20071210Lobb direct.pdf

BEFORE THE
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ZOOl DEC 10 Prl 3: 37
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-07-8
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC SERVICE )
IN THE STATE OF IDAHO. )
)
)
)
)
DIRECT TESTIMONY CF RANDY LOBB
IDAHO PUBLIC UTILITIES COMMISSION
DECEMBER 10, 2007
1 Q.Please state your name and business address for
2 the record.
3 A.My name is Randy Lobb and my business address is
4 472 West Washington Street, Boise, Idaho.
5 Q.By whom are you employed?
6 A.I am employed by the Idaho Public Utilities
7 Commission as Utilities Division Administrator.
8 Q.What is your educational and professional
9 background?
10 A.I received a Bachelor of Science Degree in
11 Agricultural Engineering from the University of Idaho in
12 1980 and worked for the Idaho Department of Water Resources
13 from June of 1980 to November of 1987. I received my Idaho
14 license as a registered professional Civil Engineer in 1985
15 and began work at the Idaho Public Utilities Commission in
16 December of 1987. My duties at the Commission currently
17 include case management and oversight of all technical
18 Staff assigned to Commission filings. I have conducted
19 analysis of utility rate applications, rate design, tariff
20 analysis and customer petitions. I have testified in
21 numerous proceedings before the Commission including cases
22 dealing with rate structure, cost of service, power supply,
23 line extensions, regulatory policy and facility
24 acquisi tions.
25 Q.What is the purpose of your testimony in this
CASE NO. IPC-E-07-812/10/07
LOBB, R. (Di)
STAFF
1
1 case?
2 A.The purpose of my testimony is to introduce Staff
3 witnesses, identify issues addressed by each and discuss
4 the various policy issues associated with this case.
5 Q.Could you please describe Staff's filing in this
6 case?
7 A.Yes. Senior Staff Auditor Donn English presents
8 the Staff test year of July 1, 2006 through June 30, 2007
9 based on Staff's audit of 12 historical months of actual
10 cost data. He then adjusts the historic test year data for
11 known and measurable changes and develops the Staff revenue
12 requirement based on his proposed expense adj ustments, rate
13 base recommendations of Staff witness Stockton,
14 miscellaneous expense adjustments of Staff witness Vaughn,
15 and power supply expense adjustments of Staff witness
16 Sterling. The cost of capital recommendations are
17 discussed by Staff witnesses Carlock and English. Mr.
18 English recommends a revenue requirement increase of $17.45
19 million or an overall increase of 2.82%. Mr. English
20 specifically addresses proforma adjustments to actual test
21 year O&M expenses, payroll annualization, capitalized
22 pension expenses and legal fees.
23 Senior Staff Auditor Kathy Stockton addresses the
24 development of rate base proposed by Staff in this case.
25 Ms. Stockton uses an average of 13 monthly average rate
CASE NO. IPC-E-07-812/10/07 LOBB, R. (Di)
STAFF
2
1 base totals for the Staff proposed test year of July 1,
2 2006 through June 30, 2007 to develop a total rate base of
3 approximately $1.954 billion.
4 Ms. Stockton proposes reductions in rate base of
5 approximately $15 million. She then utilizes Staff
6 proposed plant investment criteria to increase test year
7 net rate base by $55 million to reflect annualized major
S plant additions within the test year and annualized and
9 proformed maj or plant additions beyond the test year.
10 Staff Auditor Cecily Vaughn addresses several
11 revenue and expense issues including park rents,
12 annualization of insurance to reflect known and measurable
13 changes and amortization adj ustments to more appropriately
14 recover intervenor funding and remaining Prairie Power
15 acquisition costs. Ms. Vaughn also addresses the Company's
16 use of P-cards for the purchase of miscellaneous items and
17 recommends an associated expense adjustment. The net
1S effect of Ms. Vaughn's proposed test year adjustments is an
19 increase in Staff's proposed revenue of $16,729 and an
20 increase in base expenses of approximately $2 million.
21 Senior Staff Engineer Rick Sterling is
22 responsible for review of the Company's Aurora power supply
23 model used to calculate annual net power supply costs. Mr.
