20250508Direct Maloney.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-25-22
AUTHORITY TO UPDATE ITS )
OPERATION AND MAINTENANCE )
CHARGES APPLICABLE TO SCHEDULE )
72, GENERATOR INTERCONNECTIONS )
TO PURPA QUALIFYING FACILITY )
SELLERS . )
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
RILEY MALONEY

1 Q. Please state your name, business address, and
2 present position with Idaho Power Company ("Idaho Power" or
3 "Company") .
4 A. My name is Riley Maloney. My business address
5 is 1221 West Idaho Street, Boise, Idaho 83702 . I am
6 employed by Idaho Power as a Policy and Strategy Leader in
7 the Regulatory Affairs Department.
8 Q. Please describe your educational background.
9 A. I received a Bachelor of Arts degree in
10 Economics from Boise State University in 2013 . I have also
11 attended "The Basics : Practical Regulatory Training for the
12 Electric Industry, " an electric utility ratemaking course
13 offered through the New Mexico State University' s Center
14 for Public Utilities, "Electric Utility Fundamentals and
15 Insights, " an electric utility course offered by Western
16 Energy Institute, "Electric Rates Advanced Course, " an
17 electric utility ratemaking course offered through Edison
18 Electric Institute, and "Utility Finance and Accounting for
19 Finance Professionals, " a utility-focused finance and
20 accounting course offered through the Financial Accounting
21 Institute .
22 Q. Please describe your work experience with
23 Idaho Power.
24 A. In 2020 I was hired as a Regulatory Analyst
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Idaho Power Company

1 in the Company' s Regulatory Affairs Department. My primary
2 responsibilities at the time included supporting activities
3 involving tariff administration and regulatory compliance
4 filings . I also provided regulatory support to the
5 Company' s operations business units to ensure consistent
6 application of the Company' s rules and regulations,
7 authorized by its Commission-approved tariff and in 2023,
8 my responsibilities were expanded to support the Company' s
9 class cost-of-service activities . In April 2025, I was
10 promoted to my current role of Regulatory Policy and
11 Strategy Leader where my responsibilities include
12 overseeing regulatory support and strategic guidance on a
13 variety of topics including integrated resource planning,
14 demand-side management, distribution system planning, and
15 wildfire-related activities .
16 Q. What is the purpose of your testimony in
17 this matter?
18 A. My testimony will first provide a brief
19 regulatory background related to the Operation and
20 Maintenance ("O&M") charges contained in Schedule 72 . I
21 will then explain the Company' s proposed update to Schedule
22 72' s 0&M charges that are requested to be effective January
23 1, 2026 .
Maloney, DI 3
Idaho Power Company

1 I . BACKGROUND
2 Q. Please provide an overview of the
3 availability and applicability of Schedule 72 .
4 A. Schedule 72 is available to Sellers owning
5 or operating Qualifying Facilities ("QFs") that sign a
6 Uniform Interconnection Agreement. Service under Schedule
7 72 applies to the construction, operation, maintenance,
8 upgrade, relocation, or removal of transmission and/or
9 distribution lines and equipment necessary to safely
10 interconnect a seller' s generation facility to the
11 Company' s system.
12 Q. When was Schedule 72 established?
13 A. Schedule 72 was initially implemented in a
14 1990 case as the Commission approved the process to
15 facilitate the interconnection of QF generation to Idaho
16 Power' s system, in accordance with the provisions of the
17 Public Utility Regulatory Policies Act of 1978 ("PURPA") .
18 Prior to the establishment of Schedule 72, interconnection
19 requirements for QFs were provided for as part of the Power
20 Purchase Agreement negotiated between the Company and the
21 QF.
22 Q. Please explain the purpose of the O&M charge
23 contained within Schedule 72 .
24 A. When a PURPA project interconnects to the
25 Company' s facilities, the project pays the capital costs of
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Idaho Power Company

