20241127Mitch Colburn 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
MITCH COLBURN

1 Q. Please state your name .
2 A. My name is Mitch Colburn.
3 Q. Are you the same Mitch Colburn that previously
4 presented direct testimony?
5 A. Yes .
6 Q. Have you had the opportunity to review the
7 pre-filed direct testimony of Idaho Public Utilities
8 Commission ("Commission") Staff ("Staff") witness Ms .
9 Kimberly Loskot?
10 A. Yes, I have .
11 Q. What is the purpose of your rebuttal
12 testimony?
13 A. The purpose of my rebuttal testimony is to
14 provide an update on the status of the distribution portion
15 of the Wood River Valley Reliability Project ("WRV
16 Project") and respond to the transmission and distribution-
17 related project cost adjustments proposed by Idaho Public
18 Utilities Commission Staff witness Ms . Loskot in her direct
19 testimony, including the single vendor platform project
20 resulting from the grid modernization initiative and a
21 variety of other individual projects .
22 I . WOOD RIVER VALLEY RELIABILITY PROJECT
23 Q. What is the status of the WRV Project for
24 which the distribution undergrounding work was anticipated
COLBURN, DI-REB 1
Idaho Power Company

1 to be complete by November 2024 and incremental project
2 costs were included in the Company' s request in this case?
3 A. As described in Idaho Power' s Motion to
4 Suspend Procedural Schedule filed on October 16, 2024, in
5 Case No . IPC-E-24-22, 1 the Company' s compliance filing to
6 update the previously approved customer surcharge to
7 collect the incremental costs associated with the
8 distribution undergrounding of the new 138-kilovolt
9 transmission line in the Wood River Valley, due to
10 circumstances outside of the Company' s control, the
11 distribution line will not be fully completed and energized
12 by November 2024 . As a result, Idaho Power requested the
13 Commission suspend the procedural schedule in Case No. IPC-
14 E-24-22 until such time as the distribution line completion
15 and energization is reasonably anticipated to occur.
16 Q. Is the Company recommending any adjustments to
17 the proposed WRV Project costs included in the request in
18 this proceeding?
19 A. Yes . Because the distribution undergrounding
20 portion of the WRV Project is not expected to be fully
21 completed and energized in 2024, and as mentioned in Mr.
22 Larkin' s direct testimony, Idaho Power has removed the
1 In the Matter of Idaho Power Company's Compliance Filing to Update the
Customer Surcharge to Collect Incremental Costs of Distribution
Undergrounding of the New 138 KV Transmission Line in the Wood River
Valley and Establish Necessary Regulatory Accounting Treatment.
COLBURN, DI-REB 2
Idaho Power Company

1 $11 . 8 million in forecasted project costs from the request
2 in this case.
3 II . GRID MODERNIZATION INVESTMENT
4 Q. In her testimony, Staff witness Ms . Loskot
5 indicates uncertainty regarding the completion of the first
6 phase of the single vendor platform project, a project
7 resulting from Idaho Power' s grid modernization initiative .2
8 Has the first phase of the single vendor platform project
9 been completed?
10 A. Yes . The first phase of the single vendor
11 platform system went live on November 6, 2024, just one
12 week later than initially anticipated. The investments in
13 distribution management technologies as part of grid
14 modernization are laying a foundation for a platform that
15 will provide significant enhancements in modeling, control,
16 and system awareness needed to support the grid. This first
17 phase of the single vendor platform project included the
18 set-up of an Energy Management System ("EMS") /Supervisory
19 Control and Data Acquisition ("SCADA") system to replace
20 the existing EMS system, and set up a base SCADA model,
21 providing a foundation for subsequent phases of the single
22 vendor platform project to be built.
2 Loskot DI at 3, 11. 23-25.
COLBURN, DI-REB 3
Idaho Power Company

