20251118Direct White.pdf

Kelsey Jae (ISB No. 7899) RECEIVED
Law for Conscious Leadership November 18, 2025
920 N. Clover Dr. IDAHO PUBLIC
Boise, ID 83703 UTILITIES COMMISSION
Phone: [phone]
kelsey&kelseyj ae.com
Attorney for Clean Energy Opportunities for Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES CASE NO. IPC-E-25-16
AND CHARGES FOR ELECTRIC SERVICE IN
THE STATE OF IDAHO AND AUTHORITY TO
IMPLEMENT CERTAIN MEASURES TO
MITIGATE THE IMPACT OF REGULATORY LAG
DIRECT TESTIMONY OF COURTNEY WHITE
IN SUPPORT OF SETTLEMENT STIPULATION
ON BEHALF OF CLEAN ENERGY OPPORTUNITIES FOR IDAHO
1
2 I. Identification. Purpose & Recommendation
3
4 Q. Please state your name and business address.
5
6 A. Courtney White, Managing Director, Clean Energy Opportunities for Idaho, 3778 N
7 Plantation River Dr, Boise, ID 83714.
8
9 Q. What is the purpose of your testimony?
10
11 A. As a parry to this case, Clean Energy Opportunities for Idaho (CEO) signed on to the
12 Settlement Agreement filed October 24, 2025. My testimony speaks to CEO's support for the
13 Settlement. I specifically comment on two stipulations: the change in non-residential time-of-use
14 (TOU) time periods, and the single issue Class Cost of Service (CCOS) docket.
15
16 Q. Please summarize your recommendation.
17
18 A. In CEO's opinion, the Agreement represents a compromise that is just, fair, reasonable, and in
19 the public interest. CEO supports its adoption without change.
20
Case No. IPC-E-25-16 White,Direct-Clean Energy Opportunities for Idaho 1

1 II. Term 8c: Non-Residential Time-of-Use (TOU) Time Periods
2
3 O. Please describe Term 8c of the Settlement Agreement.
4 A. Term 8c of the of the Settlement Agreement(Stipulation 8c) describes:'
5 For Schedule 9 (Large General Service) and 19 (Large Power Service), the TOU periods
6 will be adjusted as follows: On-Peak hours will remain consistent with the Company's filed
7 position, Off-Peak hours will be defined as 10 a.m. to 2 p.m., Monday through Saturday
s and all hours on Sundays and Holidays; and Mid-Peak hours will include all hours not
9 designated as On-Peak or Off-Peak.
10 The updated non-residential TOU time windows are designed to reflect not only the hours of high
11 reliability risks but also the hours in which energy costs are particularly low and capacity is not
12 constrained.
13 Q. Please describe how You have organized your comments with regard to Term 8c.
14 A. With regard to the updated non-residential TOU time windows, I speak to 4 topics:
15 a) Emergence of a low-cost daytime window.
16 b) Consistency with IRP findings.
17 c) Future resilient.
d) More actionable.
19 Q. Please provide your comments with regard to Term 8c and the topics you've identified above.
20 a) Emergence of a low-cost daytime window.
21 Market price forecasts demonstrate the emergence of an exceptionally low-price window around
22 10am to 2pm when solar supply is high relative to demand. Consider, for example, this visual
23 below(Figure 1)presented in IPC-E-24-44 White Surrebuttal p6. This compares reliability risks
24 and projected market prices across 24 hours in summer. The rates and time periods proposed in the
25 IPC-E-25-16 application are presented for comparison. This illustration is not purposed for
26 evaluating rates but for comparing the patterns across a 24-hour day. One can see that the existing
27 Schedule 19 On-Peak hours align with high Loss of Load Probability risks, yet the existing
28 15-hour long Off-Peak window does not align with the daily dip in market prices. Stipulation 8c
29 modifies these time periods to better reflect a daytime window of relatively low marginal costs.
30
31
32
33
' Settlement Agreement,p10-11.
Case No. IPC-E-25-16 White,Direct-Clean Energy Opportunities for Idaho 2

