20250530Direct Buckham - Redacted.pdf

RECEIVED
May 30, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-25-16
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC SERVICE )
IN THE STATE OF IDAHO AND )
AUTHORITY TO IMPLEMENT CERTAIN )
MEASURES TO MITIGATE THE IMPACT )
OF REGULATORY LAG. )
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
BRIAN R. BUCKHAM

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 Brian Buckham. My business address
5 is 1221 West Idaho Street, Boise, Idaho 83702 . I am
6 employed by Idaho Power and Idaho Power' s parent company,
7 IDACORP, Inc. ("IDACORP") , as Senior Vice President, Chief
8 Financial Officer, and Treasurer.
9 Q. Please describe your educational background.
10 A. I received a Bachelor of Science in Mining
11 Engineering from the University of Idaho, a Master of
12 Business Administration from Gonzaga University, and a
13 Juris Doctor from the University of Idaho College of Law.
14 Q. Please describe your work experience with
15 Idaho Power.
16 A. I was hired in 2010 as an attorney in Idaho
17 Power' s Legal Department, where I focused on securities
18 compliance and external reporting, capital markets
19 transactions, corporate governance, and commercial
20 transactions, among other areas . This followed several
21 years of private law practice at two global law firms,
22 where my practice areas focused on both domestic and
23 international capital markets transactions, securities,
24 corporate governance, and mergers and acquisitions . In
25 2016, I was appointed as IDACORP' s and Idaho Power' s Vice
BUCKHAM, DI 1
Idaho Power Company

1 President & General Counsel, and in 2017 as Senior Vice
2 President & General Counsel, where in both roles I was
3 responsible for leadership of the legal, corporate
4 governance, compliance, risk management, and physical and
5 cyber security functions at IDACORP and Idaho Power. In
6 2022, I was appointed as IDACORP' s Senior Vice President
7 and Chief Financial Officer, where I oversee the companies'
8 finance, accounting, financial planning and analysis,
9 investor relations, treasury, tax, Sarbanes-Oxley
10 compliance, internal audit, environmental compliance,
11 regulatory compliance, credit risk, risk management, and
12 physical and cyber security functions .
13 Q. What are your duties as Senior Vice President
14 and Chief Financial Officer of Idaho Power as they relate
15 to this proceeding?
16 A. I oversee the direct financial planning and
17 forecasting, capital procurement, financing, and investment
18 of funds for Idaho Power, as well as supervise corporate
19 liquidity management and credit. I also have oversight and
20 responsibility for our financial reporting, both internal
21 and external, our investor relations function, and our
22 capital markets transactions and associated relationships
23 with stakeholders in those forums .
24 My duties and responsibilities include various
25 aspects of the Company' s capital markets transactions,
BUCKHAM, DI 2
Idaho Power Company

1 treasury management, and other financial matters . With
2 respect to long-term financing, sale of debt securities,
3 credit facilities, and sale of equity, my duties include
4 development of financial plans with senior officers and
5 senior managers; meeting with representatives of current
6 and prospective investment banking firms that underwrite
7 IDACORP and Idaho Power securities; preparation of
8 materials and meetings with credit rating agencies;
9 assisting in preparation of financial material (including
10 registration statements and prospectuses filed with the
11 U. S . Securities and Exchange Commission) ; representing
12 IDACORP and Idaho Power in meetings with investment banking
13 firms; assessing information relative to the companies'
14 financings; participating in investor deal and non-deal
15 roadshows and other similar events; meeting with current
16 and prospective debt and equity investors; meeting with
17 infrastructure and alternative investment funds; and
18 meeting with investment analysts, New York Stock Exchange
19 representatives, and other members of the investment
20 community. With respect to short-term financing, these
21 duties and responsibilities include negotiation of credit
22 facilities and term loans with commercial banks, overseeing
23 the purchase and sale of commercial paper, and establishing
24 and maintaining the relationships that help facilitate
25 those transactions .
BUCKHAM, DI 3
Idaho Power Company

1 Q. Do your responsibilities include communicating
2 with members of the financial community?
3 A. Yes . I am in regular, and effectively daily,
4 contact with individuals associated with investment and
5 commercial banking firms, credit rating agencies, insurance
6 companies, institutional investment firms, pension funds,
7 infrastructure funds, and other organizations interested in
8 aspects of publicly-traded and privately-placed securities,
9 as well as securities analysts, who follow IDACORP and
10 Idaho Power. Along with the Company' s Vice President of
11 Finance, Compliance, and Risk, my responsibilities include
12 keeping these representatives of the financial community
13 informed of the Company' s financial condition, arranging
14 and participating in meetings with these individuals and
15 IDACORP' s and Idaho Power' s other senior executive
16 management, and visiting with financial representatives in
17 their respective offices or virtually and at industry
18 events . Many of these members of the investment community
19 have followed the electric utility industry for an extended
20 period of time, have a great deal of expertise in the
21 specific financial risks and prospects of utilities and in
22 the regulatory process, and are highly sophisticated.
23 Through my contact with the financial community and
24 review of investment banking and both buy-side and sell-
25 side analytical reports and publications issued by these
BUCKHAM, DI 4
Idaho Power Company

1 firms and the credit rating agencies, I keep informed on
2 market trends, equity valuations, interest rates, debt
3 costs, financing costs, security ratings, credit ratings,
4 mergers and acquisitions, capital-raising transactions,
5 financing methodologies and costs, and other financial
6 developments in the public utility industry.
7 Q. Are you a member of any professional societies
8 or associations?
9 A. Yes . I am a current member of the Idaho State
10 Bar, the Oregon State Bar, the Arizona State Bar
11 (inactive) , the Governing Council of the Business &
12 Corporate Law Section of the Idaho State Bar, and the
13 University of Idaho Law Advisory Council, in addition to
14 serving on various non-profit boards, both currently and in
15 the past . I am also a member of the advisory board for FM,
16 a global property-casualty insurance company. Further, I
17 was previously an adjunct professor of law at the
18 University of Idaho College of Law, where I taught the
19 securities regulation course . I also previously held the
20 licensed designation of Registered Investment Advisor
21 Representative as an agent of an SEC-regulated wealth
22 management firm.
23 I also attend numerous conferences and seminars of
24 these and other utility business, law, and finance
25 professional groups, such as the Edison Electric Institute
BUCKHAM, DI 5
Idaho Power Company

1 and Western Energy Institute, and an investor-owned utility
2 Chief Financial Officer forum, on a regular basis . I meet
3 regularly with bankers, lawyers, investment analysts,
4 investors, debtholders, executive management at peer
5 companies, and other members of the investment community
6 and capital markets, and read numerous sources of analyst
7 and market commentary. Through participation in these
8 areas, I gain additional information and insights into the
9 financial developments affecting IDACORP and Idaho Power,
10 as well as the electric utility industry.
11 Q. What is the purpose of your testimony in this
12 proceeding?
13 A. The purpose of my testimony is to discuss
14 financial risk factors generally and risk factors unique to
15 Idaho Power that justify the Company' s proposed rate of
16 return ("ROR") of 7 . 818 percent. I discuss the components
17 of the requested ROR, including a requested return on
18 equity ("ROE") of 10 . 4 percent as supported by the Direct
19 Testimony of Company Witness Dr. John Thompson, a capital
20 structure of 51 percent equity and 49 percent debt, and an
21 embedded cost of long-term debt of 5 . 132 percent. My
22 testimony also addresses the importance of the proposed
23 depreciation and interest expense tracking mechanism
24 discussed in Mr. Timothy E. Tatum' s Direct Testimony, and
BUCKHAM, DI 6
Idaho Power Company

1 how its approval is vital to maintaining the overall
2 financial health of Idaho Power.
3 Q. What Exhibits are you sponsoring?
4 A. I am sponsoring Exhibit Nos . 15-17 .
5 I . GENERAL OVERVIEW
6 Q. Generally speaking, how does Idaho Power
7 obtain financing for its operations?
8 A. Financing of Idaho Power' s operations, beyond
9 what is originated from operating cash flows, comes from a
10 combination of debt transactions conducted at Idaho Power
11 and equity (stock) transactions conducted at the publicly
12 traded IDACORP level . IDACORP is the sole owner of Idaho
13 Power.
14 Q. What are the primary costs associated with
15 debt and equity financing?
16 A. Beyond issuance costs, the primary cost of
17 debt financing is the interest rate charged by lenders,
18 similar to the interest rate an individual would pay on a
19 home or car loan. Equity financing costs can be
20 represented by the return investors expect in exchange for
21 their investment, referred to as return on equity, or
22 "ROE . "
23 Q. How do debt financing costs and the ROE impact
24 customer rates?
BUCKHAM, DI 7
Idaho Power Company

1 A. For ratemaking purposes, the Company' s
2 weighted average cost of debt and equity financing -
3 referred to as the "rate of return" or "ROR" - is applied
4 to the Company' s rate base to determine financing costs
5 allowed in customer rates . With all else held constant,
6 increased financing costs result in higher rates for
7 customers . This relationship between financing and customer
8 rates also works in reverse - lower financing costs result
9 in lower customer rates .
10 Q. Does a utility' s financial health impact its
11 overall cost of financing?
12 A. Yes . Credit ratings and the outlook for a
13 company' s financial condition and operating cash flow are
14 primary drivers of the interest rates a lender is willing
15 to offer for debt financing. Those credit ratings and
16 financial outlook also significantly impact a company' s
17 stock price . Idaho Power is currently monitored by two
18 credit ratings agencies - Moody' s Investors Service
19 ("Moody' s") and Standard & Poor' s Global Ratings ("S&P") -
20 that issue credit ratings for IDACORP and Idaho Power based
21 on a number of metrics that measure each company' s
22 financial health.
23 Q. Based on the interplay between the financial
24 health of a utility and its overall cost of financing, is
25 it in the public interest that a utility is provided with
BUCKHAM, DI 8
Idaho Power Company

1 adequate and timely cost recovery through rates, including
2 through an appropriate ROE?
3 A. Yes . Rate recovery that supports more timely
4 cash flows and a financially healthy utility is a direct
5 benefit to customers by ensuring that the utility can, in
6 the lowest cost manner possible, obtain the funds needed to
7 construct, operate, and maintain a safe and reliable
8 electric grid. This is especially important in a period of
9 high growth when exceptionally high levels of incremental
10 debt and equity financing will certainly be required for
11 the Company to fulfill its obligation to serve customers .
12 The amount of financing necessary, as well as the cost of
13 that financing, correlates closely with the cash flow the
14 utility generates from customer revenues and the timely
15 receipt of those cash flows . Regulatory lag can create
16 pressure on operating cash flows, resulting in a need for
17 greater external financing and at a higher cost to the
18 utility and to its customers .
19 Q. As context for the remainder of your
20 testimony, can you provide an overview of the Company' s
21 financial condition and plans and why the outcome of this
22 case is important to the Company?
23 A. Absolutely. Stated simply, the Company' s
24 financial health has degraded notably. The outcome of this
25 case is critical to the Company' s financial condition and
BUCKHAM, DI 9
Idaho Power Company

1 ability to cost-effectively serve customers in light of
2 financing costs . Idaho Power is in a period of
3 unprecedented investment - a once in multiple generations
4 level of infrastructure development where the Company
5 expects its rate base will at least double in a five-year
6 period. Other than Idaho Power from 1955-1960 when it
7 constructed part of the Hells Canyon Complex, I am not
8 aware of any investor-owned utility in modern history that
9 has organically doubled its rate base growth in such a
10 short period of time. That growth gets its genesis from
11 the State of Idaho' s economic development efforts and from
12 organic growth in the State through an influx of new
13 residents, and Idaho Power has been working to fulfill its
14 obligation to provide electric service as the State' s
15 economy grows and the State prospers . That investment
16 requires the Company to pursue enormous levels of
17 financing. As Mr. Tatum notes in his testimony, when
18 investments and associated costs are increasing annually as
19 significantly as they are today, even with annual general
20 rate cases, rates derived under a historical average rate
21 base methodology will inevitably be inadequate to cover the
22 costs that will exist in the rate effective period. To add
23 some perspective, that impacts Idaho Power' s financial
24 condition and ultimately customer rates in several ways,
25 including the following:
BUCKHAM, DI 10
Idaho Power Company

I • For 2024, Idaho Power' s Idaho-jurisdiction return on
2 equity was 8 . 19 percent prior to the accelerated
3 amortization of nearly $30 million of additional
4 accumulated deferred investment tax credits ("ADITCs")
5 under the Idaho ADITC amortization and earnings
6 sharing regulatory mechanism. That accelerated
7 amortization of ADITCs was necessary to achieve a
8 floor-level of 9 . 12 percent return on equity, below
9 the Company' s authorized return on equity of 9 . 6
10 percent, reflective of substantial regulatory lag.
11 Recall, accelerated amortization of ADITCs is a non-
12 cash event, so while accelerated amortization of
13 ADITCs is beneficial to the Company' s earnings, it
14 does not benefit the Company' s operating cash flow.
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BUCKHAM, DI 11
Idaho Power Company

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1 Case No. IPC-E-24-07.
BUCKHAM, DI 12
Idaho Power Company

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18 • Idaho Power plans to invest approximately $1 billion
19 in new infrastructure during 2025, with associated
20 incremental depreciation and interest expense of
21 approximately $52 . 5 million over 2024 levels . With
22 additional plant in service and incremental debt to
23 fund capital investment not in rates, this amount
24 increases each year. The 2025 incremental
25 depreciation and interest expense alone will exceed
BUCKHAM, DI 13
Idaho Power Company

1 the total amount of the rate increase the Company
2 received in its 2024 Limited Scope Rate Case that
3 became effective January 1, 2025, which was based on a
4 2024 historical test year. This has rendered the
5 Company with no realistic opportunity to earn its
6 authorized rate of return in 2025 .
7 • IDACORP and Idaho Power have been very active in the
8 capital markets . From 2023 to present, Idaho Power
9 issued approximately $1 . 6 billion in debt securities .
10 In that same period, IDACORP has transacted for
11 approximately $1 . 0 billion in common stock sales .
12 Thus, in approximately 2 . 5 years, the Company has
13 accessed the capital market for $2 . 6 billion of
14 incremental financing. As stated in IDACORP' s
15 investor relations materials, IDACORP and Idaho Power
16 have significant additional debt and equity financing
17 needs through at least the next five years . This
18 financing is on top of the imputed debt caused by
19 power purchase and lease arrangements . The
20 substantial need for debt and equity is a function of
21 inadequate operating cash flow from customer rates to
22 sustain the business . While the need for external
23 financing for utility operations is not unusual, the
24 need for financing of this magnitude is very atypical,
25 particularly for a utility of Idaho Power' s size . In
BUCKHAM, DI 14
Idaho Power Company

1 fact, Idaho Power' s need for external equity capital
2 relative to its market cap is the highest of all
3 investor-owned utilities, which is not an accolade.
4 • During 2024 and 2025, IDACORP sold over $700 million
5 of stock, meaning the company had to sell over 10
6 percent of the company' s market capitalization in less
7 than one year (a substantial percentage for a company
8 that has been in existence for more than 100 years) .
9 IDACORP also sold nearly $300 million of stock in
10 late-2023 . For a company like Idaho Power, these
11 amounts are staggeringly high. These stock sales were
12 in an effort to maintain a reasonably healthy balance
13 sheet and try to prevent further credit metric
14 degradation, and to fund operations, as cash flow is
15 currently grossly inadequate to do so . Unfortunately,
16 it also meant the stock was sold at a time when
17 IDACORP' s equity valuation factored-in weaker
18 financial and credit metrics and the financial and
19 market-perception impacts of substantial regulatory
20 lag and unprecedented levels of anticipated equity
21 dilution.
22 • During 2025, Idaho Power issued $400 million in long-
23 term debt . In 2026, Idaho Power expects to issue
24 approximately $- million in long-term debt. Based
25 on the known interest rate for the debt issued in 2025
BUCKHAM, DI 15
Idaho Power Company

1 and based on current credit ratings, Treasury rates,
2 and pricing spreads from recent debt transactions by
3 peers for evaluating the potential cost of 2026 debt
4 financing, Idaho Power expects the annual incremental
5 interest expense on that $1 . 1 billion in indebtedness
6 issued after the conclusion of the 2024 Limited Scope
7 Rate Case will be around $67 million . None of that
8 amount of interest is included for recovery in current
9 rates, but it is a very real expense the Company will
10 incur, and part of which it is already incurring
11 without recovery.
12 • In 2024, Idaho Power' s operating cash flow was $561
13 million, which was abnormally high relative to history
14 based on power supply collection. By contrast,
15 capital expenditures were over $1 billion. For 2025,
16 the Company expects the delta between operating cash
17 flow and capital expenditures to be even greater.
18 This negative free cash flow is persistent and
19 exacerbated by regulatory lag, and it has a
20 particularly adverse impact on credit metrics .
21 • Idaho Power remains on negative watch from Moody' s .
22 S&P' s rating for Idaho Power is already one notch
23 lower than Moody' s . IDACORP' s rating at Moody' s and
24 Idaho Power' s rating at S&P are only one notch above
25 the non-investment grade, speculative level . Moody' s
BUCKHAM, DI 16
Idaho Power Company

1 downgrade threshold for Idaho Power for its primary
2 metric, Cash Flow from Operations pre-Working Capital
3 to Debt is 13 percent . S&P' s downgrade threshold for
4 its primary metric, Funds from Operations to Debt, is
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10 I believe the foregoing are illustrative of the Company' s
11 financial condition, and they reflect the adverse impacts
12 of regulatory lag. The Company' s continued weak cash flow
13 performance and the pervasive deterioration of credit
14 metrics are demonstrative of the challenging environment in
15 which the Company is operating and the importance of a
16 supportive regulatory environment and outcome in this case .
17 A key component of the Company' s long-term financial
18 profile is the ability to receive timely recovery of
19 capital additions and expenses, so that the Company has the
20 opportunity to earn its authorized rate of return on
21 prudent capital expenditures . Under the current rate
22 structure, the Company has no such opportunity, and it has
23 contributed to unsustainable financial weakness and
24 substantial risk.
BUCKHAM, DI 17
Idaho Power Company

1 II . COST OF EQUITY POINT ESTIMATE
2 Q. Given the risks and financial profile you
3 describe in your general overview above, what ROE is the
4 Company requesting in this proceeding?
5 A. The Company requests 10 . 4 percent as the point
6 estimate to be used for the cost of equity.
7 Q. Does that point estimate align with the
8 midpoint of the reasonable range of ROEs developed by Dr.
9 Thompson, the Company' s outside cost of capital expert?
10 A. No, it is lower. As the Company evaluated its
11 request it decided to apply an ROE that is lower than the
12 10 . 7 percent midpoint provided by Dr. Thompson.
13 Q. How did you arrive at your recommendation?
14 A. The Company believes this requested ROE, when
15 coupled with its request to implement the depreciation and
16 interest expense tracking mechanism described in Mr.
17 Tatum' s testimony, will enable the Company to attract
18 capital at customer-beneficial rates in the currently
19 competitive, uncertain, and volatile financial markets .
20 While I believe the discussion of risk factors later in my
21 testimony justifies an ROE in excess of 10 . 4 percent, as
22 supported by Dr. Thompson, the Company is cognizant of the
23 impact to customers of rising rates . Therefore, the Company
24 is proposing in this case to utilize a ROE at the lower
25 bound of what it would consider to be a reasonable range of
BUCKHAM, DI 18
Idaho Power Company

1 ROEs .
2 Q. Can you describe the financial market
3 conditions Idaho Power is currently facing that influenced
4 the proposed 10 . 4 percent ROE?
5 A. Yes . Interest rates have remained elevated,
6 with the 30-year United States ("US") Treasury rate
7 hovering between 4 . 98 percent on January 1, 2025, and
8 approximately 4 . 89 percent as of May 16, 2025 (source:
9 Federal Reserve Economic Data) . As interest rates are
10 elevated, investors expect a higher ROE given the higher
11 risk for both debt and equity compared to their alternative
12 investment in debt instruments . In today' s market, the ROE
13 needs to appropriately reflect the increase in debt cost
14 and prevailing interest rates, given investors' available
15 options and expectations . The number of basis points should
16 increase even further in light of volatile market
17 conditions and other factors I discuss in this testimony.
18 Moreover, in my conversations with current and
19 prospective investors and with equity analysts, the topic
20 of authorized ROES is frequently raised. Based on those
21 conversations, it is my impression that an ROE of the level
22 the Company has requested in this case, assuming it also
23 includes recovery of prudent expenditures and a return on
24 and of investment, would be sufficient to meet the
25 expectations of those investors and thus maintain IDACORP' s
BUCKHAM, DI 19
Idaho Power Company

1 reasonable access to equity capital and Idaho Power' s
2 access to debt capital . The authorized ROE is one of the
3 primary factors participants in the equity capital markets
4 will review when assessing the constructiveness of the
5 regulatory environment and the adequacy of the outcome of a
6 general rate case for purposes of making an investment
7 decision, and an authorized ROE lower than Idaho Power' s
8 request could increase the Company' s cost of equity
9 issuances . With IDACORP anticipating substantial debt and
10 equity issuances in the coming years, an authorized ROE
11 that meets investor expectations will benefit customers
12 through greater value in debt issuances via interest rates
13 and equity financing via issuance pricing. Dr. Thompson
14 addresses this important intersection of utility regulation
15 and the investment markets in his testimony.
16 Q. Why is Idaho Power' s requested 10 . 4 percent
17 ROE justified in this case?
18 A. Unstable economic conditions, persistent high
19 cost levels, heightened competition for equity and debt
20 capital, market volatility and uncertainty, direct and
21 indirect tariff impacts, and elevated interest rates, have
22 taken place in the past few years, and exacerbated
23 recently. In his testimony, Dr. Thompson also discusses
24 these changes and their implications on capital costs and
25 ROE .
BUCKHAM, DI 20
Idaho Power Company

1 Over the last few years, the utility risk landscape
2 has been shifting dramatically, increasing several risks
3 that the Company must address . I highlight in the next
4 section of my testimony several of these heightened risks,
5 including the Company' s financial health, power supply
6 costs, liquidity challenges, wildfires, cybersecurity, and
7 physical security. I will also discuss other specific risks
8 Idaho Power continues to face .
9 There is also a risk that the Company' s ROE falls
10 behind in the marketplace and the competition for capital
11 becomes more difficult, particularly as recent state
12 utility commissions have authorized ROES in other
13 jurisdictions that are higher than Idaho Power' s currently
14 authorized ROE, such as 9 . 8 percent for Avista Utilities in
15 Washington in December 2024 and a settlement of 10 . 5
16 percent for Southern Company in Georgia in May 2025 .
17 Ultimately, IDACORP and Idaho Power compete with other
18 companies for debt and equity in the capital markets,
19 including both utility industry peers and the broader
20 market . To attract the capital necessary to fund its
21 operations, IDACORP and Idaho Power must be able to
22 demonstrate to the investment and banking community the
23 likelihood of a reasonable return on investment at an
24 acceptable level of risk and the ability to timely fund its
25 interest and principal debt repayment obligations .
BUCKHAM, DI 21
Idaho Power Company

