20250530Direct Richins - 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
ADAM RICHINS

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 Adam Richins . My business address
5 is 1221 West Idaho Street, Boise, Idaho 83702 . I am
6 employed by Idaho Power as Senior Vice President and Chief
7 Operating Officer.
8 Q. Please describe your educational background.
9 A. I graduated from the University of Puget Sound
10 with a Bachelor of Science degree in Mathematics and from
11 Columbia University with a Bachelor of Science degree in
12 Civil Engineering, Magna Cum Laude. Thereafter, I earned my
13 law degree from the University of Washington with high
14 honors . In 2016, I graduated from Harvard Business School' s
15 Advanced Management Program.
16 Q. Please describe your work experience with
17 Idaho Power.
18 A. From 2010 to 2013 I was employed by Idaho
19 Power as Senior Counsel in the Legal Department. After that
20 role, I served as General Manager of Customer Operations
21 Engineering and Construction. In 2017, I was promoted to
22 Vice President of Customer Operations and Business
23 Development . In this role, I oversaw teams dedicated to
24 customer operations, customer satisfaction, and supporting
25 the Company' s brand. I was promoted to my current position,
RICHINS, DI 1
Idaho Power Company

1 Senior Vice President and Chief Operating Officer of Idaho
2 Power, in 2019 where I have responsibility over operations
3 departments that include Idaho Power' s generation,
4 transmission, and distribution resources; customer
5 operations; planning, engineering, and construction;
6 business innovation; information systems; safety;
7 environmental; and training.
8 Q. What is the purpose of your testimony in this
9 matter?
10 A. The purpose of my testimony is to, first,
11 provide an overview of Idaho Power' s recent reliability
12 performance, supporting the Company' s 2025 investments .
13 Next, I describe Idaho Power' s "Safety First" culture and
14 outline our ongoing efforts to enhance the customers'
15 overall experience with Idaho Power. Lastly, I discuss the
16 Company' s advancements in energy efficiency as well as
17 customer relations activities and related technology
18 upgrades .
19 Q. How is your testimony organized?
20 A. My testimony will begin with a discussion of
21 Idaho Power' s recent history of reliability and performance
22 that demonstrates a thoughtful approach to grid
23 construction and maintenance. I provide an overview of the
24 nearly $1 billion in investments the Company will be making
25 to ensure the continued delivery of safe, reliable electric
RICHINS, DI 2
Idaho Power Company

1 service, detailing three specific general-plant related
2 investments . Next, I describe how Idaho Power promotes a
3 culture of safety with its customers and the communities it
4 services . Finally, I provide a high-level overview of
5 various initiatives the Company has and continues to
6 undertake to provide an exceptional customer experience and
7 enhance customer choices and service.
8 Q. What exhibits are you sponsoring?
9 A. I am sponsoring Exhibit No . 2 .
10 I . RELIABILITY AND PERFORMANCE
11 Q. How is reliability typically measured on the
12 Company' s system?
13 A. Idaho Power primarily uses four indices to
14 measure reliability of the system: (1) System Average
15 Interruption Frequency Index ("SAIFI") , (2) System Average
16 Interruption Duration Index ("SAIDI") , (3) Customers
17 Experiencing Multiple Interruptions ("CEMI") , and Momentary
18 Average Interruption Frequency Index ("MAIFI") . SAIFI,
19 SAIDI, and CEMI are indices that measure sustained outages .
20 A sustained outage is defined as an outage where customers
21 are without power for five minutes or longer. CEMI is
22 typically referred to as "CEMI-1" through "CEMI-6, " where
23 CEMI-1 indicates the percentage of customers who had one or
24 more outage, CEMI-2 indicates the percentage of customers
25 who had two or more outages, and so on. MAIFI is an index
RICHINS, DI 3
Idaho Power Company

1 that measures momentary interruptions . Momentary
2 interruptions are when customers are out of power for fewer
3 than five minutes .
4 Q. Based on these metrics, has Idaho Power
5 demonstrated prudent and reliable operation of the
6 electrical grid?
7 A. Yes . Idaho Power' s SAIFI metric has improved
8 substantially since 2007 . On a relative basis, a comparison
9 of the Company' s rolling five-year average SAIFI compared
10 to peer utilities demonstrates that Idaho Power generally
11 outperformed its peers in each year since 2017 . The Company
12 has also shown improvement in the MAIFI, SAIDI, and CEMI
13 metrics as demonstrated in Figures 1 through 4 below,
14 presenting the results for the 2007 through 2024 time
15 period.
16
RICHINS, DI 4
Idaho Power Company

1 FIGURE 1
2 SAIDI, 2007 THROUGH 2024
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Year
6
RICHINS, DI 5
Idaho Power Company

1 FIGURE 3
2 CEMI 3 AND CEMI 6, 2007 THROUGH 2O24
CEMI 3 and CEMI 6
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Year
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4 FIGURE 4
5 SAIFI, 2007 THROUGH 2O24
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Year
6
RICHINS, DI 6
Idaho Power Company

1 Q. Do these metrics indicate prudent construction
2 and maintenance of the Company' s distribution and
3 transmission systems?
4 A. Yes . Idaho Power' s reliability metrics reflect
5 a thoughtful approach to construction and maintenance of
6 its transmission and distribution systems . Since the
7 completion of the limited scope case in 2024 that included
8 incremental capital investments, Case No. IPE-E-24-07
9 ("2024 Limited Scope Rate Case") , the Company is expecting
10 to place in service nearly $1 billion in infrastructure by
11 year-end 2025 . As I will discuss in my testimony,
12 approximately $408 . 4 million of this total reflects prudent
13 investment in the transmission and distribution systems .
14 The corresponding improvement in the Company' s reliability
15 metrics indicates that these investments were prudent to
16 ensure the safe, reliable provision of electric service .
17 II . CAPITAL INVESTMENTS OVERVIEW
18 Q. What is driving Idaho Power' s expected
19 investment of nearly $1 billion in infrastructure in 2025?
20 A. As discussed in the Direct Testimony of both
21 Company Witnesses Ms . Lisa A. Grow and Mr. Timothy E.
22 Tatum, historically high load growth and aging
23 infrastructure at a time of rising costs, supply chain
24 constraints, permitting obstacles, and constrained system
25 capacity is currently posing significant challenges for the
RICHINS, DI 7
Idaho Power Company