24 Sterling proposes an adjustment in the natural gas price
25 forecast used by the Company in its modeling. The results
CASE NO. IPC-E-07-S12/10/07 LOBB, R. (Di)
STAFF
3
1 of the forecast modification are a decrease in fuel
2 expenses, system opportunity sales and purchase power costs
3 for an overall decrease in annual net power supply expenses
4 of $6 million.
5 Senior Staff Engineer Keith Hessing addresses
6 jurisdictional cost allocation, class cost of service
7 (COS), rate design and the PCA load growth adjustment.
S Mr. Hessing accepts the Company's jurisdictional allocation
9 methodology as reasonable but recommends use of the Base
10 Case cost of service study rather than the 3cp/12cp
11 methodology proposed by the Company. Mr. Hessing has
12 modified the jurisdictional allocation study to reflect
13 adjustments proposed by Staff. He then recommends a rate
14 spread based upon the cost of service study results.
15 Mr. Hessing proposes class revenue requirement changes
16 ranging from no change for some classes where COS suggests
17 declines are warranted to a 10% cap on the increase for the
1S irrigation class. Other classes are moved to 75% of the
19 increase suggested by the COS. Mr. Hessing recommends an
20 increase of 1.37% for the residential class to generate the
21 overall revenue requirement increase of 2.82% percent.
22 Mr. Hessing proposes to increase the energy
23 component in each class to generate the additional revenue
24 except for the Irrigation class, which would receive a
25 uniform increase in all rate components.
CASE NO. IPC-E-07-S12/10/07
LOBB, R. (Di) 4
STAFF
1 Finally, Mr. Hessing addresses the issue of the
2 Expense Adjustment Rate for Growth (EARG) also known as the
3 load growth adjustment within the Power Cost Adjustment
4 mechanism (PCA). Mr. Hessing concludes that the
5 methodology described in testimony by Company witness Said
6 does not comply with Commission Order No. 30215. Rather
7 than a $29. 16/Mwh variable power supply cost adjustment for
8 customer growth as proposed by Mr. Said, the load growth
9 adjustment shòuld be $62. 79/MWh to reflect the entire
10 marginal cost of growth as described in the Commission
11 Order.
12 As previously mentioned, the cost of capital and
13 return on equity is discussed by Staff witness Terri
14 Carlock. Ms. Carlock recommends a return on equity in the
15 range of 9.25% to 10.75%. Staff's recommended capital
16 structure consists of approximately 51% debt and 49% equity
17 with a recommended return on equity point of 10.25% and an
18 overall recommended rate of return of 7.864%.
19 Finally, Staff witness Chris Hecht, a Utility
20 Compliance Investigator, will address consumer issues
21 including customer complaints received by the Commission,
22 Company response to customer service requests, and Company
23 compliance with rate case notification rules. Mr. Hecht
24 concludes that customer complaints for the Company are on
25 the decline and the Company does a good job of processing
CASE NO. IPC-E-07-812/10/07 LOBa, R. (Di)
STAFF
5
1 customer service inquiries.
2 Q.What has been your role in this case?
3 A.My role as Staff Administrator has been to
4 oversee the preparation of the Staff case with respect to
5 identification of issues, coordination of positions on
6 those issues and development of Staff policy.
7 Q.What are the important policy issues in this
S case?
9 A.In my opinion, the most important policy issues
10 include establishing the rate case test year, identifying
11 revenue requirement adjustments, assigning cost of service
12 responsibili ty and applying appropriate rate design.
13 Q.How does the rate case test year filed in this
14 case differ from test years filed in prior cases?
15 A.In the past two general rate cases, Idaho Power
16 Company provided 6 months of actual booked data and 6
17 months of forecasted data for use as its test year. The 6
lS months of forecast/budgeted data was then trued up to
19 actual booked data before the end of the case. For
20 example, the Company filed its case in October of 2003 with
21 actual data through June 2003 and forecasted data through
22 December 2003. By the time rates were put in place on
23 June 1, 2004, and in fact before Staff filed testimony in
24 March 2004, the Company had provided and Staff had audited
25 actual booked data for the remaining 6 months of the test
CASE NO. IPC-E-07-S12/10/07
LOBB, R. (Di)
STAFF
6
1 year that had been forecasted. Rates were fully based on
2 actual expenditures.
