20241127Mattew Larkin Rebuttal.pdf

RECEIVED
Wednesday, November 27, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-24-07
AUTHORITY TO INCREASE RATES FOR )
ELECTRIC SERVICE TO RECOVER )
COSTS ASSOCIATED WITH )
INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS )
AND MAINTENANCE EXPENSES . )
IDAHO POWER COMPANY
REBUTTAL TESTIMONY
OF
MATTHEW T . LARKIN

1 Q. Please state your name .
2 A. My name is Matthew T . Larkin.
3 Q. Are you the same Matthew T. Larkin that
4 previously presented direct testimony?
5 A. Yes .
6 Q. What is the purpose of your rebuttal
7 testimony?
8 A. The purpose of my rebuttal testimony is to
9 respond to the revenue requirement modifications proposed
10 by Idaho Public Utilities Commission ("Commission") Staff
11 ("Staff") and intervening parties in their direct testimony
12 filed on November 6, 2024 . Throughout this discussion I
13 detail which proposed modifications the Company finds
14 reasonable and which modifications the Company disagrees
15 with. My testimony concludes with a summary of the
16 Company' s revised revenue requirement that it believes, if
17 approved, would result in fair, just, and reasonable rates .
18 Q. How is your testimony organized?
19 A. The first part of my testimony is organized
20 into four sections that correspond to components of the
21 Company' s revenue requirement in this case: 1) rate base
22 methodology, 2) operations and maintenance ("O&M") labor
23 expense, 3) the revenue growth offset, and 4) capital
24 projects . Because multiple parties offered differing
25 recommendations for the various components of the Company' s
LARKIN, DI-REB 1
Idaho Power Company

1 filing, my testimony addresses each component of revenue
2 requirement rather than responding to each intervening
3 party' s position individually. My testimony concludes by
4 presenting the Company' s revised revenue requirement
5 proposal based on guidance I received from Mr. Timothy
6 Tatum and the adjustments discussed throughout my
7 testimony.
8 I . RATE BASE METHODOLOGY
9 Q. Please generally describe Idaho Power' s rate
10 base methodology as filed in this case.
11 A. As detailed in my direct testimony, rate base
12 in this filing was determined by projecting expected plant
13 closings through year-end 2024 in conjunction with a mid-
14 year accumulated depreciation convention. Depreciation
15 expense was determined by applying currently effective
16 annual depreciation rates to expected plant balances at
17 month-end December 2024 .
18 Q. Did Parties express concerns with this
19 approach?
20 A. Yes . Witnesses for Staff, Micron, the Idaho
21 Irrigation Pumpers Association ("IIPA") , and the Industrial
22 Customers of Idaho Power ("ICIP") expressed concerns with
23 Idaho Power' s filed methodology, proposing various
24 adjustments to reduce the Company' s filed rate base in this
25 case . Staff, Micron, and IIPA presented specific proposals
LARKIN, DI-REB 2
Idaho Power Company

1 to modify the Company' s rate base calculation, while ICIP
2 generally disagreed with the Company' s methodology but did
3 not propose a specific adjustment.
4 Q. What adjustments were proposed by Staff,
5 Micron, and IIPA?
6 A. Staff recommended the Commission adopt a
7 methodology using an average-monthly-average ("AMA")
8 approach applied to actual plant balances between August
9 31, 2023, and August 31, 2024 .' Micron was also in favor of
10 an AMA approach, utilizing a mid-year average convention to
11 estimate the impact to the Company' s test year.z IIPA
12 proposed to calculate rate base using the 13-month average
13 from December 2023 through December 2024 .3
14 Q. Does the Company' s revised revenue requirement
15 presented in your testimony incorporate any of these three
16 proposed methodologies?
17 A. No. At Mr. Tatum' s direction I did not
18 incorporate any of these adjustments . He addresses in his
19 testimony why the Company cannot support the methodologies
20 proposed by Staff, Micron, and IIPA in this area. Company
21 witness Mr. Brian R. Buckham also discusses why these
22 proposals are unworkable from a financial perspective .
1 Louis DI at 5, 11. 5-9.
2 Leyko DI at 10.
3 Kaufman DI at 10, 11. 2-3.
LARKIN, DI-REB 3
Idaho Power Company