Figure 1:Schedule 19S proposed summer rates relative to Avg Mid-C Prices(2026-2030) and Loss of Load
Probability(LOLP,secondary axis)by Hour of day for Summer(Jun-Sep) LOLP Average
�M Wh The existing Schedule 19 Off Peak Time Period is (indicative of capacity cost drivers)
15 hours in Summer(Midnight to 3pm).Marginal
80 costs at night are substantially different than = E^<
during early to mid day.A Time Period offering a ___ O_n Peak
70 dip in rates during day hours is needed. u
jpattern)
60
�--� Off Peak 50
40 Schedule 19S30 rates proposed in202025 GRC(for Mid-A g Mark t prices
illustration of Time (indicative of hourly marginal cos
10 Periods)
0
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Hour ending
Source:8760 Mid-C data,20231RP Data,sourced from IPC-E-24-23;8760 LOLP data from IPC response to Staff PR 34b,lPC-E-23-14;avgof 6 test years;CEO calc ofaverages
proposed rates from IPC-E-25-16 Application,pdf p62 Schedule 19 Secondary Service Energy Rates
1
2 b) Consistency with IRP findings.
3 In preparing the 2023 IRP, the Company modeled a"Load Flattening" scenario to compare costs if
4 demand shifted from peak hours into lowest demand hours. That scenario shifted load to
5 night-time hours and resulted in higher portfolio costs. In the 2025 IRP, the Company modeled a
6 "Load Shift" scenario that moved load out of the 6pm-IOpm hours in summer and into the I Oam—
7 2pm hours when the supply of solar on the grid relative to demand creates a low-cost window.
8 That scenario resulted in lower portfolio costs.
9 c) Future resilient.
10 There is a global movement toward rate designs with deep valley rates corresponding to daytime
11 hours when marginal costs are low. For example, in addition to U.S. tariffs, China is moving
12 toward TOU with ultra-low rates during day hours associated with surplus solar. Consider the
13 following two excerpts related to the province of Shandong:
14 These "deep off-peak"prices offer discounts of up to 90%, incentivizing users to shift
15 energy-intensive operations to midday hours and increase consumption of surplus
16 renewable energy. In 2024 alone, this pricing strategy helped the provincial grid add up to
17 5.84 million kilowatts of midday load and absorb an additional 2.3 billion kilowatt-hours
18 of solar and wind power—significantly easing grid pressure and boosting efficiency.2
19 Specific to industrial customers:
2 The Paper,New Energy Era,31 July 2025.
20 hM2s://www.12etromineralscop2.com/blo2s-shandong-becomes-first-in-china-to-offer-ultra-low-deep-off-peak-electricity-r
21 ates-as-low-as-0-2-yuan-per-kwh-931452.html.
Case No. IPC-E-25-16 White,Direct-Clean Energy Opportunities for Idaho 3

I This more refined time segmentation has created a powerful economic incentive. In the
2 industrial sector, manufacturers are using smart upgrades and flexible scheduling to shift
3 high-energy processes to cheaper time slots, significantly lowering electricity costs.3
4
5 d) More actionable.
6 Narrowing the lowest-cost time window can create a higher differential between the highest and
7 lowest cost hours of the day, which allows greater opportunity for customers to financially benefit
a when they provide system benefits via load shifting, storage, or other forms of demand flexibility.
9 Such load shifting can both reduce energy costs and improve overall system utilization, changes
10 which are clearly in the public interest.
11
12 III. Term 10: Single Issue CCOS Case
13
14 Q. Please describe Term 10 of the Settlement Agreement.
15 A. Term 10 of the Settlement Agreement(Stipulation 10)provides for a future docket to review
16 CCOS methodology and associated issues:
17 The Stipulating Parties agree that it would be appropriate for the Commission to address
18 the CCOS methodology and associated policy issues in a separate proceeding in which
19 alternatives to the Company's filed CCOS methodology in this case, including a CCOS
20 study with an hourly-informed class allocation of Production and Transmission revenue
21 requirement,will be presented for the Commission' s consideration.'
22 Q. Please describe how you have organized your comments with regard to Term 10.
23 A. With regard to this stipulation agreement term, I speak to 4 topics supporting the scope and
24 efficacy of such a future CCOS docket:
25 a) Specific inclusion of an hourly-informed CCOS methodology is appropriate.
26 b) Substantial reviews of CCOS have occurred outside of GRC dockets and/or when the
27 GRC application presented multiple methodologies.
28 c) The public interest is not served by continuing to solely rely on the allocation policies
29 presented in the IPC-E-25-16 application.
30 d) In future proceedings, Commission guidance and staff facilitation play an increasingly
31 key role to ensure a growing asymmetry of influence over regulatory proceedings does
32 not tilt the balance of fairness.
33
34
s Ibid.
4 IPC-E-25-16 Settlement Agreement,p11.
Case No. IPC-E-25-16 White,Direct-Clean Energy Opportunities for Idaho 4