1 Certainly, the rating agencies also perform this
2 assessment .
3 Some of the important risk factors highlighted by
4 the investment community relate to cost pressures due to
5 inflation and supply chain issues, balance sheet strength,
6 weakening returns, and regulatory outcomes that have not
7 provided the Company with a reasonable opportunity to earn
8 its authorized rate of return. Because IDACORP is
9 comprised almost entirely of Idaho Power, and because over
10 96 percent of Idaho Power' s retail jurisdiction resides
11 within Idaho, the Company' s ability to earn a fair rate of
12 return in Idaho is paramount to capital market access and
13 outcomes . Based on my discussions with current and
14 prospective investors, analysts, credit rating agencies,
15 and other participants in the capital markets, it is
16 apparent that they are heavily focused on the Company' s
17 ability to maintain balance sheet strength going into and
18 through this heavy period of capital expenditures, as well
19 as the willingness of the state regulatory commissions to
20 maintain the financial health of the Company through rates
21 that reduce regulatory lag, increase cash flows, allow
22 access to capital markets at a reasonable amount and cost,
23 and allow the Company an opportunity to earn a reasonable
24 return. As such, an authorized ROE responsive to that
25 investor sentiment is important to Idaho Power' s financial
BUCKHAM, DI 22
Idaho Power Company

1 health, and thus ultimately to customer rates for the
2 Company' s cost of financing.
3 Q. You mentioned the impact of elevated interest
4 rates . How do interest rates affect the required ROE?
5 A. As Idaho Power competes with other investments
6 (both stocks and bonds) in the capital markets, to attract
7 capital at reasonable costs the Company must provide a
8 return that adequately compensates its investors relative
9 to the risk of other investments . With elevated interest
10 rates, investors can obtain relatively higher returns on
11 debt instruments while retaining a much lower risk profile
12 relative to stocks . The Company is competing not only with
13 other utilities for capital, but also with businesses in
14 other sectors . More recently, the Company is also
15 competing with the risk-free Treasury rate, which has made
16 utility dividends, and IDACORP' s relatively low dividend in
17 particular, less attractive. To compete as an investment,
18 utilities must then provide the opportunity for a higher
19 return commensurate with their higher relative risk level .
20 Q. Can you quantify the recent increases in
21 interest rates?
22 A. Certainly. As seen in the chart below (based
23 on data from Yahoo Finance as of May 19, 2025) , 30-year US
24 Treasury bond yields have risen from around 1 . 8 percent
25 near the start of 2022, peaking at over 5 . 0 percent in fall
BUCKHAM, DI 23
Idaho Power Company

1 of 2023, and remaining as high as 4 . 98 percent in January
2 2025, a nearly 300 percent increase over that time period.
3 Please refer to Exhibit No. 15 for daily Treasury bond
4 yields from 2022 to current.
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8 Q. Have markets been more or less stable in
9 recent months during this time period?
10 A. Capital markets have grown increasingly
11 unstable in 2025 . Using a 30-day moving average of the COBE
12 VIX index, which is a real-time index that represents the
13 market' s expectations for the relative strength of near-
14 term price changes of the S&P 500 Index, the peak
15 volatility in 2025 was 34 percent higher than peak
16 volatility in 2023, pointing to the more anxious market.
17 This volatility is also a key factor in Idaho Power' s
BUCKHAM, DI 24
Idaho Power Company

1 proposed 10 . 4 percent ROE . Exhibit No. 16 supplies data
2 underpinning this summary.
3 Q. Based on current market conditions, do you
4 believe Idaho Power' s request for a 10 . 4 percent ROE is
5 justified?
6 A. Yes . Based on the market characteristics I
7 just described, I would consider Idaho Power' s requested
8 10 . 4 percent ROE to be conservative in nature.
9 Additionally, as I will discuss in detail in the next
10 section of my testimony, Idaho Power faces several specific
11 risks that further bolster its request for a 10 . 4 percent
12 ROE .
13 III . RISK FACTORS
14 Q. While you have highlighted several risks
15 already earlier in your testimony, could you briefly
16 outline the risks confronting the Company that further
17 support your recommendation for a 10 . 4 percent ROE as the
18 authorized return?
19 A. Yes . I will summarize them here and discuss
20 each in greater detail later in my testimony. I believe
21 that a 10 . 4 percent ROE is required to properly account for
22 the risks confronting Idaho Power for the following
23 reasons :
24 (1) The general decline in the Company' s credit
25 quality, in conjunction with the growing need for
BUCKHAM, DI 25
Idaho Power Company

1 access to debt and equity capital to fund the
2 Company' s growing capital expenditures in
3 response to recent and expected future economic
4 growth in its service area. The Company forecasts
5 capital expenditures of approximately $6 . 1
6 billion from 2025 to 2029 to reliably serve
7 customer needs, for which it will need
8 substantial debt and equity capital .
9 (2) Energy market volatility and associated liquidity
10 challenges .
11 (3) Large and growing Public Utility Regulatory
12 Policies Act of 1978 ("PURPA") project and Power
13 Purchase Agreement ("PPA") expenditures, and more
14 recently, energy storage agreement expenditures .
15 (4) Risks related to wildfires from a financial,
16 reliability, insurability, reputational, and
17 operational standpoint.
18 (5) The renewal of federal licenses for the Company' s
19 hydroelectric projects, primarily the Hells
20 Canyon Complex, which provides 36 percent of the
21 Company' s total generating nameplate capacity,
22 and particularly the costs and uncertainties
23 associated with the relicensing of that project .
24 (6) Increased risks related to power reliability, as
25 well as execution risk associated with
BUCKHAM, DI 26
Idaho Power Company

1 infrastructure projects intended to address
2 growth and maintain reliability.
3 (7) Risks and uncertainties related to new or
4 proposed legislation and requirements, executive
5 orders, tax proposals, tariffs, and their impacts
6 on the Company' s planning and operations .
7 (8) The increasing risks of cyber and physical
8 security attacks on Idaho Power' s and other
9 entities' infrastructure .
10 (9) The impacts of changing weather conditions on the
11 Company, including the perceived risk in the
12 financial community associated with the
13 variability of the Company' s hydroelectric
14 generating base, variances in sales, impacts on
15 operations, reputational concerns, and
16 application of investment policies .
17 (10) The Company' s small size in terms of market
18 capitalization and concentrated geographic and
19 associated regulatory risk (i . e . , 96 percent of
20 the Company' s business is in Idaho) .
21 (11) The financial impact of a lag in the recovery of
22 costs associated with higher capital
23 expenditures, including growing depreciation
24 expense and the higher costs of financing those
25 capital expenditures .
BUCKHAM, DI 27
Idaho Power Company

1 (12) Heightened scrutiny by equity investors,
2 analysts, lenders, and credit rating agencies, of
3 authorized ROEs and regulatory outcomes, and the
4 disproportionate impact it has on the success of
5 debt and equity financing transactions,
6 particularly in light of the magnitude of the
7 Company' s need for equity issuances .
8 I address several of those risks below in my
9 testimony. Many of the risks associated with the Company
10 and IDACORP, and that factor into equity and debt
11 valuations, are included in the Annual Report on Form 10-K
12 that the Company files with the US Securities and Exchange
13 Commission, under the heading "Risk Factors . " For the Form
14 10-K filed in February 2025, that section of the document
15 was approximately 14 pages in length, owing to the
16 substantial risks that the Company faces .'
17 Credit Ratings, Capital Market Expectations, and Balance
18 Sheet Pressures
19 Q. What is the status of Idaho Power' s credit
20 ratings, and how does that compare to peer utilities?
21 A. Idaho Power' s credit ratings as of May 30,
22 2025, are as follows :
23
2 The Company's 10-K is available at:
https://dl8rnOp25nwr6d.cloudfront.net/CIK-0000049648/Oel6568d-8ad5-
4306-83e6-1d338bfa96d7.pdf
BUCKHAM, DI 28
Idaho Power Company

1 TABLE 1
2 Idaho Power Credit Ratings as of May 30, 2025
Moody' s
Standard and Investors
&Nd&L- Poor' s Rating Service
Services (S&P) (Moody' s)
Corporate Credit Rating BBB Baal
Senior Secured Debt A- A2
Senior Unsecured Debt BBB Baal
Commercial Paper A-2 P-2
Rating Outlook Stable Negative
3 Unfortunately, these credit ratings place the Company on
4 the lower end of the distribution curve for credit ratings
5 with, for example, the bulk of utilities having an S&P
6 credit rating of A- or BBB+. Ideally, the Company would
7 have a credit rating at that higher level, as it would
8 result in lower cost debt and equity and a more comfortable
9 gap from "junk" status, which ultimately inures to the
10 benefit of customers through rates .
11 Q. Have there been any changes in the Company' s
12 credit ratings recently?
13 A. Yes . In April 2024, Moody' s rating outlook for
14 Idaho Power was downgraded from stable to negative. This
15 followed a downgrade of Idaho Power' s long-term issuer
16 rating from A3 to Baal by Moody' s in July 2022 . In
17 addition, in July 2022, Moody' s ratings for First Mortgage
18 Bonds and Senior Secured Debt were downgraded to A2 from
19 Al . Also, in February 2023, S&P downgraded its liquidity
20 assessment of the Company from "strong" to "adequate . " The
BUCKHAM, DI 29
Idaho Power Company

1 2024 rating outlook downgrade by Moody' s occurred after
2 approval of the settlement stipulation in Case No. IPC-E-
3 23-11 ("2023 GRC") , but the negative outlook was confirmed
4 in March 2025 after the finalization of the 2024 Limited
5 Scope Rate Case, despite incorporating an expectation that
6 Idaho Power will file general rate cases in 2025 and
7 beyond.
8 Q. What is the Company' s assessment of the impact
9 of these downgrades?
10 A. As of now, the Company' s credit ratings remain
11 investment grade. However, Idaho Power' s corporate credit
12 rating for Moody' s is only two rating notches above the
13 cutoff to being below investment grade, referred to as
14 "junk bond" status . S&P' s corporate credit rating is only
15 one rating notch above the cutoff. And Moody' s has Idaho
16 Power' s credit rating on "negative watch, " recently
17 affirmed by Moody' s based on weak operating cash flow due
18 to regulatory lag.
19
20
21
22
23
24 Further ratings downgrades or imposition of a
25 negative watch from S&P would cause additional harm to the
BUCKHAM, DI 30
Idaho Power Company

1 risk perception of the Company in both the debt and equity
2 markets . If, for example, Idaho Power' s credit ratings were
3 to fall below investment grade, which would be below Baa3
4 for Moody' s and below BBB- for S&P, also known as "junk"
5 status, Idaho Power' s cost of borrowing would increase
6 substantially. Many investors represent funding sources
7 that expressly prohibit investing in junk bonds, such as
8 pension funds and insurance companies, which comprise a
9 significant portion of the utility debt investment market,
10 and junk status would thus substantially diminish the
11 marketplace for the Company' s debt securities . A change
12 below investment grade will also trigger significant
13 increases in collateral-related margining deposits as well
14 as significant cost increases for the Company' s credit
15 facility, which will increase costs to customers . That
16 downgrade would also further negatively impact IDACORP' s
17 stock price, decreasing the value the Company would receive
18 for IDACORP' s issuances in the equity markets .
19 A downgrade in the short-term debt rating could make
20 it difficult for the Company to issue commercial paper
21 under reasonable terms, if at all, which is an instrument
22 Idaho Power may rely upon during volatile power and fuel
23 markets for its liquidity and to meet margin requirements .
24 Additionally, in tight markets such as a recession,
25 liquidity for companies that are below investment grade
BUCKHAM, DI 31
Idaho Power Company

1 becomes extremely limited, resulting in lack of cash on
2 reasonable terms to finance the business .
3 The increased financing costs associated with weak
4 credit metrics and ratings would remain in the Company' s
5 cost of financing - and ultimately customer rates -
6 throughout the lives of the applicable financial
7 instruments . Idaho Power issues debt instruments with
8 maturities as long as 30 years, and IDACORP' s equity
9 issuances are effectively permanent as stock is generally
10 originally issued only once. Thus, the damage and cost to
11 customers of high-cost securities is long-tenured.
12 Q. How did Moody' s describe the reasons for its
13 current negative outlook?
14 A. In March 2025, Moody' s noted financial metrics
15 and a need for more timely rate relief as reasons for its
16 negative outlook, stating as follows :
17 Idaho Power' s financial profile has declined
18 due to a combination of high capital
19 expenditures, slow cash flow growth and the
20 lack of general rate cases (GRC) filed for
21 several years prior to June 2023 . We expect
22 IPC' s credit metrics to continue to be
23 pressured due to a sizeable capital
24 expenditure program that will necessitate
25 additional debt with a ratio of cash flow
26 from operations before changes in working
27 capital (CFO pre-WC) to debt expected to be
28 around 130 over the next two years . The
29 negative outlook reflects these weak credit
30 metrics that, despite supportive rate case
31 outcomes in 2023 and 2024, may not improve
32 due to the higher capital expenditures, the
33 lack of cost recovery mechanisms to expedite
BUCKHAM, DI 32
Idaho Power Company

1 cash flow recovery and limited equity
2 issuance to offset higher debt levels .
3
4 and
5 ... Although it expects to fund the negative
6 free cash flow with a mix of debt and equity
7 to maintain a 50/50 capital structure, cash
8 flow recovery could be delayed because
9 Idaho ' s regulatory framework lacks
10 mechanisms that could help expedite cash
11 flow collection.
12
13 Q. How did S&P characterize its February 2023
14 change?
15 A. S&P cited Idaho Power' s reliability and
16 economic growth-driven capital spending needs as reflecting
17 its liquidity downgrade, as it perceived "elevated capital
18 spending that will result in modest weakening of the
19 Company' s liquidity throughout the forecast period. "
20 Q. Would an improvement in credit ratings benefit
21 customers?
22 A. Yes . Stronger credit ratings would be
23 beneficial . New debt/bond issues are at a higher cost now
24 than if Idaho Power' s credit ratings were higher (i .e. , the
25 higher the credit rating, the lower the debt financing
26 cost) . Stronger credit ratings also result in more
27 liquidity in all market conditions, which could become
28 important as Idaho Power will be raising significant
29 amounts of equity and debt financing to fund its required
BUCKHAM, DI 33
Idaho Power Company

1 capital investments and operating costs over the next few
2 years .
3 Q. How else can credit ratings impact the Company
4 and its customers?
5 A. Idaho Power maintains margin agreements
6 relating to its wholesale commodity contracts that allow
7 performance assurance collateral to be requested of and/or
8 posted with certain counterparties . If Idaho Power
9 experiences a reduction in its credit rating on its
10 unsecured debt to below investment grade, Idaho Power could
11 be subject to requests by its wholesale counterparties to
12 post additional performance assurance collateral . Likewise,
13 counterparties to derivative instruments and other forward
14 contracts could request immediate payment or demand
15 immediate ongoing full daily collateralization on
16 derivative instruments and contracts in net liability
17 positions . For example, on March 31, 2025, the amount of
18 collateral that could be requested by counterparties upon a
19 downgrade to below investment grade was $21 . 5 million. The
20 costs to finance the cash needed to meet these margin
21 requirements would increase costs to customers .
22 Q. What factors could lead to a credit rating
23 upgrade or downgrade?
24 A. Moody' s shared their opinion on potential
25 factors that could lead to an upgrade in March 2025 :
BUCKHAM, DI 34
Idaho Power Company

1 A rating upgrade is unlikely given the
2 negative outlook. The rating of IPC could
3 be upgraded if key credit metrics increase
4 significantly, including a CFO pre-WC to
5 debt ratio sustained above 160 . An upgrade
6 could also occur if the utility' s
7 regulatory construct improves materially,
8 including authorization of cost recovery
9 mechanisms that result in faster cash flow
10 recovery, reducing regulatory lag and
11 limiting the reliance on debt .
12
13 Factors cited that could lead to a downgrade include:
14 A rating downgrade could occur if IPC ' s
15 credit metrics remain weak including a CFO
16 pre-WC to debt ratio sustained below 13% . A
17 rating downgrade could also occur if there
18 is an adverse rate case outcome or a decline
19 in regulatory support for the utility.
20
21 Per S&P in March 2025, factors that could lead to an
22 upgrade include :
23 We could raise our ratings on Idaho Power
24 if IDACORP strengthens its business risk
25 profile through more-robust management of
26 its regulatory relationships, improves its
27 operating efficiency, and strengthens its
28 cash flow measures such that its FFO to debt
29 consistently exceeds 200 .
30
31 Factors cited that could lead to a downgrade include:
32 We could lower our ratings on Idaho Power
33 if we lower our ratings on IDACORP, which
34 could occur if its business risk increases
35 because of the unsupported recovery of
36 operating expenses, including a higher-
37 than-average reliance on purchased power or
38 unsupported capital investments through the
39 regulatory process . Furthermore, we could
40 downgrade IDACORP if its consolidated
41 financial measures consistently
42 underperform our base-case assumptions,
43 leading it to sustain FFO to debt of
44 consistently below 140 .
BUCKHAM, DI 35
Idaho Power Company

1 Q. Are there any other considerations mentioned
2 by the rating agencies that could point to future downgrade
3 risks?
4 A. Yes . Moody' s pointed to regulatory lag on
5 material investments that, in its view, overshadows
6 regulatory mechanisms that are in place in Idaho.
7 Specifically, Moody' s stated in March 2025 that:
8 ...the utility' s financial profile has
9 historically lagged peers due to certain
10 unusual regulatory constructs, such as
11 flow-through tax accounting and the long-
12 lived depreciation of its hydro asset base.
13 Since Idaho lacks the type of timely
14 investment and operating cost recovery
15 mechanisms seen in many other states, IPC' s
16 cash flow growth is primarily dependent
17 upon general rate case (GRC) filings, which
18 it had not filed for 12 years prior to its
19 2023 GRC filed in June 2023 . IPC also filed
20 a limited scope GRC filing in May 2024,
21 with a relatively supportive outcome, and
22 it plans to file another GRC in 2025 .
23
24 Q. When determining Idaho Power' s credit ratings,
25 do the rating agencies consider wildfire risk in Idaho
26 Power' s service area?
27 A. Both rating agencies have highlighted wildfire
28 risk as a key risk or credit challenge in their most recent
29 credit rating reports . In March 2025, Moody' s indicated:
30 IPC' s credit profile is further pressured
31 by wildfire risk in its service territory,
32 which we view as moderate due to the
33 company' s well developed mitigation plans .
34 IPC has a total of 34, 415 miles of
35 transmission and distribution lines across
BUCKHAM, DI 36
Idaho Power Company

1 Idaho and Oregon, most of which is exposed
2 to wildfires to some degree... Although IPC
3 has experienced several wildfires within
4 its service territories over the years,
5 including several major wildfires in the
6 last three years, to date, IPC has not had
7 wildfire losses large enough to exceed its
8 insurance coverage . Additionally, IPC
9 successfully implemented its PSPS program
10 during the 2024 wildfire season. This
11 demonstrates the strength of IPC ' s
12 planning and execution, which we view
13 positively. Nevertheless, the utility
14 remains exposed to litigation risk that
15 could lead to court decisions that result
16 in severe losses to the company.
17
18 S&P also noted Idaho Power' s exposure to wildfire risk as a
19 "key risk" in its March 2025 ratings report for Idaho
20 Power:
21 To date, the company has not experienced
22 any significant liability due to wildfires
23 in its operating jurisdictions; however,
24 we believe it faces an elevated exposure
25 to wildfires in some parts of its service
26 territory.
27
28 Q. What are Idaho Power' s expected near-term
29 capital needs?
30 A. Over the five-year period from 2025-2029,
31 Idaho Power anticipates spending between $5 . 35 and $6 . 05
32 billion, and approximately $2 .25 billion in 2025-2026, on
33 new property, plant, and equipment to serve customers .
34 Those amounts could increase, for instance, depending on
35 the outcomes of pending requests for proposals . For
36 comparison, Idaho Power' s annual capital expenditures have
BUCKHAM, DI 37
Idaho Power Company

1 averaged about $554 million over the five-year period from
2 2020-2024, and they were considerably lower for the five-
3 year period preceding that period. On February 20, 2025,
4 Idaho Power disclosed its capital expenditure estimates for
5 purposes of IDACORP' s fourth quarter earnings press release
6 and 2024 Annual Report on Form 10-K. Those capital
7 expenditures are represented in a chart filed with the US
8 Securities and Exchange Commission on a Form 8-K on
9 February 20, 2025 . The chart was as follows :
Capital Expenditures ForecastM u
ncM
2025-2029
$1,500
$1,400
$1,300 '$1,127M per year
$1,200 average forecast
$1,100
$1,000
„ $900 —103%
$900 increase
f $700
$600
$$00
---- -------- -------- -------- -------- -- --
$400 `$554M actual
$300 per year average,
$200 previous 5 years
$100
$o
2025 2026 2027 2028 2029
■New Capacity&Energy Resources($OM-$463M) ■Distribution($21610-$26210) ■High Voltage Transmission($190M-$406M)
■Transmission($87M-$222M) ■Hydro($107M-$166M) ■General Plant($76M-$304M)
■Thermal($1010-$6810)
13 1%ofFE ,20,2025.TW v.pM 4.nprof ,ionof,*S.w.opPlule.perMitwts fret...S.MOW,2024 Form 2o.for.WmnurY of Wokct InNn 1n[h,0.0 in nit S-e,fo,­t
10 The amount of capital expenditures shown for 2028
11 and 2029 could increase, depending on a number of factors,
12 including the outcomes of pending requests for proposals .
13 Several factors, including those identified in the 2024
14 Annual Report on Form 10-K described above, could cause
15 costs in any year listed in the table to increase. This
BUCKHAM, DI 38
Idaho Power Company

1 amount of capital expenditures perpetuates the Company' s
2 need for debt and equity financing, as cash flows are
3 grossly inadequate to fund these expenditures .
4 Q. Do you believe the relief requested in this
5 case will serve to stabilize or improve the Company' s
6 credit ratings going forward?
7 A. I believe it could stabilize the current
8 credit ratings but not improve them. The credit rating
9 agencies have built their models and assumptions, in part,
10 based on forecasts Idaho Power has discussed with them over
11 the past few years . Those forecasts have contemplated in
12 many respects the rate relief requested in this case. In
13 addition, this case requests additional return of and
14 return on rate base that has been placed into service since
15 the last general rate case, and that substantial investment
16 has carried regulatory lag from a cash flow perspective.
17 The credit rating agencies will view as positive the
18 Company' s requests in this case to continue to address
19 needed cash collections related to regulatory deferrals,
20 such as those related to wildfire mitigation expenses, as
21 well as the depreciation and interest expense tracker
22 described in Mr. Tatum' s testimony. But they will
23 understandably be more focused on the Commission' s actual
24 order in this case rather than the Company' s request . They
25 will assess the ultimate order from the perspective of the
BUCKHAM, DI 39
Idaho Power Company

