Loading...
HomeMy WebLinkAbout20031021Obenchain Direct.pdfBEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC SERVICE TO ELECTRIC CUSTOMERS IN THE STATE ) OF IDAHO ) ��������������) CASE NO. IPC-E-03-13 IDAHO POWER COMPANY DIRECT TESTIMONY OF PHIL A. OBENCHAIN 1 2 Q. A. Please state your name and business address. My name is Phil A. Obenchain, and my 3 business address is 1221 West Idaho Street, Boise, Idaho. 4 Q. By whom are you employed and in what 5 capacity? 6 A. I am employed by Idaho Power Company as a 7 Senior Pricing Analyst in the Pricing and Regulatory 8 Services Department. 9 Q. Please describe your educational background 10 and professional experience. 11 A. In May of 1979, I received a Bachelor of 12 Arts Degree in Economics from Boise State University in 13 Boise, Idaho. 14 In August of 1979, I was employed as an 15 Economic Research Assistant with Idaho First National Bank 16 (presently U. S. Bank) . 17 In August of 1981, I left Idaho First to 18 attend the University of Idaho in Moscow, Idaho to pursue a 19 Masters of Science Degree in Economics, with emphasis in 20 Regulatory Economics. I completed the necessary course 21 work in the spring of 1982. 22 In January of 1983, I accepted the position OBENCHAIN, Di Idaho Power Company 1 1 of Pricing Analyst with Idaho Power Company. My duties as 2 Pricing Analyst include the preparation of cost-of-service 3 information for use in the development of jurisdictional 4 separation studies and class cost-of-service studies. More 5 specifically, I am responsible for gathering and analyzing 6 data from various sources to carry out cost-of-service 7 related analyses as required by the three jurisdictions 8 regulating Idaho Power Company. 9 I was the Company's revenue requirement 10 witness before this Commission in Case No. IPC-E-94-5 and 11 testified on the earnings test results as part of Case No. 12 IPC-E-97-12. In addition, I have sponsored testimony 13 before the Oregon Public Utility Commission in Case UE 92 14 on the Oregon jurisdictional revenue requirement. 15 Q. What is the scope of your testimony in this 16 proceeding? 17 A. I am sponsoring testimony in this proceeding 18 on the Idaho jurisdictional revenue requirement resulting 19 from the Jurisdictional Separation Study (JSS). 20 My testimony is outlined as follows: 21 First, I am offering testimony summarizing 22 the adjustments to total system test year data used by the OBENCHAIN, Di Idaho Power Company 2 1 Company for purposes of restating the Company's rate base, 2 revenues, and expenses for the 12 months ending December 3 31, 2003. 4 Second, I am offering testimony relative to 5 the preparation of a jurisdictional separation study 6 prepared using the adjusted total system data for the 12 7 months ending December 31, 2003 for the purpose of 8 determining the Idaho jurisdictional revenue deficiency. 9 Q. Have you prepared or supervised the 10 preparation of various exhibits for this proceeding? 11 A. Yes. I have prepared or supervised the 12 preparation of the following exhibits: 13 14 15 16 17 18 19 20 21 22 EXHIBIT Exhibit No. 21 Exhibit No. 22 Exhibit No. 23 Exhibit No. 24 TITLE Summary of Total Rate Base and Net Income Adjustments Summary of Adjustments - Electric Plant In Service Summary of Adjustments - Accumulated Provision for Depreciation and Amortization Summary of Adjustments - Additions and Deductions to Rate Base OBENCHAIN, Di Idaho Power Company 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Exhibit No. 25 Exhibit No. 26 Exhibit No. 27 Exhibit No. 28 Exhibit No. 29 Exhibit No. 30 Exhibit No. 31 Q. A. Summary of Adjustments - Operating Revenues Summary of Adjustments - Operation and Maintenance Expenses Summary of Adjustments - Depreciation and Amortization Expense Summary of Adjustments - Taxes Other Than Income Taxes Summary of Adjustments - Income Taxes Jurisdictional Separation Study - Idaho Revenue Requirement Development of Jurisdictional Allocation Factors Please describe Exhibit No. 21. Exhibit No. 21 consists of two pages and 16 identifies the development of the adjusted total electric 17 system rate base and the development of net income for the 18 12 months ending December 31, 2003. The 2003 test year 19 values contained in column 1 of Exhibit No. 21 are the 20 unadjusted test year amounts. The adjustments proposed by 21 the Company for purposes of developing the 2003 adjusted 22 total electric system combined rate base and net income for OBENCHAIN, Di Idaho Power Company 4 1 this proceeding are shown in columns 2 through 5 of Exhibit 2 No. 21. The unadjusted test year information and 3 adjustments, except as otherwise noted, were provided to me 4 by Ms. Smith. The total system adjusted test year rate 5 base, expenses and revenues are summarized in column 6 of 6 Exhibit No. 21. 