20251118Direct Michael Louis.pdf

RECEIVED
November 18, 2025
IDAHO PUBLIC
BEFORE THE UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-25-16
AUTHORITY TO INCREASE ITS )
RATES AND CHARGES FOR )
ELECTRIC SERVICE IN THE STATE )
OF IDAHO )
DIRECT TESTIMONY OF MICHAEL LOUIS
IN SUPPORT OF THE STIPULATION
AND SETTLEMENT
IDAHO PUBLIC UTILITIES COMMISSION
NOVEMBER 18, 2025

1 Q. Please state your name and business address for
2 the record.
3 A. My name is Michael Louis . My business address
4 is 11331 W. Chinden Blvd. , Ste . 201-A, Boise, ID 83714 .
5 Q. By whom are you employed and in what capacity?
6 A. I am employed by the Idaho Public Utilities
7 Commission ("Commission") as the Engineering Section
8 Program Manager.
9 Q. What is your educational and professional
10 background?
11 A. Please see a summary of my educational and
12 professional background in Exhibit No . 102 .
13 Q. What is the purpose of your testimony in this
14 proceeding?
15 A. The purpose of my testimony is to explain
16 Staffs support for the proposed Stipulation and
17 Settlement ("Settlement") regarding the allocation of the
18 revenue requirement increase to the customer classes, the
19 design of the rates used to recover the allocation to
20 each of the customer classes, and the future Cost of
21 Service Study docket proposed by the Company, Staff, and
22 intervenors ("Parties") .
23 Q. Please summarize your testimony.
24 A. Staff believes that the allocation of the
25 revenue requirement increase to the customer classes and
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 1
11/18/25 STAFF

1 the rate designs negotiated by the Parties as reflected
2 in the Settlement are fair, just and reasonable .
3 There are three issues important to the
4 agreement : (1) evidence that capital investments included
5 in the Company' s case for recovery are not tied to future
6 large load customers as discussed in Staff Witness Suess'
7 testimony making the CCOS study valid for purposes of
8 spreading the revenue requirement increase in this case,
9 (2) inclusion of a separate docket to be filed by the
10 Company prior to the next general rate case to resolve
11 issues related to class cost-of-service ("CCOS") study
12 methodologies, and (3) the amount of the monthly service
13 charge for residential customers .
14 Other items negotiated by the Parties affected
15 Schedule 9 (Large General Service) and Schedule 19 (Large
16 Power Service) customers include : (1) increases in
17 service charges, (2) a 40% movement of revenue collection
18 through demand-related charges, and (3) adjustments to
19 off-peak time-of-use hours .
20 Q. How is your testimony organized?
21 A. My testimony is structured under the following
22 sections :
23 I . CCOS Methodology and Revenue Allocation Page 3
24 II . Rate Design Page 7
25 III . Other Items related to Rate Design Page 11
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 2
11/18/25 STAFF

I IV. Conclusion Page 12
2 I . CCOS Methodology and Revenue Allocation
3 Q. Please explain the Company' s proposed approach
4 for the allocation of the revenue requirement increase to
5 the customer classes .
6 A. The Company developed a CCOS study based on the
7 proposed revenue requirement using estimates for cost and
8 revenue during a forecasted 2025 test year as explained
9 in Staff Witness English' s testimony. The study provides
10 the amount of revenue increase or decrease each class
11 should pay if each customer class was to pay its full
12 cost of service .
13 To spread the amount of the increase, the
14 Company proposed a cap and spread methodology to allocate
15 the amount of increase to the customer classes . The
16 Company proposed using 130% of the overall percentage
17 revenue requirement increase for the cap and 30% of the
18 overall percentage increase for the floor.
19 At its most basic level, the method limits the
20 amount of the increase for each class to 130% of the
21 overall percentage increase for those classes currently
22 under cost of service but requires an increase over the
23 cap to pay its full cost of service . It also moves all
24 classes up to the floor for classes that require an
25 increase (or decrease) that is below the overall
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 3
11/18/25 STAFF