1 Q. Is the Company willing to adopt any
2 modifications to rate base methodology as proposed by
3 parties?
4 A. Yes . In testimony, Micron witness James A.
5 Leyko offered an alternative solution if the Commission
6 chooses to reject Micron' s AMA recommendation. Mr. Leyko' s
7 alternative solution was to "... [use] year-end accumulated
8 depreciation and the year-end number of customers . 114
9 Q. Why is the Company willing to adopt this
10 adjustment?
11 A. Multiple parties expressed concern with the
12 perceived mismatch between the treatment of rate base,
13 expense, and revenue items in the Company' s initial filing.
14 Additionally, Order No. 35762 cited by Staff, Micron, and
15 ICIP as reason to reject Idaho Power' s proposed year-end
16 rate base treatment, states that "...it is unreasonable...to
17 allow full recovery of plant investment as if the plant has
18 been in operation the full year without a corresponding
19 adjustment to revenues and expenses. "5 The Company is
20 willing to adopt Micron' s proposal to utilize year-end
21 accumulated depreciations to bring all components of the
22 proposed revenue requirement to year-end 2024 values, thus
4 Leyko DI at 11, 11. 4-8.
5 Case No. VEO-W-22-02, Order No. 35762 at 23 (emphasis added) .
6 Mr. Leyko's recommendation regarding the use of year-end customer
counts is addressed later in my testimony.
LARKIN, DI-REB 4
Idaho Power Company

1 addressing the concerns raised by parties in this case and
2 the language in Commission Order No. 35762 .
3 Q. What is the revenue requirement impact of
4 moving to year-end accumulated depreciation?
5 A. Movement to year-end accumulated depreciation
6 results in a reduction to Idaho-allocated net rate base of
7 $29 . 81 million, which reduces the Company' s revenue
8 requirement by $2 . 91 million .
9 II . O&M LABOR EXPENSE
10 Q. Please generally describe the adjustments to
11 0&M labor expense proposed by parties .
12 A. Parties' proposals regarding O&M labor expense
13 were largely related to three items : removal of the 2025
14 general wage adjustment ("GWA") , updating the labor
15 calculation to reflect the most recent available actual
16 labor data, and removal of the Company' s proposed
17 annualizing adjustment.
18 Q. Please describe the proposals related to the
19 2025 GWA.
20 A. Witnesses for Staff,' Micron,$ and IIPA9 all
21 propose to remove the 2025 GWA in its entirety, generally
22 citing the view that this represents a future cost beyond
23 the 2024 test year that should not be allowed.
' Conilogue DI at 4, 11. 9-11.
8 Leyko DI at 4, 11. 4-5.
9 Kaufman DI at 11, 11. 6.
LARKIN, DI-REB 5
Idaho Power Company

1 Q. Is the Company willing to adopt this
2 adjustment?
3 A. No. The 2025 GWA becomes effective December
4 21, 2024, and reflects wage levels that will be in place at
5 the end of the 2024 test year. Similar to the treatment of
6 accumulated depreciation I just discussed, as well as test
7 year revenues and customer counts which I will discuss
8 later in my testimony, this amount is appropriately
9 included in customer rates by reflecting all components of
10 revenue requirement consistently as of year-end 2024 .
11 Q. Staff states that the 2025 GWA would not take
12 effect until several months after new rates will be in
13 effect from this case.10 Is that true?
14 A. No. The 2025 GWA will become effective
15 December 21, 2024 . The requested rate effective date in
16 this case is January 1, 2025 .
17 Q. Is the 2025 GWA known and measurable?
18 A. Yes . While the 2025 GWA was not publicly
19 announced at the time Staff filed testimony, on November
20 21, 2024, the IDACORP board of directors approved a 3
21 percent GWA effective December 21, 2024 . This confirms the
22 3 percent assumption utilized in this case.
io Conilogue DI at 4, 11. 15-19.
LARKIN, DI-REB 6
Idaho Power Company

