20251224Direct Brady.pdf

RECEIVED
DECEMBER 24, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY' S )
COMPLIANCE WITH ORDER NOS . 34031 ) CASE NO. IPC-E-25-35
AND 35816 FOR A PRUDENCE )
DETERMINATION OF HELLS CANYON )
COMPLEX RELICENSING COSTS FROM )
JANUARY 1, 2016, THROUGH )
DECEMBER 31, 2025 . )
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
JESSICA G. BRADY

1 Q. Please state your name, business address, and
2 current position with Idaho Power Company ("Idaho Power" or
3 "Company") .
4 A. My name is Jessica G. Brady. My business
5 address is 1221 West Idaho Street, Boise, Idaho 83702 . I am
6 employed by Idaho Power as a Regulatory Consultant in the
7 Regulatory Affairs Department.
8 Q. Please describe your educational background.
9 A. In May 2016, I received a Bachelor of Science
10 degree in Economics and a Bachelor of Arts degree in
11 Spanish from the University of Idaho. I have also attended
12 "The Basics : Practical Regulatory Training for the Electric
13 Industry, " an electric utility ratemaking course offered
14 through New Mexico State University' s Center for Public
15 Utilities, "Electric Utility Fundamentals & Insights, " an
16 electric utility course offered through the Western Energy
17 Institute, and Edison Electric Institute' s "Electric Rates
18 Course" offered at the University of Wisconsin-Madison.
19 Q. Please describe your work experience with
20 Idaho Power.
21 A. In September 2021, I accepted a position at
22 Idaho Power as a Regulatory Analyst in the Regulatory
23 Affairs Department. I was promoted to Senior Regulatory
24 Analyst in October 2023 and to Regulatory Consultant in
25 October 2025 . As a Regulatory Consultant, I am responsible
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Idaho Power Company

1 for running the AURORA model ("AURORA") , an hourly economic
2 dispatch model, to calculate net power supply expenses
3 ("NPSE") . AURORA is used for ratemaking purposes, as well
4 as in the determination of the marginal cost of energy used
5 in the Company' s marginal cost analyses . My duties also
6 include testifying on behalf of Idaho Power in Annual Power
7 Cost Update ("APCU") and other power supply cost-related
8 proceedings, as well as providing analytical support for
9 regulatory activities within the Regulatory Affairs
10 Department .
11 Q. What is the Company requesting in this case?
12 A. In compliance with Order Nos . 34031 and 35816
13 issued in Case Nos . IPC-E-16-32 and IPC-E-23-13,
14 respectively, Idaho Power is requesting a prudence
15 determination for Hells Canyon Complex ("HCC") relicensing
16 costs incurred from January 1, 2016, through December 31,
17 2025 . The Company' s filing at this time includes
18 approximately $305 million in HCC relicensing costs
19 recorded through September 30, 2025 ("Q3 2025") , and the
20 Company will submit a supplemental application containing
21 information for expenditures incurred in October, November,
22 and December 2025 ("Q4 2025") in early 2026 .
23 Q. Why is the Company filing before all 2025
24 costs are available?
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Idaho Power Company

1 A. The Company is initiating the proceeding at
2 this time to provide adequate time for the Idaho Public
3 Utilities Commission ("Commission") Staff to establish a
4 schedule that will allow for review of the record and
5 discovery related to licensing activities to be conducted
6 prior to the Spring 2026 retirement of the Company' s
7 Environmental Affairs Director, Brett Dumas, who has
8 historical and technical knowledge relevant to this case .
9 Q. How is the Company' s case organized?
10 A. My testimony presents the Company' s request
11 for a prudence determination regarding the HCC relicensing
12 costs incurred after December 31, 2015, explains the
13 relevant regulatory history, and describes the Company' s
14 compliance with Order Nos . 34031 and 35816 . Company witness
15 Brett Dumas will then present a narrative of Idaho Power' s
16 relicensing efforts over the last ten years .
17 I . OVERVIEW OF THE HCC
18 Q. What is the Hells Canyon Complex and why is it
19 significant to Idaho Power?
20 A. The Hells Canyon Complex consists of three
21 hydroelectric developments, Brownlee, Oxbow, and Hells
22 Canyon, located on the Snake River at the Idaho-Oregon
23 border. It represents approximately 1, 276 megawatts of
24 nameplate generation capacity or about 24 percent of the
25 Company' s total generating capacity. As the Company' s
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Idaho Power Company