3 In this case, the Company has provided 12 months
4 of forecasted data based on budgets for use as its rate
5 case test year. Its filing was made on June S, 2007 with
6 forecasted monthly expenses and investments for a 2007 test
7 year. While 6 to S months of actual 2007 data may be
S available for review, neither Staff nor the Commission will
9 have actual information for the entire test year before new
10 rates are scheduled to become effective in 200S.
11 Q.Has the Company always filed a test year with 6
12 months actual costs and 6 months forecasted costs?
13 A.No. Past rate case filings have been based on 12
14 historical months of actual costs. Idaho Power's test year
15 filings in general rate cases have transitioned from a
16 fully historical 12 months of actual costs to 6 months of
17 actual and 6 months of forecasted costs. The Company
lS proposes in this case to use 12 months of fully forecasted
19 costs.
20 Q.What is the Commission's approach to ratemaking?
21 A.wi th few exceptions, the Commission has only
22 approved recovery through rates of costs that have actually
23 been incurred or are known and measurable. The Commission
24 has routinely utilized the principles of "used and useful" ,
25 "known and measurable" and "expense reducing or revenue
CASE NO. IPC-E-07-S
12/1Q/07
LOBB, R. (Di)
STAFF
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1 producing" in approving an historic 13 -month average rate
2 base that includes annualized and proformed adjustments for
3 specific large plant investments. In Order No. 29838, Case
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No. UWI-W-04-4, the Commission stated,
To make clear the Commission's preference for
future cases, we direct United Water to file
future rate cases utilizing a 13 -month average
rate base methodology. To facilitate an adequate
review, Company data should be provided in time
to incorporate the information in the prefiled
testimony of Staff and other parties.
The Commission went on to say,
Using recent, actual data for the hearing will
reduce if not eliminate the need to argue over
forecasts. To this end, the Commission suggest
rate cases be filed with no more than six months
of forecast data. Not only will data be known
and measurable by the time other parties prefile
testimony and for the hearing, it will be more
convenient and administratively easier for allparties.
In Order No. 29505 in Case No IPC-E-03-13 the Commission
said,
Generally speaking, the Commission expects all
utilities to attempt to identify expense savings
and revenue producing effects when proposing rate
base adjustments for maj or plant additions. It is
unfair to ratepayers to assume that the investment
in these plants will not increase Company revenues
or decrease Company expenses in the future.
Finally in Order No. 30342, Case No. SWS-W-06-1, the
Commission said,
The Commission has consistently determined that
the annual revenue requirement and rates should
be the basis of an historic test year.
CASE NO. IPC-E-07-8
12/10/07
LOBB, R. (Di)
STAFF
8
1 Q.Why has the Company moved from a fully historical
2 test year to a fully forecasted test year?
3 A.According to Company witness Gale, the use of an
4 historic test year in combination with increasing marginal
5 costs and a growing customer base causes "regulatory lag".
6 Q.What is "regulatory lag"?
7 A.Mr. Gale does not specifically define the term.
S However, my understanding of "regulatory lag" based on Mr.
9 Gale's testimony is the delay between when the Company
10 actually incurs costs and when the Commission approves
11 rates to recover those costs.
12 Q.Has anything been done to minimize this delay or
13 its effect?
14 A.Yes. The Commission allows the actual test year
15 cost information to be adjusted to reflect known and
16 measurable changes in costs that will occur in the future
17 and also allows annualization of known and measurable cost
1S increases to reflect the higher costs for the entire year.
19 In addition, the Commission has allowed the Company to late
20 file actual cost data within the processing of a rate case
21 to further reduce the delay between when costs are incurred
22 and when rates are put in place.