1 percentage increase to be at their cost of service . Any
2 amount of revenue not fully allocated to the classes at
3 the cap and the floor is spread to the remaining classes
4 on a percentage of revenue basis .
5 Q. Does Staff support the methodology?
6 A. Yes . The method with different caps and floors
7 has been successfully used to determine the class
8 allocation in the Company' s last two general rate cases
9 and for most of the rate cases of other large utilities
10 put before the Commission over the last decade . Staff
11 believes the method aligns with the Commission' s value
12 for rate stability and incrementalism while making
13 movement towards cost of service .
14 Q. Was the cap and spread used to determine the
15 revenue allocation for the Settlement?
16 A. Yes . The CCOS study was used as the basis to
17 spread the revenue requirement increase . Staff performed
18 an analysis showing that the costs included for recovery
19 in this case are not driven by the need to provide
20 service for these new large-load customers as detailed in
21 Staff Witness Suess' Testimony. This analysis showed the
22 validity of the CCOS study and that the results could be
23 used to allocate the revenue requirement for the
24 Settlement .
25 Q. What other important item was negotiated
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 4
11/18/25 STAFF

1 relative to CCOS study methods in the Settlement?
2 A. The Parties agreed to the Company initiating a
3 single-issue case related to CCOS methodology for the
4 Commission' s consideration prior to its next general rate
5 case .
6 Q. Does Staff support the CCOS single issue case?
7 A. Yes . Staff believes that a docket focused on
8 CCOS methodologies is important for several reasons .
9 First, trying to resolve CCOS in a general rate case is
10 difficult due to the focus on developing and supporting
11 the revenue requirement as a first priority. Second,
12 CCOS study methodologies are very complex, making it
13 difficult to understand the appropriateness of different
14 methods and to understand their impact . Third, there are
15 significant consequences and risk of misallocating cost
16 given large load customers that will be driving large
17 investments and costs into the Company' s system. By
18 having a docket focused on CCOS methods prior to the
19 Company filing a Notice of Intent for its next rate case,
20 Staff believes there is a much better chance of
21 identifying the relevant issues and appropriate solutions
22 needing to be addressed when allocating the revenue
23 requirement to the classes in the next several general
24 rate cases .
25 Q. Please summarize the final spread of the
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 5
11/18/25 STAFF

I revenue requirement increase to the customer classes .
2 A. The final rate spread is detailed in Exhibit
3 No . 1 of the Settlement . The cap and spread methodology
4 with a 130% cap (equivalent to a 9 . 89% increase given an
5 overall 7 . 48% increase) and 30% floor (equivalent to a
6 2 . 38% increase) proposed by the Company in their filing
7 was used by the Parties to negotiate a rate spread that
8 the Parties could agree upon.
9 Increases for Residential, Small General
10 Service, and Traffic Control Lighting customer classes
11 are all limited by the cap, while Area Lighting,
12 Municipal Street Lighting, Simplot' s Donn and Caldwell
13 special contracts, and Lamb Weston special contract
14 customers were sufficiently over cost of service to be
15 moved up to the floor. With small adjustments necessary
16 to arrive at a negotiated rate spread agreement,
17 unrecovered amounts after applying the cap and floor were
18 spread to the remaining classes based on the percentage
19 share of their revenue .
20 Q. Do you support the final rate spread?
21 A. Yes . Staff believes the Parties negotiated in
22 good faith and were able to arrive at a rate spread that
23 all Parties could support or at least not oppose .
24 In addition, the amount of the increase for
25 each of the classes stayed within the range established
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 6
11/18/25 STAFF

1 by the cap and spread (2 . 38% - 9 . 89%) that allowed for
2 incremental movements toward cost of service while
3 maintaining rate stability for the Company' s customers . '
4 For these reasons, Staff believes the resulting
5 allocation was fair, just, and reasonable .
6 II . Rate Design
7 Q. Please explain the stipulated changes to the
8 rate design included in the Settlement that were
9 different than the Company proposed in its Application.
10 A. There were three sets of changes to the rate
11 design included in the Settlement that were different
12 than what the Company proposed in its Application: (1)
13 changes to the monthly service charge, (2) changes to
14 demand-charges, and (3) adjustments to the time frames
15 used for Non-Residential Time-of-Use ("TOU") customers .
16 Q. Please explain the changes to the monthly
17 service charges included in the Settlement that differ
18 from the Company' s proposal in its Application.
19 A. The Parties agreed to the changes of the
20 service charges included in the Settlement as summarized
21 in Table No . 1 below. For each class, the table shows
22 the current amount of the service charge, the amount the
23
24 ' The Brisbie special contract received an increase that was above
the cap due to a limited amount of revenue during the test year
25 isolated to take-or-pay Billing Demand revenue until Brisbie enters
its load ramp in 2026.
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 7
11/18/25 STAFF