1 largest hydroelectric resource, the HCC plays a vital role
2 in delivering reliable, affordable, and clean energy to
3 customers .
4 Q. Is a license required to operate the HCC?
5 A Yes . Idaho Power obtains licenses for its
6 hydroelectric projects from the Federal Energy Regulatory
7 Commission ("FERC") . The process for obtaining a license
8 includes an extensive public review and involves numerous
9 resources and environmental agencies .
10 Q. What is the status of Idaho Power' s current
11 license for the HCC?
12 A. In July 2003, the Company filed an application
13 with FERC for a new long-term license in anticipation of
14 the expiration of the then-existing license in July 2005 .
15 Since that expiration, Idaho Power has operated the project
16 under annual licenses issued by FERC.
17 Q. When does Idaho Power estimate receiving a new
18 long-term license from FERC?
19 A. Although Idaho Power is unable to predict with
20 certainty the timing of the issuance of a new license for
21 the HCC, the Company estimates issuance of the license will
22 occur no earlier than 2027 .
23
24
25
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Idaho Power Company

1 II . REGULATORY HISTORY
2 Q. Has Idaho Power received a prudence
3 determination for previously incurred HCC relicensing
4 expenses?
5 A. Yes . In Case No . IPC-E-16-32, Idaho Power
6 applied to the Commission to deem prudent and eligible for
7 future inclusion in rates HCC relicensing costs incurred
8 through December 31, 2015 . The Company sought this prudence
9 review outside of a general rate case to allow for a more
10 focused review of the relicensing costs, given the large
11 volume of transaction data, the multi-decade span of the
12 project, and the impending retirement of key employees with
13 direct knowledge of relicensing activities .
14 Q. What was the outcome of that case?
15 A. Ultimately, in Order No. 34031, the Commission
16 approved the Settlement Stipulation filed by Idaho Power,
17 Commission Staff, and Idaho Irrigation Pumpers Association
18 ("IIPA") , collectively referred to as the Signing Parties .
19 Q. Can you describe the pertinent portions of the
20 Settlement Stipulation?
21 A. Yes . Under the Settlement Stipulation, the
22 Signing Parties agreed to accept HCC relicensing
23 expenditures incurred through December 31, 2015, totaling
24 approximately $213 . 6 million. An additional $2 . 9 million
25 associated with a settlement with Baker County, Oregon, was
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Idaho Power Company

1 also deemed prudently incurred but was reclassified as
2 operations and maintenance expense to be deferred and
3 amortized at a later date.
4 The Stipulation also contained several compliance
5 obligations for the Company, including: (1) development of
6 a refined process for submitting annual reports to the
7 Commission detailing HCC relicensing activities and
8 associated costs; (2) as part of the effort associated with
9 refined reporting, improve how the Company presented work
10 order descriptions; (3) implement a document-retention
11 policy specific to HCC relicensing materials to ensure all
12 documents are retained until such expenditures are included
13 in customer rates; (4) more broadly modify its information
14 retention policy to provide evidence of actual expenditures
15 and purpose, either in physical or electronic format, for
16 future capital projects that are expected to span more than
17 five years, until such time as a prudence determination of
18 the expenditures has been made and the expenditures are
19 included in customer rates .
20 The Signing Parties also agreed that in the event
21 Idaho Power engages in settlement discussions or activities
22 with any party as part of the relicensing effort, the
23 Company would involve Staff where appropriate, in
24 discussions regarding the proposed accounting of costs that
25 may be incurred as a result of those settlement
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Idaho Power Company

