HomeMy WebLinkAbout20250530Direct Grow.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
LISA A. GROW
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 Lisa A. Grow. My business address
5 is 1221 West Idaho Street, Boise, Idaho 83702 . I am
6 employed by Idaho Power as the President and Chief
7 Executive Officer ("CEO") .
8 Q. Please describe your educational background.
9 A. I received a Bachelor of Science in Electrical
10 Engineering from the University of Idaho in 1987 and an
11 Executive Master of Business Administration from Boise
12 State University in 2008, in addition to numerous industry
13 and leadership courses and trainings over the past 38
14 years .
15 Q. Please describe your work experience with
16 Idaho Power.
17 A. I have held 14 positions in my 38 years with
18 Idaho Power. I became President & CEO in June 2020 . Before
19 that I held several officer positions : Senior Vice
20 President & Chief Operating Officer, Senior Vice President
21 of Power Supply, and Vice President of Engineering and
22 Construction. I was also the General Manager, Grid
23 Operations & Planning, and Senior Manager, Grid Operations,
24 and Control Area Operations Leader. In the early part of my
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Idaho Power Company
1 career, I held many engineering positions throughout the
2 Company.
3 Q. Please summarize your testimony.
4 A. The Company is currently in a period of
5 unprecedented capital investment necessary to maintain,
6 improve, and protect the electrical system. Idaho Power
7 will continue to make considerable ongoing investments in
8 response to rapid customer and load growth, as well as
9 aging infrastructure. The Company continues to work hard
10 to manage increases in Operations & Maintenance ("O&M")
11 expenses by maintaining a cost-conscious culture; however,
12 the increasing cost of wildfire mitigation and insurance
13 make such efforts difficult at best.
14 The request in this case is largely focused on the
15 rate base additions needed to safely and reliably serve our
16 customers, the associated incremental depreciation and
17 interest expense, as well as increased wildfire mitigation
18 and insurance costs . The Company' s current rates are not
19 sufficient to cover the cost to serve customers nor do they
20 allow for an opportunity for Idaho Power to earn a
21 reasonable rate of return on investment for our owners who
22 are providing the capital to finance the investments . This
23 dynamic was clearly demonstrated in 2024 as the Company
24 fell well short of earning its authorized rate of return on
25 equity, and it expects to fall well short again in 2025 .
GROW, DI 2
Idaho Power Company
1 The application of a historical test year in the
2 current environment of high growth and rising costs has
3 resulted in unsustainable regulatory lag impacting the
4 Company' s ability to achieve reasonable rates of return and
5 maintain sufficient credit metrics between rate cases . As a
6 result, Idaho Power is proposing as part of this General
7 Rate Case ("GRC") a depreciation/amortization and interest
8 expense ("Depreciation and Interest Expense") tracking
9 mechanism and other earnings support measures to help
10 address some, but not all, of the harmful regulatory lag
11 caused by using a historical test year.
12 Q. What is the Company' s request in this case?
13 A. Idaho Power is requesting the Idaho Public
14 Utilities Commission ("Commission") authorize an increase
15 to Idaho jurisdictional retail revenue of $199 . 1 million,
16 or 13 . 09 percent, effective January 1, 2026, which is net
17 of a $46 . 8 million Power Cost Adjustment decrease . This
18 request is based upon a 2025 test year and a rate of return
19 on equity ("ROE") of 10 . 4 percent.
20 In addition to the rate relief requested in this
21 case, the Company is also seeking authorization to 1)
22 establish a tracking mechanism for incremental Depreciation
23 and Interest Expense effective January 1, 2026, 2) continue
24 deferring incremental wildfire mitigation and insurance
25 costs from a base level of cost recovery established in
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Idaho Power Company
1 this case, and 3) designate additional accumulated deferred
2 investment tax credits ("ADITC") as eligible for
3 accelerated amortization under the terms of the currently
4 approved ADITC/Revenue Sharing Mechanism', with the addition
5 of a $75 million annual amortization cap.
6 Q. What is the purpose of your testimony in this
7 matter?
8 A. The purpose of my testimony is to 1) provide a
9 general overview of Idaho Power and its core business
10 practices, 2) generally discuss Idaho Power' s business
11 management practices, 3) present the Company' s request in
12 this case and inform the Commission of the financial and
13 economic factors driving the need for the requested base
14 revenue adjustment and other requests in this case, and 4)
15 discuss the harmful effects of regulatory lag the Company
16 has, and will continue to, experience as a result of
17 applying a historical test year in the rate setting
18 process .
19 Q. Are you the witness that can address overall
20 Company policy?
21 A. Yes .
' The current terms of the ADITC/Revenue Sharing mechanism are detailed
in the Settlement Stipulation approved by Final Order No. 36042 in Case
No. IPC-E-23-11.
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Idaho Power Company
1 I . COMPANY OVERVIEW
2 Q. Please provide an overview of Idaho Power.
3 A. Idaho Power Company is headquartered in Boise,
4 Idaho, and has been a locally operated energy company since
5 1916 . The Company has approximately 2, 100 employees that
6 proudly serve approximately 650, 000 customers (and a
7 population of around 1 . 3 million people) over a 24, 000-
8 square-mile service area in Idaho and Oregon. With 17 low-
9 cost hydropower projects at the core of its diverse energy
10 mix, Idaho Power' s residential, business, and agricultural
11 customers pay among the nation ' s lowest prices for
12 electricity.
