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HomeMy WebLinkAbout20250415APPLICATION.pdf 0IQAW POWER@ RECEIVED April 15, 2025 IDAHO PUBLIC MEGAN GOICOECHEA ALLEN UTILITIES COMMISSION Corporate Counsel mgoicoecheaal len(cDidahopower.com April 15, 2025 Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-25-20 Application of Idaho Power Company for Authority to Implement Power Cost Adjustment ("PICK) Rates for Electric Service from June 1, 2025, through May 31, 2026 Dear Commission Secretary: Attached for electronic filing is Idaho Power Company's Application and Direct Testimony of Jessica G. Brady filed in support of the Application. Exhibit Nos. 4 and 5 to the Direct Testimony of Jessica G. Brady contain confidential information and will be provided separately via an encrypted email to the parties who sign the Protective Agreement. A Word version of the testimony will also be sent in a separate email for the convenience of the Reporter. Accompanying this filing is the Company's Press Release, Customer Notice, and Direct Mail Postcard. If you have any questions about the attached documents, please do not hesitate to contact me. Sincerely, T.Cm Megan Goicoechea Allen MGA:sg Attachments P.O.Box 70(83707) 1221 W.Idaho St. Boise,ID 83702 CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Idaho Power Company's Application for Authority to Implement Power Cost Adjustment ("PCA") Rates for Electric Service from June 1, 2025 through May 31, 2026 Case No. IPC-E-25-20 The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that Exhibit Nos. 4 and 5 to the Direct Testimony of Jessica G. Brady, dated April 15, 2025, may contain information that Idaho Power Company and a third-party claim constitutes confidential trade secrets, proprietary information, and/or private business records required by law to be submitted to or inspected by a public agency as described in Idaho Code§ 74-101, et seq., and §48-801, et seq., or is otherwise protected from public disclosure and as such is exempt from public inspection, examination, or copying. DATED this 15th day of April 2025. �_%r I Megan Goicoechea Allen Counsel for Idaho Power Company MEGAN GOICOECHEA ALLEN (ISB No. 7623) DONOVAN WALKER (ISB No. 5921) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2664 Facsimile: (208) 388-6935 mgoicoecheaallen(a).idahopower.com dwalker(a-)idahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-25-20 AUTHORITY TO IMPLEMENT POWER ) COST ADJUSTMENT ("PCA") RATES ) APPLICATION FOR ELECTRIC SERVICE FROM JUNE ) 1, 2025, THROUGH MAY 31, 2026. ) Idaho Power Company ("Idaho Power" or "Company"), in accordance with Idaho Code § 61-502 and Commission Rule of Procedure' 52, hereby respectfully requests the Idaho Public Utilities Commission ("IPUC" or "Commission") approve an update to Schedule 55 based on the quantification of the 2025-2026 Power Cost Adjustment ("PCA") to become effective June 1, 2025, for the period of June 1, 2025, through May 31, 2026. If the proposed rates and charges for electric service in the state of Idaho ' Hereinafter cited as RP. APPLICATION - 1 included as Attachment 1 to this Application are approved, the 2025-2026 PCA will result in an overall revenue decrease of approximately$94.8 million, or a 5.89 percent decrease from current billed revenue. In support of this Application, Idaho Power has filed the Direct Testimony of Jessica G. Brady, Senior Regulatory Analyst ("Brady Testimony"). Ms. Brady's testimony provides an overview of the PCA, details the 2025-2026 PCA amount in comparison to last year's PCA amount, explains the factors impacting this year's PCA quantification, presents the calculation of the proposed 2025-2026 PCA rates, and discusses the additional PCA component related to revenue sharing. In addition, the Brady Testimony details the net customer impact of the 2025-2026 PCA rates if approved as filed. In further support of this Application, Idaho Power represents as follows: L BACKGROUND 1. Idaho Power is an Idaho corporation whose principal place of business is 1221 West Idaho Street, Boise, Idaho 83702. 2. Idaho Power is a public utility supplying retail electric service to more than 600,000 customers in southern Idaho and eastern Oregon. Idaho Power is subject to the jurisdiction of this Commission in Idaho and to the jurisdiction of the Public Utility Commission of Oregon. Idaho Power is also subject to the jurisdiction of the Federal Energy Regulatory Commission. 3. The Company is compensated for "normal" costs of generating electricity through its base electricity rates established by the Commission in general rate cases. However, though the power supply expense component embedded in base rates is static, due to the Company's unique reliance on hydro generation, actual power supply APPLICATION - 2 expenses vary from year to year with changes in streamflow conditions. 4. As a result of the Company's request to establish a permanent mechanism to adjust rates annually to reflect variations in power supply costs in Case No. IPC-E-92- 25, the Commission issued Order No. 24806 on March 29, 1993, in which it approved the implementation of an annual Power Cost Adjustment procedure in order to provide consistency and stability to rates.2 The PCA is a cost recovery mechanism that passes on both the benefits and costs of supplying energy to Idaho Power customers. Neither Idaho Power nor its shareholders receive any financial return on this filing — money collected from the surcharge can be used only to pay power supply expenses. 