1 the facilities necessary to connect the project to the
2 Company' s system. Once completed, ownership of these
3 facilities prior to the QF' s interconnection point
4 transfers to the Company, which then assumes responsibility
5 for all ongoing 0&M expenses . The charge within Schedule 72
6 represents a monthly 0&M charge ("O&M Charge") designed to
7 reimburse the Company for the costs, using system averages,
8 associated with operating and maintaining such
9 interconnection facilities . These charges are necessary to
10 ensure the Company' s general body of customers do not
11 shoulder the ongoing 0&M of the facilities caused by the
12 addition of the QF project.
13 Q. How does the 0&M Charge work?
14 A. The 0&M Charge currently has two components :
15 a calculation of a system average monthly 0&M rate and a
16 de-levelization mechanism that lowers the rate in the early
17 years of a project' s life and escalates the rate over a 35-
18 year period. The applicable percentage changes annually on
19 the anniversary of the first energy date of the project in
20 accordance with the 0&M Charge contained within Tables 1
21 and 2 in Schedule 72 .
22 Q. Please explain the range of rates applicable
23 to transmission facilities and distribution facilities .
24 A. Table 1 contains the rates applicable to QF
25 interconnections considered to be at the transmission-
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Idaho Power Company

1 level (138-kilovolt ("kV") and 161 kV) , which range from
2 0 .26 percent in year 1 to 1 . 14 percent in year 35 . These
3 charges are equivalent to a 35-year levelized rate of 0 . 40
4 percent .
5 Table 2 contains the rates applicable to QF
6 interconnections considered to be at a distribution-level
7 (below 138 kV) , which range from 0 . 47 percent in year 1 to
8 2 . 11 percent per month in year 35 . These charges are
9 equivalent to a 35-year levelized rate of 0 . 70 percent.
10 Q. When were these charges first implemented?
11 A. The 35-year tables of 0&M charges in
12 Schedule 72 were first implemented in 1992 . The Commission
13 adopted these rates in Case IPC-E-90-20, with an effective
14 date of March 1, 1992 .'
15 Q. How were the rates developed?
16 A. The rates were developed using a formulaic
17 methodology based on actual system O&M costs as a
18 percentage of system plant balances .
19 Q. Have the 0&M Charge monthly rates been
20 updated since 1992?
21 A. Not materially. One modification was made in
22 2016 to incorporate a charge for projects greater than 35
Order No. 24172
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Idaho Power Company

1 years old.2 For all projects 36 years or older, the 0&M
2 Charge applied relies on the levelized rates of 0 . 70
3 percent and 0 . 40 percent for distribution and transmission
4 projects, respectively.
5 Q. Was an 0&M Charge applied to projects that
6 existed before the development of Schedule 72?
7 A. Yes . Prior to the establishment of Schedule
8 72, projects paid the levelized 0 . 70 percent and 0 . 40
9 percent for distribution and transmission projects,
10 respectively, but were not subject to the 35-year table .
11 Instead, the flat rates were embedded into each individual
12 project' s contract.
13 Q. Has the 0&M Charge been the subject of any
14 other proceedings since 1990?
15 A. Yes . In Case No. IPC-E-18-073, several
16 parties submitted a Petition to the Commission, arguing
17 among other things, that the "Commission should modify its
18 existing policy and orders approving of use the current
19 regime for Schedule 72 0&M charges for QFs . "4 In that case,
20 the petitioners argued that Idaho Power should assess only
2 Advice No. 16-04, filed on September 2, 2016, and approved on
September 26, 2016
3 IN THE MATTER OF PETITION OF IDAHYDRO, SHOROCK HYDRO, INC. , J.R.
SIMPLOT COMPANY, AND RENEWABLE ENERGY COALITION FOR MODIFICATION OF THE
90/110 PERFORMANCE BAND AND CALCULATION OF OPERATION AND MAINTENANCE
CHARGES FOR PURPA QUALIFYING FACILITIES
4 Petition, page 9.
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Idaho Power Company

1 the actual 0&M costs expended by the Company for each
2 individual QF interconnection. After discovery and
3 discussions among the parties, the Petition in that case
4 was eventually withdrawn and no changes were implemented
5 from the proceedings .5
6 Q. Have the Schedule 72 0&M Charges been at
7 issue in any other cases since IPC-E-18-07?
8 A. Yes . The Company filed a general rate case
9 in 2023 (Case No. IPC-E-23-11) . While the Company had not
10 proposed any modifications to the Schedule 72 0&M Charges
11 as part of its application, in the Settlement Stipulation
12 approved by the Commission in that case, the parties agreed
13 to the following:
14 11 . Generator Interconnection Charges . The
15 monthly operations and maintenance (0&M) charge
16 in Schedule 72, Generator Interconnections to
17 PURPA Qualifying Facility Sellers, will be
18 updated in the future to reflect current
19 operating metrics and assumptions, in
20 conjunction with the informal proceeding
21 described in paragraph 13 (b) below. . .
22 13 . Separate Informal Proceedings . To
23 facilitate further investigation and
24 participation, the Parties agree that : . . .
25 (b) IdaHydro will initiate and meet with Idaho
26 Power to discuss Qualified Facility 0&M charges .
27 Execution of, and agreement to this Stipulation
28 and Settlement is without prejudice to any
29 Parties' ability to bring a separate action
5 On October 17, 2018, Idahohydro, Shorock, Simplot, and REC filed a
Notice of Withdrawal of their April 16, 2018 Petition and Idaho Power
filed a Notice of Withdrawal of its July 25, 2018, Cross-Petition.
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Idaho Power Company