I Company proposed in its Application, and the amount in
2 the Settlement .
3 Table No. 1 : Summary of Service Charges
4 Customer Classes Current Proposed Settlement
5 Residential (Sched. $15 $25 $15
6 1, 3, 5, 6)
7 Small General $25 $30 $25
8 Service (Sched.
9 7, 8) and Large
10 General Service
11 (Sched. 9S, 9S-TOU)
12 Large General $340 $360 $345
13 Service (Sched.
14 9P, 9T)
15 Large Power Service $85 $125 $110
16 (Sched. 19S)
17 Large Power Service $415 $490 $450
18 (Sched. 19P, 19T)
19 Q. Does Staff support the monthly service charges
20 included in the Settlement?
21 A. Yes . The Parties agreed to maintain the
22 customer charge for residential and small commercial
23 customer at the current rate, while increasing the
24 customer charge for other customers but not up to the
25 amount proposed in the Company' s Application.
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 8
11/18/25 STAFF

1 Staff believes the amount of the monthly
2 service charge is more critical for residential and small
3 commercial customers whose usage can be influenced by
4 price signals through a volumetric rate . The lower the
5 service charge, the higher the volumetric rate and
6 therefore the larger the incentive to conserve energy.
7 However, Staff recognizes that the Company prefers
8 recovery through a higher fixed service charge because it
9 provides higher certainty of cost recovery. To balance
10 both sets of interests, Staff believes the threshold for
11 the service charge should be based on the types of cost
12 that the service charge is commonly assumed to recover,
13 which are categorized as customer-classified costs in a
14 CCOS study. These costs include the costs of billing,
15 meters, and service line connections, which increase for
16 each customer added.
17 To balance the two sets of interests, Staff
18 supports the service charge for residential and small
19 commercial customers in the Settlement because it is
20 close to the customer-classified cost (without
21 distribution) in the Company' s COSS study. 2
22 Staff is less concerned with the amount of
23
24 2 Customer-classified cost (without distribution cost) is $12. 67 per
customer per month for Schedule 1 Residential and $18.88 per
25 customer per month for Schedule 7 Small General Service. See
Maloney DI, Exhibit No.37.
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 9
11/18/25 STAFF

1 service charges for larger customers since the service
2 charge is a much smaller proportion of their total bill,
3 with the largest proportion of their bill being recovered
4 through both volumetric and demand charges . Staff
5 believes the increase in the service charge for these
6 customers is reasonable .
7 Q. Please explain the changes to the monthly
8 demand charges included in the Settlement that differ
9 from the Company' s proposal in its Application.
10 A. The Parties agreed to increase the collection
11 of demand-classified costs for Schedule 9 (Large General
12 Service - Primary and Transmission) , Schedule 19 (Large
13 Power Service) , and Schedule 30 (special contract with
14 the Department of Energy) through the Demand and/or Basic
15 Load Capacity charges .
16 Q. Does Staff support the demand charges included
17 in the Settlement?
18 A. Yes . The changes to the demand charges will
19 collect demand-classified cost to reflect about a 400
20 incremental movement toward cost of service for those
21 pricing components using the CCOS study updated with the
22 settled revenue requirement . Staff believes a movement
23 towards cost of service is appropriate and reasonable .
24 Q. Does Staff support the adjustments to the TOU
25 periods for Schedule 9 (Large General Service) and
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 10
11/18/25 STAFF