1 revenue change, overall constructiveness of the regulatory
2 environment, and degree to which it mitigates regulatory
3 lag. Investors, analysts, and debt holders will also
4 assess those same items .
5 Q. Does Idaho Power' s substantial equity need
6 factor into investors' and rating agencies' assessment of
7 risk and the appropriate ROE?
8 A. Yes, it does . As I noted in my general
9 overview above, Idaho Power (through its publicly traded
10 parent IDACORP) has the highest equity capital need
11 relative to market capitalization of all investor-owned
12 utilities in the U. S . , and it has entered into transactions
13 for a staggeringly high amount of equity for a company of
14 Idaho Power' s size. Those equity issuances are dilutive to
15 existing shareholders, and they are demonstrative of
16 contributions from net income being inadequate to maintain
17 a balance sheet at a strong 50 percent debt, 50 percent
18 equity level . That net income deficiency is due in large-
19 part to inadequate revenues from customer rates to fund the
20 Company' s operations . Idaho Power' s ability to raise the
21 equity capital, and also the debt capital, necessary to
22 fund its capital investment and operating expenses is a
23 risk the investment community has identified and cited as a
24 concern based on the size of the Company relative to its
25 needs .
BUCKHAM, DI 40
Idaho Power Company

1 Energy Market Volatility and Liquidity Challenges
2 Q. How have recent events in the energy markets
3 impacted the Company?
4 A. Higher and more volatile prices in the energy
5 and natural gas markets continue to create risks for the
6 Company, though the drivers of that volatility have
7 evolved. While global events and relatively low hydro
8 conditions were key contributors in 2022 and 2023, current
9 volatility is increasingly tied to structural shifts in the
10 energy landscape, particularly the accelerated retirement
11 of coal-fired generation and the rapid addition of variable
12 energy resources like wind and solar in the western US .
13 These changes have reduced the availability of dispatchable
14 generation and increased reliance on intermittent
15 resources, which can lead to sharp price swings, especially
16 during periods of high demand or limited renewable output.
17 Although wholesale market prices have moderated from recent
18 peaks, volatility remains relatively high and continues to
19 impact power supply costs . The power cost adjustment
20 mechanism ("PCA") helps mitigate in-part the financial
21 effects of this volatility, but the Company still absorbs a
22 portion of the cost variance. For example, for the
23 Company' s April 2024-March 2025 PCA year, total actual
24 power supply costs were approximately $550 million,
25 compared to base power supply costs of $484 . 9 million.
BUCKHAM, DI 41
Idaho Power Company

1 After jurisdictionalization and the PCA mechanism' s 95
2 percent/5 percent sharing was applied to the majority of
3 the variance, this resulted in $3 . 8 million of increased
4 power supply costs being absorbed by the Company. While
5 this GRC will establish new base power supply costs that
6 will help mitigate some of this impact, continued
7 volatility will likely continue to negatively impact the
8 Company and its cash flows, and thus the return expected by
9 investors .
10 Additionally, higher prices and volatility in the
11 energy and natural gas markets impact the Company' s
12 liquidity. While the PCA mechanism mitigates in-part the
13 potential adverse earnings impacts to Idaho Power of
14 fluctuations in power supply costs, collection from
15 customers of most of the difference between actual power
16 supply costs compared with those included in retail rates
17 is deferred to a subsequent period, which can affect Idaho
18 Power' s operating cash flow and liquidity until those costs
19 are recovered from customers . In 2023, revenue collection
20 lag associated with the PCA mechanism caused cash flows to
21 be alarmingly low.
22 Further, as mentioned earlier in my testimony,
23 wholesale commodity contracts often require performance
24 assurance collateral be posted with counterparties . During
25 recent energy market price spikes, the Company was required
BUCKHAM, DI 42
Idaho Power Company

1 to post very large amounts of cash collateral,
2 significantly straining its available liquidity. To give an
3 order of magnitude, one relatively recent margin call was
4 nearly $50 million of cash performance assurance collateral
5 related to energy market contracts .
6 PURPA and PPA Expenditures and Associated Credit and Equity
7 Impacts
8 Q. What is the significance of PURPA, PPA, and
9 Battery Storage Agreement ("BSA") expenditures?
10 A. The Company has significant amounts of
11 financial commitments related to PURPA facilities, other
12 PPAs, and BSAs . In Idaho Power' s 2024 Annual Report on Form
13 10-K, it cites contractual obligations associated with
14 these contracts totaling nearly $7 . 1 billion. Additional
15 contracts signed in 2025 and awaiting Commission approval
16 push that total to nearly $8 .2 billion .
17 The regulatory cost recovery treatment for these
18 costs is typically one-for-one recovery of dollars
19 expended, meaning neither provides for any return to
20 compensate the Company for its long-term purchase
21 obligation under the applicable contract, despite it being
22 a debt-like obligation and long-term capital commitment.
23 The Company is, in effect, buying and selling energy
24 (pursuant to a legal mandate in the case of qualifying
25 facilities (%Fs") ) without any compensation for providing
BUCKHAM, DI 43
Idaho Power Company

1 this service . The mere dollar-for-dollar recovery of these
2 expenditures and the significant size of the obligation,
3 with no return for the use of the Company' s general and
4 administrative resources, balance sheet, and liquidity in
5 managing QF programs, PPAs, and BSAs, is viewed as a long-
6 term contractual and debt-like obligation, and thus a risk,
7 by the rating agencies . The rating agencies are not making
8 a judgment related to the appropriateness of QF or PPA- or
9 BSA-based energy purchase programs, but merely pointing out
10 the cost of the financial risk (s) arising from a QF or
11 PPA/BSA transaction, and that this risk should be reflected
12 in a higher ROE to recognize the impact of the Company' s QF
13 and PPA/BSA contracts .
14 Q. Do the rating agencies recognize the financial
15 costs of QF and PPA/BSA transactions beyond the contract
16 price?
17 A. Yes . Like other electric utilities, when the
18 Company adds to its rate base, it must use some portion of
19 shareholder equity to fund the investment. The Company must
20 maintain its proportion of equity to debt above a certain
21 level as it continues this investment process . If it does
22 not, the debt level increases and the Company will face the
23 threat of a ratings downgrade. Conversely, when the Company
24 enters into a QF or PPA contract for purchased power, an
25 obligation is generally not reflected in the Company' s
BUCKHAM, DI 44
Idaho Power Company

1 financial statements; however, the rating agencies add to
2 the financial statement an imputed debt for the QF or PPA,
3 resulting in an increase in total debt and a need to
4 increase equity in order to maintain credit quality. BSAs
5 appear on the financial statements as long-term lease
6 obligations, and thus receive debt-like treatment, when the
7 battery storage projects begin commercial operation.
8 Unless an equity component is provided to offset the
9 debt-like obligation of those long-term contracts, the
10 Company faces off-balance sheet financial risk that
11 threatens a reduction in credit ratings . For financial
12 commitments that are not presented on the balance sheet,
13 rating agency analysts impute the debt and interest
14 equivalents on the financial statements of the Company to
15 achieve a more accurate picture of the risk associated with
16 the investment and the Company' s related commitment. For
17 BSAs that appear as a long-term lease obligation on the
18 balance sheet, the credit rating agencies apply that
19 directly to the debt load. The added equity needed to
20 offset this imputed debt, interest cost, and long-term
21 lease obligation represents the effect that long-term
22 purchased power and battery storage commitments have on the
23 cost of capital . An increase in the long-term obligation of
24 a utility related to its capacity and energy resources will
BUCKHAM, DI 45
Idaho Power Company

1 have to be backed by an appropriate amount of equity in the
2 eyes of the ratings agencies .
3 In reviewing its evaluation of the credit
4 implications of QF-related expenditures, in November of
5 2013, as stated below, S&P noted that it viewed such
6 agreements as creating "fixed debt-like financial
7 obligations" that must be considered in evaluating a
8 utility' s credit risks .
9 We view long-term purchased power
10 agreements (PPA) as creating fixed, debt-
11 like financial obligations that represent
12 substitutes for debt-financed capital
13 investments in generation capacity. By
14 adjusting financial measures to incorporate
15 PPA fixed obligations, we achieve greater
16 comparability of utilities that finance and
17 build generation capacity and those that
18 purchase capacity to satisfy new load. PPAs
19 do benefit utilities by shifting various
20 risks to the electricity generators, such
21 as construction risk and most of the
22 operating risk. The principal risk borne by
23 a utility that relies on PPAs is recovering
24 the costs of the financial obligation in
25 rates .
26
27 ...Risk factors based on regulatory or
28 legislative cost recovery typically range
29 between 0 o and 50 0, but can be as high as
30 1000 . A 100% risk factor would signify that
31 substantially all risk related to
32 contractual obligations rests on the
33 company, with no regulatory or legislative
34 support . A 0% risk factor indicates that
35 the burden of the contractual payments
36 rests solely with ratepayers .
37
38 Q. How material are QF- and PPA/BSA-related
39 expenditures?
BUCKHAM, DI 46
Idaho Power Company

1 A. As of the end of 2024, Idaho Power had online
2 QF and PPA contracts representing 1, 524 megawatts ("MW") of
3 capacity, and an additional 1, 048 MW of capacity from
4 signed contracts scheduled to be online through 2027 . Idaho
5 Power also had commitments for 250 MW of output from
6 battery storage units under BSAs . In 2024, the Company
7 incurred approximately $294 million of expense related to
8 QF and PPA projects . As of December 31, 2024, the Company
9 is obligated to pay approximately $7 billion to QF and PPA
10 developers over the remaining life of these contracts . To
11 provide context on how significant the $7 billion liability
12 is to Idaho Power, the Company' s total long-term debt
13 obligation at year-end 2024 is only $3 billion. The QF and
14 PPA obligations are over 230 percent of the debt financing
15 for all assets the Company owns to serve customers .
16 Q. Are QF and PPA/BSA expenses increasing?
17 A. Yes . Idaho Power has been engaged in resource
18 procurement activities that the Company expects will result
19 in several new, large PPAs and BSAs to meet future resource
20 needs . Currently, Idaho Power has 745 MW of signed solar
21 PPAs, a signed 300 MW wind PPA, and 250 MW of signed
22 battery BSAs, all expected to be online between 2025 and
23 2027, with additional substantial resource procurement in
24 the competitive bidding process . The substantial and
25 increasing obligations of PURPA QF, PPAs, and BSAs create a
BUCKHAM, DI 47
Idaho Power Company

1 material risk factor for Idaho Power and increase costs to
2 customers due to the imputed debt associated with these
3 agreements .
4 Wildfire Risks, Insurability, and Insurance Costs
5 Q. Please describe the increased risks associated
6 with wildfires .
7 A. Since the 1980s, wildfire activity in the
8 United States in terms of acres burned has more than
9 tripled and, according to the National Interagency Fire
10 Center, western states account for upwards of 95 percent
11 of the acres burned in recent years . While Idaho Power has
12 not experienced catastrophic wildfires within its service
13 area at the same level experienced in other western
14 states, such as California and Oregon, millions of acres
15 of rangeland and southern Idaho forests have burned in the
16 last 30 years .
17 A variety of factors have contributed to more
18 destructive wildfires, including climate change, increased
19 human encroachment in wildland areas, historical land
20 management practices, and changes in wildland and forest
21 health, among other factors .
22 Specific to Idaho Power, wildfires have the
23 potential to damage or destroy the Company' s facilities,
24 impact personnel, and cause significant harm to Idaho
25 Power' s customers and the communities in which the Company
BUCKHAM, DI 48
Idaho Power Company

1 serves . Company Witness Mr. Mitch Colburn provides a more
2 detailed discussion of wildfire risk in his testimony.
3 Q. Have Idaho Power' s overall insurance premium
4 costs increased in recent years?
5 A. Yes . While Idaho Power undertakes significant
6 efforts to manage the cost of insurance and obtain the
7 greatest insurance value possible for its customers, the
8 Company is to some degree a price-taker in the insurance
9 market . In that regard, despite annual assessment of its
10 insurance portfolio to identify the best value and the
11 retention of an experienced insurance broker, the Company
12 is subject to price increases as insurers raise premiums
13 due to losses, either pertaining to Idaho Power or to
14 insurers' overall insured base.
15 Idaho Power' s wildfire insurance premium costs
16 continue to increase. Much of the increase in premiums is
17 attributable to the frequency and magnitude of western-
18 state wildfires in recent years, as well as insurance
19 providers' perceptions of Idaho Power' s specific wildfire
20 risk. The sizable increase in Idaho Power' s premiums became
21 prominent in 2024 due in part to the loss of insurance
22 capacity provided by the insurance providers . Energy
23 Insurance Mutual reduced wildfire insurance capacity from
24 $75 million in 2023 to $25 million in 2024 . This required
25 Idaho Power to secure insurance from the commercial
BUCKHAM, DI 49
Idaho Power Company

1 insurance market where insurance rates are substantially
2 much more than what the Company was historically able to
3 secure through the utility mutuals .
4 To help manage the costs of insurance, Idaho Power
5 has taken actions such as intense marketing of its programs
6 as needed, formation of a captive insurance program to
7 access the reinsurance market, reviewing and adjusting of
8 self-insured retentions, meeting regularly with insurers to
9 provide details on risk-mitigation practices, and regularly
10 assessing the adequacy of overall coverage. While these
11 efforts have resulted in benefits, costs of insurance for
12 the Company, and for the industry as a whole, have
13 increased notably in recent years .
14 Q. Does Idaho Power anticipate these premium
15 increases will continue?
16 A. Because insurance markets continue to be
17 volatile, premium increases are difficult to forecast .
18 Idaho Power anticipates that, notwithstanding its heavy
19 efforts to negotiate favorable rates and coverage, premiums
20 for insurance will continue to increase for the foreseeable
21 future . This trend has been echoed by Idaho Power' s third-
22 party insurance broker, who has explained that insurance
23 premiums will continue to increase due to prior losses
24 incurred by insurance providers and projected increased
25 risks of losses by insurers from wildfires .
BUCKHAM, DI 50
Idaho Power Company

1 Q. Aside from insurance premium increases, which
2 are representative of third-party assessments of Idaho
3 Power' s wildfire risk, does wildfire risk impact the cost
4 of capital?
5 A. Yes, it does . In recent years, credit rating
6 agencies have inquired about Idaho Power' s wildfire risk
7 and the efforts it undertakes to mitigate the risk.
8 Investment analysts and current and prospective debt and
9 equity investors also frequently inquire about wildfire
10 risk and mitigation efforts . This was elevated by the
11 Pacific Gas & Electric bankruptcy that resulted in large
12 part from wildfire liability associated with numerous
13 California wildfires ignited by the utility, as well as
14 subsequent large wildfires throughout the western U. S .
15 Credit rating agencies, analysts, and investors have
16 inquired about operating practices, financial exposure,
17 insurance coverage, legal risks, and other topics relevant
18 to wildfire liability, and the exposure the Company has to
19 wildfires factors . They then incorporate this information
20 into their decision about whether to purchase debt and
21 equity securities and in credit ratings, and the pricing
22 associated with those securities, and thus ultimately the
23 cost of capital, in much the same way that exposure
24 influences insurance premiums .
25
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Idaho Power Company

1 Hydroelectric Facility Relicensing Risks and Costs
2 Q. What risks are associated with the Company' s
3 relicensing efforts for its hydroelectric facilities?
4 A. Relicensing of the Company' s hydroelectric
5 facilities will create additional obligations . It involves
6 large capital expenditures, increased operating costs, and
7 reduced hydropower generation, all of which can negatively
8 affect Idaho Power' s results of operations and financial
9 condition. For the last several years, Idaho Power has been
10 engaged in an effort to renew its federal license for its
11 largest hydropower generation source, the Hells Canyon
12 Complex ("HCC") . Idaho Power is also in the process of
13 relicensing the American Falls hydroelectric facility.
14 Relicensing and ongoing permitting requirements
15 include an extensive public review process that involves
16 numerous natural resource issues and environmental
17 conditions . For instance, the existence of endangered and
18 threatened species in the watershed may result in major
19 operational changes to the region' s hydropower projects,
20 which may be reflected in hydropower licenses, including
21 for the HCC and the American Falls facilities .
22 In addition, new interpretations of existing laws
23 and regulations could be adopted or become applicable to
24 hydropower facilities, which could further increase
25 required expenditures for endangered species protection and
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Idaho Power Company

1 other environmental compliance obligations and reduce the
2 amount of hydropower generation available to meet Idaho
3 Power' s generation requirements . Idaho Power cannot
4 accurately predict the requirements that might be imposed
5 during the relicensing and permitting process, or the
6 financial or operational impact of those requirements .
7 Q. Are there other hydroelectric relicensing-
8 based financial risks considered by the investment
9 community?
10 A. Yes . For any particular generating facility,
11 the worst possible outcome would be the loss of the license
12 to a competing party. Along with the uncertainty as to the
13 eventual receipt of licenses and the costs involved in
14 preparing for the license applications, costs of
15 protection, mitigation, and enhancement ("PM&E") related to
16 these projects are also difficult to quantify. The
17 potential financial magnitude of these PM&E costs and their
18 effect on the Company' s low-cost hydro generation resources
19 threaten the financial stability of a company the size of
20 Idaho Power and the ultimate rates it must charge its
21 customers . These amounts will vary among facilities;
22 however, in all cases, they can be significant due to lost
23 generation capacity, generation at a higher cost, and the
24 decreased ability of the Company to time and control water
25 releases . If the Company cannot generate when it is most
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Idaho Power Company

1 advantageous for the system, then some of the economic
2 value of the generation will be lost even if the amount of
3 total generation does not change.
4 Q. What will occur when the Company receives a
5 new license for the Hells Canyon facilities?
6 A. The amounts in construction work in progress
7 ("CWIP") will be transferred to plant in service and the
8 accumulation of AFUDC will cease and the amortization of
9 the relicensing costs will start. The result will be an
10 increase in rate base, net of the accrued balance in the
11 regulatory liability account for pre-collected amounts
12 received relative to the allowance for funds used during
13 construction ("AFUDC") , with earnings of the Company
14 declining substantially unless or until this additional
15 amount is included in rate base and reflected in rates,
16 since there will be no ongoing contribution to earnings
17 from AFUDC . This is a notable risk to the Company' s
18 financial condition. Because this is a relicense of an
19 existing hydro facility, there will be no increase (and
20 potentially a decrease due to operational changes) in the
21 generation of power and thus no increase in sales revenues .
22 Q. What other risks does the relicensing process
23 create?
24 A. As Idaho Power' s largest single generating
25 resource, continued operation of the HCC and failure to
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Idaho Power Company

1 renew a federal license for HCC could have a dramatic
2 operational impact. Further, imposition of onerous
3 conditions in the relicensing and permitting processes
4 could result in Idaho Power incurring significant
5 additional capital expenditures, increase operating costs
6 (including power purchase costs) , and reduce hydropower
7 generation, which could negatively affect the financial
8 condition of the Company and the prices its customers pay
9 for electricity.
10 Reliability Risk and Execution Risk on Infrastructure
11 Q. What issues with reliability are creating
12 additional risk?
13 A. The transition to intermittent renewable
14 energy resources in the region, transmission constraints,
15 retirement of baseload fossil fuel plants, aging
16 infrastructure, demand growth, weather conditions and
17 wildfires, and other factors have all impacted the
18 Company' s ability to reliably provide energy. As noted in
19 Ms . Lisa Grow' s testimony, the Company is making a
20 concerted effort to maintain reliability using a variety of
21 programs . However, the aforementioned items do subject the
22 Company to greater reliability risks than existed in the
23 past .
24 Q. Besides the risk of not being able to deliver
25 energy, what other risks does reliability entail?
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Idaho Power Company

1 A. Idaho Power could be subject to regulatory
2 penalties, reputational harm, legal claims, and operational
3 changes if it fails to provide reliable service or violates
4 mandatory reliability and security requirements . The
5 obligation to provide reliable service also entails a
6 significant commitment of capital, both for operating and
7 maintenance expenses and for capital improvements . As I
8 noted previously, Idaho Power is in a stage of significant
9 capital investment, upgrading and constructing the
10 resources needed to reliably serve customers . The capital
11 needed to maintain reliability introduces two elements of
12 risk -- the ability of the Company to attract that required
13 capital, and the recovery of the investments on a deferred
14 basis and subject to the uncertainty of the regulatory
15 process .
16 There are also significant efforts at the national
17 level to reshape energy policy, and that can put upward
18 pressure on that spending and the associated need to
19 attract capital . New federal energy policies are evolving
20 and could introduce new spending requirements to meet
21 reliability standards and regulatory requirements .
22 Q. Are there other risks associated with Idaho
23 Power' s build-out of infrastructure to address reliability?
24 A. Yes . There are several considerable risks .
25 These risks include, as examples :
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Idaho Power Company

1 • the ability to timely obtain labor or materials
2 at reasonable costs;
3 • defaults and delays by suppliers and
4 contractors, including delays for specialty
5 equipment that require significant lead times;
6 • increases in price and limitations on
7 availability of commodities, materials, and
8 equipment;
9 • imposition of tariffs on commodities,
10 materials, and equipment sourced by foreign
11 providers;
12 • equipment, engineering, and design failures;
13 • credit quality of counterparties and suppliers
14 and their ability to meet financial and
15 operational commitments;
16 • unexpected environmental and geological
17 problems;
18 • the effects of adverse weather conditions;
19 • catastrophic events, natural disasters,
20 epidemics, pandemics and other public health or
21 disruptive events that could result in supply
22 chain disruptions, as well as permitting and
23 construction delays;
24 • availability of financing;
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Idaho Power Company

1 • the ability to obtain approval from local,
2 state, or federal regulatory and governmental
3 bodies and to comply with permits and land use
4 rights, and environmental constraints; and
5 • delays and costs associated with disputes and
6 litigation with third parties .
7 The occurrence of any of these risks could cause Idaho
8 Power to operate at reduced capacity levels, increase
9 expenses, incur penalties, and adversely affect Idaho
10 Power' s financial condition.
11 Environmental Issues and Risks
12 Q. Please describe the Company' s risks related to
13 environmental issues .
14 A. Idaho Power ' s operations are subject to
15 numerous federal, state, and local environmental statutes,
16 rules, and regulations relating to air and water quality,
17 natural resources, endangered species and wildlife,
18 renewable energy, and health and safety. Compliance with
19 environmental regulations can significantly increase
20 capital spending, operating costs, and plant availability
21 and can negatively affect the affordability of Idaho
22 Power' s services for customers .
23 Q. What are the costs associated with
24 environmental compliance?
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Idaho Power Company