7 Page 1 of Exhibit No. 21 summarizes the 8 development of rate base components for the 12 months 9 ending December 31, 2003. The total combined rate base 10 prior to adjustments is $1,752,511,220 as seen on line 24 11 in column 1 on page 1 of Exhibit No. 21. The total 12 combined rate base is reduced to $1,673,283,777, after all 13 test year adjustments have been included, and can be seen 14 on line 24 in column 6 on page 1 of Exhibit No. 21. 15 Page 2 of Exhibit No. 21 presents the 16 development of the total system net income for the 12 17 months ending December 31, 2003. Operating revenues are 18 summarized on line 31 in columns 1 through 6. Total 19 operating expenses are summarized on line 42 in columns 1 20 through 6. The resulting net income is summarized on line 21 46 in columns 1 through 6. Net income increases from the 22 test year level of $65,895,300 to $81,433,150 after all OBENCHAIN, Di Idaho Power Company 5 1 ratemaking adjustments have been included. 2 Q. Please describe the total test year 2003 3 rate base, expenses and revenues found in column 1 of 4 Exhibit No. 21. 5 A. Total test year amounts, before adjustment, 6 are presented in column 1 of Exhibit No. 21. With the 7 exception of test year firm operating revenues and test 8 year power supply expenses, the amounts in column 1 were 9 provided to me by Ms. Smith. Firm operating revenues, line 10 29, are calculated utilizing (1) 2003 normalized test year 11 sales provided by the Company's Power Supply Planning 12 department, and (2) the current base rates. The test year 13 values for the Company's power supply accounts (Surplus 14 Sales Revenues - Account 447, Fuel - Accounts 501 and 547, 15 Market Purchases - Account 555.1 and Purchases from 16 Qualifying Facilities - Account 555.2) are the account 17 balances from the most recent PCA filing provided to me by 18 Mr. Said. A summary of these accounts is presented by FERC 19 Account on lines 48 through 55 on page 2, of Exhibit No. 20 21. 21 Q. Why have the 2003 test period rate base, 22 revenues, and expenses of the Company been adjusted? OBENCHAIN, Di Idaho Power Company 6 1 A. Test year information is adjusted to reflect 2 known changes to the test year data for determining the 3 Company's rates. In this way, rates will reflect the most 4 current cost information available at the time those rates 5 become effective. 6 Q. Please explain what types of ratemaking 7 adjustments are made for the development of the Idaho 8 jurisdictional revenue requirement? 9 10 A. three types. Ratemaking adjustments are generally one of First, normalizing adjustments are made to 11 those items that are influenced by weather. Mr. Said 12 discusses the normalization of the Company's Net Power 13 Supply Expenses in his testimony in this proceeding. 14 Normalizing adjustments are shown in column 2 of Exhibit 15 No. 21. 16 Second, annualizing adjustments are made to 17 reflect changes that occur within the test year, but need 18 to be incorporated for the full year on an ongoing basis. 19 Annualizing adjustments are shown in column 3 of Exhibit 20 No. 21. 21 Third, known and measurable adjustments 22 proposed in this filing reflect changes that will occur OBENCHAIN, Di Idaho Power Company 7 1 after December 31, 2003, but prior to or coincident with 2 the effective date of the new rates. Known and measurable 3 adjustments are shown in column 4, Exhibit No. 21. 4 Q. Please discuss the annualizing adjustments 5 to the rate base components summarized in column 3 of page 6 1 of Exhibit No. 21. 7 A. The first annualizing adjustment in column 3 8 on page 1 of Exhibit No. 21 is an increase of $6,621,907 to 9 production plant in service investment, line 9, for the 10 rewind of Bridger Unit No. 3. The second is an increase of 11 $13,157,482 to transmission plant in service, line 10, for 12 the Brownlee-Oxbow transmission line. The last is an 13 increase of $1,709,301 to Accumulated Provision for 14 Depreciation to capture plant at the end of 2003. The 15 above adjustments were provided to me by Ms. Smith. 16 Q. Please discuss the known and measurable 17 adjustments to rate base presented in column 4 on page 1 of 18 Exhibit No. 21? 19 A. The first is an increase of $18,388,690, 20 line 10, to transmission plant in service investment for 21 upgrades to the Brownlee-Oxbow transmission line and the 22 Star, Vallivue, Midrose and Goshen (345 capacitor bank) OBENCHAIN, Di Idaho Power Company 8 1 transmission stations. The investment amounts were 2 provided to me by Ms. Smith. The second is an increase of 3 $3,211,822 to the accumulated provision for depreciation 4 reserve associated with one-half of the annualized 5 depreciation expense adjustment that was also provided to 6 me by Ms. Smith. The last known and measurable adjustment 7 is a reduction of $2,076,923 to IERCO subsidiary rate base 8 associated with the revaluation of prior year contingent 9 tax reserves and a true-up of deferred tax related to prior 10 years. This adjustment was provided to me by the Company's 11 Tax Department. 