1 Q. Does the 2025 GWA reflect a full forecast of
2 2025 labor costs?
3 A. No. While the 2025 GWA is a component of labor
4 costs that will exist commencing December 21, 2024, it does
5 not comprise a full forecast of 2025 labor. For example,
6 head count changes, benefit cost changes, and expected
7 merit salary increases in 2025 are not included in this
8 calculation.
9 Q. Please clarify what the 2025 GWA captures .
10 A. The 2025 GWA is the result of the Company' s
11 annual wage review. It is implemented each December to
12 account for multiple considerations such as employee
13 retention needs and inflation. Its inclusion in the
14 requested revenue requirement in this case is to ensure
15 labor costs included in rates align with expected year-end
16 costs as closely as possible.
17 Q. Does Staff' s proposed adjustment include more
18 recent actual labor data?
19 A. Yes . To determine expected 2024 test year
20 labor costs, Idaho Power' s filed case utilized payroll
21 figures as of February 2024, which at the time this filing
22 was prepared reflected the most recent cost information
23 available . Given the passage of time since the Company
24 first prepared its filing, additional actual labor data is
25 now available. Consequently, Staff proposed to update the
LARKIN, DI-REB 7
Idaho Power Company

1 Company' s calculation to reflect actual data through month-
2 end August 2024, the most recent month available when Staff
3 was preparing its testimony."
4 Q. Does Idaho Power agree with updating the
5 expected 0&M labor expenses to reflect the most recent
6 actual data available?
7 A. Yes . Idaho Power agrees with Staff' s principle
8 of adjusting the calculation for the most recent data
9 available . However, now that additional time has passed
10 since Staff prepared its testimony, the Company' s revised
11 revenue requirement reflects a recalculation of labor
12 utilizing actual data through month-end October 2024 .
13 Q. What is the revenue requirement impact of this
14 adjustment?
15 A. Incorporating actual 0&M labor data through
16 month-end October 2024 results in a reduction to the
17 Company' s filed 0&M labor expense of $2 . 3 million on an
18 Idaho jurisdictional basis . This revised calculation is
19 provided as Exhibit No. 12 to my revised testimony.
20 Q. Did Staff propose to make an adjustment to 0&M
21 labor related to the Company' s annualizing adjustment?
ii Conilogue DI at 3, 11. 15-17.
LARKIN, DI-REB 8
Idaho Power Company

1 A. Yes . Staff proposed to remove the Company' s
2 annualizing adjustment from its labor calculation due to a
3 perceived double counting, stating:
4 ...since Idaho Power is already
5 annualizing the 2024 payroll, there is no
6 need to add a 2023 annualizing
7 adjustment. The 2023 annualization on top
8 of the 2024 annualization could lead to
9 a double counting of payroll expense.12
10
11 Q. Does Idaho Power agree that this statement
12 accurately reflects its filed methodology?
13 A. No . Idaho Power appropriately applied a single
14 annualizing adjustment.
15 Q. Why do you believe Staff interpreted the
16 Company' s methodology as applying two annualizing
17 adjustments?
18 A. I believe Staff may have misinterpreted
19 certain figures included in the Company' s 0&M labor expense
20 calculation. Specifically, the Company' s 2024 projected
21 base labor cost prior to annualization was $198, 678, 494,
22 which was calculated by applying the three-year historical
23 relationship between February year-to-date labor costs
24 relative to full year non-annualized labor costs . This
25 calculation yields a non-annualized expectation for 2024
26 0&M labor expense that is referred to as the "2024
27 Projected Base" in my initial workpapers, now included as
12 Conilogue DI at 4, 11. 4-8.
LARKIN, DI-REB 9
Idaho Power Company

1 Exhibit No. 13 to my rebuttal testimony. In Staff' s
2 testimony, they refer to this figure as the Company' s
3 "annualized base, 1113 which I believe is the source of
4 misunderstanding and the logic behind Staff' s proposed
5 adjustment .
6 If Staff misinterpreted the 2024 Projected Base as
7 already including an annualization adjustment, it would
8 appear that the $1, 561, 952 annualization adjustment applied
9 later would double annualize the Company' s labor expense .
10 This is not the case. As shown in Exhibit No. 13, the
11 Company applied a single annualizing adjustment of
12 $1, 561, 952 to determine expected O&M labor expense as of
13 year-end 2024, therefore it would not be appropriate to
14 remove this amount from the Company' s test year.
15 III . REVENUE GROWTH OFFSET
16 Q. Please generally describe the intent of the
17 revenue growth offset.
18 A. As discussed in my direct testimony, the
19 revenue growth offset is intended to reflect incremental
20 collection of the revenue requirement components included
21 in this case since the conclusion of the Company' s 2023
22 General Rate Case in IPC-E-23-11 ("2023 GRC") due to sales
13 Conilogue DI at 6, 11. 2-3.
LARKIN, DI-REB 10
Idaho Power Company