1 A. Idaho Power' s current estimated compliance
2 expenditures for the three-year period from 2025 to 2027
3 are $156 million of capital expenditures and $151 million
4 of operating expenses, based on current environmental laws
5 and regulations . Idaho Power anticipates that finalization,
6 revocation, implementation, or modification of federal and
7 state rulemakings and other proceedings could result in
8 unanticipated changes in operating and compliance costs .
9 Idaho Power is unable to estimate the changes in costs that
10 could result, given the uncertainty associated with
11 existing and potential future regulations, but Idaho Power
12 expects the expenditures will remain substantial
13 regardless .
14 Q. What other impacts could environmental
15 compliance requirements have?
16 A. In some cases, the costs to obtain permits and
17 ensure facilities are in compliance may be prohibitively
18 expensive . In other instances, the permitting process might
19 substantially delay the Company' s ability to acquire
20 resources or construct infrastructure in accordance with
21 its resource planning process . Furthermore, Idaho Power may
22 not be able to obtain or maintain all environmental
23 regulatory approvals necessary for operation of its
24 existing infrastructure or construction of new
25 infrastructure.
BUCKHAM, DI 59
Idaho Power Company

1 Q. What would be the impact of prohibitively
2 expensive compliance costs or inability to acquire
3 regulatory approval to operate facilities?
4 A. If regulations render generating facilities
5 uneconomical or impossible to maintain or operate or to
6 timely construct, Idaho Power would need to identify
7 alternative resources for power, potentially in the form of
8 new generation and transmission facilities, market power
9 purchases, demand-side management programs, or a
10 combination of these and other methods .
11 Q. What impact do lengthy permitting processes
12 have on the ability to operate facilities and the Company' s
13 financial condition?
14 A. Idaho Power' s resource procurement and long-
15 term planning process, its Integrated Resource Plan
16 ("IRP") , assumes the ability of the Company to timely plan
17 and procure the necessary resources to serve load. Lengthy
18 permitting processes impact the Company' s ability to
19 execute on its lowest-cost, least-risk resource portfolios .
20 For example, the Boardman to Hemingway ("B2H") transmission
21 project was first identified in the preferred portfolio of
22 the Company' s 2009 IRP, with an estimated in-service date
23 of 2015 . Since that time, B2H has remained in subsequent
24 IRP preferred portfolios, and the Company has continued to
25 work to obtain the permits and approvals necessary for
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Idaho Power Company

1 construction of B2H, but the process has significantly
2 delayed construction and commercial operation of the
3 project . As of March 31, 2025, the Company has $216 million
4 in CWIP for future recovery for the B2H project. Similar to
5 the HCC relicensing, the prolonged B2H permitting process
6 negatively impacts liquidity and recovery of the costs is
7 subject to regulatory lag.
8 Physical Security and Cyber Security Risks
9 Q. What risks do physical security and
10 cybersecurity pose?
11 A. Idaho Power operates in an industry that
12 requires the continuous use and operation of sophisticated
13 information technology and increasingly complex operational
14 technology systems and network infrastructure. In addition
15 to those cyber assets, Idaho Power' s generation and
16 transmission facilities and its grid operations are
17 potential targets for terrorist acts and threats, acts of
18 war, social unrest, cyber and physical security attacks,
19 and other disruptive activities of individuals or groups,
20 including by nation states or nation state-sponsored
21 groups .
22 Q. Have there been recent examples of such
23 attacks?
24 A. Yes . There have been recent cyber and physical
25 attacks within the energy industry on infrastructure such
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Idaho Power Company

1 as electric substations and fuel pipelines, with notable
2 reports in the media of electric industry infrastructure
3 specifically being targeted for and impacted by physical
4 attacks more recently. There have also been multiple
5 reports of embedded vulnerabilities in U. S . energy
6 infrastructure . Unfortunately, there will be additional
7 attacks in the future. Idaho Power and its vendors have
8 been subject to, and will likely continue to be subject to,
9 continuous attempts to gain unauthorized access to systems
10 and confidential information, and efforts to disrupt
11 operations .
12 Q. Besides attempts to damage utility
13 infrastructure, are there other cybersecurity risks?
14 A. Yes . In the normal course of business, Idaho
15 Power or its vendors collect and store sensitive and
16 confidential customer and employee information and
17 proprietary information of Idaho Power . Idaho Power' s
18 technology systems are dependent upon connectivity to the
19 internet and third-party vendors to host, maintain, modify,
20 and update its systems, which may experience significant
21 system failures or cyberattacks that could compromise the
22 security of Idaho Power' s assets and information . All
23 information technology systems are vulnerable to
24 disability, unauthorized access, unintentional defects,
BUCKHAM, DI 62
Idaho Power Company

1 user error, errors in system changes, and cybersecurity
2 incidents .
3 Idaho Power is in the process of pursuing complex
4 business system upgrades, and these significant changes
5 increase the risk of system interruption. Any data security
6 breaches, such as misappropriation, misuse, leakage,
7 falsification, or accidental release or loss of information
8 maintained in Idaho Power' s information technology systems
9 or on third-party systems, including customer or employee
10 data, could result in violations of privacy and other laws
11 and associated litigation and liability for damages, fines,
12 and penalties; financial loss to Idaho Power or to its
13 customers; customer dissatisfaction or diminished customer
14 confidence; and damage to Idaho Power' s reputation, all of
15 which could materially affect Idaho Power' s financial
16 condition and results of operations .
17 No security measures can completely shield Idaho
18 Power' s systems, infrastructure, and data from
19 vulnerabilities to cyberattacks, human error, intrusions,
20 or other events that could result in their failure or
21 reduced functionality, and ultimately the potential loss of
22 sensitive information or the loss of Idaho Power' s ability
23 to fulfill critical business functions and provide reliable
24 electric power to customers . Despite the steps Idaho Power
25 may take to detect, mitigate, or eliminate threats and
BUCKHAM, DI 63
Idaho Power Company

1 respond to security incidents, the techniques used by those
2 who seek to obtain unauthorized access, and possibly
3 disable or sabotage systems or abscond with information and
4 data, change frequently and Idaho Power may not be able to
5 protect against all such actions .
6 Although Idaho Power continues to make investments
7 in its cyber and physical security programs, including
8 personnel, technologies, and training of personnel, there
9 can be no assurance that these systems or their expected
10 functionality will be implemented, maintained, or expanded
11 effectively; nor can security measures completely eliminate
12 the possibility of a cyber or physical security breach or
13 incident . Further, the implementation of security
14 guidelines and measures has resulted in, and Idaho Power
15 expects to continue to result in, increased costs .
16 Weather and Hydrologic Conditions Risks
17 Q. Are changes or variability in weather
18 conditions creating increased risk for the Company?
19 A. Yes, in a number of ways, including the
20 following:
21 • The price of power in the wholesale energy
22 markets tends to be higher during periods of
23 high regional demand that often occur with
24 weather extremes, which may cause Idaho Power
25 to purchase power in the wholesale market
BUCKHAM, DI 64
Idaho Power Company

1 during peak price periods, increasing power
2 supply costs . The PCA helps mitigate the
3 effects of energy market price volatility, but
4 the volatility levels can result in the Company
5 absorbing significant amounts of power supply
6 costs .
7 • The Company' s hydroelectric generating base
8 depends on water conditions in the Snake River
9 Basin. Warmer temperatures and changes in
10 precipitation levels and sustained drought
11 conditions can adversely affect the amount of
12 energy generated by its hydroelectric
13 generation facilities . Low water conditions in
14 the Snake River Basin, as well as in other
15 areas, can increase wholesale market prices due
16 to a lack of hydroelectric generation in the
17 region and a reliance on more costly energy
18 sources . This can result in power supply cost
19 variances that are absorbed by the Company, as
20 noted previously in my testimony.
21 • The increased frequency and severity of storms,
22 lightning, high winds, icing events, droughts,
23 heat waves, fires, floods, snow loading, and
24 other extreme weather events can damage
25 transmission, distribution, and generation
BUCKHAM, DI 65
Idaho Power Company

1 facilities, causing service interruptions and
2 extended or mass outages, which increases costs
3 and impairs Idaho Power' s ability to meet
4 customer energy demand.
5 • The costs of repairing and replacing
6 infrastructure or any costs related to Idaho
7 Power' s liability for personal injury, loss of
8 life, and property damage from utility
9 equipment that fails, including as a result of
10 significant weather and weather-related events
11 and fires, is not covered in full by insurance.
12 • Customers ' energy use could increase or
13 decrease based on variable weather conditions,
14 impacting the predictability of revenues and
15 earnings .
16 • Idaho Power has experienced certain
17 stakeholders, including investors and lenders,
18 placing importance on the impact and social
19 cost associated with climate change. The focus
20 on climate change may result in Idaho Power
21 facing adverse reputational risks associated
22 with certain of its operations that produce
23 carbon emissions or that mine coal, and
24 inquiries from investors on carbon-emitting and
25 coal mining operations persist. If Idaho Power
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Idaho Power Company

1 is unable to satisfy the expectations of
2 certain stakeholders, IDACORP and Idaho Power
3 may suffer reputational harm or reduce
4 investment interest. This could cause IDACORP' s
5 stock price to decrease or cause certain
6 investors and financial institutions not to
7 purchase the companies' debt securities or
8 otherwise provide the companies with capital or
9 credit on favorable terms, which may cause
10 IDACORP' s and Idaho Power' s cost of capital to
11 increase .
12 Company Size and Geographic Concentration
13 Q. Does IDACORP' s size have an impact on
14 investors' perceived level of risk?
15 A. Yes, IDACORP' s relatively small market
16 capitalization compared to its peers is a factor that makes
17 IDACORP riskier than the average electric utility holding
18 company. IDACORP' s $6 . 3 billion market capitalization is
19 much smaller than the $29 . 5 billion average market cap of
20 the electric utilities used by Dr . Thompson to estimate the
21 range of acceptable ROEs . There is well-documented evidence
22 that investors in smaller companies expect higher rates of
23 return than larger companies but also face higher risk.
24 Idaho Power does not have a corporate parent with a large
25 balance sheet and strong credit ratings to rely on during
BUCKHAM, DI 67
Idaho Power Company

1 times of financial stress given the fact that Idaho Power
2 is the primary subsidiary of IDACORP.
3 Also, the Company faces a concentrated regulatory
4 risk compared to many of its peers because 96 percent of
5 its retail revenues come from one jurisdiction. Both equity
6 analysts and the credit agencies consistently identify
7 regulatory risk as one of the chief risk factors for the
8 Company. This risk from lack of diversification, combined
9 with the relatively small size, gravitates toward a higher
10 required return from investors compared to many of Idaho
11 Power' s peers, in addition to investors' and rating
12 agencies' enhanced scrutiny on the regulatory compact and
13 methodology in Idaho Power' s primary jurisdiction of Idaho.
14 Growth and Regulatory Lag
15 Q. What will prevent the Company from earning its
16 authorized or allowed ROE, absent approval of this rate
17 request?
18 A. In light of the substantial infrastructure
19 development Idaho Power is undertaking, and will be
20 undertaking for the foreseeable future, in my opinion the
21 reliance on a historical test year is a primary reason the
22 Company will be unable to earn its authorized or allowed
23 ROE going forward. Idaho Power is in a position of applying
24 to recover its costs on a historical basis when its costs
25 are constantly increasing on a prospective basis, including
BUCKHAM, DI 68
Idaho Power Company

1 recovery of costs it incurs for plant that is already in
2 service, serving customers . As a result, there is and will
3 continue to be a consistent recovery lag.
4 Q. What effect does growth have on the use of
5 historical data?
6 A. Growth inherently worsens the effects .
7 Separate from rising operation & maintenance costs that
8 must accommodate that growth, the allowed rate of return is
9 applied to a rate base from a prior historical period, and
10 thus new plant additions that are in-service and serving
11 customers suffer some period of zero-percent return
12 awaiting eventual rate base treatment. Financing costs and
13 depreciation associated with the assets that receive this
14 zero-percent return are unsustainably high, and investors
15 and credit rating agencies notice that impact.
16 IV. CAPITAL STRUCTURE
17 Q. Would you please describe Exhibit No . 17?
18 A. Exhibit No. 17 details the 2025 test year
19 capital structure for long-term debt and common equity
20 prepared under my direction, the resulting recommended
21 overall rate of return, and the calculation of the
22 Company' s weighted average cost of long-term debt.
23 Q. What is the rationale for proposing a capital
24 structure of 51 percent equity and 49 percent debt?
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Idaho Power Company

1 A. This is the projected actual capital structure
2 as of the end of 2025 . Idaho Power believes a higher equity
3 proportion than the typical 50/50 split is needed to help
4 support the Company' s credit ratings, particularly with the
5 significant QF and PPA/BSA debt-like obligations I referred
6 to previously, which are not included in the debt component
7 of the ratio . IDACORP very recently entered into equity
8 sale transactions that will allow for over-equitization of
9 the balance sheet at year-end which, combined with revenues
10 from this case, will help with balance sheet health, though
11 it comes at a substantial cost.
12 Q. What is the Company' s proposed cost of debt?
13 A. As shown on page 2 of Exhibit No. 17, which
14 details the calculation of the cost of debt used in the
15 2025 test year capital structure, the Company' s proposed
16 cost of debt is 5 . 132 percent.
17 Q. What was the Company' s cost of debt in its GRC
18 filed in 2023?
19 A. In that case, the Company filed a cost of debt
20 of 4 . 895 percent .
21 Q. Has there been any significant refinancing
22 since the last GRC?
23 A. Yes . There has been some refinancing since
24 the last GRC (a $50 million 1 . 45 percent pollution control
25 bond matured in 2024) , but the greater impact has been
BUCKHAM, DI 70
Idaho Power Company

1 incremental debt issuances used to fund capital
2 expenditures and general corporate purposes . Idaho Power
3 issued $300 million of 10-year debt during 2024 at a coupon
4 rate of 5 .20 percent, and $400 million of 30-year debt in
5 March of 2025 at a 5 . 7 percent coupon rate.
6 Q. What method did the Company use for
7 calculating its cost of debt in this case?
8 A. Idaho Power applied a debt calculation method
9 to fully consider the effect of discounts, premiums, and
10 expense of issue on the annual cost of each bond, adopting
11 the bond yield to maturity method.
12 Q. Please explain the cost of debt calculation on
13 page 2 of Exhibit No. 17 .
14 A. The calculation takes the settlement date,
15 maturity date, coupon rate, and net proceeds at the
16 issuance date for each debt issue to produce a bond yield
17 to maturity. The bond yield was then multiplied by the
18 principal amount outstanding for each debt issue, resulting
19 in an annualized cost of each debt issuance in column 12 .
20 The total in column 12 for all the debt issuances produces
21 a total annual effective cost of debt in line 31 . This
22 total was divided by the total in column 6, line 31 to
23 produce the weighted average cost for all long-term debt in
24 column 11, line 31 . This method is appropriate because the
25 expense of issuance associated with a bond is essentially
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Idaho Power Company

1 prepaid interest, and the net proceeds, not the principal
2 amount of the bond, are all that is available to be
3 invested in property, plant, and equipment (rate base) .
4 Q. Does the Company use variable rate securities
5 in its long-term capitalization?
6 A. No. The Company retired its only variable rate
7 security, the Port of Morrow (Boardman) Pollution Control
8 Revenue Bonds, in 2022 upon the demolition of the Boardman
9 plant and its pollution control equipment, and previously
10 repaid in full its variable-rate term loan entered into in
11 March 2022 .
12 V. OVERALL COST OF CAPITAL
13 Q. What is the overall cost of capital for Idaho
14 Power?
15 A. As shown on page 1 of Exhibit No. 17, using
16 the Company' s projected year-end 2025 capital structure,
17 the Company' s cost of debt as presented in my testimony,
18 and incorporating the recommended 10 . 4 percent cost of
19 equity, the resulting overall cost of capital for Idaho
20 Power is 7 . 818 percent. This is an appropriate rate of
21 return to be utilized by the Commission when deriving the
22 Company' s revenue requirement .
23
24
25
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Idaho Power Company

1 VI . DEPRECIATION AND INTEREST EXPENSE TRACKER
2 Q. Are you familiar with the proposed tracking of
3 depreciation and interest expense discussed by Company
4 Witness Mr. Tatum?
5 A. Yes . In his testimony, Mr. Tatum discusses the
6 implementation of a mechanism that would track the
7 difference between actual depreciation and interest expense
8 and a sales-adjusted baseline level of depreciation and
9 interest expense on a January through December calendar
10 year basis .
11 Q. If approved, what would be the impact of this
12 mechanism on the financial health of Idaho Power?
13 A. While the proposed tracking mechanism lacks a
14 ` return on" or ROE component, or an 0&M recovery component,
15 the ability to recover depreciation and interest expense on
16 a timelier basis would serve as a benefit to the Company' s
17 operating cash flows . As noted previously in my testimony,
18 ratings agencies have cited Idaho Power' s cash flow metrics
19 as a central concern in their view of the Company' s current
20 financial position, including the lack of a regulatory
21 mechanism for those types of costs .
22 Q. Can you elaborate on how these agencies
23 incorporate cash flow metrics into their evaluations?
24 A. Yes . As I described earlier in my testimony,
25 credit rating agencies use various ratios to evaluate the
BUCKHAM, DI 73
Idaho Power Company

1 financial health of a utility. For Moody' s, a key ratio is
2 referred to as "Cash Flow from Operations ( `CFO' ) pre-WC to
3 Debt, " which measures the ratio of net cash flow from
4 operations net of changes in working capital to total debt.
5 S&P utilizes a similar metric referred to as "Funds from
6 Operations ("FFO") to Total Debt, " which measures the ratio
7 of funds from operations to a company' s total debt . Both
8 agencies use these metrics as key components of their
9 current ratings as well as their outlook designations, and
10 they have repeatedly and recently with increased emphasis
11 and alarm expressed concerns with Idaho Power' s cash-based
12 metrics relative to industry peers .
13 Q. How would the proposed tracking mechanism
14 impact cash flow metrics?
15 A. Because the measures of CFO and FFO are the
16 primary drivers of the Moody' s and S&P ratings,
17 respectively, implementation of the proposed tracking
18 mechanism would have a positive impact on these key metrics
19 by reducing regulatory lag associated with depreciation and
20 interest expense stemming from plant that is used and
21 useful and serving customers . Barring other changes, the
22 approval of this mechanism would at least help maintain
23 Idaho Power' s current financial standing in the eyes of the
24 ratings agencies, if not improve it. I could not attest
25 that it would result in the lifting of the current negative
BUCKHAM, DI 74
Idaho Power Company

1 outlook by Moody' s, but it may stabilize the ratings with
2 both credit rating agencies .
3 Q. As Chief Financial Officer and Treasurer, do
4 you believe that approval of the proposed mechanism is
5 important to the financial health of Idaho Power and its
6 ability to serve customers?
7 A. Yes, I do. As discussed earlier in my
8 testimony, a company' s credit rating is central to its cost
9 of accessing capital . Both Moody' s and S&P have cited
10 relatively weak cash flow metrics as key components of
11 their recent negative actions related to Idaho Power.
12 Further, these agencies also cite the lack of mechanisms to
13 address regulatory lag, which is inherent in a jurisdiction
14 in which forecast test year methodologies have not been
15 permitted. In order to address the concerns of ratings
16 agencies and maintain the financial health of Idaho Power,
17 I believe that approval of the proposed tracking mechanism
18 is in the best interest of the Company and its customers .
19 VII . CONCLUSION
20 Q. Please summarize your testimony.
21 A. Idaho Power faces a number of challenges to
22 maintaining, and at this point repairing, its financial
23 health while continuing to provide safe, reliable service
24 to customers during the current climate of unprecedented
25 growth. Market conditions currently reflect an environment
BUCKHAM, DI 75
Idaho Power Company

1 of sustained elevated interest rates and volatility and
2 heightened competition for capital, leading investors to
3 require increased returns in exchange for their investment.
4 In addition to systemic market issues, Idaho Power
5 possesses a number of characteristics that further elevate
6 its risk profile, including massive external capital needs,
7 liquidity issues with volatile net power supply costs,
8 wildfire risk, substantial debt-like obligations to
9 PPAs/BTAs and QFs, and pervasive declining financial
10 performance and metrics in the eyes of ratings agencies and
11 investors . In light of these challenges and the Company' s
12 financing needs for the foreseeable future, Idaho Power' s
13 proposed ROR of 7 . 818 percent, including the proposed 10 . 4
14 percent ROE, represents the lower bound of a range of
15 reasonable returns that will allow the Company to continue
16 to attract the capital it needs to construct, operate, and
17 maintain a safe, reliable electrical grid. This rate of
18 return, in conjunction with the depreciation and interest
19 expense tracking mechanism discussed by Mr. Tatum, will
20 serve to help repair the financial health of Idaho Power
21 while meeting the needs of its customers and the
22 affordability of financing costs for the Company' s
23 customers .
24 Q. Does this conclude your direct testimony in
25 this case?
BUCKHAM, DI 76
Idaho Power Company

1 A. Yes, it does .
2
BUCKHAM, DI 77
Idaho Power Company

1 DECLARATION OF BRIAN BUCKHAM
2 I, Brian Buckham, declare under penalty of perjury
3 under the laws of the state of Idaho:
4 1 . My name is Brian Buckham. I am employed by
5 Idaho Power Company as Senior Vice President and Chief
6 Financial Officer.
7 2 . On behalf of Idaho Power, I present this
8 pre-filed direct testimony and Exhibit Nos . 15 through 17
9 in this 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 30th day of May 2025, at Boise, Idaho.
17
18 Signed: "��
19 Brian R. Buckham
20
BUCKHAM, DI 78
Idaho Power Company

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-16
IDAHO POWER COMPANY
BUCKRAM, DI
TESTIMONY
EXHIBIT NO. 15

Statistics
Max Min Terminal
2021 1.90
2022 4.40 2.01
2023 5.11 3.54
2024 4.82 3.94
2025 4.98 4.41
Start of 2022 to Max 2025 2.621053
Graphic
6.00
5.00
4.00
3.00
2.00
1.00
0.00
O O O O O O O O O O O O O O O O O O O O O
ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti � ti ti ti ti ti
Data
Observation Date DGS30
2021-12-31 1.90
2022-01-03 2.01
2022-01-04 2.07
2022-01-05 2.09
2022-01-06 2.09
2022-01-07 2.11
2022-01-10 2.11
2022-01-11 2.08
2022-01-12 2.08
2022-01-13 2.05 Exhibit No. 15
2022-01-14 2.12 Case No. IPC-E-25-16
B. Buckham, IPC
1 of 20

