HomeMy WebLinkAbout20231129Technical Hearing Transcript.pdf BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC SERVICE ) CASE NO. IPC-E-23-11
IN THE STATE OF IDAHO AND FOR )
ASSOCIATED REGULATORY ACCOUNT )
TREATMENT. )
)
BEFORE
COMMISSIONER ERIC ANDERSON (Presiding)
COMMISSIONER JOHN HAMMOND
COMMISSIONER EDWARD LODGE (Telephonically)
PLACE: Commission Hearing Room
11331 West Chinden Blvd.
Building 8, Suite 201-A
Boise, Idaho
DATE: November 29, 2023
VOLUME IV - Pages 34 - 146
CSB REPORTING
ORIGINAL Certified Shorthand Reporters
Post Office Box 9774
Boise, Idaho 83707 Reporter:
CSbI'eportlrig(a7yahoo.com Constance Bucy,
Ph: 208-890-5198 CSR
1 A P P E A R A N C E S
2
3 For the Staff: Chris Burdin
Deputy Attorney General
4 IPUC
11331 W. Chinden Blvd. ,
5 Bldg. No. 8, Suite 201-A
PO Box 83720
6 Boise, ID 83720-0074
7
For Idaho Power Company: Lisa Nordstrom
8 Donovan Walker
Idaho Power Company
9 1221 W. Idaho Street
PO Box 70
10 Boise, ID 83707-0070
11
For Idaho Conservation Brad Heusinkveld
12 League: Idaho Conservation League
710 N. Sixth Street
13 Boise, ID 83702
14
For Industrial Customers RICHARDSON, ADAMS, PLLC
15 of Idaho Power: Peter J. Richardson
515 N. 27th Street
16 PO Box 7218
Boise, ID 83702
17
18 For Idaho Irrigation ECHO HAWK & OLSEN PLLC
Pumpers Association: Eric L. Olsen
19 505 Pershing Ave. , Suite 100
PO Box 6119
20 Pocatello, ID 83205
21
For Micron Technology, HOLLAND & HART LLP
22 Inc. : Austin Rueschhoff
Thorvald Nelson
23 555 17th Street, Suite 3200
Denver, CO 80202
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25
CSB REPORTING 35 APPEARANCES
208 . 890 . 5198
1
2 AP PEARAN C E S (Continued)
3
4 For Clean Energy Michael Heckler
Opportunities for Idaho: Courtney White
5 (Of Record) Clean Energy Opportunities
for Idaho Inc.
6 3778 Plantation River Drive
Suite 102
7 Boise, ID 83703
8
For City of Boise: Ed Jewell
9 (Of Record) Deputy City Attorney
Boise City Attorney' s Office
10 150 N. Capitol Blvd.
PO Box 500
11 Boise, ID 83701-0500
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CSB REPORTING 36 APPEARANCES
208 . 890. 5198
1 I N D E X
2
3 WITNESS EXAMINATION BY PAGE
4 Timothy Tatum Ms. Nordstrom (Direct) 43
(IPCo) Prefiled Testimony 45
5
Lance Kaufman Prefiled Testimony 63
6 (IIPA)
7 Wil Gehl Mr. Jewell (Direct) 72
(City of Boise) Prefiled Testimony 74
8
Brad Heusinkveld Prefiled Testimony 84
9 (ICL)
10 Jessica York Mr. Rueschhoff (Direct) 95
(Micron) Prefiled Testimony 97
11
Donn English Mr. Burdin (Direct) 106
12 (Staff) Prefiled Testimony 108
13 Taylor Thomas Mr. Burdin (Direct) 127
(Staff) Prefiled Testimony 129
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CSB REPORTING 37 INDEX
208 . 890. 5198
I BOISE, IDAHO, WEDNESDAY, NOVEMBER 29, 2023, 9 : 00 A. M.
2
3
4 COMMISSIONER ANDERSON: Good morning,
5 everyone. It looks like everybody is comfortable and we
6 tried to get enough seating for everyone. I think we did
7 pretty well today. We did put name cards out . When we
8 have this many intervenors, it ' s a little helpful for us
9 here, but let ' s go ahead and kick this off, so once
10 again, good morning.
11 This is the time and place set for a
12 technical hearing in Case No. IPC-E-23-11, further
13 identified as in the matter of the application of Idaho
14 Power Company for authority to increase its rates and
15 charges for electric service in the State of Idaho and
16 for associated regulatory account treatment .
17 This hearing is taking plays to consider
18 the general rate case filed with the Commission on
19 June 1st, 2023, seeking authority to increase Idaho Power
20 Company' s general rates for electric service in Idaho.
21 My name is Commissioner Eric Anderson and
22 I 'm the Chair for today' s proceedings . I 'm joined by
23 Commissioner John Hammond and unfortunately, Commissioner
24 Ed Lodge is feeling a bit under the weather this morning,
25 so he will not be attending in person, but he is
CSB REPORTING 38 COLLOQUY
208 . 890 . 5198
1 listening in as we ' re having this hearing. The three of
2 us do comprise the Commission and will collectively make
3 a final determination in this matter.
4 For today' s proceedings, we have Connie
5 Bucy serving as our court reporter. Please talk slowly,
6 clearly, and into the microphone for her benefit . If we
7 don' t, she ' ll correct us and slow us down a little bit.
8 On September 18th, October 4th, and
9 October 5th, the Company, all intervenors and Staff
10 participated in settlement negotiations, which resulted
11 in a proposed settlement. On October 27th, 2023, the
12 Company filed a stipulation settlement and a motion for
13 approval of the stipulation settlement.
14 The proposed settlement was signed by
15 staff, the Company, and all intervenors, collectively the
16 parties .
17 Let ' s move to the appearance of the
18 parties . In the order of witnesses, we will begin this
19 morning by taking the appearance of the parties for this
20 proceedings . The Company shall present its witness
21 first, followed by the intervenors and then by Commission
22 Staff. With that, let ' s begin by introduction of the
23 intervenors and the parties . Idaho Power?
24 MS. NORDSTROM: Good morning, Lisa
25 Nordstrom and Donovan Walker for Idaho Power.
CSB REPORTING 39 COLLOQUY
208 . 890 . 5198
I COMMISSIONER ANDERSON: Thank you very
2 much. Clean Energy Opportunities?
3 MR. HECKLER: Michael Heckler and Courtney
4 White for Clean Energy Opportunities for Idaho.
5 COMMISSIONER ANDERSON: Welcome. Idaho
6 Irrigation Pumpers Association?
7 MS . OLSEN: Yes, Eric Olsen for Idaho
8 Irrigation Pumpers Association.
9 COMMISSIONER ANDERSON: Welcome.
10 Industrial Customers of Idaho?
11 MR. RICHARDSON: Thank you, Mr. Chairman.
12 Peter Richardson of Richardson Adams on behalf of the
13 Industrial Customers of Idaho Power.
14 COMMISSIONER ANDERSON: Thank you,
15 Mr. Richardson.
16 Micron Technologies?
17 MR. RUESCHHOFF: Good morning, Austin
18 Rueschhoff of the law firm Holland & Hart on behalf of
19 Micron, joined by my co-counsel Thor Nelson and Jessica
20 York, our witness in the case. I also want to introduce
21 representatives of Micron who are observing today, Greg
22 Green, Jim Swier, and Michele Dulet.
23 COMMISSIONER ANDERSON: Thank you.
24 Welcome, Micron. IdaPower? IdaHydro, excuse me.
25 Okay, City of Boise?
CSB REPORTING 40 COLLOQUY
208 . 890 . 5198
1 MR. JEWELL: Good morning, Chairman, Ed
2 Jewell for the City of Boise, and I 'm joined today by Wil
3 Gehl.
4 COMMISSIONER ANDERSON: Welcome City of
5 Boise.
6 Idaho Conservation League?
7 MR. HEUSINKVELD: Good morning, all. Brad
8 Heusinkveld with the Idaho Conservation League.
9 COMMISSIONER ANDERSON: Welcome.
10 Federal Executive Agencies?
11 Northwest Energy Coalition?
12 And Walmart?
13 Are there any other parties that I 've
14 missed in my list here today? I don' t see any. Are
15 there any preliminary matters that need to come before
16 the Commission before we begin the proceedings this
17 morning?
18 MS. NORDSTROM: Yes, Commissioner. As you
19 know, Idaho Power Company has filed a settlement
20 stipulation that resolves all of the issues presented in
21 the Company' s application. To date, however, an Order
22 has not been issued accepting or rejecting the
23 stipulation and, of course, that ' s why we' re here.
24 For purposes of the record in this
25 proceeding, the Company proposes that the Commission
CSB REPORTING 41 COLLOQUY
208 . 890 . 5198
1 accept the direct testimony and exhibits of Idaho Power
2 dated June 1st, 2023, for filing as part of the record so
3 that the parties and the Commission can reference those
4 testimonies and exhibits during the hearing today, if
5 necessary.
6 If the settlement is not accepted by the
7 Commission' s Order, Idaho Power could then make available
8 the sponsoring witnesses at a later date to be determined
9 by the Commission if it comes to that.
10 COMMISSIONER ANDERSON: Do you still plan
11 on testimony from one of your witnesses?
12 MS. NORDSTROM: Correct.
13 COMMISSIONER ANDERSON: That ' s fine.
14 Without objection, so be it. Thank you very much.
15 MS. NORDSTROM: Thank you.
16 COMMISSIONER ANDERSON: Okay, with that,
17 we are -- well, we' re scheduled for multi-day, but we
18 didn't know there was going to be a settlement so we ' re
19 not going to prescribe any breaks. If we get to moving
20 along, just raise your hand if you want to take a break.
21 I don' t want to make this too loose where somebody has to
22 take a break on their own. We ' ll stop the proceedings
23 and then come back in, so just raise your hand if you
24 need to, Connie, also, please.
25 With that, we' re ready to start with our
CSB REPORTING 42 COLLOQUY
208 . 890. 5198
1 first witness. Let ' s begin with Idaho Power
2 MS. NORDSTROM: Thank you. Idaho Power
3 calls Timothy Tatum to the stand.
4
5 TIMOTHY TATUM,
6 produced as a witness at the instance of the Idaho Power
7 Company, having been first duly sworn to tell the truth,
8 was examined and testified as follows:
9
10 DIRECT EXAMINATION
11
12 BY MS. NORDSTROM:
13 Q Good morning.
14 A Good morning.
15 Q Please state your name and spell your last
16 name for the record.
17 A Timothy E. Tatum, T-a-t-u-m.
18 Q By whom are you employed and in what
19 capacity?
20 A Idaho Power Company, vice president of
21 regulatory affairs .
22 Q Are you the same Timothy Tatum who caused
23 to be filed direct testimony in support of the settlement
24 stipulation with no exhibits in this docket on
25 October 27th, 2023?
CSB REPORTING 43 TATUM (Di)
208 . 890 . 5198 Idaho Power Company
1 A Yes, I am.
2 Q Do you have any corrections or changes to
3 your testimony?
4 A I do not.
5 Q If I were to ask you the questions set out
6 in your prefiled testimony, would your answers be the
7 same today?
8 A Yes, they would.
9 MS. NORDSTROM: I move that the prefiled
10 testimony of Timothy Tatum in support of the settlement
11 stipulation be spread upon the record as if read.
12 COMMISSIONER ANDERSON: Without objection,
13 we ' ll spread Mr. Tatum' s testimony across the record as
14 if read.
15 MS . NORDSTROM: Thank you.
16 (The following prefiled testimony of
17 Mr. Timothy Tatum is spread upon the record. )
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CSB REPORTING 44 TATUM (Di)
208 . 890. 5198 Idaho Power Company
1 Q. Please state your name and business address.
2 A. My name is Timothy E. Tatum and my business
3 address is 1221 West Idaho Street, Boise, Idaho.
4 Q. By whom are you employed and in what capacity?
5 A. I am employed by Idaho Power Company ("Idaho
6 Power" or "Company") as Vice President of Regulatory
7 Affairs.
8 Q. Are you the same Timothy E. Tatum that
9 previously submitted testimony in this proceeding?
10 A. Yes, I submitted direct testimony on behalf of
11 Idaho Power providing an overview of the Company' s
12 overall rate request in this proceeding.
13 Q. What is the purpose of your testimony?
14 A. My testimony describes the Stipulation that was
15 signed by Idaho Power, the Staff of the Idaho Public
16 Utilities Commission ("Staff") , and all intervenors in
17 this docket: Clean Energy Opportunities for Idaho
18 ("CEO") , Industrial Customers of Idaho Power ("ICIP") ,
19 City of Boise, Idaho Irrigation Pumpers Association, Inc.
20 ("IIPA") , Micron Technology, Inc. ("Micron") , Federal
21 Executive Agencies ("FEA" ) , Idaho Conservation League
22 ("ICL") , NW Energy Coalition ("NWEC") , IdaHydro, and
23 Walmart, Inc. These entities are referred to
24 individually as a "Party" or
25
45 TATUM, DI 1
Idaho Power Company
1 collectively referred to as the "Parties . " The
2 Stipulation filed in this docket on October 27, 2023,
3 settles all issues that arose in this case ( "Proposed
4 Settlement") . My testimony also expresses Idaho Power' s
support for the Stipulation and urges the Commission to
adopt the Proposed Settlement without material change or
condition.
Q. Do you believe that the Proposed Settlement is
in the public interest?