5. Since its establishment, the PCA mechanism has been incrementally refined and modified through a series of Commission Orders, as more fully set forth below, to ensure the mechanism achieves its desired purpose and to incorporate other distinct elements, such as revenue sharing, as circumstances dictated. Case No. IPC-E-08-19 6. For example, following several Commission orders addressing the need to modify the Company's then-existing PCA methodology, the Company initiated Case No. IPC-E-08-19 requesting the Commission approve a settlement stipulation that addressed a number of issues and components of the PCA. In Order No. 30715, the Commission approved the stipulation and changes to the PCA formula, which included, in pertinent part, revising the PCA sharing methodology allocating non-PURPA3 power supply 2 In the Matter of the Application of Idaho Power Company for Authority to Implement a Power Cost Adjustment Tariff for Electric Service to Customers in the State of Idaho and for Approval of New Rates for Service Under the FMC Special Contract, Case No. IPC-E-92-25, Order No. 24806, p. 25-26 (Mar. 23, 1993). 3 Public Utility Regulatory Policies Act of 1978 ("PURPA"). APPLICATION - 3 expenses between customers and shareholders.4 More specifically, the PCA sharing ratio was modified to 95 percent customer, 5 percent Idaho Power.5 In addition, the Commission approved changes to the Load Growth Adjustment Rate ("LGAR"), third- party transmission expense, the PCA forecast, and power supply expense distribution.6 Case No. IPC-E-09-30 7. Following the notice of intent to file a general rate case filed by the Company in August 2009, the Company, Commission Staff, and other stakeholders worked together to develop an approach that would allow the Company to implement a multi-year rate case moratorium while at the same time giving the Company the opportunity to recover a maintenance level of earnings over the term of the moratorium. This ultimately resulted in the Company seeking approval of a settlement stipulation filed in lieu of a general rate case in Case No. IPC-E-09-30, which was granted by the Commission in Order No. 30978.7 Through this stipulation, a revenue sharing mechanism was established including provisions for the accelerated amortization of Accumulated Deferred Investment Tax Credits ("ADITC") to help the Company achieve a minimum specified percent Idaho- jurisdictional return on year-end equity ("Idaho ROE") and also provides for the potential sharing between Idaho Power and its Idaho customers of Idaho jurisdictional earnings in excess of a maximum specified Idaho ROE. Since then, the ADITC/Revenue Sharing mechanism has been extended, and percentages, thresholds, and accounting modified 4 In the Matter of Idaho Power Company's Petition for Approval of Changes to its Power Cost Adjustment (PCA) Mechanism, Case No. IPC-E-08-19, Order No. 30715, p. 4-5 (Jan. 9, 2009). 5 With respect to PUPRA expenses and demand response incentive payments, when actual annual expenses deviate from base level NPSE, the Company is allowed to pass 100 percent of the difference for recovery or credit through the PCA. 6 Case No. IPC-E-08-19, Order No. 30715, p. 5-7. In the Matter of the Application of Idaho Power Company for an Accounting Order to Amortize Additional Accumulated Deferral Income Tax Credit and Approving a Rate Case Moratorium, Case No. IPC-E-09-30, Order No. 30978, p. 5-7 (Jan. 13, 2010). APPLICATION -4 by numerous Commission Orders.$ The mechanism was most recently modified in the Company's 2023 General Rate Case, effective January 1, 2024 (Order No. 36042). Case No. GNR-E-10-03 8. At the Commission's request, Staff initiated Case No. GNR-E-10-03 to explore issues related to the load growth adjustment portion of the utilities' power cost adjustment mechanisms, particularly considering use of a LGAR in periods of declining load. In that case, the Commission ultimately adopted a revised LGAR methodology and changed the name of the methodology to the Load Change Adjustment Rate ("LCAR"), as set forth in Order No. 32206.9 Case No. IPC-E-15-15 9. In 2014 and 2015, the Company and Staff considered potential ways to improve the PCA's accuracy and, as a result of these efforts, agreed on a number of changes to the calculation of the PCA true-up. The ensuing proposal, to convert the PCA's existing Load Change Adjustment deferral calculation to a Sales-Based Adjustment ("SBA"), and modify the PCA deferral balance's monthly interest calculation, was set forth in a settlement agreement and submitted to the Commission in Case No. IPC-E-15-15. On May 28, 2015, the Commission issued Order No. 33307 approving changes to the PCA pursuant to the settlement agreement: (1) replacing the existing LCAR with the SBA, calculated in the same manner as the LCAR but replacing the load- ' See, e.g., In the Matter of the Application of Idaho Power Company to Extend and Modify Accounting Order to Amortize Additional Accumulated Deferred Income Tax Credits (ADITC), Case No. IPC-E-11-22, Order No. 32424, p. 4 (Dec. 27, 2011); In the Matter of Idaho Power Company's Application to Extend its Accumulated Deferred Investment Tax Credits/Revenue Sharing Mechanism Beyond 2014, Case No. IPC-E-14-14, Order No. 33149, p. 4-5 (Oct. 9, 2014); In the Matter of the Investigation into the Impact of Federal Tax Code Revisions on Utility Costs and Ratemaking, Case No. GNR-U-18-01, Order No. 34071, p. 4-5 (May 31, 2018). 9 In the Matter of the Commission's Inquiry into Load Growth Adjustments that Are Part of Power Cost Adjustment Mechanisms, Case No. GNR-U-10-03, Order No. 32206, p. 6-7 (Mar. 15, 2011). APPLICATION - 5 based megawatt-hour ("MWh") denominator with the corresponding sales-based MWh denominator; and (2) calculating monthly interest on the deferral balance by assigning annual base Net Power Supply Expenses ("NPSE") to each month according to expected base rate revenue collection as set in the Company's general rate case, Case No. IPC- E-11-08.10 Case No. GNR-U-18-01 10. Following changes to federal and Idaho state tax rates implemented in 2018, the Commission opened a multi-utility case, Case No. GNR-U-18-01, to investigate whether to adjust utilities' rates and charges to reflect the income tax and revenue requirement reductions resulting from the tax changes. After considering the impacts of tax reform on its operations, the Company worked together with Staff on a proposal that would return to customers the tax benefits the Company was realizing under the tax law changes with limited negative impact to the Company and entered into a settlement