13 Q. What is Idaho Power' s overall business focus?
14 A. Idaho Power endeavors to remain a financially
15 strong, independent, vertically integrated utility
16 supported by a safe and engaged work force dedicated to
17 providing safe, reliable, and affordable electric service
18 to our customers .
19 Q. What are the key elements that guide Idaho
20 Power' s company culture?
21 A. Idaho Power' s culture is guided by our
22 purpose, values, and our commitment to each other. We are
23 passionate about powering lives with safe, reliable,
24 affordable service, while developing innovative solutions
25 every day. Serving those who depend on us is at the center
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Idaho Power Company
1 of everything we do. We prosper by committing to the needs,
2 safety and success of our customers, communities,
3 employees, and owners .
4 Our Company' s three core values are Safety First,
5 Integrity Always, and Respect for All . Safety First - We
6 are committed to the safety of our employees, our
7 customers, and the communities we serve. Integrity Always -
8 Customers, owners, and employees can count on us to be fair
9 and ethical . Respect for All - We treat our customers,
10 partners, employees, and the environment with care and
11 dignity.
12 Q. What is Idaho Power' s philosophy regarding
13 safety?
14 A. Because safety is a core value at Idaho Power,
15 the Company embraces and fosters a Safety First culture .
16 The Safety First culture recognizes that Idaho Power' s
17 family of employees is the Company' s greatest asset and
18 emphasizes that each employee' s most important
19 responsibility in their daily work is safety and that no
20 work is so critical that safety should be disregarded. The
21 Company is committed to the safety of its employees,
22 customers, and the public.
23 Q. Where does Idaho Power focus its efforts to
24 maintain and improve reliability?
25 A. Idaho Power makes significant efforts toward,
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Idaho Power Company
1 and investment in, improving and maintaining reliable
2 service to its customers . The Company recognizes that
3 providing safe, reliable service is among its highest
4 operational priorities for our customers . Idaho Power has
5 completed many projects in recent years to either maintain
6 or improve reliability.
7 At the generation level, Idaho Power must ensure it
8 has sufficient resources to fulfill its obligation to
9 reliably and safely serve customers, especially in light of
10 the unprecedented growth Idaho Power has experienced over
11 the past decade. In their testimonies, Company Witnesses
12 Mr. Eric Hackett and Mr. Ryan Adelman provide detailed
13 discussions of investments Idaho Power has made in new and
14 existing generation resources to ensure sufficient,
15 reliable generation capacity to serve customers .
16 With regard to the transmission and distribution
17 ("T&D") systems, Idaho Power has made significant
18 investments to maintain aging infrastructure, enhance
19 system safety, and ensure reliable service while
20 accommodating growth at the local level . These efforts
21 include, but are not limited to, distribution line
22 hardening, which involves strengthening infrastructure to
23 improve system resilience, reduce likelihood of equipment
24 failure, and enhance performance during severe weather or
25 wildfire conditions . Additional investments include the
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Idaho Power Company
I replacement of certain underground distribution cables,
2 vegetation management to reduce outage and wildfire risk,
3 and targeted improvements to portions of the transmission
4 system and substations . Company Witness Mr. Mitch Colburn
5 describes in greater detail the Company' s reliability-
6 related investments and activities in his testimony.
7 Q. What is the Company' s overall approach to
8 providing a positive customer experience?
9 A. Idaho Power strives to be regarded as an
10 exceptional utility by the customers it serves . To
11 accomplish this, the Company must provide superior and
12 satisfying customer service and experiences that meet or
13 exceed its customers' needs and expectations .
14 The Company continually focuses on ways to cost-
15 effectively improve its relationships with customers by
16 assessing customer perception of the Company, identifying
17 performance and experience gaps based on customer feedback,
18 and reviewing industry best practices and trends .
19 Idaho Power' s J. D. Power Customer Satisfaction
20 results for residential and business customers remain
21 strong. The Company is currently ranked 3rd out of 14 within
22 the West Large electric utility segment for overall
23 residential customer satisfaction, and ranks 9th out of 94
24 investor-owned utilities in overall residential customer
25 satisfaction. The efforts focused on improving
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Idaho Power Company
1 communication to customers regarding wildfire mitigation,
2 outages, and safety has helped solidify these strong
3 results . Idaho Power ranked lst out of 12 within the West
4 Large electric utility segment for overall business
5 customer satisfaction; an example of how the focus on
6 proactive outreach and building customer relationships has
7 helped improve the overall customer experience.
8 The Direct Testimony of Company Witness Mr. Adam
9 Richins describes more fully the Company' s efforts to
10 support our safety culture and enhance customers'
11 experiences with our Company.
12 Q. What steps has the Company taken to help keep
13 its prices affordable for its customers?
14 A. First and foremost, Idaho Power works hard to
15 ensure its necessary investments to maintain and operate
16 the electric system safely and reliably for customers are
17 least cost and least risk. We also apply a disciplined and
18 thoughtful approach to managing our ongoing O&M expense .
