20251210N. Erekson Declaration of Support of Idahydro Comment - Redacted.pdf

RECEIVED
DECEMBER 10, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
C. Tom Arkoosh, ISB No. 2253
Nicholas J. Erekson,ISB No. 9325
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: tom.arkooshkarkoosh.com
nick.erekson(a,arkoo sh.com
Admin copy: erin.cecil&arkoosh.com
Attorneys for IdaHydro
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) Case No. IPC-E-25-22
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO UPDATE ITS ) DECLARATION OF NICK EREKSON
OPERATION AND MAINTENANCE ) IN SUPPORT OF SUPPLEMENTAL
CHARGES APPLICABLE TO SCHEDULE ) COMMENT OF IDAHYDRO
72, GENERATOR INTERCONNECTIONS )
TO PURPA QUALIFYING FACILITY )
SELLERS. )
NICHOLAS J. EREKSON declares and states as follows:
1. All statements made in this declaration are true to the best of my knowledge and belief.
2. I am one of the attorneys for Idaho Hydroelectric Power Producers Trust, an Idaho Trust,
d/b/a IdaHydro ("IdaHydro').
3. Attached hereto as Exhibit A is a true and correct copy of the transcript of the Deposition
of Andres Delgado,who was deposed on November 17, 2025.
4. Attached hereto as Exhibit B is a true and correct copy of the transcript of the Deposition
of Aubrae Sloan,who was deposed on November 18, 2025.
5. Attached hereto as Exhibit C is a true and correct copy of the transcript of the Deposition
of Riley Maloney,who was deposed on November 18, 2025.
DECLARATION OF NICK EREKSON IN SUPPORT OF
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 1

6. As provided by Idaho Code § 9-1406, I certify and declare under penalty of perjury
pursuant to the law of the State of Idaho that the foregoing is true and correct.
DATED this 1 Oth day of December 2025.
ARKOOSH LAW OFFICES
r � C r1
ok
Nicholas J. Erekson
Attorneys for IdaHydro
DECLARATION OF NICK EREKSON IN SUPPORT OF
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 2

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the loth day of December 2025, I served a true and correct
copy of the foregoing document(s) upon the following person(s), in the manner indicated:
IDAHO PUBLIC UTILITIES U.S. Mail, Postage Prepaid
COMMISSION: Overnight Courier
Commission Secretary Hand Delivered
Idaho Public Utilities Commission Via Facsimile
11331 W. Chinden Blvd., Building 8, X_ E-mail:
Suite 201-A (83714) secretgakpuc.idaho.gov
P.O. Box 83720
Boise, ID 83720-0074
IDAHO PUBLIC UTILITIES U.S. Mail, Postage Prepaid
COMMISSION STAFF: Overnight Courier
Jeff Loll Hand Delivered
Deputy Attorney General Via Facsimile
Idaho Public Utilities Commission X_ E-mail:
11331 W. Chinden Blvd., Building 8, jeff.loll(a�uc.idaho.gov
Suite 201-A (83714)
P.O. Box 83720
Boise, ID 83720-0074
IDAHO POWER:
Donovan E. Walker U.S. Mail, Postage Prepaid
IPC Dockets Overnight Courier
Idaho Power Company Hand Delivered
1221 W. Idaho Street(83702) Via Facsimile
P.O. Box 70 X E-mail:
Boise, ID 83707 dwalker(cidahopower.com
dockets&idahopower.com
Tim Tatum U.S. Mail, Postage Prepaid
Riley Maloney Overnight Courier
Idaho Power Company Hand Delivered
1221 W. Idaho Street(83702) Via Facsimile
P.O. Box 70 X_ E-mail:
Boise, ID 83707 ttatum(d),idahopower.com
rmaloney&idahopower.com
DECLARATION OF NICK EREKSON IN SUPPORT OF
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 3

RENEWABLE ENERGY U.S. Mail, Postage Prepaid
COALITION: Overnight Courier
Irion Sanger Hand Delivered
Sanger Greene, P.C. Via Facsimile
4031 SE Hawthorne Blvd. X_ E-mail: irionksanger-law.com
Portland, OR 97214
Nicholas J. Erekson
DECLARATION OF NICK EREKSON IN SUPPORT OF
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 4

APPLICATION OF IDAHO POWER FOR AUTHORITY
IDAHO POWER - ANDRES DELGADO
November 17, 2025
30(b)(6)
ND
DEPOIDAHO
11-��
Local Reoltim.e tiCrortinq & Videogrophy Experts PO Box 44385, Boise, I D 83711
0 1 0 . 0 .

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF IDAHO POWER ) Case No . IPC-E-25-22
COMPANY FOR AUTHORITY TO )
UPDATE ITS OPERATION AND )
MAINTENANCE CHARGES APPLICABLE )
TO SCHEDULE 72, GENERATOR )
INTERCONNECTIONS TO PURPA )
QUALIFYING FACILITY )
SELLERS . )
RULE 30 (b) (6) DEPOSITION OF IDAHO POWER COMPANY
TESTIMONY OF ANDRES V. DELGADO
TAKEN NOVEMBER 17, 2025
REPORTED BY:
Beverly A. Benjamin, CSR No. 710
Notary Public

