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HomeMy WebLinkAbout20251024Direct Tatum.pdf RECEIVED OCTOBER 24, 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 TIMOTHY E . TATUM IN SUPPORT OF SETTLEMENT STIPULATION 1 I . INTRODUCTION 2 Q. Please state your name, business address, and 3 present position with Idaho Power Company ("Idaho Power" or 4 "Company") . 5 A. My name is Timothy E . Tatum. My business 6 address is 1221 West Idaho Street, Boise, Idaho 83702 . I am 7 employed by Idaho Power as Vice President of Regulatory 8 Affairs . 9 Q. Are you the same Timothy E. Tatum that 10 previously submitted testimony in this proceeding? 11 A. Yes, I submitted direct testimony on behalf 12 of Idaho Power providing an overview of the Company' s 13 overall rate request in this proceeding. 14 Q. What is the purpose of your testimony? 15 A. My testimony describes the Stipulation and 16 Settlement ("Stipulation") entered into by and among Idaho 17 Power, the Staff of the Idaho Public Utilities Commission 18 ("Staff") , and the following intervenors in this docket: 19 City of Boise, Clean Energy Opportunities for Idaho 20 ("CEO") , Federal Executive Agencies ("FEA") , Idaho 21 Irrigation Pumpers Association, Inc. ("IIPA") , Industrial 22 Customers of Idaho Power ("ICIP") , Kroger Co. ("Kroger") , 23 Micron Technology, Inc. ("Micron") , and NW Energy Coalition 24 ("NWEC") . These entities are referred to individually as a TATUM, DI (Stip) 1 Idaho Power Company 1 "Stipulating Party" or collectively referred to as the 2 "Stipulating Parties . " The signed Stipulation and 3 accompanying exhibits are provided as Attachment 1 to the 4 Company' s Motion for Approval of Stipulation and Settlement 5 and Request for Accounting Order filed contemporaneously 6 herewith. My testimony also expresses Idaho Power' s 7 support for the Stipulation, which settles all issues that 8 arose in this case ("Proposed Settlement") and urges the 9 Commission to adopt the Proposed Settlement without 10 material change or condition. 11 Q. Do you believe that the Proposed Settlement 12 is in the public interest? 13 A. Yes . The Stipulating Parties have agreed to 14 settle the issues identified in the Stipulation, thus 15 indicating their satisfaction with the outcome . From the 16 Company' s perspective, the Proposed Settlement provides the 17 Company with the ability to update its rates to better 18 reflect current costs and a reasonable opportunity under 19 current conditions to finance new investments in 20 infrastructure for its system under relatively reasonable 21 terms and costs . The Company also believes that the rates 22 that result from the Stipulation are just and reasonable 23 for its customers . TATUM, DI (Stip) 2 Idaho Power Company 1 II . BACKGROUND 2 Q. Please describe the Company' s original 3 revenue requirement increase request. 4 A. On May 30, 2025, Idaho Power filed an 5 Application with the Commission seeking authority to 6 increase the Company' s Idaho jurisdictional retail revenue 7 an average of 13 . 09 percent. If the Company' s initial 8 proposal had been approved, the Company' s revenues would 9 have increased by approximately $199 . 1 million annually. 10 Idaho Power proposed spreading the rate increase to varying 11 degrees among all customer classes and special contract 12 customers . Anticipating suspension of the proposed tariff 13 pursuant to Idaho Code § 61-622 (4) and Commission Rule of 14 Procedure' 123 . 03, the Company requested that new rates 15 become effective on January 1, 2026 . Idaho Power notified 16 customers of the requested rate increase via press release 17 and customer notices mailed to individual customers in 18 accordance with the requirements of Procedural Rule 125 . 19 Q. How was this case processed after the 20 Company' s Application was received? 21 A. On June 13, 2025, the Commission issued a 22 combined Notice of Application, Notice of Intervention ' Hereinafter cited as "Procedural Rule" . TATUM, DI (Stip) 3 Idaho Power Company 1 Deadline, and Notice of Suspension of Proposed Effective 2 Date, which also designated the proceeding as a general 3 rate case . Intervenor status was subsequently granted to 4 City of Boise, CEO, FEA, IIPA, IdaHydro, ICIP, Kroger, 5 Micron, NWEC, and John Gannon, Deborah Fease, Amy Lorrance, 6 and Randy Morris ("Gannon, et al . , pro se") . These entities 7 are collectively referred to as the "Parties . " The Parties 8 consulted informally in July to devise a proposed schedule 9 for completing discovery, filing testimony, and holding 10 hearings in this proceeding. The Parties also agreed to 11 engage in settlement discussions in accordance with 12 Procedural Rule 272 with a view toward resolving the issues 13 in this case and tentatively scheduled settlement 14 discussions for September 2025 . 