19 These are the most impactful ways Idaho Power can keep its
20 rates affordable.
21 Idaho Power, with support from the Commission, has a
22 long history of applying a "growth pays for growth" policy
23 to guide its cost assignment practices . For example, all
24 customers must pay upfront for distribution-related costs
25 incurred to serve new or incremental loads, with
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Idaho Power Company
1 residential, commercial and irrigation customers receiving
2 a modest allowance to offset a portion of such costs .
3 Larger load customers do not receive any allowance for
4 distribution upgrade costs downstream from the substation.
5 In addition, the Company' s tariff requires any load
6 greater than 20 megawatts ("MW") to enter into a special
7 contract with cost-based pricing that must be approved by
8 the Commission. The terms of the contracts are negotiated
9 by the Company to prevent any inappropriate cost shifting
10 to other customers . These are just a few examples of the
11 "growth pays for growth" policies that help keep our rates
12 lower for customers .
13 Q. What assistance is available to customers to
14 help them manage their electric bills?
15 A. There are a number of options available to
16 customers who need assistance in managing their energy
17 costs . Project Share is a year-round bill pay assistance
18 program started by Idaho Power in 1982 and administered by
19 the Salvation Army. Funding is provided by Idaho Power' s
20 customers and shareholders, other utilities, and private
21 donations, with 100 percent of Idaho Power customers'
22 donations going to Project Share recipients . Idaho Power
23 shareowners also contribute an additional amount equal to
24 10 percent of monthly customer donations to support the
25 Salvation Army' s program administration costs . In addition,
GROW, DI 10
Idaho Power Company
1 shareowners make an annual Project Share donation of
2 approximately $25, 000 to directly fund customer bill
3 assistance.
4 There are also several energy efficiency programs
5 designed for low-income qualified customers -
6 Weatherization Assistance for Qualified Customers ("WAQC") ,
7 Weatherization Solutions for Eligible Customers
8 ("Solutions") , and Easy Savings, a low-income energy
9 efficiency educational program.
10 II . IDAHO POWER' S BUSINESS MANAGEMENT OVERVIEW
11 Q. When was Idaho Power' s last GRC in Idaho?
12 A. Idaho Power' s last full Idaho GRC, Case No .
13 IPC-E-23-11, was filed on June 1, 2023, with rates becoming
14 effective January 1, 2024 . On May 31, 2024, the Company
15 filed a Limited Scope Rate Case, Case No. IPC-E-24-07,
16 involving 2024 rate base additions and incremental labor
17 costs, which the Commission processed as a GRC with new
18 rates becoming effective January 1, 2025 .
19 Q. Considering the relatively recent base rate
20 increase, why do you believe this requested increase is
21 necessary?
22 A. This increase is important for Idaho Power to
23 achieve fair and timely recovery of its prudently incurred
24 expenses and a reasonable return on the Company' s
25 investment in its electrical system, which today' s rates
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Idaho Power Company
1 will not provide. The rate changes effective January 1,
2 2025, provided for an approximately $50 million increase in
3 Idaho jurisdictional annual revenue. Despite that increase,
4 the Company still expects to accelerate amortization of up
5 to $77 million of its remaining ADITC under the associated
6 revenue sharing and earnings support mechanism in 2025 .
7 Even with the January 1, 2025, rate increase and added
8 earnings (but not cash) support from ADITC, the Company
9 expects to earn below its authorized rate of return in
10 2025 . The relatively large amount of ADITC the Company
11 expects to use under the mechanism in 2025 is reflective of
12 substantially underearning below the Idaho ROE floor level
13 specified in the mechanism. If left unaddressed, these
14 financial challenges will substantially and unsustainably
15 worsen in 2026 .
16 Q. What efforts does Idaho Power undertake to
17 mitigate the need for a general rate increase?
18 A. Idaho Power employs a robust capital and 0&M
19 budgeting process . The capital budget process begins with
20 maintenance personnel, planners, and others within the
21 business identifying needs and submitting projects to
22 business unit management. Business unit management reviews
23 submitted projects and prioritizes them based on spending
24 guidelines provided by senior management.
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Idaho Power Company
1 0&M budgets are established based on extensive
2 discussions between the business units and senior
3 management and represent a combination of prior year
4 experience plus or minus identified changes and
5 adjustments . As the Company prepared its 0&M budgets for
6 2025, the target was based on holding to a 2024 budget
7 adjusted for known items, with only identified unavoidable
8 increases allowed as an adjustment.
9 Throughout the year, senior management reviews the
10 status of spending for both 0&M and capital against updated
11 estimates as well as original budget. Variances are
12 reviewed and analyzed in order to determine changes that
13 may need to be made during the year to manage to budgeted
14 levels of spend.
15 Q. What is Idaho Power' s general compensation
16 philosophy?