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 2
1 THE RULE 30 (b) (6) DEPOSITION OF IDAHO POWER
2 COMPANY, TESTIMONY OF ANDRES V. DELGADO, was taken on
3 behalf of IdaHydro at the Arkoosh Law Offices, 913 W.
4 River Street, Suite 450, Boise, Idaho, commencing at
5 9 : 02 a.m. on November 17, 2025, before Beverly A.
6 Benjamin, Certified Shorthand Reporter and Notary Public
7 within and for the State of Idaho, in the above-entitled
8 matter.
9 A P P E A R A N C E S :
10 For IdaHydro:
11 Arkoosh Law Offices
12 BY MR. NICHOLAS J. EREKSON
13 MR. C. TOM ARKOOSH
14 913 W. River Street, Suite 450
15 Boise, Idaho 83701
16 nick.erekson@arkoosh. com
17 [e-mail]
18 For Idaho Power Company:
19 Idaho Power Company
20 BY MR. DONOVAN E. WALKER
21 MS . LISA C. LANCE
22 1221 W. Idaho Street
23 Boise, Idaho 83707
24 dwalker@idahopower. com
25 (Appearances continued. )
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1 For Idaho Public Utilities Commission :
2 BY MR. JEFF LOLL
3 Deputy Attorney General
4 11331 W. Chinden Blvd. , Building 8
5 Suite 201-A (83714 )
6 Boise, Idaho 83720
7
8 ALSO PRESENT : Ms . Yao Yin
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1 I N D E X
2 TESTIMONY OF ANDRES V. DELGADO PAGE
3 Examination by Mr. Erekson 5
4 Examination by Mr. Walker 24
5
6
7 E X H I B I T S
8 NO. DESCRIPTION PAGE
9 Exhibit 1 Response to Interrogatory No . 15 10
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1 ANDRES V. DELGADO,
2 first duly sworn to tell the truth relating to said
3 cause, testified as follows :
4
5 EXAMINATION
6 QUESTIONS BY MR. EREKSON:
7 Q. Good morning.
8 A. Good morning.
9 Q. Can you please state your full name and spell
10 your last name just for the record.
11 A. Yeah. My name is Andres Valdepena Delgado .
12 You spell it V-A-L-D-E-P-E-N-A, and then Delgado is
13 D-E-L-G-A-D-O.
14 Q. Have you ever been in a deposition before,
15 Andres?
16 A. Not a deposition .
17 Q. I 'm going to go over just a few ground rules
18 then.
19 A. Okay.
20 Q. It is being stenographically recorded. So it
21 is important that you speak audibly and that you speak
22 slow enough that she can keep an accurate transcript.
23 A. Okay.
24 Q. You are under oath, so there are a few things
25 that come along with that. You have to answer
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1 truthfully so as not to be held in contempt or there
2 could be accusations of misconduct.
3 So this is a question-and-answer format. I ' ll
4 ask the questions and you provide the answers . If you
5 don' t understand my question, it' s okay to ask for a
6 clarification.
7 We' ll just jump right in. So do you know why
8 you're here today, Andres?
9 A. Yes, I do .
10 Q. There' s specific questions I 'm going to focus,
11 specific areas . One of those is the segregation of
12 interconnection costs . The other is the inclusion of
13 interconnection costs and avoided cost methodologies .
14 Actually, segregation was for another witness .
15 So, the other is assumptions regarding avoided O&M.
16 Can you give me a little bit about your
17 background. Like, how did you get to this spot in Idaho
18 Power?
19 A. I 've been with Idaho Power for about 12 years
20 now, all of them in planning. So I did 5 years in
21 distribution planning, I did about 4 years in system
22 planning, and I have been in this new role for about
23 2 years .
24 Part of my role is to support regulatory with
25 cases, which includes this one . And then planning
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1 department, we provide some inputs to different dockets,
2 such as this, inclusion of interconnection costs, of
3 what it costs . So part of the IRP, which is kind of
4 what fits one of our programs, which is the ICIRP, comes
5 from the planning department. So that ' s how I have been
6 involved over the years .
7 Q. What is your education?
8 A. I have a bachelor' s in engineering, a master ' s
9 and a Ph. D. in electrical and computer engineering.
10 Q. The bachelor' s and the master' s are electrical
11 and computer engineering also?
12 A. Bachelor ' s electrical; master' s and Ph. D.
13 electrical and computer.
14 Q. Where did you go school?
15 A. My undergrad is at Durango Institute of
16 Technology back in Mexico. Master' s and Ph. D. at Boise
17 State.
18 Q. What did you study to get your Ph.D. ?
19 A. I did, we designed what is called a
20 Residential Static VAR Compensator, which is a voltage
21 regulating device.
22 Q. Now, for your day-to-day, what do you do for
23 Idaho Power?
24 A. So as assistant consultant engineer, I provide
25 some support to all three of the planning groups . So
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1 inside the planning department we have system planning,
2 which they handle pretty much anything in the system or
3 transmission level, which is 100kV and above . And then
4 we also provide support to the distribution planning,
5 which is 100kV and below. And resource planning, which
6 is in charge of procuring resources to meet Idaho Power
7 load.
8 Q. Is that 100 kilovolt, is that like an
9 arbitrary amount? Why is above that transmission and
10 below that distribution --
11 A. That ' s what NERC defines as the BES, or bulk
12 electric system. So that is a NERC defined voltage .
13 Q. But besides that there ' s no other reason to
14 kind of draw the line in the sand right there?
15 A. Anything that is part of the bulk electric
16 system --
17 (Reporter clarification . )
18 (Discussion off the record. )
19 THE WITNESS : What I was trying to say is :
20 Transmission is regulated by FERC . And distribution is
21 usually regulated by the utility commission, so by
22 state . There is a difference on who oversights the
23 different processes .
24 Q. (BY MR. EREKSON) And that 100 kilovolt, they
25 both use that same delineator between transmission and
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1 distribution?
2 A. There are more rules of what accounts as
3 transmission and distribution, not only the voltage, but
4 voltage is one of the main ones, the easiest ones .
5 Q. Then for purposes of interconnection O&M
6 tariffs, that' s the cutoff that' s being used?
7 A. You have to check with Mr. Maloney, but I
8 believe so .
9 Q. So how familiar are you with the SAR, the
10 surrogate avoided resource model?
11 A. I 'm pretty familiar.
12 Q. And what is the model?
13 A. So the model, the SAR, it tries to capture the
14 costs, all-inclusive costs, of a combined cycle to get
15 the rate of what we will pay contracts under the
16 published threshold.
17 Q. How is the SAR developed?
18 A. Well, it was developed back in 2008, is the
19 last time it has some changes . And it gets updated
20 every year. And some of the updates that we do is the
21 gas prices . And then every other year we update
22 capacity positions .
23 But in terms of the cost, they are set by an
24 order from the Idaho Public Utility Commission, and
25 those costs have not changed.
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1 Q. That' s Order 30738?
2 A. Correct .
3 Q. You had referenced that in your discovery
4 response; correct?
5 A. That is correct .
6 Q. You wrote the discovery response to
7 Interrogatory No. 15?
8 I printed it out for you if it' s helpful as an
9 exhibit. It' s Exhibit 1 .
10 (Exhibit 1 marked. )
11 THE WITNESS : Yeah. I did respond to that .
12 Q. (BY MR. EREKSON) In that you have a footnote
13 referencing this order. And you have a second footnote
14 referencing the Northwest Power and Conservation
15 Council, their Sixth Conservation and Electric Power
16 Plan. Is that the basis for the SAR model that was
17 adopted in Order 30738?
18 A. It is the basis for the cost .
19 Q. Just for like the cost assumptions?
20 A. Yes .
21 Q. Now, when the Northwest Power and Conservation
22 Council comes out with an additional report, like they
23 do every 5 years, is the model updated or is it just
24 left back in the 2000-2006 report?
25 A. To my knowledge, it has not been updated. It
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1 is still the same cost from the sixth power plan.
2 Q. And that' s because that is the last time that
3 the avoided cost rate was set was in 2008?
4 A. The fixed costs, yes . The actual avoided rate
5 changes with gas prices and other inputs .
6 Q. The variable costs.
7 A. Correct .
8 Q. Now, how familiar are you with those
9 assumptions that go into this model?
10 A. I would say relatively familiar. I read over
11 them.
12 Q. So the variable and the fixed rate operating
13 and maintenance, were those inclusive or exclusive of
14 interconnection operating and maintenance?
15 A. The fixed costs included, there is a fixed 0&M
16 that gets added to the capital cost . So they are
17 included on the cost .
18 Q. On the fixed costs?
19 A. On the fixed costs .
20 Q. Are they included on the variable costs?
21 A. The variable costs they are -- I ' ll have to
22 double-check. I know the fixed costs for sure they are .
23 Q. What are the units on the fixed costs? Like
24 we talked about them being included but --
25 A. Usually they are given in dollars-per-kilowatt
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1 month.
2 Q. Per kilowatt month?
3 A. Or kilowatt year, depending on the time . So
4 it ' s a fixed payment based on kW every year.
5 Q. So if it' s month, it would change per month
6 based on the amount of power produced?
7 A. No. It ' s based on nameplate . So it does not
8 change . So if you have 100kW, and the fixed on them is
9 $2 per kW per month, then it gets multiplied 100 times 2
10 every month.
11 Q. So if it was per kilowatt per year, it would
12 be the same every year.
13 A. Correct .
14 Q. It' s just a fixed cost. It doesn' t change
15 regardless of how much --
16 A. Based on escalation rate that changes that
17 every year.
18 Q. It changes that every year.
19 A. Correct .
20 Q. But that base fixed just stays the same,
21 notwithstanding the escalation rate?
22 A. Correct .
23 Q. That escalation rate, that' s an assumption.
24 Is that pulled from the --
25 A. Conservation Council .
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1 Q. From the sixth report.
2 A. Correct .
3 Q. Is that updated as new reports come out, or do
4 you still look at the sixth report?
5 A. To my knowledge, it has not been updated
6 because those values are set by the order. So the order
7 has the values .
8 Q. So when you reference cells D37, D39, and D40,
9 you're talking about the SAR fixed O&M of $14 . 57 per --
10 is this kilowatt month or kilowatt year?
11 A. Those are kilowatts . . .
12 Q. Well, the fixed 0&M, is that done per kilowatt
13 month or per kilowatt year, or is that just per
14 kilowatt?
15 A. Per kilowatt . And then when you go into the
16 model, they get calculated on a yearly basis .
17 Q. So if it' s per kilowatt, it does change based
18 on the amount of power that' s produced?
19 A. Usually it ' s based on nameplate, so it will
20 not .
21 Q. Okay. So what portion of that $14 .57 would be
22 for interconnection 0&M?
23 A. I don ' t have the actual breakdown . When you
24 look at the power plan for the Power and Conservation
25 Council, they do not have a breakdown of which one, each
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1 line item. They have it all together .
2 Q. So it' s just not segregated out?
3 A. They do include on the write-up when you look
4 at that, what is included on the price . But they don't
5 have a line item. They don ' t have like this dollar,
6 this dollar, this dollar. They just have a total amount
7 that includes everything.
8 Q. So we have no way of knowing whether it' s $1
9 or $5?
10 A. You have to contact them.
11 There is some data on that appendix that I
12 referenced, but it ' s not line by line.
13 Q. It doesn' t ever break it out.
14 A. They do have a breakdown for transmission,
15 local transmission connection. Part of that is
16 broke down, but that is the only one that they break
17 down.
18 Q. How much did that breakdown at?
19 A. I don ' t remember off the top of my head, but
20 I ' ll have to look at the number.
21 Q. In your response you didn' t reference that it
22 was broken out anywhere.
23 A. So in my response I put kind of the language
24 of what everything includes . If you go into the
25 reference and dive into the appendix, specifically they
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1 do break down a little bit more what gets included, but
2 they don' t have a line item.
3 Q. There ' s no number. Qualitatively they' re
4 saying that it' s there.
5 A. Correct .
6 Q. But quantitatively they don' t get to see the
7 number.
8 A. Correct .
9 Q. We just take their word for it that it' s in
10 the overall rate --
11 A. Correct .
12 Q. -- that' s paid to the QF.
13 So it would be very difficult to compare, or
14 impossible to compare the actual, like a 72 charge, to
15 what someone is being paid on the front end.
16 A. To my knowledge, those are different costs,
17 but yes . If you don ' t have the breakdown, you cannot
18 compare them.
19 Q. There ' s no way to do a comparison. Okay.
20 Same thing for the IRP model?
21 A. No, that is different . So the IRP model, the
22 costs there, the capital cost and the fixed 0&M, they
23 come from the Renewable Energy Lab, NREL. And the
24 transmission and the connection costs, they come from
25 the Idaho Power interconnection queue .
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1 Q. So the interconnection costs are broken out.
2 Are the interconnection O&M broken out?
3 A. No. The 0&M is a fixed number that gets
4 applied to everything.
5 Q. Can you explain this for someone who doesn' t
6 have a Ph.D. Just break it down.
7 A. So we provided some -- Interrogatory 16 .
8 Q. Yes .
9 A. So there ' s a fixed 0&M component on the fifth
10 column. So that fixed 0&M includes everything. It ' s
11 not breaking it down piece by piece . So it is fixed 0&M
12 that gets applied to the total .
13 Q. And that' s for the whole plant.
14 A. Correct .
15 Q. So, again, is the interconnection O&M broken
16 out? Just on the interconnection piece.
17 What kind of plant is the IRP?
18 A. So the IRP will have the cost . Let ' s say the
19 simple-cycle combustion turbine . So the capital cost
20 that is included here that we provided, that capital
21 cost also has some assumptions that includes everything
22 of what is called the fence line . So it ' s the plant
23 plus the gen-tie, plus the transformer, and they end at
24 the high side of the transformer. So that is the
25 capital .
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1 And then you have the transmission and
2 interconnection costs, which is column three on
3 Interrogatory 16, transmission and interconnection
4 costs . So that gets added into the capital costs .
5 And then you have the fixed 0&M that gets
6 applied to the total capital .
7 Q. So I see $81 per kilowatt for the transmission
8 and interconnection capital for the --
9 A. For the SCOT, simple-cycle combustion turbine .
10 Q. And this is with respect to the ICIRP?
11 A. That is the ICIRP.
12 Q. Then I see $2 . 10 per kilowatt month, a fixed
13 O&M for the same model. Which one of these numbers
14 would represent interconnection operating and
15 maintenance?
16 A. It would be included as part of the fixed 0&M.
17 Q. How much of the $2 . 10?
18 A. It ' s not broken down by that .
19 Q. But it' s less than $2 . 10?
20 A. I would assume so .
21 Q. It' s not all of it.
22 Can you point to anywhere here that that
23 interconnection O&M is broken out, like a separate line
24 item?
25 A. It ' s not.
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1 Q. It' s not.
2 A. Correct .
3 Q. So I guess in the context of why we 're here,
4 it' s a Schedule 72 rate case. Again, it' s impossible to
5 compare the unknown amount of interconnection 0&M that' s
6 paid to a QF on the front end to what' s proposed being
7 charged kind of on the back end.
8 A. To my understanding about the cost, ICIRP and
9 the SAR model, they compensate for the entire plan,
10 including 0&M, including interconnection facilities .
11 All of that gets paid into the avoided costs .
12 Schedule 72 is incremental costs that Idaho Power incurs
13 by maintaining those facilities, because we include
14 everything on the avoided costs .
15 Q. But any avoided cost modeling under both
16 models, neither one of them has a line item for
17 interconnection operating and maintenance; correct?
18 A. Correct . They are included. They are part of
19 entire .
20 Q. There' s a broader cost that includes them, but
21 we can' t see whether it' s 50 cents out of this $2 . 10 per
22 kilowatt month or whether it' s 1 cent or whether it' s
23 $2, we don' t know.
24 A. Correct . But we know they are included in
25 there .
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1 Q. Just we don' t know to what extent they are
2 included.
3 A. Correct .
4 Q. So it' s kind of like apples and oranges
5 comparing the two.
6 A. Well, on one side you have the entire cost of
7 the avoided -- right? -- these avoided resource, either
8 in the SAP, methodology or the ICIRP methodology, they
9 are included everything that is in there . Schedule 72
10 was incremental to that to maintain those facilities .
11 Q. So we don' t know -- I guess, we don' t know
12 whether the amount under Schedule 72 is greater than the
13 amount that was included under the avoided cost modeling
14 or whether it' s less than; correct?
15 A. Correct .
16 Q. We have no idea.
17 A. They are different .
18 Q. They are different?
19 A. Yes . Because one of them you have a
20 theoretical resource for what it costs, and the Schedule
21 72 are actuals . So it ' s hard to compare them when you
22 have a proxy resource versus actual .
23 Q. Yeah. Just hypothetically -- we get to talk
24 hypothetically since I don' t have a Ph.D. so I
25 understand this.
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 20
1 If the Schedule 72 tariff were more than the
2 actual cost, would the company have a gain, a financial
3 gain?
4 A. Well, they are different so -- they serve
5 different purposes, so it ' s hard to do that . Because
6 you have a hypothetical resource that gets avoided cost
7 that we pay to the QFs, and then you have actuals of
8 what was actually incurred to maintain that system.
9 Q. The QF is not an actual, but I get what you' re
10 trying to say. The QF is another model -- the Schedule
11 72 is another model. You would agree that it' s not
12 actual cost.
13 A. From my understanding, it ' s averages of actual
14 costs for the company.
15 Q. So I guess to repeat my question: So let' s
16 say, because we don' t know, it' s somewhere between zero
17 and $2 . 10 per kilowatt month; right?
18 A. Per kW, yes, month.
19 Q. What does the kW stand for?
20 A. Kilowatt.
21 Q. Kilowatt month.
22 We don' t know whether it' s 5 cents or if it' s
23 $2; correct?
24 A. Correct .
25 Q. And that set Schedule 72 tariff has different
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 21
1 units, but it could come out, you could put it in terms
2 of a kilowatt month; right?
3 You could; I couldn' t.
4 A. Right .
5 Q. You're the Ph.D.
6 So to the extent it is more than the
7 interconnection O&M, would that be a gain for the
8 company?
9 A. So your question is if those are different,
10 could be gain or could be a lose; right? It depends .
11 Q. If they' re different, it has to be a gain or a
12 loss; correct?
13 A. Yeah. Again, we ' re comparing two different. . .
14 Q. We' re comparing two different things . This is
15 a hypothetical question.
16 If it' s less, it would be a loss to the
17 company. You can agree with that; right?
18 A. This hypothetical scenario? Yes .
19 Q. If the model had one rate and they were paid
20 back at another that was less than, they would have a
21 loss .
22 A. Hypothetical it could be more or less .
23 Q. Same thing, the contrapositive, if the
24 Schedule 72 rate were more than was in the model, it
25 would be a gain to Idaho Power; correct?
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 22
1 A. Hypothetical, yes . If they are different, it
2 could be a gain or a loss .
3 Q. So if it were more it would be a gain.
4 A. In this hypothetical scenario, yes .
5 Q. But we don' t know whether it' s more or less .
6 We know it' s not exactly though; correct?
7 A. Correct .
8 Q. When you are reviewing these models and their
9 assumptions, does Idaho Power have any actual data that
10 you can use to test the validity of these models?
11 A. Which ones? So for --
12 Q. I guess we can start out with SAR. It would
13 be easier to talk about one model at a time.
14 A. We don ' t compare those .
15 Q. You just kind of take them at their face?
16 A. Yeah. So the Power Conservation Council, they
17 go through a lot of validation data. The same thing
18 with the ICIRP.
19 For the SAR model, there ' s nothing we can do .
20 That ' s in the order. We have to use that .
21 For the ICIRP, we do a little vetting on
22 public sources to make sure they are good data .
23 Q. Then ultimately you adjust some of the inputs
24 for the model for the ICIRP?
25 A. The costs we do not . We take them from either
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 23
1 NREL --
2 Q. But there ' s no like independent analysis . You
3 just accept these because somebody else has done them.
4 A. Yes . But they go through a lot of vetting
5 before they publish those numbers .
6 Q. With this case pending, have you done any of
7 your own research with respect to interconnection O&M
8 costs?
9 A. I have not .
10 Q. Has anybody, to your knowledge?
11 A. Not to my knowledge .
12 Q. Are you aware of any, as far as quantitative
13 evidence, that relates to specifically the
14 interconnection O&M at Idaho Power?
15 A. Not to my knowledge .
16 Q. No modeling specifically of that particular
17 piece?
18 A. Not to my knowledge . At least not in the
19 planning department .
20 MR. ARKOOSH: Let ' s take just a moment ' s
21 break.
22 (Off the record. )
23 MR. EREKSON: That ' s all the questions I have,
24 unless you want to follow up.
25 MR. WALKER: I have just one quick follow-up.
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 24
1 EXAMINATION
2 QUESTIONS BY MR. WALKER:
3 Q. I usually just say "Mr. Andres, " by the way,
4 instead of trying to correctly pronounce. . .
5 So there was a little bit of talk and question
6 back and forth about, in the hypothetical, about whether
7 it would be a loss or a gain to the company under
8 different hypotheticals .
9 And to the extent that you know, or maybe this
10 is more appropriate for one of the other witnesses, but
11 does the company make a gain or a loss on any kind of
12 O&M collection or under-collection or over-collection?
13 A. To my knowledge, it does not . It ' s a
14 pass-through on a rate case .
15 Q. In other words, it would be something that
16 other customers would pay more or less in this gain or
17 loss, it wouldn' t be a gain or a loss to the company.
18 A. Correct .
19 Q. And the company doesn' t earn any authorized
20 return or profits on any type of 0&M?
21 A. That is correct .
22 MR. WALKER: That ' s the only follow-up I had.
23 MR. EREKSON: No further questions .
24 (Deposition concluded at 9 : 37 a.m. )
25 (Signature requested. )
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