1 before the Commission related to 0&M charges in
2 Schedule 72 .6
3 Q. Have Idaho Power and IdaHydro discussed 0&M
4 charges?
5 A. Yes . Idaho Power has discussed Schedule 72 0&M
6 charges on several occasions with representatives of IdaHydro
7 and discussed the basis for the methodology used to establish
8 the current 0&M Charges in 1990 ("Original Methodology") .
9 Coincident with these discussions, Idaho Power provided Excel
10 workbooks that performed the calculations to allow IdaHydro
11 to develop a more complete understanding of the methodology.
12 Those workbooks also recalculated the equivalent levelized
13 0&M charge rates using historical financial information from
14 several other select years (2015-2017, 2022, 2023) .
15 Q. What was the outcome of that analysis?
16 A. The table below shows a summary of the
17 analyses provided to IdaHydro. Notably, the results across
18 all years reviewed remained relatively consistent, when
19 evaluating 0&M on a levelized basis .
Interconnection
Level 19897 2015 2016 2017 2022 2023
Transmission 0 . 380 0 . 350 0 . 320 0 . 310 0 . 350 0 . 340
Distribution 0 . 650 0 . 640 0 . 650 0 . 620 0 . 710 0 . 610
20
6 CASE NO. IPC-E-23-11 MOTION FOR APPROVAL OF STIPULATION AND SETTLEMENT
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 Account Treatment. Page 12
7 The approved Schedule 72 charges of 0.40 and 0.70 percent had been
rounded to the nearest tenth of a percent.
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Idaho Power Company

1 Q. Has the Company calculated an updated O&M
2 rate that it proposes for this update?
3 A. Yes . Generally relying on the Original
4 Methodology, the Company calculated new rates based on 13-
5 month average plant balances and such plant' s associated
6 0&M expenses, as stated within the Company' s 2024 FERC Form
7 1 .
8 Q. What are the new rates being proposed in
9 this case?
10 A. The Company proposes a monthly 0 . 96 percent
11 rate applied to the original cost of distribution
12 interconnection equipment and a 0 . 28 percent rate applied
13 to the original cost of transmission interconnection
14 equipment. Exhibit No. 1 provides the calculation of these
15 proposed levelized rates .
16 Q. How do these rates compare to the levelized
17 rates currently in effect?
18 A. The levelized distribution rate increases
19 from 0 . 70 percent per month to 0 . 96 percent per month,
20 while the levelized transmission rate decreases from 0 . 40
21 percent per month to 0 . 28 percent per month.
22 Q. What drove the increase to the distribution
23 rate?
24 A. The primary driver of the increase in the
25 proposed distribution 0&M rate is increased distribution
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Idaho Power Company

I maintenance expenses . Specifically, FERC Account 593
2 "Distribution Maintenance-Overhead Lines" is one of the
3 accounts used in the formula to determine the Distribution
4 0&M Charge. This account includes the costs of vegetation
5 management, among several other costs . The amount in this
6 account in 2024 was approximately $35 . 5 million dollars,
7 compared to approximately $17 . 8 million and $21 . 9 million
8 in 2023 and 2022, respectively. The driver of this increase
9 was largely wildfire-related costs, such as vegetation
10 management expenses and amortization of the Company' s
11 wildfire deferral .
12 Q. You mentioned you generally followed the
13 Original Methodology to develop the proposed rates . What
14 changes to that methodology did you incorporate to develop
15 the proposed rates?
16 A. A couple changes were necessary that apply to
17 both the distribution and transmission rate calculation
18 methodology, as well as other changes specific to the
19 transmission rate' s derivation.
20 First, property taxes are no longer being allocated.
21 The Company' s tax department confirmed that the State of
22 Idaho no longer assesses property taxes on what is
23 considered "contributed property, " which the PURPA
24 interconnection facilities relevant to this case are
25 considered to be. Second, the previous methodology
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Idaho Power Company