1 Company. Despite considerable investment and expansion in
2 recent years, Idaho Power' s system today is fully utilized
3 by current customers and the Company continues to
4 experience sustained customer growth. The investment growth
5 has also been driven by the maintaining of an aging
6 infrastructure and required compliance and security
7 investments . As a result, Idaho Power' s request in this
8 case includes $941 . 5 million in infrastructure investments
9 including the addition of capacity to its generation fleet,
10 transmission system, and distribution facilities to ensure
11 an adequate supply of electricity to customers, to provide
12 service to new customers, and to maintain system
13 reliability.
14 Q. What portion of the $941 . 5 million in
15 infrastructure investments is associated with investments
16 in the Company' s generation fleet?
17 A. At the generation level, Idaho Power must
18 ensure it has sufficient resources to fulfill its
19 obligation to reliably and safely serve customers,
20 especially in light of the unprecedented growth Idaho Power
21 has experienced over the past decade. Nearly half of the
22 infrastructure investments anticipated to be complete in
23 2025, or $438 . 5 million, are associated with investments in
24 Idaho Power' s generation fleet, including the steam,
25 hydroelectric, other production, and battery storage
RICHINS, DI 8
Idaho Power Company

1 facilities . Company Witnesses Mr. Eric Hackett and Mr. Ryan
2 N. Adelman discuss these investments, providing a detailed
3 explanation of the drivers of the projects over $2 million
4 included in the 2025 test year in this case ("major
5 projects") .
6 Idaho Power' s aging hydroelectric and thermal
7 generation facilities have required continuing upgrades and
8 component replacement. In 2025, due to age and
9 deterioration, the units at the American Falls Power Plant
10 will undergo a turbine replacement and generator
11 refurbishment, with Unit 1 being completed in 2025, and the
12 penstock at the Clear Lake Power Plant will be replaced due
13 to corrosion. Also, the Oxbow Power Plant controls will be
14 modernized and parts from Unit 2 at Danskin Power Plant
15 will be refurbished and utilized as replacement components
16 on Unit 3 .
17 Environmental mandates require the replacement or
18 retrofitting of aging equipment with technology that is
19 often more expensive, demonstrated by the addition of the
20 coal combustion residual disposal site at the Jim Bridger
21 Power Plant discussed in Mr. Adelman' s testimony.
22 Additionally, the conversion of Unit 1 at the North Valmy
23 Power Plant is coincident with the Unit 1 generator rewind
24 and turbine major overhaul . Further, the Company is
25 operating in an environment of ever-increasing reliability
RICHINS, DI 9
Idaho Power Company

1 and compliance standards that also require increased levels
2 of investment as evidenced by the threat and vulnerability
3 assessment investments at the CJ Strike Power Plant and the
4 Oxbow Power Plant and the spillway remediation at the Bliss
5 Power Plant . Finally, the addition of the utility-scale
6 battery project is necessary to ensure sufficient, reliable
7 generation capacity to serve customers .
8 Q. What is driving the investment in the
9 transmission and distribution systems?
10 A. Idaho Power' s aging transmission and
11 distribution infrastructure requires continued investment
12 in upgrades and replacement to maintain their operational
13 viability while also accommodating growth at the local
14 level . Of the $941 . 5 million in infrastructure expected to
15 be placed in service since the 2024 Limited Scope Rate
16 Case, approximately $201 . 3 million is associated with
17 investment in the Company' s transmission system and
18 approximately $207 . 1 million reflects investment in Idaho
19 Power' s distribution system.
20 Company Witness Mr. Mitch Colburn provides detailed
21 discussions of these investments, including 12
22 transmission-related major projects, 11 of which are
23 required to address aging infrastructure and one of which
24 is growth-related, and 10 distribution-related major
25 projects, five of which are required to address aging
RICHINS, DI 10
Idaho Power Company

I infrastructure and five of which are growth-related. Mr.
2 Colburn will also discuss the Wood River Valley Reliability
3 Project ("WRV Project") , a combined distribution and
4 transmission project with a long, complex regulatory
5 history, for which the distribution portion of those
6 investments are proposed for recovery in this case; and
7 finally, an investment in Idaho Power' s mobile workforce
8 system to ensure its continued support of the Company' s
9 operations .
10 Q. What is the remaining portion of the $941 . 5
11 million in infrastructure investments expected to be
12 completed in 2025?
13 A. The remaining portion of the infrastructure
14 investments, $94 . 6 million, is associated with intangible
15 and general plant additions to be completed in 2025 . I will
16 discuss the major projects in my testimony which, too, are
17 the result of aging infrastructure or the replacement or
18 retrofitting of aging equipment with improved technology.
19 Q. Does the Company have a general procurement
20 policy for which it follows to ensure that investments
21 Idaho Power makes are procured in a least cost, least risk
22 manner?
23 A. Yes . The Company has a Procurement Policy and
24 Procurement Standard in place to provide guidance for
25 procurement activities, including competitive bidding
RICHINS, DI 11
Idaho Power Company