I O. Please provide your comments with regard to Term 10 and the topics you've identified above.
2 a) The specific inclusion in the stipulation of"an hourly-informed class allocation of
3 Production and Transmission" is an appropriate component of any future CCOS docket.
4 In the 2023 GRC (IPC-E-23-11), the parties agreed to hold workshops to specifically address the
5 development of an"Hourly Informed Class Cost of Service," stating in that Settlement
6 Agreement:'
7 The second series of workshops will address three topic areas based upon analysis
s provided by CEO and others class cost-of-service study methodology and analysis
9 including development of an"Hourly Informed Class Cost of Service (CCOS)"
10 methodology that assesses what resources are used to serve system load in each hour of the
11 test year, the cost of those resources in each hour(including analysis of impacts of
12 transmission& distribution functionalization, financing cost allocations, and
13 hydrogeneration forecasting), and how those costs are associated with customer load in
14 each hour(to be used for comparison to the one observation per month 12 Coincident Peak
15 ("CP")/4CP CCOS methodology used in Case No. IPC-E-23-11.
16 Via follow-up presentations, emails, workshops, and a summary report, the development of an
17 hourly informed CCOS methodology has been more thoroughly vetted among parties than any
18 other alternative to the Company's CCOS methodology that could be presented in a future CCOS
19 docket. The inclusion of references to an hourly informed CCOS being addressed in a future
20 CCOS docket is an essential component of settlement term 10.
21
22 b) Looking back over 20 years, a substantial review of cost allocation methodologies has
23 either been deferred to a process outside the GRC and/or the GRC application
24 presented multiple methodologies.
25 For example, consider the following history:
26 • In the 2003 GRC, cost of service issues were raised. The Commission ordered a new
27 docket to address those issues (Order 29505), which led to Case No. IPC-E-04-23 for
28 the purpose of evaluating cost-of-service issues.
29 • In the 2005 GRC, the Company presented 2 alternative CCOS methodologies informed
30 by workshops held in 2004 & 2005.
31 • In the 2008 GRC, the Company proposed 3 alternative CCOS methodologies.
32 • Prior to the 2023 GRC, CEO met with PUC staff and the Company to discuss when
33 alternative cost allocation methodologies should be reviewed. Our understanding from
34 discussion with staff and the Company was that the next GRC would be the forum for
35 such a review.
5 IPC-E-23-11 Settlement Agreement,Stipulation 13,pl 1.
Case No. IPC-E-25-16 White,Direct-Clean Energy Opportunities for Idaho 5

1 • In the 2023 GRC, the Settlement Agreement noted that review of hourly informed cost
2 allocation methodologies would occur in workshops to be held after the 2023 GRC.
3 • CEO Final Comments in IPC-E-23-11 recommended that a review of hourly costs was
4 needed to supplement the Company's (12CP/4CP) method. The comments stressed:
5 CEO believes that there shouldn't be another rate case filed by the Company
6 that is not informed by a cost to serve analysis reflecting the costs to serve load
7 in all hours of the test year.6
a • In 2024, CEO held workshops during which an hourly informed methodology for cost
9 of service was presented and discussed. CEO published a report to the parties which
10 found:
11 When compared to the traditional 12CP/4CP method, the magnitude of
12 differences in class allocations that arise from use of an hourly informed cost
13 of service method are substantial, challenging the appropriateness of
14 continuing to solely rely on a 12CP/4CP method, as it was employed in Idaho
15 Power's 2023 General Rate Case (GRC), in future general rate cases.7
16 • In 2025, the Company filed a GRC informed by a singular, traditional CCOS. This
17 proposed Settlement Agreement stipulates that review of Cost of Service will be
18 deferred to a separate single-issue docket which is to be instigated on a specific timeline.
19 CEO does not suggest that changes to allocation policies should not be considered during a GRC.
20 We point to history and our direct experience as evidence of the difficulty intervenors face in
21 advocating for changes to allocation policies or even the presentation of alternatives, particularly
22 when the customer classes who stand to benefit from those alternatives are not directly
23 represented.
24
25 c) Public interest will not be served if a future application for a rate increase is solely
26 informed by the allocation policies presented in the IPC-E-25-16 application.
27 The Company's traditional class cost allocation policies spread higher than average increases to
28 small customers and lower than average increases to large customers. Consider the spread of
29 revenue increases proposed by the Company in the IPC-E-25-16 application. Figure 2 visually
30 displays the Company's proposed increase in revenue in mills/kWh across customer classes. For
31 example, the Company proposed in its application that Small General Service customers should
32 bear an increase of 24.5mills/kWh(or 2.45 cents per kWh), an increase which is over 7 times
33 higher than the 3.3mills/kWh(or 0.3 cents per kWh) increase proposed for Special Contracts.
6 IPC-E-23-11,CEO Final Comments,p7.
CEO,IPC-E-23-11 Follow-up:An Hourly Informed Bulk Power System COS Alternative,distributed via email 12/16/24.
Case No. IPC-E-25-16 White,Direct-Clean Energy Opportunities for Idaho 6