1 growth. This adjustment serves as an offset to revenue
2 requirement .
3 Q. How is the revenue growth offset calculated?
4 A. To determine the revenue growth offset, Idaho
5 Power first calculated a mill rate reflecting the existing
6 cost recovery of capital-related items and O&M labor
7 expense currently embedded in rates . This mill rate was
8 then applied to estimated sales growth between the
9 stipulated results of the 2023 GRC and the 2024 test year
10 utilized in this case.
11 Q. After reviewing parties' testimonies, is Idaho
12 Power proposing any adjustments to its sales forecast
13 methodology that would impact the determination of the
14 revenue growth offset?
15 A. Yes . Idaho Power is proposing two
16 modifications to its sales forecast based on
17 recommendations made by parties . The first is related to
18 updating the 2024 test year to reflect the most recent
19 actual data available, and the second is related to the
20 annualization of customer counts as of year-end 2024 .
21 Q. Please describe the adjustment related to
22 incorporating the most recent actual data available .
23 A. Staff Witness Mr. Michael Eldred proposed an
24 adjustment to test year kilowatt-hour ("kWh") sales to
25 incorporate actual normalized data from January 2024
LARKIN, DI-REB 11
Idaho Power Company

1 through August 2024, which reflects the most recent actual
2 data available at the time Staff prepared its testimony.
3 Mr. Eldred then proposed to compare those values to the
4 same time period from the stipulated 2023 GRC test year and
5 apply the proportional difference to the Company' s 2024
6 test year to recalculate expected 2024 kWh sales .14
7 Q. Does Idaho Power generally agree with this
8 approach?
9 A. Yes . Similar to the update to 0&M labor
10 expense discussed earlier in my testimony, the Company
11 agrees with Staff' s proposal to incorporate the most
12 recently available data into its expectation for 2024 .
13 Therefore, Idaho Power proposes to utilize actual
14 normalized data from January 2024 through September 2024 to
15 implement the methodology proposed by Mr. Eldred.15
16 Q. What is the impact of this adjustment?
17 A. Incorporating actual normalized sales data
18 through September 2024 and applying Staff' s method to
19 estimate October through December 2024 results in an
20 increase in the Company' s kWh sales forecast of 6, 428, 468
21 kWh compared to the as-filed sales forecast. The resulting
14 Eldred DI at 4, 11. 9-16.
is For the O&M adjustment, the most recent data available reflects
month-end October 2024. For kWh sales, however, the weather
normalization process requires additional time to prepare after the
close of a month. Therefore, the most recent normalized kWh sales
figures at the time of this filing are through month-end September
2024.
LARKIN, DI-REB 12
Idaho Power Company

1 2024 test year incremental sales under this methodology is
2 131, 152, 938 kWh. When incorporated into the revenue growth
3 offset calculation, this increases the proposed revenue
4 requirement adjustment from $5 . 5 million to $5 . 8 million.
5 Exhibit No . 14 to my rebuttal testimony provides the
6 details supporting this calculation.
7 Q. What proposals did parties make with regard
8 to revenue annualization?
9 A. Both Micron and IIPA discussed the need to
10 annualize year-end 2024 customer counts if the Commission
11 were to allow the use of year-end rate base.16 My
12 understanding of the logic presented in their testimonies
13 is that if other components of the revenue requirement
14 calculation - i .e. , rate base, labor, and depreciation
15 expense - reflect year-end 2024 amounts, then customer
16 counts utilized in the determination of the revenue growth
17 offset should be afforded consistent treatment.
18 Q. Do you believe the customer count
19 annualization arguments offered by IIPA and Micron are
20 reasonable?
21 A. Yes . I believe it is reasonable to annualize
22 customer counts to improve consistency between the
23 determination of the revenue growth offset and other
16 Leyko DI at 11, 11. 4-8; Kaufman DI at 12, 11. 12-14.
LARKIN, DI-REB 13
Idaho Power Company