IddaTh`To ppPoower - Andres DDe�ill1gado 30 (b) (6) 11/17/2025
AIPdaLYlio-Fo Oer OF Andres DelgadoORU(TbI�OTY 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 25
1 CERTIFICATE OF WITNESS
2 I, ANDRES V. DELGADO, being first duly sworn,
3 depose and say:
4 That I am the witness named in the foregoing
5 deposition, consisting of pages 1 through 26; that I
6 have read said deposition and know the contents thereof;
7 that the questions contained therein were propounded to
8 me; and that the answers contained therein are true and
9 correct, except for any changes that I may have listed
10 on the Change Sheet attached hereto:
11 DATED this 3 day of Dece,,,., b,N , 20 2S.
12
13
14
15 ANDRES V. DELGADO
16
17 SUBSCRIBED AND SWORN to before me this �aY
18 of � ,QnnnV2�V 20
19
20
i
NAME OF NOTAR PUBLIC
CHRISTY LYN DAVENPORT
Notary Pu He-State of Idaho `^
CoWmissi nNumber52970 NOTARY PUBLIC FOR � � V n
My Commissio Expires Sep 10,2026
RESIDING AT
24 MY COMMISSION EXPIRES
25
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 26
1 REPORTER' S CERTIFICATE
2 I, BEVERLY BENJAMIN, CSR No . 710, Certified
3 Shorthand Reporter, certify:
4 That the foregoing proceedings were taken before
5 me at the time and place therein set forth, at which
6 time the witness was put under oath by me.
7 That the testimony and all objections made were recorded
8 stenographically by me and transcribed by me or under my
9 direction.
10 That the foregoing is a true and correct record
11 of all testimony given, to the best of my ability;
12 I further certify that I am not a relative or
13 employee of any attorney or party, nor am I financially
14 interested in the action.
15 IN WITNESS WHEREOF, I set my hand and seal this
16 25th day of November 2025 .
17
18
A BF
20
z
G
21 S'j°?MNoL3° 'p • BEVERLY A. BENJAMIN, CSR No. 710
,, '•q�E IOP\>
OF
22 """" Notary Public
23
24
25
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
10:1,17 agree back cells 22:16
Exhibits 20:11 21:17 7:16 9:18 10:24 13:8 consultant
4 all-inclusive 18:7 21:20 24:6 cent 7:24
EXH 1 Delga 9:14 background 18:22 contact
do 111725 4 amount 6:17 cents 14:10
4:910:9,10 6:21 8:912:613:18 base 18:2120:22 contempt
14:6 18:5 19:12, 12:20 change 6:1
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25 14:11, Boise
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14:9 11,25 21:24 16:4,12 17:6 16:6 23:21 15 20:23,24
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9 areas 1815:17 combined correctly
6:11 breaking 9:14 24:4
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24:24 ARKOOSH 16:19 17:9
23:20 broader 6:13 9:23 10:18,
1 commission 1911:1,3,16,17
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p 12:23 17:18,23 p 6:12,13 7:2,3
100kw 23:3 bulk 15:13,14,18 9:14,2511:4,6,
12:8 accounts assumptions 18:519:21 15,18,19,20,21,
6:15 10:19 11:9 8:11,15 22:14
12 9:2 22,23 15:16,22,
6:19 accurate 16:2122:9 comparing 2416:117:2,4
15 5:22 audibly C 19:5 21:13,14 18:11,12,14
10:7 accusations 5:21 comparison 19:20 20:14
16 6:2 authorized calculated 15:19 22:25 23:8
16:717:3 24:19 13:16 compensate Council
actual 11:4 13:23 averages called 18:9 10:15,2212:25
15:14 19:22 20:13 7:19 16:22 Compensator 13:25 22:16
2 20:2,9,12,13 avoided capacity 7:20 customers
2 22:9 6:13,15 9:10 9:22 component 24:16
actualS 11:3,418:11,14, capital 16:9 cutoff
6:23 12:9 15 19:7,13 20:6
2000-2006 19:2120:7 11:1615:22 computer 9.6
added aware 16:19,20,25 7:9,11,13 Cycle
10:24 23:12 17:4,6,8
11:1617:4 concluded 9:14
2008
additional capture 24:24
9:18 11:3 9:13
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adjust case 14:15 15:24
3 22:23 bachelor's 18:4 23:6 24:14 D-E-L-G-A-D-
7:8,10,12 cases Conservation
adopted 10:14,15,21 O
30738 10:17 6.25 12:2513:24 5:13
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: $1 to D-E-L-G-A-

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
D37 double-check ground 19:2,9,13 12,13,14,15,17
13:8 11:22 F 5:17 includes 17:7,1218:22
D39 draw groups 6:2514:7,24 20:17,20,21
13:8 8:14 face 7:25 16:10,2118:20 21:2
D40 duly 22:15 guess including kilowatts
13:8 5:2 facilities 18:319:11 18:10 13:11
data Durango 18:10,13 19:10 20:15 22:12 kind
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8:11 22:13 20:2 head incurs 15,18 24:13
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8:25 7:7 11:4,12,15,18, helpful inputs L
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5:14,16 24:24 23:24
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8:22 7:4 17:10,11
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discovery escalation 16:17,18 lot
10:3,6 12:16,21,23 G 6:17,19 7:23 8:6
9:24 15:25 item 22:17 23:4
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24:7,11,16,17 19:16 ,J main
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14:25 11:13 gen-tie impossible 6:7 19:10 20:8
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7:1 10:9,10 give include K 18:13
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14:5,6 16:5 included kilovolt 11:13,1417:15
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11:25 17:1618:18,24 owatt
19:12 12:2,3,11 13:10, 22:22 24:11
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: D37 to make

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Maloney number plan published referenced
9:7 14:20 15:3,7 10:16 11:1 9:16 10:3 14:12 S
marked 16:3 13:2418:9 pulled referencing
10:10 numbers planning 12:24 10:13,14 sand
master's 17:13 23:5 6:20,21,22,25 purposes regulated 8:14
7:8,10,12,16 7:5,25 8:1,4,5 9:5 20:5 8:20,21 SAR
meet O 23:19 put regulating 9:9,13,1710:16
8:6 plant 14:23 21:1 7:21 13:9 18:9 19:8
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7:16 24:12,20 9:22 QFS remember 18:4,1219:9,12,
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6:2 5:24 6:18,19 7:23 8:6 Qualitatively Renewable 21:24
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13:10,13 17:12 8:6 15:25 signature
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1121:19 resource 16:1917:9
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proposed 21:19,24 24:14 respond 22:22
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9:15 20:7 24:16 read speak
12:7 13:19
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8:11,12 provided 8:13 return 6:10,11
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23:6 record specifically
10:14,21
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notwithstand 7:9,12,16,18 19:22 recorded 22:8 spell
ing 16:6 19:24 21:5 public 5:20 role 5:9,12
12:21 piece 9:24 22:22 reference 6:22,24 Spot
NREL 16:11,16 23:17 publish 13:8 14:21,25 rules 6:17
15:23 23:1 23:5 5:17 9:2
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: Maloney to spot

Idaho Power - Andres Delgado 30 (b) (6) 11/17/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
stand threshold updates years
20:19 9:16 9:20 6:19,20,21,23
start time utility 7:6 10:23
22:12 9:19 11:2 12:3 8:21 9:24
state 22:13
5:9 7:17 8:22 times V
Static 12:9
7:20 today V-A-L-D-E-P-
stays 6:8 E-N-A
12:20 top 5:12
stenographic 14:19 Valdepena
ally total 5:11
5:20 14:6 16:12 17:6 validation
study transcript 22:17
7:18 5:22 validity
support transformer 22:10
6:24 7:25 8:4 16:23,24 values
surrogate transmission 13:67
9:10 8:3,9,20,25 9:3 VAR
sworn 14:14,1515:24 7:20
3 17:1, ,7
5:2 variable
system truth 11:6,12,20,21
5:2
6:21 8:1,2,12,16 versus
20:8 truthfully 19:22
6:1
turbine vetting
T 22:21 23:4
16:19 17:9
voltage
talk type 7:20 8:12 9:3,4
19:23 22:13 24:20
24:5
W
talked U
11:24 WALKER
talking ultimately 23:25 24:2,22
13:9 22:23
under- witnesses
tariff 24:10
20:1,25 collection word
tariffs 24:12
15:9
9:6 undergrad words
Technology 7:15 24:15
7:16 understand write-up
terms 6:5 19:25
14:3
9:23 21:1 understandin wrote
test g 10:6
22:10 18:8 20:13
testified units Y
5:3 11:23 21:1
theoretical unknown
19:20 18:5 year
9:20,21 12:3A
thing update 11,12,17,18
15:20 21:23 9:21 13:10,13
22:17 updated yearly
things 9:19 10:23,25 13:16
5:24 21:14 13:3,5
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: stand to years

APPLICATION OF IDAHO POWER FOR AUTHORITY
IDAHO POWER COMPANY - AUBRAE SLOAN
November 18, 2025
ND
DEPOIDAHO
Local Reoltime Reporting & Videogrophy Experts PO Box 44385, Boise, I D 83711
0 1 • • 0 . • •

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) Case No . IPC-E-25-22
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO UPDATE ITS OPERATION)
AND MAINTENANCE CHARGES )
APPLICABLE TO SCHEDULE 72, )
GENERATOR INTERCONNECTIONS TO )
PURPA QUALIFYING FACILITY )
SELLERS, )
DEPOSITION OF IDAHO POWER COMPANY
TESTIMONY BY AUBRAE SLOAN
Tuesday, November 18, 2025
Pages 1 - 40
REPORTED BY:
SARAH L. GOEKLER, CSR No . 1178
Notary Public

