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Home My WebLink About20250808Errata and Corrected Pages to Application and Direct of Maloney.pdf -0IQAHO R® RECEIVED DONOVAN WALKER August 8, 2025 Lead Counsel IDAHO PUBLIC dwalkerC�idahopower.com UTILITIES COMMISSION August 8, 2025 Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Boulevard Building 8, Suite 201-A Boise, Idaho 83714 Re: Case No. IPC-E-25-22 Idaho Power Company's Application for Authority to Update its Operation and Maintenance Charges Applicable to Schedule 72, Generator Interconnections to PURPA Qualifying Facility Sellers Dear Commission Secretary: Attached please find the Errata and Corrected Pages to Application and Direct Testimony of Riley Maloney to be filed in the above-entitled matter. If you have any questions about the attached documents, please do not hesitate to contact me. Sincerely, Donovan E. Walker DEW:cd Attachments 1221 W. Idaho St(83702) P.O.Box 70 Boise, ID 83707 DONOVAN E. WALKER (ISB No. 5921) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalker idahopower.com Attorney for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-25-22 AUTHORITY TO UPDATE ITS OPERATION ) AND MAINTENANCE CHARGES ) ERRATA AND CORRECTED APPLICABLE TO SCHEDULE 72, ) PAGES TO APPLICATION AND GENERATOR INTERCONNECTIONS TO ) DIRECT TESTIMONY OF RILEY PURPA QUALIFYING FACILITY SELLERS. ) MALONEY Idaho Power Company ("Idaho Power" or "Company") hereby respectfully submits to the Idaho Public Utilities Commission ("Commission") this Errata and corrected pages to the Company's Application to Update Operation and Maintenance Charges Applicable to Schedule 72, Generator Interconnection to PURPA Qualifying Facility Sellers, and the Direct Testimony of Riley Maloney ("Maloney Direct") filed contemporaneously therewith on May 8, 2025, to ensure accuracy, consistency, and clarity of the record as follows. 1 . In the process of preparing responses to discovery requests, the Company identified that it had inadvertently relied on 2023 13-month average plant investment amounts when calculating the proposed monthly O&M rates, rather than ERRATA AND CORRECTED PAGES TO APPLICATION AND DIRECT TESTIMONY OF RILEY MALONEY- 1 the intended 2024 13-month average values. To correct this, the Company has revised the relevant portions of its Application, Maloney Direct, as well as separately filing Supplemental Responses to the relevant discovery requests. Idaho Power has prepared and submits herewith the corrected, replacement pages of the Application including replacement Sheet No. 72-12 of Schedule 72 (Attachment 1); Maloney Direct including corrected Exhibit No. 1 (Attachment 2); and redlined versions of each (Attachment 3). 2. Correcting for the intended 2024 amounts, rather than the 2023 amounts, has the effect of reducing the proposed updated rate applied to both the distribution and transmission interconnection equipment: the distribution rate moves from 0.96 to 0.90; and transmission rate from 0.28 to 0.26. It also has the effect of changing the difference in the total annualized amount collected, if the new rates are applied to projects active at the end of 2024, from an increase of approximately$4,800 to a decrease of approximately $125,000, as shown on page 16 of Maloney Direct. 3. The corrections reflected in the replacement pages are as follows: Application: Page 4, replaces 0.96 with 0.90, and 0.28 with 0.26; and Sheet No. 72-12 of Schedule 72 Maloney Direct: Page 10, replaces 0.96 with 0.90, and 0.28 with 0.26; Page 16, replaces increase with decrease, and $4,800 with $125,000; Page 17, replaces 45 with 46, $553 with $625, 76 with 75, $373 with $293, and $623 with $719; and ERRATA AND CORRECTED PAGES TO APPLICATION AND DIRECT TESTIMONY OF RILEY MALONEY- 2 Corrected Exhibit No. 1 In addition, the Company has separately submitted supplemental responses to Staff Request for Production Nos. 6, 8, 9, and 10. These updates do not change anything else about the Application or the Maloney Direct. Respectfully submitted this 8th day of August 2025. ,a"." '�;l')&a Donovan Walker Attorney for Idaho Power Company ERRATA AND CORRECTED PAGES TO APPLICATION AND DIRECT TESTIMONY OF RILEY MALONEY- 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 8th day of May 2025, 1 served a true and correct copy of the within and foregoing ERRATA AND CORRECTED PAGES TO APPLICATION