1 components of revenue requirement when utilizing a year-end
2 measure of rate base.
3 Q. Is the Company proposing to further adjust the
4 revenue growth offset based on this assumption?
5 A. Yes .
6 Q. How did the Company calculate its proposed
7 revenue annualization adjustment?
8 A. Idaho Power first calculated the expected use
9 per customer based on the revised kWh forecast
10 incorporating the previously described adjustment proposed
11 by Staff. This calculation was performed on a monthly basis
12 to capture seasonal variance in use-per-customer. The
13 Company then applied these monthly use-per-customer values
14 to year-end customer counts to determine what sales would
15 have been had year-end customer levels existed throughout
16 the entire year.
17 Q. Was an annualization adjustment applied to all
18 rate classes?
19 A. No. An annualization adjustment was not
20 applied to the irrigation class because year-end customer
21 counts for this class are typically less than in-season
22 customer counts due to some irrigation customers closing
23 their accounts in the off-season.
24 Q. What is the revenue requirement impact of the
25 revenue annualization adjustment?
LARKIN, DI-REB 14
Idaho Power Company

1 A. As shown in Exhibit No . 14, this adjustment
2 increases the sales forecast by an additional 152, 288, 553
3 kWh, resulting in a corresponding $6 . 7 million increase in
4 the revenue growth offset.
5 Q. Did parties propose any other adjustments to
6 the revenue growth offset methodology?
7 A. Yes . IIPA witness Dr. Lance Kaufman expressed
8 concern with the use of a system mill rate as opposed to a
9 class-specific mill rate. In his testimony he recommended
10 "...that incremental revenue be determined by schedule load
11 changes rather than system average load changes . ""
12 Q. Does Idaho Power believe Dr. Kaufman' s
13 proposal is reasonable?
14 A. Yes . While the Company believes its initial
15 filed approach to the revenue growth offset calculation was
16 reasonable, it is not opposed to utilizing a more granular
17 class-based approach as proposed by Dr. Kaufman.
18 Q. Has the Company modified its requested revenue
19 requirement to reflect a more granular class-based approach
20 in light of IIPA' s suggestion?
21 A. Yes . As detailed in Exhibit No . 14, Idaho
22 Power utilized the same general methodology described in my
23 direct testimony but determined class-specific mill rates
17 Kaufman DI at 15, 11. 7-8.
LARKIN, DI-REB 15
Idaho Power Company

1 of existing recovery, which were then applied to class-
2 specific kWh sales changes between the stipulated 2023 GRC
3 results and the 2024 test year to determine the total
4 amount of the revenue growth offset.
5 Q. What is the impact of modifying the revenue
6 growth offset to reflect a class-specific approach?
7 A. Modifying the revenue growth offset to apply a
8 class-specific approach results in an increase to the
9 revenue growth offset of $2 . 7 million. Mr. Grant Anderson
10 explains how the Company proposes to apportion this amount
11 to customer classes .
12 Q. Did parties propose any adjustments to the
13 revenue growth offset that the Company is unwilling to
14 adopt?
15 A. Yes . As discussed previously, the mill rate
16 utilized to determine the revenue growth offset reflected
17 existing recovery of revenue requirement components
18 included in this case, i .e. , capital and 0&M labor expense .
19 Micron asserts that the mill rate should include the
20 Company' s full retail rate excluding net power supply
21 expenses .18
22 Q. Do you agree with this assertion?
18 Leyko DI at 15, 11. 14-16.
LARKIN, DI-REB 16
Idaho Power Company

1 A. No. As discussed in Mr. Tatum' s direct
2 testimony, the Company' s approach in this limited scope
3 case is to focus on specific components of revenue
4 requirement to ensure the financial health of Idaho Power
5 while mitigating upward rate pressure . To achieve this,
6 Idaho Power' s request does not include any incremental
7 costs aside from those related to capital items and 0&M
8 labor expense. Incorporating these items into a revenue
9 growth offset without incorporating the corresponding
10 increases in costs would be inconsistent and unduly reduce
11 Idaho Power' s revenue requirement in this case.
12 Q. Please summarize the Company' s revised
13 proposal for the revenue growth offset as detailed in your
14 testimony.
15 A. The Company believes it is reasonable to
16 increase the revenue growth offset from the filed $5 . 5
17 million to $15 . 2 million. First, the Company agrees with
18 Staff witness Mr. Eldred that it is reasonable to update
19 sales to incorporate the most recent data available . The
20 Company also agrees that it is reasonable to further adjust
21 this amount to apply an annualizing adjustment to reflect
22 customer levels as of year-end 2024 . Lastly, the Company
23 believes it is reasonable to apply a class-specific mill
24 rate calculation to the adjusted expectation of sales
25 growth. Exhibit No. 14 details each of the three
LARKIN, DI-REB 17
Idaho Power Company