17 A. As described more fully by Company Witness Ms .
18 Sarah Griffin in her testimony, Idaho Power' s compensation
19 philosophy is to provide a balanced, competitive, and
20 sustainable total compensation or "total rewards" package,
21 ensuring it attracts and retains high quality employees and
22 motivates them to achieve performance goals that benefit
23 customers and shareholders . Maintaining a competitive total
24 rewards package allows the Company to recruit and retain
25 its highly skilled workforce. The competitiveness of Idaho
GROW, DI 13
Idaho Power Company
1 Power' s total rewards package also supports the Company' s
2 intent to maintain a flexible workforce that can easily
3 adjust work duties and assignments to meet changing demands
4 and operational needs, which in turn keep the Company' s
5 costs of service lower.
6 Q. Do you believe these cost increase mitigation
7 efforts have been successful?
8 A. Yes, despite ongoing inflationary pressures,
9 the Company has been successful in managing controllable
10 costs . Excluding necessary wildfire mitigation and
11 insurance cost expenditures, the Company has successfully
12 managed its O&M expenses . As can be seen on Figure 1,
13 during the twelve-year period of 2012-2024, the Company' s
14 annual O&M, excluding power supply expenses, demand-side
15 management, and 2022-2024 wildfire-related costs, grew by
16 a compound annual growth rate of just 1 . 5 percent .
17
GROW, DI 14
Idaho Power Company
1 FIGURE 1
2 Annual 0&M Growth 2012-2024
3 Excludes purchase power, fuel expense, power cost
4 adjustment, and demand-side management.
�IDIIICORP
2012-2024 Operations& Maintenance Expenses ($ Millions)
$500
$425 .
$350
$275
$200
$125
$50
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
*WMP Expenses Net of Deferral
5
6 III . CASE OVERVIEW AND DRIVERS
7 Q. What is Idaho Power' s requested revenue
8 increase in this case?
9 A. As discussed further in the Direct Testimonies
10 of Company Witnesses Mr. Timothy Tatum and Ms . Kelley Noe,
11 the Company is requesting rate relief of approximately
12 $199 . 1 million, which is net of a corresponding proposed
13 PCA decrease of $46 . 8 million. If approved, this request
14 would result in an overall increase to adjusted base
15 revenue of 13 . 09 percent effective January 1, 2026 .
16 Q. What is the Company' s proposed cost of
17 capital?
GROW, DI 15
Idaho Power Company
1 A. The Company' s request is based on a proposed
2 rate of return of 7 . 818 percent, with a capital structure
3 comprised of 51 percent equity and 49 percent debt, a 5 . 132
4 percent cost of debt, and a 10 . 4 percent ROE. Company
5 Witnesses Dr. John Thompson and Mr. Brian Buckham provide
6 support for this recommendation in their respective
7 testimonies .
8 Q. What are the current challenges facing the
9 Company driving the need for the requested rate relief in
10 this case?
11 A. Historically high load growth at a time of
12 rising costs and constrained system capacity is currently
13 posing significant challenges for Idaho Power. Despite
14 considerable investment and expansion in recent years, the
15 Company' s system today is fully utilized by our current
16 customers and the Company continues to experience sustained
17 customer growth. To provide safe, reliable service to all
18 customers, the Company must continue to make major
19 investments in both new and existing infrastructure .
20 Supply chain constraints and worldwide demand for the
21 materials and services required to build needed
22 infrastructure have placed upward pressure on cost. More
23 recently, tariffs (and even the prospects of tariffs) on
24 foreign goods have also driven up prices dramatically.
25 Q. Can you cite examples that show how inflation
GROW, DI 16
Idaho Power Company
1 has impacted the procurement of supplies?
2 A. A combination of supply and demand factors
3 have resulted in persistent high inflation since early
4 2020 . Idaho Power is continuing to see escalated pricing
5 across most commodities . Since 2020, core steel is up 103
6 percent, aluminum pricing is up 50 percent, and high-grade
7 copper has increased 81 percent . These increases translate
8 directly into price escalations for key pieces of
9 equipment needed to reliably serve our customers . Over the
10 same period, the average cost of distribution transformers
11 has increased by 110 percent, wood poles by 58 percent,
12 and electrical cable by 105 percent .
13 Other factors driving procurement pricing increases
14 are the cost of labor and the cost of freight . In
15 addition, manufacturers in our industry have not been able
16 to meet demand, causing higher prices among new and
17 existing suppliers .
18 Q. Can you cite examples of how supply chain
19 disruptions have been a challenge?
20 A. Supply chain disruptions have settled;
21 however, increased market demand has affected business
22 operations, creating an environment of scarcity where
23 manufacturers are unable to meet demand in a timely manner.
24 More recently, lead times have stabilized but are still
25 longer than they were prior to the market disruptions that
GROW, DI 17
Idaho Power Company
1 began in 2020 . For example, lead times for distribution
2 transformers have doubled since 2020 — from 22 weeks to 44
3 weeks — but are down from 65 weeks just one year ago. Power
4 transformer lead times have increased fourfold, from 1 year
5 to 4 years, and have not come down. Meter packages have
6 also increased fourfold, from 12 weeks to 48 weeks, but
7 have come down from the 72-week high after manufacturers
8 added capacity. Lead times for 230kV breakers have grown
9 from 20 weeks to 227 weeks with no relief in sight.