1 practices as well as for the purchase of many minor and
2 ancillary materials and services, and to help ensure that
3 procurement decisions are made based on the best overall
4 value to Idaho Power and its customers . In addition, many
5 goods are stock items in Idaho Power warehouses and are not
6 bid through a Request for Proposal on a project basis, but
7 rather as wholesale purchases .
8 III . INTANGIBLE AND GENERAL PLANT INVESTMENTS
9 Q. What are the major intangible and general
10 plant investments included in the Company' s request in this
11 case and expected to be complete in 2025?
12 A. There are three major projects, all general
13 plant investments, that are expected to be complete in
14 2025 : (1) a new operations center, (2) a new data center,
15 and (3) replacement of the airplane.
16 The Pocatello Operations Center
17 Q. Please describe the new operations center
18 anticipated to be completed in 2025 .
19 A. The largest of the investments I will be
20 discussing, the new Pocatello Operations Center, is a
21 replacement of the existing facility that was built in 1954
22 and was no longer adequately accommodating both employees
23 and customers . First, due to growth, the building lacked
24 space for the current workforce . In addition, the existing
25 operations center was no longer compliant with the
RICHINS, DI 12
Idaho Power Company

1 Americans with Disabilities Act ("ADA") and lacked
2 appropriate security for customer facing employees .
3 Finally, ongoing maintenance of the building was costly. As
4 a result, the Company evaluated potential solutions to
5 address the building needs .
6 Q. What alternatives were evaluated?
7 A. Idaho Power considered maintaining status quo
8 by making only the essential building repairs, but that
9 solution would not address ADA compliance, safety and
10 security concerns, or the need for additional space . This
11 alternative would be temporary and proved to be a costly
12 solution. The second alternative evaluated was a complete
13 remodel of the existing building, which also proved to be
14 costly and would not address existing deficiencies . Because
15 a remodel would use the same building footprint, it would
16 require keeping most walls because they were load bearing
17 walls, not providing the ability to open the building for
18 additional space. One component of ADA-compliance would
19 require the addition of an elevator to the building.
20 Further, the existing operations center did not have
21 adequate space for an elevator, therefore a building
22 addition would be required. To address the lack of space,
23 this existing warehouse would require significant upgrades,
24 and to bring the yard up to code, improvements were
25 necessary. Finally, to remodel the existing operations
RICHINS, DI 13
Idaho Power Company

I center, employees would need to be temporarily relocated,
2 adding costs to the project and creating disruption to both
3 employees and customers . The most cost-effective approach
4 that would ensure the operations center meets all business
5 needs was the construction of a new building.
6 Q. Where did the Company build the new Pocatello
7 Operations Center?
8 A. The new facility was built on the existing
9 property. Without disruption to employees or customers, the
10 existing operations center was utilized until construction
11 of the new facility was complete. With a lower cost on a
12 net present value basis when compared to a remodel of the
13 existing building, the new 19, 000 square foot building
14 provides two floors for employee working space, a basement
15 for storage, rooms for meeting with customers, the addition
16 of a security vestibule, and is fully ADA compliant.
17 Q. What is the total cost of the Pocatello
18 Operations Center included in Idaho Power' s request in this
19 case?
20 A. The Company' s request in this case includes
21 approximately $10 . 3 million associated with construction of
22 the new Pocatello Operations Center which was completed in
23 April 2025 .
24 The Data Center
25 Q. Why was a new data center necessary?
RICHINS, DI 14
Idaho Power Company

1 A. The new data center, the _ Data Center
2 ("Data Center") , replaces the existing data center
3 infrastructure and systems that support the critical
4 business functions of the Company' s Load Serving
5 Organization ("LSO") . I will first provide an overview
6 Idaho Power' s data center structures to better understand
7 the facilities . There are three teams that operate the
8 Company' s data centers with distinct reason for the
9 separation: (1) the corporate Information Technology group
10 manages the corporate environment data center; (2) the
11 OpsNet group, within the LSO, manages an operational data
12 center for grid supporting systems; and (3) the grid
13 solutions group, also within the LSO, manages the Energy
14 Management System ("EMS") data center. Each team manages
15 infrastructure in two different physical locations to
16 provide geographic redundancy. While the primary data
17 center is the same for all teams, the secondary data center
18 differs by team.
19 Q. What types of functions do the operational
20 data centers support?
21 A. These data centers support critical business
22 processes and projects such as the EMS, Integrated Volt/VAR
23 Control, Physical Security, and Cyber Security for
24 operational systems, servers, workstations, and other
25 assets, and applications that support the North American
RICHINS, DI 15
Idaho Power Company

1 Electric Reliability Corporation Critical Infrastructure
2 Protection ("CIP") compliance. The operational data centers
3 will also be supporting upcoming projects such as the
4 Outage Management System and the Distribution Management
5 System. Because of the applications they support, the data
6 centers and the associated communications equipment must be
7 exceptionally reliable .
8 Q. What was the primary driver that required
9 construction of a new data center?
10 A. Two of the existing secondary data centers
11 were limited not only in their ability to expand to
12 accommodate the equipment necessary to support additional
13 applications, but in their ability to meet industry
14 standard data center reliability tiers on an ongoing basis .
15 The reliability tiers are based on a data center' s downtime
16 per year, overall redundancy, power redundancy, generator
17 run time, distribution feeds, and cooling redundancy. Idaho
18 Power strives to balance system availability for critical
19 systems with the cost of providing redundancy. In addition,
20 the ancillary equipment necessary to support the data
21 centers, including the ability to power and cool equipment,
22 communications equipment with high bandwidth, and the
23 ability to utilize fiber optic cabling, was lacking in two
24 of the existing secondary data centers .
25 Q. How did the Company address those limitations
RICHINS, DI 16
Idaho Power Company