1 adjustments Idaho Power has incorporated into its revised
2 revenue requirement, as well as the final revenue growth
3 offset the Company is proposing in this case.
4 IV. CAPITAL-RELATED ADJUSTMENTS
5 Q. Did any party propose adjustments to Idaho
6 Power' s revenue requirement related to specific capital
7 projects?
8 A. Yes . Staff witnesses Kimberly Loskot and Jason
9 Talford proposed adjustments based on a number of capital
10 projects included for recovery in the Company' s case . Mr.
11 Talford' s testimony focused on the Company' s investments in
12 battery energy storage system ("BESS") projects, while Ms .
13 Loskot' s testimony addressed various other capital projects
14 included in the Company' s rate base .
15 Q. Does Idaho Power' s revised revenue requirement
16 include any adjustments related to Mr. Talford' s testimony?
17 A. No. Company witness Mr. Eric Hackett responds
18 to Mr. Talford' s testimony and supports why the Company
19 does not believe any adjustment is warranted in this area.
20 Q. Which capital projects did Ms . Loskot propose
21 to adjust?
22 A. On page 2 of her testimony, Ms . Loskot lists
23 seven projects for which she proposed adjustments : 1) Grid
24 Modernization, 2) Itron Enterprise Edition ("IEE") License
25 Expansion 2024, 3) Outage Alert Auto Enrollment, 4)
LARKIN, DI-REB 18
Idaho Power Company

1 SharePoint 2024 Development, 5) Non-Criteria Based
2 Equipment, 6) Conference Room Furniture at the Company' s
3 Corporate Headquarters ("CHQ") , and 7) investments in
4 trailers and mobile housing for Company employees .
5 Q. Does Idaho Power' s revised revenue requirement
6 incorporate any of the adjustments proposed by Ms . Loskot?
7 A. Yes . Idaho Power' s revised revenue requirement
8 reflects two of the proposed seven adjustments : the removal
9 of revenue requirement associated with the IEE License
10 Expansion 2024 and CHQ Conference Room Furniture .
11 Q. What is the Company' s position with regard to
12 the CHQ Conference Room Furniture addressed by Staff?
13 A. While I am not the Company' s expert in the
14 replacement and procurement of conference room furniture,
15 it is reasonable to assume that office furniture is a
16 necessary and prudent cost of business . However, the
17 documentation cited by Ms . Loskot in her testimony
18 indicated that the specific furniture in question was
19 purchased for aesthetic reasons . 19 While in actuality Idaho
20 Power replaced this furniture because it was dilapidated
21 and over twenty years old, the Company believes it is
22 reasonable to remove these specific costs from this case
19 Loskot DI at 9, 11. 11-14.
LARKIN, DI-REB 19
Idaho Power Company

1 due to the documentation of business need provided to Staff
2 through discovery.
3 Q. What is the Company' s position with regard to
4 the IEE License Expansion 2024?
5 A. In consultation with the Company' s Information
6 Technology ("IT") department, it is my understanding that
7 the IEE License Expansion 2024 comprises a specific number
8 of licenses purchased by Idaho Power, some of which are
9 currently in use and some of which are not in use but are
10 expected to be utilized in the future . While Idaho Power
11 believes its actions in procuring these licenses were
12 prudent, it acknowledges that not all of the licenses are
13 currently used and useful . Rather than attempting to
14 quantify the number of licenses currently used as compared
15 to those that will be used in the future, the Company is
16 willing to remove the entirety of these costs from its
17 request in this case.
18 Q. Is Idaho Power willing to adopt the remaining
19 five adjustments recommended by Ms . Loskot?
20 A. No. Company witness Mr. Mitch Colburn details
21 the Company' s support for including the remaining five
22 items in revenue requirement as filed.
23 Q. Are there any other adjustments presented in
24 Ms . Loskot' s testimony you would like to address?
LARKIN, DI-REB 20
Idaho Power Company