1C A. Yes . The Parties have agreed to settle the
11 issues identified in the Stipulation, thus indicating
12 their satisfaction with the outcome. From the Company' s
1.3 perspective, the Proposed Settlement provides the Company
1.4 with the ability to update its rates to better reflect
15 current costs and the ability to economically finance new
16 investments in infrastructure for its system. The
17 Company also believes that the rates that result from the
1cc Stipulation are just and reasonable for its customers .
19 Q. How did the Parties arrive at the Stipulation?
20 A. On September 18, 2023, a settlement conference
21 was held at the Commission' s offices . All parties to the
22 case were represented and discussed the issues presented
23 in the Company' s case. The Parties continued their
?: discussions on
46 TATUM, DI 2
Idaho Power Company
I October 4 and 5, 2023 and ultimately those discussions
2 led to agreements which resulted in the Stipulation.
3 Q. Have all Parties in this case joined in the
4 Stipulation?
5 A. Yes .
6 Background
7 Q. Please describe Idaho Power ' s original revenue
8 requirement increase request .
9 A. On June 1, 2023, Idaho Power filed an
10 Application in this case seeking authority to increase
the Company' s Idaho jurisdictional retail revenue an
12 average of 8 . 61 percent. If the Company' s initial
13 proposal had been approved, the Company' s revenues would
14 have increased by approximately $111 million annually.
15 Idaho Power proposed spreading the rate increase to
16 varying degrees among all customer classes and special
17 contract customers . The Company requested that new rates
18 become effective on January 1, 2024, which is the end of
19 the statutory period set forth in Idaho Code § 61-622 (4 )
20 and Commission Rule of Procedure ("RP" or "Procedural
21 Rule" ) 123 . Pursuant to Procedural Rule 125, Idaho Power
22 notified customers of the requested rate increase via
23 press release, customer notices mailed to individual
24
25
47 TATUM, DI 3
Idaho Power Company
I customers, and personal contact with some customers .
2 Q. Did Staff and other Parties conduct a thorough
3 examination of the Company' s filing?
4 A. Yes . The Parties conducted extensive discovery
5 on Idaho Power' s filing. Over the course of this
6 proceeding, the Company provided responses to
7 approximately 400 data requests, the vast majority of
8 which were from Staff. In addition, Staff auditors and
9 engineers have made numerous visits to Idaho Power' s
10 Corporate Headquarters to review the underlying
11 accounting data and capital project documentation that
12 was the basis for the Company' s filed revenue
13 requirement . Additionally, Staff conducted on-site visits
14 of certain hydro and gas plants, as well as transmission,
15 distribution, battery, security, and communication
16 projects .
17 Proposed Settlement Overview
18 Q. What is the Idaho jurisdictional revenue
19 increase to which the Parties agree?
20 A. The Parties agree to an Idaho jurisdictional
21 revenue increase of $54 . 7 million, which represents a
22 settlement of all issues in this case.
23 Q. What is the overall percentage increase to
24 rates resulting from the Stipulation?
25
48 TATUM, DI 4
Idaho Power Company
1 A. The stipulated test period revenue increase of
2 $54 . 7 million is an approximate 4 . 25 percent average
3 increase to Idaho retail revenue.
4 Q. When will the rates to recover the stipulated
5 revenue increase and new tariff riders go into effect?
6 A. The Parties have requested that the Commission
7 issue an Order approving the agreed-upon rates as
8 reflected in the Stipulation to become effective on
9 January 1, 2024 .
10 Q. Please describe the Stipulation' s terms related
11 to cost of capital.
12 A. The Parties agreed to a 9. 6 percent return on
13 equity ("ROE") and a 7 . 247 percent overall rate of return
14 ("ROR") based on a non-specified cost of debt and capital
15 structure. This cost of capital adjustment served to
16 reduce the Company' s rate request by $23, 461, 105.
17 Q. What are the Stipulation' s terms related to
18 rate base?
19 A. The Parties agreed to an authorized Idaho
20 jurisdictional rate base of $3, 816, 351, 478 . This rate
21 base value reflects the removal of certain plant held for
22 future use items and annualizing adjustments associated
23 with certain large capital projects, which reduced the
24 test year revenue
25
49 TATUM, DI 5
Idaho Power Company
I requirement by $8, 294, 557 . In addition, the Parties
2 agreed to reduce the filed request by $2, 273, 749 to
3 remove the revenue requirement related to battery
4 augmentation. To offset the revenue impact of removing
5 the battery-related revenue requirement, Idaho Power will
6 be provided the opportunity to accelerate the
7 amortization of additional accumulated deferred
8 investment tax credits ("ADITC") . The combined impact of
9 the stipulated rate base adjustments reduced the
10 Company' s rate request by $10, 568, 306.
11 Q. Did Staff have any reservations regarding a
12 prudence determination of any capital projects presented
13 in the Company' s filed case?
14 A. Yes. At the time of the Stipulation, Staff had
15 yet to complete its review of capital projects included
16 in the test year rate base. Except as otherwise noted in
17 the Stipulation, all capital projects included in the
18 Company' s test year are presumed to be prudently incurred
19 as Staff continues its plant investment review. Staff
20 agreed to update the Company on its progress toward
21 completing its review by November 15, 2023, and commits
22 to fully complete its plant investment review by December
23 1, 2023 . To the extent Staff identifies potential
24 prudence concerns, it will identify
25
50 TATUM, DI 6
Idaho Power Company
1 specific plant investments to be the subject of further
2 prudence review in the Company' s next general rate case.
3 Also, Idaho Power and Staff commit to discuss capital
4 project review options and documentation generally, and
5 specifically for the Company' s partnered plants, to
6 establish a framework for future prudence reviews .
7 Q. What are the details related to the agreement
8 reached by Parties regarding the Company' s authority to
9 accelerate amortization of ADITC?
10 A. Since 2009, the Company has been subject to an
11 ADITC / Revenue Sharing Mechanism, that includes
12 provisions for the accelerated amortization of ADITC to
13 help achieve a minimum specified percent
14 Idaho-jurisdiction return on year-end equity ("Idaho
15 ROE") , currently set at 9. 4 percent . The mechanism also
16 provides for the potential sharing between Idaho Power
17 and Idaho customers of Idaho jurisdictional earnings in
18 excess of a 10 . 0 percent Idaho ROE. Under the current
19 mechanism, the ADITC and sharing thresholds are to be
20 reset at a general rate case to align the sharing
21 threshold with the newly authorized ROE and the threshold
22 for use of accelerated amortization of ADITC if the
23 Company' s Idaho jurisdictional ROE falls below 95 percent
24 of the authorized
25
51 TATUM, DI 7
Idaho Power Company
I ROE .
2 Under the Stipulation, the ADITC Revenue
3 Sharing Mechanism is modified to include an additional
4 amount of Investment Tax Credits ("ITC") equal to the
5 incremental ITC generated from the Company' s investment
6 in the 2023 battery storage projects, including
7 augmentation costs . Further, the Parties agreed that the
8 maximum allowed annual accelerated amortization of ADITC,
9 currently set at a $25 million cap, is removed.
10 Effective January 1, 2024, potential revenue sharing
11 between Idaho Power and Idaho customers of
12 Idaho-jurisdictional earnings will occur if earnings are
13 in excess of a 9 . 6 percent Idaho ROE. Under the
14 Stipulation, all revenue sharing will be implemented
15 through the Power Cost Adjustment ("PCA") rather than a
16 portion offsetting customer-funded pension obligations,
17 which is what occurs under the current mechanism
18 structure. The new minimum-specified Idaho ROE is set at
19 95 percent of the stipulated 9 . 6 percent, or 9 . 12
20 percent .
21 Q. What are the Stipulation' s terms related to
22 expenses?
23 A. The Parties agreed to six categories of expense
24 adjustments that when combined totaled a $21, 736, 202
25 reduction
52 TATUM, DI 8
Idaho Power Company
1 to the Company' s rate request. The categories of expense
2 adjustments are as follows : 1) Employee Housing, 2)
3 Long-Term Pay at Risk, 3) General Labor, 4) Uncollectible
4 Expenses, 5) Miscellaneous Administrative and General
5 Expenses, and 6) Non-Specific Adjustment. The rationale
6 for each of these adjustments is detailed in the
7 Stipulation.
8 Q. What are the Stipulation' s terms regarding
9 deferrals and other rate mechanisms?
10 A. The Parties agreed to five separate revenue
11 requirement adjustments that either adjust the timing of
12 cost recovery or move recovery to other rate mechanisms.
13 The total net impact of these adjustments is a reduction
14 to the Company' s rate request of $819, 583 . The revenue
15 requirement adjustments in this category are as follows:
16 1) Energy Efficiency Rider Funded Activities, 2) Western
17 Resource Adequacy Program, 3) Intervenor Funding
18 Amortization, 4) Wildfire Expense Removal, Deferral and
19 Amortization, and 5) Net Power Supply Expense. The
20 rationale for each of these adjustments is detailed in
21 the Stipulation.
22 Q. What are the Stipulation' s terms regarding the
23 appropriate class cost of service to be used to inform
24 class-specific cost allocation and rate design?
25
53 TATUM, DI 9
Idaho Power Company
1 A. The Parties do not agree on any particular
2 cost-of-service methodology. The Company' s filed
3 cost-of-service methodology, updated to reflect the
4 settled revenue requirement, has been utilized on a
5 limited basis to determine Fixed Cost Adjustment ("FCA")
6 rates, the Sales Based Adjustment Rate ("SBAR" ) used in
7 the PCA, Schedule 20 High-Density Load Interruption
8 Compensation, special contract rates (except for Schedule
9 30, as discussed further in paragraph 10 of the
10 Stipulation) , and optional service offerings including
11 Schedules 31, 45, 46, and 62 .
12 Q. Please describe the Stipulation' s terms related
13 to revenue spread.
14 A. The Parties agree that the above-described
15 $54 . 7 million net revenue increase should be recovered
16 according to a rate spread method under which revenue
17 from rates for each customer class will be generally
18 increased by a factor at least 0 . 5 times, but not more
19 than 1 . 3 times, the overall 4 . 25 percent increase, with
20 no increase for any customer class above 120 percent of
21 the cost-of-service index.
22 Q. Please describe the Stipulation' s terms related
23 to rate design.
24 A. The Parties agree to the rate design and tariff
25
54 TATUM, DI 10
Idaho Power Company
1 provisions included in Attachment No. 2 to the Motion for
2 Approval of Stipulation ( "Motion") filed
3 contemporaneously herewith. The Parties note the
4 following terms as included in Attachment No. 2 and
5 Stipulation Exhibit No. 2, which detail the rate
6 calculations for the various schedules, that differ from
7 the Company' s Application.
8 First, in determining the individual rates for
9 residential Schedules 1, Residential Service Standard
10 Plan, and 6, Residential Service On-Site Generation, the
11 Parties agree to use the customer billing determinants as
12 proposed by the Company in this case but maintain the
13 current percentage differential between each block.
14 Second, the Parties agree the residential
15 Service Charge will increase from $5 per month to $10 per
16 month on January 1, 2024, and to $15 per month on January
17 1, 2025 .
18 Third, the small general Service Charge will
19 increase from $5 to $25 per month on January 1, 2024 .
20 Fourth, a summer mid-peak period from 3 p.m. to
21 7 p.m. is added to residential time-of-use ("TOU")
22 offerings contained in Schedules 5, Residential Service
23 Time-of-Use Plan, and 6, Residential Service On-Site
24 Generation, to generally align with Schedules 9, Large
25 General Service, and
55 TATUM, DI 11
Idaho Power Company
1 19, Large Power Service as defined in the respective
2 tariff schedules included in Attachment No. 2 to the
3 Motion.
4 Fifth, the revenue requirement allocated to
5 Schedule 30, U. S . Department of Energy Special Contract,
6 will be effectuated by setting the demand charge at
7 $9. 75/kW and the energy charge at $0 . 040951/kWh.
8 Sixth, the Schedule 8 tariff sheet will be
9 updated to reflect the inclusion of September as part of
10 the summer season as reflected in Attachment No. 2 to the
11 Motion.
12 Q. Are there any other non-revenue items to which
13 the Parties agreed in the Stipulation?
14 A. Yes . There are four other non-revenue
15 stipulated agreements made by the Parties. First, Parties
16 agreed that Idaho Power' s share of all capital
17 expenditures at the jointly owned Jim Bridger Power Plant
18 ("Bridger") and the North Valmy Power Plant ("Valmy")
19 through year-end 2022 were prudently incurred. Idaho
20 Power' s rate increase resulting from this case reflects
21 the full level of collection related to previously
22 authorized coal-related cost recovery for the Bridger
23 plant .
24 Second, Parties agreed that the Idaho
25 jurisdictional amount of $46, 361, 643 in third-party
point-to-point wheeling
56 TATUM, DI 12
Idaho Power Company
1 revenues will serve as the baseline for discussions in a
2 subsequent separate proceeding regarding the potential
3 annual tracking of these revenues .
4 Third, the Parties agreed that wildfire
5 expenses included into base rates will be $26, 080, 688 .
6 Incremental vegetation management costs above the 2022
7 actuals amount of $24, 848, 875 will continue to be
8 deferred through the earlier of the Company' s next
9 general rate case or 2025 . Expenses for the Covered Wire
10 Evaluation pilot and the Vegetation Management Satellite
11 and Aerial Patrols pilot are to be deferred through 2025 .
12 Incremental insurance above the 2022 actuals amount of
13 $14, 489, 412 will continue to be deferred through the
14 earlier of Idaho Power' s next general rate case or 2025.