AND DIRECT TESTIMONY OF RILEY MALONEY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Jeffrey R. Loll U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email - Jeff.Loll(c)-puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 IDAHYDRO Hand Delivered C. Tom Arkoosh U.S. Mail Nicholas J. Erekson Overnight Mail ARKOOSH LAW OFFICES FAX 913 W. River Street, Suite 450 X Email — tom.arkoosh(o)_arkoosh.com P.O. Box 2900 Nick.erekson(a-).arkoosh.com Boise, ID 83701 Erin.cecil(a)_arkoosh.com RENEWABLE ENERGY COALITION Hand Delivered Irion Sanger U.S. Mail SANGER GREENE, P.C. Overnight Mail 4031 SE Hawthrone Blvd. FAX Portland, OR 97214 X Email —irion(a)-sanger-law.com ('Of�v� Christy Davenport, Legal Assistant ERRATA AND CORRECTED PAGES TO APPLICATION AND DIRECT TESTIMONY OF RILEY MALONEY-4 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-25-22 IDAHO POWER COMPANY ATTACHMENT NO. 1 Replacement Pages to the Application II. PROPOSED SCHEDULE 72 O&M CHARGE UPDATE 5. Generally using the Original Methodology, Idaho Power calculated new O&M Charges based on 13-month average plant balances and such plant's associated O&M expenses, as stated within the Company's 2024 FERC Form 1. These levelized rates equate to a proposed monthly 0.90 percent rate applied to the original cost of distribution interconnection equipment and a 0.26 percent rate applied to the original cost of transmission interconnection equipment. Exhibit No. 1 to the Direct Testimony of Riley Maloney provides the calculation of these proposed rates. In comparison to the existing O&M Charge, the updated levelized distribution rate increases from 0.70 percent per month to 0.90 percent per month, while the levelized transmission rate decreases from 0.40 percent per month to 0.26 percent per month. 6. Idaho Power proposes to implement the updated O&M Charges utilizing the levelized, average rates to collect O&M going forward, and to abandon the de-levelized schedule containing different O&M charges on a yearly basis over 35 years as currently exists. The rates that are currently in effect were subjected to a "de-levelization" process, where the rate is lower early in the life of the interconnection equipment and escalated for 35 years using an inflation factor. As more fully set forth in the Direct Testimony of Riley Maloney, the Company proposes to remove the de-levelization concept from the rate and instead charge the same calculated average rate each year. 7. Additionally, Idaho Power proposes to update Schedule 72's O&M Charge, along with the associated revenue credit, on a more frequent basis in conjunction with each general rate case proceeding, similar to how it updates Rule M, Facilities Charges. APPLICATION - 4 Idaho Power Company First Revised Sheet No. 72-12 Cancels I.P.U.C. No. 30, Tariff No. 101 Original Sheet No. 72-12 SCHEDULE 72 GENERATOR INTERCONNECTIONS TO PURPA QUALIFYING FACILITY SELLERS (Continued) SECTION 2: INTERCONNECTION OF GENERATION FACILITIES (Continued) VESTED INTEREST (Continued) 5. In no circumstance will Vested Interest refunds exceed 100 percent of the refundable portion of any party's cash payment to the Company. 6. Vested Interest refund payments may be waived by notifying the Company in writing. 7. All existing agreements' refund provisions will be governed and administered under the provisions in effect at the time the agreement was entered into between the Company and Seller or Additional Applicant. OPERATION AND MAINTENANCE OBLIGATIONS AND EXPENSES The Company will operate and maintain Company furnished Interconnection Facilities, as well as any Seller-Furnished Facilities transferred to the Company. Seller will pay the Company a monthly operation and maintenance charge equal to a percentage of the Construction Cost and Transfer Cost paid by the Seller. The monthly percentage charged will be as follows: Facilities rated 138 kV and 161 kV: 0.26% Facilities rated below 138 kV: 0.90% The cost upon which an individual Seller's operation and maintenance charge is based will be reduced by subsequent Vested Interest refunds. Additional Applicants who are Sellers will pay the monthly operation and maintenance charge on the amount they paid as an Additional Applicant. Seller-Furnished Facilities not transferred to the Company will be operated and maintained by the Seller at the Seller's sole risk and expense. The monthly operating and maintenance charges stated above will be applied as a percentage of the applicable original interconnection investment. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs Effective—January 1, 2026 1221 West Idaho Street, Boise, Idaho BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-25-22 IDAHO POWER COMPANY ATTACHMENT NO. 2 Replacement Pages to the Direct Testimony of Riley Maloney 1 Q. Has the Company calculated an updated O&M 2 rate that it proposes for this update? 3 A. Yes . Generally relying on the Original 4 Methodology, the Company calculated new rates based on 13- 5 month average plant balances and such plant' s associated 6 0&M expenses, as stated within the Company' s 2024 FERC Form 7 1 . 8 Q. What are the new rates being proposed in 9 this case? 10 A. The Company proposes a monthly 0 . 90 percent 11 rate applied to the original cost of distribution 12 interconnection equipment and a 0 . 26 percent rate applied 13 to the original cost of transmission interconnection 14 equipment. Exhibit No. 1 provides the calculation of these 15 proposed levelized rates . 16 Q. How do these rates compare to the levelized 17 rates currently in effect? 18 A. The levelized distribution rate increases 19 from 0 . 70 percent per month to 0 . 90 percent per month, 20 while the levelized transmission rate decreases from 0 . 40 21 percent per month to 0 . 26 percent per month. 22 Q. What drove the increase to the distribution 23 rate? 24 A. The primary driver of the increase in the 25 proposed distribution 0&M rate is increased distribution Maloney, DI 10 Idaho Power Company 1 it hard to develop assumptions regarding the proper 2 timeframe to use when developing de-levelized rates . 3 Finally, and as discussed in more detail below, the 4 Company proposes to more frequently update its O&M charge 5 percentages, which will negate some of the perceived 6 benefits of de-levelization. 7 Q. How are 0&M Charges treated for ratemaking 8 purposes? 9 A. O&M Charges collected from PURPA projects are 10 treated as a revenue credit when calculating the revenue 11 requirement of Idaho Power' s retail service customers . This 12 revenue credit was last updated as part of the Company' s 13 general rate case filed as Case No. IPC-E-23-13 and totaled 14 approximately $1, 800, 000 for Idaho customers . 15 Q. Has the Company quantified the ratemaking 16 impact of its proposal? 17 A. Yes . If the proposed rates were applied to 18 projects active at the end of 2024, the total annualized 19 amount collected from 0&M Charges would decrease by 20 approximately $125, 000 . 21 Q. Has the Company reviewed the impact of its 22 proposed changes on current PURPA projects? 23 A. Yes . The impact to existing projects will be 24 driven by three interrelated factors : (1) what point in 25 time during the 36+-year horizon the project is in, (2) Maloney, DI 16 Idaho Power Company 1 whether the project' s interconnection facilities are 2 transmission or distribution, and (3) the impact of an 3 increase to the average distribution rate and a decrease in 4 the average transmission rate. 5 Overall, when holistically considering the Company' s 6 proposal, of the 121 non-mixed facility Idaho PURPA 7 projects paying an 0&M Charge at the end of 2024 : 46 will 8 be assessed a lower charge (an average decrease of 9 approximately $625 per month) and 75 will be assessed a 10 higher charge (an average increase of approximately $293 11 per month) . For the five Idaho PURPA projects with both 12 transmission and distribution facilities subject to an O&M 13 Charge as of the end of 2024, their monthly charge will, on 14 average, decrease by approximately $719 . 15 Q. How many projects have reached the 36 plus 16 years and reverted back to the flat rate? 17 A. As of the end of 2024, 40 projects have 18 reached the 36 plus years and accordingly have reverted 19 back to the flat rate. 20 Q. Is the Company proposing to periodically 21 update the new formula rates? 