stipulation reflecting the same. The settlement stipulation filed with the Commission on April 12, 2018, included, among other things, extending and modifying the ADITC/Revenue Sharing mechanism. On May 31, 2018, the Commission issued Order No. 34071 approving the settlement stipulation that included modifications to the sharing portion of the mechanism to allow for greater customer benefits." Case Nos. IPC-E-21-10 and IPC-E-21-38 11. On May 28, 2021, the Commission issued Order No. 35054 approving the Company's 2021 annual PCA filing and instructing it, based on Staff's recommendation 10 In the Matter of Idaho Power Company's Application for Approval of Computational Modifications to the True-Up Portion of the Power Cost Adjustment, Case No. IPC-E-15-15, Order No. 33307, p. 4-5 (May 28, 2015). "Case No. GNR-U-18-01, Order No. 34071, p. 4-5. APPLICATION - 6 to simplify the PCA mechanism, "to initiate discussions with interested parties and to file a case with the Commission to review whether the PCA mechanism should be modified" before the Company's next PCA application.12 12. As a result of this endeavor, the Company proposed in Case No. IPC-E-21- 38 to simplify its PCA mechanism by replacing the "true-up" and "true-up of the true-up" components of the PCA with a balancing account. On January 10, 2022, the Commission issued Order No. 35290 approving the Company's request to modify the PCA mechanism thereby combining the two true-up components into one balancing account rate, referred to below as the "Balancing Adjustment."13 This modification was intended to make the PCA more transparent and easier to understand and did not materially affect the overall cost recovery of the PCA. Case No. IPC-E-23-11 13. On December 28, 2023, the Commission issued Order No. 36042 approving the settlement stipulation in the Company's 2023 General Rate Case ("GRC").14 The stipulation included, among other things, modifications related to the ADITC/Revenue Sharing mechanism. The mechanism was modified to include an additional amount of Investment Tax Credits ("ITC") equal to the incremental ITC generated from the Company's investment in 2023 battery storage projects, including augmentation costs. In addition, the ADITC cap previously set at $25 million was removed. Next, it was modified 12 In the Matter of Idaho Power Company's Application for Authority to Implement Power Cost Adjustment (PCA) Rates for Electric Service from June 1, 2021 through May 31, 2022, IPC-E-21-10, Order No. 35054, p. 5 (May 28, 2021). 13 Idaho Power Company's Application for Modification of the Power Cost Adjustment Mechanism, Case No. IPC-E-21-38, Order No. 35290, p. 2-3 (Jan. 10, 2022). 14 In the Matter of the Application of Idaho Power Company for Authority to Increase its Rates and Charges for Electric Service in the State of Idaho and for Associated Regulatory Accounting Treatment, Case No. IPC-E-23-11, Order No. 36042 (Dec. 28, 2023). APPLICATION - 7 so that potential revenue sharing between Idaho Power and customers of Idaho- jurisdictional earnings will occur if earnings are in excess of 9.6 percent, and also provided that all revenue sharing be implemented only through the PCA, rather than a portion offsetting customer-funded pension obligations as was done previously. In addition to updating the maximum Idaho ROE for earnings sharing to 9.6 percent, the minimum- specified Idaho ROE was set at 9.12 percent (95 percent of the stipulated 9.6 percent). This is the first PCA filing impacted by the stipulated modifications, which became effective January 1, 2024. 14. The settlement stipulation in the Company's 2023 GRC also implemented a Commission mandate stemming from the 2013 PCA case for the Company to include third-party wheeling revenue differences in the PCA once a base level of revenue was set in a general rate case.15 As part of the Commission-approved settlement in the 2023 GRC, the parties agreed that the Idaho-jurisdictional amount of$46,361,643 in third-party point-to-point wheeling revenues would serve as the baseline for potential tracking of these revenues. Case No. IPC-E-24-38 15. Following the conclusion of the 2023 GRC, Idaho Power developed, with input from Staff, a proposed methodology to track wheeling revenues in the PCA, which it presented to the Commission in Case No. IPC-E-24-38 filed on October 7, 2024. 16. In Order No. 36502 issued on March 11, 2025, the Commission approved the Company's request to track annual wheeling revenues in the PCA, and its proposal 15 In the Matter of the Application of Idaho Power Company for Authority to Implement Power Cost Adjustment(PCA) Rates for Electric Service From June 1, 2013, Through May 31, 2014, Case No. IPC-E- 13-10, Order No. 32796 (Apr. 23, 2013). APPLICATION - 8 to implement a transmission wheeling revenue tracking mechanism that would measure the difference between actual wheeling revenues and a sales-adjusted baseline level of wheeling revenues as a component of the Balancing Adjustment, effective April 2024.16 II. 2025-2026 PCA OVERVIEW 17. The PCA is a rate mechanism that quantifies and tracks annual differences between actual NPSE and the normalized or "base level" of NPSE recovered in the Company's base rates, resulting in a credit or surcharge that is updated annually on June 1. The PCA mechanism utilizes a 12-month test period of April through March ("PCA Year") and consists of a forecast component and a Balancing Adjustment (formerly referred to as the "true-up" and the "true-up of the true-up") as more fully described below. 