15 Fourth, Parties agreed that Idaho Power should
16 be authorized to defer and amortize annual differences
17 between certain periodic maintenance costs at the
18 Company' s natural gas-fired power plants . This deferral
19 will not include a carrying charge.
20 Acceptance of the Proposed Adjustments
21 Q. Why was the Company willing to accept in
22 settlement a lower general rate increase than it
23 initially
24
25
57 TATUM, DI 13
Idaho Power Company
1 filed?
2 A. In her direct testimony, Ms . Lisa Grow
3 explained that in the preparation of its initial request
4 the Company looked for areas where it could forego
5 requesting an increase at this time in recognition of the
6 impact the rate increase would have on customers at a
7 time when they are facing other inflationary pressures .
8 Idaho Power participated in the settlement negotiations
9 with those same concerns in mind and believes that the
10 Proposed Settlement strikes the right balance between the
11 Company' s need for timely cost recovery and its
12 recognition of the state of the current economic
13 pressures its customers are facing. The $54 . 7 million net
14 revenue increase will provide additional cash flow to
15 help support current credit ratings, and the additional
16 ADITC provisions and other deferral authorizations (i. e. ,
17 vegetation management, insurance, and gas plant
18 maintenance) will provide some positive support to the
19 Company' s earnings until the next general rate case.
20 Although the Proposed Settlement is a
21 reasonable resolution of a broad range of contested rate
22 issues, the agreement will require the Company to
23 continue to look for ways to manage ongoing inflationary
24 pressures on its expenses
25
58 TATUM, DI 14
Idaho Power Company
1 and be thoughtful in its capital markets transactions as
2 well as with its credit ratings .
3 Q. Were there other reasons why the Company was
4 willing to accept a lower revenue requirement?
5 A. Yes . In consideration of the settlement terms
6 the Company recognized that the adjustments related to
7 income-qualified weatherization, WRAP expenses,
8 intervenor funding amortization, wildfire mitigation
9 costs and net power supply expenses will have no material
10 impact to the Company' s earnings, as these adjustments
11 serve to either adjust the timing of cost recovery or
12 move recovery to other rate mechanisms .
13 Q. Please explain the Company' s acceptance of an
14 overall rate of return that was less than originally
15 requested.
16 A. For purposes of the Proposed Settlement, Idaho
17 Power is willing to accept an overall rate of return that
18 is lower than originally requested because Idaho Power
19 believes that the agreed-upon rate of return will allow
20 the Company to finance its electric utility operations in
21 the near-term.
22 Q. Do you have any observations regarding the
23 revenue spread provided for in the Stipulation?
24
25
59 TATUM, DI 15
Idaho Power Company
1 A. Yes. Idaho Power believes that it is important
2 to have rates that reflect the costs to serve its
3 individual classes of customers. With that said, the
4 Company also recognizes that there are many differing
5 views regarding class cost-of-service methodologies. In
6 order to facilitate settlement and avoid potentially
7 contentious issues, the Company has agreed to a rate
g spread method that it believes represents meaningful
9 movement toward cost-of-service while also mitigating the
10 rate increase assigned to any one customer class .
11 Q. Do you have any concluding remarks regarding
12 the Proposed Settlement?
13 A. Yes . During this proceeding the Company
14 experienced a willingness by the Commission Staff and the
15 other Parties to address the issues in this case in a
16 straight-forward manner and to approach the possibility
17 of settlement in a productive way. The Company is very
18 appreciative of these efforts by Staff and the other
19 Parties.
20 Q. Does this conclude your testimony?
21 A. Yes, it does.
22
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25
60 TATUM, DI 16
Idaho Power Company
I (The following proceedings were had in
2 open hearing. )
3 MS. NORDSTROM: I tender this witness for
4 cross-examination.
5 COMMISSIONER ANDERSON: Thank you,
6 Ms . Nordstrom.
7 Is there any cross from any of the parties
8 in this case? Seeing none, at this time, without
9 objection, I would excuse the witness for any further
10 testimony. You' re excused. Thank you very much.
11 THE WITNESS: Thank you.
12 (The witness left the stand. )
13 COMMISSIONER ANDERSON: And Idaho Power
14 has no other testimony?
15 MS. NORDSTROM: That ' s correct.
16 COMMISSIONER ANDERSON: Thank you.
17 Idaho Irrigation Pumpers Association.
18 MS. OLSEN: We had sponsored the testimony
19 of Lance Kaufman. Due to the expense of bringing him
20 out, we haven' t made him available today, but would
21 request that the Commission would take note of his
22 testimony and treat it as if he were present and put that
23 into the record and spread it therefor. Thanks .
24 COMMISSIONER ANDERSON: Thank you, and I
25 know that we have read that . Without objection, we will
CSB REPORTING 61 TATUM
208 . 890 . 5198 Idaho Power Company
1 spread it across the record as if read. Hearing none,
2 thank you very much.
3 (The following prefiled testimony of
4 Dr. Lance Kaufman is spread upon the record. )
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CSB REPORTING 62 COLLOQUY
208 . 890 . 5198
1 I . INTRODUCTION AND SUMMARY
2 Q. PLEASE STATE YOUR NAME AND OCCUPATION.
3 A. My name is Lance D. Kaufman. I am a consultant
4 representing utility customers before state public
5 utility commissions in the Northwest and Intermountain
6 West. My witness qualification statement can be found at
7 LDK-2 .
8 Q. PLEASE IDENTIFY THE PARTY ON WHOSE BEHALF YOU
9 ARE TESTIFYING.
10 A. I am testifying on behalf of the Idaho
11 Irrigation Pumper' s Association, Inc. ("IIPA") . IIPA is
12 a non-profit trade association whose members are large
13 energy users in the Idaho, including customers receiving
14 electric services from Idaho Power Company ("IPC" or
15 "Company) .
16 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
17 A. I provide testimony on the following items:
18 The proposed settlement.
19 Q. PLEASE SUMMARIZE YOUR RECOMMENDATIONS.
20 A. I make the following recommendations :
21 Find the proposed settlement results in fair,
22 just, and reasonable rates .
23 II. SUMMARY OF IIPA PARTICIPATION IN THIS CASE
24 Q. PLEASE SUMMARIZE IIPA' S PARTICIPATION,
25 ANALYSIS, AND FINDINGS IN THIS CASE.
63 KAUFMAN DI 1
IIPA
1 A. IIPA reviewed the opening testimony and
2 workpapers of all company witnesses, issued discovery on
3 cost of capital, test year expenses, and cost of service,
4 and developed positions on potentially appropriate
5 adjustments to the Company' s filed case. Prior to
6 participation in settlement discussions IIPA identified
7 and quantified potential adjustments related to the
8 following issues:
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64 KAU FMAN DI la
IIPA
1 1 . Cost of capital,
2 2 . Rate base,
3 3 . Expenses,
4 4 . Load forecast,
5 5. Irrigation peak rewards program,
6 6. Cost of service,
7 7 . Rate spread, and
8 8 . Rate design.
9 IIPA participated in settlement discussions on
10 September 18, October 4, and October 5, 2023. During
11 these discussions all issues considered by IIPA, with the
12 exception of net power supply, were raised and discussed
13 by parties, including IPC. IPC offered reasonable
14 responses to many of the issues and concerns raised by
15 parties . Between settlement discussions IIPA met with
16 members and other intervening parties to discuss issues
17 in the case. IIPA proposed many of the compromises that
18 led to the final settlement proposal and finds the final
19 proposal contains terms and conditions that are
20 acceptable to the IIPA, provides an appropriate balance
21 between the participating parties, and will likely result
22 in fair, just and reasonable rates.
23 Q. PLEASE DESCRIBE YOUR ANALYSIS OF IPC' S COST OF
24 CAPITAL.
25 A. IIPA submitted discovery and performed analysis
65 KAUFMAN DI 2
IIPA
I of IPC' s cost of capital, including estimates of cost of
2 equity and evaluation of capital structure and cost of
3 debt . IIPA evaluated cost of capital using discounted
4 cash flow and capital pricing asset models . The cost of
5 equity agreed to in the stipulation was contained within
6 the range of estimates of IPC ' s cost of equity analysis .
7 /
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66 KAUFMAN DI 2a
IIPA
1 IIPA reviewed the company' s credit position,
2 debt coverage, debt issuances, and historical changes in
3 capital structure and did not find any material issues.
4 The overall cost of capital is consistent with IPC' s
5 review.
6 Q. PLEASE DESCRIBE YOUR REVIEW OF IPC' S EXPENSES
7 A. IIPA reviewed IPC' s base year expense ledgers
8 and test year adjustments . IIPA identified potential
9 issues with labor escalation, benefits, impacts of
10 turnover on average wage, depreciation, and tax expense.
11 The final revenue requirement in this case is consistent
12 with IPC' s review of expenses.
13 Q. PLEASE DESCRIBE YOUR REVIEW OF IPC' S LOAD
14 FORECAST .
15 A. IIPA compared IPC' s proposed billing
16 determinants with the IPC IRP load forecast, and with the
17 timing decisions imbedded in IPC' s requested rate base.
18 IIPA found that billing determinants did not reflect
19 material anticipated load growth in 2024, and that this
20 was inconsistent with the basis for IPC' s requested rate
21 base. IIPA' s primary concern with load forecast was
22 temporal consistency and IIPA' s concerns are addressed in
23 the proposed stipulation because revenue requirement is
24 based on a level of rate base consistent with IPC' s filed
25 load forecast.
67 KAUFMAN DI 3
IIPA
1 Q. PLEASE DESCRIBE YOUR REVIEW OF IPC'S IRRIGATION
2 PEAK REQARDS PROGRAM.
3 A. IIPA observed that IPC requested a material
4 increase in demand charges for Schedule 24 Irrigation
5 Service, due in part to increases in IPC' s cost of
6 capacity. IIPA was concerned that the Irrigation Peak
7 Rewards program did not also reflect this increase in
8 cost of capacity. The proposed settlement includes
9 workshops addressing cost of service modeling and IIPA
10 intends
11 /
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68 KAUFMAN DI 3a
IIPA
I to continue evaluating the peak rewards program in the
2 context of potential revisions to cost of service
3 modeling in future cases .
4 Q. PLEASE DESCRIBE YOUR REVIEW OF IPC' S COST OF
5 SERVICE MODEL.
6 A. IIPA identified several potential changes to
7 IPC' s cost of service model . These changes generally
8 reduced the cost of demand in summer months. The proposed
9 stipulation is consistent with IIPA' s potential changes
10 to cost of service, and parties have agreed to ongoing
11 workshops and discussions to address IIPA' s concerns .
12 Q. PLEASE DESCRIBE YOUR REVIEW OF IPC' S RATE
13 SPREAD.
14 A. IIPA' s revised cost of service model indicated
15 that excessive costs were allocated to Schedule 24
16 Agricultural Irrigation Service. IIPA proposed an
17 alternative rate spread that was more consistent with
18 IIPA' s cost of service model during settlement
19 discussions. This alternative rate spread was adopted in
20 the final proposal and addresses IIPA' s rate spread
21 concerns .
22 Q. PLEASE DESCRIBE YOUR REVIEW OF IPC' S RATE
23 DESIGN.
24 A. IPC proposed a moderate change to the Schedule
25 24 monthly fixed charge and a material increase to
69 KAUFMAN DI 4
IIPA
I Schedule 24 demand charges. IIPA finds the monthly fixed
2 charge change reasonable, but has ongoing concerns about
3 the large increase to demand charges . While not specified
4 in the stipulation, IPC has scheduled a meeting with IIPA
5 to discuss treatment of demand charges in the next
6 general rate case.
7 Q. ARE ALL OF IIPA' S CONCERNS ADDRESSED IN THE
8 PROPOSED SETTLEMENT?
9 A. Yes, all of IIPA' s concerns are either directly
10 addressed in the proposed settlement through changes to
11 revenue requirement and rate spread, or indirectly
12 through agreement for ongoing collaboration. IIPA
13 recommends that the commission find the proposed
14 settlement to be fair, just, and reasonable and in the
15 public interest.
16 /
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18 /
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20 /
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70 KAUFMAN DI 4a
IIPA
1 Q. DOES THIS CONCLUDE YOUR TESTIMONY SUPPORTING
2 THE STIPULATION?
3 A. Yes .
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71 KAUFMAN DI 5
IIPA
1 (The following proceedings were had in
2 open hearing. )
3 COMMISSIONER ANDERSON: City of Boise.
4 MR. JEWELL: Thank you, Mr. Chairman. The
5 City of Boise would like to call Wil Gehl.
6
7 WIL GEHL,
8 produced as a witness at the instance of the City of
9 Boise, having been first duly sworn to tell the truth,
10 was examined and testified as follows:
11
12 DIRECT EXAMINATION
13
14 BY MR. JEWELL:
15 Q Good morning, Mr. Gehl. Will you state
16 your name and spell your last name for the record,
17 please?
18 A Wil Gehl, G-e-h-l .
19 Q And who are you employed by?
20 A The City of Boise.
21 Q Are you the same Wil Gehl that caused to
22 be submitted prefiled direct testimony on November 15th,
23 2023, in this matter?
24 A Yes, I am.
25 Q Is there anything you would like to change
CSB REPORTING 72 GEHL (Di)
208 . 890. 5198 City of Boise
1 or amend about your testimony?
2 A No, thank you.
3 Q If I were to ask you the same questions
4 today, would your answers be the same?
5 A Yes.
6 MR. JEWELL: Mr. Chairman, I move that the
7 testimony be spread across the record as if read.