12 Q. Have you included any other adjustments to 13 rate base other than the annualizing and known and 14 measurable adjustments? 15 A. Yes, other adjustments to rate base are 16 presented in column 5 on page 1 of Exhibit No. 21. 17 Q. Please describe the other adjustments shown 18 in column 5 on page 1 of Exhibit No. 21. 19 A. The three adjustments shown in column 5 on 20 page 1 of Exhibit No. 21 are: 21 22 1 . A reduction to production plant of $1,577,314 to reverse the amount booked in OBENCHAIN, Di Idaho Power Company 9 1 2 3 4 5 6 7 8 9 10 11 12 13 2 . 3 . 2003 for Asset Retirement Obligation (ARO) provided to me by Ms. Smith. An increase of $106,204,452 to Accumulated Deferred Depreciation to reverse amounts booked in 2003 associated with ARO, as provided by Ms. Smith. A reduction of $2,615,452 to Fuel Inventory to reflect current operating criteria that result in the required coal inventory of 140,000, 90,000 and 30,000 tons at Bridger, Valmy and Boardman, respectively. The fuel inventory adjustment was provided by Mr. Said. 14 Q. Please recap the net effect of the 15 annualizing, known and measurable, and other adjustments to 16 rate base. 17 A. After the annualizing, known and measurable, 18 and other adjustments are included, the adjusted total 19 electric system combined rate base for the 12 months ending 20 December 31, 2003, as shown on line 24 in column 7 of page 21 1 of Exhibit No. 21, is $1,673,283,777. This amount is 22 $79,227,443 less than the unadjusted number in column 1. OBENCHAIN, Di 10 Idaho Power Company 1 2 Q. A. Please describe page 2 of Exhibit No. 21. Page 2 of Exhibit No. 21 shows the 3 development of the adjusted total electric system net 4 income for the 12 months ending December 31, 2003. 5 Q. Please describe the Company's normalizing 6 adjustments to the net income components shown in column 2 7 on page 2 of Exhibit No. 21. 8 A. The normalizing adjustments in column 2 on 9 page 2 of Exhibit No. 21 consist of the following two 10 adjustments: 11 12 13 14 15 16 17 18 19 20 21 22 1. 2 . An increase to Operating Revenues in the amount of $14,562,765 reflects the increased level of opportunity sales associated with multiple historical water conditions provided and discussed by Mr. Said in his testimony in this proceeding. A reduction to Operation and Maintenance Expense in the amount of $42,122,055 reflects the decreased fuel and purchase power expenses associated with multiple historical water conditions as quantified and discussed by Mr. Said in his testimony OBENCHAIN, Di 11 Idaho Power Company 1 2 Q. in this proceeding. Please explain the Company's annualizing 3 adjustments to the statement of income in column 3 on page 4 2 of Exhibit No. 21. 5 A. The annualizing adjustments to the income 6 component shown in column 3 on page 2 of Exhibit No. 21 are 7 made to reflect changes to expenses and revenues, occurring 8 within the test year that should be included for a full 9 year. 10 Q. Were there any annualizing adjustments to 11 the operating revenues of the Company? 12 A. Yes. A reduction of $72,871 was made to 13 other operating revenues to reflect changes to facility 14 charge revenue as provided and discussed by Ms. Brilz in 15 her testimony in this proceeding. 16 Q. Please describe the annualizing adjustments 17 made to the operating expenses of the Company. 18 A. The annualizing adjustments to the Company's 19 operating expenses were provided to me by Ms. Smith and 20 consist of the following three adjustments presented in 21 column 3 on page 2 of Exhibit No. 21: 22 1. An increase of $3,256,361 to Operation and OBENCHAIN, Di 12 Idaho Power Company 1 2 3 4 5 6 7 8 Maintenance Expenses (O&M), which consists of: ( 1) an increase to specific O&M expense accounts to reflect an annualized Payroll adjustment of $2, 913, 244; (2) an increase to Property and Liability Insurance of $389,417; and (3) a reduction to Account 908, Customer Assistance, of $46,300 related to the expiration of DSM amortization in 9 Oregon. This last adjustment has no impact 10 11 12 13 14 15 16 17 18 2 . 3 . Q. on the Idaho jurisdictional revenue requirement. An increase to Depreciation Expense, Account 403, of $3,418,600, which reflects the 2003 annualized depreciation. An increase of $120,655 to Taxes Other Than Income Taxes to reflect the property tax impact of the annualized plant additions. Please explain the known and measurable 19 adjustments to the statement of income presented in column 20 4 on page 2 of Exhibit No. 21. 