15 Q. Did Staff and other Parties conduct a 16 thorough examination of the Company' s filing? 17 A. Yes . The Staff and Parties conducted 18 extensive discovery on Idaho Power' s filing. Over the 19 course of this proceeding, the Company provided responses 20 to approximately 370 data requests, the majority of which 21 were from Staff. In addition, Staff auditors and engineers 22 met with Company personnel to review the underlying 23 accounting data and capital project documentation that was 24 the basis for the Company' s filed revenue requirement. TATUM, DI (Stip) 4 Idaho Power Company 1 Additionally, Staff conducted on-site visits of certain 2 transmission, distribution, battery, security, and 3 communication projects . 4 III . OVERVIEW OF THE PROPOSED SETTLEMENT 5 Q. How did the Stipulating Parties arrive at 6 the Stipulation? 7 A. On September 2, 2025, Commission Staff 8 provided notice of settlement negotiations to all Parties 9 of record. All Parties were given an opportunity, whether 10 in person or virtually, to participate in or be apprised of 11 the course of settlement negotiations, which were held on 12 September 9, September 29, and October 6, 2025 . The 13 Stipulation is the product of the settlement discussions 14 held on those dates . 15 Q. Have all Parties in this case joined in the 16 Stipulation? 17 A. No . Gannon, et al . , pro se, and IdaHydro did 18 not join in the Stipulation; the former has indicated it 19 will not object to the settlement while the latter has not 20 indicated a position. 21 Q. Does the Company believe the Proposed 22 Settlement is fair, just, and reasonable? 23 A. Yes . It represents a compromise among 24 differing points of view, with concessions made by each TATUM, DI (Stip) 5 Idaho Power Company 1 Stipulating Party, to reach a balancing of interests and 2 has broad-based support from a variety of stakeholder 3 interests including Staff, City of Boise, CEO, FEA, IIPA, 4 ICIP, Kroger, Micron, and NWEC. In addition, the Proposed 5 Settlement is supported by the extensive audit work 6 conducted through the discovery process, including various 7 onsite and virtual conference discussions with Commission 8 Staff, and diligent, good-faith negotiations by the 9 Stipulating Parties in this proceeding. 10 Q. What is the Idaho jurisdictional revenue 11 increase to which the Stipulating Parties agree? 12 A. The Stipulating Parties agree that Idaho 13 Power shall be allowed to increase annual Idaho 14 jurisdictional retail revenues by approximately $110 15 million, or 7 . 48 percent, effective January 1, 2026 . 16 Q. Please describe the Stipulation' s terms 17 related to cost of capital . 18 A. The Stipulating Parties agreed to a 9 . 6 19 percent return on equity ("ROE") and a 7 . 410 percent 20 overall rate of return ("ROR") based on the filed cost of 21 debt and capital structure. This cost of capital adjustment 22 served to reduce the Company' s rate request by $27, 687, 577 . 23 Q. What are the Stipulation' s terms related to 24 rate base? TATUM, DI (Stip) 6 Idaho Power Company 1 A. The Stipulating Parties agreed to an 2 authorized Idaho jurisdictional rate base of 3 $4, 881, 563, 721 . This rate base value reflects the following 4 adjustments to plant in service, which reduced the test 5 year revenue requirement by $21, 605, 673 : 1) modification to 6 the plant forecast from a 13-month average to a December 7 2025 average of monthly averages ("AMA") utilizing actual 8 plant additions for January through July 2025, 2) the 9 removal of the annualizing adjustments associated with 10 projects over $2 million, 3) updating the forecast for 11 projects under $2 million based on actual plant additions 12 for January through July 2025, 4) removal of the C. J. 13 Strike Boat Barrier project, which is not expected to close 14 to plant in 2025, and 5) removal of the Wood River Valley 15 ("WRV") distribution line . In addition, the Stipulating 16 Parties agreed to reduce the filed request by $1, 411, 447 to 17 reflect higher actual customer advance balances as of July 18 2025 compared to the forecasted balances included in the 19 original filing as well as a further reduction to the filed 20 request of $986, 816 to include the Boardman to Hemingway 21 seller' s security deposit received from the Bonneville 22 Power Administration ("BPA") . The combined impact of the 23 stipulated rate base adjustments reduced the Company' s rate 24 request by $24, 003, 936 . TATUM, DI (Stip) 7 Idaho Power Company I Q. What are the Stipulation' s terms related to 2 revenue forecast? 