1 Q. Can you demonstrate the new EMS/SCADA system
2 is used and useful following replacement in November 2024?
3 A. As the system that controls all the Company' s
4 generating units, transmission assets and distribution
5 feeder relays, monitoring the energy flowing across Idaho
6 Power' s network, the EMS/SCADA is critical to maintaining
7 reliable electric service within Idaho Power' s service
8 territory and the bulk electric system. Absent an
9 operational EMS/SCADA system, the Company would be unable
10 to serve its customers . On November 6, 2024, both Idaho
11 Power and the EMS/SCADA system vendor signed the Cutover
12 Certificate, included as Exhibit No. 18, acknowledging
13 replacement has been completed and the new system is fully
14 operational .
15 Q. In her testimony, Ms . Loskot states that if
16 the Commission allows recovery of the single vendor
17 platform project, a corresponding adjustment to reduce
18 operations and maintenance ("O&M") expense by $3 million
19 should be made.3 Do you agree with this adjustment?
20 A. No. Ms . Loskot' s recommendation is based on
21 the Company' s business case analysis, which reflects
22 anticipated revenue requirement savings of approximately $3
23 million on a net present value basis resulting from
3 Loskot DI at 4, 11. 7-10.
COLBURN, DI-REB 4
Idaho Power Company

1 implementation of all three phases of the single vendor
2 platform project, not just the first phase included in the
3 Company' s request in this case. In addition, the savings
4 were based on the 15-year life of the software, not annual
5 savings as suggested by Ms . Loskot. Thus, the proposal to
6 adjust 0&M expenses by $3 million is significantly
7 overstated. Moreover, an adjustment to non-labor 0&M
8 expenses is out of the scope of Idaho Power' s request in
9 this case, as discussed in the Direct Testimony of Mr.
10 Tatum4.
11 Q. Is it appropriate to include the single vendor
12 platform project costs in the Company' s request in this
13 proceeding?
14 A. Yes . The replacement and modernization of
15 the EMS/SCADA system is critical to maintaining reliability
16 of the Company' s electrical grid; the replacement EMS/SCADA
17 system is used and useful while also laying the foundation
18 for improved reliability for customers in the future and
19 therefore is a prudent investment that is appropriately
20 included in the request in this case .
21
4 Tatum DI at 9, 11. 13-17.
COLBURN, DI-REB 5
Idaho Power Company

1 III . OTHER INVESTMENTS
2 Q. Are there any additional capital projects
3 adjustments proposed by Ms . Loskot that you would like to
4 address?
5 A. Yes . I am going to provide additional support
6 for the Company' s prudent investment in the following
7 capital projects : (1) Outage Alert Auto Enrollment, (2)
8 SharePoint 2024, (3) Non-Criteria Based Equipment, and (4)
9 the trailer and mobile housing purchases .
10 Outage Alert Auto Enrollment
11 Q. What was the purpose of the Outage Alert Auto
12 Enrollment project?
13 A. Idaho Power is focused on continually
14 improving the customer experience and recent customer
15 feedback, survey results, research, and benchmarking
16 consistently indicated a need to increase outage-related
17 communication. Customers are asking to receive consistent
18 and timely updates on outages . The Outage Alert Auto
19 Enrollment project was the result of that feedback and is
20 intended to improve customer experience. Previously,
21 customers were only able to enroll in outage alerts through
22 the Company' s My Account web and mobile applications . The
23 project allowed for the auto enrolling of all qualifying
24 residential customers, those customers with a mobile phone
25 or email address on file that had not previously opted out,
COLBURN, DI-REB 6
Idaho Power Company

