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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 24 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 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 14 15 16 17 18 19 20 21 22 23 24 25 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. ) 18 19 20 21 22 23 24 25 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 23 24 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. ) 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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: 9 / 10 11 / 12 13 / 14 15 16 17 18 19 20 21 22 23 24 25 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 / 8 9 / 10 11 / 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 / 12 13 / 14 15 / 16 17 18 19 20 21 22 23 24 25 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 / 17 18 / 19 20 / 21 22 23 24 25 70 KAUFMAN DI 4a IIPA 1 Q. DOES THIS CONCLUDE YOUR TESTIMONY SUPPORTING 2 THE STIPULATION? 3 A. Yes . 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. ) 13 14 15 16 17 18 19 20 21 22 23 24 25 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 / 7 8 / 9 10 / 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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? 7 / 8 9 I 10 11 / 12 13 14 15 16 17 18 19 - 20 21 22 23 24 25 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 / 12 13 / 14 15 / 16 17 18 19 20 21 22 23 24 25 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. 9 / 10 11 / 12 13 / 14 15 16 17 18 19 20 21 22 23 24 25 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. 13 14 15 16 17 18 19 20 21 22 23 24 25 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 / 11 12 / 13 14 / 15 16 17 18 19 20 21 22 23 24 25 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 . 7 / 8 9 / 10 11 / 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 / 19 20 / 21 22 / 23 24 25 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. 11 / 12 13 / 14 15 / 16 17 18 19 20 21 22 23 24 25 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 . 12 / 13 14 / 15 16 / 17 18 19 20 21 22 23 24 25 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. 19 20 21 22 23 24 25 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. ) 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 6 / 7 8 / 9 10 / 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 12 / 13 14 / 15 16 / 17 18 19 20 21 22 23 24 25 100 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, 8 / 9 10 / 11 12 / 13 14 15 16 17 18 19 20 21 22 23 24 12020 was excluded due to the COVID-19 pandemic, which contributed to an abnormally high level of uncollectibles. 25 102 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. 8 / 9 10 / 11 12 / 13 14 15 16 17 18 19 20 21 22 23 24 25 104 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. ) 24 25 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 4 / 5 6 / 7 8 / 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 3 / 4 5 / 6 7 / 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 3 / 4 5 6 / 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NO. IPC-E-23-11 118 English, D (Stip) 8a 11/15/23 STAFF 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 . 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. ) 22 23 24 25 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 3 / 4 5 / 6 7 / 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 6 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 . 11 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 3 / 4 5 / 6 7 / 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. 3 / 4 5 / 6 7 / 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 . 6 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 3 / 4 5 / 6 7 / 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 3 / 4 5 / 6 7 / 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NO. IPC-E-23-11 142 Thomas, T. (Stip) 9a 11/15/23 STAFF 1 proceeding? 2 A. Yes . 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. ) 17 18 19 20 21 22 23 24 25 CSB REPORTING 145 COLLOQUY 208 . 890. 5198 1 A U T H E N T I C A T I O N 2 3 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. 19 20 21 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