3 A. The Stipulating Parties agreed to reduce the 4 filed request by $9, 054, 540 to reflect an update to the 5 revenue forecast based on normalized actual sales revenue 6 through July 2025 . 7 Q. What are the Stipulation' s terms related to 8 expenses? 9 A. The Stipulating Parties agreed to three 10 categories of expense adjustments that when combined 11 totaled a $6, 456, 796 reduction to the Company' s rate 12 request. The categories of expense adjustments are as 13 follows : 1) Executive Compensation, Training, and Travel, 14 2) Board of Directors Comp and Expenses, 3) Miscellaneous 15 Administrative and General Expenses Adjustments . The 16 rationale for each of these adjustments is detailed in the 17 Stipulation. 18 Q. What are the Stipulation' s terms regarding 19 deferrals and other rate mechanisms? 20 A. The Stipulating Parties agreed to five 21 separate revenue requirement adjustments that either adjust 22 the timing of cost recovery or move recovery to other rate 23 mechanisms . The total net impact of these adjustments is a 24 reduction to the Company' s rate request of $21, 879, 691 . The TATUM, DI (Stip) 8 Idaho Power Company 1 revenue requirement adjustments in this category are as 2 follows : 1) Wildfire operations and maintenance ("O&M") 3 Adjustment, 2) Insurance Base, 3) Wildfire Deferral 4 Amortization, 4) Net Power Cost Update - Gas Prices, and 5) 5 Net Power Cost Update - Energy Imbalance Market ("EIM") . 6 The rationale for each of these adjustments is detailed in 7 the Stipulation. 8 Q. What are the Stipulation' s terms regarding 9 the class cost of service to be used to inform class- 10 specific cost allocation and rate design? 11 A. The Stipulating Parties do not agree on any 12 particular cost-of-service methodology. The Company' s 13 filed cost-of-service methodology, updated to reflect 14 customer, energy, and demand allocators based on January 15 through July normalized actuals and the settled revenue 16 requirement ("Settlement CCOS Study") , has been utilized on 17 a limited basis to inform a starting point for revenue 18 allocation, Schedule 9, Schedule 19, and Schedule 30 rate 19 design, Fixed Cost Adjustment ("FCA") rates, the Sales 20 Based Adjustment Rate ("SBAR") used in the Power Cost 21 Adjustment ("PCA") , special contract pricing, and optional 22 service offerings including Schedules 31, 45, 46, and 62 . 23 Q. Please describe the Stipulation' s terms 24 related to revenue spread. TATUM, DI (Stip) 9 Idaho Power Company 1 A. The Stipulating Parties agree that the 2 above-described $110 million revenue increase should be 3 recovered by implementing tariffs in conformance with the 4 Rate Spread set forth in Exhibit No. 1 to the Stipulation. 5 The revenue allocation was generally developed using a 6 method to increase the prices for each customer class 7 ranging between approximately 0 . 3 times (2 . 38 percent) to 8 1 . 3 times (9 . 89 percent) of the overall 7 . 48 percent 9 increase. 10 Q. Please describe the Stipulation ' s terms 11 related to rate design. 12 A. For settlement purposes, the Stipulating 13 Parties agree to the rate design and related tariff 14 provisions proposed by the Company in Mr. Anderson' s direct 15 testimony, updated to reflect the Settlement CCOS Study, 16 with the following exceptions : 17 Service Charges : The Stipulating Parties agree the 18 existing $15 Service Charge will be retained for Schedule 1 19 (Residential Service Standard Plan) , Schedule 3 (Master- 20 Metered Mobile Home Park Residential Service) , Schedule 5 21 (Residential Service - Time-of-Use Plan) , and Schedule 6 22 (Residential Service On-Site Generation) . The existing $25 23 Service Charge will be retained for Schedule 7 (Small 24 General Service) , Schedule 8 (Small General Service On-Site TATUM, DI (Stip) 10 Idaho Power Company 1 Generation) , and Schedule 9 (Large General Service - 2 Secondary) . For Schedule 9 (Large General Service - Primary 3 and Transmission) , a Service Charge of $345 will be 4 implemented, for Schedule 19 (Large Power Secondary 5 Service) , a Service Charge of $110 will be implemented, and 6 for Schedule 19 (Large Power - Primary and Transmission 7 Service) , a Service Charge of $450 will be implemented. 