18. The PCA mechanism allows the Company to pass to Idaho customers 95 percent of the annual differences in actual NPSE as compared to the base level NPSE, whether positive or negative, with the exception of PUPRA expenses and demand response incentive payments. With respect to those expenses, when actual annual expenses deviate from base level NPSE, the Company is allowed to pass 100 percent of the difference for recovery or credit through the PCA. In addition, beginning with this year's PCA filing, Idaho Power is requesting to include recovery of the capital lease payments associated with the Kuna Battery Energy Storage System ("BESS") at 100 percent.17 The PCA is also the rate mechanism used by the Company to provide 16 In the Matter of Idaho Power Company's Filing in Compliance with Order No. 36402 for Authority to Track Annual Wheeling Revenues in the Power Cost Adjustment, Case No. IPC-E-24-38, Order No. 36502 (Mar. 11, 2025). " In the Matter of the Application for CPCN to acquire resources to be online in both 2024 and 2025 and for Approval of an Energy Storage Agreement with Kuna BESS LLC, Case No. IPC-E-23-20, Order No. 36011 (Nov. 27, 2023) (approving the Company's Application for a Certificate of Public Convenience and Necessity for the Kuna BESS, acknowledging the expenses as prudently incurred for ratemaking purposes, and acknowledging the necessary lease accounting necessary to facility the transaction). APPLICATION - 9 customer benefits resulting from the Revenue Sharing mechanism originally approved in Order No. 34071. PCA Forecast Component 19. The PCA forecast component represents the difference between the Company's NPSE forecast from its March Operating Plan and the base level NPSE recovered in the Company's base rates. 20. The Brady Testimony describes and computes the PCA rate to be effective June 1, 2025, through May 31, 2026. The system-level forecast of NPSE for the 2025- 2026 PCA Year is $563,563,648, which is $78,656,404 higher than the currently approved base level NPSE of $484,907,244, and $54,007,658 higher than last year's forecast amount of $509,555,990. 21. As described in Ms. Brady's testimony, the difference between the system- level forecast of NPSE and the currently approved base level NPSE is adjusted for the PCA sharing provisions and allocated to Idaho customers to determine the 2025-2026 PCA forecast component to be collected from Idaho customers of $73,092,256. PCA Balancing Adjustment 22. Per Order No. 35290,18 the "true-up" and the "true-up of the true-up" have been combined into a single Balancing Adjustment, which includes a backward-looking tracking of differences between the prior PCA Year's forecast and actual NPSE incurred by the Company, and also tracks the collection of the prior year's Balancing Adjustment. In addition, as approved by the Commission in Order No. 36502, beginning with this year's PCA filing, the Balancing Adjustment tracks the annual variance between actual and '$ Case No. IPC-E-21-38. APPLICATION - 10 base-level wheeling revenues. However, this year's Balancing Adjustment did not include Western Energy Imbalance Market ("EIM") participation costs because those were included in base rates resulting from the Company's 2023 GRC, which went into effect on January 1, 2024; as a result, EIM costs are no longer included in the PCA as of that date. Benefits associated with EIM participation are embedded in actual NPSE. 23. The PCA Balancing Adjustment deferral balance at the end of March 2025, with interest applied, was approximately negative $52 million, which represents a decrease to customers rates in this year's PCA Balancing Adjustment. Actual power supply expenses in the 2024-2025 PCA Year were just 2 percent lower than forecast expenses. As a result, the variance between forecast and actual power supply expenses for the 2024-2025 PCA Year had a relatively small impact on this year's deferral balance. However, this year's deferral balance does include increased benefits associated with the SBA, which accounts for the variance in actual sales and the sales used to set base level NPSE, as well as increased Renewable Energy Credit ("REC") sales, wheeling revenues, and liquidated damages associated with the delayed commissioning of BESS resources as more fully discussed in the Brady Testimony. 24. This year's Balancing Adjustment also includes two other items that resulted in an additional credit to customers: 1) in accordance with Order No. 36048 issued in Case No. IPC-E-23-14, a one-time adjustment to recover the conversion of accumulated kWh credits into a financial credit for commercial, irrigation, and industrial customers19 and 2) a one-time adjustment to credit the difference between February and January base 11 See, In the Matter of the Application of Idaho Power Company for Authority to Implement Changes to the Compensation Structure Applicable to Customer On-Site Generation Under Schedules 6, 8, and 84 and to Establish and Export Credit Rate, Case No. IPC-E-23-14, Order No. 36048 (Dec. 29, 2023). APPLICATION - 11 rates, as a result of the Errata issued on January 21, 2025 in the Company's filing to recover incremental capital investments and certain ongoing operations and maintenance expenses.20 A cents per kwh rate for these two adjustments was calculated for each individual rate class and added to the overall Balancing Adjustment Rate as described in the Brady Testimony. Revenue Sharing 25. The Revenue Sharing mechanism allows the Company to amortize ADITC when earnings fall below a certain Idaho ROE threshold or share a portion of revenues with Idaho customers in the form of a rate reduction when earnings are above a certain ROE threshold. The Company's earnings in each year from 2011 through 2015, as well as 2018 and 2021, resulted in revenue sharing with Idaho customers totaling $126.7 million, either as a direct rate offset in the PCA or as an offset to amounts that would have otherwise been collected in rates. The Company's earnings in 2016, 2017, 2019, 2020, 2022, and 2023 were below the revenue sharing threshold. 26. As a result of the Company's 2023 GRC, effective January 1, 2024, potential revenue sharing between Idaho Power and customers will occur if earnings are in excess of a 9.6 percent Idaho ROE. In addition, all revenue sharing will be implemented through the PCA, rather than a portion offsetting customer-funded pension obligations. Lastly, the minimum-specified Idaho ROE is 9.12 percent. 