22 A. Yes . As noted above, the Company proposes that 23 the 0&M Charges and corresponding revenue credit would be 24 updated during each general rate case, similar to how it 25 updates Rule M, Facilities Charges . Maloney, DI 17 Idaho Power Company IDAHO POWER COMPANY BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION TRANSMISSION MONTHLY OPERATIONS AND MAINTENANCE CHARGE IPC-E-25-22 Line No. Description 2024 Amount Notes: Investment in Transmission Service Lines 1 Total Transmission Plant $ 1,438,934,807 2 Transmission Service Lines $ 280,621,066 3 Transmission Services Lines as a Percent of Total Transmission Plant 19.502% (Lines 2/1) Investment in General Plant 4 Total General Plant-Accounts 389-398 $ 547,995,454 5 Total Operations&Maintenance(O&M)Labor 174,159,861 6 Total O&M Labor,Excluding Administrative&General(A&G) 109,097,959 7 Total Transmission Labor 12,843,204 8 Labor Assigned to Transmission Service Lines $ 2,504,682 (Lines 3*7) 9 Transmission Service Lines Labor as a Percent of Total O&M Labor Expenses,Excluding A&G 2.296% (Lines 8/6) 10 General Plant Assigned to Transmission Service Lines $ 12,580,934 (Lines 4*9) 11 Total Investment in Transmission Service Lines $ 293,202,000 (Lines 2+10) 12 Transmission Service Lines Labor as a Percent of Total O&M Labor,Including A&G 1.438% (Lines 8/5) Operations&Maintenance Expenses-Transmission Service Lines 13 Total Transmission O&M Expense,Excluding Account 565 $ 25,826,526 14 Transmission O&M Assigned to Transmission Service Lines $ 5,036,689 (Lines 3*13) Administrative and General Expenses Assigned to Transmission Service Lines 15 Account 920 $ 110,254,504 16 Account 921 19,328,502 17 Account 923 10,696,562 18 Account 930.2 4,681,625 19 Account 931 - 20 Account 935 7,588,454 21 Total $ 152,549,646 (71-ines 15,16,17,18,19,and 20) 22 A&G Assigned to Transmission Service Lines Based on Transmission Service Lines Labor $ 3,502,250 (Lines 9*21) 23 Account922 $ (47,555,951) 24 Account 925 10,612,690 25 Account 926 84,097,252 26 Total $ 47,153,991 (71-ines 23,24,and 25) 27 Accounts 922,925 and 926 Assigned to Transmission Service Lines Based on Total Labor $ 678,146 (Lines 12*26) 28 Total A&G Assigned $ 4,180,395 (Lines 22+27) ................................................................"io"...................................................................................................................................................................................................................................................................................................................................................................., 29 :Total Annual Transmission Service Lines O&M Expenses $ 9,217,084 :(Lines 14+28) .............................................................................................................................................................................................................................................................................................................................................................................................................................................. 30 Annual Transmission Service Lines O&M As a Percent of Total Investment in Transmission Service Lines 3.144% (Lines 29/11) ............................................................................................................................................................................................................................................................................................................................................................................................................................................1 31 Monthly Transmission Service Lines O&M Cost(Rounded) 0.26% ............................................................................................................................................................................................................................................................................................................................................................................................................................................. *Unless noted otherwise,amounts shown are truncated for presentment purposes. Exhibit No.1 R.Maloney,IPC IDAHO POWER COMPANY BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION DISTRIBUTION MONTHLY OPERATIONS AND MAINTENANCE CHARGE IPC-E-25-22 Line No. Description 2024 Amount Notes: Investment in Overhead Distribution Lines 1 Distribution Poles,Towers&Fixtures-Plant Account 364 $ 352,535,104 2 Distribution Overhead Conductor&Devices-Plant Account 365 169,354,436 3 Total $ 521,889,541 (Lines 1+2) Investment in General Plant 4 Total General Plant-Accounts 389-398 $ 547,995,454 5 Total