20150415Noe Direct.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMTSSION
IN THE MATTER OE THE APPLICATTON
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POV{ER COST
ADJUSTMENT (..PCA") RATES EOR
ELECTRTC SERVICE FROM JUNE T,
2015, THROUGH MAY 31, 2076.
CASE NO.rPC-E-15-14
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
KELLEY K. NOE
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a. Please state your name and business address.
A.My name is Ke11ey K. Noe. My business address
is L227 West Idaho Street, Boise, Idaho 83702.
O. By whom are you employed and in what capacity?
A. I am employed by fdaho Power Company ("Idaho
Power" or "Company") as a Regulatory Analyst II in the
Regulatory Affairs Department.
O. Please descrlbe your educatj-onal- background.
A.In May of 2004, f rece j-ved a Bachelor of
Business Administration in Finance from Boise State
University. I have al-so attended el-ectric utility
ratemaking courses, including "The Basics: Practical
Regulatory Training for the Electric Industry, " a course
offered through New Mexico State University's Center for
Public Utilities as well as "Introduction to Rate Design
and Cost of Service Concepts and Techniques" presented by
Electric Utilities Consultants, Inc.
o.P1ease describe your work experience with
Idaho Power.
A. In September 2006, I accepted a position at
Idaho Power as a Einancial- Analyst in the Finance
Department. My responsibilities as a Financial Analyst
were two-fold. In the credit analysis portion of my
position I was responsible for gathering counterparty
credit and financial- j-nformation, preparing a risk
NOE, Dr 1
Idaho Power Company
1 analysis, and approving an appropriate credit limit
2 assignment. When necessary, f negotiated security or
3 col-Iatera1 documents in accordance with corporate credit
4 standards. The other responsibilities in my position
5 included providing the financial- support for the Grid
5 Operations, Planning, and Operations Analysis and
7 Development groups. This included preparing studies,
8 reports, analyses, and recommendations j-n areas such as
9 budgets, forecasts, capital expenditure proposals,
10 financial plans, and regulatory requirements.
1t-In October 20L0, T accepted a Regulatory Analyst II
t2 position within the Regulatory Affairs Department of the
13 Company. My duties as a Regulatory Analyst II include
74 gathering, analyzing, and coordinating data from various
15 departments throughout the Company required for development
L6 of jurisdictional separation studies. In addition, I
t7 provide analyst support for the Company's regulatory j-ssues
1-8 related to its pension plan, emission control upgrades at
79 the Jim Bridger power plant, the exchange of certain
20 transmission assets wlth PacifiCorp, and the Environmental-
2l Protection Agency's proposed rul-e to regulate carbon
22 emissions from existing power plants under Cl-ean Air Act
23 Section 111 (d) .
24 O. What is the purpose of your testimony in this
NOE, Dr 2
Idaho Power Company
25 proceeding?
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A My testimony describes the Company's proposed
implementatj-on of the revenue sharing mechanism establ-ished
by the Idaho Public Utilities Commission ("Commission") in
Order No. 32424 in Case No. IPC-E-11-22. My testimony
begi-ns with a brief background of the mechanism as it
applies to the 2074 financial results. Eurther, my
testimony details the determj-nation of the 20L4 revenue
sharing benefits and the allocation of benefits to
individual customer classes. My testimony concludes with
the proposed class-allocated benefj-ts to be included in the
2075-2016 PCA.
I. BACKGROT'IID
o.Please describe the mechanism as it was
approved in Order No. 32424 in Case No. IPC-E-11-22.
A.Per the terms approved in the settlement
stipulation, if the Company's actual Idaho jurisdictional
year-end return on equity ("ROE") falIs below 9.5 percent
in any fiscal year from 2012 through 2014, the Company is
authorized to accelerate the amortization of accumul-ated
deferred investment tax credits (*ADITC"), up to a total of
$45 mi11ion. The revenue sharing portion of the mechanism
consists of two components. Eirst , for actual year-end
Idaho earnings greater than 10 percent ROE up to and
including 10.5 percent in the years 20L2 through 20L4, the
earni-ngs wil-l be shared equally between Idaho customers and
NOE, Dr 3
Idaho Power Company
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the Company. The customer share wil-l- be a reduction to
rates at the same time as the PCA becomes effective.
Second, Idaho earni-ngs above a 10. 5 percent ROE wil-I also
be shared, with customers receiving 75 percent of the
earnings applied as a reduction to the Company's pensj-on
balancing account.
o.Has the mechanism resulted in any action
fol-lowing the completion of the 2009-20L3 fiscal years?