10 These challenges are expected to continue for the
11 next several years . They have caused delays in project
12 execution, increased costs, and imposed additional workload
13 as the Company works to find other vendors that can provide
14 timely support. All of these factors have combined to cause
15 the Company to increase its inventory to levels necessary
16 to support its obligation to serve, which comes at an
17 escalating cost.
18 Q. Are the supply chain disruptions unique to
19 Idaho Power?
20 A. No . Cost increases and longer lead times are
21 an industrywide issue . In March 2025, an Idaho Power
22 supplier delivered a Utility Market presentation to the
23 Company, highlighting cost increases in aluminum, steel,
24 and transportation. In addition, the report noted that
25 utilities could see added disruption from the change and
GROW, DI 18
Idaho Power Company
1 implementation of tariffs . These recent changes to tariffs
2 are creating added challenges in the industry as companies
3 are looking toward domestic suppliers to meet business
4 needs and control costs . This is creating higher demand and
5 adding to the capacity constraints that are already a
6 challenge. We anticipate this could also contribute to
7 further cost increases domestically and impact lead times,
8 exacerbating the challenges of obtaining needed materials
9 to meet business needs .
10 We have already been approached with proposed price
11 increases ranging from 4 to 40 percent directly attributed
12 to tariffs . We are continuing to challenge these increases
13 and negotiate with suppliers to mitigate the impacts on
14 customers and the Company.
15 Q. What is Idaho Power doing to actively manage
16 supply chain disruptions?
17 A. Idaho Power monitors inventory closely,
18 tracking more than 127, 000 items and 33, 000 unique catalog
19 identifiers . The Company works with suppliers and vendors
20 to ensure they are taking the proper actions, such as
21 continuously looking for new suppliers, lengthening our
22 planning horizon to identify demand, providing alternative
23 and substitute products, managing lead times, and investing
24 in forward-looking buys .
25 Q. What other cost pressures is the Company
GROW, DI 19
Idaho Power Company
1 facing?
2 A. The Company also continues to grow and enhance
3 its wildfire mitigation efforts at an increasing cost.
4 Vegetation management represents the largest single cost
5 category in Idaho Power' s wildfire mitigation activities
6 and those costs continue to rise as demand exceeds supply
7 for those important services . The Company has also added
8 staff, analytical tools and targeted system hardening
9 investments as part of its implementation of a
10 comprehensive wildfire mitigation plan. At the same time,
11 Idaho Power continues to experience increases in its
12 insurance costs driven by wildfire and other weather-
13 related events across the country. Since the 2023 GRC, when
14 wildfire mitigation and insurance costs were last
15 addressed, the Company has experienced an increase in the
16 annual cost of those cost categories of approximately $14 . 9
17 million. The Commission has authorized Idaho Power to defer
18 the incremental cost of certain wildfire mitigation and
19 insurance costs since the 2023 GRC, and this current rate
20 request reflects 2025 wildfire mitigation and insurance
21 costs, as well as amortization of amounts deferred through
22 2025 .
23 Q. Has Idaho Power been able to maintain
24 investment grade credit ratings?
25 A. Yes . However, Idaho Power' s credit ratings, as
GROW, DI 20
Idaho Power Company
1 measured by the national credit rating agencies, remains at
2 the lower end of investment grade. The rate relief and
3 Depreciation and Interest Expense tracker requested in this
4 case are critically important in preventing the Company' s
5 credit ratings from falling below investment grade . Rates
6 in effect today will not provide the Company with a
7 sufficient opportunity to generate adequate operating cash
8 flow or earn the rate of return necessary to assure access
9 to the capital markets to finance needed investments in
10 2026 and beyond. Any delay in or lack of recovery of
11 prudent operating or financing costs is seen as risk by the
12 financial community, including the credit rating agencies,
13 during this period of high capital investment. These
14 pressures combine to present a formidable challenge to
15 sustaining the financial health, operational excellence,
16 and, ultimately, the independence of the Company.
17 Q. You mentioned growth in investment over the
18 past few years . What is driving the growth in investment?
19 A. Investment growth has been driven by a
20 combination of factors including meeting growing customer
21 demands, maintaining an aging infrastructure, and required
22 compliance and security investments .
23 The Company must be financially prepared to serve
24 that growth as it occurs . To provide safe, reliable service
25 to all customers, the Company must make investments in both
GROW, DI 21
Idaho Power Company
1 new and existing infrastructure. The Company is adding
2 capacity to its generation fleet, transmission system, and
3 distribution facilities to ensure an adequate supply of
4 electricity to customers, to provide service to new
5 customers, and to maintain system reliability.
6 Idaho Power' s aging T&D infrastructure requires
7 continued investment in upgrades and replacement to
8 maintain its operational viability. The Company' s aging
9 hydroelectric and thermal generation facilities also
10 require continuing investment in upgrades and component
11 replacement. In addition, environmental mandates require
12 the replacement or retrofitting of aging equipment with
13 technology that is often more expensive. Further, the
14 Company is operating in an environment of ever-increasing
15 reliability, security and compliance standards that also
16 require increased levels of investment.