1 separately calculated an allocation of payroll taxes that
2 were recorded in a distinct FERC account separate from
3 labor expenses . This is no longer necessary due to a change
4 in the way the Company accounts for payroll taxes . Payroll
5 taxes are now allocated directly to the 0&M accounts that
6 contain the associated labor expenses (i .e. , payroll taxes
7 now "follow the labor") . This second change does not impact
8 the results of the calculation, just the presentment when
9 contrasting against the Original Methodology.
10 Q. Are there any other changes to the Original
11 Methodology?
12 A. Yes . For the original calculation of the
13 transmission 0&M rate in 1990, the Company had used a
14 "Transmission Sub-Functionalization" report to determine
15 the proportion of transmission service lines to total
16 transmission investment. The Company discontinued creating
17 this report in approximately the early 2000' s and, as such,
18 now relies upon the proportion of 138 kV and 161 kV line
19 investment for such allocation purposes . Additionally,
20 another modification from the methodology previously relied
21 upon is the exclusion of expenses contained within FERC
22 Account 565 - Transmission of Electricity by Others when
23 determining the 0&M Charge for transmission facilities
24 given these costs are unrelated to those imposed on the
25 Company by PURPA project interconnections .
Maloney, DI 12
Idaho Power Company

1 Q. Will these changes impact the results of the
2 Transmission 0&M Charge formula rate calculation?
3 A. Based on the Company' s review of the 1990
4 data, the Company' s revised methodology to determine the
5 proportion of transmission service lines provides similar
6 results . That said, removing expenses contained within FERC
7 Account 565 - Transmission of Electricity by Others does
8 reduce transmission' s 0&M charge. However, as stated above,
9 these expenses are unrelated to those imposed by PURPA
10 project interconnections and therefore should not be
11 recovered through Schedule 72' s O&M charge.
12 Q. Is the Company proposing to continue to
13 apply a non-levelized rate to collect 0&M Charges?
14 A. No . The Company proposes to rely on the
15 levelized rates to collect 0&M going forward. Relying on a
16 levelized collection is similar to how the Company collects
17 0&M associated with its Rule M, Facilities Charge service .
18 Q. Please explain the Company' s proposal to
19 change its collection from a de-levelized rate to a
20 levelized rate.
21 A. The rates that are currently in effect were
22 subjected to a "de-levelization" process, where the rate is
23 lower early in the life of the interconnection equipment
24 and escalated for 35 years using an inflation factor. The
25 Company proposes to remove the de-levelization concept from
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Idaho Power Company

1 the rate and instead charge the same calculated average
2 rate each year.
3 Q. Why was the de-levelized rate initially
4 implemented?
5 A. Certain parties to Case IPC-E-90-20 argued
6 that actual maintenance expenses tend to be lower early in
7 the life of the equipment and increase over time, and that
8 de-levelization would more closely match 0&M charge revenue
9 with 0&M expenses . Also, the de-levelization was thought to
10 provide a benefit to PURPA project financing by lowering
11 the 0&M charges in the early years of the project and thus
12 improving project cash flows .
13 Q. What assumptions were relied on for the basis
14 for the de-levelized structure?
15 A. An assumed inflation rate, a discount rate,
16 and the estimated life of the interconnection equipment
17 were all components of the de-levelization calculation.
18 Notably, at that time (early in the implementation of
19 PURPA) , the standard PURPA contract was 35 years, which was
20 the basis for the 35-year horizon . Currently, PURPA
21 contract lengths can range from 2 to 20 years .
22 Q. Why is the Company proposing to remove the de-
23 levelization component?
24 A. For several reasons, the first of which is
25 simplification. De-levelization requires the Company to
Maloney, DI 14
Idaho Power Company