21 A. The known and measurable adjustments to the 22 statement of income components reflect the following: OBENCHAIN, Di 13 Idaho Power Company 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 1. 2 . 3 . 4 . An increase of $8,930,300 to Firm Sales Revenues resulting from an increase to the level of Opportunity Sales - Account 447 provided by Mr. Said. An increase of $346,171 to Other Operating Revenues resulting from a change to Pole Attachment Revenues - Account 456 reflecting 2004 Cableone contract revenues provided to me by Ms. Smith. An increase in Operation and Maintenance Expenses of $18,185,548 that is composed of two primary adjustments: the first, an increase of $8,269,427 in accounts 501, 547 and 555, which reflect the increased levels provided by Mr. Said, and the second, an increase to Operation and Maintenance Expenses other than power supply expenses of $9,916,121 provided to me by Ms. Smith. An increase to Depreciation Expense of $6,423,645 to reflect the additional depreciation expense associated with the known and measurable adjustments to electric OBENCHAIN, Di 14 Idaho Power Company 1 2 3 4 5 6 7 8 9 10 11 5 . 6 . Q. plant in service provided to me by Ms. Smith. An increase to Taxes Other Than Income Taxes of $112,171 for Property Taxes associated with the known and measurable adjustment to Electric Plant In Service provided to me by Ms. Smith. A reduction to IERCO operating income of $5,291,270 provided to me by the Company's Tax Department Please explain the other adjustments 12 presented in column 5 on page 2 of Exhibit No. 21. 13 A. Other system adjustments proposed by the 14 Company consist of the following: 15 16 1. An increase to retail sales revenues of $665,816, which can be found on line 29 in 17 column 5. In addition, there were two 18 19 20 21 22 adjustments to other operating revenues: (1) a reduction of $665,816 in Account 454 Facilities Charge Revenues to reflect the change in treatment of facilities charge revenues paid by MICRON under its special OBENCHAIN, Di 15 Idaho Power Company 1 2 3 4 5 6 7 8 9 10 11 2 . contract retail rate as provided to me by Ms. Brilz, and (2) an increase to Miscellaneous Service Revenue of $907,290 to reflect the Company's revised Service Establishment, Reconnection and Field Collection fees provided to me by Ms. Drake. These two adjustments net to the $241,474 found on line 30 in column 5 on page 2 of Exhibit No. 21. A reduction to Operation and Maintenance Expenses of $475,556 reflecting the sum of 12 three separate components. The first 13 14 15 16 17 18 19 20 21 22 component is an increase to Idaho Rate Case Expense of $4,953. The second component is a decrease of $452,125 to reflect the removal of General Advertising Expense. The final component is a $28,384 reduction to Memberships and Contributions. Advertising Expense and Memberships and Contributions have been disallowed in past orders of this Commission and thus have been removed from the 2003 test year operating expenses. Ms. OBENCHAIN, Di 16 Idaho Power Company 1 2 Q. Smith provided these adjustments. Are there any additional adjustments to the 3 test year actual data that should be mentioned? 4 A. Yes. The impacts to Federal and State 5 income taxes paid resulting from the ratemaking adjustments 6 discussed above were provided to me by the Company's Tax 7 Department and are shown on lines 40 and 41 on page 2 of 8 Exhibit No. 21. 9 10 Q. A. Please describe Exhibit No. 22. Exhibit No. 22 consists of 2 pages and 11 provides greater detail of the adjustments to the Company's 12 Electric Plant In Service, by FERC account, used in this 13 proceeding. 14 15 Q. A. Please describe Exhibit No. 23. Exhibit No. 23 consists of 2 pages and 16 provides greater detail of the Accumulated Provision for 17 Depreciation and Amortization Reserve. 18 19 Q. A. Please describe Exhibit No. 24. Exhibit No. 24 is a two-page exhibit, which 20 provides greater detail of other additions to or deductions 21 from the Company's total combined rate base. 22 Q. Please describe Exhibit No. 25. OBENCHAIN, Di 17 Idaho Power Company 1 A. Exhibit No. 25 is a one-page exhibit, which 2 summarizes by FERC Account the Company's operating revenues 3 for the test period used in this proceeding. 4 5 Q. A. Please describe Exhibit No. 26. Exhibit No. 26 is a six-page exhibit, which 6 provides greater detail of test year and adjusted test year 7 operation and maintenance expenses for the 12-month period 8 ending December 31, 2003. 9 10 Q. A. Please describe Exhibit No. 27. Exhibit No. 27 is a two-page exhibit, which 11 provides greater detailed information by FERC account of 12 Depreciation and Amortization Expenses used in this 13 proceeding. 