17 The Company plans to invest approximately $1 billion
18 in new infrastructure during 2025 with associated
19 incremental Depreciation and Interest Expense of
20 approximately $52 . 5 million over 2024 levels . The 2025
21 incremental Depreciation and Interest Expense alone will
22 exceed the total amount of the rate increase granted by the
23 Commission in the Company' s 2024 Limited Scope Rate Case
24 that became effective January 1, 2025, which was based on a
25 2024 historical test year.
GROW, DI 22
Idaho Power Company
1 IV. REGULATORY LAG
2 Q. Please define your use of the term regulatory
3 lag.
4 A. I define regulatory lag as the difference
5 between the time when costs or benefits are realized by a
6 utility and the time when rates are implemented to reflect
7 those cost or benefits . The impact of regulatory lag is
8 dependent upon the situation and can either be financially
9 beneficial or harmful to a utility. For the foreseeable
10 future, the negative effects of regulatory lag will be
11 particularly pronounced for Idaho Power because the Company
12 is currently experiencing an unprecedented level of load
13 growth, a business environment with heavy inflationary
14 impacts, increased wildfire risk mitigation investment, and
15 a once in a generation level of capital spend necessary to
16 provide safe, reliable service to its customers .
17 Q. What is the current projection of system sales
18 growth over the same time period of 2024 to 2028?
19 A. As can be seen on Figure 2, Idaho Power
20 expects to experience an annual system sales growth
21 increase of approximately 9 percent per year or 29 percent
22 overall between 2025 and 2028 . Adding plant and equipment
23 to serve these higher demands on the system combined with
GROW, DI 23
Idaho Power Company
1 ongoing replacement of aging infrastructure are driving
2 this generational level of capital spend.
3 FIGURE 2
4 Annual Sales Growth 2024-2028
11 WICORP
Sales Growth
Aver 29°�B�awrth i sales forecasted to 202 20,969
15,971
i
10,000
5,000
2024 2025 2026 2027 2026
5
6 Q. How will these higher demands on the system
7 combined with ongoing replacement of aging infrastructure
8 impact rate base growth over the same period?
9 A. As can be seen on Figure 3, during the five-
10 year period of 2024 to 2028, the Company currently expects
11 to experience rate base growth at a compound average rate
12 of 19 . 3 percent annually totaling approximately $4 . 5
13 billion dollars of incremental rate base over what is
14 currently reflected in rates . That means that Idaho Power
15 expects to double its rate base over the next four years .
16 This represents a once in a several generations level of
GROW, DI 24
Idaho Power Company
1 investment growth for Idaho Power. The Company has not
2 experienced such high growth in investment since the
3 construction of the Hells Canyon Complex over 60 years ago.
4 The Company cannot absorb the depreciation and financing
5 expense associated with the incremental plant investment
6 without the rate relief and support mechanisms requested in
7 this case, and likely subsequent rate adjustments going
8 into the future.
9 FIGURE 3
10 Idaho Power Annual Rate Base Growth 2024-2028
�ioaco�
Total System Rate Base Growth Forecast
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2024 2m 2= 2=7 70¢!
11
12 Q. How does this level of rate base growth
13 compare to other similarly sized electric utilities in the
14 country?
15 A. Based on interactions with my peers at
16 industry events as well as commentary from industry
17 analysts, I am not aware of any similarly sized electric
GROW, DI 25
Idaho Power Company
1 utility in the country that is experiencing the level of
2 investment growth that Idaho Power is currently undertaking
3 to safely and reliably serve growing customer demands .
4 Q. What is the significance of this projected
5 growth in rate base as it relates to regulatory lag?
6 A. As recently as the Company' s 2024 Limited
7 Scope Rate Case, the Commission has indicated a preference
8 for a historical test year with rate base calculated under
9 a historical averaging approach. This method of determining
10 rates based on a historical average of plant balances
11 results in the rates effective in one period being
12 reflective of costs that existed in a prior period. When
13 costs are increasing annually as significantly as they are
14 today, even with annual general rate cases, rates derived
15 under a historical average rate base method will inevitably
16 be inadequate to cover the costs that will exist in the
17 rate effective period. For example, the incremental
18 Depreciation and Interest Expense associated with the rate
19 base growth between 2024 and 2028 will range between $52 . 5
20 million to $93 . 5 million annually. Even with the filing of
21 annual rate cases under the use of a historical test year
22 method, these incremental costs would be borne by Idaho
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Idaho Power Company
1 Power for at least a year, making it unlikely, if not
2 impossible, to earn a reasonable return on investment .
3 Q. What is Idaho Power' s preferred method of
4 addressing this issue of regulatory lag?
5 A. As described by Mr. Tatum in his testimony,
6 utility commissions and policy makers throughout the
7 country are increasingly recognizing that in times of high
8 inflation and heavy construction, future or forecast test
9 years are necessary to allow utilities a reasonable
10 opportunity to earn their authorized rate of return. Idaho
11 Power believes that the use of a forecast test year for
12 setting rates in a GRC is the most straightforward and
13 effective method of addressing the regulatory lag Idaho
14 Power is currently experiencing and is expecting to
15 experience over the coming years .
16 Q. Is the Company proposing the use of a forecast
17 test year in this case?