A. Yes. The mechanism was originally established
in Case No. IPC-E-09-30 and approved in Order No. 30978,
effective for the years 2009-2071. The mechanism was
modified and extended in Case No. IPC-E-LL-22 and approved
in Order No. 32424, effective for the years 2012-20L4. The
ROE thresholds approved under each settl-ement stipulation
are displayed in the table below. Idaho Power's Idaho
jurisdictional earnings Ln 201,1, 20L2, and 2073 triggered
the earnings sharing provisions of the mechanism. As shown
in the table beIow, the Company has shared with customers a
total- of $93.3 million either as a direct rate offset in
the PCA or as an offset to amounts that would otherwise be
collected in rates. In 2009 and 2010, the Company's actual
Idaho jurisdictional year-end ROE was between 9.5 and 10.5
percent, resulting in no accelerated amortization of ADITC
or revenue sharing.
NOE, Dr 4
Idaho Power Company
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2409-2011,20L2-20L3
Availabl-e ADITC For Use
ROE Threshold
50-50 Sharing Threshold
15-25 Sharing Threshold
Customer Benefits ($Millions) :
Reduction to Rates
Offset to Pension Bal Acct
TotaI
$45 Million
9.5%
10.5U
N/A
$27.L
$20.3
$45 Million
9.5%
10%
10. 5%
$14.8
$31.1
s47 .4 $4s. e
O.The Commission extended the revenue sharing
mechanism with modj-fications through 2019 in Order No.
33149. Did approval of the mechanj-sm's extension in Case
No. IPC-E-LA-LA affect the 2014 revenue sharing
computation?
A. No. The changes made to the mechanism in Case
No. IPC-E-14-74 and approved in Order No. 33149 take effect
beglnning with fiscal year-end 2075 financial results.
II. QUATiETFTCATION AIID AT DIT OF yEAR-Er[p 2014 RE\ZENUE
STIARING CAICT'I.ATTONS
O. Pl-ease describe the methodology used to
determine the Idaho jurisdictional 2014 year-end ROE.
A. The methodology used to determine the
Company's Idaho jurisdictional- 2014 year-end ROE is
consistent with the methodology used for the year-end 2009
through 20L3 ROE determinations and approved by the
Commission in Order No. 32558. First, the Company prepared
a full jurisdictional separation study ("JSS") based on
third quarter financial information as of September 30,
2014, and jurisdictional al-location factors from the 20L3
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Idaho Power Company
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Federal Energy ReguJ-atory Commission Form 1 filj-ng. The
results of this study were used to develop allocation
factors for various components of operating income and rate
base. Followlng the completion of the 2074 fiscal year,
retail- revenues were directly assi-gned to each
jurisdiction, and the al-l-ocation factors from the third
quarter JSS were applied to al-l other year-end system
financj-al figures to determine year-end Idaho
jurisdictj-ona1 net rate base and operating income. Common
equity was then all-ocated according to each jurisdictj-on's
proportion of net rate base. Finally, the Idaho
jurisdictional year-end ROE was determined by dividing the
Idaho-allocated earnings on common stock by the ldaho-
allocated portion of common equity.
O. Do you have an exhibit demonstrating the
application of this methodology?
A. Yes. Exhibit No. 3 provides a step-by-step
calcul-ation of the Idaho jurisdictional ROE and subsequent
revenue sharing benefits based on year-end 201-4 financial
results utilizing the Commission-approved methodology
described above.
O. Has the Company quantified the Idaho
jurisdictional 201-4 ROE and any year-end earnings in excess
of 10 percent?
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Idaho Power Company
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A.
2074 Idaho
quantified
Company's
end ROE of
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approved in
$23 ,298 ,296
Yes. As seen on l-ine 46 of Exhibit No. 3, the
jurisdictional ROE was 11.19 percent. As
on line 73 of Exhibit No. 3, rn 20t4, the
earnings exceeded an Idaho jurisdictional year-
10 percent by $23,298,296.
Per the terms of the settlement stipulation
Order No. 32424, what portion of the
will be shared with customers?
A. In accordance with Order No. 32424, revenue
sharing based on year-end 201,4 financial results will be
provided to customers in two tiers. The first tier
refl-ects customers' 50 percent share of the Idaho
jurisdictj-onal 20L4 year-end earnings in excess of 10
percent ROE up to and including 10.5 percent. The first
tier, calculated at 50 percent of $9,143,1,13 (Line 63,
Exhibit No. 3), results in a customer benefit prior to tax
gross-up of $4,877,586. After tax gross-up, customers
receive a total rate reduction of $1,999,745. These
amounts are displayed in Exhibit No. 3 on line 69.