14 15 Q. A. Please describe Exhibit No. 28. Exhibit No. 28 is a one-page exhibit, which 16 provides detailed information regarding taxes other than 17 income taxes used in this proceeding. 18 19 Q. A. Please describe Exhibit No. 29. Exhibit No. 29 is a one-page exhibit, which 20 provides a detailed summary of the income tax related 21 adjustments that result in the adjusted tax expenses on 22 lines 40 and 41 of page 2 of Exhibit No. 21. These OBENCHAIN, Di 18 Idaho Power Company 1 adjustments were provided to me by the Company's Tax 2 Department. 3 Q. Have you prepared an exhibit that sets forth 4 the Idaho jurisdictional revenue deficiency? 5 A. Yes. I have prepared Exhibit No. 30 titled 6 "Jurisdictional Separation Study - Idaho Revenue 7 Requirement" consisting of 35 pages. 8 Q. Please discuss the methodology used to 9 jurisdictionally separate costs in the preparation of this 10 study. 11 A. The cost of providing electric service is 12 measured through the use of test year data as adjusted for 13 the 12-month period ending December 31, 2003. 14 In order to establish a methodology for 15 separating costs among jurisdictions, a three-step process 16 is generally used. The steps are referred to as 17 classification, functionalization, and allocation of costs. 18 In all three steps, recognition is given to the way in 19 which costs are incurred by relating these costs to the way 20 in which a utility is operated to provide electrical 21 service. The methodology used to separate costs by 22 jurisdiction and calculate the Idaho jurisdictional revenue OBENCHAIN, Di 19 Idaho Power Company 1 requirement in the present case is the same methodology 2 utilized by the Company and accepted by the Commission in 3 previous rate cases. 4 Q. Would you please briefly explain the meaning 5 of classification, functionalization, and allocation? 6 A. Classification refers to the identification 7 of costs as being related to one of three components; 8 demand-related, energy-related or customer-related. In 9 addition to classification, costs are functionalized; that 10 is, identified with utility operating functions such as 11 generation, transmission and distribution. Individual 12 plant items are examined and, where possible, the 13 associated investment costs are assigned to one or more 14 operating functions. Once the Company's total system costs 15 are classified and assigned to the appropriate function 16 they may be allocated among jurisdictions. 17 The process of allocation is merely one of 18 apportioning the total system cost among jurisdictions by 19 introducing allocation factors into the process. An 20 allocation factor is nothing more than an array of numbers, 21 which specifies the jurisdictional value or share of the 22 total system quantity. For example, in the case of OBENCHAIN, Di 20 Idaho Power Company 1 energy-related costs, the allocation factor is annual 2 jurisdictional energy use, adjusted for losses. 3 Once individual accounts have been allocated 4 to the various jurisdictions, it is possible to summarize 5 these into total utility rate base and net income by 6 jurisdiction. The results are stated in a summary form to 7 measure adequacy of revenues for the jurisdiction under 8 consideration. The measure of adequacy is typically the 9 rate of return earned on rate base, which is compared to 10 the requested rate of return. 11 Q. How have the various functional plant and 12 cost items been allocated? 13 A. After classification and functionalization, 14 allocation factors based on demand and energy use were 15 determined. In order to allocate demand-related costs, the 16 average of the 12 monthly coincident peak demands was used. 17 The Company has used this allocation method for 18 jurisdictional separation purposes in all of its retail and 19 wholesale rate applications prepared during the past 25 20 years. This allocation method has been adopted by this 21 Commission and accepted by the Oregon Public Utility 22 Commission, and the Federal Energy Regulatory Commission. OBENCHAIN, Di 21 Idaho Power Company 1 The demand-related allocation factors used in the study are 2 designated as DlO, Dll, D60. The respective values used in 3 these demand allocation factors are shown at line numbers 4 967 through 969 on page 29 of Exhibit No. 30. 5 Q. What method was used to allocate general 6 plant and certain labor-related administrative and general 7 expenses? 8 A. In accordance with FERC procedures, general 9 plant and administrative and general expenses have been 10 allocated in accordance with functionalized wages and 11 salaries. These labor-related allocation factors are shown 12 on Table 12 of Exhibit No. 30, pages 23 through 28. 