18 A. No. In the Final Order in the Company' s 2024
19 Limited Scope Rate Case, Order No. 36438, the Commission
20 stated the following regarding its willingness to accept
21 forecast information:
22 With respect to the test year, while the Commission
23 does not adopt the August 31, 2024, cut-off
24 deadline recommended by Staff in this specific case
25 and based upon these specific circumstances, this
26 is not an invitation for public utilities to
27 present extensive forecasted data in future
28 proceedings, nor is it an indication of the
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Idaho Power Company
1 Commission' s willingness to accept forecasted data
2 in future proceedings . The Commission expects that
3 when any public utility appears before the
4 Commission in a recovery proceeding, that public
5 utility will present known and measurable data, for
6 used and useful projects, with sufficient time for
7 all parties to review that data and formulate any
8 necessary testimony.
9 The Company has interpreted this statement to
10 indicate the Commission opposes a forecast test year and
11 accordingly, it has prepared a historical test year with
12 known and measurable adjustments to comply with that
13 understanding.
14 Q. Do you believe the rate relief requested in
15 this case based on a historical test year will provide the
16 Company with a reasonable opportunity to earn a fair rate
17 of return on its investment to safely and reliably serve
18 its customers?
19 A. No, I do not . As mentioned earlier in my
20 testimony, the Depreciation and Interest Expense associated
21 with Idaho Power' s required capital investments in the
22 coming year alone, will likely render the rates requested
23 in this case ineffective in providing the Company a
24 reasonable opportunity to earn an allowed rate of return.
25 Q. Does the Company have a proposal in this case
26 to address regulatory lag as an alternative to a forecast
27 test year?
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Idaho Power Company
1 A. Yes . In the same Order No . 36438, the
2 Commission stated the following:
3 As always, the Commission is open to considering
4 requests for additional riders, or other cost
5 recovery mechanisms as may be appropriate; however,
6 in this case year- end rate base treatment is not
7 an appropriate remedy for the Company' s concerns .
8 In light of the Commission' s openness to considering
9 additional riders or other cost recovery mechanisms, the
10 Company has developed a proposed tracking mechanism for
11 Depreciation and Interest Expense that, if approved, would
12 help provide timely cost recovery of those expense
13 categories between rate cases . Specifically, the Company
14 proposes to implement effective January 1, 2026, a
15 Depreciation and Interest Expense tracking mechanism that
16 would measure differences between those expense categories
17 included in the rates approved in a GRC against the
18 associated actual expenses on an annual basis . The
19 mechanism would have a forecast and a true-up component and
20 would provide for an annual rate adjustment request to be
21 filed in the first quarter of each year and a rate
22 adjustment each June 1 . Mr. Tatum describes this proposed
23 mechanism in greater detail in his testimony.
24 Q. Has the Commission recently adopted any
25 mechanisms to track revenues or costs between rate cases?
26 A. Yes . On March 11, 2025, the Commission issued
27 Order No. 36502, in Case No. IPC-E-24-38, approving a
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Idaho Power Company
I tracking mechanism to track differences between actual
2 wheeling revenue compared to the level of wheeling revenue
3 reflected in customer rates, effective April 1, 2024 .
4 Q. Has this mechanism resulted in rate reduction
5 benefits for customers?
6 A. Yes . Under the recently approved wheeling
7 revenue tracking mechanism, the wheeling revenue deferral
8 for the 2025 Power Cost Adjustment ("PCA") year is a credit
9 to customers of approximately $3 . 9 million. This credit
10 amount is currently under review by the Commission in Case
11 No . IPC-E-25-20 and if approved will be reflected in rates
12 effective June 1, 2025 .
13 Q. Has the Commission approved other mechanisms
14 to address regulatory lag that share costs and benefits
15 associated with regulatory lag between the Company and its
16 customers?
17 A. Yes . Idaho Power has in place several rate
18 mechanisms that symmetrically pass along to customers costs
19 and benefits of regulatory lag. First and foremost, Idaho
20 Power has a revenue sharing mechanism that has been in
21 place for over a decade.
22 Since 2009, the Company has been subject to an
23 ADITC/Revenue Sharing Mechanism that includes provisions
24 for the accelerated amortization of ADITC to help achieve a
25 minimum specified percent Idaho-jurisdiction return on
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Idaho Power Company
1 year-end equity ("Idaho ROE") , currently set at 9 . 12
2 percent . The mechanism also provides for the potential
3 sharing between Idaho Power and Idaho customers of Idaho-
4 jurisdictional earnings in excess of a 9 . 60 percent Idaho
5 ROE . Since its inception, this mechanism has resulted in
6 earnings sharing or the sharing of beneficial regulatory
7 lag with Idaho Power' s Idaho customer of approximately $126
8 million.
9 Secondly, Idaho Power' s PCA and Fixed Cost
10 Adjustment ("FCA") also pass along certain elements of
11 beneficial regulatory lag between rate cases . The PCA is a
12 symmetrical power supply expense mechanism that passes
13 through to customers annual differences between actual net
14 power supply expense ("NPSE") and the normalized level of
15 NPSE included in base rates . To the extent that actual NPSE
16 is lower than the NPSE included in base rates, customers
17 receive that benefit through the PCA, and if actual NPSE
18 are higher than the base level customers receive a charge .