2022-01-17
2022-01-18 2.18
2022-01-19 2.14
2022-01-20 2.14
2022-01-21 2.07
2022-01-24 2.10
2022-01-25 2.12
2022-01-26 2.16
2022-01-27 2.09
2022-01-28 2.07
2022-01-31 2.11
2022-02-01 2.12
2022-02-02 2.11
2022-02-03 2.14
2022-02-04 2.23
2022-02-07 2.22
2022-02-08 2.25
2022-02-09 2.25
2022-02-10 2.30
2022-02-11 2.24
2022-02-14 2.29
2022-02-15 2.37
2022-02-16 2.34
2022-02-17 2.31
2022-02-18 2.24
2022-02-21
2022-02-22 2.24
2022-02-23 2.29
2022-02-24 2.28
2022-02-25 2.29
2022-02-28 2.17
2022-03-01 2.11
2022-03-02 2.24
2022-03-03 2.24
2022-03-04 2.16
2022-03-07 2.19
2022-03-08 2.24
2022-03-09 2.29
2022-03-10 2.38
2022-03-11 2.36
2022-03-14 2.47
2022-03-15 2.49
2022-03-16 2.46
2022-03-17 2.50
2022-03-18 2.42
2022-03-21 2.55 Exhibit No. 15
2022-03-22 2.60 Case No. IPC-E-25-16
B. Buckham, IPC
2 of 20

2022-03-23 2.52
2022-03-24 2.51
2022-03-25 2.60
2022-03-28 2.57
2022-03-29 2.53
2022-03-30 2.48
2022-03-31 2.44
2022-04-01 2.44
2022-04-04 2.48
2022-04-05 2.57
2022-04-06 2.63
2022-04-07 2.69
2022-04-08 2.76
2022-04-11 2.84
2022-04-12 2.82
2022-04-13 2.81
2022-04-14 2.92
2022-04-15
2022-04-18 2.95
2022-04-19 3.01
2022-04-20 2.90
2022-04-21 2.94
2022-04-22 2.95
2022-04-25 2.88
2022-04-26 2.86
2022-04-27 2.91
2022-04-28 2.92
2022-04-29 2.96
2022-05-02 3.07
2022-05-03 3.03
2022-05-04 3.01
2022-05-05 3.15
2022-05-06 3.23
2022-05-09 3.19
2022-05-10 3.12
2022-05-11 3.05
2022-05-12 3.00
2022-05-13 3.10
2022-05-16 3.09
2022-05-17 3.17
2022-05-18 3.07
2022-05-19 3.05
2022-05-20 2.99
2022-05-23 3.08
2022-05-24 2.98
2022-05-25 2.97 Exhibit No. 15
2022-05-26 2.99 Case No. IPC-E-25-16
B. Buckham, IPC
3 of 20

2022-05-27 2.97
2022-05-30
2022-05-31 3.07
2022-06-01 3.09
2022-06-02 3.09
2022-06-03 3.11
2022-06-06 3.19
2022-06-07 3.13
2022-06-08 3.18
2022-06-09 3.18
2022-06-10 3.20
2022-06-13 3.42
2022-06-14 3.45
2022-06-15 3.39
2022-06-16 3.35
2022-06-17 3.30
2022-06-20
2022-06-21 3.39
2022-06-22 3.25
2022-06-23 3.21
2022-06-24 3.26
2022-06-27 3.31
2022-06-28 3.30
2022-06-29 3.22
2022-06-30 3.14
2022-07-01 3.11
2022-07-04
2022-07-05 3.05
2022-07-06 3.14
2022-07-07 3.20
2022-07-08 3.27
2022-07-11 3.18
2022-07-12 3.13
2022-07-13 3.08
2022-07-14 3.11
2022-07-15 3.10
2022-07-18 3.14
2022-07-19 3.17
2022-07-20 3.17
2022-07-21 3.08
2022-07-22 3.00
2022-07-25 3.04
2022-07-26 3.03
2022-07-27 3.03
2022-07-28 3.02
2022-07-29 3.00 Exhibit No. 15
2022-08-01 2.92 Case No. IPC-E-25-16
B. Buckham, IPC
4 of 20

2022-08-02 3.00
2022-08-03 2.96
2022-08-04 2.97
2022-08-05 3.06
2022-08-08 3.00
2022-08-09 3.01
2022-08-10 3.04
2022-08-11 3.15
2022-08-12 3.12
2022-08-15 3.10
2022-08-16 3.11
2022-08-17 3.15
2022-08-18 3.14
2022-08-19 3.22
2022-08-22 3.24
2022-08-23 3.26
2022-08-24 3.32
2022-08-25 3.25
2022-08-26 3.21
2022-08-29 3.25
2022-08-30 3.23
2022-08-31 3.27
2022-09-01 3.37
2022-09-02 3.35
2022-09-05
2022-09-06 3.49
2022-09-07 3.42
2022-09-08 3.45
2022-09-09 3.47
2022-09-12 3.53
2022-09-13 3.51
2022-09-14 3.47
2022-09-15 3.48
2022-09-16 3.52
2022-09-19 3.52
2022-09-20 3.59
2022-09-21 3.50
2022-09-22 3.65
2022-09-23 3.61
2022-09-26 3.72
2022-09-27 3.87
2022-09-28 3.70
2022-09-29 3.71
2022-09-30 3.79
2022-10-03 3.73
2022-10-04 3.70 Exhibit No. 15
2022-10-05 3.78 Case No. IPC-E-25-16
B. Buckham, IPC
5 of 20

2022-10-06 3.81
2022-10-07 3.86
2022-10-10
2022-10-11 3.92
2022-10-12 3.90
2022-10-13 3.97
2022-10-14 3.99
2022-10-17 4.04
2022-10-18 4.04
2022-10-19 4.15
2022-10-20 4.24
2022-10-21 4.33
2022-10-24 4.40
2022-10-25 4.26
2022-10-26 4.19
2022-10-27 4.12
2022-10-28 4.15
2022-10-31 4.22
2022-11-01 4.14
2022-11-02 4.15
2022-11-03 4.18
2022-11-04 4.27
2022-11-07 4.34
2022-11-08 4.28
2022-11-09 4.31
2022-11-10 4.03
2022-11-11
2022-11-14 4.07
2022-11-15 3.98
2022-11-16 3.85
2022-11-17 3.89
2022-11-18 3.92
2022-11-21 3.91
2022-11-22 3.83
2022-11-23 3.74
2022-11-24
2022-11-25 3.74
2022-11-28 3.74
2022-11-29 3.81
2022-11-30 3.80
2022-12-01 3.64
2022-12-02 3.56
2022-12-05 3.62
2022-12-06 3.52
2022-12-07 3.42
2022-12-08 3.44 Exhibit No. 15
2022-12-09 3.56 Case No. IPC-E-25-16
B. Buckham, IPC
6 of 20

2022-12-12 3.57
2022-12-13 3.53
2022-12-14 3.52
2022-12-15 3.48
2022-12-16 3.53
2022-12-19 3.62
2022-12-20 3.74
2022-12-21 3.74
2022-12-22 3.73
2022-12-23 3.82
2022-12-26
2022-12-27 3.93
2022-12-28 3.98
2022-12-29 3.92
2022-12-30 3.97
2023-01-02
2023-01-03 3.88
2023-01-04 3.81
2023-01-05 3.78
2023-01-06 3.67
2023-01-09 3.66
2023-01-10 3.74
2023-01-11 3.67
2023-01-12 3.56
2023-01-13 3.61
2023-01-16
2023-01-17 3.64
2023-01-18 3.54
2023-01-19 3.57
2023-01-20 3.66
2023-01-23 3.69
2023-01-24 3.62
2023-01-25 3.62
2023-01-26 3.62
2023-01-27 3.64
2023-01-30 3.66
2023-01-31 3.65
2023-02-01 3.55
2023-02-02 3.55
2023-02-03 3.63
2023-02-06 3.67
2023-02-07 3.72
2023-02-08 3.70
2023-02-09 3.75
2023-02-10 3.83
2023-02-13 3.79 Exhibit No. 15
2023-02-14 3.81 Case No. IPC-E-25-16
B. Buckham, IPC
7 of 20

2023-02-15 3.85
2023-02-16 3.92
2023-02-17 3.88
2023-02-20
2023-02-21 3.98
2023-02-22 3.94
2023-02-23 3.88
2023-02-24 3.93
2023-02-27 3.93
2023-02-28 3.93
2023-03-01 3.97
2023-03-02 4.03
2023-03-03 3.90
2023-03-06 3.92
2023-03-07 3.88
2023-03-08 3.88
2023-03-09 3.88
2023-03-10 3.70
2023-03-13 3.70
2023-03-14 3.77
2023-03-15 3.70
2023-03-16 3.71
2023-03-17 3.60
2023-03-20 3.65
2023-03-21 3.73
2023-03-22 3.68
2023-03-23 3.66
2023-03-24 3.64
2023-03-27 3.77
2023-03-28 3.77
2023-03-29 3.78
2023-03-30 3.74
2023-03-31 3.67
2023-04-03 3.64
2023-04-04 3.60
2023-04-05 3.56
2023-04-06 3.54
2023-04-07 3.61
2023-04-10 3.62
2023-04-11 3.62
2023-04-12 3.64
2023-04-13 3.69
2023-04-14 3.74
2023-04-17 3.81
2023-04-18 3.79
2023-04-19 3.79 Exhibit No. 15
2023-04-20 3.75 Case No. IPC-E-25-16
B. Buckham, IPC
8 of 20

2023-04-21 3.78
2023-04-24 3.73
2023-04-25 3.65
2023-04-26 3.70
2023-04-27 3.76
2023-04-28 3.67
2023-05-01 3.84
2023-05-02 3.72
2023-05-03 3.70
2023-05-04 3.73
2023-05-05 3.76
2023-05-08 3.84
2023-05-09 3.85
2023-05-10 3.80
2023-05-11 3.73
2023-05-12 3.78
2023-05-15 3.84
2023-05-16 3.87
2023-05-17 3.88
2023-05-18 3.91
2023-05-19 3.95
2023-05-22 3.97
2023-05-23 3.96
2023-05-24 3.97
2023-05-25 4.01
2023-05-26 3.96
2023-05-29
2023-05-30 3.90
2023-05-31 3.85
2023-06-01 3.84
2023-06-02 3.88
2023-06-05 3.89
2023-06-06 3.87
2023-06-07 3.95
2023-06-08 3.89
2023-06-09 3.89
2023-06-12 3.87
2023-06-13 3.94
2023-06-14 3.90
2023-06-15 3.85
2023-06-16 3.86
2023-06-19
2023-06-20 3.83
2023-06-21 3.81
2023-06-22 3.88
2023-06-23 3.82 Exhibit No. 15
2023-06-26 3.83 Case No. IPC-E-25-16
B. Buckham, IPC
9 of 20

2023-06-27 3.84
2023-06-28 3.81
2023-06-29 3.92
2023-06-30 3.85
2023-07-03 3.87
2023-07-04
2023-07-05 3.95 1.9 Start of 2022
2023-07-06 4.01
2023-07-07 4.05
2023-07-10 4.05
2023-07-11 4.03
2023-07-12 3.96
2023-07-13 3.90
2023-07-14 3.93
2023-07-17 3.94
2023-07-18 3.91
2023-07-19 3.84
2023-07-20 3.91
2023-07-21 3.91
2023-07-24 3.92
2023-07-25 3.95
2023-07-26 3.94
2023-07-27 4.06
2023-07-28 4.03
2023-07-31 4.02
2023-08-01 4.11
2023-08-02 4.17
2023-08-03 4.32
2023-08-04 4.21
2023-08-07 4.27
2023-08-08 4.20
2023-08-09 4.18
2023-08-10 4.24
2023-08-11 4.27
2023-08-14 4.29
2023-08-15 4.32
2023-08-16 4.38
2023-08-17 4.41
2023-08-18 4.38
2023-08-21 4.45
2023-08-22 4.42
2023-08-23 4.27
2023-08-24 4.30
2023-08-25 4.30
2023-08-28 4.29
2023-08-29 4.23 Exhibit No. 15
2023-08-30 4.23 Case No. IPC-E-25-16
B. Buckham, IPC
10 of 20

2023-08-31 4.20
2023-09-01 4.29
2023-09-04
2023-09-05 4.38
2023-09-06 4.37
2023-09-07 4.36
2023-09-08 4.33
2023-09-11 4.37
2023-09-12 4.35
2023-09-13 4.34
2023-09-14 4.39
2023-09-15 4.42
2023-09-18 4.40
2023-09-19 4.43
2023-09-20 4.40
2023-09-21 4.56
2023-09-22 4.53
2023-09-25 4.67
2023-09-26 4.70
2023-09-27 4.73
2023-09-28 4.71
2023-09-29 4.73
2023-10-02 4.81
2023-10-03 4.95
2023-10-04 4.87
2023-10-05 4.89
2023-10-06 4.95
2023-10-09
2023-10-10 4.85
2023-10-11 4.73
2023-10-12 4.86
2023-10-13 4.78
2023-10-16 4.87
2023-10-17 4.94
2023-10-18 5.00
2023-10-19 5.11
2023-10-20 5.09
2023-10-23 5.01
2023-10-24 4.96
2023-10-25 5.09
2023-10-26 5.01
2023-10-27 5.03
2023-10-30 5.04
2023-10-31 5.04
2023-11-01 4.96
2023-11-02 4.82 Exhibit No. 15
2023-11-03 4.77 Case No. IPC-E-25-16
B. Buckham, IPC
11 of 20

2023-11-06 4.84
2023-11-07 4.75
2023-11-08 4.64
2023-11-09 4.77
2023-11-10 4.73
2023-11-13 4.75
2023-11-14 4.61
2023-11-15 4.68
2023-11-16 4.63
2023-11-17 4.59
2023-11-20 4.57
2023-11-21 4.57
2023-11-22 4.55
2023-11-23
2023-11-24 4.60
2023-11-27 4.53
2023-11-28 4.52
2023-11-29 4.44
2023-11-30 4.54
2023-12-01 4.40
2023-12-04 4.43
2023-12-05 4.30
2023-12-06 4.22
2023-12-07 4.25
2023-12-08 4.31
2023-12-11 4.32
2023-12-12 4.30
2023-12-13 4.19
2023-12-14 4.03
2023-12-15 4.00
2023-12-18 4.05
2023-12-19 4.03
2023-12-20 3.98
2023-12-21 4.03
2023-12-22 4.05
2023-12-25
2023-12-26 4.04
2023-12-27 3.95
2023-12-28 3.98
2023-12-29 4.03
2024-01-01
2024-01-02 4.08
2024-01-03 4.05
2024-01-04 4.13
2024-01-05 4.21
2024-01-08 4.17 Exhibit No. 15
2024-01-09 4.18 Case No. IPC-E-25-16
B. Buckham, IPC
12 of 20

2024-01-10 4.20
2024-01-11 4.18
2024-01-12 4.20
2024-01-15
2024-01-16 4.30
2024-01-17 4.31
2024-01-18 4.37
2024-01-19 4.36
2024-01-22 4.32
2024-01-23 4.38
2024-01-24 4.41
2024-01-25 4.38
2024-01-26 4.38
2024-01-29 4.31
2024-01-30 4.28
2024-01-31 4.22
2024-02-01 4.10
2024-02-02 4.22
2024-02-05 4.35
2024-02-06 4.29
2024-02-07 4.31
2024-02-08 4.36
2024-02-09 4.37
2024-02-12 4.37
2024-02-13 4.46
2024-02-14 4.45
2024-02-15 4.42
2024-02-16 4.45
2024-02-19
2024-02-20 4.44
2024-02-21 4.49
2024-02-22 4.47
2024-02-23 4.37
2024-02-26 4.40
2024-02-27 4.44
2024-02-28 4.40
2024-02-29 4.38
2024-03-01 4.33
2024-03-04 4.36
2024-03-05 4.27
2024-03-06 4.24
2024-03-07 4.25
2024-03-08 4.26
2024-03-11 4.26
2024-03-12 4.31
2024-03-13 4.35 Exhibit No. 15
2024-03-14 4.44 Case No. IPC-E-25-16
B. Buckham, IPC
13 of 20

2024-03-15 4.43
2024-03-18 4.46
2024-03-19 4.44
2024-03-20 4.45
2024-03-21 4.44
2024-03-22 4.39
2024-03-25 4.42
2024-03-26 4.40
2024-03-27 4.36
2024-03-28 4.34
2024-03-29
2024-04-01 4.47
2024-04-02 4.51
2024-04-03 4.51
2024-04-04 4.47
2024-04-05 4.54
2024-04-08 4.55
2024-04-09 4.50
2024-04-10 4.64
2024-04-11 4.65
2024-04-12 4.61
2024-04-15 4.74
2024-04-16 4.77
2024-04-17 4.71
2024-04-18 4.74
2024-04-19 4.72
2024-04-22 4.72
2024-04-23 4.73
2024-04-24 4.78
2024-04-25 4.82
2024-04-26 4.78
2024-04-29 4.75
2024-04-30 4.79
2024-05-01 4.74
2024-05-02 4.72
2024-05-03 4.66
2024-05-06 4.64
2024-05-07 4.61
2024-05-08 4.64
2024-05-09 4.60
2024-05-10 4.64
2024-05-13 4.63
2024-05-14 4.59
2024-05-15 4.52
2024-05-16 4.52
2024-05-17 4.56 Exhibit No. 15
2024-05-20 4.58 Case No. IPC-E-25-16
B. Buckham, IPC
14 of 20

2024-05-21 4.55
2024-05-22 4.55
2024-05-23 4.58
2024-05-24 4.57
2024-05-27
2024-05-28 4.66
2024-05-29 4.74
2024-05-30 4.69
2024-05-31 4.65
2024-06-03 4.55
2024-06-04 4.48
2024-06-05 4.44
2024-06-06 4.43
2024-06-07 4.55
2024-06-10 4.59
2024-06-11 4.53
2024-06-12 4.47
2024-06-13 4.40
2024-06-14 4.34
2024-06-17 4.40
2024-06-18 4.36
2024-06-19
2024-06-20 4.39
2024-06-21 4.39
2024-06-24 4.38
2024-06-25 4.36
2024-06-26 4.45
2024-06-27 4.43
2024-06-28 4.51
2024-07-01 4.64
2024-07-02 4.60
2024-07-03 4.53
2024-07-04
2024-07-05 4.47
2024-07-08 4.46
2024-07-09 4.49
2024-07-10 4.47
2024-07-11 4.41
2024-07-12 4.39
2024-07-15 4.46
2024-07-16 4.38
2024-07-17 4.37
2024-07-18 4.41
2024-07-19 4.45
2024-07-22 4.48
2024-07-23 4.48 Exhibit No. 15
2024-07-24 4.54 Case No. IPC-E-25-16
B. Buckham, IPC
15 of 20

2024-07-25 4.50
2024-07-26 4.45
2024-07-29 4.42
2024-07-30 4.40
2024-07-31 4.35
2024-08-01 4.27
2024-08-02 4.11
2024-08-05 4.06
2024-08-06 4.18
2024-08-07 4.26
2024-08-08 4.28
2024-08-09 4.23
2024-08-12 4.19
2024-08-13 4.16
2024-08-14 4.12
2024-08-15 4.18
2024-08-16 4.15
2024-08-19 4.11
2024-08-20 4.07
2024-08-21 4.06
2024-08-22 4.13
2024-08-23 4.10
2024-08-26 4.11
2024-08-27 4.13
2024-08-28 4.13
2024-08-29 4.15
2024-08-30 4.20
2024-09-02
2024-09-03 4.13
2024-09-04 4.06
2024-09-05 4.02
2024-09-06 4.03
2024-09-09 4.00
2024-09-10 3.97
2024-09-11 3.96
2024-09-12 4.00
2024-09-13 3.98
2024-09-16 3.94
2024-09-17 3.96
2024-09-18 4.03
2024-09-19 4.06
2024-09-20 4.07
2024-09-23 4.09
2024-09-24 4.09
2024-09-25 4.14
2024-09-26 4.12 Exhibit No. 15
2024-09-27 4.10 Case No. IPC-E-25-16
B. Buckham, IPC
16 of 20

2024-09-30 4.14
2024-10-01 4.08
2024-10-02 4.14
2024-10-03 4.18
2024-10-04 4.26
2024-10-07 4.30
2024-10-08 4.32
2024-10-09 4.34
2024-10-10 4.38
2024-10-11 4.39
2024-10-14
2024-10-15 4.32
2024-10-16 4.30
2024-10-17 4.39
2024-10-18 4.38
2024-10-21 4.49
2024-10-22 4.49
2024-10-23 4.51
2024-10-24 4.47
2024-10-25 4.51
2024-10-28 4.53
2024-10-29 4.52
2024-10-30 4.49
2024-10-31 4.47
2024-11-01 4.57
2024-11-04 4.50
2024-11-05 4.44
2024-11-06 4.60
2024-11-07 4.52
2024-11-08 4.47
2024-11-11
2024-11-12 4.58
2024-11-13 4.63
2024-11-14 4.58
2024-11-15 4.60
2024-11-18 4.61
2024-11-19 4.57
2024-11-20 4.59
2024-11-21 4.61
2024-11-22 4.60
2024-11-25 4.45
2024-11-26 4.48
2024-11-27 4.44
2024-11-28
2024-11-29 4.36
2024-12-02 4.36 Exhibit No. 15
2024-12-03 4.40 Case No. IPC-E-25-16
B. Buckham, IPC
17 of 20

2024-12-04 4.35
2024-12-05 4.33
2024-12-06 4.34
2024-12-09 4.39
2024-12-10 4.41
2024-12-11 4.48
2024-12-12 4.55
2024-12-13 4.61
2024-12-16 4.60
2024-12-17 4.59
2024-12-18 4.65
2024-12-19 4.74
2024-12-20 4.72
2024-12-23 4.78
2024-12-24 4.76
2024-12-25
2024-12-26 4.76
2024-12-27 4.82
2024-12-30 4.77
2024-12-31 4.78
2025-01-01
2025-01-02 4.79
2025-01-03 4.82
2025-01-06 4.85
2025-01-07 4.91
2025-01-08 4.91
2025-01-09 4.92
2025-01-10 4.96
2025-01-13 4.97
2025-01-14 4.98
2025-01-15 4.88
2025-01-16 4.84
2025-01-17 4.84
2025-01-20
2025-01-21 4.80
2025-01-22 4.82
2025-01-23 4.87
2025-01-24 4.85
2025-01-27 4.76
2025-01-28 4.78
2025-01-29 4.79
2025-01-30 4.76
2025-01-31 4.83
2025-02-03 4.77
2025-02-04 4.75
2025-02-05 4.64 Exhibit No. 15
2025-02-06 4.65 Case No. IPC-E-25-16
B. Buckham, IPC
18 of 20