1 discussions .
2 Finally, the Signing Parties agreed that the Company
3 would request a prudence determination for relicensing
4 expenditures incurred after December 31, 2015, covering a
5 period extending up to five years from the Commission' s
6 approval of the Settlement Stipulation.
7 Q. Has Idaho Power complied with the described
8 requirements for annual reporting and work order level
9 information?
10 A. Yes . Throughout 2018, the Signing Parties
11 collaborated on the content to be incorporated into future
12 annual reports, including how costs would be categorized
13 and described in the Company' s accounting system. In
14 February 2019, the Company filed its first annual report
15 under the new guidelines for the year ending 2018 .
16 Q. Can you describe how costs are categorized and
17 described under these new guidelines?
18 A. HCC relicensing costs are categorized and
19 described using a structured system of work orders and
20 budget IDs . Each work order corresponds to a specific type
21 of relicensing activity, and each is assigned a budget ID
22 that groups related work orders under broader relicensing
23 efforts . For example, a work order titled HCC Watershed
24 Enhancement Program Development is assigned a budget ID of
25 HCC Snake River Stewardship Program ("SRSP") Development,
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Idaho Power Company

1 allowing the Company to quickly identify all projects
2 associated with that particular program.
3 As part of the annual reporting process, the Company
4 compiles all work orders and budget IDs for HCC relicensing
5 expenditures incurred during the reporting period. The
6 reports also identify the relevant regulatory or procedural
7 process associated with each expenditure, such as Clean
8 Water Act Section 401 certification, consultation under the
9 Endangered Species Act ("ESA") , National Environmental
10 Policy Act ("NEPA") compliance, or other HCC relicensing
11 efforts . This approach ensures that expenditures are
12 clearly tied to specific activities and broader
13 programmatic efforts, improving transparency and
14 facilitating the review process for Commission Staff.
15 Q. How has the Company complied with the
16 requirement to modify HCC specific document retention
17 practices?
18 A. In the Settlement Stipulation, Idaho Power
19 agreed to maintain records that were in the Company' s
20 possession associated with HCC relicensing, in order to
21 evidence actual expenditures and HCC relicensing purpose .
22 The Company committed to maintaining evidence of future
23 such expenditures for the HCC relicensing project until the
24 expenditures are included in customer rates . The Company
25 has adhered to this requirement by maintaining all records
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Idaho Power Company

1 that were in its possession at the time the Settlement
2 Agreement was executed and has continued to retain all
3 other documentation since the prior prudence review.
4 Q. How did the Company comply with the
5 requirement to more broadly modify its document retention
6 policy?
7 A. In 2018, Idaho Power established an
8 enterprise-wide Record Retention Standard, which is
9 implemented under the Company' s Information Retention
10 Policy. This standard sets forth the requirements for the
11 retention, disposition, and protection of Company records .
12 The Record Retention Standard is reviewed on a monthly
13 basis by a multi-disciplinary team to ensure that its
14 provisions remain appropriate, effective, and aligned with
15 applicable requirements .
16 Q. Can you describe Idaho Power' s petition in
17 Case No . IPC-E-23-13?
18 A. Yes . In April 2023, Idaho Power petitioned the
19 Commission to modify the timing of the requirement approved
20 by Order No. 34031 that the Company file a request for a
21 prudence determination on HCC expenditures incurred after
22 December 31, 2015, through a time not to exceed five years
23 from the Commission' s approval of the Settlement
24 Stipulation. Instead, the Company sought to file a request
25 for prudence determination within 12 months of receiving
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Idaho Power Company

I the final license, or in the event a final license is not
2 received by year-end 2025, to file in early 2026 for
3 prudence of expenditures incurred through year-end 2025 .
4 Q. What was the outcome of that case?
5 A. The Commission granted the Company' s request
6 for a modification of the timeframe and directed the
7 Company to file a prudence determination of HCC
8 expenditures incurred after December 31, 2015, within 12
9 months of receiving the final FERC license, or in early
10 2026, if the final FERC license is not received by year-end
11 2025 .1
12 III . PRUDENCE REQUEST
13 Q. What amount of HCC relicensing costs is the
14 Company requesting the Commission find were prudently
15 incurred?
16 A. Idaho Power is requesting a prudence
17 determination of approximately $305 million of HCC
18 relicensing costs incurred from January 1, 2016, through Q3
19 2025 . As discussed previously, this number will be updated
20 to include costs through Q4 2025, when the Company submits
21 a supplemental application in early 2026 .
1 In the Matter of Idaho Power Company's Petition to Modify Order No. 34031's
Timeframe for a Prudence Determination of Hells Canyon Complex Expenditures,
Case No. IPC-E-23-13, Order No. 35816 (June 14, 2023) .
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Idaho Power Company