1 with the two secondary data centers?
2 A. Idaho Power first considered co-locating the
3 two secondary data centers as several of the functions on
4 the operational side are duplicated between each data
5 center and could potentially be merged without compromising
6 resiliency or security. Merging the functions inherently
7 reduces infrastructure and application costs, while also
8 reducing labor resource needs . Unfortunately, neither of
9 the locations sufficiently offered the resiliency, space,
10 and geographic needs required to accomplish the merger.
11 Q. Did the Company evaluate any additional
12 alternatives to address the secondary data center
13 deficiencies?
14 A. Yes . Idaho Power considered remodeling the two
15 secondary data centers but neither had the ability to
16 expand to adequately accommodate the necessary data center
17 and ancillary equipment, and retrofitting the buildings
18 would be costly. The remaining alternative was to find a
19 new building to house the data center. Because utility data
20 centers house infrastructure with high CIP classification,
21 they must meet requirements that differ from infrastructure
22 that is not subject to CIP standards or penalties may be
23 imposed. As such, Idaho Power keeps direct control over the
24 data center. Therefore, co-locating or renting a facility
25 was not feasible as extensive build outs to meet
RICHINS, DI 17
Idaho Power Company

I reliability and security standards would have been
2 required, resulting in a more costly alternative .
3 The construction of a new data center was also
4 analyzed. Idaho Power identified the existing _
5 as a more cost-effective location for
6 the data center when compared to purchasing land to
7 construct a building. In addition to being lower cost, the
8 Data Center addresses the deficiencies with the existing
9 secondary data centers, it provides increased operational
10 resiliency, and it allows the Company to maintain control
11 of the facility supporting CIP requirements, while also
12 remaining near the backup control center and critical
13 communication infrastructure. The new location will house
14 both the EMS and OpsNet secondary data centers, providing
15 for larger power and cooling equipment, fiber
16 communications, more rack space, and the necessary network
17 communications . The Data Center provides a resilient
18 secondary location for business-critical operational needs .
19 Q. What is the total cost of the Data Center
20 included in Idaho Power' s request in this case?
21 A. The Company' s request in this case includes
22 approximately $4 . 0 million associated with the new data
23 center which is anticipated to be completed in November
24 2025 .
RICHINS, DI 18
Idaho Power Company

1 The Airplane
2 Q. Why is the Company replacing the airplane?
3 A. Idaho Power' s current plane, a Cessna Citation
4 II ("Citation II") was built in 1992 and, with more than
5 6, 900 flight hours and 8, 600 landings, is at the end of its
6 life . Maintenance costs have been consistently increasing
7 and, with the last Citation II having been built in 1994,
8 parts for the plane are no longer being manufactured and
9 replacement parts are difficult to find. As a result, the
10 Company evaluated alternatives to continue to safely and
11 cost-effectively transport crews and leaders to conduct
12 necessary Company business . First, Idaho Power assessed
13 whether the continuance of the nearly 80-year aviation
14 program was necessary.
15 Q. What drives the need for Idaho Power' s
16 aviation program?
17 A. The biggest driver for the Company' s aviation
18 program is the lack of intrastate service in many parts of
19 Idaho Power' s service area. More than 75 percent of the
20 existing plane' s usage is transporting crewmembers to
21 various parts of eastern Oregon and Idaho to perform
22 maintenance on, or the replacement of, Company
23 infrastructure, as well as crews conducting environmental
24 studies necessary for the Hells Canyon Complex relicensing
25 efforts . The existing plane has been essential in Idaho
RICHINS, DI 19
Idaho Power Company

1 Power' s ability to expedite service and response time
2 across the Company' s rural service area. Further, the
3 ability to fly the Citation II in and out of the Hells
4 Canyon Complex has been critical to operation and
5 maintenance of the Brownlee, Oxbow, and Hells Canyon
6 hydroelectric facilities . In addition to shuttling
7 employees between locations, the plane occasionally picks
8 up parts and materials in emergency situations .
9 Q. Does the Company regularly use the Citation
10 II?
11 A. Yes . Over the past decade, the Citation II has
12 taken an average 261 flights annually. The average
13 passengers per year count dipped in 2021 and 2022 due to
14 COVID but in 2023 the plane' s usage returned to pre-COVID
15 levels . However, it was at this time Idaho Power also had
16 to cancel numerous flights due to lengthy repairs and
17 unexpected maintenance.
18 Q. You indicated maintenance costs have been
19 increasing. Why has maintenance of the Citation II become
20 more costly?
21 A. Absent the ability to purchase new parts for
22 the plane, which have longer lifespans, are more compatible
23 and have better warranties, the Company has been required
24 to purchase refurbished parts which were getting
25 increasingly more difficult, or even impossible, to find.
RICHINS, DI 20
Idaho Power Company

1 For example, in 2022, retreaded main landing gear tires had
2 to be used due to the 18-month long search to find new main
3 landing gear tires . Another example is the aileron, which
4 due to a design flaw in the Citation II, forms cracks and
5 must be replaced. The last time it occurred, a replacement
6 was ultimately found but the plane was out of service for
7 several weeks . Finally, the air cycle machine, which is
8 critical to providing cabin pressurization and temperature
9 control, has failed several times in flight. While a back-
10 up system exists in emergencies, the refurbished parts
11 being used to repair the machine have been repeatedly
12 failing.
13 Q. What alternatives to the aviation program did
14 Idaho Power consider?
15 A. As an alternative to the Company' s aviation
16 program, Idaho Power considered leasing or chartering a
17 plane and considered retirement of the plane and travel to
18 the rural areas via vehicle. Boise is a relatively small
19 market for chartered plane options; charter services do
20 exist, but availability is limited and requires advanced
21 planning which is not ideal for flights that are taken for
22 emergency repairs . While there are two light jets similar
23 to the Citation II that can be chartered, they are not
24 qualified and do not have the safety ratings necessary for
25 a carrier to charter to Hells Canyon. When compared to the
RICHINS, DI 21
Idaho Power Company