Operations&Maintenance(O&M)Labor 174,159,861 6 Total O&M Labor,Excluding Administrative&General(A&G) $ 109,097,959 Overhead Distribution Lines Labor 7 Distribution Overhead Lines Expenses-Account 583 $ 4,494,833 8 Distribution Overhead Lines Maintenance-Account 593 6,306,916 9 Total Distribution Overhead Lines Labor $ 10,801,749 (Lines 7+8) 10 Total Distribution Labor $ 35,278,296 11 Less:Accounts 580 and 590 3,395,913 12 Total Distribution Labor Expenses,Excluding Accounts 580 and 590 $ 31,882,384 (Lines 10-11) 13 Accounts 583 and 593 as a Percent of Total Distribution Labor Expenses,Excluding Accounts 580 and 590 33.880%(Lines 9/12) 14 Portion of Accounts 580 and 590 Assigned to Accounts 583 and 593 $ 1,150,535 (Lines 11*13) 15 Total Overhead Distribution Lines Labor,Including Accounts 580 and 590 $ 11,952,284 (Lines 9+14) 16 Overhead Distribution Lines Labor,Inc.Supervision,as a Percentage of Total Labor Excluding A&G 10.956%(Lines 15/6) 17 Overhead Distribution Lines Labor,Inc.Supervision,as a Percentage of Total O&M Labor Expenses 6.863%(Lines 15/5) 18 General Plant Investment Assigned to Overhead Distribution Lines $ 60,035,926 (Lines 4*16) 19 Total Investment in Overhead Distribution Lines $ 581,925,467 (Lines 3+18) Operations&Maintenance Expenses-Overhead Distribution Lines 20 Overhead Distribution Lines Expenses-Account 583 $ 6,679,549 21 Operations Supervision and Engineering-Account 580 4,981,783 22 Total Distribution Operations Expenses $ 38,526,794 23 Account 583 as a Percent of Total Distribution Operations Expenses,Excluding Account 580 19.912%(Lines 20/(22-21)) 24 Supervision&Engineering Assigned to Overhead Distribution Lines Expenses $ 991,983 (Lines 21*23) 25 Maintenance Expenses-Account 593 35,534,246 26 Maintenance Supervision and Engineering-Account 590 9,118 27 Total Distribution Maintenance $ 43,367,688 28 Account 593 as a Percent of Total Distribution Maintenance,Excluding Account 590 81.954%(Lines 25/(27-26)) 29 Supervision&Engineering Assigned to Overhead Distribution Lines Maintenance $ 7,473 (Lines 26*28) 30 Total Overhead Distribution Lines O&M Expenses $ 43,213,250 (SLines 20,24,25,and 29) Administrative and General Expenses Assigned to Overhead Distribution Lines 30 Account 920 $ 110,254,504 31 Account 921 19,328,502 32 Account 923 10,696,562 33 Account 930.2 4,681,625 34 Account 931 - 35 Account 935 7,588,454 36 Total $ 152,549,646 (SLines 30,31,32,33,34,and 35) 37 A&G Assigned to Overhead Distribution Lines Based on Overhead Line Labor $ 16,712,656 (Lines 16*36) 38 Account 922 $ (47,555,951) 39 Account 925 10,612,690 40 Account 926 84,097,252 41 Total $ 47,153,991 (SLines 38,39,and 40) 42 Accounts 922,925 and 926 Assigned to Overhead Distribution Lines Based on Total Labor $ 3,236,095 (Lines 17*41) 43 Total A&G Assigned $ 19,948,751 (Lines 37+42) .................................................................................................................................................................................................................................................................................................................................................................................................................... 44 Total Annual Overhead Distribution Lines O&M Expenses $ 63,162,001 (Lines 30+43) 45 Annual Overhead Distribution Lines O&M As a Percent of Total Investment in Overhead Distribution Lines 10.854%(Lines 44/19) 46 ..M........o n....th........ly Ove r................h.................Di ead ...st.......ribu..........t.i o...........n .Lin....................................................................es OB,M Cost(R oun d e d)........................................................................................................................................................................................................................................0.90..........