13 Q. How were the energy-related expenses 14 allocated among jurisdictions? 15 A. Energy-related expenses were allocated on 16 the basis of normalized jurisdictional kilowatt-hour sales, 17 adjusted for losses so as to establish energy requirements 18 at the generation level. The energy-related allocation 19 factors used in the study are designated as ElO and ElOO. 20 The respective values used in these energy allocation 21 factors are shown on Table 13 of Exhibit No. 30, page 29 22 lines 972 & 973, respectively. OBENCHAIN, Di 22 Idaho Power Company 1 Q. What was the method by which you allocated 2 customer-related costs? 3 A. The principal customer-related expenses, 4 which require allocation, are Account 902, Meter Reading 5 Expenses and Account 903, Customer Accounting and Billing. 6 These accounts were allocated based upon a review of actual 7 Company practices in reading meters and preparing monthly 8 bills or statements. 9 Q. Please describe the derivation of the 2003 10 total system allocation factors used in this case. 11 A. The 2003 Jurisdictional Separation Study 12 utilizes 2002 data for most of the Allocation Factors with 13 some exceptions: 14 15 16 17 18 19 20 21 22 1. 2 . Capacity or demand-related allocation factors (DlO, Dll, and D60) utilized 2002 Coincident Peak information that was adjusted to reflect known changes for 2003, for example the expiration of the DAMPS and Washington City Sales for Resale contracts. Energy-related allocation factors (ElO and ElOO) are the 2003 normalized test year sales at generation level. OBENCHAIN, Di 23 Idaho Power Company 1 2 3 4 5 6 3 . 4 . Q. The directly assigned revenue accounts were updated to reflect 2003 test year revenues. Finally, the direct assignment of plant accounts 360, 361 and 362 received specific new treatment. Would you please explain how the direct 7 assignment of accounts 360, 361 and 362 differs in the 2003 8 Jurisdictional Separation Study from prior studies? 9 A. Yes. Historically Contributions In Aid of 10 Construction (CIAC) have been treated as a reduction to the 11 total investment in accounts 360, 361 and 362 prior to any 12 allocation of plant and related operation and maintenance 13 expense. Consequently, all customers (jurisdictions) have 14 shared in the benefits of contributions paid by a few. 15 In order to pass the benefit of the CIAC to 16 the customers (jurisdictions) that made the contribution, 17 accounts 360, 361 and 362 were identified by the net 18 investment and by the net plus CIAC investment. The net 19 plus CIAC amount was then directly assigned to customers 20 (jurisdictions) prior to any reduction for CIAC. In this 21 way the customers (jurisdictions) that make the 22 contribution receive the full credit. OBENCHAIN, Di 24 Idaho Power Company 1 In addition, operation and maintenance 2 expenses resulting from investment in accounts 360, 361 and 3 362 are related to the total investment and thus allocated 4 by the net plus CIAC investment. 5 In this way the Idaho jurisdictional costs 6 that are passed to Ms. Brilz for input into the class cost- 7 of-service model will give the proper recognition to the 8 customers who made the contribution. 9 10 30. 11 Q. A. Please describe the content of Exhibit No. Exhibit No. 30 is the complete 12 Jurisdictional Separation Study detailing allocation of 13 each component of rate base, operating revenues and 14 expenses by FERC account resulting in the Idaho 15 jurisdictional revenue deficiency. The JSS is organized as 16 follows: 17 Summary of Results 18 Table 1 - Electric Plant in Service 19 Table 2 - Accumulated Provision for 20 Depreciation and Amortization 21 Table 3 - Additions and Deductions to Rate 22 Base OBENCHAIN, Di 25 Idaho Power Company 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Q. Table 4 - Operating Revenues Table 5 - Operation and Maintenance Expenses Table 6 - Depreciation and Amortization Expense Table 7 - Taxes Other Than Income Taxes Table 8 - Deferred Income Taxes and ITC Table 9 - Federal Income Tax Table 10 - State Income Tax -- Oregon Table 11 - State Income Tax - Idaho and Other Table 12 - Development of Labor Allocator Table 13 - Summary of Allocation Factors Table 14 - Summary of Distribution/CIAC Allocation Factors Table 15 - Summary of Allocation Factors- Ratios Briefly describe the manner in which you 18 allocated Electric Plant In Service as shown in Table 1 of 19 Exhibit No. 30. 20 A. Production plant has been allocated to all 21 jurisdictions on the basis of the average of the 12 monthly 22 coincident peaks. The allocation of transmission and OBENCHAIN, Di 26 Idaho Power Company 1 distribution plant has been based on the same methodology. 