1 current annual cost of the Citation II, the annual cost of
2 chartering a plane is nearly 70 percent greater.
3 Leasing a plane proved infeasible as fewer companies
4 lease aircraft due to accounting rule changes that reduced
5 the financial benefit to the lessor and nearly all planes
6 available were large cabin business aircrafts . Accordingly,
7 leasing a plane was not a viable option .
8 Q. What were the analysis results of using
9 vehicles as an alternative?
10 A. To analyze driving instead of flying, Idaho
11 Power calculated what the estimated annual driving cost
12 would be based on historical passenger usage of the plane .
13 This analysis incorporated additional meal and hotel costs,
14 mileage reimbursements, commercial flights for out-of-state
15 trips, and the value of lost productivity due to additional
16 travel time. While driving was estimated to be
17 approximately 2 . 5 percent lower cost on a net present value
18 basis, the Company had concerns with discontinuing the
19 aviation program because of the safety and system
20 reliability concerns the driving alternative creates . It
21 was estimated this alternative would add 200, 000 Idaho
22 Power-employee driven miles per year, significantly
23 increasing the odds of an accident and even death.
24 The Citation II has been crucial to maintaining
25 system reliability. As a couple of examples, the plane
RICHINS, DI 22
Idaho Power Company

1 transported a part for Langley Gulch that was urgently
2 needed to operate the plant; and the plane was used to pick
3 up fire-retardant paint and pole protections when the
4 supplier could not deliver, transporting the equipment to
5 crews in Salmon working to protect infrastructure from a
6 wildfire. With a core value of safety first and a focus on
7 responding rapidly to outages to keep the system as
8 reliable as possible, the purchase of a replacement plane
9 was determined to be the least-cost, least-risk
10 alternative .
11 Q. What is the total cost of the plane purchased
12 to replace the Citation II included in Idaho Power' s
13 request in this case?
14 A. The Company anticipates the purchase of the
15 plane will be completed in September 2025 and has included
16 approximately $9 . 8 million associated with the plane
17 replacement in the request in this case. Note, because the
18 plane is also utilized by IDACORP, a portion of the costs
19 associated with the plane have been allocated to IDACORP
20 and are therefore not included for recovery in this case .
21 The amounts included in the request in this case are Idaho
22 Power-specific costs .
23 Q. Do you believe the major projects you
24 discussed demonstrate a prudent approach to management of
25 Idaho Power' s general plant facilities?
RICHINS, DI 23
Idaho Power Company

1 A. Yes . The construction of the new Pocatello
2 Operations Center and the Data Center, as well as
3 replacement of the airplane, were necessary to address the
4 Company' s existing aging infrastructure and are necessary
5 to supporting Idaho Power' s critical business and
6 operational functions .
7 IV. SAFETY
8 Q. Please briefly explain Idaho Power' s
9 philosophy regarding safety.
10 A. As mentioned in Ms . Grow' s testimony, safety
11 is a core value at Idaho Power and accordingly, Idaho Power
12 embraces a Safety First culture. The Safety First culture
13 recognizes that Idaho Power' s family of employees is the
14 Company' s greatest asset and emphasizes that each
15 employee' s most important responsibility in their daily
16 work is safety and that no work is so critical that safety
17 should be disregarded. The Company is committed to the
18 safety of its employees, customers, and the public.
19 Q. How does the Company promote its Safety First
20 culture with employees?
21 A. The Company routinely conducts regular safety
22 and job-specific training for all employees in relation to
23 their respective area of coverage. While these safety
24 trainings vary in cadence based on role and responsibility,
25 the Company' s approximately 800 field employees, who are
RICHINS, DI 24
Idaho Power Company

1 largely tasked with constructing and maintaining the
2 Company' s system, attend safety meetings on at least a
3 monthly basis to ensure continual safety and best practice
4 updates . Additionally, since 2017, the Company has provided
5 training and videos to employees emphasizing how certain
6 behaviors and mental statuses, such as rushing,
7 complacency, multi-tasking, and fatigue, may impact one' s
8 ability to make safe decisions . In 2024, the Company
9 revitalized its MoveSafe program to address issues related
10 to soft tissue and body positioning injuries, also
11 incorporating mandatory vehicle walk arounds for all
12 Company vehicles to reduce backing accidents . Another
13 example of a program implemented by the Company to enhance
14 its Safety First culture is the development of the
15 Company' s Fail-Safe Capacity Model .
16 The Fail-Safe Capacity Model shifts the focus from
17 merely assigning blame to understanding the underlying
18 causes of incidents . It asks critical questions such as :
19 What happened? What failed? How did it occur? By analyzing
20 these aspects, the model recognizes that human errors are
21 inevitable. However, it also highlights that systems and
22 processes can be designed to accommodate these mistakes
23 without leading to catastrophic outcomes . In essence, the
24 Fail-Safe Capacity Model advocates for building resilience
25 into organizational practices, ensuring that even when
RICHINS, DI 25
Idaho Power Company