2025-02-07 4.69
2025-02-10 4.71
2025-02-11 4.75
2025-02-12 4.83
2025-02-13 4.72
2025-02-14 4.69
2025-02-17
2025-02-18 4.77
2025-02-19 4.76
2025-02-20 4.74
2025-02-21 4.67
2025-02-24 4.66
2025-02-25 4.55
2025-02-26 4.51
2025-02-27 4.56
2025-02-28 4.51
2025-03-03 4.45
2025-03-04 4.53
2025-03-05 4.57
2025-03-06 4.58
2025-03-07 4.62
2025-03-10 4.54
2025-03-11 4.59
2025-03-12 4.63
2025-03-13 4.59
2025-03-14 4.62
2025-03-17 4.60
2025-03-18 4.58
2025-03-19 4.56
2025-03-20 4.55
2025-03-21 4.59
2025-03-24 4.66
2025-03-25 4.65
2025-03-26 4.69
2025-03-27 4.73
2025-03-28 4.64
2025-03-31 4.59
2025-04-01 4.52
2025-04-02 4.54
2025-04-03 4.49
2025-04-04 4.41
2025-04-07 4.58
2025-04-08 4.71
2025-04-09 4.72
2025-04-10 4.86
2025-04-11 4.85 Exhibit No. 15
2025-04-14 4.80 Case No. IPC-E-25-16
B. Buckham, IPC
19 of 20

2025-04-15 4.79
2025-04-16 4.74
2025-04-17 4.80
2025-04-18
2025-04-21 4.91
2025-04-22 4.88
2025-04-23 4.83
2025-04-24 4.77
2025-04-25 4.74
2025-04-28 4.69
2025-04-29 4.64
2025-04-30 4.66
2025-05-01 4.74
2025-05-02 4.79
2025-05-05 4.83
2025-05-06 4.81
2025-05-07 4.77
2025-05-08 4.83
2025-05-09 4.83
2025-05-12 4.89
2025-05-13 4.94
2025-05-14 4.97
2025-05-15 4.91
2025-05-16 4.89
Exhibit No. 15
Case No. IPC-E-25-16
B. Buckham, IPC
20 of 20

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-16
IDAHO POWER COMPANY
BUCKRAM, DI
TESTIMONY
EXHIBIT NO. 16

Statistics
Maximum Avg
of 30 day MA of 30 day MA
2023 21.81 17.38
2025 29.29 20.66
Difference 34.3% 18.9%
2023 Avg to 25 Max 68.6%
Graphic
30 Day Avg
35.00
30.00
25.00
20.00
15.00
10.00
5.00
0.00
N N N N N N N N N N N N N N N N N N N N N N N N N N N N N
O O O O O O O O O O O O O O O O O O O O O O O O O O O O O
c-I N M V In (O r� w M O .-i N .--i N M V Ln 0 n W M O e-I N ti N M V In
O O O O O O O O O O O O O O O O O O 1 1 -- O O O O O
M N N M V V V V V V N V N N V V u] N N CN N
N N N N N N N N N N N N N N N N N N N N N N N N N N N N N
O O O O O O O O O O O O O O O O O O O O O O O O O O O O O
N N N N N N N N N N N N N N N N N N N N N N N N N N N N N
Data
Observation Date I VIXCLS 17 period Avg 130 Period Avg
2020-05-18 29.30
2020-05-19 30.53
2020-05-20 27.99
2020-05-21 29.53
2020-05-22 28.16
2020-05-25
2020-05-26 28.01 28.92
2020-05-27 27.62 28.64
2020-05-28 28.59 28.32
2020-05-29 27.51 28.24
2020-06-01 28.23 28.02
2020-06-02 26.84 27.80
2020-06-03 25.66 27.49
2020-06-04 25.81 27.18
2020-06-05 24.52 26.74
2020-06-08 25.81 26.34
2020-06-09 27.57 26.35
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
1 of 25

2020-06-10 27.57 26.25
2020-06-11 40.79 28.25
2020-06-12 36.09 29.74
2020-06-15 34.40 30.96
2020-06-16 33.67 32.27
2020-06-17 33.47 33.37
2020-06-18 32.94 34.13
2020-06-19 35.12 35.21
2020-06-22 31.77 33.92
2020-06-23 31.37 33.25
2020-06-24 33.84 33.17
2020-06-25 32.22 32.96
2020-06-26 34.73 33.14
2020-06-29 31.78 32.98 30.38
2020-06-30 30.43 32.31 30.42
2020-07-01 28.62 31.86 30.36
2020-07-02 27.68 31.33 30.35
2020-07-03 30.91 30.37
2020-07-06 27.94 30.20 30.37
2020-07-07 29.43 29.31 30.33
2020-07-08 28.08 28.70 30.34
2020-07-09 29.26 28.50 30.39
2020-07-10 27.29 28.28 30.35
2020-07-13 32.19 29.03 30.50
2020-07-14 29.52 29.10 30.55
2020-07-15 27.76 29.08 30.58
2020-07-16 28.00 28.87 30.66
2020-07-17 25.68 28.53 30.65
2020-07-20 24.46 27.84 30.65
2020-07-21 24.84 27.49 30.62
2020-07-22 24.32 26.37 30.51
2020-07-23 26.08 25.88 30.46
2020-07-24 25.84 25.60 29.96
2020-07-27 24.74 25.14 29.58
2020-07-28 25.44 25.10 29.28
2020-07-29 24.10 25.05 28.96
2020-07-30 24.76 25.04 28.67
2020-07-31 24.46 25.06 28.39
2020-08-03 24.28 24.80 28.03
2020-08-04 23.76 24.51 27.76
2020-08-05 22.99 24.26 27.48
2020-08-06 22.65 23.86 27.11
2020-08-07 22.21 23.59 26.78
2020-08-10 22.13 23.21 26.36
2020-08-11 24.03 23.15 26.10
2020-08-12 22.28 22.86 25.83
2020-08-13 22.13 22.63 25.61
2020-08-14 22.05 22.50 25.42
2020-08-17 21.35 22.31 25.29
2020-08-18 21.51 22.21 25.08
2020-08-19 22.54 22.27 24.86
2020-08-20 22.72 22.08 24.69
2020-08-21 22.54 22.12 24.47
2020-08-24 22.37 22.15 24.31
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
2 of 25

2020-08-25 22.03 22.15 23.99
2020-08-26 23.27 22.43 23.78
2020-08-27 24.47 22.85 23.68
2020-08-28 22.96 22.91 23.52
2020-08-31 26.41 23.44 23.54
2020-09-01 26.12 23.95 23.59
2020-09-02 26.57 24.55 23.65
2020-09-03 33.60 26.20 23.95
2020-09-04 30.75 27.27 24.10
2020-09-07 27.74 24.04
2020-09-08 31.46 29.15 24.26
2020-09-09 28.81 29.55 24.38
2020-09-10 29.71 30.15 24.56
2020-09-11 26.87 30.20 24.63
2020-09-14 25.85 28.91 24.68
2020-09-15 25.59 28.05 24.72
2020-09-16 26.04 27.76 24.80
2020-09-17 26.46 27.05 24.92
2020-09-18 25.83 26.62 25.02
2020-09-21 27.78 26.35 25.21
2020-09-22 26.86 26.34 25.37
2020-09-23 28.58 26.73 25.52
2020-09-24 28.51 27.15 25.72
2020-09-25 26.38 27.20 25.87
2020-09-28 26.19 27.16 26.00
2020-09-29 26.27 27.22 26.17
2020-09-30 26.37 27.02 26.33
2020-10-01 26.70 27.00 26.47
2020-10-02 27.63 26.86 26.63
2020-10-05 27.96 26.79 26.81
2020-10-06 29.48 27.23 27.05
2020-10-07 28.06 27.50 27.25
2020-10-08 26.36 27.51 27.35
2020-10-09 25.00 27.31 27.37
2020-10-12 25.07 27.08 27.44
2020-10-13 26.07 26.86 27.43
2020-10-14 26.40 26.63 27.44
2020-10-15 26.97 26.28 27.45
2020-10-16 27.41 26.18 27.25
2020-10-19 29.18 26.59 27.20
2020-10-20 29.35 27.21 27.26
2020-10-21 28.65 27.72 27.17
2020-10-22 28.11 28.01 27.15
2020-10-23 27.55 28.17 27.08
2020-10-26 32.46 28.96 27.26
2020-10-27 33.35 29.81 27.50
2020-10-28 40.28 31.39 27.98
2020-10-29 37.59 32.57 28.35
2020-10-30 38.02 33.91 28.72
2020-11-02 37.13 35.20 29.09
2020-11-03 35.55 36.34 29.34
2020-11-04 29.57 35.93 29.43
2020-11-05 27.58 35.10 29.39
2020-11-06 24.86 32.90 29.28
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
3 of 25

2020-11-09 25.75 31.21 29.26
2020-11-10 24.80 29.32 29.21
2020-11-11 23.45 27.37 29.12
2020-11-12 25.35 25.91 29.09
2020-11-13 23.10 24.98 28.97
2020-11-16 22.45 24.25 28.80
2020-11-17 22.71 23.94 28.63
2020-11-18 23.84 23.67 28.45
2020-11-19 23.11 23.43 28.29
2020-11-20 23.70 23.47 28.21
2020-11-23 22.66 23.08 28.13
2020-11-24 21.64 22.87 28.02
2020-11-25 21.25 22.70 27.87
2020-11-26 22.70 27.91
2020-11-27 20.84 22.20 27.71
2020-11-30 20.57 21.78 27.48
2020-12-01 20.77 21.29 27.20
2020-12-02 21.17 21.04 26.93
2020-12-03 21.28 20.98 26.68
2020-12-04 20.79 20.90 26.44
2020-12-07 21.30 20.96 26.23
2020-12-08 20.68 20.94 25.84
2020-12-09 22.27 21.18 25.47
2020-12-10 22.52 21.43 24.88
2020-12-11 23.31 21.74 24.40
2020-12-14 24.72 22.23 23.96
2020-12-15 22.89 22.53 23.48
2020-12-16 22.50 22.70 23.05
2020-12-17 21.93 22.88 22.79
2020-12-18 21.57 22.78 22.59
2020-12-21 25.16 23.15 22.60
2020-12-22 24.23 23.29 22.55
2020-12-23 23.31 23.08 22.50
2020-12-24 21.53 22.89 22.44
2020-12-25 22.96 22.34
2020-12-28 21.70 22.92 22.29
2020-12-29 23.08 23.17 22.31
2020-12-30 22.77 22.77 22.31
2020-12-31 22.75 22.52 22.28
2021-01-01 22.37 22.25
2021-01-04 26.97 23.45 22.36
2021-01-05 25.34 23.77 22.46
2021-01-06 25.07 24.33 22.58
2021-01-07 22.37 24.21 22.62
2021-01-08 21.56 24.01 22.58
2021-01-11 24.08 24.23 22.70
2021-01-12 23.33 24.10 22.79
2021-01-13 22.21 23.42 22.84
2021-01-14 23.25 23.12 22.91
2021-01-15 24.34 23.02 23.02
2021-01-18 23.13 23.10
2021-01-19 23.24 23.41 23.17
2021-01-20 21.58 22.99 23.20
2021-01-21 21.32 22.66 23.17
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
4 of 25

2021-01-22 21.91 22.61 23.14
2021-01-25 23.19 22.60 23.14
2021-01-26 23.02 22.38 23.08
2021-01-27 37.21 24.50 23.59
2021-01-28 30.21 25.49 23.87
2021-01-29 33.09 27.14 24.26
2021-02-01 30.24 28.41 24.57
2021-02-02 25.56 28.93 24.59
2021-02-03 22.91 28.89 24.54
2021-02-04 21.77 28.71 24.49
2021-02-05 20.87 26.38 24.46
2021-02-08 21.24 25.10 24.35
2021-02-09 21.63 23.46 24.35
2021-02-10 21.99 22.28 24.31
2021-02-11 21.25 21.67 24.26
2021-02-12 19.97 21.25 24.16
2021-02-15 21.16 24.16
2021-02-16 21.46 21.26 23.97
2021-02-17 21.50 21.30 23.84
2021-02-18 22.49 21.44 23.75
2021-02-19 22.05 21.45 23.74
2021-02-22 23.45 21.82 23.81
2021-02-23 23.11 22.34 23.77
2021-02-24 21.34 22.20 23.70
2021-02-25 28.89 23.26 23.93
2021-02-26 27.95 24.18 24.10
2021-03-01 23.35 24.31 24.06
2021-03-02 24.10 24.60 24.06
2021-03-03 26.67 25.06 24.18
2021-03-04 28.57 25.84 24.41
2021-03-05 24.66 26.31 24.52
2021-03-08 25.47 25.82 24.64
2021-03-09 24.03 25.26 24.67
2021-03-10 22.56 25.15 24.65
2021-03-11 21.91 24.84 24.14
2021-03-12 20.69 23.98 23.83
2021-03-15 20.03 22.76 23.39
2021-03-16 19.79 22.07 23.04
2021-03-17 19.23 21.18 22.83
2021-03-18 21.58 20.83 22.79
2021-03-19 20.95 20.60 22.76
2021-03-22 18.88 20.16 22.69
2021-03-23 20.30 20.11 22.66
2021-03-24 21.20 20.28 22.65
2021-03-25 19.81 20.28 22.57
2021-03-26 18.86 20.23 22.50
2021-03-29 20.74 20.11 22.52
2021-03-30 19.61 19.91 22.43
2021-03-31 19.40 19.99 22.36
2021-04-01 17.33 19.56 22.23
2021-04-02 19.29 22.22
2021-04-05 17.91 18.98 22.08
2021-04-06 18.12 18.85 21.90
2021-04-07 17.16 18.26 21.70
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
5 of 25

2021-04-08 16.95 17.81 21.56
2021-04-09 16.69 17.36 21.15
2021-04-12 16.91 17.29 20.78
2021-04-13 16.65 17.20 20.56
2021-04-14 16.99 17.07 20.32
2021-04-15 16.57 16.85 19.99
2021-04-16 16.25 16.72 19.57
2021-04-19 17.29 16.76 19.33
2021-04-20 18.68 17.05 19.10
2021-04-21 17.50 17.13 18.88
2021-04-22 18.71 17.43 18.76
2021-04-23 17.33 17.48 18.60
2021-04-26 17.64 17.63 18.50
2021-04-27 17.56 17.82 18.42
2021-04-28 17.28 17.81 18.34
2021-04-29 17.61 17.66 18.28
2021-04-30 18.61 17.82 18.18
2021-05-03 18.31 17.76 18.10
2021-05-04 19.48 18.07 18.12
2021-05-05 19.15 18.29 18.08
2021-05-06 18.39 18.40 17.98
2021-05-07 16.69 18.32 17.88
2021-05-10 19.66 18.61 17.91
2021-05-11 21.84 19.07 17.94
2021-05-12 27.59 20.40 18.21
2021-05-13 23.13 20.92 18.33
2021-05-14 18.81 20.87 18.38
2021-05-17 19.72 21.06 18.43
2021-05-18 21.34 21.73 18.54
2021-05-19 22.18 22.09 18.67
2021-05-20 20.67 21.92 18.78
2021-05-21 20.15 20.86 18.88
2021-05-24 18.40 20.18 18.94
2021-05-25 18.84 20.19 19.00
2021-05-26 17.36 19.85 19.02
2021-05-27 16.74 19.19 19.02
2021-05-28 16.76 18.42 19.02
2021-05-31 18.04 19.11
2021-06-01 17.90 17.67 19.13
2021-06-02 17.48 17.51 19.09
2021-06-03 18.04 17.38 19.11
2021-06-04 16.42 17.22 19.04
2021-06-07 16.42 17.17 19.01
2021-06-08 17.07 17.22 18.99
2021-06-09 17.89 17.32 19.00
2021-06-10 16.10 17.06 18.96
2021-06-11 15.65 16.80 18.89
2021-06-14 16.39 16.56 18.82
2021-06-15 17.02 16.65 18.78
2021-06-16 18.15 16.90 18.73
2021-06-17 17.75 16.99 18.69
2021-06-18 20.70 17.39 18.76
2021-06-21 17.89 17.65 18.80
2021-06-22 16.66 17.79 18.70
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
6 of 25

2021-06-23 16.32 17.78 18.52
2021-06-24 15.97 17.63 18.13
2021-06-25 15.62 17.27 17.88
2021-06-28 15.76 16.99 17.78
2021-06-29 16.02 16.32 17.66
2021-06-30 15.83 16.03 17.47
2021-07-01 15.48 15.86 17.25
2021-07-02 15.07 15.68 17.06
2021-07-05 15.63 16.96
2021-07-06 16.44 15.77 16.89
2021-07-07 16.20 15.84 16.80
2021-07-08 19.00 16.34 16.85
2021-07-09 16.18 16.40 16.83
2021-07-12 16.17 16.51 16.81
2021-07-13 17.12 16.85 16.82
2021-07-14 16.33 16.78 16.77
2021-07-15 17.01 16.86 16.76
2021-07-16 18.45 17.18 16.77
2021-07-19 22.50 17.68 16.97
2021-07-20 19.73 18.19 17.08
2021-07-21 17.91 18.44 17.11
2021-07-22 17.69 18.52 17.10
2021-07-23 17.20 18.64 17.14
2021-07-26 17.58 18.72 17.20
2021-07-27 19.36 18.85 17.30
2021-07-28 18.31 18.25 17.35
2021-07-29 17.70 17.96 17.33
2021-07-30 18.24 18.01 17.35
2021-08-02 19.46 18.26 17.31
2021-08-03 18.04 18.38 17.31
2021-08-04 17.97 18.44 17.36
2021-08-05 17.28 18.14 17.39
2021-08-06 16.15 17.83 17.39
2021-08-09 16.72 17.69 17.43
2021-08-10 16.79 17.49 17.46
2021-08-11 16.06 17.00 17.47
2021-08-12 15.59 16.65 17.46
2021-08-13 15.45 16.29 17.46
2021-08-16 16.12 16.13 17.49
2021-08-17 17.91 16.38 17.51
2021-08-18 21.57 17.07 17.67
2021-08-19 21.67 17.77 17.85
2021-08-20 18.56 18.12 17.83
2021-08-23 17.15 18.35 17.86
2021-08-24 17.22 18.60 17.90
2021-08-25 16.79 18.70 17.89
2021-08-26 18.84 18.83 17.97
2021-08-27 16.39 18.09 17.95
2021-08-30 16.19 17.31 17.88
2021-08-31 16.48 17.01 17.68
2021-09-01 16.11 16.86 17.56
2021-09-02 16.41 16.74 17.52
2021-09-03 16.41 16.69 17.47
2021-09-06 16.33 17.48
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
7 of 25

2021-09-07 18.14 16.62 17.50
2021-09-08 17.96 16.92 17.46
2021-09-09 18.80 17.31 17.47
2021-09-10 20.95 18.11 17.58
2021-09-13 19.37 18.61 17.62
2021-09-14 19.46 19.11 17.62
2021-09-15 18.18 18.98 17.62
2021-09-16 18.69 19.06 17.65
2021-09-17 20.81 19.47 17.76
2021-09-20 25.71 20.45 18.08
2021-09-21 24.36 20.94 18.34
2021-09-22 20.87 21.15 18.47
2021-09-23 18.63 21.04 18.56
2021-09-24 17.75 20.97 18.63
2021-09-27 18.76 20.98 18.74
2021-09-28 23.25 21.33 18.98
2021-09-29 22.56 20.88 19.13
2021-09-30 23.14 20.71 19.19
2021-10-01 21.15 20.75 19.17
2021-10-04 22.96 21.37 19.32
2021-10-05 21.30 21.87 19.45
2021-10-06 21.00 22.19 19.58
2021-10-07 19.54 21.66 19.67
2021-10-08 18.77 21.12 19.67
2021-10-11 20.00 20.67 19.79
2021-10-12 19.85 20.49 19.91
2021-10-13 18.64 19.87 19.98
2021-10-14 16.86 19.24 20.01
2021-10-15 16.30 18.57 20.01
2021-10-18 16.31 18.10 20.00
2021-10-19 15.70 17.67 19.86
2021-10-20 15.49 17.02 19.78
2021-10-21 15.01 16.33 19.68
2021-10-22 15.43 15.87 19.57
2021-10-25 15.24 15.64 19.39
2021-10-26 15.98 15.59 19.28
2021-10-27 16.98 15.69 19.20
2021-10-28 16.53 15.81 19.15
2021-10-29 16.26 15.92 19.07
2021-11-01 16.41 16.12 18.93
2021-11-02 16.03 16.20 18.61
2021-11-03 15.10 16.18 18.32
2021-11-04 15.44 16.11 18.14
2021-11-05 16.48 16.04 18.07
2021-11-08 17.22 16.13 18.05
2021-11-09 17.78 16.35 18.02
2021-11-10 18.73 16.68 17.88
2021-11-11 17.66 16.92 17.72
2021-11-12 16.29 17.09 17.50
2021-11-15 16.49 17.24 17.35
2021-11-16 16.37 17.22 17.14
2021-11-17 17.11 17.20 17.00
2021-11-18 17.59 17.18 16.89
2021-11-19 17.91 17.06 16.84
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
8 of 25

2021-11-22 19.17 17.28 16.85
2021-11-23 19.38 17.72 16.83
2021-11-24 18.58 18.02 16.79
2021-11-25 18.29 16.73
2021-11-26 28.62 20.21 17.12
2021-11-29 22.96 21.10 17.34
2021-11-30 27.19 22.65 17.70
2021-12-01 31.12 24.64 18.22
2021-12-02 27.95 26.07 18.63
2021-12-03 30.67 28.09 19.16
2021-12-06 27.18 27.96 19.55
2021-12-07 21.89 26.99 19.77
2021-12-08 19.90 26.56 19.90
2021-12-09 21.58 25.76 20.05
2021-12-10 18.69 23.98 20.13
2021-12-13 20.31 22.89 20.26
2021-12-14 21.89 21.63 20.44
2021-12-15 19.29 20.51 20.55
2021-12-16 20.57 20.32 20.73
2021-12-17 21.57 20.56 20.94
2021-12-20 22.87 20.74 21.15
2021-12-21 21.01 21.07 21.28
2021-12-22 18.63 20.83 21.31
2021-12-23 17.96 20.27 21.28
2021-12-24 20.44 21.40
2021-12-27 17.68 19.95 21.45
2021-12-28 17.54 19.28 21.49
2021-12-29 16.95 18.30 21.51
2021-12-30 17.33 17.68 21.52
2021-12-31 17.22 17.45 21.50
2022-01-03 16.60 17.22 21.46
2022-01-04 16.91 17.18 21.38
2022-01-05 19.73 17.47 21.39
2022-01-06 19.61 17.76 21.43
2022-01-07 18.76 18.02 21.34
2022-01-10 19.40 18.32 21.03
2022-01-11 18.41 18.49 20.88
2022-01-12 17.62 18.63 20.56
2022-01-13 20.31 19.12 20.20
2022-01-14 19.19 19.04 19.91
2022-01-17 18.95 19.54
2022-01-18 22.79 19.62 19.39
2022-01-19 23.85 20.36 19.45
2022-01-20 25.59 21.56 19.65
2022-01-21 28.85 23.43 19.90
2022-01-24 29.90 25.03 20.29
2022-01-25 31.16 27.02 20.66
2022-01-26 31.96 27.73 21.01
2022-01-27 30.49 28.83 21.40
2022-01-28 27.66 29.37 21.64
2022-01-31 24.83 29.26 21.75
2022-02-01 21.96 28.28 21.72
2022-02-02 22.09 27.16 21.76
2022-02-03 24.35 26.19 21.96
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
9 of 25