27. As described in greater detail in the Brady Testimony, the Company's year-end 2024 financial results yielded an actual Idaho ROE of 8.19 percent, falling 20 In the Matter of the Application of Idaho Power Company to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses, Case No. IPC-E-24-07, Errata to Order No. 36438 (Jan. 21, 2025). APPLICATION - 12 below the 9.6 percent ROE threshold for revenue sharing. Therefore, the 2025-2026 PCA will not include a revenue sharing component. Moreover, because the Company's Idaho ROE was below the 9.12 percent minimum threshold, the Company utilized approximately $30 million of ADITC to achieve the minimum specified ROE of 9.12 percent. III. 2025-2026 PCA AND PROPOSED RATE CHANGES 28. The 2025-2026 PCA rates proposed in this case would result in total PCA collection of $21.0 million. This represents a decrease in total billed revenue of $94.8 million for the upcoming year, a decrease of 5.89 percent. Table 1 below presents a separation of the $94.8 million decrease into each component included in the Company's proposed rates as more fully explained above. Table 1 Revenue Impact by Component Line No. Rate Component 2024-2025 PCA 2025-2026 PCA Difference 1 PCA Forecast $ 23,342,867 $ 73,092,256 $ 49,749,389 2 PCA Balancing Adjustment $ 92,469,480 $ (52,064,539) $ (144,534,019) 3 PCA Total $ 115,812,347 $ 21,027,717 $ (94,784,630) 4 Revenue Sharing $ 0 $ 0 $ 0 5 Total Revenue Impact $ 115,812,347 $ 21,027,717 $ (94,784,630) 29. The decrease in this year's PCA is driven by a decrease in the Balancing Adjustment, partially offset by an increase in the forecast component. The decrease in this year's Balancing Adjustment is largely attributed to the completed recovery of the 2023 PCA balancing adjustment, which was recovered over two years per Order No. 35804. Additional factors as discussed above include the SBA, an increase in REC sales, a credit related to the variance in actual wheeling revenues as compared to the levels recovered in base rates, and a credit for liquidated damages associated with the delayed commissioning of certain BESS resources. APPLICATION - 13 PCA Rate Determination 30. The Brady Testimony describes in detail how this year's rates for the forecast portion and the Balancing Adjustment were determined, and the resulting uniform PCA rate when all components are combined, which for the 2025-2026 PCA Year is comprised of (1) the 0.4700 cents per kilowatt-hour ("kWh") for the 2025-2026 projected power cost of serving firm loads under the current PCA methodology and 95 percent sharing, and (2) the negative 0.3347 cents per kWh for the 2024-2025 Balancing Adjustment. The sum of these two components results in a summary rate of 0.1354 cents per kWh. Additionally, the two one-time adjustments, as described above and in the Brady Testimony, resulted in an additional decrease to the Balancing Adjustment of $13,372, which was applied at the class level; more specifically, the cents per kwh rates associated with these two adjustments were added to the Balancing Adjustment Rate of negative 0.3347 cents per kwh to determine class-specific Balancing Adjustment Rates. Cumulative Proposed June 1, 2025, Rate Changes 31. PCA. The 2025-2026 total PCA amount, as measured from the currently approved base level NPSE is $21.0 million. This represents a decrease in total billed revenue of $94.8 million, or 5.89 percent, for Idaho customers, effective June 2025 through May 2026. 32. Fixed Cost Adjustment ("FCA"). On March 15, 2025, Idaho Power filed its annual FCA in Case No. IPC-E-25-11. The Company's 2025 FCA filing proposes a $40.7 million decrease in current billed revenue, or a 5.28 percent decrease, for Idaho Residential and Small General Service customers, effective June 2025 through May 2026. APPLICATION - 14 33. Hells Canyon Complex Relicensing_ On March 14, 2025, Idaho Power filed a request to increase rates to recover incremental Allowance for Funds Used During Construction ("AFUDC") costs associated with the Hells Canyon Complex ("HCC") relicensing project. The Company proposes a $29.7 million dollar increase, effective June 1, 2025, or a 1.85 percent increase to billed revenue. 34. Combined Effect of the PCA, FCA, and HCC Filings. If the proposed PCA, FCA, and HCC rate changes are approved as filed, the combined impact is an overall decrease in current billed revenue of $105.8 million, or 6.57 percent, for June 2025 through May 2026. 35. Attachment 1 to this Application is Idaho Power's proposed IPUC No. 30, Tariff No. 101, in both clean and legislative formats, which contains the tariff sheets specifying the proposed Schedule 55 rates for providing retail electric service to its customers in the state of Idaho for June 1, 2025, through May 31, 2026. 36. Attachment 2 to this Application contains a summary of revenue impact showing the effect to each customer class of applying the Company's proposed PCA rates that collect $94.8 million less, from June 2025 through May 2026, than the PCA rates currently in effect. IV. MODIFIED PROCEDURE 37. Idaho Power believes that a technical hearing is not necessary to consider the issues presented herein and respectfully requests that this Application be processed under Modified Procedure, i.e., by written submissions rather than by hearing. RP 201, et seq. If, however, the Commission determines that a technical hearing is required, the Company stands ready to present its testimony, including but limited to the Brady APPLICATION - 15 Testimony filed contemporaneously herewith, and support the Application in such hearing. V. COMMUNICATIONS AND SERVICE OF PLEADINGS 38. In conformance with RP 125, this Application will be brought to the attention of Idaho Power's customers by means of a press release to media in the Company's service area and a customer notice distributed in customers' bills, both of which accompany this filing. The customer notice will be distributed over the course of the Company's current billing cycles, and additionally, to ensure that all customers are notified in a timely manner and have sufficient time to submit comments, Idaho Power is sending a direct mail postcard to a subset of customers that receive their bill toward the end of the processing time for this case. As such, a bill insert and/or the direct mail postcard will be mailed no later than May 20, 2025. 