I errors occur, they do not result in severe consequences,
2 reducing serious injuries and fatalities .
3 Q. How does the Company promote its Safety First
4 culture with customers?
5 A. The Company routinely sponsors print, digital
6 or radio ads related to overhead line safety, downed power
7 lines, wildfire, and water safety, among other topics . In
8 2024, the Company also authored 60 safety-related social
9 media posts . Additionally, for customers that the Company
10 has an email on file for, the Company frequently emails
11 targeted safety-related tips and reminders . For example, in
12 Spring and Fall of 2024, the Company emailed irrigation
13 safety tips to customers who receive irrigation service .
14 Similarly, in February 2024, the Company sent all customers
15 various tips to promote safe winter weather safety tips and
16 "How Idaho Power Helps Keep Our Communities Safe . "
17 Aside from the above stated outreach channels, the
18 Company frequently publishes news briefs that discuss
19 differing safety topics, as well as including safety-
20 focused inserts within customers' bills, an example of
21 which is included as Exhibit No. 2 .
22 Q. How does the Company promote its Safety First
23 culture within the communities it serves?
24 A. The Company frequently provides training to
25 fire, police, and other first responders to inform them how
RICHINS, DI 26
Idaho Power Company

1 to remain safe around power lines . Fundamental to that
2 training, Idaho Power employees educate first responders on
3 Idaho Power' s process for de-energizing electrical
4 equipment as part of their response to house fires and
5 other emergencies . Similarly, the Company has also
6 published an online first responder training aid called
7 "Responding to Utility Emergencies . " This short online
8 course is available at no-cost to participants and teaches
9 emergency response personnel how to recognize potential
10 hazards involving electricity.
11 Idaho Power' s education and outreach energy advisors
12 also work with schools and community groups to conduct
13 educational presentations . These presentations vary in
14 content based on the audience, but typically aim to promote
15 general safety awareness and certain vital behaviors to
16 help minimize the occurrence of electrical accidents .
17 The Company also conducts safety presentations at
18 numerous contractor, customer, or partner agency events
19 throughout the year. For example, in 2024, the Company held
20 a Contractor Safety meeting whereby the Company shared best
21 practices and information related to the Company' s safety
22 culture and programs with contractors doing business on
23 behalf of Idaho Power.
24 Q. How is the Company educating customers in the
25 communities it serves on its wildfire mitigation efforts?
RICHINS, DI 27
Idaho Power Company

1 A. In 2024, the Company launched a comprehensive
2 campaign to educate its customers and other local partners
3 about its Wildfire Mitigation Plan and how the use of
4 enhanced protection settings and, as a last resort, Public
5 Safety Power Shutoff ("PSPS") are used as wildfire
6 mitigation. As part of this initiative, the Company held
7 over 35 meetings throughout the spring of 2024 with public
8 safety partners, where it provided crucial preparedness
9 information to all critical facilities in wildfire risk
10 areas . Additionally, Company representatives facilitated
11 and organized more than 50 public meetings across 18
12 counties during that same time, including virtual town hall
13 meetings, and joint virtual presentations in partnership
14 with agencies and businesses supporting access and
15 functional needs customers . These efforts helped establish
16 important connections with customers, particularly those in
17 rural communities . The Company' s relationships with its
18 public safety partners were greatly strengthened, allowing
19 it to take an active role in community discussions about
20 planning, mitigation, and emergency response .
21 In 2025, the Company has built on the valuable
22 insights gained from 2024, expanding its outreach and
23 messaging efforts, to include 30 public meetings across the
24 service area throughout this spring. The Company' s enhanced
RICHINS, DI 28
Idaho Power Company

1 2025 wildfire mitigation efforts are discussed in more
2 detail in Mr. Colburn' s testimony.
3 Q. Are there other reasons the Company has
4 developed its Safety First culture?
5 A. Yes . Idaho Power' s reputation for putting
6 Safety First also provides benefits in the area of employee
7 recruitment and retention. Although Idaho Power may not be
8 able to pay the higher hourly rates of some contractors,
9 Idaho Power is known for having first-rate safety programs .
10 This is a major attraction for individuals seeking
11 employment in the lines, substation, and power generation
12 fields .
13 V. CUSTOMER OPERATIONS & CUSTOMER SERVICE
14 Q. Please briefly describe Idaho Power' s Customer
15 Operations organization.
16 A. The Customer Operations organization within
17 Idaho Power is supported by several departments, including
18 Regional Operations, Transmission and Distribution
19 Construction, Customer Relations and Energy Efficiency, and
20 the Customer Service Center ("CSC") and is comprised of
21 roughly 700 employees who are engaged in activities that
22 provide direct service to the Company' s retail customers
23 and in the communities it serves . The Customer Operations
24 organization exists to provide excellent service to
25 customers in the most cost-effective way possible .
RICHINS, DI 29
Idaho Power Company

1 Q. Please briefly describe Idaho Power' s customer
2 service organization.
3 A. Idaho Power operates a centralized CSC that
4 provides customers with full-service access to Customer
5 Service Representatives ("CSR") weekdays from 7 : 30 a.m. to
6 6 : 30 p.m. MST, and outage emergency access to Outage
7 Specialists 24 hours a day, seven days a week. Idaho Power
8 also employs bilingual CSRs that provide service to the
9 Company' s Spanish-speaking customers . Additionally, the
10 Company utilizes a third-party language service to help it
11 communicate with other non-English speaking customers . Over
12 the last five years, an average of approximately 1 . 9
13 million inbound customer calls were received by the CSC
14 each year.
15 Q. How does the Company try to ensure that
16 customers calling the CSC have a positive experience?
17 A. "First Call Resolution" is a priority for the
18 Company. If a CSR can resolve a customer' s concerns on the
19 first call, the customer is likely to have a more positive
20 experience, and costs can be reduced from less calls . As
21 such, a strong emphasis is placed on ensuring customers'
22 concerns are addressed as efficiently and effectively as
23 possible .
24 Q. Please describe how CSRs assist customers who
25 express having difficulty paying their electric bill .
RICHINS, DI 30
Idaho Power Company