8 COMMISSIONER ANDERSON: Without objection,
9 we will spread Mr. Gehl' s testimony across the record as
10 if read.
11 (The following prefiled testimony of
12 Mr. Wil Gehl is spread upon the record. )
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CSB REPORTING 73 GEHL (Di)
208 . 890. 5198 City of Boise
1 I. IDENTIFICATION
2 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS FOR
3 THE RECORD.
4 A. My name is Wil Gehl and my business address is
5 150 North Capitol Boulevard, Boise, Idaho.
6 Q. WHERE ARE YOU EMPLOYED?
7 A. I am employed by the city of Boise City ("Boise
8 City") as the Energy Program Manager in the Department of
9 Public Works .
10 II. PURPOSE AND SU14MARY
11 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
12 A. I discuss Boise City' s support for the October
13 27, 2023, Stipulation and Settlement ("Proposed
14 Settlement") entered into by Idaho Power Company
15 ("Company") , the Idaho Public Utilities Commission
16 ("Commission" ) Staff, and all Intervenors in this
17 proceeding, collectively referred to as the "Parties" .
18 Q. PLEASE SUMMARIZE THE TOPICS COVERED BY YOUR
19 TESTIMONY.
20 A. First, I describe the settlement process and
21 summarize significant provisions of the Proposed
22 Settlement. I then explain Boise City' s support for the
23 Proposed Settlement and why Boise City believes it is in
24 the public interest .
25 Q. PLEASE SUMMARIZE YOUR RECOMMENDATIONS.
74 GEHL, DI 1
City of Boise
1 A. I recommend the Commission adopt the Proposed
2 Settlement as agreed to by the Parties. The Proposed
3 Settlement represents a compromise between all Parties,
4 including a significantly lower revenue requirement and
5 corresponding rate increase than originally
6 /
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75 GEHL, DI la
City of Boise
1 proposed by the Company and beneficial modifications to
2 rate design and rate spread. Boise City believes the
3 Proposed Settlement is in the public interest.
4 III . SETTLEMENT SUMMARY
5 Q. HAVE YOU REVIEWED THE OCTOBER 27, 2023,
6 PROPOSED SETTLEMENT AND THE COMPANY' S ACCOMPANYING
7 SUPPORTING TESTIMONY?
8 A. Yes .
9 Q. PLEASE SUMMARIZE THE SETTLEMENT PROCESS AND
10 BOISE CITY' S PARTICIPATION?
11 A. The Parties met for a series of settlement
12 conferences beginning on September 18, 2023 and
13 concluding on October 5, 2023. Parties presented
14 positions and engaged in discussions on the Company' s
15 application and proposed rate increase as well as
16 additional proposals on cost-of-service, rate design,
17 rate spread, energy efficiency and other items. Boise
18 City participated in all settlement meetings and
19 presented its analysis and proposals to be considered by
20 Parties in the context of the broader settlement
21 discussions . Boise City was particularly concerned with
22 the potential impacts on residential customers from this
23 proceeding. While Parties were not able to reach
24 agreement on all revenue requirement modifications or all
25 proposals made by intervenors, the Parties reached a
76 GEHL, DI 2
City of Boise
1 compromise position, resulting in an overall revenue
2 increase of $54 . 7 million or approximately 4 . 25% average
3 rate increase and an authorized Idaho jurisdictional rate
4 base of $3, 816, 351, 478 .
5 Q. IN ADDITION TO THE REVENUE REQUIREMENT, PLEASE
6 SUMMARIZE KEY PROVISIONS OF THE PROPOSED SETTLEMENT?
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77 GEHL, DI 2a
City of Boise
1 A. The Parties reached a compromise position
2 reflected in the Proposed Settlement that is based on an
3 agreement to settle all issues in this docket, including
4 rate design, revenue sharing, prudency determinations,
5 rate spread and other issues . The Proposed Settlement
6 sets out a 2-year increase in monthly service charges for
7 residential customers from the currently authorized level
8 of $5 per month to $10 per month in 2024 and $15 per
9 month in 2025 . The Proposed Settlement also includes an
10 agreement reached by Parties to modify the Company' s
11 revenue sharing mechanism and the Company' s ability to
12 accelerate amortization of Accumulated Deferred
13 Investment Tax Credits ("ADITC") . The Parties agreed to
14 a rate spread methodology where each customer class below
15 120 percent of cost of service will be increased by at
16 least 0. 5 times the overall 4 . 25 percent increase and the
17 maximum increase will be capped 1 . 3 times . Any customer
18 class above 120 percent of cost-of-service level will see
19 no rate increase. The Parties agreed to use the Company' s -
20 cost of service methodology for limited purposes,
21 including establishing an appropriate rate spread.
22 Q. PLEASE EXPLAIN WHY THE PROPOSED SETTLEMENT
23 ADDRESSES THE CONCERNS OF BOISE CITY.
24 A. While the Proposed Settlement and Stipulation
25 entered into by all Parties does not address every issue
78 GEHL, DI 3
City of Boise
1 identified by Boise City in its review of the Company' s
2 application, the Proposed Settlement in its entirety,
3 inclusive of the changes to rate spread, monthly service
4 charges, and revenue sharing mechanisms, reasonably
5 addresses the affordability and clean energy concerns of
6 Boise City in this proceeding. Boise City is extremely
7 sensitive to the impacts of any rate increase on its
8 residents and believes the Proposed Settlement strikes a
9 reasonable balance between maintaining affordability for
10 customers
11 /
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79 GEHL, DI 3a
City of Boise
1 and ensuring the Company can recover its prudently
2 incurred costs. The Proposed Settlement, if approved by
3 the Commission, would result in approximately 50o smaller
4 overall rate increase compared to the Company' s
5 Application; a smaller and more gradual increase in
6 residential monthly service charges; and improved revenue
7 sharing while maximizing the Company' s opportunity to
8 benefit from investment tax credits secured through clean
9 energy deployment. Additionally, the Proposed Settlement
10 promotes continued investment in energy efficiency and
11 promotes demand-side management program participation.
12 Boise City believes these are a significant benefit to
13 Idaho Power ratepayers, including Boise City residents.
14 Q. DO YOU HAVE ANY ADDITIONAL COMMENTS ON THE
15 SETTLEMENT OR PROCESS?
16 A. Yes. Boise City recognizes the important
17 contributions of the Company, Commission Staff, and
18 Intervenors to effectively reach a settlement in this
19 general rate case. With significant time elapsed since
20 the Company' s last General Rate Case, Boise City
21 appreciates the collaborative and straightforward
22 discussions with all parties to resolve as many contested
23 issues as possible in this proceeding. Boise City looks
24 forward to further engagement with Parties in the
25 proposed workshop series and in future proceedings.
80 GEHL, DI 4
City of Boise
1 IV. RECOMMNDATIONS
2 Q. WHAT IS BOISE CITY' S RECOMMENDATION TO THE
3 COMMISSION?
4 A. Boise City recommends the Commission approve
5 the Proposed Settlement as agreed to by the Parties in
6 its entirety, without material change or condition.
7 Q. PLEASE EXPLAIN WHY YOU BELIEVE THE PROPOSED
8 SETTLEMENT IS IN THE PUBLIC INTEREST.
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81 GEHL, DI 4a
City of Boise
1 A. Boise City believes the overall result of the
2 Proposed Settlement is a reasonable and fair compromise
3 between the Company and its customers. The overall
4 revenue requirement in the Proposed Settlement balances
5 customer interests with the Company' s ability to make
6 necessary investments to support the safe provision of
7 affordable, clean electricity to its customers. Boise
8 City believes the gradual and moderated rate increase
9 resulting from the Proposed Settlement is in the public
10 interest.
11 Q. DOES THIS CONCLUDE YOUR TESTIMONY?
12 A. Yes, thank you.
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82 GEHL, DI 5
City of Boise
1 (The following proceedings were had in
2 open hearing. )
3
4 COMMISSIONER ANDERSON: Is there any cross
5 from any of the parties? Seeing none, if there ' s no
6 objection, the witness ' testimony will be spread across
7 the record and he will be excused without further
8 questioning. Thank you very much.
9 THE WITNESS: Thank you.
10 (The witness left the stand. )
11 COMMISSIONER ANDERSON: Idaho Conservation
12 League.
13 MR. HEUSINKVELD: Mr. Chairman, attorney
14 for Idaho Conservation League Matt Nykiel is not present
15 at the moment. I filed prefiled testimony in support of
16 the settlement on November 15th. We would be happy to
17 enter that into the record otherwise, but do not do so
18 with counsel at the moment .
19 COMMISSIONER ANDERSON: Thank you. We
20 have read that testimony and we will recognize it as if
21 it were presented. Thank you.
22 MR. HEUSINKVELD: Thank you, Mr. Chair.
23 That' s all from us .
24 (The following prefiled testimony of
25 Mr. Brad Heusinkveld is spread upon the record. )
CSB REPORTING 83 COLLOQUY
208 . 890. 5198
I I. INTRODUCTION AND TESTIMONY
2 Q. Please state your name.
3 A. My name is Bradley J. Heusinkveld.
4 Q. Please state your employer, business address, and
5 position.
6 A. I am the Energy Policy Associate for the Idaho
7 Conservation League. My business address is 710 N. 6th
8 Street, Boise, Idaho.
9 Q. Please describe your educational and professional
10 background.
11 A. I hold a Batchelor of Science Degree in
12 Chemistry from the University of Puget Sound and Juris
13 Doctorate from Lewis & Clark Law School. Prior to
14 pursuing a law degree, I worked as an analytic chemist,
15 first under contract for tThe Environmental Protection
16 Agency' s Region 10 CERCLA Emergency Response program in
17 Seattle, Washington, and then for Glorietta Geoscience,
18 Inc. , a hydrogeology consulting firm in Santa Fe, New
19 Mexico.
20 I joined the Idaho Conservation League ("ICL") as
21 its Energy Policy Associate in August 2022 . My
22 responsibilities include engaging with Idaho' s regulated
23 utilities in Integrated Resource Planning, efficiency
24 program development, and other avenues for energy and
25 decarbonization advocacy. I frequently engage in utility
84 HEUSINKVELD, DI 1
ICL
1 dockets at the Idaho Public Utilities Commission ("PUC"
2 or "Commission") , including general rate cases brought by
3 Intermountain Gas Company and Avista Corporation brought
4 in the past calendar year. I advise my colleagues at ICL
5 on energy and regulatory matters as they intersect with
6 other organizational campaigns and Idaho' s natural
7 values . As part of my portfolio, I coordinate with
8 colleagues across the Pacific and Intermountain West on
9 regional energy advocacy.
10 /
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85 HEUSINKVELD, DI la
ICL
I My organizational goal is to promote access to
2 affordable and reliable energy that ensures the quality
3 of life of Idahoans by protecting clean air, clean water,
4 resilient landscapes and critical to all, a stable
5 climate system.
6 Q. Have you previously testified before the
7 Commission?
8 A. Yes . I sponsored the direct testimony of Lauren
9 McCloy in Avista Corporation' s General Rate Case,
10 AVU-E-23-01, at technical hearings before the Commission
11 on August 2, 2023. My testimony was limited in scope to
12 the written responses of Lauren McCloy, a colleague
13 employed by the Northwest Energy Coalition.
14 Q. What is the purpose of your testimony in this
15 proceeding?
16 A. The purpose of my testimony is to support the
17 settlement stipulations agreed to by Idaho Power
18 ( "Company") , the Commission Staff ( "Staff" ) , and all
19 intervenor parties regarding the Company' s general rate
20 case, IPC-E-23-11. Intervenor parties (collectively,
21 "Pparties") are: Clean Energy Opportunities for Idaho
22 ( "CEO") , Industrial Customers of Idaho Power ("ICIP") ,
23 City of Boise, Idaho Irrigation Pumpers Association,
24 ("IIPA") , Micron Technology Inc. ("Micron") , the Federal
25 Executive Agencies ("FEA") , NW Energy Coalition ("NWEC") ,
86 HEUSINKVELD, DI 2
ICL
1 IdaHydro, Walmart, Inc. , and ICL. The Company filed the a
2 proposed settlement agreement and an accompanying motion
3 with the Commission on October 27, 2023 . My testimony
4 expresses the Idaho Conservation League' s support of the
5 proposed settlement and recommends the Commission adopt
6 its terms without material alteration or conditions .
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87 HEUSINKVELD, DI 2a
ICL
1 Q. Do you believe the settlement is in the public
2 interest and meets fair, just, and reasonable standards .
3 A. Yes . Parties agreed to the proposed settlement
4 following extensive negotiations and review of the
5 Company' s applications, work papers, discoverydiscovery,
6 and data requests. Importantly, all Pparties agreed to
7 the settlement in its totality. Staff and intervenors
8 collectively represent a diverse set of customer groups
9 and interests. Reaching an agreeable compromise between
10 all twelve Parties necessitated balancing these
11 interests, while accommodating the Company' s need for
12 cost recovery and financial stability. For its part, ICL
13 believes the settlement is a fair compromise and in the
14 public interest. Parties arrived at moderate reductions
15 in revenue requirement, rate of return, revenue
16 adjustments, and reasonable alterations to rate design
17 elements. Broadly, these adjustments would reduce bill
18 impacts to customers, more equitably spread revenue
19 burdens between customer classes, gradually change rate
20 design elements, and better align cost allocation to
21 system costs . We believe the proposed settlement better
22 aligns with the public interest than the Company' s
23 application.