23 Moreover, the Commission has allowed proforma
24 test year adjustments to include costs associated with
25 significant plant additions that the Company expects to
CASE NO. IPC-E-07-S12/10/07 LOBB, R. (Di)
STAFF
9
1 incur beyond the test year. These post-test year additions
2 have been included in the test year as if they have been in
3 service for the entire period. Finally, the delay between
4 when costs are incurred and when rates are put in place to
5 recover those costs has always been a business risk of a
6 regulated utility. I believe that over time the Commission
7 has established returns on equity that reflects overall
S risk of the Company including that associated with
9 "regulatory lag".
10 Q.Why are rates normally based on costs that are
11 known and measurable?
12 A.Rates are based on known and measurable costs to
13 assure ratepayers that expenditures were actually made
14 prior to approving rates designed to recover them, that the
15 expenditures were properly incurred, and that expenditures
16 were properly booked in the appropriate accounts. Absent a
17 demonstration that costs are known and measurable, the
1S Commission is simply left to trust that the Company will
19 actually make expenditures in the amounts assumed, actual
20 expenditures will ultimately be reasonable for the projects
21 proposed and expenditures will be made in the time frames
22 anticipated. A fully forecasted test year based on
23 internally generated Company budgets as the Company has
24 proposed in this case cannot be audited or adjusted because
25
CASE NO. IPC-E-07-S12/10/07 LOBB, R. (Di) 10
STAFF
1 the costs are only anticipated and not yet actually
2 incurred.
3 Q.How does the Commission review the Company's
4 forecast to determine if it is appropriate?
5 A.It is very difficult if not impossible to
6 determine if the forecast is appropriate. Because the
7 Company did not provide actual expenditures on which to
8 base rates, comparisons must be made to other historical
9 information to evaluatè whether the forecasted expenses are
10 appropriate. A comparison of the forecast to historical
11 data is immediately frustrated because the forecast is
12 based on internal Company budgets that are allocated
13 uniformly to Federal Energy Regulatory Commission (FERC)
14 accounts.
15 For example, while 2006 FERC accounts show actual
16 expenditures, 2007 forecastedFERC accounts show what the
17 Company has allocated to those accounts based on a uniform
1S allocation methodology, not what would actually be booked
19 in 2007. The Commission will be unable to determine if
20 increases in these accounts from year to year are
21 reasonable because 2007 account totals will not reflect
22 actual expenditures.
23 A comparison of actual booked account totals for
24 the first half of 2007 is also frustrated because it too
25 compares actual account totals to allocated totals and only
CASE NO. IPC-E-07-S12/10/07 LOBB, R. (Di) 11
STAFF
1 reflects a portion of the Company forecasted test year.
2 The Company can easily justify any difference between
3 actual booked 2007 account totals and 2007 forecasted
4 totals in numerous ways such as change in
5 investment/ expense requirements or an expectation that
6 account differences will be eliminated by year end.
7 Q.Why is it important to audit actual Company
S expendi t ure s ?
9 A.The Commission has a responsibility and an
10 obligation to insure that costs included for recovery in
11 rates were actually incurred, were prudently incurred and
12 were incurred in a reasonable time frame. Only an audit of
13 actual expenditures can provide that assurance. Forecasts
14 based on internal Company budgets that simply allocate
15 costs uniformly among FERC accounts do not allow the
16 Commission to ever really determine whether costs are
17 appropriately incurred. Absent an audit of actual costs,
1S the Commission will be unable to apply the well-established
19 principles of "used and useful", "known and measurable" and
20 "expense reducing or revenue producing" to determine what
21 costs should reasonably be included for recovery through
22 rates. Budget estimates, proj ections and forecasts do not
23 easily lend themselves to evaluation based on these
24 principles.
25 Q.What are the reasons the Company asserts it
CASE NO. IPC-E-07-S12/10/07
LOBB, R. (Di) 12
STAFF
1 should be permitted to file a rate case with a forecasted
2 test year?
3 A.The Company maintains that it will not have a
4 reasonable opportunity to earn its authorized rate of
5 return, the investment community will loose confidence in
6 the Company's ability to make necessary investment and earn
7 a reasonable return and borrowing costs included in
S customer rates will increase.