1 make and the Commission to approve assumptions about future
2 inflation rates, and the formula requires estimates of
3 interconnection asset lives and PURPA contract lives that
4 are subject to uncertainty. Eliminating the need to
5 develop, monitor, and update these assumptions simplifies
6 the 0&M charge process . Inflation rates that had been
7 historically low for several decades have recently spiked
8 back up to levels not seen since the 1980s . Determining the
9 proper inflation rate to apply to the de-levelization
10 formula is particularly challenging.
11 Second, the Company' s proposal makes the Schedule 72
12 0&M Charge consistent with the Company' s Rule M, Facilities
13 Charges, which also use system average costs .
14 Third, project development under PURPA has now
15 matured compared to the early days of PURPA when the
16 current Schedule 72 0&M charge was first developed. Among
17 other things, contract terms are shorter now (2 years to 20
18 years) as opposed to Idaho' s initial PURPA implementation
19 when contract terms were regularly 35 years . Many early
20 PURPA contracts have also reached the 35+ year time frame
21 and are back to being assessed the levelized rate . Further,
22 recent PURPA development has been focused on hydro and wind
23 projects . The Company has no experience with replacement
24 contracts for these developer-owned resources, which makes
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Idaho Power Company

1 it hard to develop assumptions regarding the proper
2 timeframe to use when developing de-levelized rates .
3 Finally, and as discussed in more detail below, the
4 Company proposes to more frequently update its O&M charge
5 percentages, which will negate some of the perceived
6 benefits of de-levelization.
7 Q. How are 0&M Charges treated for ratemaking
8 purposes?
9 A. O&M Charges collected from PURPA projects are
10 treated as a revenue credit when calculating the revenue
11 requirement of Idaho Power' s retail service customers . This
12 revenue credit was last updated as part of the Company' s
13 general rate case filed as Case No. IPC-E-23-13 and totaled
14 approximately $1, 800, 000 for Idaho customers .
15 Q. Has the Company quantified the ratemaking
16 impact of its proposal?
17 A. Yes . If the proposed rates were applied to
18 projects active at the end of 2024, the total annualized
19 amount collected from 0&M Charges would increase by
20 approximately $4, 800 .
21 Q. Has the Company reviewed the impact of its
22 proposed changes on current PURPA projects?
23 A. Yes . The impact to existing projects will be
24 driven by three interrelated factors : (1) what point in
25 time during the 36+-year horizon the project is in, (2)
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Idaho Power Company

1 whether the project' s interconnection facilities are
2 transmission or distribution, and (3) the impact of an
3 increase to the average distribution rate and a decrease in
4 the average transmission rate.
5 Overall, when holistically considering the Company' s
6 proposal, of the 121 non-mixed facility Idaho PURPA
7 projects paying an 0&M Charge at the end of 2024 : 45 will
8 be assessed a lower charge (an average decrease of
9 approximately $553 per month) and 76 will be assessed a
10 higher charge (an average increase of approximately $373
11 per month) . For the five Idaho PURPA projects with both
12 transmission and distribution facilities subject to an O&M
13 Charge as of the end of 2024, their monthly charge will, on
14 average, decrease by approximately $623 .
15 Q. How many projects have reached the 36 plus
16 years and reverted back to the flat rate?
17 A. As of the end of 2024, 40 projects have
18 reached the 36 plus years and accordingly have reverted
19 back to the flat rate.
20 Q. Is the Company proposing to periodically
21 update the new formula rates?
22 A. Yes . As noted above, the Company proposes that
23 the 0&M Charges and corresponding revenue credit would be
24 updated during each general rate case, similar to how it
25 updates Rule M, Facilities Charges .
Maloney, DI 17
Idaho Power Company

1 Q. If the Company' s proposal is approved, how
2 does the Company propose to handle PURPA projects paying
3 under the existing de-levelized rate mechanism?
4 A. Given the relatively small change in overall
5 revenue, the Company proposes transitioning all PURPA
6 projects to the fixed rates outlined in this case,
7 regardless of where each project is within the existing de-
8 levelized rate table. If its proposal is approved, Idaho
9 Power would implement this change, effective January 1,
10 2026 .
11 Q. Does this conclude your direct testimony in
12 this case?
13 A. Yes, it does .
14
Maloney, DI 18
Idaho Power Company