24 The testimony of Idaho Power' s Timothy Tatum
25 delivered on October 27, 2023 summarizes the components
88 HEUSINKVELD, DI 3
ICL
1 of the proposed settlement and explains why the Company
2 supports the settlement detailing the Company agreement
3 to settlement as a whole and acceptance of individual
4 provisions .
5 Q. How did the Pparties arrive at settlement?
6 A. Settlement meetings with the Company began on
7 September 18, 2023 followed by a. series meetings between
8 Staff and intervenors . All parties attended, in person or
9 remotely. . While the contents of the negotiations remain
10 confidential under Commission Rule 272, it will suffice
11 to say thatthe parties extensively negotiated the
12 multitude of issues presented by the Company' s
13 application, resulting in several iterative settlement
14 proposals. Individual parties supported positions with
15 various analyses and sample work papers, some of which
16 are incorporated into the proposed settlement before the
17 Commission. Over three weeks of meetings
18 /
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20 /
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89 HEUSINKVELD, DI 3a
ICL
I concluding on October 5, 2023, Parties and the Company
2 gradually moved towards the broad contours of a
3 prospective agreement while addressing individual issues
4 and navigating inherent tensions and trade-offs between
5 party positions . Staff and all the intervenor parties
6 aligned around a wholistic offer , which the Company
7 accepted before drafting and revising the proposed
8 settlement and motion delivered to the Commission on
9 October 27, 2023 .
10 Q. Did ICL advocate for any settlement provisions?
11 A. Yes . During negotiations ICL advocated for
12 several positions and, at times, supported the requests
13 of other parties . In other instances, we withheld
1.4 commentary or deferred to the positions and analysis of
15 others . To reach agreement, we moderated our positions to
16 accommodate other parties and the Company.
17 Q. How does the Settlement Address the Idaho
18 Conservation Leagues interests?
19 A. ICL ' s energy program aims to promote energy
20 efficiency and renewable integration as steps toward
21 decarbonization. We believe the proposed settlement
22 offers a marked improvement in these matters over the
23 Company' s application. If adopted by the Commission, the
24 settlement would more gradually increase monthly customer
25 charges, an issue we focused on in previous dockets
90 HEUSINKVELD, DI 4
ICL
1 before the Commission, as it impacts rate payer interests
2 in efficiency, intraclass equity, and its relation to
3 long term resource planning and utility investment . We
4 also welcome progress on the Company' s time of use
5 schedules, commitment to develop a revenue neutral bill
6 protection program, and engagement with parties on
7 examining cost of service methodologies. Additionally,
8 the settlement allows the Company to better utilize
9 investment tax credits, support demand side management
10 programs, and manage its efficiency programs.
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91 HEUSINKVELD, DI 4a
ICL
1 Q. How did ICL evaluate the settlement
2 stipulations?
3 A. ICL assessed the settlement stipulations in
4 theirits totality. While we advocated for a number of
5 provisions , we ultimately agreed to the proposal, as a
6 whole, based on its fairness and compatibility with the
7 public interest of the whole offer. Many issues presented
8 in the Company' s application and the stipulations are
9 interrelated, and fairness requires delicate balancing
10 and co-consideration. We believe the negotiations and
11 proposed settlement before the Commission accommodate
12 this balance, and so offer our support. We would have
13 been unlikely to accept a bifurcated settlement with some
14 parties agreeing on individual issues and disagreeing on
15 others . In this instance, an all- parties, all- issues
16 settlement was key to our evaluation of a fair and just
17 offer.
18
19 II . CONCLUSION
20 Q. What are your recommendations regarding the
21 proposed settlement?
22 A. I recommend the Commission accept the proposed
23 settlement in whole without material alteration and
24 withoutor condition. It represents a fair compromise
25 between the Company and Pparties, addresses ICL' s
92 HEUSINKVELD, DI 5
ICL
1 concerns, and accommodates the public interest.
2 Q. Do you offer other concluding remarks?
3 A. Yes . I appreciate the efforts of the Staff,
4 Company, and Parties in this matter. In my opinion, the
5 breadth and complexity of matters in this rate case is
6 impressive and was well handled. Reaching settlement
7 required respect, tact, and flexibility from all, and it
8 is good to see commonality emerge from our various posts
9 and perspectives .
10 Q. Does this conclude your testimony?
11 A. Yes, it does .
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93 HEUSINKVELD, DI 5a
ICL
1 (The following proceedings were had in
2 open hearing. )
3 COMMISSIONER ANDERSON: Do we have any
4 exhibits that need to be presented at all? Seeing none.
5 MR. BURDIN: Mr. Chair, Staff' s witnesses
6 have exhibits, but they' re just resume exhibits .
7 COMMISSIONER ANDERSON: Okay, at this
8 point let ' s move to Staff for their witnesses, please.
9 MR. RUESCHHOFF: Chairman Anderson, can
10 Micron go ahead and present its witness?
11 COMMISSIONER ANDERSON: Excuse me, I
12 didn' t even see that on my list. You have a witness,
13 too?
14 MR. RUESCHHOFF: Yes.
15 COMMISSIONER ANDERSON: Yes, please, my
16 apologies .
17 MR. RUESCHHOFF: No problem. Micron would
18 call Jessica York to the stand.
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CSB REPORTING 94 COLLOQUY
208 . 890. 5198
1 JESSICA YORK,
2 produced as a witness at the instance of Micron
3 Technology, Inc. , having been first duly sworn to tell
4 the truth, was examined and testified as follows :
5
6 DIRECT EXAMINATION
7
8 BY MR. RUESCHHOFF:
9 Q Good morning, Ms. York. Would you please
10 state your name and spell your last name for the
11 record?
12 A Jessica York, Y-o-r-k.
13 Q And by whom are you employed and in what
14 capacity?
15 A I 'm employed by Brubaker & Associates, an
16 energy consulting firm, as an associate.
17 Q And are you the same Jessica York who
18 caused to be prefiled testimony in support of a
19 settlement stipulation on November 15th, 2023?
20 A Yes, I am.
21 Q Do you have any corrections to that
22 testimony?
23 A I do not .
24 Q If I were to ask you the questions in your
25 testimony today, would your answers be the same?
CSB REPORTING 95 YORK (Di)
208 . 890 . 5198 Micron Technology, Inc.
1 A Yes .
2 MR. RUESCHHOFF: I move for the prefiled
3 testimony in support of the stipulation to be spread
4 across the record as if it were read.
5 COMMISSIONER ANDERSON: Without objection,
6 we will spread Ms. York' s testimony across the record as
7 if read.
8 MR. RUESCHHOFF: Thank you.
9 COMMISSIONER ANDERSON: Thank you.
10 (The following prefiled testimony of
11 Ms. Jessica York is spread upon the record. )
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CSB REPORTING 96 YORK (Di)
208 . 890 . 5198 Micron Technology, Inc.
1 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A Jessica A. York. My business address is 16690
3 Swingley Ridge Road, Suite 140, Chesterfield, Missouri
4 63017 .
5 Q WHAT IS YOUR OCCUPATION?
6 A I am a consultant in the field of public
7 utility regulation and an Associate with the firm of
8 Brubaker & Associates, Inc. ("BAI") , energy, economic and
9 regulatory consultants .
10 Q PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND
11 EXPERIENCE.
12 A This information is included in Appendix A to
13 my testimony.
14 Q ON WHOSE BEHALF ARE YOU APPEARING IN THIS
15 PROCEEDING?
16 A I am appearing on behalf of Micron Technology,
17 Inc. ("Micron") .
18 Q WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS
19 PROCEEDING?
20 A The purpose of my testimony is to support the
21 unanimous Stipulation and Settlement ("Stipulation")
22 filed by Idaho Power Company ("IPC" or "Company") and the
23 other parties to this proceeding on October 27, 2023.
24 The Stipulation resolves all revenue requirement, class
25 cost of service, and rate design issues in this
97 York, Di 1
Micron Technology, Inc.
1 proceeding.
2 Q DO YOU RECOMMEND APPROVAL OF THE STIPULATION?
3 A Yes. I recommend approval of the Stipulation.
4 The Stipulation is a comprehensive agreement that
5 represents give and take among the parties and
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98 York, Di la
Micron Technology, Inc.
1 resolves the revenue requirement, cost allocation, and
2 rate design issues that would have likely been raised by
3 the parties in this proceeding. The Stipulation is a
4 result of extensive arms length negotiations between the
5 settling parties in order to reach a comprehensive
6 settlement. Notably, the Stipulation is within the range
7 of outcomes that would have resulted from a litigated
8 case .
9 In sum, the Stipulation should be approved for
10 the following reasons :
11 1 . The stipulated overall revenue requirement will
result in an overall level of revenues for IPC that is
12 just and reasonable and will allow the utility a
reasonable opportunity to earn a fair return on its
13 investments . The revenue requirement adjustments
contained in the Stipulation represent a compromise on
14 the issues that would have been contested in this case .
15 2 . The stipulated revenue allocation reflects a
compromise between the parties to resolve the issues that
16 would have been contested in this case and is reasonably
based on cost of service principles . The compromise
17 revenue allocation in the Stipulation is within the range
of what would have likely been the parties ' litigated
18 positions in this case.
19 3 . The stipulated rate design for the various customer
rates is fair, reasonable, and in the public interest.
20
4 . The Stipulation is likely to reduce the Commission' s
21 administrative burden and save rate case expenses for all
parties.
22
23 Q PLEASE DESCRIBE THE STIPULATION' S RESOLUTION OF
24 THE COMPANY' S REVENUE REQUIREMENT IN THIS PROCEEDING.
25 A The Stipulation resolves the revenue
99 York, Di 2
Micron Technology, Inc.
1 requirement issues that would have been raised by parties
2 in this rate case.
3 The Company' s original filing in this docket
4 proposed to increase base rate revenues by $111 million,
5 or a system average increase of 8 . 61 percent. Under the
6 Stipulation, the increase in total revenue was reduced to
7 $54 . 7 million, or a system average increase of 4 .25
8 percent.
9 The Stipulation reflects several adjustments to
10 the Company' s originally filed revenue requirement, which
11 are summarized in the table on page 4 of the
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100 York, Di 2a
Micron Technology, Inc.
1 Stipulation. The Commission Staff ("Staff") and
2 intervenors, including Micron, provided a thorough and
3 detailed assessment of the Company' s cost of service in
4 these negotiations . Staff' s and the other intervenors '
5 review and input was very useful in identifying and
6 reaching an agreement on the revenue requirement
7 adjustments included in the Stipulation.
8 Q DID MICRON HAVE CONCERNS ABOUT ANY SPECIFIC
9 COMPONENTS OF THE COMPANY' S PROPOSED REVENUE REQUIREMENT?
10 A Yes. Micron had several concerns with IPC' s
11 originally proposed revenue requirement, which are
12 resolved by the compromise represented in the
13 Stipulation. First, Micron was concerned that the
14 Company' s proposed Return on Equity ("ROE") of 10. 4
15 percent was excessive based on current market conditions .
16 Micron conducted an independent analysis of IPC' s
17 proposed ROE and concluded that we would, in the context
18 of a litigated case, advocate for an ROE in the range of
19 9. 0 percent. The Stipulation provides for a reasonable
20 compromise between these positions and recommends the
21 Commission approve a 9. 6 percent ROE.
22 In addition, Micron had several other concerns
23 with the Company' s proposed revenue requirement including
24 the use of end of period rate base instead of average
25 rate base; the inclusion of 2024 salary increases, which
101 York, Di 3
Micron Technology, Inc.
1 were outside the test year; an excessive projection of
2 uncollectibles ' expense relative to the three-year
3 average of 2019, 2021, and 20221; the inclusion of
4 incentive compensation tied to financial performance,
5 which benefits shareholders rather than ratepayers; and a
6 potentially understated residential sales forecast. In
7 total,
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102 York, Di 3a
Micron Technology, Inc.
1 Micron estimated that its adjustments related to these
issues would have reduced the Company' s claimed revenue
deficiency by approximately $45 million. The adjustments
are, in many instances, incremental to other adjustments
that Micron understands that the Staff and other
intervenors would have raised. The Stipulation addresses
several of Micron' s various revenue requirement
adjustments and reflects a reasonable compromise of the
=+ various issues presented in this proceeding and the
parties ' positions in those issues .
11 Q DID THE SETTLING PARTIES REACH AN AGREEMENT ON
12 THE REVENUE ALLOCATION?
13 A Yes . Stipulation Exhibit No . 1 provides the
14 parties ' agreement regarding revenue allocation.
15 Stipulation Exhibit No. 2 identifies the settlement rates
16 agreed to by all settling parties .
17 As particularly applicable to Micron, the
18 Stipulation provides for an increase of approximately
19 3 . 65 percent for Micron' s Special Contract Rate Schedule
20 26. This outcome is consistent with IPC ' s cost of
21 service study, which concluded that Micron warranted a
22 cost-based rate increase less than the system average
23 rate increase. In addition, Micron is satisfied with the
24 rate design for Rate Schedule 26, as it generally
25 reflects cost-based rates based on its preferred class
103 York, Di 4
Micron Technology, Inc .
1 cost of service study methodology.
2 With regard to the other customer classes,
3 Micron analyzed IPC ' s class cost of service study and
4 finds the revenue allocation reasonable based on the
5 class cost of service study proposed by IPC, including
6 any adjustments to that study that Micron would have
7 proposed had this case been fully litigated.
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104 York, Di 4a
Micron Technology, Inc.