9 Q.Do you agree?
10 A.I agree that reduced returns could increase
11 borrowing costs included in customer rates. However , given
12 that customer rates will increase more quickly with
13 forecasted costs and could also increase as the ability of
14 regulatory Staff to audit actual expenditures is reduced or
15 eliminated, Staff is concerned the unaudited test year
16 approach is likely to have a greater impact on customer
17 rates.
18 Q.What does Staff suggest?
19 A.At this time, Staff proposes to continue using
20 and expand on a test year methodology previously approved
21 by the Commission to address the Company's desire to
22 reduce "regulatory lag" by including in rates, major plant
23 investment on a more timely basis. We do this without
24 accepting proj ected increases in Company cost accounts
25 across the board based on internal Company budgets as
CASE NO. IPC-E-07-S
12/10/07
LOBB, R. (Di) 13
STAFF
1 proposed by the Company or eliminating the Staff's ability
2 to audit actual Company expenditures.
3 Q.Would you please explain the Staff's proposal?
4 A.Yes. Staff proposes to utilize the most recent
5 audited historic test year of July 1, 2006 through June 30,
6 2007 adjusted to: 1) annualize major plant additions within
7 the test year, that are classified as distribution,
S transmission or generation investment and exceed a
9 $2 million threshold, 2) annualize or proform for inclusion
10 in the test year plant additions that exceed $2 million
11 during the period July 1, 2007 through December 31, 2007.
12 This approach in this case increases plant in service by
13 approximately $60 million over what was allowed in prior
14 rate cases. Staff witnesses Stockton and Carlock provide
15 additional detail regarding specific rate base annualizing
16 and proforma adjustments.
17 Q.Do you believe Staff's approach is reasonable?
1S A.Yes, I believe it is a reasonable alternative to
19 a test year established using an unaudited budget based
20 cost forecast as proposed by the Company. The Staff
21 proposal allows the Commission to pursue its responsibility
22 and maintain its long-standing policy to audit and verify
23 actual known and measurable Company expenditures before
24 they are recovered in rates. At the same time we address
25 the Company's desire to incorporate more recent costs in
CASE NO. IPC-E-07-S12/10/07 LOBB, R. (Di) 14
STAFF
1 revenue requirement by focusing on improved cost recovery
2 associated with large plant investment and critical
3 infrastructure.
4 Q.What adjustments has Staff made to test year
5 results of operations?
6 A.As indicated previously, Staff has selected the
7 historic test year of July 1, 2006 through June 30, 2007.
S Besides the proforma and annualizing adjustments to
9 payroll, insurance and other expenses included in test year
10 revenue requirement, Staff has identified known and
11 measurable transmission distribution and generation
12 investment within the test year for special annualization
13 to include the plant in rate base as if it were in service
14 for an entire year.
15 Staff has also selected additional investment
16 during the last 6 months of 2007 for special annualization
17 or proforma treatment within the test year. Staff believes
1S that special treatment of these plant additions recognizes
19 the significance of the individual investment in terms of
20 impact on Company earnings and the critical nature of the
21 investment to serve new and existing customers. Staff also
22 recognizes that a revenue producing effect of the
23 annualization has been included in the test year and the
24 special treatment of the investment is consistent with
25 plant used in the determination of annual power supply
CASE NO. IPC-E-07-S12/10/07 LOBB, R. (Di) 15
STAFF
1 costs.
2 Staff has also included in its test year
3 determination of annual revenue requirement the Company's
4 calculated power supply expense and revenues at forecasted
5 customer levels. Staff chose to use the Company number due
6 to the forecasted nature of the Company's filing and the
7 fact that customer numbers and associated power supply
S costs corresponding to Staff's historic test year were very
9 difficult if not impossible to independently develop.
10 Moreover, by utilizing the Company numbers, the Staff was
11 able to adj ust test year rate base for some investment made
12 beyond the historic test period. While Staff recognizes
13 that some customer growth is reflected at the end of
14 Staff's proposed histOLic test year, we also recognize that
15 including variable power supply costs in revenue
16 requirement more than offsets new customer revenue so the
17 net effect on annual revenue requirement is negligible.