1 Schedule 19 (Large Power Service) energy charges included
2 in the Settlement?
3 A. Yes . The change adjusts the Off-Peak hours
4 during the summer season to better align with the lowest
5 market prices that occur from 10 a.m. to 2 p.m. Monday
6 through Saturday and all hours on Sundays and holidays .
7 Mid-Peak hours will also be adjusted to occur from 2 p.m.
8 to 7 p.m. and from 11 p.m. to 10 a.m. Monday through
9 Saturday, except holidays . On-Peak hours will remain as
10 filed from 7 p.m. to 11 p.m. Monday through Saturday,
11 except holidays .
12 Staff believes the adjustments to these hours
13 provide a more accurate price signal by aligning to
14 market prices during different times of the day. This
15 will become more important because the Company is
16 increasingly relying on market to meet its load.
17 III . Other Items Related to Rate Design
18 Q. Please explain the discussions that the Company
19 committed to hold regarding the potential establishment
20 of an Irrigation TOU offering.
21 A. If the Settlement is approved, the Company will
22 immediately initiate collaborative meetings to develop an
23 optional Agricultural Irrigation TOU Service schedule
24 that could be filed as early as January 1, 2026, with an
25 effective date on or after June 1, 2026 .
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 11
11/18/25 STAFF

1 Q. Does Staff support this effort?
2 A. Yes . Due to Irrigation customers driving large
3 summer loads that affect the Company' s peak capacity
4 needs, Staff believes an Irrigation TOU schedule could
5 provide price signals to incentivize Irrigators to shift
6 their load to other hours of the day. Staff also
7 supports the effort because the scope of the discussions
8 will need to reconcile the new schedule with the current
9 irrigation demand response programs and may even displace
10 them if found to be more cost effective for irrigation
11 customers who currently participate in the Irrigation
12 Peak Rewards program.
13 IV. Conclusion
14 Q. Please summarize the conclusions of your
15 testimony.
16 A. I believe that the results of the Settlement
17 with regard to the allocation of the revenue requirement
18 increase to the customer classes and the design of the
19 rates that will be used to recover the revenue
20 requirement were negotiated in good faith by all of the
21 Parties to the Settlement and are fair, just and
22 reasonable . I also believe that the CCOS docket that the
23 Company will initiate in the coming months will be
24 necessary to resolve the issues that will surface in the
25 next general rate case .
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 12
11/18/25 STAFF

1 Q. Does this conclude your testimony in this
2 proceeding?
3 A. Yes, it does .
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
CASE NO. IPC-E-25-16 LOUIS, M. (Stip) 13
11/18/25 STAFF

Professional Qualifications
of
Michael Louis
Program Manager - Engineering
Idaho Public Utilities Commission
EDUCATION
Mr. Louis received his B. S . and M. S . degrees in Industrial
Engineering with concentrations in manufacturing systems and
engineering economics from Purdue University in 1985 and 1992,
respectively. He also received his Masters in Public Policy and
Administration at Boise State University in 2005 . In addition
to his formal education, Mr. Louis has attended Michigan State
University Institute of Public Utilities Annual Regulatory
Studies Program, NARUC Utility Rate School, and Electricity Grid
School .
BUSINESS EXPERIENCE
Mr. Louis is currently and has served 10 years as the Staff
Engineering Program Manager over the Engineering Section at the
Idaho Public Utilities Commission where he has supervised Staff
and worked on a variety of cases to regulate electric, natural
gas, and water utilities . Over his 25 years at the Commission,
his assignments and responsibilities have included cases
involving prudence determination of major utility investments
and power supply cost, integrated resource plans, cost
adjustment mechanisms, reviews of power purchase agreements and
customer special contracts, demand-side management, sales of
utilities and their assets, avoided cost ratemaking for PURPA,
class and jurisdictional cost allocation using cost of service
principles, rate design, and a variety of engineering studies
involving the design and operation of public utility systems . I
have also served as the supervising lead in three General Rate
Cases .
Mr. Louis' work experience also includes 18 years of
industrial/commercial practice at General Motors, Hewlett-
Packard, Jabil Circuit, and Albertsons Companies developing,
managing, and improving manufacturing systems and operations,
planning processes, and supply chains . He has also spent six
years at Boise State University where he administrated and
conducted energy policy research as the Assistant Director of
the Energy Policy Institute and taught classes in program and
project management and Energy Policy in the Department of Public
Policy and Administration.
Exhibit No . 102
Case No . IPC-E-25-16
M. Louis, Staff
11/18/25

