financing of NM American
Water Co.by EPCOR, Inc. Expert witness testimony on financing and customer hold-harmless on
behalf of the City of Clovis, July-August 2011.
NM PRC, Case No. 08-00134-UT,"In the Matter of the Petition by New Mexico-American Water
Company, Inc. for Adjustment of Water Rates for Its Clovis District," expert witness testimony
responding to revenue requirements and rate design in the petition to adjust water rates on behalf of
the City of Clovis, December 2008.
NM PRC, Case No. 08-00321-UT,"In the Matter of the Petition by New Mexico-American Water
Company,Inc. for a Certificate of Convenience and Necessity and Other Authorizations Related to
an Exploratory Test Well into the Lower Dockum Formation to Serve the Clovis District,"expert
witness testimony assessing accounting and regulatory treatment ofthe project costs associated with
the proposed exploratory test well into the lower Dockum Formation to serve the Clovis district of
New Mexico-American Water Company, Inc. ("NMAW"or"Company")on behalf of the City of
Clovis, March 2009.
NV PUC,Docket No. 97-8002,Investigation into alternative forms of regulation for natural gas local
distribution companies and alternative sellers of natural gas, and related matters (extensive
comments and testimony on all restructuring issues including the development of new regulations),
1997.
NV PUC, Docket No. 97-5034, Rulemaking to establish standards of conduct and related
requirements for distribution companies and affiliates, 1997.
Telecommunications:
NM PRC, Case No. 18-00295-UT, "In the Matter of the Petition of Centuryl-ink QC
Regarding Effective Competition for Retail Residential Services." Expert witness
testimony on behalf of the City of Albuquerque, 2019.
MT PSC, Docket No. D2005.6.105, Investigation on Use of Federal Universal Service Funds
(testimony filed on behalf of PSC advocacy staff), 2005.
NM PRC,Case No. 05-00094-UT,Qwest Corporation's Amended Alternative Form of Regulation
Plan, (testimony filed on behalf of Qwest regarding computation and appropriateness of refund),
2005.
Line Extension Policy and Contribution in Aid ofConstruction, expert witness work on behalf of 3
Rivers Telephone Cooperative, before the Montana Eighteenth Judicial District Court, Cause No.
DV-04-731, March 2006.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
15

NV PUC, Docket No. 00-7012, Nevada Bell Petition for order commencing a proceeding to
determine new costs and rates for unbundled network elements (testimony filed on behalf of
wholesale customers), 2000.
FCC CC Docket No. 00-247, Petition for Arbitration, Developed Unbundled Costs and
Interconnection Agreement on behalf of Virtual Hipster Corp., December 2000.
Case No. CV771923, Superior Court of the State of California(Santa Clara), Worldcom v. Co-net
Communications,Oral Expert Witness Testimony on potential service development including cost
and revenue estimates, damage estimate, standard of care in circuit disconnect, and other circuit
contractual issues (deposition and oral testimony), April 2000.
NV PUC,Docket Nos. 98-10015 and 99-11007,Nevada Bell Arbitrations on the issue of reciprocal
compensation and Internet service provider traffic, 1998.
NV PUC, Review of Interconnection and Resale Agreements between Incumbent Local Exchange
Carriers and Competitors for approval in Nevada.
NV PUC,Docket No. 98-6005, Sprint of Nevada,Unbundled Network Element Costs(testimony),
1998.
NV PUC,Docket No.98-6004,Nevada Bell,Unbundled Network Element Costs(testimony), 1998.
NV PUC, Docket No. 97-11017, Virtual Hipster Corp., Petition to terminate rural exemption of
Churchill County Telephone Company (testimony), 1997.
NV PUC, Docket No. 96-8035, GTE, Depreciation Filing(testimony), 1997.
NV PUC, Docket No. 97-5027, Central Telephone Company-Nevada, tariff filing requesting an
increase in directory assistance rates (testimony and cost analysis), 1997.
NV PUC,Docket No. 97-5018,Investigation into the impact of the Telecommunications Act of 1996
on Universal Service in Nevada(comments), 1997.
NV PUC,Docket No. 96-4041,Nevada Bell Petition on Confidential Nature of Telecommunications
Cost Studies (testimony filed), 1996.
NV PUC,Docket No. 96-9035,Investigation into Procedures and Methodologies to Develop Costs
for Bundled or Unbundled Telephone Services (comments,testimony and cost analysis), 1996.
NV PUC, Docket Nos. 96-3002 and 96-3003, Nevada Bell's Entry into a Plan of Alternative
Regulation(testimony), 1996.
Exhibit No. 501 (LB-1)
Larry Blank, DI
Federal Executive Agencies
16

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-24-07
OF IDAHO POWER COMPANY TO )
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ) CERTIFICATE OF SERVICE
ASSOCIATED WITH INCREMENTAL )
CAPITAL INVESTMENTS AND CERTAIN )
ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES )
I CERTIFY that on this date I sent by email a true and correct copy of THE DIRECT
TESTIMONY OF LARRY BLANK on behalf of the Federal Executive Agencies on the
parties of record to this proceeding.
DATED November 6, 2024.
61L A 11�I
Emily W. Medlyn
Attorney-Adviser
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
[e-mail]
I