2022-02-04 23.22 24.94 22.14
2022-02-07 22.86 23.85 22.16
2022-02-08 21.44 22.96 22.29
2022-02-09 19.96 22.27 22.37
2022-02-10 23.91 22.55 22.60
2022-02-11 27.36 23.30 22.93
2022-02-14 28.33 23.87 23.30
2022-02-15 25.70 24.22 23.61
2022-02-16 24.29 24.43 23.85
2022-02-17 28.11 25.38 24.13
2022-02-18 27.75 26.49 24.40
2022-02-21 26.92 24.60
2022-02-22 28.81 27.17 24.92
2022-02-23 31.02 27.61 25.36
2022-02-24 30.32 28.38 25.80
2022-02-25 27.59 28.93 26.05
2022-02-28 30.15 29.27 26.42
2022-03-01 33.32 30.20 26.65
2022-03-02 30.74 30.28 26.92
2022-03-03 30.48 30.52 27.14
2022-03-04 31.98 30.65 27.35
2022-03-07 36.45 31.53 27.61
2022-03-08 35.13 32.61 27.78
2022-03-09 32.45 32.94 27.82
2022-03-10 30.23 32.49 27.77
2022-03-11 30.75 32.50 27.77
2022-03-14 31.77 32.68 27.91
2022-03-15 29.83 32.37 28.08
2022-03-16 26.67 30.98 28.24
2022-03-17 25.67 29.62 28.35
2022-03-18 23.87 28.40 28.34
2022-03-21 23.53 27.44 28.35
2022-03-22 22.94 26.33 28.35
2022-03-23 23.57 25.15 28.42
2022-03-24 21.67 23.99 28.48
2022-03-25 20.81 23.15 28.38
2022-03-28 19.63 22.29 28.12
2022-03-29 18.90 21.58 27.80
2022-03-30 19.33 20.98 27.59
2022-03-31 20.56 20.64 27.47
2022-04-01 19.63 20.08 27.19
2022-04-04 18.57 19.63 26.88
2022-04-05 21.03 19.66 26.69
2022-04-06 22.10 20.02 26.47
2022-04-07 21.55 20.40 26.17
2022-04-08 21.16 20.66 25.87
2022-04-11 24.37 21.20 25.77
2022-04-12 24.26 21.86 25.58
2022-04-13 21.82 22.33 25.21
2022-04-14 22.70 22.57 24.95
2022-04-15 22.64 24.76
2022-04-18 22.17 22.75 24.44
2022-04-19 21.37 22.78 23.93
2022-04-20 20.32 22.11 23.44
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
10 of 25

2022-04-21 22.68 21.84 23.12
2022-04-22 28.21 22.91 23.05
2022-04-25 27.02 23.63 22.92
2022-04-26 33.52 25.04 22.98
2022-04-27 31.60 26.39 23.04
2022-04-28 29.99 27.62 23.15
2022-04-29 33.40 29.49 23.41
2022-05-02 32.34 30.87 23.69
2022-05-03 29.25 31.02 23.88
2022-05-04 25.42 30.79 23.97
2022-05-05 31.20 30.46 24.22
2022-05-06 30.19 30.26 24.50
2022-05-09 34.75 30.94 24.97
2022-05-10 32.99 30.88 25.41
2022-05-11 32.56 30.91 25.87
2022-05-12 31.77 31.27 26.28
2022-05-13 28.87 31.76 26.56
2022-05-16 27.47 31.23 26.82
2022-05-17 26.10 30.64 27.07
2022-05-18 30.96 30.10 27.40
2022-05-19 29.35 29.58 27.65
2022-05-20 29.43 29.14 27.91
2022-05-23 28.48 28.67 28.15
2022-05-24 29.45 28.75 28.32
2022-05-25 28.37 28.88 28.46
2022-05-26 27.50 29.08 28.65
2022-05-27 25.72 28.33 28.75
2022-05-30 26.54 27.93 28.68
2022-05-31 26.19 27.46 28.81
2022-06-01 25.69 27.07 28.95
2022-06-02 24.72 26.39 29.09
2022-06-03 24.79 25.88 29.16
2022-06-06 25.07 25.53 29.05
2022-06-07 24.02 25.29 28.96
2022-06-08 23.96 24.92 28.65
2022-06-09 26.09 24.91 28.47
2022-06-10 27.75 25.20 28.40
2022-06-13 34.02 26.53 28.42
2022-06-14 32.69 27.66 28.43
2022-06-15 29.62 28.31 28.44
2022-06-16 32.95 29.58 28.69
2022-06-17 31.13 30.61 28.68
2022-06-20 31.03 31.31 28.71
2022-06-21 30.19 31.66 28.56
2022-06-22 28.95 30.94 28.43
2022-06-23 29.05 30.42 28.32
2022-06-24 27.23 30.08 28.17
2022-06-27 26.95 29.22 28.11
2022-06-28 28.36 28.82 28.14
2022-06-29 28.16 28.41 28.21
2022-06-30 28.71 28.20 28.13
2022-07-01 26.70 27.88 28.05
2022-07-04 27.53 27.66 27.99
2022-07-05 27.54 27.71 27.96
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
11 of 25

2022-07-06 26.73 27.68 27.87
2022-07-07 26.08 27.35 27.80
2022-07-08 24.64 26.85 27.70
2022-07-11 26.17 26.48 27.72
2022-07-12 27.29 26.57 27.74
2022-07-13 26.82 26.47 27.76
2022-07-14 26.40 26.30 27.79
2022-07-15 24.23 25.95 27.77
2022-07-18 25.30 25.84 27.79
2022-07-19 24.50 25.82 27.77
2022-07-20 23.88 25.49 27.76
2022-07-21 23.11 24.89 27.74
2022-07-22 23.03 24.35 27.64
2022-07-25 23.36 23.92 27.50
2022-07-26 24.69 23.98 27.19
2022-07-27 23.24 23.69 26.89
2022-07-28 22.33 23.38 26.65
2022-07-29 21.33 23.01 26.28
2022-08-01 22.84 22.97 26.01
2022-08-02 23.93 23.10 25.78
2022-08-03 21.95 22.90 25.52
2022-08-04 21.44 22.44 25.27
2022-08-05 21.15 22.14 25.02
2022-08-08 21.29 21.99 24.83
2022-08-09 21.77 22.05 24.66
2022-08-10 19.74 21.61 24.38
2022-08-11 20.20 21.08 24.13
2022-08-12 19.53 20.73 23.83
2022-08-15 19.95 20.52 23.61
2022-08-16 19.69 20.31 23.36
2022-08-17 19.90 20.11 23.11
2022-08-18 19.56 19.80 22.88
2022-08-19 20.60 19.92 22.71
2022-08-22 23.80 20.43 22.68
2022-08-23 24.11 21.09 22.61
2022-08-24 22.82 21.50 22.47
2022-08-25 21.78 21.80 22.30
2022-08-26 25.56 22.60 22.28
2022-08-29 26.21 23.55 22.34
2022-08-30 26.21 24.36 22.37
2022-08-31 25.87 24.65 22.42
2022-09-01 25.56 24.86 22.47
2022-09-02 25.47 25.24 22.55
2022-09-05 25.99 25.84 22.64
2022-09-06 26.91 26.03 22.76
2022-09-07 24.64 25.81 22.75
2022-09-08 23.61 25.44 22.77
2022-09-09 22.79 25.00 22.78
2022-09-12 23.87 24.75 22.86
2022-09-13 27.27 25.01 23.01
2022-09-14 26.16 25.04 23.08
2022-09-15 26.27 24.94 23.22
2022-09-16 26.30 25.18 23.37
2022-09-19 25.76 25.49 23.52
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
12 of 25

2022-09-20 27.16 26.11 23.71
2022-09-21 27.99 26.70 23.91
2022-09-22 27.35 26.71 24.16
2022-09-23 29.92 27.25 24.47
2022-09-26 32.26 28.11 24.88
2022-09-27 32.60 29.01 25.29
2022-09-28 30.18 29.64 25.63
2022-09-29 31.84 30.31 26.01
2022-09-30 31.62 30.82 26.40
2022-10-03 30.10 31.22 26.71
2022-10-04 29.07 31.10 26.88
2022-10-05 28.55 30.57 27.02
2022-10-06 30.52 30.27 27.27
2022-10-07 31.36 30.44 27.58
2022-10-10 32.45 30.52 27.80
2022-10-11 33.63 30.81 28.04
2022-10-12 33.57 31.31 28.28
2022-10-13 31.94 31.72 28.47
2022-10-14 32.02 32.21 28.68
2022-10-17 31.37 32.33 28.87
2022-10-18 30.50 32.21 29.02
2022-10-19 30.76 31.97 29.14
2022-10-20 29.98 31.45 29.32
2022-10-21 29.69 30.89 29.51
2022-10-24 29.85 30.60 29.74
2022-10-25 28.46 30.09 29.89
2022-10-26 27.28 29.50 29.89
2022-10-27 27.39 29.06 29.93
2022-10-28 25.75 28.34 29.91
2022-10-31 25.88 27.76 29.90
2022-11-01 25.81 27.20 29.90
2022-11-02 25.86 26.63 29.86
2022-11-03 25.30 26.18 29.77
2022-11-04 24.55 25.79 29.68
2022-11-07 24.35 25.36 29.50
2022-11-08 25.54 25.33 29.28
2022-11-09 26.09 25.36 29.07
2022-11-10 23.53 25.03 28.86
2022-11-11 22.52 24.55 28.56
2022-11-14 23.73 24.33 28.30
2022-11-15 24.54 24.33 28.12
2022-11-16 24.11 24.29 27.96
2022-11-17 23.93 24.06 27.81
2022-11-18 23.12 23.64 27.58
2022-11-21 22.36 23.47 27.29
2022-11-22 21.29 23.30 26.93
2022-11-23 20.35 22.81 26.50
2022-11-24 20.42 22.23 26.07
2022-11-25 20.50 21.71 25.70
2022-11-28 22.21 21.46 25.39
2022-11-29 21.89 21.29 25.08
2022-11-30 20.58 21.03 24.76
2022-12-01 19.84 20.83 24.41
2022-12-02 19.06 20.64 24.06
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
13 of 25

2022-12-05 20.75 20.69 23.77
2022-12-06 22.17 20.93 23.52
2022-12-07 22.68 21.00 23.33
2022-12-08 22.29 21.05 23.17
2022-12-09 22.83 21.37 23.03
2022-12-12 25.00 22.11 23.00
2022-12-13 22.55 22.61 22.90
2022-12-14 21.14 22.67 22.74
2022-12-15 22.83 22.76 22.65
2022-12-16 22.62 22.75 22.56
2022-12-19 22.42 22.77 22.49
2022-12-20 21.48 22.58 22.40
2022-12-21 20.07 21.87 22.22
2022-12-22 21.97 21.79 22.09
2022-12-23 20.87 21.75 22.00
2022-12-26 21.57 21.99
2022-12-27 21.65 21.41 21.92
2022-12-28 22.14 21.36 21.84
2022-12-29 21.44 21.36 21.75
2022-12-30 21.67 21.62 21.67
2023-01-02 21.55 21.62
2023-01-03 22.90 21.96 21.64
2023-01-04 22.01 21.97 21.67
2023-01-05 22.46 22.10 21.74
2023-01-06 21.13 21.94 21.76
2023-01-09 21.97 22.02 21.81
2023-01-10 20.58 21.84 21.76
2023-01-11 21.09 21.73 21.73
2023-01-12 18.83 21.15 21.67
2023-01-13 18.35 20.63 21.62
2023-01-16 19.49 20.21 21.63
2023-01-17 19.36 19.95 21.59
2023-01-18 20.34 19.72 21.52
2023-01-19 20.52 19.71 21.45
2023-01-20 19.85 19.53 21.36
2023-01-23 19.81 19.67 21.26
2023-01-24 19.20 19.80 21.06
2023-01-25 19.08 19.74 20.94
2023-01-26 18.73 19.65 20.86
2023-01-27 18.51 19.39 20.71
2023-01-30 19.94 19.30 20.62
2023-01-31 19.40 19.24 20.51
2023-02-01 17.87 18.96 20.39
2023-02-02 18.73 18.89 20.34
2023-02-03 18.33 18.79 20.22
2023-02-06 19.43 18.89 20.17
2023-02-07 18.66 18.91 20.12
2023-02-08 19.63 18.86 20.05
2023-02-09 20.71 19.05 20.00
2023-02-10 20.53 19.43 19.97
2023-02-13 20.34 19.66 19.93
2023-02-14 18.91 19.74 19.89
2023-02-15 18.23 19.57 19.74
2023-02-16 20.17 19.79 19.68
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
14 of 25

2023-02-17 20.02 19.84 19.60
2023-02-20 21.23 19.92 19.61
2023-02-21 22.87 20.25 19.64
2023-02-22 22.29 20.53 19.69
2023-02-23 21.14 20.85 19.69
2023-02-24 21.67 21.34 19.79
2023-02-27 20.95 21.45 19.87
2023-02-28 20.70 21.55 19.91
2023-03-01 20.58 21.46 19.95
2023-03-02 19.59 20.99 19.92
2023-03-03 18.49 20.45 19.86
2023-03-06 18.61 20.08 19.82
2023-03-07 19.59 19.79 19.81
2023-03-08 19.11 19.52 19.81
2023-03-09 22.61 19.80 19.92
2023-03-10 24.80 20.40 20.12
2023-03-13 26.52 21.39 20.38
2023-03-14 23.73 22.14 20.50
2023-03-15 26.14 23.21 20.72
2023-03-16 22.99 23.70 20.88
2023-03-17 25.51 24.61 21.10
2023-03-20 24.15 24.83 21.29
2023-03-21 21.38 24.35 21.35
2023-03-22 22.26 23.74 21.47
2023-03-23 22.61 23.58 21.56
2023-03-24 21.74 22.95 21.60
2023-03-27 20.60 22.61 21.60
2023-03-28 19.97 21.82 21.59
2023-03-29 19.12 21.10 21.59
2023-03-30 19.02 20.76 21.62
2023-03-31 18.70 20.25 21.57
2023-04-03 18.55 19.67 21.52
2023-04-04 19.00 19.28 21.45
2023-04-05 19.08 19.06 21.33
2023-04-06 18.40 18.84 21.20
2023-04-07 18.79 21.21
2023-04-10 18.97 18.78 21.12
2023-04-11 19.10 18.85 21.05
2023-04-12 19.09 18.94 21.00
2023-04-13 17.80 18.74 20.91
2023-04-14 17.07 18.41 20.82
2023-04-17 16.95 18.16 20.77
2023-04-18 16.83 17.97 20.71
2023-04-19 16.46 17.61 20.61
2023-04-20 17.17 17.34 20.54
2023-04-21 16.77 17.01 20.35
2023-04-24 16.89 16.88 20.09
2023-04-25 18.76 17.12 19.83
2023-04-26 18.84 17.39 19.66
2023-04-27 17.03 17.42 19.36
2023-04-28 15.78 17.32 19.12
2023-05-01 16.08 17.16 18.81
2023-05-02 17.78 17.31 18.59
2023-05-03 18.34 17.52 18.49
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
15 of 25

2023-05-04 20.09 17.71 18.42
2023-05-05 17.19 17.47 18.24
2023-05-08 16.98 17.46 18.08
2023-05-09 17.71 17.74 17.98
2023-05-10 16.94 17.86 17.88
2023-05-11 16.93 17.74 17.81
2023-05-12 17.03 17.55 17.74
2023-05-15 17.12 17.13 17.69
2023-05-16 17.99 17.24 17.67
2023-05-17 16.87 17.23 17.60
2023-05-18 16.05 16.99 17.50
2023-05-19 16.81 16.97 17.45
2023-05-22 17.21 17.01 17.44
2023-05-23 18.53 17.23 17.43
2023-05-24 20.03 17.64 17.46
2023-05-25 19.14 17.81 17.46
2023-05-26 17.95 17.96 17.46
2023-05-29 17.46 18.16 17.47
2023-05-30 17.46 18.25 17.49
2023-05-31 17.94 18.36 17.53
2023-06-01 15.65 17.95 17.50
2023-06-02 14.60 17.17 17.42
2023-06-05 14.73 16.54 17.35
2023-06-06 13.96 15.97 17.26
2023-06-07 13.94 15.47 17.10
2023-06-08 13.65 14.92 16.93
2023-06-09 13.83 14.34 16.83
2023-06-12 15.01 14.25 16.81
2023-06-13 14.61 14.25 16.76
2023-06-14 13.88 14.13 16.63
2023-06-15 14.50 14.20 16.51
2023-06-16 13.54 14.15 16.30
2023-06-19 14.19 14.22 16.20
2023-06-20 13.88 14.23 16.10
2023-06-21 13.20 13.97 15.96
2023-06-22 12.91 13.73 15.83
2023-06-23 13.44 13.67 15.71
2023-06-26 14.25 13.63 15.62
2023-06-27 13.74 13.66 15.51
2023-06-28 13.43 13.55 15.37
2023-06-29 13.54 13.50 15.26
2023-06-30 13.59 13.56 15.18
2023-07-03 13.57 13.65 15.08
2023-07-04 13.70 13.69 14.96
2023-07-05 14.18 13.68 14.82
2023-07-06 15.44 13.92 14.67
2023-07-07 14.83 14.12 14.54
2023-07-10 15.07 14.34 14.44
2023-07-11 14.84 14.52 14.36
2023-07-12 13.54 14.51 14.23
2023-07-13 13.61 14.50 14.09
2023-07-14 13.34 14.38 14.02
2023-07-17 13.48 14.10 13.98
2023-07-18 13.30 13.88 13.94
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
16 of 25

2023-07-19 13.76 13.70 13.93
2023-07-20 13.99 13.57 13.93
2023-07-21 13.60 13.58 13.93
2023-07-24 13.91 13.63 13.93
2023-07-25 13.86 13.70 13.89
2023-07-26 13.19 13.66 13.85
2023-07-27 14.41 13.82 13.87
2023-07-28 13.33 13.76 13.83
2023-07-31 13.63 13.70 13.83
2023-08-01 13.93 13.75 13.82
2023-08-02 16.09 14.06 13.89
2023-08-03 15.92 14.36 13.98
2023-08-04 17.10 14.92 14.12
2023-08-07 15.77 15.11 14.19
2023-08-08 15.99 15.49 14.25
2023-08-09 15.96 15.82 14.32
2023-08-10 15.85 16.10 14.40
2023-08-11 14.84 15.92 14.44
2023-08-14 14.82 15.76 14.48
2023-08-15 16.46 15.67 14.57
2023-08-16 16.78 15.81 14.67
2023-08-17 17.89 16.09 14.79
2023-08-18 17.30 16.28 14.85
2023-08-21 17.13 16.46 14.93
2023-08-22 16.97 16.76 14.99
2023-08-23 15.98 16.93 15.02
2023-08-24 17.20 17.04 15.14
2023-08-25 15.68 16.88 15.21
2023-08-28 15.08 16.48 15.26
2023-08-29 14.45 16.07 15.30
2023-08-30 13.88 15.61 15.31
2023-08-31 13.57 15.12 15.31
2023-09-01 13.09 14.71 15.28
2023-09-04 13.82 14.22 15.29
2023-09-05 14.01 13.99 15.29
2023-09-06 14.45 13.90 15.31
2023-09-07 14.40 13.89 15.35
2023-09-08 13.84 13.88 15.33
2023-09-11 13.80 13.92 15.34
2023-09-12 14.23 14.08 15.36
2023-09-13 13.48 14.03 15.35
2023-09-14 12.82 13.86 15.24
2023-09-15 13.79 13.77 15.18
2023-09-18 14.00 13.71 15.08
2023-09-19 14.11 13.75 15.02
2023-09-20 15.14 13.94 14.99
2023-09-21 17.54 14.41 15.05
2023-09-22 17.20 14.94 15.09
2023-09-25 16.90 15.53 15.16
2023-09-26 18.94 16.26 15.29
2023-09-27 18.22 16.86 15.34
2023-09-28 17.34 17.33 15.36
2023-09-29 17.52 17.67 15.35
2023-10-02 17.61 17.68 15.36
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
17 of 25

2023-10-03 19.78 18.04 15.45
2023-10-04 18.58 18.28 15.50
2023-10-05 18.49 18.22 15.58
2023-10-06 17.45 18.11 15.59
2023-10-09 17.70 18.16 15.65
2023-10-10 17.03 18.09 15.72
2023-10-11 16.09 17.87 15.77
2023-10-12 16.69 17.43 15.86
2023-10-13 19.32 17.54 16.04
2023-10-16 17.21 17.36 16.18
2023-10-17 17.88 17.42 16.31
2023-10-18 19.22 17.63 16.48
2023-10-19 21.40 18.26 16.70
2023-10-20 21.71 19.06 16.94
2023-10-23 20.37 19.59 17.15
2023-10-24 18.97 19.54 17.31
2023-10-25 20.19 19.96 17.51
2023-10-26 20.68 20.36 17.74
2023-10-27 21.27 20.66 18.01
2023-10-30 19.75 20.42 18.20
2023-10-31 18.14 19.91 18.34
2023-11-01 16.87 19.41 18.43
2023-11-02 15.66 18.94 18.44
2023-11-03 14.91 18.18 18.36
2023-11-06 14.89 17.36 18.28
2023-11-07 14.81 16.43 18.22
2023-11-08 14.45 15.68 18.07
2023-11-09 15.29 15.27 17.98
2023-11-10 14.17 14.88 17.87
2023-11-13 14.76 14.75 17.79
2023-11-14 14.16 14.65 17.67
2023-11-15 14.18 14.55 17.49
2023-11-16 14.32 14.48 17.36
2023-11-17 13.80 14.38 17.20
2023-11-20 13.41 14.11 17.07
2023-11-21 13.35 14.00 16.93
2023-11-22 12.85 13.72 16.80
2023-11-23 12.80 13.53 16.69
2023-11-24 12.46 13.28 16.56
2023-11-27 12.69 13.05 16.34
2023-11-28 12.69 12.89 16.20
2023-11-29 12.98 12.83 16.04
2023-11-30 12.92 12.77 15.84
2023-12-01 12.63 12.74 15.55
2023-12-04 13.08 12.78 15.27
2023-12-05 12.85 12.83 15.03
2023-12-06 12.97 12.87 14.84
2023-12-07 13.06 12.93 14.61
2023-12-08 12.35 12.84 14.34
2023-12-11 12.63 12.80 14.06
2023-12-12 12.07 12.72 13.81
2023-12-13 12.19 12.59 13.62
2023-12-14 12.48 12.54 13.48
2023-12-15 12.28 12.44 13.37
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
18 of 25