1 in automated outage alerts . The efforts enabled the Company
2 to reach customers that do not generally interact with the
3 web or mobile application and/or do not proactively manage
4 their alert preferences through these channels .
5 Q. Did the project help facilitate public safety
6 notifications such as Public Safety Power Shutoff ("PSPS")
7 event notifications?
8 A. Yes, the need to provide public safety
9 notifications was one of the drivers of the Outage Alert
10 Auto Enrollment project. Idaho Power' s proactive de-
ll energization notifications during a PSPS event can now
12 reach a larger customer base, which is critical to keeping
13 customers informed and communities safe.
14 Q. How many customers was Idaho Power able to
15 reach through the Outage Alert Auto Enrollment project?
16 A. The Company' s efforts increased the number of
17 customers receiving outage alerts by 473, 000, or 850
18 percent. Of the approximately 536, 000 customers now
19 enrolled, over 187, 000 have been impacted by an outage and
20 received associated alerts since being auto enrolled.
21 Q. What work was required to enable auto
22 enrollment of outage alerts in Idaho Power' s systems?
23 A. Enabling the ability to enroll customers
24 without a My Account profile required: (1) a re-design of
25 the underlying data structure, (2) conversion of existing
COLBURN, DI-REB 7
Idaho Power Company

I data to the new database structure, (3) development of new
2 alerts for all existing alerts including outage, payment,
3 past due, and bill threshold alerts, (4) changes to the My
4 Account web and mobile applications, (5) development of an
5 internal application to provide Customer Service
6 Representatives the ability to manage customer contact,
7 preference, and enrollment information, (6) scaling and
8 tuning of enterprise messaging services to ensure message
9 delivery met performance requirements, and (7) testing and
10 implementation of the previously referenced changes . Idaho
11 Power is now able to distribute email notifications, Short
12 Message Services ("SMS") text notifications, and push
13 notifications through the system created by the Outage
14 Alert Auto Enrollment project, informing customers of
15 outages and associated status, cause, estimated time of
16 restoration, and restoration.
17 Q. In her direct testimony, Staff witness Ms .
18 Loskot indicates the project is redundant and imprudent.5 Do
19 you agree with this assessment?
20 A. No. Ms . Loskot indicates that outage-related
21 notifications are currently available through a variety of
22 systems and that self-enrollment can take place through
23 MyAccount and the Outage Maps Notifications systems While
5 Loskot DI at 6, 11. 4-6.
6 Loskot DI at 6, 11. 6-7 .
COLBURN, DI-REB 8
Idaho Power Company

1 not entirely incorrect,' the Company' s concern was the
2 efficacy of the available options, the inadequacy of which
3 was demonstrated by the low level of enrollment that was
4 occurring prior to the Outage Alert Auto Enrollment
5 project. The 850 percent increase in customers the Company
6 was able to reach through the Outage Alert Auto Enrollment
7 project illustrates the project was necessary to enable
8 Idaho Power to reach a broader customer base to inform them
9 of information critical to the delivery of safe and
10 reliable electric service .
11 SharePoint 2024 Development
12 Q. Do you agree with Staff witness Ms . Loskot' s
13 assessment that the SharePoint 2024 Development project is
14 not used and useful?8
15 A. No. The Company is transitioning from the
16 existing SharePoint 2016 to SharePoint Online due to the
17 existing SharePoint software' s upcoming end-of-life in
18 2026 . The transition began in 2024 and will take over two
19 years to complete. However, the Company' s request in this
20 case only includes costs for those components of the
21 SharePoint 2024 Development project placed in service in
22 2024 and are therefore used and useful .
' Phase 2 of the Single Vendor Platform grid modernization project will
allow for the sending of automated notifications but will not
facilitate auto enrollment.
8 Loskot DI at 7, 11. 3-6.
COLBURN, DI-REB 9
Idaho Power Company

1 Q. What is Idaho Power' s primary use for
2 SharePoint Online?
3 A. SharePoint Online is in use as the Company' s
4 main intranet site and to date, heavily used sites
5 including Human Resources, Information Technology, and
6 Corporate Services have been moved to SharePoint Online .
7 Q. Have all the Company' s sites been transitioned
8 to the main intranet site contained on SharePoint Online?
9 A. No. However, because the project will span
10 multiple years to complete, multiple work orders associated
11 with the SharePoint 2024 Development project were created.
12 A work order, which includes project costs associated with
13 one component of the project, is typically placed in-
14 service when work has been completed and the associated
15 assets are used and useful . Projects may have multiple in-
16 service dates, as significant portions of the project might
17 be completed and go live at different times . Therefore,
18 separate work orders are created for each phase of the
19 project as a single work order can only have one in-service
20 date . Similar to the rebuild of a transmission line that
21 occurs in phases as I discussed in my direct testimony, the
22 transition to SharePoint Online will occur in phases .
23 Q. Which SharePoint 2024 Development project
24 costs were placed in-service in 2024?
COLBURN, DI-REB 10
Idaho Power Company