1 Q. How are these costs allocated between
2 Construction Work in Progress ("CWIP") and Allowance for
3 Funds Used During Construction ("AFUDC") ?
4 A. As reflected in Attachment No . 1 to the
5 Application, of the approximately $305 million incurred
6 from January 1, 2016, through the third quarter of 2025,
7 about $258 million is AFUDC.
8 Q. What portion of the $258 million in AFUDC is
9 associated with CWIP balances through December 2015 that
10 were deemed prudent in Order No. 34031?
11 A. Approximately $228 . 2 million, or 88 percent,
12 of the $258 million in AFUDC is associated with CWIP
13 balances deemed prudent in Order No. 34031 .
14 Q. Is Idaho Power asking for recovery of the HCC
15 relicensing costs incurred since December 31, 2015, as a
16 part of this request?
17 A. No. The Company is not requesting an
18 adjustment to customer rates at this time. However, Idaho
19 Power is requesting the Commission authorize the costs as
20 prudently incurred and eligible for inclusion in customer
21 rates at a later date.
22 Q. Are there HCC relicensing costs currently
23 included in customer rates, and if so, what Commission
24 decisions authorized their recovery?
25
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Idaho Power Company

1 A. Yes . Customer rates currently include a
2 portion of AFUDC associated with the HCC relicensing
3 effort . Idaho Power first requested recovery of these costs
4 in Case No. IPC-E-08-10 . In that case, the Commission
5 approved the Company' s request in Order Nos . 30722 and
6 32426, authorizing the annual collection of approximately
7 $8 . 8 million in HCC-related AFUDC. This amount was later
8 updated in 2023 to reflect the revised Idaho jurisdictional
9 allocation from the Company' s general rate case.
10 More recently, in Case No. IPC-E-25-13, Idaho Power
11 sought to increase the level of AFUDC recovery by
12 approximately $30 million to better align the amount
13 collected from customers with the ongoing financing costs
14 of the relicensing project. The Commission approved the
15 Company' s request in Order No. 36775 . Through those orders,
16 the Commission has authorized annual collection of $38 . 5
17 million in customer rates .
18 Q. What is the September 30, 2025, HCC
19 relicensing Construction Work In Progress ("'CWIP") balance
20 net of AFUDC amounts collected in customer rates?
21 A. As of September 30, 2025, Idaho Power has
22 collected approximately $269 million in AFUDC from
23 customers . After netting these amounts against total HCC
24 relicensing expenditures, the remaining HCC relicensing
25 CWIP balance is approximately $257 million on a system
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Idaho Power Company

1 basis . The Idaho-jurisdictional portion of this net CWIP
2 balance represents the level of project investment through
3 September 30, 2025, that the Company would seek to recover
4 from customers in a future rate proceeding.
5 IV. CONCLUSION
6 Q. Please summarize the Company' s request in this
7 case .
8 A. In compliance with Order Nos . 34031 and 35816,
9 Idaho Power is requesting a prudence determination for HCC
10 relicensing costs incurred from January 1, 2016, through
11 December 31, 2025 . The Company' s filing currently includes
12 approximately $305 million of HCC relicensing costs
13 recorded through Q3 2025 and will be supplemented with
14 final expenditures through Q4 2025 in early 2026 . While
15 Idaho Power is not seeking recovery of these costs in
16 customer rates at this time, the Company is requesting that
17 the Commission find these expenditures prudently incurred
18 and eligible for future inclusion in rates .
19
20
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Idaho Power Company

1 DECLARATION OF JESSICA G. BRADY
2 I, Jessica G. Brady, declare under penalty of
3 perjury under the laws of the state of Idaho:
4 1 . My name is Jessica G. Brady. I am employed
5 by Idaho Power Company as Regulatory Consultant in the
6 Regulatory Affairs Department.
7 2 . On behalf of Idaho Power, I present this
8 pre-filed direct testimony in this matter.
9 3 . To the best of my knowledge, my pre-filed
10 direct testimony are true and accurate.
11 I hereby declare that the above statement is true to
12 the best of my knowledge and belief, and that I understand
13 it is made for use as evidence before the Idaho Public
14 Utilities Commission and is subject to penalty for perjury.
15 SIGNED this 24th day of December 2025, at Boise,
16 Idaho .
17
18 Signed. �V wwr
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Idaho Power Company