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 2
1 THE DEPOSITION OF AUBRAE SLOAN was taken on
2 behalf of the IDAHO POWER COMPANY, TESTIMONY BY AUBRAE
3 SLOAN at the offices of Arkoosh Law Offices, 913 W.
4 River Street, Suite 450, Boise, Idaho, commencing at
5 10 : 04 a.m. on Tuesday, November 18, 2025, before Sarah
6 L. Goekler, Certified Shorthand Reporter and Notary
7 Public within and for the State of Idaho, in the
8 above-entitled matter .
9
10 APPEARANCES :
11
12 FOR IDAHYDRO:
13 ARKOOSH LAW OFFICES
NICHOLAS J. EREKSON, ESQ.
14 C. TOM ARKOOSH, ESQ.
913 W. River Street, Suite 450
15 Boise, Idaho 83701
nick.erekson@arkoosh. com
16 tom. arkoosh@arkoosh. com
17
18 FOR IDAHO PUBLIC UTILITIES COMMISSION:
19 DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
20 ERIKA K. MELANSON, ESQ.
11331 W. Chinden Blvd. , Building 8
21 Suite 201-A (83714)
Boise, Idaho 83720
22 erika.melanson@puc. idaho .gov
23
24
25
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 3
1 APPEARANCES (CONTINUED) :
2
3 FOR IDAHO POWER:
4 IDAHO POWER COMPANY
DONOVAN E . WALKER, ESQ .
5 1221 W. Idaho Street ( 83702 )
Boise, Idaho 83707
6 dwalker@idahopower . com
7
8 ALSO PRESENT :
9 Connie Aschenbrenner, Idaho Power
10 Lisa Lance, Idaho Power
11 Yao Yin, Public Utilities Commission
12
13 ---000---
14
15
16
17
18
19
20
21
22
23
24
25
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APPLICATION OF IDAHO POWER FOR AUTHORITY
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1 I N D E X
2
3 TESTIMONY OF AUBRAE SLOAN PAGE
4 Examination by Mr . Arkoosh . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
5 Examination by Mr . Walker . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
6
7
8 E X H I B I T S
9 PAGE
10 Exhibit 4 IdaHydro ' s Request for Production 17
No. 4, Interconnect
11 Investment; 3 pages
(CONFIDENTIAL - bound separately)
12
Exhibit 5 Predicate language in the FERC 24
13 regulations; 1 page
14 Exhibit 6 593, Maintenance of Overhead Lines, 27
Major Only; 2 pages
15
Exhibit 7 364, Poles, Towers, and Fixtures; 29
16 1 page
17 Exhibit 8 2 . Maintenance; 1 page 30
18
19
20 EXHIBITS PREVIOUSLY MARKED
21 PAGE
22 Exhibit 2 (First Referenced) 31
23 Exhibit 3 (First Referenced) 8
24
25 ---000---
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APPLICATION OF IDAHO POWER FOR AUTHORITY
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1 Tuesday, November 18, 2025 10 : 04 a.m.
2 ---000---
3 AUBRAE SLOAN,
4 having first been duly sworn by a Certified Shorthand
5 Reporter for the State of Idaho, was examined and
6 testified as follows :
7 EXAMINATION
8 BY MR. ARKOOSH:
9 Q. Aubrae, would you state and spell your last
10 name, please?
11 A. Yes . Sloan, S-L-O-A-N.
12 Q. And your first name is spelled just a little
13 bit different. Would you spell that as well?
14 A. Yep. Aubrae, A-U-B-R-A-E .
15 Q. Have you ever been deposed before?
16 A. I have not .
17 Q. Okay. It' s a process of questions and
18 answers . And you just took an oath, so you have to
19 answer truthfully, and I would expect that to happen
20 whether or not you've taken an oath.
21 Probably the most important thing is we don' t
22 step on each other' s speech. So when I 'm asking a
23 question, listen to the question, and when you answer,
24 I ' ll try and listen to the answer, and that way we ' ll
25 get a clear transcript of what was said and done.
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1 A. Sure .
2 Q. Do you have any questions about the process?
3 A. Not yet .
4 Q. If you need a break at all, just tell me that.
5 A. Okay.
6 Q. The only thing I ask is if you take a break
7 and there' s a pending question, you answer the question
8 before you take the break.
9 A. Sure .
10 Q. Okay. How are you currently employed?
11 A. I 'm employed as a Finance Team Leader at
12 Idaho Power, so I manage our financial accounting and
13 financial reporting teams .
14 Q. How long have you been with Idaho Power?
15 A. 20 years .
16 Q. Okay. And before that?
17 A. Before that, I was an accountant for Jackson ' s
18 Food Stores for three years .
19 Q. And before that?
20 A. College .
21 Q. Okay. And where was college?
22 A. Idaho State University.
23 Q. And what was your major?
24 A. Accounting.
25 Q. Oh. That' s a surprise.
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APPLICATION OF IDAHO POWER FOR AUTHORITY
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1 Okay. Generally what are your duties as a
2 team leader with Idaho Power?
3 A. So I have -- I have two teams . My financial
4 accounting team is responsible for managing our monthly
5 financial statement closing process, and they get us all
6 the way up to our -- issuing our internal financial
7 statements and all the processes that -- and numbers --
8 a lot of the numbers that go into the financial
9 statements . And then our financial reporting team takes
10 those statements and makes them pretty for our
11 investors, our SEC financial statements and other
12 reports .
13 Q. And what' s your involvement with Schedule 72?
14 A. My team manages the accounting process all the
15 way from the generator interconnection process through
16 to the actual power purchase agreement . So we ' re
17 calculating all of the payments made to our energy
18 suppliers and then the Schedule 72 0&M charges as well .
19 Q. You understand that the process we're involved
20 in here is that my client, IdaHydro, has made a
21 challenge to the assumptions underlying the O&M charges
22 on interconnections that our particular hydro PURPA
23 projects are charged.
24 Are you aware of that?
25 A. I am, yep.
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Page 8
1 Q. Okay. And I want to talk about those
2 assumptions for a minute. We just finished with
3 Mr. Maloney, and he explained those, but I want to have
4 a solid basis with you so you and I are talking about
5 the same assumption.
6 So I 'm going to state them as I understand
7 them, please follow me along, and then tell me where I 'm
8 off the rails . Okay?
9 A. Okay.
10 Q. So as I understand the assumptions in
11 Schedule 72 , the first assumption is, all plant is the
12 same, okay, has the same O&M. Is that part of the
13 assumptions?
14 A. All plant by functional --
15 Q. All transmission --
16 A. -- by functional type, yes .
17 Q. Yes, by functional type. Transmission and
18 distribution plant in the Idaho Power system has the
19 same O&M cost?
20 A. Yes .
21 (Exhibit 3 was previously marked for
22 identification. )
23 BY MR. ARKOOSH:
24 Q. Okay. And to calculate -- and because we have
25 an Exhibit 3, which is the transmission charges, I 'm
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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 9
1 going to talk about transmission.
2 A. Okay.
3 Q. But for purposes of this deposition, I 'm going
4 to assume that all of the questions and answers also
5 apply to distribution so we don' t have to do things
6 twice. Is that okay with you?
7 A. Yep.
8 Q. Okay. So as I understand the assumptions,
9 there are -- there' s an overall capital cost embedded in
10 your transmission plant is an assumption?
11 A. Yes .
12 Q. It' s not an assumption; it' s a fact?
13 A. It ' s a fact, yep.
14 Q. And there ' s an overall capital cost embedded
15 in interconnections, PURPA interconnections?
16 A. Actual costs .
17 Q. Actual costs?
18 A. Yes .
19 Q. And there ' s an overall accounted-for cost in
20 the entire transmission plant in Idaho Power of
21 operation, maintenance, and transmission?
22 A. Actual system costs, yes, for 0&M.
23 Q. And so the ratio of capital costs is a
24 numerator of interconnections, and the capital costs --
25 overall capital costs in the system, including those is
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Page 10
1 the denominator.
2 Is the ratio of the percentage of the overall
3 O&M that is charged to the PURPA interconnections? Is
4 that how that' s done? Do I have that correct?
5 A. I can ' t speak to how the actual Schedule 72
6 rate is developed. That would be Mr. Maloney' s
7 expertise .
8 Q. Okay. I think that' s what he told us. And
9 counsel has a chance to ask you questions, or his
10 testimony is what it is, both in his deposition and in
11 his pretrial testimony, but I am proceeding on that
12 basis .
13 A. Okay.
14 Q. And Mr. Maloney was asked some questions about
15 is that assumption accurate? Which the inference
16 underlying that question was, is all plant really the
17 same, or maybe some of these interconnections cost more
18 or less for O&M than the overall plant. So that' s where
19 we left off with Mr. Maloney.
20 A. Okay. Mm-hm.
21 Q. And there was some questions to him about
22 whether this has ever been ground-truthed, and to his
23 knowledge, it has not; it' s based on a set of
24 assumptions and a set of numbers .
25 So what I want to talk to you about is --
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1 well, before I get into it. What' s the -- I 'm going to
2 call it probably the wrong thing, but what' s the FERC
3 chart of accounts that you all use? Can you describe
4 that for me?
5 A. Sure . Yeah, we have a certain numbering
6 system that identifies certain activity. For example,
7 maintenance on overhead lines or maintenance on
8 underground lines or, you know, there ' s an operation
9 account and a maintenance account for each type of
10 activity: for transmission, distribution, power
11 production, all the different functions . So we follow
12 that chart of accounts for all of them.
13 Q. One set of the chart of the accounts is
14 transmission?
15 A. Mm-hm.
16 Q. And one set of the chart of accounts is
17 distribution costs?
18 A. Yep.
19 Q. And in those, there' s subsets of O&M and
20 administration for distribution?
21 A. Mm-hm.
22 Q. O&M administration for transmission?
23 A. Correct .
24 Q. Okay. And your answers are very short and
25 quiet, so she can' t take a nod of the head. So just be
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1 right out there and say yes or no or --
2 A. Okay.
3 Q. -- or, Tom, you're totally off the mark, so we
4 know what' s going on.
5 A. Okay.
6 Q. All right. So there' s a number -- I want to
7 show you what' s been marked as Exhibit 3 . And, again,
8 this is the transmission numbers . But there' s a total
9 O&M charge in Exhibit 3, and it' s line 14 .
10 A. Okay.
11 Q. Do I have that right?
12 A. Transmission 0&M assigned to transmission
13 service lines . Yep. Yes .
14 Q. Okay. And that' s the number we're dividing up
15 and parsing out, some to O&M for PURPA interconnections
16 and some for 0&M for the rest of Idaho Power' s
17 transmission plant?
18 A. Again, that I cannot speak to; I 'm not
19 familiar with how the rates are developed.
20 Q. Do you know where this number comes from?
21 A. It looks like it probably comes from our FERC
22 Form 1 information, which would come directly from our
23 chart of accounts .
24 Q. Okay. So we'd look at the accounting that you
25 keep in accordance with the FERC chart of accounts, and
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1 you would have some numbers and you add those numbers
2 up, and it gives you a total, and then you report to
3 FERC --
4 A. Correct .
5 Q. -- is that correct?
6 A. Yes .
7 Q. And FERC is -- these chart of accounts,
8 they' re not suggestions . FERC requires you to keep your
9 books that way?
10 A. Yes .
11 Q. So where do the numbers -- and I 'm not asking
12 you to identify the account number. Okay? But how do
13 you get these numbers?
14 A. Well, through several different methods . We
15 have a general ledger system. So all of our costs go
16 into our general ledger system. As people charge labor
17 or charge purchase services or materials, all of those
18 costs are assigned to specific accounts, and all that
19 account information is pulled into the reports for the
20 FERC form.
21 Q. Okay. So these are operational expenses, but
22 you have the same for capital expenses as well, I
23 imagine, if you build -- I know you're building a
24 transmission line over the hill in Ketchum. That goes
25 into a capital account; is that correct?
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1 A. Yes .
2 Q. I had a line built to a house site, and the
3 Idaho Power men came out, and it was an all-man crew.
4 And, first, the engineers came out, and a very
5 interesting one stood in the middle of the field and
6 went like this and said, Put the pole right there. And
7 then the men with the pole truck came out and then the
8 men with the line truck came out.
9 How is that activity captured into line 14?
10 That was a capital expenditure, but how were those
11 activities captured? Did somebody give you a chit? Or
12 how does that work?
13 A. So for capital -- sorry. For capital work or
14 for 0&M? All of it?
15 Q. Expense work, not capital work.
16 A. Expense work.
17 Generally we would have work orders created or
18 work orders written for kind of areas of the territory.
19 Those would then further be classified as transmission,
20 distribution, you know, based on the functional
21 classification but by area. So somebody knows when they
22 go to do work on a specific line or station in
23 Twin Falls, then they have kind of a blanket work order
24 that those charges go to .
25 Q. Okay. And there ' s a monetary amount put on
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1 that work order at some point?
2 A. For direct -- yeah, direct labor, materials,
3 purchase services .
4 Q. Okay. So if you have a contractor, you know
5 what they charged.
6 A. Mm-hm.
7 Q. If you send a truck out, you have a set charge
8 for both labor and use of the truck?
9 A. Mm-hm.
10 Q. And if you have to install a transformer that
11 blew out, for instance, you know what the transformer
12 cost is, and there' s a cost to that; correct?
13 A. Correct .
14 Q. And so you add all of those up and you put
15 them in your various pots . You've got a transmission
16 pot and you've got a distribution pot, and so you come
17 up with -- for transmission O&M, you've come up with a
18 $5 million figure here in line 14?
19 A. Yes .
20 Q. Okay. So is that the same? One witness
21 testified that -- and I 'm not going to get these numbers
22 exactly right. But generally, I can inform you that he
23 testified that they go out, say, to look at these
24 interconnections on these plants once a month and then
25 once every three months, and then once every quarter or
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1 something like that, and then annually, they do some
2 kind of a review.
3 Are you familiar with that at all?
4 A. I am not, no.
5 Q. But there would be a work order that said this
6 truck went out and these guys looked at the batteries in
7 this interconnection and did a visual observation and
8 then came home. There'd be a work order for that with a
9 monetary amount?
10 A. Okay. It would probably be a blanket work
11 order, not specific to, you know, specific equipment
12 or -- yeah.
13 Q. Okay. But there could be?
14 A. I suppose anything is possible . There is not
15 currently work orders written per facility -- other than
16 for capital .
17 Q. If you have general journal, you have inputs
18 in that general journal, and it' s a discretionary
19 decision how granular those inputs might be; is that
20 correct?
21 A. Well, I wouldn ' t say it ' s discretionary. It ' s
22 according to what our PUC has directed us to track the
23 level of expenses at .
24 Q. Okay. And there was discussion that the
25 reason we're doing Schedule 72 the way we do Schedule 72
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1 is there' s a Commission-directed methodology?
2 A. Correct .
3 Q. And if the PUC, whose employees are sitting
4 here in the room today, directs Idaho Power to do a
5 certain thing, they' ll do it?
6 A. We should figure out a way to do it, sure .
7 Q. Yes, ma'am. Okay.
8 Can we have this marked as 4 , please?
9 (Exhibit 4 was marked for identification. )
10