1 A. The work order associated with the SharePoint
2 2024 Development project that was placed in-service is
3 comprised of costs associated with the labor necessary to
4 build the new SharePoint sites, testing of every new
5 SharePoint site, and the rebuilding and testing of
6 workflows to ensure proper functionality. The work
7 completed has been the environment configuration of
8 SharePoint Online in the Microsoft tenant, where data and
9 configurations are stored for all the Microsoft services
10 the Company uses, and implementation of information
11 barriers, necessary under Idaho Power' s Standards of
12 Conduct standard to prevent marketing function employees
13 from communicating with transmission function employees .
14 When using the main intranet site, one can visibly see in
15 the figures below, those pages that have been moved to
16 SharePoint Online, Figure 1, and those pages that remain on
17 SharePoint 2016, Figure 2 .
18 Figure 1
19 SharePoint Online
C Q n https:,�;'idahopowercompany,sharepoint.com/sites/Spillway/
25IQAHO POMR
Thc-
Spillway Home Departments Employee Portal/Workday Forms&Publications
20
COLBURN, DI-REB 11
Idaho Power Company

1 Figure 2
2 SharePoint 2016 .
C Q n https://spillway/del/Pages/welcome.aspx
SharePoint
�iaowo �Rm The
3
4 The project costs associated with the SharePoint
5 2024 Development project placed in-service in 2024 are used
6 and useful . If the Commission, however, determines that
7 prudence of the project costs placed in-service is more
8 appropriately considered upon completion of the multi-year
9 transition of all sites to SharePoint Online, Idaho Power
10 believes it is more appropriate to delay the prudence
11 determination rather than disallow the project costs, as
12 suggested by Staff witness Ms . Loskot.
13 Non-Criteria Based Equipment
14 Q. What is Staff witness Ms . Loskot' s proposed
15 adjustment associated with Idaho Power' s Non-Criteria Based
16 Equipment investments?
17 A. In her testimony, Ms . Loskot is proposing a
18 disallowance of $19, 350 associated with the Company' s
COLBURN, DI-REB 12
Idaho Power Company

1 investment in a lawnmower for the CJ Strike parks complex,
2 stating the existing lawn care equipment was sufficient and
3 an additional mower was unnecessary.9
4 Q. Do you agree with Ms . Loskot' s assessment that
5 the current lawn care equipment is sufficient, and the
6 additional mover was an unnecessary purchase?
7 A. No. The third lawnmower purchase was a
8 necessary and prudent investment. The CJ Strike parks
9 complex includes over 100 campsites consisting of over 60
10 acres of turf that must be mowed weekly. The complex is
11 staffed with three full-time employees and one seasonal
12 employee between the months of April and September. The
13 employees provide customer service, as well as grounds and
14 facilities maintenance, seven days per week. The turf was
15 being managed with two zero-turn mowers, taking
16 approximately 25 hours per week to mow. The addition of a
17 third mower was necessary to help increase efficiency and
18 productivity by enabling an additional staff member to
19 assist in managing mowing, reducing the total time
20 employees spend mowing by approximately 30 percent . The
21 mower was purchased from the same manufacturer of the other
22 mowers used at CJ Strike and the Oxbow parks because of the
23 familiarity with the units, interchangeable parts,
9 Loskot DI at 8, 11. 15-17 .
COLBURN, DI-REB 13
Idaho Power Company