1 Q DID THE SETTLING PARTIES AGREE UPON A
2 PARTICULAR COST OF SERVICE STUDY?
3 A No. The parties did not agree on any
4 particular class cost of service methodology. Instead,
5 the settling parties negotiated a modified revenue
6 allocation to adjust rates and charges for each customer
7 class .
8 Q IN YOUR OPINION, IS THE STIPULATION REASONABLE
9 AND IN THE PUBLIC INTEREST?
10 A Yes . The settling parties compromised on their
11 various positions in order to reach a Stipulation that
12 economically and efficiently resolves what would have
13 been contested issues in this case . The Stipulation
14 provides the Company with updated rates to better reflect
15 current costs and the ability to economically finance new
16 investments in infrastructure while maintaining just and
17 reasonable rates for its customers2. Furthermore,
18 approving the Stipulation will result in efficiencies for
19 the Commission, Staff, and parties, and reduced rate case
20 expenses to the benefit of all IPC customers .
21 Q DOES THIS CONCLUDE YOUR TESTIMONY IN SUPPORT OF
22 THE SETTLEMENT STIPULATION?
23 A Yes, it does .
24
25 2 Settlement Testimony of Timothy Tatum at page 2, 11. 7-17.
105 York, Di 5
Micron Technology, Inc.
1 (The following proceedings were had in
2 open hearing. )
3 COMMISSIONER ANDERSON: Is there any
4 cross-examination of Ms. York? Seeing none, without
5 objection, she may be excused.
6 MR. RUESCHHOFF: Thank you.
7 (The witness left the stand. )
8 COMMISSIONER ANDERSON: Have I missed
9 anybody else? And I do apologize, Micron, for that.
10 MR. BURDIN: Mr. Chair, Staff would call
11 Donn English to the stand.
12 COMMISSIONER ANDERSON: Thank you.
13
14 DONN ENGLISH,
15 produced as a witness at the instance of the Staff,
16 having been first duly sworn to tell the truth, was
17 examined and testified as follows :
18
19 DIRECT EXAMINATION
20
21 BY MR. BURDIN:
22 Q Would you please state your name and spell
23 your last name for the record?
24 A My name is Donn English, E-n-g-l-i-s-h.
25 Q And what is your position with Commission
CSB REPORTING 106 ENGLISH (Di)
208 . 890 . 5198 Staff
1 Staff?
2 A I am a program manager overseeing the
3 accounting department.
4 Q And are you the same Donn English who
5 submitted direct testimony with an exhibit in this
6 matter?
7 A Yes, I am.
8 Q And do you have any modifications to that
9 testimony?
10 A No, I do not.
11 Q If I were to ask you the same questions
12 that are in that testimony today, would those answers be
13 the same?
14 A Yes, they would.
15 MR. BURDIN: Thank you. With that, the
16 Commission Staff moves to have that testimony submitted
17 as if read on the record.
18 COMMISSIONER ANDERSON: Without objection,
19 we will spread Mr. English' s testimony across the record
20 as if read.
21 MR. BURDIN: Thank you.
22 (The following prefiled testimony of
23 Mr. Donn English is spread upon the record. )
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CSB REPORTING 107 ENGLISH (Di)
208 . 890. 5198 Staff
1 Q. Please state your name and business address .
2 A. My name is Donn English. My business address
3 is 11331 W. Chinden Blvd. , BLDG 8, STE 201-A, Boise,
4 Idaho 83714 .
5 Q. By whom are you employed and in what capacity?
6 A. I am employed by the Idaho Public Utilities
7 Commission ("Commission") as a Program Manager overseeing
8 the Accounting and Finance Department in the Utilities
9 Division.
10 Q. Please describe your educational background and
11 professional experience.
12 A. I was hired by the Commission in 2003 and I
13 have provided testimony in numerous proceedings. My
14 educational background and professional experience are
15 provided in more detail in Exhibit No. 101 .
16 Q. What is the purpose of your testimony in this
17 proceeding?
18 A. The purpose of my testimony is to describe the
19 Application of Idaho Power Company ("Idaho Power" or
20 "Company") for authority to increase its rates and
21 charges for electric service in Idaho, explain Staff' s
22 investigation and evaluation of the Application, and
23 provide an overview of the stipulated revenue
24 requirement. Staff Witness Taylor Thomas will testify to
25 the Cost of
CASE NO. IPC-E-23-11 108 English, D (Stip) 1
11/15/23 STAFF
1 Service, Rate Spread and Rate Design issues, and other
2 agreements discussed in the Settlement.
3 Q• How is your testimony organized?
4 A. My testimony is subdivided under the following
5 headings:
6 Background Page 2
7 Staff Investigation Page 4
8 Settlement Evaluation Page 6
9 Settlement Overview Page 7
10 Revenue/Expense Adjustments Page 7
11 Deferrals/Mechanism-Related Adj . Page 11
12 Revenue Sharing Mechanism Page 15
13 Background
14 Q. Please describe Idaho Power' s original filing.
15 A. Idaho Power made its original filing with the
16 Commission on June 1, 2023, requesting authority to
17 increase its revenue in Idaho by approximately $111. 3
18 million, or 8 . 610, which included a corresponding
19 decrease in the Power Cost Adjustment ("PCA" ) of $173 . 4
20 million and a reduction to the annual Energy Efficiency
21 Rider collection of $3. 5 million. The Company requested
22 the increase to be effective July 1, 2023, recognizing
23 that the effective date would be suspended to January 1,
24 2024 .
25 The Company proposed a 10 . 4% Return on Equity
("ROE")
CASE NO. IPC-E-23-11 109 English, D (Stip) 2
11/15/23 STAFF
1 and a 4 . 895% cost of debt, for an overall return of
2 7 . 702% and a capital structure of 51% equity and 49%
3 debt.
4 Additionally, the Company proposed several changes
5 to the rate design intended to recover costs . Most
6 notably, the Company proposed increasing the residential
7 monthly Service Charge from $5. 00 to $15. 00 and
8 increasing by $10. 00 each year until it reaches $35 . 00
9 after three years .
10 Q. How was this case processed after the Company' s
11 filing was received?
12 A. The Commission issued a combined Notice of
13 Application, Notice of Suspension of Proposed Effective
14 Date, and Notice of Intervention Deadline ("Notice") on
15 June 23, 2023 . The Notice established an Intervention
16 Deadline of July 14, 2023 . Intervenor status was
17 subsequently granted to Clean Energy Opportunities for
18 Idaho ("CEO" ) , City of Boise, the Federal Executive
19 Agencies ("FEA") , the Industrial Customers of Idaho Power
20 ("ICIP") , Idaho Conservation League ("ICL") , IdaHydro,
21 Idaho Irrigation Pumpers Association, Inc. ("IIPA") ,
22 Micron Technology, Inc. ("Micron") , NW Energy Coalition
23 ("NWEC") , and Walmart, Inc. ("Walmart" ) . These entities
24 are collectively referred to as the "Parties" along with
25 Staff and the Company.
CASE NO. IPC-E-23-11 110 English, D (Stip) 3
11/15/23 STAFF
1 The Parties participated in settlement conferences
2 on September 18, 2023, and October 4-5, 2023. Following
3 the
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CASE NO. IPC-E-23-11 ill English, D (Stip) 3a
11/15/23 STAFF
1 settlement conferences and further discussions,
2 agreements were reached which ultimately resulted in the
3 Stipulation and Settlement ("Proposed Settlement" ) that
4 was signed by all Parties and filed on October 27, 2023 .
5 Staff Investigation
6 Q. What type of investigation did Staff conduct to
7 evaluate the Company' s rate increase request?
8 A. Staff' s approach in any general rate case is to
9 extensively review the Company' s Application and
10 associated testimony and workpapers, identify adjustments
11 to the proposed revenue requirement, and prepare to file
12 testimony for a fully litigated proceeding. There were
13 15 Staff members analyzing this case consisting of
14 auditors, engineers, utility analysts, and compliance
15 investigators . Additionally, five supervisors reviewed
16 the results of all analysis .
17 Staff auditors reviewed the Company' s test year
18 results of operations, capital budgets, capital spending
19 trends, operations and maintenance ("O&M") expenses and
20 trends . Additionally, Staff verified all of the
21 Company' s calculations and assumptions with regard to the
22 overall revenue requirement . The auditors reviewed
23 thousands of transactions, selected samples, and
24 performed transaction testing in accordance with standard
25 audit procedures . Staff reviewed the Company' s labor
expenses, incentive
CASE NO. IPC-E-23-11 112 English, D (Stip) 4
11/15/23 STAFF
1 plans, and employee benefits to ensure the appropriate
2 level of expenditures are included in rates.
3 Staff reviewed both completed and proposed
4 Company investments to determine the prudency of capital
5 additions. Expenditures including insurance expense,
6 salaries, and O&M expenses were also examined.
7 Additionally, Staff investigated the Company' s cost of
8 capital, capital structure, cost of service, revenue
9 normalization, and proposed rate design. In total, Staff
10 submitted over 300 production requests, performed an
11 onsite audit of the Company' s books, and held several
12 meetings with Company personnel as a part of its
13 comprehensive investigation.
14 Following its investigation, Staff proposed
15 over 40 separate revenue requirement adjustments during
16 settlement discussions . Many of which were either
17 completely or partially accepted by the Company.
18 Settlement Evaluation
19 Q. How did Staff determine that the overall
20 Proposed Settlement was reasonable?
21 A. In every settlement evaluation, Staff and other
22 parties must examine the risks of losing positions at
23 hearing and determine if the settlement is a better
24 overall outcome. Staff must evaluate each individual
25 adjustment and determine the likelihood of the Commission
accepting
CASE NO. IPC-E-23-11 113 English, D (Stip) 5
11/15/23 STAFF
1 or rejecting Staff' s rationale for the adjustment .
2 Ultimately, Staff ' s intent in every settlement conference
3 is to negotiate the best possible outcome for customers .
4 Q. Does Staff support the Proposed Settlement as
5 reasonable?
6 A. Yes, after a comprehensive review of the
7 Company' s Application, a thorough audit of the Company' s
8 books and records, an analysis of the Company' s class
9 cost of service study, and extensive negotiations with
10 the Parties to the case, Staff supports the Proposed
11 Settlement . The Proposed Settlement offers a reasonable
12 balance between the Company' s opportunity to earn a
13 reasonable return on its investment and affordable rates
14 for customers . Staff believes the Proposed Settlement is
15 in the public interest; is fair, just, and reasonable;
16 and should be approved by the Commission.
17 Settlement Overview
18 Q. Would you please briefly describe the terms of
19 the Proposed Settlement?
20 A. The Proposed Settlement provides for a
21 reduction in the Company' s requested revenue requirement .
22 Instead of the Company' s proposed increase of $111 . 3
23 million (8 . 610) , under the Proposed Settlement, retail
24 revenues for Idaho customers will increase by $54 . 7
25 million (4 . 250) effective January 1, 2024 . For
residential customers, the
CASE NO. IPC-E-23-11 114 English, D (Stip) 6
11/15/23 STAFF
1 monthly Service Charge will increase from $5 . 00 to $10 . 00
2 on January 1, 2024 . On January 1, 2025, the monthly
3 Service Charge will increase to $15 . 00 . For Small
4 General Service customers, the Service Charge will
5 increase from $5 . 00 per month to $25 . 00 per month: Other
6 specific rate design issues in the Proposed Settlement
7 are discussed in greater detail in Staff Witness Thomas '
8 testimony.
9 Revenue/Expense Adjustments
10 Q. Please explain how the Proposed Settlement
11 addresses the Company' s cost of capital.
1.2 A. The Parties agree to a 9. 6% ROE and a 7 . 2470
13 overall rate of return applied to an Idaho jurisdictional
14 rate base of $3, 816, 351, 478 . The Company' s cost of debt
15 and capital structure were not specified in the Proposed
16 Settlement. The impact of this cost of capital
17 adjustment is a reduction of $23, 461, 105 to the Company' s
18 requested increase . Staff believes the overall cost of
19 capital adjustment is reasonable. However, Staff' s
20 review included a different capital structure and 9 . 50
21 ROE when justifying the agreed terms in this area.
22 Q. Will you please explain rate base adjustments
23 identified in the Proposed Settlement?
24 A. In its Application, the Company annualized
25 large capital projects that were placed in service during
CASE NO. IPC-E-23-11 115 English, D (Stip) 7
11/15/23 STAFF
1 2023 to include in its proposed rate base at End of
2 Period
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CASE NO. IPC-E-23-11 116 English, D (Stip) 7a
11/15/23 STAFF
1 ("EOP" ) values . The Proposed Settlement removes the
2 Company' s annualization adjustments, effectively
3 including those capital projects in rate base at an
4 Average of Monthly Averages ("AMA" ) value instead of EOP.
5 Additionally, Plant Held for Future Use ( "PHFU") was also
6 removed from the Company' s proposed rate base. The test
7 year methodology adjustment and the PHFU adjustment
8 decrease the Company' s proposed revenue requirement by
9 approximately $8 . 3 million.
10 Q. Please describe the Battery Augmentation
11 adjustment .
12 A. The final rate base adjustment removes the
13 Battery Augmentation projects for the Black Mesa and
14 Hemingway Battery Energy Storage Systems ("BESS") from
15 the Company' s proposed rate base. This adjustment
16 removes approximately $2 . 3 million from the revenue
17 requirement . To offset the revenue impact of this
18 adjustment, the Company will be provided the opportunity
19 to accelerate the amortization of additional Accumulated
20 Deferred Investment Tax Credits ("ADITC") .
21 Q. Please explain the expense adjustments outlined
22 in the Proposed Settlement .