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1 Q. Okay. So this number 12 says, "Separate
2 records shall be maintained by electric plant accounts
3 of the book cost of each plant. "
4 And you do that, that would be -- that' s why
5 you know what the initial investment is on Exhibit 4?
6 A. Correct .
7 Q. "Owned, including additions by the utility to
8 plant leased to others, and of the cost of operating and
9 maintaining each plant owned and operated. "
10 And Idaho Power does own these
11 interconnections; correct?
12 A. We do.
13 Q. Okay. So it seems to me that whether you
14 interpret each plant to be a regional question or to be
15 plant specific, as it seems to say, there is certainly
16 room in the FERC chart of accounts to keep track of what
17 it costs to do the maintenance and operation and
18 administration of each interconnection; correct?
19 A. Well, I think if you read on to the next
20 sentence, it kind of clarifies that you could use that
21 at each line or group of lines or -- it doesn' t seem to
22 indicate that it has to be at each individual facility.
23 Q. It can be either one. Let' s read that
24 language.
25 "The term 'plant' as here used means each
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1 generating station and each transmission line or the
2 appropriate group of transmission lines . "
3 So you have a choice of doing it
4 plant-by-plant basis or regionally as you do it;
5 correct?
6 A. Correct .
7 Q. So there' s certainly room to do it on a
8 plant-by-plant basis under the FERC chart of accounts?
9 A. With different set of accounting, yeah, a
10 different system setup.
11 Q. And, again, the only reason I 've heard so far
12 why we're using an assumption methodology rather than an
13 actual cost is it' s Commission-directed methodology?
14 A. Well, I wouldn ' t say that would be the only
15 reason. It is consistent with how we assess costs for
16 all of our retail customers .
17 Q. But Mr. Maloney said that' s never been trued
18 up. We don' t know if you're undercharging or
19 overcharging. Or, stated another way, we don' t know if
20 we' re really making the rate payor indifferent.
21 MR. WALKER: Objection. That ' s not what he
22 testified.
23 MR. ARKOOSH: Okay.
24 BY MR. ARKOOSH:
25 Q. You do need to answer the question. And I can
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1 just leave Mr. Maloney out of it.
2 A. I cannot speak to that . I 'm not in
3 regulatory --
4 Q. I 'm going to withdraw that last question.
5 If it' s never been ground-truthed and it' s
6 only based on assumptions, we don' t really know whether
7 it' s an overcharge or undercharge; we don' t know
8 actuals?
9 A. We know total system actuals, not by facility.
10 Correct .
11 Q. And so we don' t really know whether the rate
12 payor is indifferent?
13 A. I think we have a system that is a reasonable
14 methodology to ensure that they aren' t .
15 Q. You're assuming the rate payor is indifferent,
16 but we don' t know; correct?
17 A. It is not absolute, no .
18 (Exhibit 6 was marked for identification. )
19 BY MR. ARKOOSH:
20 Q. I 'm going to show you number 6 .
21 I 'm going to show you one of the many as you
22 said hundreds of accounts . This is 593, Maintenance of
23 Overhead Lines, Major Only.
24 "This account shall include the cost of labor,
25 materials used, and expenses incurred in the maintenance
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1 of overhead distribution line facilities, the book cost
2 of which is includible in Account 364, poles, towers,
3 and fixtures and Account 365, overhead conductors and
4 devices, and Account 369, services . See Operating
5 Expense Instruction Number 2 . "
6 So this would be one of the maintenance
7 accounts that the 5 million comes out of; correct?
8 A. Correct .
9 Q. Okay. And then I 'm just going to give you --
10 A. Actually, can I clarify that?
11 Q. Yeah.
12 A. I think the 5 million is specific to
13 transmission.
14 Q. Yes .
15 A. This is distribution.
16 Q. Absolutely correct.
17 A. Okay.
18 Q. So if I had in Exhibit 3, the distribution
19 exhibit, line 14 would include this?
20 A. Correct .
21 Q. Okay. When I say "this, " I mean Exhibit 6.
22 A. Sure .
23 Q. And I 'm going to hand you, in fairness, 364
24 and 365, which is Poles, Towers, and Fixtures, one of
25 the three that' s included in there. And we' ll mark that
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1 as Exhibit 7 .
2 (Exhibit 7 was marked for identification. )
3 BY MR. ARKOOSH:
4 Q. So Exhibit 7 shows the capital costs you' re
5 supposed to keep track of; is that correct?
6 A. Correct .
7 Q. Okay. As part of the overall accounting for
8 the expenses in the company?
9 A. Correct . These are just -- to clarify, these
10 are plant accounts, not the -- the 394 -- or 364 are
11 plant accounts, not 0&M accounts .
12 Q. Correct.
13 And so you have to show under 593, Exhibit 6,
14 the costs of labor, materials, and expenses incurred
15 and, for our interests here, the maintenance and
16 overhead -- of overhead distribution, this is the
17 distribution one -- line facilities, and it' s got all
18 the items that you have to keep track of.
19 So you have to show any work on the poles,
20 towers, and fixtures, you have to keep track of that.
21 Installing clamps or removing clamps or strain
22 insulators and guys in place, and you can do that on a
23 particular plant.
24 A. So just to clarify, these are examples of
25 items that should be charged to this account . They are
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1 not -- it ' s not indicating that we have to keep track of
2 the installation of additional clamps or removing
3 charge . It ' s not that granular. These are just
4 examples of types of charges that should go into the
5 593 account .
6 Q. Correct.
7 But going back to Exhibit 5 under the first
8 paragraph, you' re sure allowed to, and it says, "each
9 plant. "
10 A. Each. Yes .
11 Q. You're allowed to?
12 A. Mm-hm.
13 Q. Okay. And it references -- Exhibit 6
14 references Operating Expense Instruction 2 .
15 Do you see that on Exhibit 6?
16 A. I do, yes .
17 Q. And so I 'm going to give you Number 8 .
18 (Exhibit 8 was marked for identification. )
19 BY MR. ARKOOSH:
20 Q. Comment Number 2 under the distribution --
21 this one I think I got right, it' s the right comment.
22 A. Yep.
23 Q. And it says, "The cost of maintenance
24 chargeable to various operating expense and clearing
25 accounts includes labor, material, overheads, and other
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1 expenses incurred in maintenance work. A list of work
2 operations applicable generally to utility plant is
3 included hereunder. Other work operations applicable to
4 specific classes of plant are listed in functional
5 maintenance expense accounts. "
6 So to me that indicates that there' s some
7 granularity in at least labor materials and overhead; is
8 that correct?
9 A. We can distinguish between the different types
10 of costs, yes .
11 Q. Okay. So we have preview testimony that the
12 useful life of -- I 'm going to now talk about a
13 four-pole distribution interconnect.
14 A. Okay.
15 Q. Because I 'm not very savvy -- we don' t have a
16 chart of the transmission ones, but Exhibit 2 shows a
17 four-pole interconnect, and I ' ll just show you a copy of
18 Exhibit 2 .
19 (Exhibit 2 was previously marked for
20 identification . )
21 BY MR. ARKOOSH:
22 Q. And I 'm not -- I don' t know how much you' re
23 required to know about this kind of stuff.
24 A. Very little .
25 Q. Yeah.
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1 A. Just through what I 've been curious about .
2 Q. And my understanding is the transmission
3 interconnects are general at a substation, but this
4 would be right, we'd have a power plant right on one
5 side or the other of this and then Idaho Power' s grid
6 would be on the other -- or distribution system would be
7 on the other.
8 A. Okay.
9 Q. But we 're told that the useful life of one of
10 these -- well, what is "useful life" as an accountant?
11 Can you tell me what that is?
12 A. It ' s the average life of a plant that -- where
13 it stays operational .
14 Q. Okay. And we're told that the useful life was
15 the life of these first contracts about 36 years was the
16 useful life of a four-pole interconnect.
17 Does that sound right to you?
18 A. That would be consistent with the Schedule 72
19 table .
20 Q. Okay. I 'm going to ask you to try and define,
21 if you can, if it needs a definition, what the word
22 "useful" in the phrase "useful life" means .
23 Does that question even make sense to you?
24 A. Yes . I guess in my opinion, it means
25 operational and working as intended.
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4 MR. ARKOOSH: Take a brief recess, Donovan. I
5 think I 'm about finished.
6 MR. WALKER: Okay.
7 (Break taken from 10 : 47 a.m. to 10 : 50 a .m. )
8 MR. ARKOOSH: That concludes my questions, and
9 I want to thank you. Your counsel may have questions
10 for you.
11 THE WITNESS : Okay.
12 EXAMINATION
13 BY MR. WALKER:
14 Q. I won' t go through individually on some of
15 these different discovery responses, but you've
16 sponsored a number of responses to discovery. We went
17 through a couple of them in our discussion with Exhibit
18 Number 4; right?
19 A. Yes .
20 Q. And I guess, without going through additional
21 ones, there' s several, at least more than a couple, that
22 talk about assessment of actual costs or the tracking of
23 actual costs versus the Commission-directed methodology
24 based on system averages .
25 Is that a fair summarization?

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 37
1 A. Yes . That ' s correct .
2 Q. And if we were to look through the discovery
3 from the '23 general rate case from the present matter
4 as well as the previous matter, IPCE-18-07 , those all
5 contain numerous questions from IdaHydro on this topic
6 and answers that were sponsored by you?
7 A. Correct .
8 Q. Okay. And one last follow-up or clarification
9 about -- there was some discussion about impact to
10 customers or customer indifference. And, if you know,
11 the system operation and maintenance that forms the
12 basis of the average system cost into Schedule 72 , is
13 that the same way that the system O&M is calculated and
14 allocated to the retail customer base in a general rate
15 case?
16 A. That ' s my understanding, yes .
17 MR. WALKER: That ' s all the follow-up that I
18 had.
19 MR. ARKOOSH: I have nothing further based on
20 that .
21 THE WITNESS : Okay.
22 THE REPORTER: Do you want to order copies of
23 both transcripts and read and sign?
24 MR. WALKER: Yes, please .
25 MR. ARKOOSH: Same for us .
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 38
1 MR. WALKER: Does Commission staff want a
2 copy?
3 MS . MELANSON: Yes, please .
4 (Deposition concluded at 10 : 54 a .m. )
5 ---000---
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

i
Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 39
1 CERTIFICATE OF AUBRAE SLOAN
2
3 I, Aubrae Sloan, being first duly sworn,
4 depose and say:
5 That I am the witness named in the foregoing
6 deposition, that I have read said deposition and know
7 the contents thereof; that the questions contained
8 therein were propounded to me; and that the answers
9 contained therein are true and correct, except for any
10 change that I may have listed on the Errata Sheet
11 attached hereto.
12 DATED this day of 0.p ( kM\�Lr, 20 .
13
14 CHANGES ON ERRATA SHEET YES N0�
15
16
17 AUBRAE SLOAN
18
19 SUBSCRIBED AND SWORN to before me this
20 day of '�X , 20 2,C .
21
G
CHRISTY LYN DAVENPORT
Notary Public State of Idaho
Comm"n Number 52970 NAME OF NOTARY P BLIC
My Commission Ex r
ires Sep 10,2026
RESIDING AT
25 MY COMMISSION EXPIRES" I �0 11�0
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 40
1 REPORTER' S CERTIFICATE
2
3 I, SARAH L. GOEKLER, CSR No. 1178, Certified
4 Shorthand Reporter, certify:
5 That the foregoing proceedings were taken before
6 me at the time and place therein set forth, at which
7 time the witness was put under oath by me .
8 That the testimony and all objections made were
9 recorded stenographically by me and transcribed by me or
10 under my direction.
11 That the foregoing is a true and correct record
12 of all testimony given, to the best of my ability.
13 I further certify that I am not a relative or
14 employee of any attorney or party, nor am I financially
15 interested in the action.
16 IN WITNESS WHEREOF, I set my hand and seal this
17 2nd day Q.�...Qecember 2025 .
`' L GU '•
18 OTAR y:
19 ^PVBL1Ce^?
••.�OF 1�Q,••
20
21 SARAH L. GOEKLER, CSR No. 1178
22 Notary Public
23 PO Box 44385
24 Boise, Idaho 83711
25 My commission expires March 17, 2028
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
17 absolute address assess
Exhibits 20:2121:19 4 27:17 21:17 26:15
18 Absolutely administratio assessed
EXH 5 Sloan 5:1 4 28:16 n 35:6
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assumed
12
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: $126, 686 . 2 to bill

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
billed characterizati column 34:8 37:12 describe
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: billed to expenses

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
18:11,12,13,17 fixtures group 27:18 29:2 install issuing
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: expertise to life

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: lines to purpose

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
purposes references 26:16 37:14 show spent supposed
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: purposes to things

Idaho Power Company - Aubrae Sloan 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: tie to years

APPLICATION OF IDAHO POWER FOR AUTHORITY
IDAHO POWER COMPANY - RILEY MALONEY
November 18, 2025
ND
DEPOIDAHO
C
Local Reoltime Reporting & Videogrophy Experts PO Box 44385, Boise, I D 83711
0 1 0 0 0 . 0 0

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) Case No . IPC-E-25-22
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO UPDATE ITS OPERATION)
AND MAINTENANCE CHARGES )
APPLICABLE TO SCHEDULE 72, )
GENERATOR INTERCONNECTIONS TO )
PURPA QUALIFYING FACILITY )
SELLERS, )
DEPOSITION OF IDAHO POWER COMPANY
TESTIMONY BY RILEY MALONEY
Tuesday, November 18, 2025
Pages 1 - 41
REPORTED BY:
SARAH L. GOEKLER, CSR No . 1178
Notary Public