39. The Company has also prominently displayed its intent to file the PCA on its website since March 15, 2025. Upon filing of this Application, this web graphic will link directly to the PCA press release and bill insert. Idaho Power will also keep its Application, testimonies, and exhibits open for public inspection at its offices throughout the state of Idaho. Idaho Power asserts that this notice procedure satisfies the Rules of Procedure of this Commission; however, the Company will, in the alternative, bring the Application to the attention of its affected customers through any other means directed by this Commission. 40. Communications and service of pleadings with reference to this Application should be sent to the following: APPLICATION - 16 Megan Goicoechea Allen Matthew T. Larkin Donovan Walker Timothy E. Tatum Regulatory Dockets Jessi Brady Idaho Power Company Idaho Power Company 1221 West Idaho Street (83702) 1221 West Idaho Street (83702) P.O. Box 70 P.O. Box 70 Boise, Idaho 83707 Boise, Idaho 83707 mgoicoecheaallen(o-)idahopower.com mlarkin(cDidahopower.com dwalker .idahopower.com ttatum idahopower.com dockets(a)idahopower.com jbrady(a)idahopower.com VI. REQUEST FOR RELIEF 41. As discussed in greater detail above, Idaho Power respectfully requests that the Commission issue an order: (1) authorizing that this matter be processed by Modified Procedure and (2) approving an update to Schedule 55 based on the quantification of the 2025-2026 PCA, resulting in an overall decrease to current billed revenue of approximately $94.8 million to become effective June 1, 2025. DATED at Boise, Idaho, this 15' day of April 2025. Awrt, I MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company APPLICATION - 17 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-25-20 IDAHO POWER COMPANY ATTACHMENT NO. 1 PROPOSED SCHEDULE 55 (CLEAN AND LEGISLATIVE FORMAT) Idaho Power Company Second Revised Sheet No. 55-1 Cancels I.P.U.C. No. 30, Tariff No. 101 First Revised Sheet No. 55-1 SCHEDULE 55 POWER COST ADJUSTMENT APPLICABILITY This schedule is applicable to the electric energy delivered to all Idaho retail Customers served under the Company's schedules and Special Contracts listed within this schedule. These loads are referred to as "firm" load for purposes of this schedule. BASE POWER COST AND PROJECTED POWER COST The Base Power Cost of the Company's rates, expressed in cents per kWh, is computed by dividing the sum of the Company's power cost components by firm kWh sales. The power cost components are segmented into three categories as described in the table below: The Projected Power Cost is the Company estimate, expressed in cents per kWh, of the power cost components for the forecasted time period beginning April 1 each year and ending the following March 31. BALANCING ADJUSTMENT The Balancing Adjustment is based upon the differences between previous Projected Power Cost and the power costs actually incurred. The Balancing Adjustment varies by rate class and is included in the table below. EARNINGS SHARING Order Nos. 30978, 32424, 33149, 34071, and 36042 directed the Company to share a portion of its earnings above a certain threshold with customers through the annual Power Cost Adjustment. The Company's 2024 earnings were not above the prescribed threshold resulting in a credit of 0.0000 cents per kWh. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs Effective — June 1, 2025 1221 West Idaho Street, Boise, Idaho Idaho Power Company Second Revised Sheet No. 55-2 Cancels I.P.U.C. No. 30, Tariff No. 101 First Revised Sheet No. 55-2 SCHEDULE 55 POWER COST ADJUSTMENT (Continued) POWER COST ADJUSTMENT The Power Cost Adjustment (PCA) is the sum of: 1) 95 percent of the difference between the Projected Power Costs in Category 1 and the Base Power Costs in Category 1; 2) 100 percent of the difference between the Projected Power Costs in Category 2 and the Base Power Costs in Category 2; 3) 100 percent of the difference between the Projected Power Costs in Category 3 and the Base Power Costs in Category 3; 4) 100 percent of the difference between the Projected Power Costs in Category 4 and the Base Power Costs in Category 4; 5) the Balancing Adjustment; and 6) Earnings Sharing. The following table calculates the rates for Categories 1, 2, 3, and 4. The following table shows the determination of PCA rates for Categories 1, 2, 3, and 4: Base Projected Sharing Category Description Power Power Difference % Rate Cost Cost (¢ per kWh) The sum of fuel expense and purchased power expense (excluding purchases from 1 cogeneration and small power 1.60371 1.89897 0.29526 95% 0.28050 producers), less the sum of off- system surplus sales revenue and revenue from market-based special contract pricing. Purchased power expense from 2 cogeneration and small power 1.32163 1.39941 0.07778 100% 0.07778 producers. 3 Demand response incentive 0.06585 0.06695 0.00110 100% 0.00110 payments. 4 Payments for battery energy 0.00000 0.11066 0.11066 100% 0.11066 storage system leases Total 2.99119 3.47599 0.48480 0.47004 IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs Effective —June 1, 2025 1221 West Idaho Street, Boise, Idaho Idaho Power Company Second Revised Sheet No. 55-3 Cancels I.P.U.C. No. 30, Tariff No. 101 First Revised Sheet No. 55-3 SCHEDULE 55 POWER COST ADJUSTMENT (Continued) The monthly Power Cost Adjustment rates applied to the Energy rate of all metered schedules and Special Contracts are shown below. The monthly Power Cost Adjustment applied to the per unit charges of the nonmetered schedules is the monthly estimated usage times the cents per kWh rates shown below. Totals may not tie due to rounding. Balancing Earning Total PCA Schedul Adjustment s e Cate or Sharin 1 2 3 4 1 0.2805 0.0778 0.0011 0.1107 0.3351 0.0000 0.1349 3 0.2805 0.0778 0.0011 0.1107 0.3351 0.0000 0.1349 5 0.2805 0.0778 0.0011 0.1107 