2023-12-18 12.56 12.37 13.29
2023-12-19 12.53 12.39 13.22
2023-12-20 13.67 12.54 13.18
2023-12-21 13.65 12.77 13.16
2023-12-22 13.03 12.89 13.08
2023-12-25 12.95 13.05
2023-12-26 12.99 13.07 12.99
2023-12-27 12.43 13.05 12.93
2023-12-28 12.47 13.04 12.87
2023-12-29 12.45 12.84 12.81
2024-01-01 12.67 12.78
2024-01-02 13.20 12.71 12.77
2024-01-03 14.04 12.93 12.79
2024-01-04 14.13 13.12 12.84
2024-01-05 13.35 13.27 12.86
2024-01-08 13.08 13.38 12.88
2024-01-09 12.76 13.43 12.88
2024-01-10 12.69 13.32 12.88
2024-01-11 12.44 13.21 12.86
2024-01-12 12.70 13.02 12.85
2024-01-15 13.25 12.90 12.88
2024-01-16 13.84 12.97 12.90
2024-01-17 14.79 13.21 12.97
2024-01-18 14.13 13.41 13.01
2024-01-19 13.30 13.49 13.02
2024-01-22 13.19 13.60 13.05
2024-01-23 12.55 13.58 13.04
2024-01-24 13.14 13.56 13.08
2024-01-25 13.45 13.51 13.12
2024-01-26 13.26 13.29 13.15
2024-01-29 13.60 13.21 13.20
2024-01-30 13.31 13.21 13.22
2024-01-31 14.35 13.38 13.28
2024-02-01 13.88 13.57 13.29
2024-02-02 13.85 13.67 13.30
2024-02-05 13.67 13.70 13.32
2024-02-06 13.06 13.67 13.31
2024-02-07 12.83 13.56 13.31
2024-02-08 12.79 13.49 13.32
2024-02-09 12.93 13.29 13.33
2024-02-12 13.93 13.29 13.38
2024-02-13 15.85 13.58 13.46
2024-02-14 14.38 13.68 13.50
2024-02-15 14.01 13.82 13.50
2024-02-16 14.24 14.02 13.50
2024-02-19 14.71 14.29 13.55
2024-02-20 15.42 14.65 13.62
2024-02-21 15.34 14.85 13.71
2024-02-22 14.54 14.66 13.77
2024-02-23 13.75 14.57 13.81
2024-02-26 13.74 14.53 13.84
2024-02-27 13.43 14.42 13.85
2024-02-28 13.84 14.29 13.85
2024-02-29 13.40 14.01 13.80
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
19 of 25

2024-03-01 13.11 13.69 13.77
2024-03-04 13.49 13.54 13.78
2024-03-05 14.46 13.64 13.82
2024-03-06 14.50 13.75 13.88
2024-03-07 14.44 13.89 13.92
2024-03-08 14.74 14.02 13.96
2024-03-11 15.22 14.28 14.03
2024-03-12 13.84 14.38 14.03
2024-03-13 13.75 14.42 14.05
2024-03-14 14.40 14.41 14.05
2024-03-15 14.41 14.40 14.07
2024-03-18 14.33 14.38 14.08
2024-03-19 13.82 14.25 14.09
2024-03-20 13.04 13.94 14.09
2024-03-21 12.92 13.81 14.09
2024-03-22 13.06 13.71 14.10
2024-03-25 13.19 13.54 14.11
2024-03-26 13.24 13.37 14.08
2024-03-27 12.78 13.15 13.99
2024-03-28 13.01 13.03 13.94
2024-03-29 13.03 13.94
2024-04-01 13.65 13.16 13.92
2024-04-02 14.61 13.41 13.92
2024-04-03 14.33 13.60 13.88
2024-04-04 16.35 14.12 13.91
2024-04-05 16.03 14.66 13.96
2024-04-08 15.19 15.03 14.01
2024-04-09 14.98 15.02 14.05
2024-04-10 15.80 15.33 14.13
2024-04-11 14.91 15.37 14.17
2024-04-12 17.31 15.80 14.30
2024-04-15 19.23 16.21 14.50
2024-04-16 18.40 16.55 14.66
2024-04-17 18.21 16.98 14.79
2024-04-18 18.00 17.41 14.91
2024-04-19 18.71 17.82 15.05
2024-04-22 16.94 18.11 15.12
2024-04-23 15.69 17.88 15.14
2024-04-24 15.97 17.42 15.21
2024-04-25 15.37 16.98 15.26
2024-04-26 15.03 16.53 15.28
2024-04-29 14.67 16.05 15.29
2024-04-30 15.65 15.62 15.34
2024-05-01 15.39 15.40 15.39
2024-05-02 14.68 15.25 15.44
2024-05-03 13.49 14.90 15.46
2024-05-06 13.49 14.63 15.48
2024-05-07 13.23 14.37 15.48
2024-05-08 13.00 14.13 15.47
2024-05-09 12.69 13.71 15.47
2024-05-10 12.55 13.30 15.45
2024-05-13 13.60 13.15 15.39
2024-05-14 13.42 13.14 15.38
2024-05-15 12.45 12.99 15.31
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
20 of 25

2024-05-16 12.42 12.88 15.25
2024-05-17 11.99 12.73 15.11
2024-05-20 12.15 12.65 14.99
2024-05-21 11.86 12.56 14.88
2024-05-22 12.29 12.37 14.79
2024-05-23 12.77 12.28 14.70
2024-05-24 11.93 12.20 14.60
2024-05-27 12.36 12.19 14.44
2024-05-28 12.92 12.33 14.24
2024-05-29 14.28 12.63 14.10
2024-05-30 14.47 13.00 13.98
2024-05-31 12.92 13.09 13.82
2024-06-03 13.11 13.14 13.64
2024-06-04 13.16 13.32 13.52
2024-06-05 12.63 13.36 13.42
2024-06-06 12.58 13.31 13.31
2024-06-07 12.22 13.01 13.21
2024-06-10 12.74 12.77 13.13
2024-06-11 12.85 12.76 13.07
2024-06-12 12.04 12.60 12.96
2024-06-13 11.94 12.43 12.85
2024-06-14 12.66 12.43 12.78
2024-06-17 12.75 12.46 12.76
2024-06-18 12.30 12.47 12.72
2024-06-19 12.48 12.43 12.69
2024-06-20 13.28 12.49 12.70
2024-06-21 13.20 12.66 12.72
2024-06-24 13.33 12.86 12.75
2024-06-25 12.84 12.88 12.72
2024-06-26 12.55 12.85 12.69
2024-06-27 12.24 12.85 12.69
2024-06-28 12.44 12.84 12.69
2024-07-01 12.22 12.69 12.69
2024-07-02 12.03 12.52 12.69
2024-07-03 12.09 12.34 12.70
2024-07-04 12.26 12.26 12.70
2024-07-05 12.48 12.25 12.69
2024-07-08 12.37 12.27 12.70
2024-07-09 12.51 12.28 12.71
2024-07-10 12.85 12.37 12.70
2024-07-11 12.92 12.50 12.66
2024-07-12 12.46 12.55 12.60
2024-07-15 13.12 12.67 12.60
2024-07-16 13.19 12.77 12.60
2024-07-17 14.48 13.08 12.65
2024-07-18 15.93 13.56 12.75
2024-07-19 16.52 14.09 12.88
2024-07-22 14.91 14.37 12.97
2024-07-23 14.72 14.70 13.03
2024-07-24 18.04 15.40 13.20
2024-07-25 18.46 16.15 13.41
2024-07-26 16.39 16.42 13.55
2024-07-29 16.60 16.52 13.68
2024-07-30 17.69 16.69 13.84
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
21 of 25

2024-07-31 16.36 16.89 13.97
2024-08-01 18.59 17.45 14.16
2024-08-02 23.39 18.21 14.49
2024-08-05 38.57 21.08 15.31
2024-08-06 27.71 22.70 15.77
2024-08-07 27.85 24.31 16.26
2024-08-08 23.79 25.18 16.62
2024-08-09 20.37 25.75 16.88
2024-08-12 20.71 26.06 17.15
2024-08-13 18.12 25.30 17.34
2024-08-14 16.19 22.11 17.47
2024-08-15 15.23 20.32 17.57
2024-08-16 14.80 18.46 17.66
2024-08-19 14.65 17.15 17.73
2024-08-20 15.88 16.51 17.84
2024-08-21 16.27 15.88 17.96
2024-08-22 17.55 15.80 18.11
2024-08-23 15.86 15.75 18.21
2024-08-26 16.15 15.88 18.33
2024-08-27 15.43 15.97 18.40
2024-08-28 17.11 16.32 18.53
2024-08-29 15.65 16.29 18.56
2024-08-30 15.00 16.11 18.53
2024-09-02 15.55 15.82 18.50
2024-09-03 20.72 16.52 18.69
2024-09-04 21.32 17.25 18.90
2024-09-05 19.90 17.89 18.96
2024-09-06 22.38 18.65 19.09
2024-09-09 19.45 19.19 19.19
2024-09-10 19.08 19.77 19.27
2024-09-11 17.69 20.08 19.27
2024-09-12 17.07 19.56 19.29
2024-09-13 16.56 18.88 19.23
2024-09-16 17.14 18.48 19.02
2024-09-17 17.61 17.80 18.35
2024-09-18 18.23 17.63 18.04
2024-09-19 16.33 17.23 17.67
2024-09-20 16.15 17.01 17.42
2024-09-23 15.89 16.84 17.28
2024-09-24 15.39 16.68 17.11
2024-09-25 15.41 16.43 17.02
2024-09-26 15.37 16.11 16.99
2024-09-27 16.96 15.93 17.05
2024-09-30 16.73 15.99 17.11
2024-10-01 19.26 16.43 17.26
2024-10-02 18.90 16.86 17.36
2024-10-03 20.49 17.59 17.49
2024-10-04 19.21 18.13 17.55
2024-10-07 22.64 19.17 17.77
2024-10-08 21.42 19.81 17.94
2024-10-09 20.86 20.40 18.11
2024-10-10 20.93 20.64 18.24
2024-10-11 20.46 20.86 18.39
2024-10-14 19.70 20.75 18.54
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
22 of 25

2024-10-15 20.64 20.95 18.71
2024-10-16 19.58 20.51 18.67
2024-10-17 19.11 20.18 18.60
2024-10-18 18.03 19.78 18.54
2024-10-21 18.37 19.41 18.41
2024-10-22 18.20 19.09 18.37
2024-10-23 19.24 19.02 18.37
2024-10-24 19.08 18.80 18.42
2024-10-25 20.33 18.91 18.52
2024-10-28 19.80 19.01 18.63
2024-10-29 19.34 19.19 18.70
2024-10-30 20.35 19.48 18.79
2024-10-31 23.16 20.19 18.95
2024-11-01 21.88 20.56 19.13
2024-11-04 21.98 20.98 19.31
2024-11-05 20.49 21.00 19.46
2024-11-06 16.27 20.50 19.49
2024-11-07 15.20 19.90 19.48
2024-11-08 14.94 19.13 19.47
2024-11-11 14.97 17.96 19.41
2024-11-12 14.71 16.94 19.34
2024-11-13 14.02 15.80 19.17
2024-11-14 14.31 14.92 19.02
2024-11-15 16.14 14.90 18.88
2024-11-18 15.58 14.95 18.77
2024-11-19 16.35 15.15 18.56
2024-11-20 17.16 15.47 18.43
2024-11-21 16.87 15.78 18.30
2024-11-22 15.24 15.95 18.11
2024-11-25 14.60 15.99 17.92
2024-11-26 14.10 15.70 17.74
2024-11-27 14.10 15.49 17.53
2024-11-28 13.90 15.14 17.35
2024-11-29 13.51 14.62 17.17
2024-12-02 13.34 14.11 17.02
2024-12-03 13.30 13.84 16.85
2024-12-04 13.45 13.67 16.70
2024-12-05 13.54 13.59 16.52
2024-12-06 12.77 13.40 16.31
2024-12-09 14.19 13.44 16.11
2024-12-10 14.18 13.54 15.93
2024-12-11 13.58 13.57 15.75
2024-12-12 13.92 13.66 15.54
2024-12-13 13.81 13.71 15.24
2024-12-16 14.69 13.88 15.01
2024-12-17 15.87 14.32 14.81
2024-12-18 27.62 16.24 15.04
2024-12-19 24.09 17.65 15.29
2024-12-20 18.36 18.34 15.39
2024-12-23 16.78 18.75 15.45
2024-12-24 14.27 18.81 15.43
2024-12-25 19.50 15.45
2024-12-26 14.73 19.31 15.48
2024-12-27 15.95 17.36 15.53
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
23 of 25

2024-12-30 17.40 16.25 15.58
2024-12-31 17.35 16.08 15.63
2025-01-01 15.94 15.61
2025-01-02 17.93 16.67 15.64
2025-01-03 16.13 16.58 15.61
2025-01-06 16.04 16.80 15.64
2025-01-07 17.82 17.11 15.75
2025-01-08 17.70 17.16 15.87
2025-01-09 18.07 17.28 16.01
2025-01-10 19.54 17.60 16.20
2025-01-13 19.19 17.78 16.40
2025-01-14 18.71 18.15 16.59
2025-01-15 16.12 18.16 16.68
2025-01-16 16.60 17.99 16.79
2025-01-17 15.97 17.74 16.88
2025-01-20 15.81 17.42 16.98
2025-01-21 15.06 16.78 17.01
2025-01-22 15.10 16.20 17.04
2025-01-23 15.02 15.67 17.09
2025-01-24 14.85 15.49 17.12
2025-01-27 17.90 15.67 17.26
2025-01-28 16.41 15.74 17.32
2025-01-29 16.56 15.84 17.35
2025-01-30 15.84 15.95 16.94
2025-01-31 16.43 16.14 16.68
2025-02-03 18.62 16.66 16.69
2025-02-04 17.21 17.00 16.70
2025-02-05 15.77 16.69 16.75
2025-02-06 15.50 16.56 16.71
2025-02-07 16.54 16.56 16.77
2025-02-10 15.81 16.55 16.77
2025-02-11 16.02 16.50 16.72
2025-02-12 15.89 16.11 16.67
2025-02-13 15.10 15.80 16.62
2025-02-14 14.77 15.66 16.52
2025-02-17 15.37 15.64 16.49
2025-02-18 15.35 15.47 16.47
2025-02-19 15.27 15.40 16.39
2025-02-20 15.66 15.34 16.32
2025-02-21 18.21 15.68 16.33
2025-02-24 18.98 16.23 16.31
2025-02-25 19.43 16.90 16.32
2025-02-26 19.10 17.43 16.33
2025-02-27 21.13 18.25 16.49
2025-02-28 19.63 18.88 16.59
2025-03-03 22.78 19.89 16.81
2025-03-04 23.51 20.65 17.06
2025-03-05 21.93 21.07 17.28
2025-03-06 24.87 21.85 17.60
2025-03-07 23.37 22.46 17.86
2025-03-10 27.86 23.42 18.28
2025-03-11 26.92 24.46 18.58
2025-03-12 24.23 24.67 18.83
2025-03-13 24.66 24.83 19.09
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
24 of 25

2025-03-14 21.77 24.81 19.28
2025-03-17 20.51 24.19 19.41
2025-03-18 21.70 23.95 19.51
2025-03-19 19.90 22.81 19.60
2025-03-20 19.80 21.80 19.73
2025-03-21 19.28 21.09 19.85
2025-03-24 17.48 20.06 19.88
2025-03-25 17.15 19.40 19.92
2025-03-26 18.33 19.09 20.00
2025-03-27 18.69 18.66 20.09
2025-03-28 21.65 18.91 20.30
2025-03-31 22.28 19.27 20.54
2025-04-01 21.77 19.62 20.75
2025-04-02 21.51 20.20 20.95
2025-04-03 30.02 22.04 21.42
2025-04-04 45.31 25.89 22.38
2025-04-07 46.98 29.93 23.31
2025-04-08 52.33 34.31 24.38
2025-04-09 33.62 35.93 24.84
2025-04-10 40.72 38.64 25.54
2025-04-11 37.56 40.93 26.07
2025-04-14 30.89 41.06 26.43
2025-04-15 30.12 38.89 26.67
2025-04-16 32.64 36.84 26.96
2025-04-17 29.65 33.60 27.21
2025-04-18 33.60 27.29
2025-04-21 33.82 32.45 27.64
2025-04-22 30.57 31.28 27.73
2025-04-23 28.45 30.88 27.78
2025-04-24 26.47 30.27 27.85
2025-04-25 24.84 28.97 27.86
2025-04-28 25.15 28.22 27.97
2025-04-29 24.17 27.64 28.10
2025-04-30 24.70 26.34 28.20
2025-05-01 24.60 25.48 28.35
2025-05-02 22.68 24.66 28.45
2025-05-05 23.64 24.25 28.59
2025-05-06 24.76 24.24 28.84
2025-05-07 23.55 24.01 29.05
2025-05-08 22.48 23.77 29.19
2025-05-09 21.90 23.37 29.29
2025-05-12 18.39 22.49 29.19
2025-05-13 18.22 21.85 29.05
2025-05-14 18.62 21.13 28.95
2025-05-15 17.83 20.14 28.82
2025-05-16 17.24 19.24 28.40
Exhibit No. 16
Case No. IPC-E-25-16
B. Buckham, IPC
25 of 25

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-16
IDAHO POWER COMPANY
BUCKRAM, DI
TESTIMONY
EXHIBIT NO. 17

IDAHO POWER COMPANY
PRO FORMA COST OF CAPITAL
SUMMARIZED
December 31, 2025 Capitalization
(000's)
(1) (2) (3) (4) (5)
Line Capitalization Structure Embedded Weighted
No Amount Percent Cost Cost
1 Long-term Debt 3,461,300 49.0% 5.132% 2.515%
3 Common Equity 3,600,000 51.0% 10.400% * 5.302%
4 Total Capitalization $7,061,300 100.000% 7.818%
Note:
* Requested Rate of Return
Exhibit No. 17
Case No. IPC-E-25-16
B. Buckham, IPC
1 of 2

IDAHO POWER COMPANY
PRO FORMA COST OF LONG-TERM DEBT
As of 12/31/2025
(000's)
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12)
Line Coupon Settlement Maturity Principal Amount Discount/ Issuance Net Yield To Effective
No. Class and Series Rate Date Date Issued Outstanding Price (Premium) Costs Proceeds Maturity Cost
First Mortgage Bonds:
1 6.00%Series due 2032 6.00% 11/15/2002 11/15/2032 100,000 100,000 98.706 1,294.0 441.2 98,264.8 6.127% 6,127.1
2 5.5%Series due 2033 5.50% 5/13/2003 4/1/2033 70,000 70,000 99.198 561.4 3,810.2 65,628.4 5.949% 4,164.3
3 5.5% Series due 2034 5.50% 3/26/2004 3/15/2034 50,000 50,000 98.483 758.5 149.4 49,092.1 5.626% 2,813.0
4 5.875% Series due 2034 5.875% 8/16/2004 8/15/2034 55,000 55,000 97.890 1,160.5 173.3 53,666.2 6.051% 3,328.2
5 5.30% Series due 2035 5.30% 8/26/2005 8/15/2035 60,000 60,000 98.569 858.6 3,399.7 55,741.7 5.802% 3,481.3
6 6.30%Series due 2037 6.30% 6/22/2007 6/15/2037 140,000 140,000 99.051 1,328.6 450.0 138,221.4 6.396% 8,953.9
7 6.25%Series due 2037 6.25% 10/18/2007 10/15/2037 100,000 100,000 98.982 1,018.0 477.5 98,504.5 6.362% 6,362.3
8 4.85%Series due 2040 4.85% 8/30/2010 8/15/2040 100,000 100,000 99.080 920.0 534.9 98,545.1 4.943% 4,943.4
9 4.30%Series due 2042 4.30% 4/13/2012 4/1/2042 75,000 75,000 99.184 612.0 1,397.8 72,990.2 4.463% 3,347.2
10 4.00%Series due 2043 4.00% 4/8/2013 4/1/2043 75,000 75,000 98.991 756.8 179.2 74,064.0 4.072% 3,054.3
11 3.65%Series due 2045 3.65% 3/6/2015 3/1/2045 250,000 250,000 98.564 3,590.0 19,137.5 227,272.5 4.185% 10,462.3
12 4.05%Series due2046 4.05% 3/10/2016 3/1/2046 120,000 120,000 98.992 1,209.6 14,689.4 104,101.0 4.898% 5,877.1
13 4.20%Series due 2048 4.20% 3/16/2018 3/1/2048 220,000 220,000 98.880 2,464.0 5,532.0 212,004.0 4.420% 9,723.8
14 4.20%Series due 2048 4.20% 4/3/2020 3/1/2048 230,000 230,000 113.013 (29,929.9) 621.1 259,308.8 3.482% 8,009.4
15 1.90%Series due 2030 1.90% 6/22/2020 7/15/2030 80,000 80,000 98.940 848.0 3,925.3 75,226.7 2.577% 2,061.4
16 4.99%Series due 2032 4.99% 12/22/2022 12/22/2032 23,000 23,000 99.500 115.0 53.9 22,831.1 5.085% 1,169.5
17 5.06%Series due 2042 5.06% 12/22/2022 12/22/2042 25,000 25,000 99.500 125.3 58.5 24,816.2 5.119% 1,279.8
18 5.06%Series due 2043 5.06% 3/8/2023 3/8/2043 60,000 60,000 99.500 300.7 140.5 59,558.8 5.119% 3,071.5
19 5.20%Series due 2053 5.20% 3/8/2023 3/8/2053 62,000 62,000 99.500 310.7 145.2 61,544.1 5.249% 3,254.3
20 5.50%Series due 2053 5.50% 3/14/2023 3/15/2053 400,000 400,000 98.182 7,272.0 881.2 391,846.8 5.642% 22,566.7
21 5.80%Series due2054 5.80% 9/11/2023 4/1/2054 350,000 350,000 98.201 6,296.5 707.1 342,996.4 5.942% 20,798.6
22 5.20%Series due 2034 5.20% 8/12/2024 8/15/2034 300,000 300,000 99.288 2,136.0 311.6 297,552.4 5.306% 15,918.1
23 5.70%Series due 2055 5.70% 3/13/2025 3/15/2055 400,000 400,000 98.357 6,572.0 970.0 392,458.0 5.834% 23,335.2
24
25 Total First Mortgage Bonds 3,345,000 3,345,000 10,578.3 58,186.6 3,276,235.1 5.205% 174,102.7
26
27 Pollution Control Revenue Bonds:
28 Sweetwater 1.70%Series 2006,due 2026 1.70% 8/21/2019 7/15/2026 116,300 116,300 99.2 930.4 8,612.9 106,756.7 3.027% 3,519.8
29
32
33 TOTAL DEBT CAPITAL 3,461,300 3,461,300 11,509 66,800 3,382,992 5.132% 177,623
Exhibit No.17
Case No.IPC-E-25-16
B.Buckham,IPC
2 of