1 A. Yes . Within her discussion of the trailers and
2 mobile housing, Ms . Loskot provides an alternative to the
3 Commission if it deems it prudent to include the costs of
4 temporary housing in this case, indicating "... a
5 corresponding adjustment to impute rent revenue should be
6 made . "20 While Company witness Mr. Colburn explains in his
7 rebuttal testimony why the Company believes these costs are
8 appropriate for rate base treatment, should the Commission
9 disagree and not approve the Company' s proposed rate base
10 treatment of these expenditures, Idaho Power believes the
11 approach proposed by Ms . Loskot should be applied. The
12 inclusion of an imputed revenue amount commensurate with
13 the revenue requirement associated with these investments
14 would effectively remove these costs from customer rates .
15 Q. Are there any additional adjustments Idaho
16 Power is proposing to make to the capital projects included
17 in revenue requirement in this case?
18 A. Yes . As Company witness Mr. Colburn discusses
19 in his testimony, the Wood River Valley ("WRV")
20 distribution line included in the Company' s initial filing
21 is no longer expected to be in-service in 2024 . Therefore,
22 the Company has removed project costs of $11 . 8 million from
23 its request in this case.
20 Loskot DI at 11, 11. 1-4.
LARKIN, DI-REB 21
Idaho Power Company

1 Q. What is the total impact of the capital
2 project-related adjustments Idaho Power incorporated into
3 its revised revenue requirement?
4 A. The total impact of removing the IEE License
5 Expansion 2024, the CHQ Conference Room Furniture, and the
6 WRV line from rate base is a $1 . 1 million reduction to
7 Idaho-allocated revenue requirement .
8 V. CONCLUSION
9 Q. Please summarize your rebuttal testimony.
10 A. Idaho Power appreciates the thorough review
11 performed by parties in this case and the positions offered
12 in their direct testimonies . After reviewing the positions
13 of parties and considering the Company' s request for year-
14 end rate base treatment, Idaho Power believes that certain
15 adjustments proposed by parties are reasonable in the areas
16 of 0&M labor expense, the calculation of the revenue growth
17 offset, and capital projects included in the Company' s rate
18 base .
19 Idaho Power' s adoption of certain direct testimony
20 party recommendations in the development of this revised
21 revenue requirement serves to address parties' concerns
22 regarding the mismatch between the treatment of the various
23 revenue requirement components in this case, moving all
24 components of revenue requirement to year-end 2024 values .
25 Idaho Power believes these adjustments reasonably address
LARKIN, DI-REB 22
Idaho Power Company

1 the concerns raised by parties in this case and the
2 language in Commission Order No. 35762 .
3 The following table summarizes the adjustments that
4 comprise Idaho Power' s revised revenue requirement in light
5 of these adjustments :
6 Table 1
7 Revised Revenue Requirement Proposal ($M)
Filed Rate Increase $99.3
Year-End Accumulated Depreciation ($2 . 9)
0&M Labor Adjustment ($2 . 3)
Revenue Growth Offset Adjustments ($9 . 7)
Capital Project Adjustments ($1 . 1)
Revised Rate Increase $83 .2
8
9 Q. Does this conclude your testimony?
10 A. Yes, it does .
11
LARKIN, DI-REB 23
Idaho Power Company

1 DECLARATION OF MATTHEW T. LARKIN
2 I, Matthew T . Larkin, declare under penalty of
3 perjury under the laws of the state of Idaho:
4 1 . My name is Matthew T. Larkin.
5 2 . On behalf of Idaho Power, I present this
6 pre-filed rebuttal testimony in this matter.
7 3 . To the best of my knowledge, my pre-filed
8 rebuttal testimony is true and accurate.
9 I hereby declare that the above statement is true to
10 the best of my knowledge and belief, and that I understand
11 it is made for use as evidence before the Idaho Public
12 Utilities Commission and is subject to penalty for perjury.
13 SIGNED this 27th day of November 2024, at Boise,
14 Idaho .
15
16 Signed:
17 MATTHEW T . LARKIN
18
19
20
21
22
LARKIN, DI-REB 24
Idaho Power Company