Figure 2: IPC 2025 GRC Application: Proposed increase in billed revenue (demand and
energy) per kWh across classes relative to current billed revenue
160
245 ❑Proposed increase, mills/kWh
1 40 ❑ Current Billed Revenue, in mills/kWh
z1.o
20.9 F2a2
120 F19.5 19.3
17.3
100 9
6.4
80 7.3
141.6 0 3.3
60 124.2 116.9 116.4
112.1 111.0
99.6 96.6
40 87.5
67.9
20
Small Small Residential Residential Residential Master- Agricultural Total Retail Large Large Power Special
General General On-Site Gen Service TOD Mobile Irrigation Sales(All General Service Contracts
Service Service On- Home Park customer Service
Site Gen average)
Source: IPC-E-25-16 Application,Attachment 3,Summary of Revenue Impact Current Billed Revenue to Proposed
Billed Revenue, p239 of pdf;chart prepared by CEO
1
2
3 However, special
4 contracts are driving Special contracts are driving growth
5 growth. The Project Growth in Load
g 30,000 Thousands ofMWh
6 Company is rapidly Idaho Power2025IRP Appendix A,p8 (labels added)
7 adding capital costs to 25,000
8 serve large 20,000
9 energy-intensive
10 flat-load customers, 15,000
11 as illustrated here in 10,000 commercial
12 the Company's 2025
5,000
13 IRP: Residential
14 2004 2009 2014 2019 2024 2029 2034 2039 2044
15 "The pipeline of prospective customers on our list exceeds our all-time peak load of around 3,800 megawatts."
Lisa Grow,IDACORP 2Q2025 Earnings Call
16
17 If the allocation method does not change, the disproportionate spread of"fixed" costs to small
18 customers will continue. The allocation policies reflected in the IPC-E-25-16 application stem
19 from assumptions that if a cost is "fixed" then it provides only capacity benefits, and that customer
20 class share of monthly system peaks is a fair and accurate means of evaluating which customer
Case No. IPC-E-25-16 White, Direct-Clean Energy Opportunities for Idaho 7