1 DECLARATION OF RILEY MALONEY
2 I, Riley Maloney, declare under penalty of perjury
3 under the laws of the state of Idaho:
4 1 . My name is Riley Maloney. I am employed by
5 Idaho Power Company as a Policy and Strategy Leader in the
6 Regulatory Affairs Department.
7 2 . On behalf of Idaho Power, I present this
8 pre-filed direct testimony and Exhibit No. 1 in this
9 matter.
10 3 . To the best of my knowledge, my pre-filed
11 direct testimony and exhibits are true and accurate .
12 I hereby declare that the above statement is true to
13 the best of my knowledge and belief, and that I understand
14 it is made for use as evidence before the Idaho Public
15 Utilities Commission and is subject to penalty for perjury.
16 SIGNED this 8th day of May 2025, at Boise, Idaho.
17
18 Signed:
19 Riley Maloney
20
21
22
23
24
25
26
Maloney, DI 19
Idaho Power Company

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-22
IDAHO POWER COMPANY
MALONEY, DI
TESTIMONY
EXHIBIT NO. 1

IDAHO POWER COMPANY
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
TRANSMISSION MONTHLY OPERATIONS AND MAINTENANCE CHARGE
IPC-E-25-22
Line No. Description 2024 Amount Notes:
Investment in Transmission Service Lines
1 Total Transmission Plant $ 1,361,738,573
2 Transmission Service Lines $ 280,627,085
3 Transmission Services Lines as a Percent of Total Transmission Plant 20.608% (Lines 2/1)
Investment in General Plant
4 Total General Plant-Accounts 389-398 $ 504,510,343
5 Total Operations&Maintenance(O&M)Labor 174,159,861
6 Total O&M Labor,Excluding Administrative&General(A&G) 109,097,959
7 Total Transmission Labor 12,843,204
8 Labor Assigned to Transmission Service Lines $ 2,646,728 (Lines 3*7)
9 Transmission Service Lines Labor as a Percent of Total O&M Labor Expenses,Excluding A&G 2.426% (Lines 8/6)
10 General Plant Assigned to Transmission Service Lines $ 12,239,472 (Lines 4*9)
11 Total Investment in Transmission Service Lines $ 292,866,557 (Lines 2+10)
12 Transmission Service Lines Labor as a Percent of Total O&M Labor,Including A&G 1.520% (Lines 8/5)
Operations&Maintenance Expenses-Transmission Service Lines
13 Total Transmission O&M Expense,Excluding Account 565 $ 25,826,526
14 Transmission O&M Assigned to Transmission Service Lines $ 5,322,331 (Lines 3*13)
Administrative and General Expenses Assigned to Transmission Service Lines
15 Account 920 $ 110,254,504
16 Account 921 19,328,502
17 Account 923 10,696,562
18 Account 930.2 4,681,625
19 Account 931 -
20 Account 935 7,588,454
21 Total $ 152,549,646 (11-ines 15,16,17,18,19,and 20)
22 A&G Assigned to Transmission Service Lines Based on Transmission Service Lines Labor $ 3,700,870 (Lines 9*21)
23 Account922 $ (47,555,951)
24 Account 925 10,612,690
25 Account 926 84,097,252
26 Total $ 47,153,991 (11-ines 23,24,and 25)
27 Accounts 922,925 and 926 Assigned to Transmission Service Lines Based on Total Labor $ 716,605 (Lines 12*26)
28 Total A&G Assigned $ 4,417,474 (Lines 22+27)
.............................................................................................................................................................................................................................................................................................................................................................................................................................................
29 Total Annual Transmission Service Lines O&M Expenses $ 9,739,805 (Lines 14+28)
............................................................................................................................................................................................................................................................................................................................................................................................................................................
30 Annual Transmission Service Lines O&M As a Percent of Total Investment in Transmission Service Lines 3.326% (Lines 29/11)
.............................................................................................................................................................................................................................................................................................................................................................................................................................................
31 Monthly Transmission Service Lines O&M Cost(Rounded) 0.28%
:...........................................................................................................................................................................................................................................................................................................................................................................................................................................:
*Unless noted otherwise,amounts shown are truncated for presentment purposes.
Exhibit No.1
R.Maloney,IPC