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-07
IDAHO POWER COMPANY
LARKIN , DI-REB
TESTIMONY
EXHIBIT NO. 12

Larkin Exhibit 12-2024 O&M Labor Recalculation
IDAHO POWER COMPANY
Revised O&M Labor utilizing October 2024 Year-to-Date
Year to Date(YTD)Payroll as%of Total Year
(2021 thru 2023)
2021 2022 2023 3 Yr Total 3yr Avg%
Jan 13,580,316 13,515,715 15,254,456 42,350,487 1 8.4%
Feb 12,480,722 13,673,027 15,413,478 41,567,226 16.7%
Mar 13,930,240 14,822,019 16,465,862 45,218,121 25.7%
Apr 13,167,461 13,376,578 14,290,014 40,834,053 33.8%
May 12,417,933 13,813,719 15,918,099 42,149,751 42.2%
Jun 13,041,800 13,459,770 14,616,382 41,117,952174.7%
50.4%
Jul 13,235,366 12,816,103 13,945,783 39,997,25258.3%
Aug 12,604,445 14,414,850 15,101,558 42,120,85266.7%
Sep 11,399,600 14,123,087 14,595,216 40,117,903
Oct 13,038,751 13,510,332 14,826,111 41,375,194 82.9%
Nov 12,866,656 13,889,919 14,156,630 40,913,205 91.1%
Dec 14,210,778 15,473,323 15,128,897 44,812,998 100.00%
155,974,068 166,888,441 179,712,486 502,574,994
Revised Request using YTD October 2024
Oct YTD 162,754,950
3yr Avg% 82.9%
2024 projected Base 196,225,993
Less: Mid Year 2%GWA 3,507,696
2024 projected Labor 192,718,297
Original Filed Request using YTD February 2024
2024 projected Base 198,678,494
Less: Mid Year 2%GWA 3,507,696
2024 projected Labor 195,170,798
Revenue Requirement Adjustment (2,452,502)
Exhibit No. 12
Case No. IPC-E-24-07
M.Larkin, IPC
Page 1 of 1

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-07
IDAHO POWER COMPANY
LARKIN , DI-REB
TESTIMONY
EXHIBIT NO. 13

Larkin Exhibit 13- 2024 O&M Labor Filed Calculation.xlsx
O&M Labor
Year to Date Payroll as % of Total Year
(2021 thru 2023)
2021 2022 2023 3 Yr Total 3yr Avg % 2024 Payroll
Jan 13,580,316 13,515,715 15,254,456 42,350,487 8.4% 17,043,196
Feb 12,480,722 13,673,027 15,413,478 41,567,226 16.7% 16,131,245
Mar 13,930,240 14,822,019 16,465,862 45,218,121 25.7%
Apr 13,167,461 13,376,578 14,290,014 40,834,053 33.8%
May 12,417,933 13,813,719 15,918,099 42,149,751 42.2%
Jun 13,041,800 13,459,770 14,616,382 41,117,952 50.4%
Jul 13,235,366 12,816,103 13,945,783 39,997,252 58.3%
Aug 12,604,445 14,414,850 15,101,558 42,120,852 66.7%
Sep 11,399,600 14,123,087 14,595,216 40,117,903 74.7%
Oct 13,038,751 13,510,332 14,826,111 41,375,194 82.9%
Nov 12,866,656 13,889,919 14,156,630 40,913,205 91.1%
Dec 14,210,778 15,473,323 15,128,897 44,812,998 100.00%
155,974,068 166,888,441 179,712,486 502,574,994 Feb YTD 33,174,442
3yr Avg % 16.7%
2024 projected Base 198,678,494
Less: Mid Year 2% GWA 3,507,696
2024 projected Labor 195,170,798
Annualizing adjustment 1,561,952
Proposed 2025 GWA @ 3% 5,901,982
Incentive 10,845,454
Total O&M Labor Forecast 213,480,186
Exhibit No. 13
Case No. IPC-E-24-07
M. Larkin, IPC
Page 1 of 1

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-07
IDAHO POWER COMPANY
CONFIDENTIAL
LARKIN , DI-REB
TESTIMONY
EXHIBIT NO. 14