1S Q.What other policy positions has the Staff taken
19 in this case?
20 A.The remaining policy positions deal primarily
21 with Staff positions regarding power supply modeling,
22 jurisdictional and class cost of service allocation
23 methodology and rate design. Staff positions on these
24 issues were developed in conjunction with the technical
25 Staff who address those issues in testimony filed in this,
CASE NO. IPC-E-07-S12/10/07
LOBB, R. (Di) 16
STAFF
1 case and are discussed by those witnesses. Generally, it
2 is the Staff's policy to maintain consistency between rate
3 cases with regard to power supply, jurisdictional
4 allocations and class cost of service methodologies. Staff
5 believes its methodologies in this case for these functions
6 adhere to that policy.
7 With respect to revenue spread it is Staff's
S policy to generally move classes closer to accepted cost of
9 service in generating the Staff recommended revenue
10 requirement. Given the limited overall revenue increase
11 proposed, Staff recommends a revenue spread that changes
12 class requirements within a relatively narrow range.
13 Likewise, Staff's recommendation to modify rate components
14 depends upon the magnitude of the revenue increase wi thin
15 the class. Staff generally recognizes the limited nature
16 of the overall increase by only increasing the energy rate
17 component for most customer classes.
lS Q.Are there other issues you wish to address?
19 A.Yes. Staff's adjustment to remove capitalized
20 pension expense and utilize the correct calculation of the
21 EARG, the load growth adjustment in the PCA, are justified
22 based on decisions made in prior Commission Orders. Staff
23 witnesses sponsoring those issues discuss the relevant
24 Commission Orders and present the rationale' for Staff's
25 position in testimony filed in this case. Generally, the
CASE NO. IPC-E-07-S12/10/07 LOBB, R. (Di) 17
STAFF
1 position taken by Staff in this case on these two issues
2 simply applies the principals and positions established by
3 the Commission in prior cases. With regard to the EARG,
4 Staff believes that the incremental approach proposed by
5 the Company fails to properly include the impact of load
6 growth on surplus sales volume and resulting affect on
7 power supply costs.
S Does this conclude your direct testimony in thisQ.
9 proceeding?
Yes, it does.10
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CASE NO. IPC-E-07-S12/10/07 LOBB, R. (Di) 1S
STAFF
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF DECEMBER 2007,
SERVED THE FOREGOING DIRECT TESTIMONY OF RANDY LODD, IN CASE
NO. IPC-E-07-8, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
EMAIL: bkline(fidahopower.com
Inordstrom(fidahopower .com
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
EMAIL: peter(frichardsonandolear.com
ERIC L OLSEN
RACINE OLSON NYE BUDGE & BAILEY
PO BOX 1391
POCATELLO ID 83204
EMAIL: elo(fracInelaw.net
MICHAEL L KURTZ ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E 7TH ST SUITE 1510
CINCINATI OH 45202
EMAIL: mkurtz(fBKLlawfirm.com
kboehm(fBKLlawfirm.com
DENNIS E PESEAU PH.D.
UTILITY RESOURCES INC
1500 LIBERTY ST SUITE 250
SALEM OR 97302
EMAIL: dpeseau(fexcite.com
JOHNRGALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
EMAIL: rgale(ßidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID83 703
EMAIL: dreading(fmindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
EMAIL: tony(fyankel.net
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
EMAIL: cew(ßgivenspursley.com
LOTH COOKE
UNITED STATES DEPARTMENT OF
ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
EMAIL: lot.cooke(fhq.doe.gov
CERTIFICATE OF SERVICE
DALE SWAN
EXETER ASSOCIATES INC
5565 STERRTT PL SUITE 310
COLUMBIA MD 21044
EMAIL: dswanßYexeterassociates.com
(ELECTRONIC COPIES ONLY)
Dennis Goins .
E-Mail: dgoinspmgßYcox.net
Arthur Perr Bruder
E-Mail: arhur.bruder(ihq.doe.gov
~~lrck
SECRETARY
CERTIFICATE OF SERVICE