%"': *Unless noted otherwise,amounts shown are truncated for presentment purposes. Exhibit No.1 R.Maloney,IPC BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-25-22 IDAHO POWER COMPANY ATTACHMENT NO. 3 Redline Copies II. PROPOSED SCHEDULE 72 O&M CHARGE UPDATE 5. Generally using the Original Methodology, Idaho Power calculated new O&M Charges based on 13-month average plant balances and such plant's associated O&M expenses, as stated within the Company's 2024 FERC Form 1. These levelized rates equate to a proposed monthly 0.906 percent rate applied to the original cost of distribution interconnection equipment and a 0.266 percent rate applied to the original cost of transmission interconnection equipment. Exhibit No. 1 to the Direct Testimony of Riley Maloney provides the calculation of these proposed rates. In comparison to the existing O&M Charge, the updated levelized distribution rate increases from 0.70 percent per month to 0.906 percent per month, while the levelized transmission rate decreases from 0.40 percent per month to 0.266 percent per month. 6. Idaho Power proposes to implement the updated O&M Charges utilizing the levelized, average rates to collect O&M going forward, and to abandon the de-levelized schedule containing different O&M charges on a yearly basis over 35 years as currently exists. The rates that are currently in effect were subjected to a "de-levelization" process, where the rate is lower early in the life of the interconnection equipment and escalated for 35 years using an inflation factor. As more fully set forth in the Direct Testimony of Riley Maloney, the Company proposes to remove the de-levelization concept from the rate and instead charge the same calculated average rate each year. 7. Additionally, Idaho Power proposes to update Schedule 72's O&M Charge, along with the associated revenue credit, on a more frequent basis in conjunction with each general rate case proceeding, similar to how it updates Rule M, Facilities Charges. APPLICATION -4 Idaho Power Company Grig+ First Revised Sheet No. 72-12 Cancels I.P.U.C. No. 30, Tariff No. 101 Fourth Rev 'sed0riginal Sheet No. 72-12 SCHEDULE 72 GENERATOR INTERCONNECTIONS TO PURPA QUALIFYING FACILITY SELLERS (Continued) SECTION 2: INTERCONNECTION OF GENERATION FACILITIES (Continued) VESTED INTEREST (Continued) 5. In no circumstance will Vested Interest refunds exceed 100 percent of the refundable portion of any party's cash payment to the Company. 6. Vested Interest refund payments may be waived by notifying the Company in writing. 7. All existing agreements' refund provisions will be governed and administered under the provisions in effect at the time the agreement was entered into between the Company and Seller or Additional Applicant. OPERATION AND MAINTENANCE OBLIGATIONS AND EXPENSES The Company will operate and maintain Company furnished Interconnection Facilities, as well as any Seller-Furnished Facilities transferred to the Company. Seller will pay the Company a monthly operation and maintenance charge equal to a percentage of the Construction Cost and Transfer Cost paid by the Seller. The monthly percentage w&chanrged will be as follows: annually on the anniversary of the Forst Energy Date in onnordaRce with the following tohloc• Facilities rated 138 kV and 161 kV: 0.268% Facilities rated below 138 kV: 0.906% TABLE 1: MONTHLY DCR/\TION AND MAINTENANCE CHARGES FOR 139 kV and 161 L\/ Year 4 2 3 4 5 6 7 8 0 40 44 42 O&M Charge0.269; 07oi 0.28% 0.29% 0.30% 0.329; 0..3396 0 0 0 040% Year 43 44 45 46 47 48 49 20 24 22 23 24 Q&M GhaFge 0.43% 0a % 047% 0.49% 0.52% 0.54% 0.56% 0.59% 0.629; 0.64% 0.67% 0.7096 Year 25 26 27 28 20 W 34 32 33 34 35 36$ O&M Charge ems°; ate°; gee% 0.84% 0.87% 0. 0. 1:ee9; a 04% 1.09% 1.14% 0.40% The cost upon which an individual Seller's operation and maintenance charge is based will be reduced by subsequent Vested Interest refunds. Additional Applicants who are Sellers will pay the monthly operation and maintenance charge on the amount they paid as an Additional Applicant. Seller-Furnished Facilities not transferred to the Company will be operated and maintained by the Seller at the Seller's sole risk and expense. TABLE 2: MONTHLY OPERATING AND M INTEN/\NGE (`H RGES BELOW 138 L\/ —vr Year 4 2 3 4 5 6 7 8 0 40 44 42 O&M Charge 0:a799; 0.49% 0-59,; 0.5 4% 0.569; 0.599; 0.61% 0.649; 0.679,; gee% 0. 0.77% Year 43 44 45 46 47 48 40 20 24 22 23 24 IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. 