I classes should pay relatively more or less of those costs. These policies favor energy-intensive
2 flat-load customers who pay relatively less for"fixed" costs though benefit from the lower energy
3 costs which are enabled by fixed-cost infrastructure (e.g., hydro, other non-fuel generation,
a transmission that provides access to low-cost markets, etc). The Company's current allocation
5 policies will continue to suggest that residents, irrigators, and small general service customers
6 should bear an above average allocation of"fixed" costs.
7 A high and rising portion of IPC customer load will be served by resources with high capital
s "fixed" costs but zero fuel cost(like transmission, hydro, wind and solar). Going forward, we
9 encourage the Commission and parties to step back and consider if fairness is served by allocation
10 policies that suggest small customers should be allocated rate increases which—in$per kWh—are
11 several times higher than the increase allocated to special contracts. CEO believes future GRC cost
12 allocations should not start from an assumption that a fixed cost must be a capacity cost, or that
13 customer class share of monthly system peaks provides a fair and accurate allocation of the
14 benefits that transmission and zero fuel cost production resources provide to the overall system.
15
16 d) In future proceedings, Commission guidance and staff facilitation play an increasingly
17 key role to ensure a growing asymmetry of influence over regulatory proceedings does
18 not tilt the balance of fairness.
19 CEO supports the Settlement Agreement in this docket. Looking ahead, we raise a concern based
20 on our cumulative experience in regulatory proceedings.
21 Any application filed by a utility anchors the starting point in a docket, and the sequence of
22 responses by parties often makes it impractical to converge on alternatives to the Company's
23 position. As new large customers intervene, the combination of interests that align with large
24 customers grows more formidable. Investor Owned Utilities in general have interests aligned with
25 special contracts - the utility has an interest in attracting new large customers, and large customers
26 benefit when residents pay disproportionately more for shared resources. Meanwhile, small
27 customers and Idaho non-profits are rarely able to fund representation and technical analysis
28 support.
29 In other words, a regulatory docket is not necessarily a level playing field. The challenge is not the
30 fault of any player, the challenge is that players on one side of the field have some advantages over
31 the players on the other side.
32 Looking ahead, Commission guidance and staff facilitation play a key role to ensure that:
33 • matters of interest to the public and unrepresented customers are adequately
34 addressed,
35 • parties collaborate to resolve what's resolvable, and
Case No. IPC-E-25-16 White,Direct-Clean Energy Opportunities for Idaho 8

1 • the Commission is presented with meaningful alternatives as well as a clear framing of
2 the policies and assumptions underlying those alternatives.
3
a Q. Does this conclude your testimony?
5
6 A. Yes,thank you.
7
8 Respectfully submitted,
1¢
11
12
13 Courtney White
14 Managing Director
15 Clean Energy Opportunities for Idaho
16
17
18
Case No. IPC-E-25-16 White,Direct-Clean Energy Opportunities for Idaho 9

CERTIFICATE OF SERVICE
I hereby certify that on this 18th day of November, I delivered true and correct copies of
the foregoing TESTIMONY IN SUPPORT OF SETTLEMENT to the following persons via the
method of service noted:
Electronic Mail Delivery See Order No. 34602)
Idaho Public Utilities Commission
Monica Barrios-Sanchez
Commission Secretary
secretary(d,)puc.idaho.gov
Idaho PUC Staff
f
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
chris.burdin(g_puc.Idaho.gov
Idaho Power Company
Megan Goicoechea Allen
Donovan Walker
Connie Aschenbrenner
Grant Anderson
mgoicoecheaallenQidahopower.com
[e-mail]
[e-mail]
gandersonPidahopower.com
dockets Oidahopower.com
City of Boise
Ed Jewell
Katie O'Neil
BoiseCityAttorneyOcityofboise.org
ejewell e cityofboise.org
koneilOcityofboise.org
Federal Executive Agencies
Emily W. Medlyn
Jelani A. Freeman
Dwight Etheridge
emily.med yOhq.do e.gov
ielani.freemanna hq.doe.gov
detheridge0exeterassociates.com
Case No. IPC-E-25-16 - White, Direct- Clean Energy Opportunities for Idaho - 10

Gannon, et. al.
John Gannon
Randy Morris
Deborah Fease
Amy Lorrance
[e-mail]
occidentalpacific0hotmail.com
feased854(a)gmail.com
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman, Ph.D.
elo(a)echohawk.com
lance 2 aegisinsight.com
Industrial Customers of Idaho Power
Peter J. Richardson
peter(@richardsonadams.com
Kroger
Kurt J. Boehm
Jody Keyle Cohn
kboehm(a)bkllawfirm.com
ikylercohn(a bkllawfirm.com
Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
darueschhoff0hollandhart.com
tnelson a0hollandhart.com
awj ensen0hollandhart.com
karoachQhollandhart.com
aclee hollandhart.com
[e-mail]
Northwest Energy Coalition
Ben Otto
Lauren McCloy
Derek Goldman
benOnwenergy.org
laurenOnwenergy.org
derekQnwenerg,�org
Case No. IPC-E-25-16 -White, Direct - Clean Energy Opportunities for Idaho - 11

Kelsey Jae
Attorney for CEO
Case No. IPC-E-25-16 - White, Direct- Clean Energy Opportunities for Idaho - 12