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 2
1 THE DEPOSITION OF RILEY MALONEY was taken on
2 behalf of the IDAHO POWER COMPANY, TESTIMONY BY RILEY
3 MALONEY at the offices of Arkoosh Law Offices, 913 W.
4 River Street, Suite 450, Boise, Idaho, commencing at
5 8 : 58 a.m. on Tuesday, November 18, 2025, before Sarah L.
6 Goekler, Certified Shorthand Reporter and Notary Public
7 within and for the State of Idaho, in the above-entitled
8 matter.
9
10 APPEARANCES :
11
12 FOR IDAHYDRO:
13 ARKOOSH LAW OFFICES
NICHOLAS J. EREKSON, ESQ.
14 C. TOM ARKOOSH, ESQ.
913 W. River Street, Suite 450
15 Boise, Idaho 83701
[e-mail]
16 [e-mail]
17
18 FOR IDAHO PUBLIC UTILITIES COMMISSION:
19 DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
20 ERIKA K. MELANSON, ESQ.
11331 W. Chinden Blvd. , Building 8
21 Suite 201-A (83714)
Boise, Idaho 83720
22 erika.melanson@puc. idaho.gov
23
24
25
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 3
1 APPEARANCES (CONTINUED) :
2
3 FOR IDAHO POWER:
4 IDAHO POWER COMPANY
DONOVAN E . WALKER, ESQ .
5 1221 W. Idaho Street (83702 )
Boise, Idaho 83707
6 dwalker@idahopower . com
7
8 ALSO PRESENT :
9 Connie Aschenbrenner, Idaho Power
10 Lisa Lance, Idaho Power
11 Yao Yin, Public Utilities Commission
12
13 ---000---
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25
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 4
1 I N D E X
2
3 TESTIMONY OF RILEY MALONEY PAGE
4 Examination by Mr. Erekson . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
5 Examination by Mr. Walker . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
6
7
8 E X H I B I T S
9 PAGE
10 Exhibit 3 Transmission Monthly Operations and 26
Maintenance Charge; 1 page
11
12
13
14 EXHIBITS PREVIOUSLY MARKED
15 PAGE
16 Exhibit 2 (First Referenced) 30
17
18 ---000---
19
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 5
1 Tuesday, November 18, 2025 8 : 58 a.m.
2 ---000---
3 RILEY MALONEY,
4 having first been duly sworn by a Certified Shorthand
5 Reporter for the State of Idaho, was examined and
6 testified as follows :
7 EXAMINATION
8 BY MR. EREKSON:
9 Q. Good morning. Can you please state your full
10 name for the record and spell your last name for the
11 record?
12 A. Yeah. My name is Riley Maloney,
13 M-A-L-O-N-E-Y.
14 Q. And, Riley, have you been deposed before?
15 A. No.
16 Q. I 'm just going to go over a few ground rules,
17 first of which is, it' s a question and answer. I ' ll ask
18 the questions, you answer. Second is, you were just
19 sworn in. So make sure -- you are under oath under the
20 penalty of perjury. You need to produce truthful
21 content. The third is, this is stenographically
22 recorded, and so it' s preferable if you use things like
23 yeses instead of mm-hm, and head nods won' t work either.
24 Do you understand?
25 A. Yes .
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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 6
1 Q. Okay. All right.
2 So we' re here today -- Idaho Power has filed
3 an application to update the Schedule 72 charges, and
4 initially offered testimony and support.
5 So can you provide a little bit about your
6 background before we jump into this?
7 A. Yeah. So I 'm a Policy and Strategy Leader at
8 Idaho Power in the Regulatory Affairs Department . And,
9 there, I oversee the provision of regulatory supports
10 and strategic guidance related to kind of, like,
11 integrated resource planning, demand side management,
12 wildfire activities, among other various topics .
13 Q. Okay. How long have you been in this role?
14 A. I 've been in my current role for a little bit
15 less than a year, but I 've been with Idaho Power for --
16 coming up on five years now.
17 Q. Five years?
18 A. Yeah.
19 Q. What'd you do prior to that?
20 A. When I first started at Idaho Power, I was in
21 tariff admin, so working a lot with Commission rules
22 and --
23 (Reporter interruption; off the record. )
24 BY MR. EREKSON:
25 Q. So what'd you get hired on as for Idaho Power?
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 7
1 A. Yeah, so when I first started, I was working
2 in tariff admin. So working a lot with Commission rules
3 and company' s Commission-approved tariffs . So ensuring
4 compliance with all the rules either the Commission
5 requires or that is stated within our tariff.
6 Q. And including 72 , Schedule 72 or different
7 tariffs?
8 A. Primarily different tariffs, Schedule 72 to a
9 very limited extent --
10 Q. Okay.
11 A. -- just because there are some synergies with
12 Schedule 72 to what we refer to as rule age, which is
13 kind of distribution interconnects for customers .
14 Q. Okay. And then prior to working at
15 Idaho Power, where did you work?
16 A. I was at a nonprofit called Boise Valley
17 Economic Partnership.
18 Q. How long were you there?
19 A. A little less than two years .
20 Q. And what was your role?
21 A. So I was conducting economic research and
22 project management for prospective businesses wanting to
23 relocate to the Valley.
24 Q. What kind of research?
25 A. So, like, demographic research. Mostly when
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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 8
1 businesses would want to either relocate here or expand
2 their operations -- they were really interested in kind
3 of the talent pipeline .
4 Q. Was it qualitative? Quantitative? Both?
5 A. Both.
6 Q. You did work with, like, models, like economic
7 models?
8 A. Yes .
9 Q. Okay. And then prior to that?
10 A. I was at a firm that was outside of
11 San Francisco. It was called Research Data Group. So
12 at that firm -- they had an office in Boise, and so at
13 that firm, working with publicly traded companies that
14 were filing their 10-Ks and 10-Qs with the SEC.
15 Q. Okay.
16 A. So mostly kind of on the formatting side.
17 So -- I 'm not sure if you ' re familiar with the term
18 EDGAR. That ' s the SEC ' s kind of electronic database
19 where all the files get electronically submitted. So
20 mostly just formatting to ensure they look good in HTML
21 format, but also ensuring compliance, to some extent,
22 with the SEC requirements .
23 Q. Was that your first job out of college?
24 A. It was .
25 Q. Okay. And where 'd you go to school?
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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 9
1 A. Boise State .
2 Q. What did you -- what' s your degree in?
3 A. Economics .
4 Q. Master? Bachelor' s?
5 A. Bachelor ' s .
6 Q. Okay. Did you -- any particular area within
7 economics that you focused on?
8 A. No. Just general .
9 Q. Did you have an honor' s, like a dissertation
10 or some kind of senior capstone project?
11 A. No. I mean, there was a -- there was a
12 renewable project that -- I don ' t know if I ' d call it
13 honor ' s or capstone, but if you -- it was displayed, and
14 I forget the name .
15 Q. Was it energy related?
16 A. Yeah. Because I was in an environmental
17 economics course --
18 Q. Okay.
19 A. -- but, I mean, very far distance from what
20 we ' re talking about here .
21 Q. Okay. Fair enough.
22 So you filed -- well, you provided some
23 testimony that you gave in response to questions as far
24 as changing the current tariff of the 72 schedule.
25 So, I guess, in your words, why does
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 10
1 Idaho Power want to make this change?
2 A. Well, it primarily results from provision out
3 of our ' 23 general rate case settlement stipulation
4 where we agreed to update Schedule 72 to reflect current
5 operating assumptions and metrics . So that is what has
6 prompted the update to a previously Commission-approved
7 methodology where we ' re just updating operating
8 assumptions and metrics to reflect more current costs .
9 Q. So you're proposing changing from an escalated
10 rate to just an average rate?
11 A. Correct -- a levelized rate .
12 Q. A levelized rate.
13 And that' s different than some kind of
14 average?
15 A. The 35-year de-levelized or inclining rate
16 that is currently under Schedule 72 uses the same
17 underlying basis as what we ' re proposing for the fixed
18 levelized rate .
19 Q. Okay. And under the current schedule, it' s
20 over 35 years . It says de-levelize, but it' s
21 escalating -- correct? -- over the 35 years?
22 A. Yeah, right . So it ' s de-levelized on the
23 beginning half and then escalates on the latter half.
24 Q. The idea being that a QF has more operating
25 and maintenance over time?
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 11
1 A. That is what the argument was at the time that
2 the Commission required us to implement that.
3 Idaho Power -- my understanding is at the time when this
4 was established, we did not advocate for that kind of
5 treatment. We had advocated for a levelized, but
6 ultimately the Commission asked that we implement a
7 de-levelized approach for a number of reasons .
8 Q. So just for purposes of this record, can you
9 explain how the -- how the rates would increase over
10 time in a de-levelized approach?
11 A. Are you asking under Schedule 72 as it
12 currently exists --
13 Q. Exactly.
14 A. -- why did the rates escalate?
15 Q. Yeah. Just explain how they escalated.
16 A. At the end of the day, we ' re trying to get to
17 the same amount. And so as I had previously mentioned,
18 the de-levelized rate is using the same underlying
19 amount . It ' s just de-levelized. Right?
20 So the very beginning amounts are lower,
21 whether there ' s an inflation adjustment and some other
22 assumptions that are included that then -- because the
23 rate is lower on the front end, then we have to kind of
24 ramp it up over time to ensure at the very end of that
25 35-year period, it ' s more or less equal to what we would
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 12
1 have recovered had a levelized rate just been
2 established throughout the entirety of that period.
3 Q. So a QF in Years, you know, 1 through 5 pays
4 less in interconnection O&M than a QF in Year 20, just
5 to break it down; correct?
6 A. That ' s correct .
7 Q. Okay. And then at the end of that 35-year
8 rate, just for the record, what happens?
9 A. It switches to a levelized rate, so exactly
10 what we ' re proposing here .
11 Q. Okay. Now -- let' s see.
12 So we' re switching from this escalating to a
13 de-levelized -- that kind of creates winners and losers .
14 Right. There ' s some people that will pay more and some
15 that will pay less?
16 A. Depending on where they' re at on the current
17 schedule, yes .
18 Q. So if they're past some kind of median tipping
19 point, you know, closer to Year 35, the current
20 schedule, they' re going to pay less?
21 A. Correct .
22 Q. But if they were before that, that tipping
23 point, they' re going to pay more just by virtue of kind
24 of an accounting change?
25 A. Yeah. Although I would also clarify, had we
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 13
1 not changed it -- I mean, they will eventually pay more
2 over time . Right? And so long-term, they should be
3 indifferent to the change; it ' s more of a cash flow.
4 Because, again, we ' re targeting that same levelized
5 amount . Right?
6 Q. Yeah, but you're talking, like, if they
7 renewed. But -- I mean, the ones that switch over
8 they' re not just going to -- it' s not necessarily just
9 dollar for dollar; right?
10 A. Correct .
11 Q. There' s winners and losers?
12 A. Again, depending upon where they' re at on that
13 schedule, but had -- had we maintained the same
14 schedule, we would be targeting that same fixed amount .
15 Q. Okay.
16 A. And so, yes, today they may pay more, but over
17 that 35-year period, they would pay the same amount .
18 Q. Okay. In your testimony, you talked about the
19 simplification?
20 A. Mm-hm.
21 Q. I mean, it' s apparent -- I can see the
22 simplification when you explain it. But are there other
23 ways in which this change would simplify things for
24 Idaho Power?
25 A. Well, it ' s also kind of reflective of the
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 14
1 current environment in which PURPA contracts are
2 established, I mean, when this methodology was first
3 implemented. My understanding is most contracts are
4 roughly 35 years in length, and now they can range from
5 2 to 20 years .
6 So to really reflect that variability, a
7 levelized rate is more appropriate so that you don ' t
8 have folks falling off after the first couple of years,
9 and -- I mean, there is a subsidy occurring there in the
10 first couple of years where they' re not paying the full
11 operation of maintenance costs . Right? And so to have
12 a levelized, that ensures that we ' re appropriately
13 recovering.
14 Q. And are those mostly, like, wind and solar
15 folks that have the shorter contracts?
16 A. I believe so, but I 'm not an expert in that
17 area.
18 Q. Fair enough.
19 So now, are there less assumptions used, I
20 think, in the method that you're proposing to switch to
21 than the prior method?
22 A. Yeah. We don' t have to assume, like, an
23 inflation factor or other various things . It ' s much
24 more straightforward.
25 Q. It' s a simpler calculation; right?
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 15
1 A. Correct .
2 Q. Can you explain what the calculation is?
3 A. Yeah. So, I mean, at a very high level, we ' re
4 essentially taking the proportion of either distribution
5 or transmission plant, identifying what proportion of
6 O&M-related costs should apply to that plant. And so
7 maybe a better way of framing this -- so for
8 transmission, because that ' s a cleaner example, we look
9 to determine how -- what proportion of overall
10 transmission plant should be allocated to 0&M costs in
11 respect to Schedule 72 ' s monthly charge .
12 Q. And you used the term 0&M broadly, but I think
13 you' re specifically referring to interconnection 0&M?
14 A. I 'm referring to system-level transmission
15 0&M, which we then proportion or allocate a portion of
16 to Schedule 72 .
17 Q. And then you do that based on the relative
18 size of the initial capital investment?
19 A. So when we ' re developing the monthly rate for
20 transmission, as we have currently proposed -- right now
21 on Schedule 72, there ' s a 138 kV, and a 161 kV amount
22 that ' s contemplated of, I believe, it ' s Table 1 .
23 So we 've taken that proportion of plant
24 investment relative to overall transmission plant
25 investment, and I think it came out to be about
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 16
1 20 percent . Then we take that 20 percent and say, okay,
2 well, because those are -- that ' s the proportion of
3 those two line voltages, then 20 percent of
4 transmission-related 0&M is what is being captured in
5 that monthly charge . And then we also proportionally
6 allocate some administrative costs .
7 Q. Okay. So I 'm going to slow you down a little
8 bit, both for the record and just for my own personal so
9 I understand. This is a little bit of another language
10 when you start breaking this out.
11 So you take all the -- you mentioned two
12 different rates. Can you say those rates again, the
13 160?
14 A. So that ' s the voltages .
15 Q. That' s the transmission --
16 A. Transmission.
17 Q. -- what you classify as transmission?
18 A. Yes .
19 Q. It was 161?
20 A. And 138 .
21 Q. Okay. So 161 is the transmission, and 138 is
22 the distribution?
23 A. 138 is what is also contemplated in Table 1,
24 which we would consider to be, like, transmission-level
25 interconnects .
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 17
1 Q. Okay. So those two are both transmission
2 levels?
3 A. Yes .
4 Q. And you look at the whole systemwide and you
5 say, Hey, how much was the initial capital investment
6 into this system?
7 A. We are using the plant investment for those
8 two line voltages --
9 Q. Okay.
10 A. -- and then comparing that to the overall
11 transmission plant to say what is this proportion, which
12 we then use as kind of the allocation factor for
13 overall, like, transmission 0&M costs .
14 Q. So when you say "systemwide, " do you mean over
15 all of Idaho Power systems?
16 A. Specific to transmission.
17 Q. Okay. So over the whole state?
18 A. Correct .
19 Q. Anything that uses those two -- the 161 or the
20 138?
21 A. No. In any 0&M that is classified as
22 transmission --
23 Q. Okay.
24 A. -- then gets a 20 percent share . So, again,
25 using that 20 percent base --
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Page 18
1 Q. You say "any 0&M that' s" -- I just want to
2 make sure I understand.
3 You mean any facility that' s 0&M -- any
4 facility gets allocated that because -- can you clarify
5 what you mean by that?
6 A. Yeah. So I guess I 'm not sure how familiar
7 you are with, like, the FERC accounts . So there ' s -- we
8 have our plant, and so the -- to determine that
9 20 percent allocation, we ' re looking purely at the plant
10 amounts . Right? And so we have that 20 percent . And
11 then further down -- I want to say it ' s in the 500s,
12 it ' s -- there ' s specific accounts that are solely for
13 transmission 0&M activities .
14 Q. You're talking about 565, FERC 565?
15 A. I don ' t know if it ' s --
16 Q. You mentioned it in your testimony.
17 A. So the one that I mentioned in the testimony
18 is one that we pulled out of the calculation because it
19 was related to wheeling charges that Idaho Power incurs
20 when we import energy.
21 Q. Like, out of state, like a contract with
22 California, kind of thing?
23 A. Yeah. Just when we ' re importing energy, that
24 had previously been included in the calculation for the
25 transmission rate . When I was updating this, I realized
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Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 19
1 it was not appropriate to include it because, again,
2 generation interconnects are not incurring or causes us
3 to incur that cost . Right? And so we should not be
4 recovering that portion.
5 Q. So it' s going to be helpful for me and helpful
6 for the record, I think, when we 're talking about
7 interconnection O&M versus 0&M that just relates just to
8 transmission lines .
9 A. Well, so --
10 Q. Are they the same, or is there a difference?
11 A. So we do not differentiate interconnection 0&M
12 to system 0&M; it ' s all one in the same .
13 Q. It' s all just O&M?
14 A. Yeah. Well, because once the interconnect --
15 once a project interconnects to our system, that portion
16 of plant is now just incorporated into our broader bulk
17 electric system, and we treat it as any other facility
18 on our system.
19 Q. So you don' t know how much O&M goes to any
20 specific interconnection?
21 A. No.
22 Q. You just don' t track it?
23 A. No.
24 Q. Okay. So -- let' s see.
25 So you mentioned this 20 percent number. Can
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1 you explain where that 20 percent comes from?
2 A. Yeah. So, again, it ' s based off of 13-month
3 averages of plant relative to, in transmission' s case,
4 the 138 kV lines and 161 kV lines .
5 So, for example, let ' s say that summed up to
6 5 million, just for simple purposes --
7 Q. Just a hypothetical?
8 A. Yeah, hypothetical .
9 -- but then our overall transmission plant was
10 25 million. So now we have 5 million divided by
11 25 million, you get 20 percent .
12 Q. And that would be just one of the 138? Is
13 that --
14 A. No. That ' s for both.
15 Q. For both of those?
16 A. Yes .
17 Q. So that' s systemwide, if you look at those
18 two -- look at those two, the 161 and the 138,
19 systemwide they -- the 0&M is 20 percent over, like, all
20 of Idaho Power' s 0&M?
21 A. Right. Well, because we ' re saying -- I mean,
22 all of our transmission 0&M has to relate to our
23 transmission facilities . Right? If these two line
24 voltages account for 20 percent of our transmission
25 investment, then it ' s reasonable to assume that
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1 20 percent of 0&M would be associated with those
2 facilities too .
3 Q. Okay. And the interconnection O&M is a part
4 of that 20 percent?
5 A. It would be, yeah, because it --
6 Q. Okay.
7 A. -- again, it ' s incorporated into our broader
8 bulk electrical system, and so there ' s not a specific
9 interconnection 0&M amount that gets added. It ' s
10 just --
11 Q. Okay.
12 A. -- when we go and perform work, it ' s just
13 included in broad 0&M.
14 Q. So to get to what is, quote/unquote,
15 transmission O&M under those two levels, it' s
16 essentially all of Idaho Power' s 0&M times .2?
17 A. Transmission --
18 Q. Transmission?
19 A. -- 0&M, yeah.
20 Q. Okay. All of Idaho Power' s transmission O&M
21 times .2?
22 A. Yeah. And then there ' s some adding of general
23 plant and administrative and general costs .
24 Q. Do those add up to something material or?