19 Further, the FCA is a symmetrical mechanism that tracks
20 annual changes in residential and small general service
21 energy usage per customer and either credits or charges
22 customers if the Company over or under collects its allowed
23 fixed cost per customer as established in a GRC.
24 Q. Is Idaho Power requesting any other support
25 mechanisms to help address the impacts of regulatory lag?
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Idaho Power Company
1 A Yes . The Company is requesting continued
2 support from two existing mechanisms . First, the Company
3 requests the Commission provide continued authorization for
4 deferral of incremental wildfire mitigation and insurance
5 costs, as measured from the base level of recovery of those
6 costs categories established in this case, until such a
7 time that these costs stabilize.
8 Second, the Company requests the Commission allow
9 the Company to add additional ADITC to the ADITC/Revenue
10 Sharing Mechanism equal to the total of existing ADITC not
11 currently eligible for accelerated amortization under the
12 mechanism and all available ITC generated through calendar-
13 year 2028 . Mr. Tatum describes these proposals in greater
14 detail in his testimony.
15 The Company believes that the continuation of these
16 two regulatory mechanisms, the proposed Depreciation and
17 Interest Expense tracker, along with the general rate
18 relief requested in this case strike an effective balance
19 between affordability for customers and maintaining the
20 financial health of Idaho Power.
21 Q. Please explain.
22 A. With regard to affordability, the use of a
23 historical test year in this case results in a lower
24 overall revenue requirement than what would exist under a
25 forecast test year. The implementation of a Depreciation
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Idaho Power Company
1 and Interest Expense tracking mechanism will result in
2 customers paying for those incremental costs closer to the
3 time they are incurred thereby reducing future rate
4 increases in future GRCs . The continuation of the wildfire
5 mitigation and insurance cost deferral will allow customers
6 to postpone paying for those necessary current costs and
7 instead pay over an extended amortization period. Lastly,
8 the earnings shortfall associated with the use of a
9 historical test year will be made up in part by accelerated
10 ADITC amortization instead of revenue from customer rates .
11 The requested rate relief and each of the proposed
12 measures will also provide Idaho Power an opportunity to
13 timely recover its prudently incurred cost to serve its
14 customers and earn a fair rate of return for its owners .
15 The rate relief requested in this case and the proposed
16 tracking mechanism will help support credit metrics in the
17 near-term and the additional ADITC will provide an earnings
18 support "bridge" (a non-cash benefit) until a future GRC.
19 V. CONCLUSION
20 Q. Can you summarize the Company' s requested rate
21 increase and explain why it is important not only to Idaho
22 Power but in the best interest of customers?
23 A. This general rate request reflects a retail
24 revenue increase of approximately $199 . 1 million, or 13 . 09
25 percent, effective January 1, 2026, which is net of a $46 . 8
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Idaho Power Company
1 million PCA decrease and includes a requested ROE of 10 . 4
2 percent . This increase is important for Idaho Power to
3 achieve fair and timely recovery of its prudently incurred
4 expenses and a reasonable return on the Company' s
5 investment in its electrical system, which today' s rates
6 will not provide. Continued growth in demand for
7 electricity, aging infrastructure, and higher compliance
8 and reliability requirements are driving the need to invest
9 large amounts of capital to expand and improve electricity
10 supply, delivery, and reliability.
11 The application of a historical test year in the
12 current rising cost environment has resulted in
13 unsustainable regulatory lag, impacting the Company' s
14 ability to achieve reasonable rates of return and maintain
15 sufficient credit metrics between rate cases . As a result,
16 Idaho Power also requests approval of a Depreciation and
17 Interest Expense tracking mechanism and other earnings
18 support measures to help address some of the harmful
19 regulatory lag caused by using a historical test year.
20 Timely and fair recovery of the Company' s prudently
21 incurred expenses and investments is critically important
22 to helping it attract capital investment and manage
23 financing costs . A low cost of capital ultimately has a
24 beneficial impact on customers' rates . By providing for
25 fair and timely recovery of the Company' s expenses it
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Idaho Power Company
1 incurs on behalf of customers and investments in the
2 systems and activities that serve its customers, this rate
3 increase is in the best interests of the Company, its
4 shareholders, and the people and communities it serves .
5 Q. Does this conclude your direct testimony in
6 this case?
7 A. Yes, it does .
8
9
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Idaho Power Company
1 DECLARATION OF LISA A. GROW
2 I, Lisa A. Grow, declare under penalty of perjury
3 under the laws of the state of Idaho:
4 1 . My name is Lisa A. Grow. I am employed by
5 Idaho Power Company as the President and Chief Executive
6 Officer.
7 2 . To the best of my knowledge, my pre-filed
8 direct testimony is true and accurate.
9 I hereby declare that the above statement is true to
10 the best of my knowledge and belief, and that I understand
11 it is made for use as evidence before the Idaho Public
12 Utilities Commission and is subject to penalty for perjury.
13 SIGNED this 30th day of May 2025, at Boise, Idaho.
14
15 Signed:
16
17 Lisa A. Grow
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Idaho Power Company