2 Q. Would you describe the functional categories 3 used for allocation of transmission plant and distribution 4 substations? 5 A. A description of the functional categories 6 used for allocation of transmission and distribution 7 substations is as follows: 8 9 10 11 12 13 14 15 16 17 18 19 20 21 1. 2 . 3 . Q. Transmission facilities are the facilities that form the bulk power transmission system together with transmission, step-up substation facilities required to introduce the Company's generation into the power supply system, which include facilities rated at 500kv through 46kv. Distribution facilities refer to lower voltage lines and substation facilities that provide localized service. Direct assignments refer to facilities that are identified as serving and paid by a specific customer. How have you allocated the Accumulated 22 Provision for Depreciation and Amortization of Other OBENCHAIN, Di 27 Idaho Power Company 1 Utility Plant shown on Table 2 of Exhibit No. 30? 2 A. Accumulated Provision for Depreciation has 3 been allocated among jurisdictions as shown on Table 2 of 4 Exhibit No. 30. The accumulated totals for each type of 5 production plant and for each primary plant account in 6 other functional groups are allocated on the basis of the 7 related plant account as allocated in Table 1. Amortization 8 of Other Utility Plant has been functionalized and then 9 allocated on the basis of the related plant items as 10 allocated in Table 1. 11 12 Q. A. Please describe Table 3 of Exhibit No. 30. Table 3 details the allocation of all other 13 additions to or deductions from rate base. Deductions from 14 rate base include Customer Advances for Construction which 15 have been directly assigned to the customers 16 (jurisdictions) and Accumulated Deferred Income Taxes which 17 are allocated by plant. Additions consist of Materials and 18 Supplies which have been functionalized and allocated by 19 the respective plant allocators; Fuel Inventory which has 20 been allocated on the basis of energy; components of IERCO, 21 the Company's fuel subsidiary which are allocated on the 22 basis of energy; and the Investment in Conservation are all OBENCHAIN, Di 28 Idaho Power Company 1 Idaho programs and directly assigned to the Idaho 2 jurisdiction. 3 Working Cash Allowance has been excluded 4 from rate base in accordance with the Commission's previous 5 orders. 6 All rate base items, with the exception of 7 Accumulated Deferred Income Taxes and the Investment in 8 Conservation Programs, reflect the average of 13 monthly 9 balances. 10 11 Q. A. Please describe Table 4 of Exhibit No. 30. Table 4 indicates adjusted Firm Operating 12 Revenues for each jurisdiction for the 12 months ending 13 December 31, 2003. Opportunity Sales represent non-firm 14 energy sales to other utilities, the revenues from which 15 are credited to each jurisdiction in proportion to its 16 generation-level energy usage. 17 Other Operating Revenues are either 18 allocated among jurisdictions in a manner which offsets 19 related allocations of rate base, or, where a particular 20 revenue item may be identified with a specific 21 jurisdiction, it is directly assigned to the appropriate 22 jurisdiction. OBENCHAIN, Di 29 Idaho Power Company 1 Q. Briefly describe the methods by which O&M 2 expenses were allocated. 3 A. The allocation of each O&M expense is 4 detailed on Table 5 of Exhibit No. 30. In general, the 5 basis for each allocation may be readily interpreted from 6 the exhibit, due to the fact that in most cases either 7 demands, those identified by a source code beginning with a 8 "D" prefix; energy use, those identified by a source code 9 beginning with an "E" prefix; or related plant, those 10 identified by a line number source code; serve as a basis 11 for the allocation. Customer-weighted allocation factors, 12 "CW", which recognize differences in customer requirements, 13 have been used in the allocation of certain expense 14 accounts. 15 Q. In what manner are supervision and 16 engineering expenses treated throughout the allocation of 17 O&M expenses? 18 A. For the applicable expense account in each 19 functional group, the labor component is separately 20 allocated in accordance with the detail provided on pages 21 25 through 28 of Table 12 of Exhibit No. 30. The total of 22 allocated labor in each functional group becomes the basis OBENCHAIN, Di 30 Idaho Power Company 1 for the allocation of Supervision and Engineering Expense. 2 Total allocated labor expense serves the additional purpose 3 of allocating employee pensions and other labor-related 4 taxes and expenses. Table 12 of Exhibit No. 30 details the 5 development of all the labor-related allocation factors 6 used in this study. 