1 exceptional reliability, and excellent customer support
2 from the dealer. Further, the additional mower provides a
3 backup unit if one mower goes down and needs repair. The
4 purchase of a third mower was prudent, allowing Company
5 personnel to cut weekly mowing down to approximately 18
6 hours and spend more time on other parks maintenance and
7 customer service needs .
8 Trailer and Mobile Housing
9 Q. Staff witness Ms . Loskot is recommending an
10 adjustment to remove the costs associated with the purchase
11 of four trailers that provide housing for the Hells Canyon
12 Complex seasonal employees . Do you agree with Ms . Loskot' s
13 evaluation of the four trailers and the conclusion that the
14 costs should be disallowed as extending beyond standard
15 industry practice?'°
16 A. No. The Company is obligated by the Federal
17 Energy Regulatory Commission in accordance with the Hells
18 Canyon Complex license to maintain the four overnight
19 parks : Hells Canyon Park, Copperfield Park, McCormick Park,
20 and Woodhead Park, and utilizes seasonal employees to do
21 so . The lack of housing options available in the Hells
22 Canyon area and the distance that would be required to
23 travel daily from affordable, available housing, created
io Loskot DI at 10, 11. 8-25.
COLBURN, DI-REB 14
Idaho Power Company

1 challenges for Idaho Power hiring seasonal workers .
2 Prospective candidates have turned down job offers because
3 of the lack of housing and the remoteness of the area. The
4 Company explored the possibility of providing Recreational
5 Vehicle ("RV") hook up sites, but this was not found to be
6 a workable solution because most seasonal workers do not
7 own or have access to an RV. Idaho Power also considered
8 rotating seasonal employees through field houses in the
9 area, but the availability of houses is limited, and no
10 additional capacity was available to accommodate seasonal
11 workers . Finally, the Company evaluated building new crew
12 quarters or bringing in modular housing, with the
13 associated infrastructure needs including power, water, and
14 sewer, but found the trailers and mobile housing was the
15 most cost-effective solution. After evaluating alternative
16 options, the Company determined that the purchase of the
17 2021 Keystone Retreat Destination trailer and Park Model
18 mobile housing to provide housing for seasonal workers in
19 the Hells Canyon area was necessary and prudent.
20 IV. CONCLUSION
21 Q. Please summarize your rebuttal testimony.
22 A. The Company' s approach to constructing and
23 maintaining its transmission and distribution systems,
24 including the single vendor platform project and the
25 various other projects discussed in my testimony, is
COLBURN, DI-REB 15
Idaho Power Company

1 thoughtful and prudent, and ensures Idaho Power maintains a
2 safe and reliable system.
3 Q. Does this conclude your testimony?
4 A. Yes, it does .
5
COLBURN, DI-REB 16
Idaho Power Company

1 DECLARATION OF MITCH COLBURN
2 I, Mitch Colburn, declare under penalty of perjury
3 under the laws of the state of Idaho:
4 1 . My name is Mitch Colburn .
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 and exhibit 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: fir+
17 MITCH COLBURN
18
19
20
21
22
COLBURN, DI-REB 17
Idaho Power Company

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-07
IDAHO POWER COMPANY
COLBURN , DI-REB
TESTIMONY
EXHIBIT NO. 18

Colburn REB Exhibit No.18
Docusign Envelope ID: B00577B5-6709-4102-BEE3-7567309FD7BD
I0*0
li, aspentech POWER.
■ An IDACORP Company
Certificate of System Cutover
This certificate recognizes the successful cutover and operation of Idaho
Power Company monarch SCADA/EMS/GMS system on November 6,
2024
E
Signed by: DocuSigned by:
lG fb4 EJ-iQFF5?PRAQFAD9
"p,eaua
F977EDC413_.
Eric Bond Idaho Power Company Roger Cottrell Aspen Technology DGM
Enterprise Technology Manager, IT Principal Professional Services Project Manager
November 6, 2024 November 6,2024
Date Date
Exhibit No. 18
Case No. IPC-E-24-07
M. Colburn, IPC
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