0.3351 0.0000 0.1349 6 0.2805 0.0778 0.0011 0.1107 0.3350 0.0000 0.1350 7 0.2805 0.0778 0.0011 0.1107 0.3353 0.0000 0.1347 8 0.2805 0.0778 0.0011 0.1107 0.3355 0.0000 0.1345 9S 0.2805 0.0778 0.0011 0.1107 0.3346 0.0000 0.1354 9P 0.2805 0.0778 0.0011 0.1107 0.3350 0.0000 0.1350 9T 0.2805 0.0778 0.0011 0.1107 0.3349 0.0000 0.1351 15 0.2805 0.0778 0.0011 0.1107 0.3357 0.0000 0.1343 19S 0.2805 0.0778 0.0011 0.1107 0.3350 0.0000 0.1350 19P 0.2805 0.0778 0.0011 0.1107 0.3348 0.0000 0.1352 19T 0.2805 0.0778 0.0011 0.1107 0.3348 0.0000 0.1352 24 0.2805 0.0778 0.0011 0.1107 0.3340 0.0000 0.1360 40 0.2805 0.0778 0.0011 0.1107 0.3349 0.0000 0.1351 41 0.2805 0.0778 0.0011 0.1107 0.3354 0.0000 0.1346 42 0.2805 0.0778 0.0011 0.1107 0.3352 0.0000 0.1348 26 0.2805 0.0778 0.0011 0.1107 0.3347 0.1353 29 0.2805 0.0778 0.0011 0.1107 0.3348 0.1352 30 0.2805 0.0778 0.0011 0.1107 0.3348 0.1352 32 0.2805 0.0778 0.0011 0.1107 0.3348 0.1352 34 0.2805 0.0778 0.0011 0.1107 (0.3348) 0.1352 * Earnings Sharing Credits are applied as monthly amounts per the table below. Schedule Special Contract Monthly Credit 26 Micron $0.00 29 Simplot $0.00 30 DOE $0.00 32 Simplot-Caldwell $0.00 34 Lamb Weston $0.00 EXPIRATION The Power Cost Adjustment included on this schedule will expire May 31, 2026. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs Effective - June 1, 2025 1221 West Idaho Street, Boise, Idaho Idaho Power Company Forst Second Revised Sheet No. 55-1 Cancels I.P.U.C. No. 30, Tariff No. 101 94q+aa4-First Revised Sheet No. 55-1 SCHEDULE 55 POWER COST ADJUSTMENT APPLICABILITY This schedule is applicable to the electric energy delivered to all Idaho retail Customers served under the Company's schedules and Special Contracts listed within this schedule. These loads are referred to as "firm" load for purposes of this schedule. BASE POWER COST AND PROJECTED POWER COST The Base Power Cost of the Company's rates, expressed in cents per kWh, is computed by dividing the sum of the Company's power cost components by firm kWh sales. The power cost components are segmented into three categories as described in the table below: The Projected Power Cost is the Company estimate, expressed in cents per kWh, of the power cost components for the forecasted time period beginning April 1 each year and ending the following March 31. BALANCING ADJUSTMENT The Balancing Adjustment is based upon the differences between previous Projected Power Cost and the power costs actually incurred. The Balancing Adjustment is 0.5946 GeRtS per 1AA"varies by rate class and is included in the table below. EARNINGS SHARING Order Nos. 30978, 32424, 33149, a d-34071, and 36042 -directed the Company to share a portion of its earnings above a certain threshold with customers through the annual Power Cost Adjustment. The Company's 20234 earnings were not above the prescribed threshold resulting in a credit of 0.0000 cents per kWh. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No.-36202 Timothy E. Tatum, Vice President, Regulatory Affairs Effective— duae-1, 2024June 1, 2025 1221 West Idaho Street, Boise, Idaho Idaho Power Company Forst Second Revised Sheet No. 55-2 Cancels I.P.U.C. No. 30, Tariff No. 101 Q4g+Ra4-First Revised Sheet No. 55-2 SCHEDULE 55 POWER COST ADJUSTMENT (Continued) POWER COST ADJUSTMENT The Power Cost Adjustment (PCA) is the sum of: 1) 95 percent of the difference between the Projected Power Costs in Category 1 and the Base Power Costs in Category 1; 2) 100 percent of the difference between the Projected Power Costs in Category 2 and the Base Power Costs in Category 2; 3) 100 percent of the difference between the Projected Power Costs in Category 3 and the Base Power Costs in Category 3; 4) 100 percent of the difference between the Protected Power Costs in Category 4 and the Base Power Costs in Category 4; 5) the Balancing Adjustment; and 56) Earnings Sharing. The following table calculates the rates for Categories 1, 2.3 -and 43. The following table shows the determination of PCA rates for Categories 1, 2,3 and 48: Base Projected Sharing Category Description Power Power Difference % Rate Cost Cost (¢ per kWh) The sum of fuel expense and purchased power expense (excluding purchases from cogeneration and small power 1�48241_6 91 0.122450. ° Q.i 16330. 1 producers), less the sum of off- 0371 .89897 29526 95/0 28050 system surplus sales revenue and revenue from market-based special contract pricing. Purchased power expense from 81_3 1.390921 0.032590. 0.v 032590. 2 cogeneration and small power 2163 .39941 07778 100% 07778 producers. Demand response incentive 0.067670_0 0.068910 0.001130. ° 0.001130. 3 payments. 6585 .06695 00110 100/° 00110 4 Payments for battery energy 0.00000 0.11066 0.11066 100% 0.11066 storage system leases �.^�42_9 3.'�r3 0�0. 0A 50050. Total 9119 .47599 48480 47004 IDAHO Issued by IDAHO POWER COMPANY Issued per Order No.-36202 Timothy E. Tatum, Vice President, Regulatory Affairs Effective—iURe 1, 2024June 1, 2025 1221 West Idaho Street, Boise, Idaho Idaho Power Company Forst Second Revised Sheet No. 55-3 Cancels I.P.U.C. No. 30, Tariff No. 101 Orig1Pa4First Revised Sheet No. 55-3 SCHEDULE 55 POWER COST ADJUSTMENT (Continued) The monthly Power Cost Adjustment rates applied to the Energy rate of all metered schedules and Special Contracts are shown below. The monthly Power Cost Adjustment applied to the per unit charges of the nonmetered schedules is the monthly estimated usage times the cents per kWh rates shown below. Totals may not tie due to rounding. Balancing Earning Total PCA Schedul Adjustment s e Cate [y Sharing 1 2 3 4 9.1630.28 0.03260_0 0.0011 0.1107 0.5946 0( 3351 (0.0000) 05 778 0.74470.134 1 9 0.11630.28 0.03260_0 0.0011 0.1107 0.5946 0( 3351 (0.0000) 0.74470.134 3 05 778 9 0.11630.28 0.03260_0 0.0011 0.1107 9.5946 0.3351 (0.0000) 0.74470.134 5 05 778 9 0.11630.28 0.03260_0 0.0011 0.1107 0.5946 0( 3350 (0.0000) 0.74470.135 6 05 778 0 0.11630.28 0.03260_0 0.0011 0.1107 9.5946 0.3353 (0.0000) 0.74470.134 7 05 778 7 0.11630.28 0.03260_0 0.0011 0.1107 8.5946 0.3355 (0.0000) 0.74470.134 8 05 778 