36042 Timothy E. Tatum, Vice President, Regulatory Affairs Effective—January 1, 20246 1221 West Idaho Street, Boise, Idaho Idaho Power Company Grig+ First Revised Sheet No. 72-12 Cancels I.P.U.C. No. 30 Tariff No. 101Fourth Reyosed0ri inal Sheet No. 72-12 O&M Charge 0.80% 0.84% 0.87% 091% 0.95% 1.00° a 04% 1 a.ate a.a9 a 24% a Year 25 2-6 27 28 2-9 W 34 32 33 34 -35 36-+ O&M Chargea a.ate 1.48% a a a 177% a a 2..11% 0. The monthly operating and maintenance charges stated above ie Table-1-and Table 2 will be applied as a percentage of the applicable original interconnection investment. Thorn monthly operating and maontenaRGe Gharges eSGalate annually and are equivalent to 35 year levelized rates of 0 fe Table 1 and n 7n0% for Table 7 IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. 36042 Timothy E. Tatum, Vice President, Regulatory Affairs Effective-January 1, 20246 1221 West Idaho Street, Boise, Idaho 1 Q. Has the Company calculated an updated O&M 2 rate that it proposes for this update? 3 A. Yes . Generally relying on the Original 4 Methodology, the Company calculated new rates based on 13- 5 month average plant balances and such plant' s associated 6 0&M expenses, as stated within the Company' s 2024 FERC Form 7 1 . 8 Q. What are the new rates being proposed in 9 this case? I10 A. The Company proposes a monthly 0 . 90-6 percent 11 rate applied to the original cost of distribution I12 interconnection equipment and a 0 . 264 percent rate applied 13 to the original cost of transmission interconnection 14 equipment. Exhibit No. 1 provides the calculation of these 15 proposed levelized rates . 16 Q. How do these rates compare to the levelized 17 rates currently in effect? 18 A. The levelized distribution rate increases 19 from 0 . 70 percent per month to 0 . 90-1& percent per month, 20 while the levelized transmission rate decreases from 0 . 40 I21 percent per month to 0 . 264 percent per month. 22 Q. What drove the increase to the distribution 23 rate? 24 A. The primary driver of the increase in the 25 proposed distribution 0&M rate is increased distribution Maloney, DI 10 Idaho Power Company 1 it hard to develop assumptions regarding the proper 2 timeframe to use when developing de-levelized rates . 3 Finally, and as discussed in more detail below, the 4 Company proposes to more frequently update its O&M charge 5 percentages, which will negate some of the perceived 6 benefits of de-levelization. 7 Q. How are 0&M Charges treated for ratemaking 8 purposes? 9 A. O&M Charges collected from PURPA projects are 10 treated as a revenue credit when calculating the revenue 11 requirement of Idaho Power' s retail service customers . This 12 revenue credit was last updated as part of the Company' s 13 general rate case filed as Case No. IPC-E-23-13 and totaled 14 approximately $1, 800, 000 for Idaho customers . 15 Q. Has the Company quantified the ratemaking 16 impact of its proposal? 17 A. Yes . If the proposed rates were applied to 18 projects active at the end of 2024, the total annualized 19 amount collected from 0&M Charges would 3nere_s—decrease 20 by approximately $4125,444000 . 21 Q. Has the Company reviewed the impact of its 22 proposed changes on current PURPA projects? 23 A. Yes . The impact to existing projects will be 24 driven by three interrelated factors : (1) what point in 25 time during the 36+-year horizon the project is in, (2) Maloney, DI 16 Idaho Power Company 1 whether the project' s interconnection facilities are 2 transmission or distribution, and (3) the impact of an 3 increase to the average distribution rate and a decrease in 4 the average transmission rate. 5 Overall, when holistically considering the Company' s 6 proposal, of the 121 non-mixed facility Idaho PURPA 7 projects paying an 0&M Charge at the end of 2024 : 46-5 will 8 be assessed a lower charge (an average decrease of 9 approximately $553-625 per month) and 75-1& will be assessed 10 a higher charge (an average increase of approximately $4-7-3 11 293 per month) . For the five Idaho PURPA projects with both 12 transmission and distribution facilities subject to an O&M 13 Charge as of the end of 2024, their monthly charge will, on I14 average, decrease by approximately $-6�719 . 15 Q. How many projects have reached the 36 plus 16 years and reverted back to the flat rate? 17 A. As of the end of 2024, 40 projects have 18 reached the 36 plus years and accordingly have reverted 19 back to the flat rate. 20 Q. Is the Company proposing to periodically 21 update the new formula rates? 22 A. Yes . As noted above, the Company proposes that 23 the 0&M Charges and corresponding revenue credit would be 24 updated during each general rate case, similar to how it 25 updates Rule M, Facilities Charges . Maloney, DI 17 Idaho Power Company