8 Demand-Related Charges : For Schedule 9 (Large 9 General Service - Primary and Transmission) , Schedule 19 10 (Large Power Service) , and Schedule 30 (Electric Service 11 Rate for United States Department of Energy Idaho 12 Operations Office) , the collection of demand-classified 13 costs through the Demand and/or Basic Load Capacity charges 14 will reflect an approximate 40 percent movement toward cost 15 of service for that pricing component, as informed by the 16 Settlement CCOS Study. 17 Non-Residential Time-of-Use ("TOU") : For Schedule 9 18 (Large General Service) and 19 (Large Power Service) , the 19 TOU periods will be adjusted as follows : On-Peak hours will 20 remain consistent with the Company' s filed position, Off- 21 Peak hours will be defined as 10 a.m. to 2 p.m. , Monday 22 through Saturday and all hours on Sundays and Holidays; and 23 Mid-Peak hours will include all hours not designated as On- 24 Peak or Off-Peak. The method for establishing the TATUM, DI (Stip) 11 Idaho Power Company 1 differentials between On-Peak, Mid-Peak, and Off-Peak will 2 remain consistent with the Company' s filed position. 3 Q. Are there any other non-revenue items to 4 which the Stipulating Parties agreed in the Stipulation? 5 A. Yes . There are several other non-revenue 6 stipulated agreements made by the Stipulating Parties, 7 which are summarized as follows and more fully set forth in 8 the Stipulation: 9 Single Issue COOS Case. The Stipulating Parties 10 agree that it would be appropriate for the Commission to 11 address the COOS methodology and associated policy issues 12 in a separate proceeding in which alternatives to the 13 Company' s filed CCOS methodology in this case, including a 14 CCOS study with an hourly-informed class allocation of 15 Production and Transmission revenue requirement, will be 16 presented for the Commission' s consideration. To this end, 17 Idaho Power agrees to initiate a single-issue case related 18 to CCOS methodology for the Commission' s consideration 19 ("Single Issue CCOS Case") in advance of filing a Notice of 20 Intent for its next General Rate Case ("GRC") but in no 21 event later than the end of the first quarter of 2026 . 22 Test Year Methodology Workshop. In advance of the 23 Company' s next GRC, Staff will initiate a workshop with 24 Idaho Power and interested parties to discuss test-year TATUM, DI (Stip) 12 Idaho Power Company 1 method. 2 Irrigation TOU. Idaho Power commits to immediately 3 initiate collaborative discussions with the IIPA, and other 4 interested parties, with the intent of developing an 5 optional Agricultural Irrigation Service (Schedule 24) TOU 6 offering that could be filed for Commission approval as 7 early as January 1, 2026, with the newly established rate 8 structure becoming effective on or after June 1, 2026 . 9 Capital Investments . At the time of this 10 Stipulation, Staff had completed its prudence review of 11 capital projects included in the test year rate base 12 through July 2025 . Except as otherwise noted in this 13 Stipulation, all capital projects included in the Company' s 14 test year are presumed to be prudently incurred. To the 15 extent Staff identifies potential prudence concerns with 16 capital investments after July 2025, it will address those 17 in the Company' s next GRC. 18 WRV Distribution Line . The Stipulating Parties agree 19 to remove the costs associated with the distribution 20 undergrounding portion of the WRV project from the revenue 21 requirement. In consideration of this removal, the 22 Stipulating Parties agree that the Company shall retain the 23 distribution undergrounding portion of the WRV project in 24 Construction Work in Progress ("CWIP") until the entire TATUM, DI (Stip) 13 Idaho Power Company 1 project (distribution and transmission) is completed and 2 placed in service. 3 NPSE Base and PCA. For purposes of calculating the 4 PCA, the new system-level base NPSE is $468, 840, 624 . The 5 decrease to base NPSE from current levels results in the 6 transfer of $13 . 1 million from base rates to the PCA. 7 Fixed Cost Adjustment ("FCA") . In determining the 8 fixed cost per customer ("FCC") and fixed costs per energy 9 ("FCE") to be tracked through the Company' s FCA, the 10 Stipulating Parties agree to use the Settlement CCOS Study. 11 Sales Based Adjustment Rate ("SBAR") . In determining 12 the agreed-upon SBAR to be applied in the Company' s PCA, 13 the Stipulating Parties agree to use the Settlement CCOS 14 Study to determine the generation-related Idaho 15 jurisdictional revenue requirement that has been classified 16 as energy-related. The resulting SBAR of $27 . 