1 A. The Company' s CSRs are committed to helping
2 all customers expressing difficulty paying their electric
3 bill and work to identify and offer reasonable payment
4 arrangement options that may be best suited to assist with
5 each customer' s individual circumstances . Additionally,
6 when a customer declares their inability to make a payment,
7 CSRs will provide the customer with the contact information
8 of their local energy assistance agency so that the
9 customer may call and request receipt of Low-Income Home
10 Energy Assistance Program funds or any other bill
11 assistance that may be available.
12 Q. Do customers calling the CSC need to speak
13 with a CSR to retrieve account information, conduct account
14 transactions, or inquire about an outage affecting their
15 service address?
16 A. No. Idaho Power customers have access to
17 account and outage information 24 hours a day, seven days a
18 week through an Interactive Voice Response ("IVR") unit,
19 which has undergone numerous enhancements over the years to
20 enable additional customer self-serve functionality. The
21 IVR unit was able to contain and resolve, within the last
22 five years, approximately 48 percent of customer calls .
23 Through the IVR, customers can make payment
24 arrangements; retrieve billing, payment, and meter reading
25 information; sign up for Budget Pay; access energy
RICHINS, DI 31
Idaho Power Company

1 efficiency and usage information; and receive personalized,
2 address-specific outage information. Notably, in 2025,
3 Idaho Power' s IVR system had its enhanced self-serve
4 functionality nationally recognized as the top rated IVR
5 system by the IVR Doctors and Chartwell, Inc. , with top
6 quartile scores in functionality, usability, and system
7 aesthetics .
8 Q. What other self-serve options does the Company
9 offer?
10 A. Customers can also enroll in the Company' s My
11 Account platform, which offers flexible payment options and
12 simplifies enrollment in additional account-related
13 services such as Paperless Billing, Auto Pay, and Budget
14 Pay. This platform also enables customers to efficiently
15 self-manage their new or existing accounts, update contact
16 information and set notification preferences .
17 Through various marketing techniques, customer
18 onboarding and key customer touchpoints, enrollments in the
19 Company' s My Account customer portal continue to increase .
20 In 2024, the Company saw a nine percent increase in
21 enrollments; approximately 38, 900 new enrollments compared
22 to approximately 35, 690 in 2023 . To date, approximately 68
23 percent of the Company' s customers currently have an active
24 My Account profile.
RICHINS, DI 32
Idaho Power Company

1 As a result of the increase in enrollments in the My
2 Account customer portal, the Company is also seeing an
3 increase in other various digital offerings to include the
4 online Start/Stop/Move form, online payments, Paperless
5 Billing, Auto Pay, and downloads of the Mobile Application.
6 Q. Are there any other customer experience
7 initiatives that you believe will result in positive
8 customer experiences?
9 A. Yes, in the Company' s ongoing commitment to
10 address affordability concerns and provide greater
11 flexibility for our customers, the Company is exploring a
12 new `Choose Your Own Due Date' option. Currently,
13 residential customers have the ability to request a change
14 to their due date within a window of ten (10) days from
15 their existing due date. However, we recognize the need for
16 even more flexibility and are actively working to expand
17 this offering. Our teams are diligently evaluating the
18 potential impacts on systems, as well as considering
19 marketing strategies, recognizing this initiative will
20 offer customers more control over their payment schedules,
21 ultimately enhancing their overall customer experience .
22 Additionally, in May 2024 the Company auto enrolled
23 all residential customers that had a viable mobile phone or
24 email contact information on file, into premise-based
25 outage alerts in an effort to keep customers informed
RICHINS, DI 33
Idaho Power Company

1 during outages . This accounted for approximately 488, 000
2 residential customer enrollments . In 2025, all remaining
3 customer segments were auto enrolled, including commercial,
4 irrigation, and large commercial and industrial customers .
5 At the same time, an additional communication channel was
6 implemented, Text to Voice. This new channel enables
7 landline only customers to be alerted via an automated
8 voice call . All remaining residential customers without a
9 mobile phone or email on file were enrolled in automated
10 voice alerts . As of May 2025, 97 percent of customers are
11 enrolled in premise-based outage alerts . While customers do
12 have the option to opt out of these alerts, this effort has
13 helped to keep customers proactively informed about
14 outages .
15 Furthermore, in May 2025, the Company implemented a
16 new outage map that offers an enhanced customer experience .
17 It includes additional features, a more user-friendly
18 mobile experience, and more visibility into outage cause
19 information.
20 VI . CUSTOMER SATISFACTION
21 Q. What is the Company' s overall approach to
22 customer satisfaction?
23 A. Idaho Power strives to be regarded as an
24 exceptional utility by the customers it serves . To
25 accomplish this, the Company must provide superior and
RICHINS, DI 34
Idaho Power Company

1 satisfying customer service and experiences that meet or
2 exceed its customers' needs and expectations .
3 Q. How does the Company determine the focus for
4 improving customer relations?
5 A. The Company continually focuses on ways to
6 cost-effectively improve its relationship with customers by
7 assessing customer perception of the Company, identifying
8 performance and experience gaps based on customer feedback,
9 and reviewing industry best practices and trends .
10 Q. Please describe Idaho Power' s continuing
11 practice of surveying its customers regarding their levels
12 of satisfaction with the Company.
13 A. Idaho Power has contracted with Burke, Inc . to
14 conduct quarterly customer relationship surveys since 1995 .
15 Burke is a full-service customer market research and
16 decision support company headquartered in Cincinnati, Ohio,
17 with regional offices throughout the United States . These
18 surveys represent Idaho Power' s primary customer
19 satisfaction research and determine the Company' s customer
20 relationship index ("CRI") , which is a key metric used to
21 evaluate the Company' s overall customer satisfaction rate .
22 Burke offers an extensive survey for the following four
23 customer segments : Residential, Small Business, Irrigation,
24 and Large Commercial and Industrial .
RICHINS, DI 35
Idaho Power Company