IDAHO POWER COMPANY
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
DISTRIBUTION MONTHLY OPERATIONS AND MAINTENANCE CHARGE
IPC-E-25-22
Line No. Description 2024 Amount Notes:
Investment in Overhead Distribution Lines
1 Distribution Poles,Towers&Fixtures-Plant Account 364 $ 333,422,399
2 Distribution Overhead Conductor&Devices-Plant Account 365 161,939,763
3 Total $ 495,362,163 (Lines 1+2)
Investment in General Plant
4 Total General Plant-Accounts 389-398 $ 504,510,343
5 Total Operations&Maintenance(O&M)Labor 174,159,861
6 Total O&M Labor,Excluding Administrative&General(A&G) $ 109,097,959
Overhead Distribution Lines Labor
7 Distribution Overhead Lines Expenses-Account 583 $ 4,494,833
8 Distribution Overhead Lines Maintenance-Account 593 6,306,916
9 Total Distribution Overhead Lines Labor $ 10,801,749 (Lines 7+8)
10 Total Distribution Labor $ 35,278,296
11 Less:Accounts 580 and 590 3,395,913
12 Total Distribution Labor Expenses,Excluding Accounts 580 and 590 $ 31,882,384 (Lines 10-11)
13 Accounts 583 and 593 as a Percent of Total Distribution Labor Expenses,Excluding Accounts 580 and 590 33.880%(Lines 9/12)
14 Portion of Accounts 580 and 590 Assigned to Accounts 583 and 593 $ 1,150,535 (Lines 11'13)
15 Total Overhead Distribution Lines Labor,Including Accounts 580 and 590 $ 11,952,284 (Lines 9+14)
16 Overhead Distribution Lines Labor,Inc.Supervision,as a Percentage of Total Labor Excluding A&G 10.956%(Lines 15/6)
17 Overhead Distribution Lines Labor,Inc.Supervision,as a Percentage of Total O&M Labor Expenses 6.863%(Lines 15/5)
18 General Plant Investment Assigned to Overhead Distribution Lines $ 55,271,892 (Lines 4'16)
19 Total Investment in Overhead Distribution Lines $ 550,634,055 (Lines 3+18)
Operations&Maintenance Expenses-Overhead Distribution Lines
20 Overhead Distribution Lines Expenses-Account 583 $ 6,679,549
21 Operations Supervision and Engineering-Account 580 4,981,783
22 Total Distribution Operations Expenses $ 38,526,794
23 Account 583 as a Percent of Total Distribution Operations Expenses,Excluding Account 580 19.912%(Lines 20/(22-21))
24 Supervision&Engineering Assigned to Overhead Distribution Lines Expenses $ 991,983 (Lines 21'23)
25 Maintenance Expenses-Account 593 35,534,246
26 Maintenance Supervision and Engineering-Account 590 9,118
27 Total Distribution Maintenance $ 43,367,688
28 Account 593 as a Percent of Total Distribution Maintenance,Excluding Account 590 81.954%(Lines 25/(27-26))
29 Supervision&Engineering Assigned to Overhead Distribution Lines Maintenance $ 7,473 (Lines 26 28)
30 Total Overhead Distribution Lines O&M Expenses $ 43,213,250 (SLines 20,24,25,and 29)
Administrative and General Expenses Assigned to Overhead Distribution Lines
30 Account 920 $ 110,254,504
31 Account 921 19,328,502
32 Account 923 10,696,562
33 Account 930.2 4,681,625
34 Account 931 -
35 Account 935 7,588,454
36 Total $ 152,549,646 (SLines 30,31,32,33,34,and 35)
37 A&G Assigned to Overhead Distribution Lines Based on Overhead Line Labor $ 16,712,656 (Lines 16'36)
38 Account 922 $ (47,555,951)
39 Account 925 10,612,690
40 Account 926 84,097,252
41 Total $ 47,153,991 (SLines 38,39,and 40)
42 Accounts 922,925 and 926 Assigned to Overhead Distribution Lines Based on Total Labor $ 3,236,095 (Lines 17'41)
43 Total A&G Assigned $ 19,948,751 (Lines 37+42)
„...........................................................................................................................................................................................................................................................................................................................................................................................................................
44 Total Annual Overhead Distribution Lines O&M Expenses $ 63,162,001 (Lines 30+43)
............................................................................................................................................................................................................................................................................................................................................................................................................................
45 Annual Overhead Distribution Lines O&M As a Percent of Total Investment in Overhead Distribution Lines 11.471%(Lines 44/19)
.............................................................................................................................................................................................................................................................................................................................................................................................................................
46 Monthly Overhead Distribution Lines O&M Cost(Rounded) 0.96%
.............................................................................................................................................................................................................................................................................................................................................................................................................................
Unless noted otherwise,amounts shown are truncated for presentmentpurposes.
Exhibit No.1
R.Maloney,IPC