82 per 17 megawatt-hour was developed using 2025 normalized Idaho 18 test year retail sales in the amount of 15, 497, 724 19 megawatt-hours ("MWh") as proposed by the Company in this 20 case . 21 Wheeling Revenue. The Stipulating Parties agree to a 22 baseline wheeling tracker level of collection of $3 . 38 per 23 MWh. This reflects Idaho jurisdictional point-to-point 24 wheeling revenues of $52, 329, 358 divided by Idaho TATUM, DI (Stip) 14 Idaho Power Company 1 jurisdictional retail sales of 15, 497, 724 MWh. 2 Valmy and Bridger. The Stipulating Parties agree 3 that the stipulated revenue requirement includes updated 4 recovery associated with both the Valmy and Bridger 5 mechanisms and reflects updated 0&M and coal-related 6 capital forecasted spend, as well as the true-up of 7 variances between prior forecasts and actual costs through 8 2024 . Also, The Stipulating Parties acknowledge that in 9 addition to the rate recovery update, the discussion 10 related to the Valmy coal-related investments provided in 11 Mr. Adelman' s direct filed testimony satisfies the 2024 12 annual reporting required by Order No. 34349 . 13 Rule H Three Phase Base Charge. The Stipulating 14 Parties agree to implement the following three phase base 15 charges : $80 (underground) , $1, 072 (overhead including 2" 16 riser) , and $1, 352 (overhead including 3" riser) , effective 17 January 1, 2026 . Idaho Power will update charges annually 18 when it submits its annual Rule H compliance filing on or 19 before December 31 of each year . 20 Q. What are the details related to the 21 agreement reached by Stipulating Parties regarding the 22 Company' s authority to accelerate amortization of 23 Accumulated Deferred Investment Tax Credits ("ADITC") ? 24 A. Since 2009, the Company has been subject to TATUM, DI (Stip) 15 Idaho Power Company 1 an ADITC/Revenue Sharing Mechanism, which was established 2 by Order No. 30978 in Case No. IPC-E-09-30 and modified and 3 extended by Order No. 32424 in Case No. IPC-E-11-22, Order 4 No . 33149 in Case No. IPC-E-14-14, Order No. 34071 in Case 5 No . GNR-U-18-01, and Order No. 36042 in Case No. IPC-E-23- 6 11, that includes provisions for the accelerated 7 amortization of ADITC to help achieve a minimum specified 8 percent Idaho-jurisdiction return on year-end equity 9 ("Idaho ROE") , currently set at 9 . 12 percent. The mechanism 10 also provides for the potential sharing between Idaho Power 11 and Idaho customers of Idaho jurisdictional earnings in 12 excess of a 9 . 6 percent Idaho ROE. Under the current 13 mechanism, the ADITC usage and earnings sharing thresholds 14 are to be reset at a GRC to align the sharing threshold 15 with the newly authorized ROE and the threshold for use of 16 accelerated amortization of ADITC if the Company' s Idaho 17 ROE falls below 95 percent of the authorized ROE. 18 Under this Stipulation, the ADITC/Revenue Sharing 19 Mechanism is modified to include an additional amount of 20 ADITC equal to the total of existing ADITC not currently 21 eligible for accelerated amortization under the mechanism 22 and all investment tax credits generated through the end of 23 calendar-year 2028 . Further, the Stipulating Parties agree 24 that the maximum allowed annual accelerated amortization of TATUM, DI (Stip) 16 Idaho Power Company 1 ADITC will be $55 million for calendar year 2026 and 2 thereafter. Effective January 1, 2026, revenue sharing 3 between Idaho Power and Idaho customers of Idaho- 4 jurisdictional earnings will occur if earnings are in 5 excess of a 9 . 6 percent Idaho ROE, and all revenue sharing 6 will continue to be implemented through the PCA at the 7 existing ratio of 80 percent to customers and 20 percent to 8 Idaho Power. The new minimum-specified Idaho ROE is set at 9 95 percent of the stipulated 9 . 6 percent, or 9 . 12 percent. 10 IV. EVALUATION OF THE PROPOSED SETTLEMENT 11 Q. Why was the Company willing to accept in 12 settlement a lower general rate increase than it initially 13 filed? 14 A. In her direct testimony, Ms . Lisa Grow 15 explained how Idaho Power works hard to help keep its 16 prices affordable for its customers by ensuring its 17 necessary investments to maintain and operate the electric 18 system safely and reliably for customers are least cost and 19 least risk and by applying a disciplined and thoughtful 20 approach to managing its ongoing O&M expenses . Idaho Power 21 participated in the settlement negotiations with those same 22 principles in mind and believes that the Proposed 23 Settlement strikes an appropriate balance between 24 affordability for customers and maintaining the financial TATUM, DI (Stip) 17 Idaho Power Company 1 health of Idaho Power under current conditions . The $110 2 million revenue increase will provide additional cash flow 3 to help support credit metrics in the near-term, thus 4 helping with the cost of financing, and the additional 5 ADITC provisions and deferral authorizations will provide 6 further support to the Company' s earnings until the 7 effectiveness of the next general rate case . 