1 In addition to the customer satisfaction surveys
2 performed by Burke, Idaho Power acquires the results of the
3 annual J.D. Power Electric Utility Residential Customer
4 Satisfaction Study ("J. D. Power Study") . The J. D. Power
5 Study is comprised of over 100, 000 customer responses
6 nationwide, including Idaho Power' s customers, and is used
7 by the Company primarily as a benchmark to other electric
8 utilities and, as its name implies, is for residential
9 customers only, although Idaho Power also receives results
10 from the business survey, which have been positive . Idaho
11 Power is consistently ranked amongst the top utilities in
12 the nation in terms of customer satisfaction.
13 Idaho Power also utilizes customer focus groups and
14 ad hoc surveys, such as within its online Empowered
15 Community group, for project-specific qualitative research,
16 when the situation is appropriate. Further, the Company
17 conducts post-construction surveys to help ensure that
18 working with Idaho Power on new construction projects
19 remains a satisfying and streamlined experience.
20 VII . CONCLUSION
21 Q. Please summarize your testimony.
22 A. As evidenced by Idaho Power' s improved
23 reliability metrics since 2007, the Company has taken a
24 thoughtful approach to construction and maintenance of its
25 transmission and distribution systems . Despite considerable
RICHINS, DI 36
Idaho Power Company

1 investment and expansion in recent years, Idaho Power
2 continues to experience historically high load growth
3 during a time of rising costs and constrained system
4 capacity, driving the need for nearly $1 billion in
5 investments in 2025 to ensure the continued delivery of
6 safe, reliable electric service.
7 The Company' s initiatives and various enhancements
8 within the Customer Operations organization continue to
9 demonstrate Idaho Power' s commitment to its customers to
10 provide superior and satisfying service. The Company
11 believes it has adequately addressed customer needs and
12 that Idaho Power' s investments that support customer
13 service and satisfaction have been appropriately incurred
14 on behalf of customers .
15 Q. Does this conclude your direct testimony in
16 this case?
17 A. Yes, it does .
18
19
RICHINS, DI 37
Idaho Power Company

1 DECLARATION OF ADAM RICHINS
2 I, Adam Richins, declare under penalty of perjury
3 under the laws of the state of Idaho:
4 1 . My name is Adam Richins . I am employed by
5 Idaho Power Company as the Senior Vice President and Chief
6 Operating Officer.
7 2 . On behalf of Idaho Power, I present this
8 pre-filed direct testimony and Exhibit No. 2 in this
9 matter.
10 3 . To the best of my knowledge, my pre-filed
11 direct testimony and exhibit 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 44, ;E�'Z..-
18 Signed:
19 Adam Richins
RICHINS, DI 38
Idaho Power Company

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-16
IDAHO POWER COMPANY
RICHINS, DI
TESTIMONY
EXHIBIT NO. 2

Nt
As winter approaches, keeping our homes warm
and comfortable becomes a priority. However, this
doesn't have to come at the expense of high energy
bills. Taking a few easy steps to stay warm and cozy
as cooler weather rolls in can make a big difference
for energy savings.
Here are our best tips for getting the most out
of your winter heating.
Utilize natural heat. Open curtains during the
day to let sunlight naturally warm your home,
and close them at night to retain heat.
Set the temperature on your water heater
so water at the tap is 1200 F.
Weatherstrip and caulk around doors and
windows to reduce drafts. Fixing air leaks
is one of the cheapest and easiest ways to
improve comfort and reduce energy use.
Install door sweeps. Adding door sweeps to
the bottom of exterior doors can block cold
drafts.
Install a smart or programmable thermostat
to easily adjust your home's temperature based
on your schedule. Visit our website to see if you
qualify for a $50 smart thermostat incentive —
idahopower.com/save.
Use energy-efficient heating. Consider an
energy-efficient furnace or heat pump when it's
time to upgrade. Regular maintenance of your
heating system can also improve efficiency.
Ensure you have adequate attic insulation.
We recommend a minimum insulation level of
R-38 or R-49 in Oregon and colder climates.
• • energy-saving • Exhibit No.2
Case No. IPC-E-25-16
visit idahopower.com/save. A. Richins, IPC
Page 1 of 2

IDAHO
POWE
r.
Idaho Power sees over 600 vehicle collisions with
our power poles annually, and many of those
happen when the roads are icy. These collisions can
sometimes cause power lines to fall, as can heavy
snow or high winds from winter storms.
If you encounter a downed power line, stay
safe by following these measures.
Always assume any power line, even if it's fallen,
has energy running through it.
Stay at least 100 feet back, keep others away,
and contact Idaho Power immediately at
208-388-2323 or call 911 .
Never touch a downed line or use any object to
move a downed power line, and never move tree
limbs or other objects touching a downed line.
If someone touches a downed power line, do not
touch or try to rescue them. You risk becoming a
victim yourself. Call 911 immediately.
What if a downed power line falls on
your vehicle?
If safe to do so, stay inside the vehicle until
help arrives.
Warn others not to touch the vehicle, and ask
them to call for help.
If you must leave the vehicle because of a fire or
other life-threatening situation, jump out and
as far away as possible with both feet landing
on the ground at the same time. Keeping your
feet together, shuffle away from the scene at
least 100 feet. Do not touch the vehicle and the
ground at the same time.
To watch a video demonstrating how to do Exhibit No.2
this, visit idahopower.com/safety. Case No. IPC-E-25-16
A. Richins, IPC
©2024 Idaho Power Page 2 of 2
31180-1-0255