23 A. The first expense adjustment relates to
24 Company-owned employee housing. Idaho Power provides
25 housing for employees in remote areas where it can be
CASE NO. IPC-E-23-11 117 English, D (Stip) 8
11/15/23 STAFF
1 difficult to attract qualified employees . To entice
2 potential employees
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CASE NO. IPC-E-23-11 118 English, D (Stip) 8a
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1 to work in those remote areas, the Company offers one
2 year of free rent in a Company-owned residence . This
3 adjustment imputes the revenue that could have been
4 received if Idaho Power charged the market rate for rent
5 on these properties . The impact of this adjustment is a
6 $136, 485 reduction to the revenue requirement.
7 Q. Please explain the adjustments for
8 employee-related expenses .
9 A. The Parties agreed to two separate adjustments
10 regarding employee labor costs . The first adjustment
11 removes the long-term "Pay at Risk" payments tied to the
12 financial performance of the Company for officers and
13 senior managers . Because the metrics to determine the
14 award and calculation of these incentive payments were
15 based on financial criteria that benefit shareholders, it
16 is appropriate to remove this amount from customers '
17 rates. The second employee labor adjustment removes a
18 portion of the Company' s 2022 General Wage Adjustment
19 ( "GWA") and the entirety of the 2024 GWA. The two
20 adjustments reduced the Company' s rate request by
21 approximately $14 . 4 million.
22 Q. Will you please discuss the remaining expense
23 adjustments?
24 A. The remaining expense adjustments are comprised
25 of an adjustment to the Company' s proposed uncollectible
expense, miscellaneous adjustments, and a non-specific
CASE NO. IPC-E-23-11 119 English, D (Stip) 9
11/15/23 STAFF
1 rate reduction adjustment. The Company proposed an
2 Uncollectible Expense adjustment that used a 10-year
3 average of actual bad debt expenses . The Parties agreed
4 to reduce the Company' s 10-year average to an amount that
5 is consistent with the Company' s recent bad debt
6 experience.
7 The Miscellaneous Expense adjustments remove
8 expenses associated with 1) a portion of the Company' s
g billing inserts that did not provide specific benefits to
10 customers, 2) injuries and damages caused by employee
11 actions, 3) Company airplane flights not associated with
12 providing service to customers and the associated
13 maintenance, 4) advertising to enhance the Company' s
14 image, 5) certain credit card expenses lacking
15 documentation and/or for purchases that did not provide
16 service to customers, 6) unrealized benefits of the
17 Company' s mobile application, and 7) board of directors '
18 compensation and expenses .
19 The Proposed Settlement also includes a Non-Specific
20 adjustment of approximately $4 . 2 million. This
21 adjustment accounts for a portion of the value of other
22 adjustments proposed by Staff and intervenors not
23 specifically accepted by the Company and is used to
24 arrive at the stipulated revenue increase of 4 . 25% .
25 Deferrals/Mechanism-Related Adjustments
CASE NO. IPC-E-23-11 120 English, D (Stip) 10
11/15/23 STAFF
1 Q. Will you please explain the Deferrals and other
2 Mechanism-Related Adjustments?
3 A. Yes, the final set of adjustments are made to
4 the Company' s proposed revenue requirement to adjust for
5 either the timing of recovery for the Company or amounts
6 moved to other mechanisms for recovery. The first of
7 these adjustments relates to the Company' s Energy
8 Efficiency Rider ("Rider") funded activities . In Order
9 No. 33908, the Commission established a 20 cap on wage
10 increases funded through the Rider to address Staff' s
11 concerns that Rider-funded labor expenses increase
12 annually without the scrutiny labor expenses receive
13 during a general rate case. Rather than continue with
14 capping the annual wage increases in the Rider, the
15 Company proposed to move all Rider-funded labor expenses
16 (approximately $3. 5 million) to base rates . The Company
17 also proposed a corresponding decrease in the Schedule
18 91, Energy Efficiency Rider, from the current 3. 1% to
19 2 . 250 .
20 The Parties agree that the Energy Efficiency
21 Rider-funded labor should be funded through base rates.
22 Additionally, the Parties agree that existing obligations
23 for the Low-Income Weatherization Assistance Program
24 ($1. 2 million) and low-income education ($125, 000) should
25 be moved from base rates to the Rider. By funding these
income-qualified programs through the Rider, interested
CASE NO. IPC-E-23-11 121 English, D (Stip) 11
11/15/23 STAFF
1 parties can request changes to the Commission Ordered
2 funding levels without having to wait until the Company
3 files a general rate case. To account for approximately
4 $1. 3 million in low-income program funding shifted from
5 base rates to the Rider, the Parties agree to increase
6 the Company' s proposed Rider collection rate from 2 . 25%
7 to 2 . 35%.
8 Q. What are the terms of the Proposed Settlement
9 regarding the Company' s participation in the Western
10 Resource Adequacy Program ("WRAP") ?
11 A. Consistent with Order No. 35920 in Case No.
12 IPC-E-23-08, the Parties agree that the Company will
13 defer its test year WRAP expenses in a regulatory asset
14 account for future recovery when the Company can show
15 realized benefits . This reduced the Company' s revenue
16 requirement by $585, 182 .
17 Q. Please describe the Intervenor Funding
18 Amortization?
19 A. The Company deferred all intervenor funding
20 ordered since its 2011 general rate case and proposed to
21 recover the balance in this case. The Parties agree to
22 amortize the deferral balance over seven years, which
23 reduces the Company' s revenue requirement by $235, 319.
24 Q. Please describe how the Proposed Settlement
25 accounts for the Company' s Wildfire Expenses and
CASE NO. IPC-E-23-11 122 English, D (Stip) 12
11/15/23 STAFF
1 Amortization?
2 A. The Parties agree to remove various one-time
3 wildfire-related costs that will not continue in the
4 future, reducing the revenue requirement by $328, 055.
5 The Parties also agree to allow Idaho Power to continue
6 to defer incremental vegetation management expenses and
7 incremental insurance expenses above the 2022 actuals
8 amount until the earlier of the Company' s next general
9 rate case or 2025 . Additionally, expenses related to the
10 Covered Wire Evaluation pilot and the Vegetation
11 Management Satellite and Aerial Patrols pilot will
12 continue to be deferred through 2025 .
13 The Company proposed to begin amortizing a portion
14 of the wildfire deferral in this case. The Parties agree
15 to begin amortizing the total balance of the wildfire
16 deferral over seven years, which will increase the
17 Company' s revenue requirement. Staff was concerned about
18 a pancaking effect in future rate cases and believes that
19 amortization of the full balance is reasonable. The
20 balance will be offset by $400, 000 of grants received for
21 the Fire Mesh and Vegetation Management Satellite
22 projects . The net effect of all wildfire expense and
23 amortization adjustments is an increase of approximately
24 $1. 6 million to the Company' s revenue requirement.
25 Q. Please describe the Net Power Supply Expense
CASE NO. IPC-E-23-11 123 English, D (Stip) 13
11/15/23 STAFF
1 ("LAPSE") adjustment?
2 A. This adjustment was made to update the
3 modelling assumptions related to wheeling that reduces
4 the Company' s filed NPSE by $5, 651, 170 . Net of the PCA
5 Transfer Adjustment proposed by the Company in its
6 Application, this adjustment results in a net reduction
7 to the Company' s revenue requirement of $291, 972.
8 Revenue Sharing Mechanism
9 Q. Please describe the Company' s revenue sharing
10 mechanism and the terms in the Proposed Settlement
11 regarding the mechanism and ADITC?
12 A. In Order No. 30978, the Commission approved a
13 stipulation that created a revenue sharing mechanism
14 based on the Company' s actual earned ROE each year. This
15 mechanism has been modified and extended through several
16 orders since inception. The mechanism provides benefits
17 to customers if the Company' s actual earned ROE for any
18 given year is greater than a predetermined ROE. When the
19 actual earned ROE exceeds the allowed ROE, the Company
20 returns a portion of the excess earnings to customers,
21 either through a rate reduction in the Company' s PCA or
22 an offset to the Company' s pension deferral . If the
23 Company' s actual earned ROE is below a certain threshold,
24 the Company is authorized to accelerate the amortization
25 of ADITC, up to $25 million annually, to improve its
actual ROE.
CASE NO. IPC-E-23-11 124 English, D (Stip) 14
11/15/23 STAFF
1 Under the terms of the Proposed Settlement, the
2 Parties agreed to continue the mechanism, modified to
3 include an additional amount of Investment Tax Credits
4 ("ITC" ) equal to the incremental ITC generated from the
5 Company' s investment in the Black Mesa and Hemingway BESS
6 projects . The Parties also agree to remove the $25
7 million cap on the annual accelerated amortization of
8 ITC. The Proposed Settlement establishes a threshold of
9 9 . 12% that the Company' s ROE must be below for it to
10 accelerate the amortization of ITCs . If the Company' s
11 ROE is above 9. 60, revenue sharing will be provided as a
12 benefit in the PCA. The Company will no longer be
13 required to use a portion of the excess earnings to
14 offset its customer-funded pension obligations .
15 Q. Do you have any other comments on the Proposed
16 Settlement?
17 A. Yes . The Proposed Settlement is a result of
18 detailed analysis and thoughtful negotiations by all
19 Parties. The Proposed Settlement results in a mitigated
20 rate increase for customers, a reasonable resolution on
21 several contested issues while identifying areas
22 requiring additional discourse to resolve. The Proposed
23 Settlement represents a compromise between the Parties to
24 establish just, fair, and reasonable rates while
25 providing the Company with additional cash flows
necessary to finance
CASE NO. IPC-E-23-11 125 English, D (Stip) 15
11/15/23 STAFF
1 its electric utility operations. Staff recommends that
2 the Commission approve the Proposed Settlement, signed by
3 all Parties, as filed.
4 Q. Does this conclude your testimony in this
5 proceeding?
6 A. Yes, it does .
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CASE NO. IPC-E-23-11 126 English, D (Stip) 16
11/15/23 STAFF
1 (The following proceedings were had in
2 open hearing. )
3 MR. BURDIN: The witness stands for any
4 cross.
5 COMMISSIONER ANDERSON: Are there
6 cross-examine? Seeing none, without objection, this
7 witness may be excused.
8 Thank you, Mr. English.
9 (The witness left the stand. )
10 MR. BURDIN: The Commission Staff calls
11 Taylor Thomas to the stand.
12
13 TAYLOR THOMAS,
14 produced as a witness at the instance of the Staff,
15 having been first duly sworn to tell the truth, was
16 examined and testified as follows:
17
18 DIRECT EXAMINATION
19
20 BY MR. BURDIN:
21 Q Would you please state your name and spell
22 your last name for the record?
23 A Taylor Thomas, T-h-o-m-a-s.
24 Q And what is your position with the
25 Commission Staff?
CSB REPORTING 127 THOMAS (Di)
208 . 890 . 5198 Staff
1 A I 'm a program manager for the technical
2 analysis team.
3 Q And are you the same Taylor Thomas that
4 submitted direct testimony and an exhibit in this
5 matter?
6 A I am.
7 Q And do you have any modifications to
8 that?
9 A I do not.
10 Q If I were to ask you the same questions
11 today as in your testimony, would your answers be the
12 same?
13 A Yes.
14 MR. BURDIN: Thank you. Commissioners, I
15 would move to have the testimony spread on the record as
16 if read.
17 COMMISSIONER ANDERSON: Without objection,
18 we will spread Mr. Thomas ' testimony across the record as
19 if read.
20 (The following prefiled testimony of
21 Mr. Taylor Thomas is spread upon the record. )
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CSB REPORTING 128 THOMAS (Di)
208 . 890 . 5198 Staff
1 Q. Please state your name and business address for
2 the record.
3 A. My name is Taylor Thomas . My business address
4 is 11331 W. Chinden Blvd. , Ste. 201-A, Boise, ID 83714 .
5 Q. By whom are you employed and in what capacity?
6 A. I am employed by the Idaho Public Utilities
7 Commission ("Commission") as a Program Manager overseeing
8 the Technical Analysis department of the Utilities
9 Division.
10 Q. Please describe your educational background and
11 professional experience.
12 A. I was hired by the Commission in 2020 and I
13 have provided numerous recommendations in proceedings
14 before the Commission. My educational background and
15 professional experience are provided in more detail in
16 Exhibit No. 102 .
17 Q. What is the purpose of your testimony in this
18 proceeding?
19 A. The purpose of my testimony is to describe the
20 proposed comprehensive Stipulation and Settlement
21 ("Settlement") reached by the signing parties ("Parties")
22 in this case based on the Application for Idaho Power
23 ("Company") to increase its rates and charges for
24 electric service and explain Staff' s support for the
25 Settlement.
CASE NO. IPC-E-23-11 129 Thomas, T. (Stip) 1
11/15/23 STAFF
1 Q. How is your testimony organized?
2 A. My testimony is subdivided under the following
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CASE NO. IPC-E-23-11 130 Thomas, T. (Stip) la
11/15/23 STAFF
1 headings :
2 - Cost-of-Service Methodology Page 2
3 - Rate Design Page 3
4 - Separate Informal Proceedings Page 6
5 - Non-Revenue Agreements Page 7
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7 Cost-of-Service Methodology
8 Q. How does the Settlement discuss the Company' s
9 Cost-of-Service methodology?
10 A. The Parties did not agree to a cost-of-service
11 methodology within this Settlement. However, the Parties
12 used the filed cost-of-service study as a guide to
13 allocate the revenue requirement of $54 . 7 million among
14 the different customer classes.