5 0.11630.28 0.03260_0 0.0011 0.1107 0.5946 0( 3346 (0.0000) 9:74470.135 9S 05 778 4 9.11630.28 0.03260_0 0.0011 0.1107 0.5946 0( 3350 (0.0000) 0.74470.135 9P 05 778 0 0.11630.28 0.03260_0 0.0011 0.1107 9.5946 0.3349 (0.0000) 0.74470.135 9T 05 778 1 0.11630.28 0.03260_0 0.0011 0.1107 �0-.59460.3357 (0.0000) 0.74470.134 15 05 778 3 0.11630.28 0.03260_0 0.0011 0.1107 9.5946 0.3350 (0.0000) 0.74470.135 19S 05 778 0 0.11630.28 0.03260_0 0.0011 0.1107 8.5946 0( 3348 (0.0000) 0.74470.135 19P 05 778 2 0.11630.28 0.03260_0 0.0011 0.1107 9.5946 0.3348 (0.0000) 9:74470.135 19T 05 778 2 0.11630.28 0.03260_0 0.0011 0.1107 0.5946 0( 3340 (0.0000) 9:74470.136 24 05 778 0 0.11630.28 0.03260_0 0.0011 0.1107 8.5946 0( 3349 (0.0000) 0.74470.135 40 05 778 1 0.11630.28 0.03260_0 0.0011 0.1107 8.5946 0.3354 (0.0000) 0.74470.134 41 05 778 6 0.11630.28 0.03260_0 0.0011 0.1107 8.5946 0.3352 (0.0000) 9 4470.134 42 05 778 8 IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. 36202 Timothy E. Tatum, Vice President, Regulatory Affairs Effective-iURe 1, 2024June 1, 2025 1221 West Idaho Street, Boise, Idaho Idaho Power Company Forst Second Revised Sheet No. 55-3 Cancels I.P.U.C. No. 30 Tariff No. 101 First Revised Sheet No. 55-3 0-1630.28 0.03260.0 0.0011 0.1107 0.5946 0( 3347 0.74470.135 26 05 778 3 0.11630.28 0.03260_0 0.0011 0.1107 0.5946 0.3348 0.74470.135 29 05 778 2 0.11630.28 0.03260_0 0.0011 0.1107 0.5946 0( 3348 0.74470.135 30 05 778 2 0.11630.28 0.03260_0 0.0011 0.1107 0.5946 0( 3348 0.74470.135 32 05 778 2 0.11630.28 0.03260_0 0.0011 0.1107 0.5946 0.3348 0.74470.135 34 05 778 2 * Earnings Sharing Credits are applied as monthly amounts per the table below. Schedule Special Contract Monthly Credit 26 Micron $0.00 29 Simplot $0.00 30 DOE $0.00 32 Simplot-Caldwell $0.00 34 Lamb Weston $0.00 EXPIRATION The Power Cost Adjustment included on this schedule will expire May 31, 20256. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No.-36202 Timothy E. Tatum, Vice President, Regulatory Affairs Effective—iURe 1, 2024June 1, 2025 1221 West Idaho Street, Boise, Idaho BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-25-20 IDAHO POWER COMPANY ATTACHMENT NO. 2 2025 REVENUE IMPACT SUMMARY Idaho Power Company Calculation of Revenue Impact State of Idaho PC Filed A 15,2025 Summary of Revenue Impact Current Billed Revenue to Proposed Billed Revenue Total Percent Rate Average Normalized Current Adjustments Proposed Change Line Sch. Number of Energy Billed Mills to Billed Billed Mills Billed to Billed No Tariff Description No. Customers l'I (kWh) Revenue Per kWh Revenue Revenue Per kWh Revenuer) Uniform Tariff Rates: 1 Residential Service 1 524,237 5,615,942,611 $714,057,042 127.15 ($34,246,018) $679,811,024 121.05 (4.80)% 2 Master Metered Mobile Home Park 3 19 5,043,898 $613,244 121.58 ($30,758) $582,486 115.48 (5.02)% 3 Residential Service Time-of-Day 5 990 17,907,943 $2,197,568 122.71 ($109,203) $2,088,366 116.62 (4.97)% 4 Residential Service On-Site Generation 6 19,350 258,375,457 $31,811,157 123.12 ($1,575,316) $30,235,841 117.02 (4.95)% 5 Small General Service 7 30,219 139,926,373 $21,483,300 153.53 ($853,551) $20,629,749 147.43 (3.97)% 6 Small General Service On-Site Generation 8 87 768,473 $94,452 122.91 ($4,689) $89,763 116.81 (4.96)% 7 Large General Service 9 40,122 4,068,443,436 $373,765,920 91.87 ($24,791,657) $348,974,263 85.78 (6.63)% 8 Dusk to Dawn Lighting 15 0 1,937,298 $1,357,634 700.79 ($11,825) $1,345,809 694.68 (0.87)% 9 Large Power Service 19 134 2,192,917,988 $166,776,995 76.05 ($13,365,848) $153,411,147 69.96 (8.01)% 10 Agricultural Irrigation Service 24 19,847 1,770,258,152 $183,663,718 103.75 ($10,775,561) $172,888,157 97.66 (5.87)% 11 Un m,tered General Service 40 1,857 14,484,473 $1,531,179 105.71 ($88,297) $1,442,882 99.62 (5.77)% 12 Street Lighting 41 1,687 20,419,614 $4,014,958 196.62 ($124,587) $3,890,371 190.52 (3.10)% 13 Traffic Control Lighting 42 859 3,056,155 $257,756 84.34 ($18,639) $239,117 78.24 (7.23)% 14 Total Uniform Tariffs 639,408 14,109,481,872 $1,501,624,923 106.43 ($85,995,950) $1,415,628,973 100.33 (5.73)% 15 Total Special Contracts 7 1,442062,021 $106,512,215 73.86 ($8,788,680) $97,723,535 67.77 (8.25)% 16 Total Clean Energy Your Way Sales 18:839,401 $253,654 $0 $253,654 0.00% 17 Idaho Power Supplied Retail Sales Rt 639,415 15,570,383,294 1,608,390,792 103.30 (94,794,630) 1,513,606,162 97.21 (5.89)% (1)Test Year Revenue Forecast Jun 2025-May 2026 (2)Impacts do not include Clean Energy Your Way and marginal energy sales Idaho Power Company Calculation of Revenue Impact State of Idaho PC Filed A 15,2025 Summary of Revenue Impact-Rates 9,19,and 24 Distribution Level Detail Current Billed Revenue to Proposed Billed Revenue Percent Rate Average Normalized Current Adjustments Proposed Change Line Sch. Number of Energy Base Mills to Base Base Mills Base to Base No Tariff Description No. Customers(1) k((kWh) Revenue Per kWh Revenue Revenue Per kWh Revenue Uniform Tariff Rates: 1 Large General Secondary 9S 39,824 3,409,784,142 $319,189,998 93.61 ($20,775,815) $298,414,183 87.52 (6.51)% 2 Large General Primary 9P 292 655,067,733 $54,240,339 82.80 ($3,993,948) $50,246,391 76.70 (7.36)% 3 Large General Transmission 9T 6 3,591,562 $335,584 93.44 ($21,894) $313,689 87.34 (6.52)% 4 Total Schedule 9 40.122 4,068,443,436 $373,765,920 91.87 ($24,791,657) $348,974,263 85.78 (6.63)% 5 Large Power Secondary 195 1 6,446,801 $531,259 82.41 ($39,306) $491,953 76.31 (7.40)% 6 Large Power Primary 19P 130 2,147,461,978 $163,389,724 76.09 ($13,088,781) $150,300,943 69.99 (8.01)% 7 Large Power Transmission 19T 3 39,009,209 $2,856,012 73.21 ($237,761) $2,618,251 67.12 (8.32)% 8 Total Schedule 19 134 2,192,917,988 $166,776,995 76.05 ($13,365,848) $153,411,147 69.96 (8A1)% 9 Irrigation Secondary 24S 19,847 1,770,258,152 $183,663,718 103.75 ($10,775,561) $172,888,157 97.66 (5.87)% 10 Irrigation Transmission 24T 0 0 $0 0.00 $0 $0 0.00 0.00% 11 Total Schedule 24 19,847 1,770,258,152 $183,663,718 103.75 ($10,775,561) $172,888,157 97.66 (5.87)% (1)Test Year Revenue Forecast Jun 2025-May 2026