25 A. I would have to look exactly at the exhibit to
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Page 22
1 tell you .
2 Q. If you want to take a look, that' s okay.
3 All right. So did you get a chance to look at
4 the exhibit?
5 A. I did.
6 Q. Okay. So is that material to the -- that
7 20 percent when you start talking about add-ins? I just
8 want to make sure I understand this before I --
9 A. Yeah, I --
10 Q. -- I don' t want to oversimplify.
11 A. When looking at this specific to the exhibit
12 that was included in my prefile testimony, it ' s
13 approximately half of the overall costs that then are
14 used to establish the monthly rate .
15 Q. Okay. So it bumps it from 20 percent to
16 30 percent?
17 A. No, no . I guess the 20 percent -- we ' re not
18 taking a -- we ' re not taking the 20 percent and then
19 adding 10 percent to it . We ' re using that 20 percent to
20 then further allocate broad system A&G.
21 Q. A&G?
22 A. Administrative and general .
23 Q. Okay.
24 A. So we ' re using that 20 percent to then develop
25 additional allocation factors as I 've shown in my
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Page 23
1 exhibit here to then determine how much A&G should be
2 included.
3 Q. Okay. So break this down a little bit for me.
4 So the 20 percent -- when you say "half, " what
5 do you mean by half? Does it add up to half the
6 20 percent?
7 A. So what I mean by half is -- on line 14 of
8 this table -- I 'm not sure if you guys have it.
9 Q. I have your direct testimony.
10 MR. WALKER: Is that Exhibit 1 of your prefile
11 direct testimony?
12 THE WITNESS : It is, yeah.
13 MR. WALKER: And you' re looking at page 1?
14 THE WITNESS : Correct.
15 MR. EREKSON: I have the correct testimony.
16 Is that from the original?
17 THE WITNESS : Yeah. I mean, it' s going to be
18 included in both.
19 MR. WALKER: Yeah, he was looking at the
20 original one. I 've got a copy if you'd like .
21 MR. EREKSON: Do you care if I look at your
22 copy, Donovan, so I don' t have to go print it out?
23 Thank you.
24 MR. WALKER: Mm-hm.
25 THE WITNESS : So if you look at line 14 in
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1 this exhibit, you can see transmission 0&M assigned to
2 what we ' re calling transmission service lines . Is about
3 5 . 3 million.
4 BY MR. EREKSON:
5 Q. Okay.
6 A. And then if you look further down on line 28,
7 it says, "Total A&G Assigned. " It ' s about 4 . 4 million.
8 Q. Okay.
9 A. And so the total 0&M that we ' re looking to
10 recover that ' s inclusive of A&G is about 9 . 7 million,
11 and that is the amount that -- we ' re taking that amount
12 and then dividing it by the total transmission plant,
13 which includes kind of general plant to an allocable
14 share of general plant to develop that 3 . 326 percent on
15 line 30, which we then just divide by 12 to arrive at
16 the -- in this case, . 28 percent, but I know my --
17 Q. That' s the distribution amount, not the
18 transmission?
19 A. No . This is transmission.
20 Q. Okay. And distribution is the . 96 or . 9 in
21 this particular --
22 (Simultaneous colloquy; reporter
23 interruption. )
24 BY MR. EREKSON:
25 Q. -- in the nonupdated?
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1 A. Yes .
2 Q. Okay.
3 -- testimony?
4 A. Yeah, in the nonupdated testimony it ' s . 96 .
5 Q. It may be helpful -- and I 'm guilty of this
6 too, but I ' ll finish, and then you start, and then you
7 finish and I ' ll start. And I ' ll try not to interrupt
8 you --
9 A. Okay.
10 Q. -- if you try not to interrupt me. Okay?
11 A. Okay.
12 Q. We ' re just going to take a minute and mark
13 this and make it an exhibit --
14 A. Yeah.
15 Q. -- and I ' ll ask you some more questions and
16 it' ll --
17 A. Sure .
18 Q. -- be part of a record.
19 Do you care if we use your exhibit?
20 MR. WALKER: No .
21 MR. EREKSON: We can take a copy and mark it
22 and we can give you your original back.
23 MR. WALKER: That ' d be great .
24 And I ' d just like to note that that ' s
25 Exhibit 1 to his original prefiled direct testimony and
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1 it was subsequently updated. So the numbers that are
2 being sought in the case are different than the numbers,
3 but for purposes of the original methodology, that ' s --
4 MR. EREKSON: It ' s the same?
5 MR. WALKER: It ' s all the same, yeah.
6 (Off the record. )
7 (Exhibit 3 was marked for identification. )
8 MR. WALKER: Yeah, and just one more note for
9 the record, that the updates to that exhibit were filed
10 with the errata and corrected pages filing --
11 MR. EREKSON: Oh. Okay.
12 MR. WALKER: -- that was made on August 8th,
13 2025, and it went through with corrections to that same
14 page and format.
15 BY MR. EREKSON:
16 Q. Okay. Well, just for purposes of explaining
17 how this works, I 'm okay using the nonupdated if you
18 are --
19 A. Yeah.
20 Q. -- if you want us to hunt down the --
21 A. No.
22 Q. Okay. So when I look at line item 13, that' s,
23 you know, $25 . 8 million approximately?
24 A. Mm-hm.
25 Q. That' s for that -- we' re excluding that 565
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1 account. That' s total 0&M expense for -- that' s
2 transmission 0&M expense for all of Idaho Power?
3 A. Correct .
4 Q. Not just on those two -- those two, the 168
5 [sic] and the 131 [sic] .
6 A. No. That allocation occurs on the line below
7 at 14 . So where we ' re taking line 13 and multiplying it
8 by the 20 percent that ' s shown on line 3 .
9 Q. Okay. And those two are -- those two are
10 specifically related to QF interconnection? Like, why
11 those two numbers?
12 A. Those two numbers were used because those are
13 the voltages that are currently contemplated in
14 Schedule 72, like that ' s shown above Table 1 .
15 Q. Okay. Okay.
16 And then nothing else Idaho Power uses those
17 voltages?
18 A. We do allow interconnects at other voltage
19 levels, so all transmission levels . I will note -- I
20 mean, staff, in their comments in this case, had noted
21 that too and have proposed a slightly different approach
22 to consider those different voltage levels .
23 Q. Okay. Does it -- when considering staff' s
24 approach, does it change the story much?
25 A. For transmission, I don' t think so.
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1 There ' s -- really, staff' s approach is to weight the 0&M
2 charge . So if we have more interconnections occurring
3 at, let ' s say, 161 kV than we do at 230 kV, then we
4 would provide greater weight to that 0&M rate for
5 that -- for the 161 compared to 230, right, just to show
6 that there ' s more interconnects occurring at that
7 161 voltage.
8 Q. Okay.
9 A. I 'm not entirely certain, though, how much it
10 changes the end result, given for transmission. It' s
11 all using the same initial plant amounts and kind of
12 proportionally allocating there. And so. . .
13 Q. So this, you know, 25 . 8 million, that' s
14 over -- that' s all the transmission in Idaho Power over
15 all the different volts?
16 A. For transmission, yes .
17 Q. Okay. And so these PURPA interconnections
18 you' re saying are about a fifth of those?
19 A. We ' re saying the allocable share when we ' re
20 determining the system average amount, that we are using
21 that 5 million, plus the A&G, to come up with this . 28
22 in this case, which we are then saying essentially for
23 every dollar in transmission plant for these -- for
24 those voltage levels is roughly 28 cents of 0&M.
25 And so then we take that and for the
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1 interconnection -- the initial cost of, like, PURPA
2 interconnections, that ' s why we don ' t use the capital
3 costs that was initially required and applying these
4 rates to that to, again, reflect for every dollar this
5 is how much 0&M we can anticipate .
6 Q. Okay. So there' s an underlying assumption in
7 your model, correct, that -- the ratio, you know, stays
8 the same, the ratio between, you know, idaho Power' s O&M
9 and it' s initial, you know, capital investment and also
10 that of the PURPA interconnection facility; correct?
11 A. I might not be understanding. Can you
12 rephrase that?
13 Q. Yeah.
14 So it strikes me that you've developed this
15 ratio that you' re saying, Hey, systemwide your O&M
16 really relates to how much your initial asset is, right,
17 your initial capital investment -- there' s a
18 relationship?
19 A. Correct .
20 Q. And that same relationship, you use to
21 allocate cost to an interconnection facility?
22 A. Correct .
23 Q. Despite there being differences in
24 infrastructure?
25 A. Differences in infrastructure? How so?
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1 Q. So these interconnection facilities -- and
2 this was Exhibit. . .
3 MR. ARKOOSH: 2 .
4 (Exhibit 2 was previously marked for
5 identification . )
6 BY MR. EREKSON:
7 Q. Exhibit 2 are just essentially these four-pole
8 interconnection facilities, but the whole transmission
9 system of Idaho Power is not just comprised of four-pole
10 interconnection facilities; correct?
11 A. Correct . Although I would clarify, for the
12 four pole, I would assume that would be under a
13 distribution, like the distribution rate .
14 Q. Are you asking me a question or?
15 A. I 'm saying I don' t know exactly what voltage
16 levels the four poles may be . But if this is for --
17 depending upon the voltage level of the four pole, it
18 might be under the distribution.
19 Q. I guess my point is that these interconnection
20 facilities -- it' s not the same equipment as the rest of
21 Idaho Power' s transmission; right? These are very,
22 like -- they have a very discrete function; correct?
23 A. We ' re not developing the rate based off
24 specific equipment though. It ' s, really, to recognize
25 how much -- on system average, how much 0&M would we
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1 anticipate incurring relative to each dollar of
2 additional investment, irrespective of type of
3 equipment .
4 Q. Yeah, that' s the point though; right? You're
5 not taking into account that it is different equipment;
6 you're treating all the equipment the same?
7 A. We still have same kind of maintenance
8 activities for all different types of equipment. So we
9 still have to inspect poles regardless of whether it ' s
10 under our four-pole methodology here or if it ' s for a
11 broad stretch of transmission poles .
12 Q. You have to inspect them, but this isn' t the
13 same equipment that' s used throughout your system.
14 You're not saying that, are you, that you don' t just
15 have these replicas of -- that' s all Idaho Power has in
16 their transmission and -- or distribution?
17 A. I mean, we have poles and wires on our system.
18 I guess I 'm not entirely following.
19 Q. So, I guess, your testimony, then, is that
20 it' s -- they have the same costs, all -- these
21 interconnections facilities have the same costs as
22 everything else, or is it that you just treat them the
23 same?
24 A. We are using a previously Commission-approved
25 methodology that has recognized that, again, on a per
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1 dollar of capital investment or plant addition, how much
2 additional 0&M would we expect to incur, which is,
3 really, irrespective of the type of plant being
4 installed.
5 Q. It doesn' t matter what the plant is; it' s the
6 same methodology?
7 A. Yeah. It doesn ' t matter if it ' s a wood pole
8 here or a wire because, again, we ' re accounting for all
9 of that 0&M within the transmission expense .
10 Q. That current -- and I grant it this is
11 Commission approved, but it does treat them all the same
12 even though they're different; correct?
13 A. I guess I wouldn' t characterize them as being
14 different because it ' s -- again, we ' re looking at the
15 capital and -- like the additional plant that ' s coming
16 on our books, right, and then comparing that relative to
17 the expected 0&M.
18 Q. But aren' t you just looking at the additional
19 interconnection facility, not the whole plant?
20 A. As far as assigning the proportional share of
21 0&M?
22 Q. Yeah.
23 A. We are looking at the -- yes, the interconnect
24 capital cost .
25 Q. Just that piece of that plant?
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1 A. Correct .
2 Q. Not the entire plant; correct?
3 A. The entire plant being Idaho Power ' s broad
4 system?
5 Q. Well, the QF. Right? Like, when you' re -- it
6 just strikes me that we're allocating -- you' re taking a
7 ratio based on Idaho Power' s transmission costs to their
8 initial capital investment. You're developing this
9 rate, and then you' re applying it to a very discrete
10 portion of a QF, the interconnection facility; correct?
11 A. Correct .
12 Q. You're not looking at just, you know, the 0&M
13 for Idaho Power just for their interconnections for --
14 throughout. You're looking at Idaho Power' s -- their
15 entire transmission system, and then you' re applying it
16 just to a QF interconnect?
17 A. Right. But that --
18 Q. And the assumption is that they cost about the
19 same? That' s the assumption?
20 A. Yes . Because when we look to recover these
21 costs from customers -- again, we ' re not differentiating
22 them; it ' s all based off of system averages and
23 allocation. Right? So in order to ensure customers
24 remain indifferent to a QF' s interconnection, we have to
25 assume -- make that assumption.
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Page 34
1 Q. I mean, there -- you said you have to assume
2 to make that assumption. Why is that?
3 A. I guess I should say that is the assumption
4 that we have been directed to assume based off of the
5 Commission-established methodology.
6 Q. Okay. So, I guess, now that we've established
7 this assumption exists that we treat the interconnection
8 facility the same as the transmission facility
9 systemwide -- I think we agree on that, that' s -- and
10 that' s the current methodology. Whether you' re
11 levelized or de-levelized, that' s happening?
12 A. Correct .
13 Q. Has that assumption been tested? Have you
14 ever tested that assumption?
15 A. I would say that assumption ' s tested every
16 time we go in for a rate case where the credit that is
17 applied to customers -- so all the Schedule 72 revenue
18 that we recover is then treated as a revenue credit in
19 customer ' s rates when we ' re developing their rates . And
20 so I would say this assumption is tested and validated
21 in that forum where -- the reasonableness of are we
22 recovering enough.
23 Q. So earlier today you testified that you didn' t
24 track these -- the O&M related to these interconnection
25 facilities . You just don' t have a separate record of
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Page 35
1 it; correct?
2 A. Correct .
3 Q. So you have no idea to know what you're
4 allocating to this interconnection facility is actually
5 what' s been charged to these QFs .
6 A. We know what we ' re allocating to this
7 interconnection is the same proportional share that our
8 customers would otherwise have to shoulder if we didn ' t .
9 Q. Agree that you know that that' s the same
10 proportional share, but you don' t know if that -- if
11 that is the same as -- or anywhere near your actual
12 costs for maintaining this interconnection facility --
13 correct? -- because you just don' t track it?
14 A. We don ' t track it .
15 Q. So you don' t know then?
16 A. I would assume that ' s to be the case, yes .
17 Q. You'd assume that to be the case? I mean, do
18 you agree --
19 A. Yeah, we --
20 Q. -- you don' t know. It could be that -- it
21 could be higher or it could be lower?
22 A. Correct . Yeah, we don ' t track it, and
23 therefore there is nothing to necessarily compare
24 Interconnection A to, you know, some 0&M amount. We
25 just -- we don' t track it because, again, it gets
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Page 36
1 brought into our bulk electric system, and it ' s just a
2 part of our overall maintenance .
3 Q. So when you have a distribution facility
4 that' s charged, you know, .28 percent of that -- well, I
5 guess it' s an updated number. Is the updated
6 number .26?
7 A. Transmission facility.
8 Q. Transmission facility. It' s .26?
9 A. Correct .
10 Q. Which is what, a quarter of a percent a month
11 about?
12 A. Correct .
13 Q. So 1 percent every four months, 3 percent a
14 year. That could be much more than it costs Idaho Power
15 to actually maintain that facility then; correct?
16 A. On average, that ' s what we would expect, an
17 additional dollar of investment.
18 Q. That' s what you would expect based on the
19 assumptions; correct?
20 A. Correct . And that --
21 Q. But you don' t know whether that' s accurate
22 because it' s not tested; correct?
23 A. Those are the same costs that are recovered in
24 customer ' s rates and therefore that ' s why that
25 assumption exists .
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Page 37
1 Q. Yeah, but you don' t know whether it' s higher
2 or lower for what the QFs actually -- the maintenance
3 that' s actually incurred to the QF?
4 A. That ' s correct . Because we don ' t separately
5 track that .
6 Q. And so same for -- this is the distribution
7 that' s at the higher rate?
8 A. Yes .
9 Q. And is that a -- was that . 9 or . 96?
10 A. The initial filing was . 96, and then the
11 corrected version that Donovan had mentioned was . 9 .
12 Q. Okay. So a little under a percent a month
13 puts you at, what, 10 percent a year?
14 A. 11 . 4-ish based off the initial --
15 Q. I was being conservative --
16 A. Yeah.
17 Q. -- but 11 . 4 percent per year. And so I
18 just -- just to make this -- let' s say it' s a half a
19 million dollar facility, 500,000 . And, you know, even
20 at 10 percent, it would be $50 ,000 in operating and
21 maintenance per year. If it' s 11 percent, it' s 55. And
22 that could be -- because this is just based on
23 assumptions, this is based on what you'd expect, that
24 could be much higher than what the actual operating
25 maintenance that goes into this facility, or it could be
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1 lower, but you don' t know because you don' t track;
2 correct?
3 A. Correct .
4 MR. EREKSON: Okay. Do you have any other
5 questions?
6 MR. ARKOOSH: I think we need to mark that as
7 Exhibit 3 .
8 MR. EREKSON: Oh, this? She did it .
9 Do you have any follow-up questions, Donovan?
10 MR. WALKER: I don ' t think so, no .
11 Well, maybe just one .
12 EXAMINATION
13 BY MR. WALKER:
14 Q. So, Mr. Maloney, we talked about transmission
15 and 138 kV and 161 kV and that -- that comes from the
16 delineation on page 13 of Schedule 72 ; correct?
17 A. That ' s correct .
18 Q. And there ' s two charts on that page; right?
19 A. That ' s correct .
20 Q. And the other -- so all of our discussion was
21 about Table 1 and transmission?
22 A. Correct .
23 Q. And there ' s a second table for 138 and below,
24 and that' s what' s referred to as distribution?
25 A. For purposes of Schedule 72, yes .
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Page 39
1 Q. And then those both have their different
2 sheets and calculations?
3 A. Correct .
4 Q. But it' s the same Commission-directed
5 methodology?
6 A. That ' s correct .
7 Q. And the numbers that you testified here about
8 populating were just the exercise that you referred to
9 from the direction from the rate case of populating
10 existing methodology with updated numbers; right?
11 A. Correct .
12 MR. WALKER: I don ' t have any more .
13 MR. EREKSON: I don ' t have any questions based
14 on that .
15 MR. WALKER: Should I --
16 MR. EREKSON: Again, it went --
17 THE REPORTER: Off the record?
18 MR. EREKSON: We ' re okay going off the record.
19 (Deposition concluded at 9 : 47 a.m. )
20 ---000---
21
22
23
24
25
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APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 40
1 CERTIFICATE OF RILEY MALONEY
2
3 I, Riley Maloney, being first duly sworn,
4 depose and say:
5 That I am the witness named in the foregoing
6 deposition, that I have read said deposition and know
7 the contents thereof; that the questions contained
8 therein were propounded to me; and that the answers
9 contained therein are true and correct, except for any
10 change that I may have listed on the Errata Sheet
11 attached hereto.
12 DATED this day of 20 ZS
13
14 CHANGES ON ERRATA SHEET YES X NO
15
16
17 RILE MALONEY
18
19 SUBSCRIBED AND SWORN to before me this
20 day of �- {� 20
CHRISYN AVENPORT
Notary P6trk- itate of Idaho
Commission Nt mber 52970
My Commissi p2Exp res Sep 10,2026
23 NAME OF NOTARY PUBLIC
24 RESIDING AT Quto'DA ,k D
25 MY COMMISSION EXPIRES 0 IIO I 0
1
DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704