15 The Parties generally recognized that certain
16 customer classes were paying more or less than their
17 relative cost of service. The Parties agreed to a method
18 of increasing the rates for each customer class by at
19 least a factor of 0. 5 times, but not more than 1 . 3 times,
20 with no increase for any customer class above 120 percent
21 of the cost-of-service index.
22 Staff believes this is in the interest of customers
23 because it spreads the overall revenue increase of 4 .25
24 percent across all classes in an equitable manner in
25 relation to their cost-of-service.
CASE NO. IPC-E-23-11 131 Thomas, T. (Stip) 2
11/15/23 STAFF
I Q. Was the cost-of-service study updated to
2 reflect the settled revenue requirement?
3 A. Yes, but the updated version was used on a
4 limited basis . It was necessary to update the cost of
5 service to ensure the following were accurately derived:
6 the Sales Based Adjustment Rate ( "SBAR") used in the PCA,
7 the fixed cost per customer and the fixed cost per energy
S used in the Fixed Cost Adjustment ("FCA" ) , Schedule 20
9 Speculative High-Density Load Interruption Compensation,
10 and certain special contract rates .
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12 Rate Design
13 Q. Did the Parties discuss rate design?
14 A. Yes .
15 Q. Did the parties agree to change the summer
16 season?
17 A. Yes . The Parties agreed to extend the summer
18 season from June 15 through September 15 to June 1 to
19 September 30, as proposed by the Company.
20 Q. Please explain what the Settlement accomplished
21 for rate design for residential services : Schedule 1,
22 Residential Service Standard Plan, and Schedule 6,
23 Residential Service On-Site Generation.
24 A. For Schedules 1 and 6, the Parties agreed to
25 use the customer billing determinants proposed by the
Company
CASE NO. IPC-E-23-11 132 Thomas, T . (Stip) 3
11/15/23 STAFF
1 in this case but maintain the current percentage
2 differential between each block. For Schedules 1, 5, and
3 6, the Parties agreed to increase the residential service
4 charge from $5 per month to $10 per month on January 1,
5 2024, and to $15 per month on January 1, 2025 .
6 Q. Why are these changes reasonable?
7 A. Staff believes that the current residential
8 service charge does not allow the Company to recover the
9 fixed costs associated with customer charges (billing and
10 meter reading) or distribution; therefore, an increase is
11 necessary to allow more recovery of fixed cost from the
12 residential service charge. However, in conjunction with
13 an increase to the service charge, an elimination of the
14 blocked tiered rates, as proposed by the Company, could
15 send customers price signals that no longer encourage
16 energy conservation. Therefore, Staff believes the
17 Settlement is reasonable as an increase in the service
18 charge will increase recovery of fixed costs while the
19 blocked tiered rates continue to encourage customers to
20 conserve energy.
21 Q. Did the Settlement discuss Schedule 5,
22 Residential Service Time-of-Use ("TOU") Plan?
23 A. Yes . The Parties agreed to align the optional
24 TOU plan to the Company' s hours of highest risk and to
25 introduce larger differentials, as discussed in the
CASE NO. IPC-E-23-11 133 Thomas, T . (Stip) 4
11/15/23 STAFF
1 Company' s Application. Additionally, the Parties agreed
2 to introduce a summer mid-peak period from 3 p.m. to 7
3 p.m.
4 Q. Why is it necessary to introduce a mid-peak
5 period to Schedule 5?
6 A. Staff believes the mid-peak creates alignment
7 with Schedule 9, Large General Service, and Schedule 19,
8 Large Power Service. Additionally, Staff believes it
9 sends price signals to TOU customers to conserve during a
10 time of moderate risk for the Company. Finally, in the
11 Company' s concurrent Export Credit Rate filing, Case No.
12 IPC-E-23-14, the Company proposed a Summer On-Peak period
13 of 3-10 p.m. for customer generators exports. Staff
14 believes the mid-peak proposal for Schedule 5 helps to
15 create alignment between the hours of highest risk for
16 the Company between the two filings .
17 Q. Please discuss additional areas of rate design
18 in the Settlement .
19 A. The Parties agree the Small General Service
20 Charge will increase from $5 to $25 per month on January
21 1, 2024 . Additionally, the revenue requirement allocated
22 to Schedule 30, U. S . Department of Energy Special
23 Contract, will be effectuated by setting the demand
24 charge at $9. 75/kW and the energy charge at
25 $0 . 040951/kWh. Lastly, the Schedule 8 tariff sheet will
CASE NO. IPC-E-23-11 134 Thomas, T. (Stip) 5
11/15/23 STAFF
1 be updated to reflect the inclusion of September as part
2 of the summer season as
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CASE NO. IPC-E-23-11 135 Thomas, T. (Stip) 5a
11/15/23 STAFF
I reflected in Attachment No. 2 to the Motion.
2 Separate Informal Proceedings
3 Q. Does the Settlement include agreements for
4 other actions to follow this rate case?
5 A. Yes.
6 Q. Please explain how the Settlement addresses
7 what the Company and Parties will need to do following
8 this case.
9 A. First, Clean Energy Opportunities for Idaho
10 ("CEO") will coordinate and lead two series of workshops .
11 The first workshop will explore revenue neutral bill
12 protection for residential customers taking service on
13 TOU schedule, and a second series of workshops to explore
14 class-cost-of-service methodology and analysis, TOU
15 option for irrigators, and TOU concerns and
16 opportunities .
17 Second, the Company and IdaHydro will meet to
18 discuss Qualified Facility interconnection operations and
19 maintenance charges after updating Schedule 72 to reflect
20 current operation costs and assumptions.
21 Third, the Company will work with Staff and
22 interested parties to discuss an evaluation of the
23 Company' s transmission system related to radial
24 transmission lines .
25 Fourth, the Company will work with Staff to discuss
CASE NO. IPC-E-23-11 136 Thomas, T. (Stip) 6
11/15/23 STAFF
1 test year sales derivation methodology prior to the
2 filing of the Company' s next general rate case.
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CASE NO. IPC-E-23-11 137 Thomas, T. (Stip) 6a
11/15/23 STAFF
1 Fifth, to aid in future prudence review of the
2 Company' s Wildfire Mitigation Plan ("WMP" ) , the Company
3 will add a component that breaks down internal labor
4 costs within its WMP. Additionally, the Company will
5 expand the WMP to forecast each version for five years .
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7 Non-Revenue Agreements
8 Q. Please explain the non-revenue agreements that
9 are included in the Settlement between the Company and
10 the Parties .
11 A. There are several agreements including:
12 1. The Parties agreed that the Company' s share of
13 all capital expenditures at the jointly owned Jim Bridger
14 Power Plant ( "Bridger") and North Valmy Power Plant
15 ("Valmy") through year end of 2022 were prudently
16 incurred. Staff believes that the Company has
17 sufficiently shown prudence of its coal partnered plants .
18 2 . At the time of signing the Settlement, Staff
19 had not completed its review of all of the Company' s
20 capital investments. For Settlement purposes, Staff
21 agreed to include the full amount of capital investments
22 into test year rate base. Staff will update the Company
23 on our progress by November 15, 2023, and will have the
24 capital investment prudence review finalized by December
25 1, 2023 . If there are any prudence concerns, Staff agreed
CASE NO. IPC-E-23-11 138 Thomas, T. (Stip) 7
11/15/23 STAFF
1 to determine prudence of those identified items in the
2 Company' s next general rate case. Additionally, Staff and
3 the Company will have further discussion on capital
4 project information and documentation necessary for Staff
5 and other parties to effectively conduct prudence reviews
6 for all capital projects, including the Company' s
7 partnered plants .
8 3 . The Settlement uses a new base system Net Power
9 Supply Expense "NSPE" of $484, 907, 243 . The Parties agreed
10 to transfer $168 . 3 million base level NPSE from the PCA
11 to base rates . Staff supports this transfer as the
12 Company will be able to recover these expected expenses
13 within base rates and ratepayers get the benefit of a
14 reduced PCA charge. In addition, the Parties agreed to
15 use the filed class cost-of-service updated to reflect
16 the settled revenue requirement for purposes of
17 determining the SBAR to be applied in the PCA. As
18 proposed by the Company in the case, the resulting SBAR
19 is $30 . 90 per megawatt-hour.
20 4 . The Settlement reflects changes to the FCA due
21 to increased monthly Service Charges to the Residential
22 and Small Commercial customer classes . For Residential
23 customer classes, the monthly service charge will be $10
24 per month in 2024 and $15 per month in 2025 . The monthly
25 service charge for Small Commercial will be $25 per
CASE NO. IPC-E-23-11 139 Thomas, T . (Stip) 8
11/15/23 STAFF
1 month. Staff supports these changes as the recovery of
2 fixed
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CASE NO. IPC-E-23-11 140 Thomas, T. (Stip) 8a
11/15/23 STAFF
I expenses shifts away from the volumetric charges .
2 S . Tracking of Third Party Wheeling: The
3 Settlement identified $46, 361, 643 of Idaho' s
4 jurisdictional share of third-party point-to-point
5 wheeling revenues . Identification of this amount complies
6 with Commission Order No. 32821 and will be used as a
7 baseline for potential annual tracking and adjustments in
8 the PCA.
9 6. Lastly, the Parties agreed that the Company
10 defer without carrying charge and amortize annual
11 differences between certain periodic maintenance costs at
12 the Company' s natural gas-fired power plants .
13 Q. Do you have any other comments on the
14 Settlement?
15 A. Yes . Staff looked at each revenue requirement
16 adjustment, class cost-of-service study, proposed rate
17 design, and other issues under consideration and
18 determined that the Settlement between the Parties was as
19 good or better than what could be expected by fully
20 litigating the case. Staff believes that the rate
21 stability and certainty, along with the reduced revenue
22 increases, provided in the Settlement, represents a fair,
23 just, and reasonable compromise of the positions put
24 forth by the Parties and is in the public interest .
25 Therefore, Staff recommends that the Commission approve
CASE NO. IPC-E-23-11 141 Thomas, T . (Stip) 9
11/15/23 STAFF
I the Settlement without material changes or modification.
2 Q. Does this conclude your testimony in this
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CASE NO. IPC-E-23-11 142 Thomas, T. (Stip) 9a
11/15/23 STAFF
1 proceeding?
2 A. Yes .
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CASE NO. IPC-E-23-11 143 Thomas, T. (Stip) 10
11/15/23 STAFF
1 (The following proceedings were had in
2 open hearing. )
3 MR. BURDIN: Mr. Thomas stands for
4 questions .
5 COMMISSIONER ANDERSON: Thank you. Is
6 there any cross? Seeing none, without objection, we will
7 excuse the witness . Thank you Mr. Thomas .
8 THE WITNESS : Thank you.
9 (The witness left the stand. )
10 COMMISSIONER ANDERSON: I believe that
11 exhausts our witness list . Are there any further issues
12 or items that need to come before the Commission? Seeing
13 none.
14 Are there any posthearing briefs or
15 closing statements that you wish to share? Seeing none,
16 once again.
17 If I 've overlooked the admission of any
18 additional exhibits previously identified in this matter,
19 they are now hereby admitted, and pursuant to Rule 267,
20 any exhibits presented during any hearing without
21 objection are deemed admitted.
22 Intervenor funding request Rule 164 allows
23 14 days to apply for intervenor funding. I do not
24 anticipate -- do you anticipate, excuse me, needing any
25 more than 14 days? Seeing none .
CSB REPORTING 144 COLLOQUY
208 . 890 . 5198
I This has been a very quick hearing. It
2 just seems unusual for a rate case hearing, but I
3 appreciate everyone' s attendance and courteous conduct
4 here today, and pursuant to Rule 47, representatives of
5 parties appearing in a proceeding must conduct themselves
6 in an ethical and courteous manner and from what I 've
7 heard, you guys have done that all the way through this
8 process and the Commission is very appreciative of that,
9 so I thank you.
10 The Commission will consider this record
11 fully developed at this point. We will deliberate
12 privately and render a decision as expeditiously as
13 possible, and with that, then, if there ' s no other
14 comments from intervenors, the Staff, or the parties, we
15 are adjourned.
16 (The Hearing adjourned at 9: 20 a.m. )
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CSB REPORTING 145 COLLOQUY
208 . 890. 5198
1 A U T H E N T I C A T I O N
2
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4 This is to certify that the foregoing
5 proceedings held in the matter of the application of
6 Idaho Power Company for authority to increase its rates
7 and charges for electric service in the State of Idaho
8 and for associated regulatory account treatment,
9 commencing at 3 : 00 p.m. on Tuesday, November 28, 2023,
10 and continuing through Wednesday, November 29, 2023, at
11 the Commission Hearing Room, 11331 West Chinden Blvd. ,
12 Building 8, Suite 201-A, Boise, Idaho, is a true and
13 correct transcript of said proceedings and the original
14 thereof for the file of the Commission.
15 Accuracy of all prefiled testimony as
16 originally submitted to the Reporter and incorporated
17 herein at the direction of the Commission is the sole
18 responsibility of the submitting parties.
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22
CONSTANCE S . BUCY
23 Certified Shorthand Report r 187
24 CONSTANCE S BUCY
NOTARY PUBLIC-STATE OF IDMO
25 COMMISSION NUMBER 12995
MY COMMISSION EXPIRES 9-5-2024
CSB REPORTING 146 AUTHENTICATION
208 . 890 . 5198