7 8 Q. A. Please describe Table 6 of Exhibit No. 30. The allocation of Depreciation Expense and 9 Amortization of Limited Term Plant is set forth on Table 6. 10 These expenses have been identified by type of production 11 plant or by primary plant account for other functional 12 plant groups. Allocation is then accomplished on the basis 13 of the related plant account as previously allocated. 14 Q. Please describe Table 7 of Exhibit No. 30, 15 and the allocation of Taxes Other Than Income Taxes. 16 A. Taxes Other Than Income Taxes are treated 17 individually and are allocated in a manner consistent with 18 the bases by which the respective taxes are assessed. 19 20 Q. A. Please describe Table 8 of Exhibit No. 30. The expenses shown on Table 8 consist of 21 Deferred Income Taxes and the Investment Tax Credit 22 Adjustment. Both have been functionalized and allocated on OBENCHAIN, Di 31 Idaho Power Company 1 the basis of total allocated plant. Also summarized on 2 Table 8 are State and Federal Income Tax liabilities. The 3 income taxes shown on Table 8 as well as Tables 9, 10 and 4 11 were obtained from the Company's Tax Department. 5 Q. Please describe how you allocated Federal 6 and State Income Taxes shown on Tables 8, 9, 10 and 11 of 7 Exhibit No. 30. 8 A. Total income taxes have not been allocated, 9 per se. Instead, the respective tax bases have been 10 developed and taxes have been calculated directly for each 11 jurisdiction. Operating income before taxes represents 12 adjusted operating revenues less all adjusted operating 13 expenses treated heretofore with the exception of deferred 14 income taxes and investment tax credits. Adjusted 15 long-term and other interest expenses are allocated on 16 total plant in order to develop net operating income before 17 taxes. From that point forward, additions to or deductions 18 from the respective tax bases are allocated to each 19 jurisdiction by net income before taxes. In this manner, 20 taxable income for each jurisdiction is developed, and the 21 appropriate tax rate is applied. Final tax amounts result 22 after the allocation of adjustments and tax credits. All OBENCHAIN, Di 32 Idaho Power Company 1 details relating to the calculation of Federal, Oregon, 2 Idaho and Other state income taxes are found on Tables 9, 3 10 and 11. 4 Q. Please describe Tables 12, 13, 14 and 15 of 5 Exhibit No. 30. 6 A. Tables 12, 13, 14 and 15 of Exhibit No. 30 7 contain a list of the allocation factors used in the 8 Jurisdictional Separation Study. Tables 12, 13, 14 and 15 9 of Exhibit No. 30 contain the principal allocation factors 10 used in the study and the respective jurisdictional values 11 for each allocation factor. Table 14 of Exhibit No. 30 12 presents the ratios of the principal allocation factors 13 included in Table 13. 14 Q. Please describe the development of the Idaho 15 Jurisdictional revenue deficiency. 16 A. The summary of results is presented on pages 17 1 and 2 of Exhibit No. 30. The development of the Idaho 18 jurisdictional revenue deficiency is presented in the 19 column entitled "Idaho IPUC" on page 1 of Exhibit No. 30. 20 As can be seen from this exhibit the Idaho net income of 21 $76,855,594 on line 24 results in a return on rate base of 22 4.967 percent on line 25. Under the rate of return of OBENCHAIN, Di 33 Idaho Power Company 1 8.334 percent provided to me by Mr. Gribble, the Company's 2 Idaho jurisdictional net income should be $128,963,944 on 3 line 30. This results in an earnings deficiency of 4 $52,108,350 on line 31. 5 Q. What net-to-gross or incremental income tax 6 factor did you use in developing the Idaho jurisdictional 7 revenue deficiency? 8 A. As indicated on line 33 on page 1 of Exhibit 9 No. 30, I used a composite incremental tax multiplier of 10 1.642 provided to me by the tax department, which 11 represents the use of the Federal effective tax rate of 12 32.795 percent, an Idaho effective tax rate of 5.9 percent, 13 an Oregon effective tax rate of 0.4 percent and an Other 14 state effective tax rate of 0.1 percent for purposes of 15 determining the Company's Idaho jurisdictional revenue. 16 Q. What is the resulting Idaho jurisdictional 17 revenue deficiency? 18 A. The results of the Jurisdictional 19 Separation Study as shown on line 34 on page 1 of Exhibit 20 No. 30, indicate a total revenue deficiency of $85,561,910 21 for the Idaho Retail Jurisdiction. This represents a 22 required 17.68 percent increase in normalized Idaho OBENCHAIN, Di 34 Idaho Power Company 1 jurisdictional revenues. 2 3 Q. A. Please describe Exhibit No. 31. Exhibit No. 31 is a six-page exhibit, which 4 provides a summary of allocation factors used in this 5 proceeding. 6 7 Q. A. Does this conclude your testimony? Yes, it does. OBENCHAIN, Di 35 Idaho Power Company