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 181h DAY OF NOVEMBER 2025,
SERVED THE FOREGOING DIRECT TESTIMONY OF MICHAEL LOUIS IN
SUPPORT OF THE STIPULATION AND SETTLEMENT , IN CASE NO. IPC-E-25-16,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E. WALKER TIMOTHY TATUM
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
IDAHO POWER COMPANY MATT LARKIN
PO BOX 70 1221 WEST IDAHO STREET
BOISE ID 83707-0070 P.O.BOX 70
E-MAIL: BOISE,ID 83707
dwalkergidahopower.com E-MAIL:
mfzoicoecheaallenkidahopower.com ttatumkidahopower.com
dockets(kidahopower.com caschenbrenner(kidahopower.com
mlarkin(kidahopower.com
CLEAN ENERGY OPPORTUNITIES: CLEAN ENERGY OPPORTUNITIES:
KELSEY JAE COURTNEY WHITE
920 N. CLOVER DRIVE MIKE HECKLER
BOISE, ID 83703 CLEAN ENERGY OPPORTUNITIES FOR
E-MAIL: kelsey(kkelseyjae.com IDAHO
3778 PLANTATION RIVER DR., STE 102
BOISE,ID 83703
EMAIL:
courtneykcleanenergyopportunities.com
mike c(r�,,cleanenergyopportunities.com
IIPA: IIPA:
ERIC L. OLSEN LANCE KAUFMAN,PH.D.
ECHO HAWK&OLSEN,PLLC 2623 NW BLUEBELL PLACE
P.O. BOX 6119 CORVALLIS, OR 97330
505 PERSHING AVE., STE. 100 E-MAIL: lance(kae.isg insi hg t.com
POCATELLO, ID 83205
E-MAIL: elokechohawk.com
BOISE CITY.• BOISE CITY.•
Ed Jewell Katie O'Neil
Deputy City Attorney Energy Program Manager
Boise City Attorney's Office Boise City Attorney's Office
P.O. Box 500 P.O. Box 500
Boise,ID 83701-0500 Boise, ID 83701-0500
eiewellkcityofboise.org koneil(kcityofboise.org
BoiseCityAttorney(kcityofboi se.org
CERTIFICATE OF SERVICE - PAGE 1

FEA: FEA:
Emily W. Medlyn Dwight Etheridge
Jelani A. Freeman Exeter Associates,Inc.
U.S. Department of Energy 10480 Little Patuxent Parkway, Ste. 300
1000 Independence Ave., S.W. Columbia,MD
Washington,D.C. 20585 detheridgekexeterassociates.com
emily.medlyn(khq.doe.gov
j elani.freeman(khq.doe.gov
ICIP:
PETER J. RICHARDSON
RICHARDSON ADAMS, PLLC
515 N. 27"' STREET
BOISE,ID 83702
E-MAIL: peter(cr�richardsonadams.com
MICRON: MaHydro:
Austin Rueschhoff C. Tom Arkoosh
Thorvald A.Nelson Nicholas J. Erekson
Austin W.Jensen Arkoosh Law Offices
Kristine A.K. Roach P.O. Box 2900
Holland&Hart,LLP Boise, ID 83701
555 17"' St., Ste. 3200 tom.arkooshkarkoosh.com
Denver,CO 80202 nick.erekson(karkoosh.com
darueschhoffkhollandhart.com erin.cecil(c_r�,arkoosh.com
tnelsonkhollandhart.com
awj ensenkho llandhart.com
(cr�,�karoachhollandhart.com
ELECTRONIC SERVICE ONLY:
acleekhollandhart.com
tlfriel(khollandhart.com
Gannon, et al.,pro se: Korger:
John Gannon Kurt J.Boehm
johngannon200(kgmail.com Jody Keyle Cohn
Randy Morris occidentalpacifickhotmail.com Boeham,Kurtz&Lowry
Deborah Fease and Amy Lorrance 425 Walnut Street, Suite 2400
feased854(kgmail.com Cincinnati, OH 45202
kboelunkbkllawfirm.com
jkylercohn ckbkllawfirm.com
Northwest Energy Coalition (NWEC) Northwest Energy Coalition (NWEC)
Benjamin J. Otto Lauren McCloy
Attorney for NWEC Utility Regulatory Director
1407 W. Cottonwood Court lauren(knwenergy.org
Boise,ID 83702 Derek Goldman
benknwenergyy.org Policy Associate
derek(knwenergy.org
PATRICIA JORDA14, SECRETARY
CERTIFICATE OF SERVICE - PAGE 2