8 Although the Proposed Settlement is a reasonable 9 resolution of a broad range of contested rate issues, the 10 agreement will require the Company to continue to manage 11 ongoing inflationary pressures on its expenses and be 12 thoughtful in its capital markets transactions as well as 13 with its credit ratings . 14 Q. Were there other reasons why the Company was 15 willing to accept a lower revenue requirement? 16 A. Yes . In consideration of the settlement 17 terms, the Company recognized that the adjustments related 18 to wildfire mitigation and insurance cost deferrals and the 19 reclassification of the WRV distribution line from rate 20 base to CWIP will have no material impact to the Company' s 21 earnings, as these adjustments serve to either adjust the 22 timing of cost recovery or move recovery to other rate 23 mechanisms . It will, however, have an adverse impact on 24 cash collection in the near-term, and could therefore TATUM, DI (Stip) 18 Idaho Power Company 1 pressure credit metrics, but the deferral is nonetheless 2 helpful overall . 3 Q. Please explain the Company' s acceptance of 4 an overall rate of return that was less than originally 5 requested. 6 A. When considered in the context of the entire 7 settlement agreement, Idaho Power believes that the agreed- 8 upon rate of return will still allow the Company to finance 9 its electric utility operations in the near-term under 10 relatively reasonable terms and costs, based on its 11 experience in recent capital markets transactions . 12 Q. Do you have any observations regarding the 13 revenue spread provided for in the Stipulation? 14 A. Yes . Idaho Power believes that it is 15 important to have rates that reflect the costs to serve its 16 individual classes of customers . With that said, the 17 Company also recognizes that there are many differing views 18 regarding class cost-of-service methodologies . In order to 19 facilitate settlement and avoid potentially contentious 20 issues, the Company has agreed to a rate spread method that 21 it believes represents some targeted movement toward cost- 22 of-service while also mitigating the rate increase assigned 23 to any one customer class . TATUM, DI (Stip) 19 Idaho Power Company 1 V. CONCLUSION 2 Q. Do you have any concluding remarks regarding 3 the Proposed Settlement? 4 A. Yes . During this proceeding the Company 5 experienced a willingness by the Commission Staff and the 6 other Parties to address the issues in this case in a 7 straight-forward manner and to approach the possibility of 8 settlement in a productive way. The Company is very 9 appreciative of these efforts by Staff and the other 10 Parties . The Proposed Settlement was the product of the 11 give-and-take of negotiation that achieved a fair, just and 12 reasonable compromise of the issues . In addition, it is 13 supported by the evidence demonstrating the need for rate 14 adjustments to provide recovery of necessary expenditures 15 and investment, the costs of which are not offset by a 16 growth in sales margins . The Proposed Settlement offers a 17 reasonable balance between the Company' s opportunity to 18 earn a reasonable return on its investment and affordable 19 rates for customers and is in the public interest. 20 Q. Does this conclude your testimony? 21 A. Yes, it does . 22 23 TATUM, DI (Stip) 20 Idaho Power Company 1 DECLARATION OF TIMOTHY E. TATUM 2 I, Timothy E . Tatum, declare under penalty of 3 perjury under the laws of the state of Idaho: 4 1 . My name is Timothy E. Tatum. I am employed 5 by Idaho Power Company as the Vice President of Regulatory 6 Affairs . 7 2 . On behalf of Idaho Power, I present this 8 pre-filed direct testimony in this matter. 9 3 . To the best of my knowledge, my pre-filed 10 direct testimony is true and accurate. 11 I hereby declare that the above statement is true to 12 the best of my knowledge and belief, and that I understand 13 it is made for use as evidence before the Idaho Public 14 Utilities Commission and is subject to penalty for perjury. 15 SIGNED this 24th day of October 2025, at Boise, 16 Idaho . 17 18 Signed: 19 Timothy E . Tatum 20 21 22 23 24 TATUM, DI (Stip) 21 Idaho Power Company