Change and Correction Sheet
Page: Line: Reads: Should Be: Reason for the Change
Or,
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Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
Page 41
1 REPORTER' S CERTIFICATE
2
3 I, SARAH L. GOEKLER, CSR No. 1178, Certified
4 Shorthand Reporter, certify:
5 That the foregoing proceedings were taken before
6 me at the time and place therein set forth, at which
7 time the witness was put under oath by me .
8 That the testimony and all objections made were
9 recorded stenographically by me and transcribed by me or
10 under my direction.
11 That the foregoing is a true and correct record
12 of all testimony given, to the best of my ability.
13 I further certify that I am not a relative or
14 employee of any attorney or party, nor am I financially
15 interested in the action.
16 IN WITNESS WHEREOF, I set my hand and seal this
17 2nd day ot...Z,ecember 2025 .
LG
18
Bye;:NOTARy':�:
�.19 •gi'�Nu.iolf�or7
20 ' �o
y'Nn,Ou,�•`'�
21 SARAH L. GOEKLER, CSR No. 1178
22 Notary Public
23 PO Box 44385
24 Boise, Idaho 83711
25 My commission expires March 17, 2028
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APPLICATION OF IDAHO POWER FOR AUTHORITY
160 allocable assigned
Exhibits 16:13 4 A 24:13 28:19 24:1,7
161 allocate assigning
EXH 3 Malon 15:21 16:19,21 4.4 A&g 15:15 16:6 32:20
ey 111825 17:19 20:4,18 24:7 22:20,21 23:1 22:20 29:21 assume
4:10 26:7 38:7 28:3,5,7 38:15 24:7,10 28:21 allocated 14:22 20:25
168 5 a.m. 15:10 18:4 30:12 33:25
$ 27:4 5:1 39:19 allocating 34:1,4 35:16,17
18 5 account 28:12 33:6 35:4, assumption
$25.8 5:1 12:3 20:6,10 20:24 27:1 31:5 6 29:6 33:18,19,
26:23 28:21 accounting
allocation 25 34:2,3,7,13,
2 5.3 12:24 32:8 17:12 18:9 14,20 36:25
37:20 2a:3 accounts
$ 000 22:25 27:6 assumption's
7:
33:23 34:15
2 537:19 1 curs amount assumptions
14:5 21:16,21 37:19 accurate p
30:3,4,7 11:17,1913:5, 10:5,811:22
5005 36:21 14,17 15:21 14:19 36:19
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: $25 . 8 to break

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: breaking to escalated

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: escalates to level

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: levelized to quarter

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: question to times

Idaho Power Company - Riley Maloney 11/18/2025
APPLICATION OF IDAHO POWER FOR AUTHORITY
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DepoIdaho, PO Box 44385, Boise, ID 83711 (208) 345-3704
Index: tipping to yeses