The second tier refl-ects customers' 15 percent share
of the Idaho jurisdictional 2074 year-end earnj-ngs in
excess of 10.5 percent ROE. The second tier, calculated at
15 percent of $13,555,1,23 (Line 66, Exhibit No. 3), results
in a customer benefit prior to tax gross-up of $10r166,343.
After tax gross-up, customers receive a total- benefit of
NOE, Dr 7
Idaho Power Company
1 $76,693,L34 in the form of a reduction to the Company's
2 pension balancing account. These amounts are displayed in
3 Exhibit No. 3 on line 71. An accounting entry was made to
4 reduce the pension deferral balancing account by
5 $76,693,\34 wj-th an effective date of December 31, 20L4, to
6 reflect this benefit.
0. What is the total- benefit customers will
8 receive as a resul-t of revenue sharing based on the
9 Company's actual year-end 201-4 financial results?
10 A. After tax gross-up, the combination of the
11 $1,999,745 reduction to rates and the $15,693,L34 reduction
L2 to the pension balancing account results in an overall
13 customer benefit of $24,692,219.
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III . CI,ASS AI,LOCATION
O. How does the Company propose to allocate the
16 $7,999,1,45 revenue sharlng to customer cl-asses?
t7 A. The Company proposes to allocate the
18 $'7 ,999,1,45 revenue sharing as a rate reduction to customer
79 cl-asses based on each class's proportional share of
20 forecasted base revenues for the June L, 20L5, through May
21 31, 2076, sharing period.
22 O. What is the impact of al-Iocating the proposed
23 rate reduction to customer classes proporti-onalIy to base
24 revenues?
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Idaho Power Company
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A.Exhibit No. 4 details the aflocation of the
$'7,999,1-45 revenue sharing benefit to customer cl-asses
proportionally to forecasted base revenues for the June 7,
2075, through May 31, 2015, sharing period. As displayed
i-n co1umn G of Exhibit No. 4, each customer class receives
a decrease of approximately 0.78 percent relative to
current base revenues.
IV. RATE DESTGN
o.How does the Company propose to include the
class-allocated revenue sharing benefits in rates?
A.With the exception of the special contracts
for Micron Technology, Inc., the U.S. Department of Energy,
and the J. R. Simplot Company - Pocate1lo, Idaho Power
proposes to include the class-allocated revenue sharing
benefits in the 2015 PCA rates effective June 1, 20L5,
through May 31, 20L6, dS detail-ed in this case by Mr. Scott
Wright. Col-umn F of Exhibit No. 4 details the proposed
class-specific revenue sharing rates I have provided to Mr.
Wright to be included in the 201,5-201,6 PCA rates.
o.What is the Company's proposal for providing
revenue sharj-ng benefits to its special contract customers?
A.Consistent with the methodology used to share
20LL, 2012, and 2013 revenues, the Company proposes to
provide the special contract customers a flat dollar-per-
month credit in twelve equal portions to serve as a
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Idaho Power Company
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reduction to monthly lnvoices billed for June 201,5 through
May 2015. The total revenue sharlng benefit allocated to
each special contract j"s displayed in column E of Exhibit
No. 4.
0. Is the Company's rate design proposal for the
20!4 revenue sharing benefits the same as what has been
proposed and approved in prior years?
A.Yes, the Company is proposing to provide the
2074 revenue sharing benefits as a cents-per-kilowatt-hour
credit to aIl- rate classes, excluding the special
contracts, and a fl-at dolIar-per-month credit to the
special contract customers.
0.
A.
Does this conclude your testimony?
Yes, it does.
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Idaho Power Company
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ATTESTATION OF TESTIMONY
STATE OF
County of
T,
IDAHO
Ada
SS.
truthfully,
following:
Kelley K. Noe, having been duly sworn to testify
and based upon my personal knowledge, state the
I am employed by Idaho Power Company as a Regulatory
Analyst in the Regulatory Affairs Department and am
competent to be a witness in this proceeding.
I declare under penalty of perjury of the laws of
L2 the state of Idaho that the foregoing pre-fil-ed testimony
13 and exhibits are true and correct to the best of my
!4 inf ormation and bel-ief .
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DATED this 15th day of April 2015.
Kel
SUBSCRIBED AND SWORN
. Noe
before me this 15th day of
20 April 2075.
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My commission expires z I 7.;>O -;)oJto
NOE, Dr 1_1
Idaho Power Company
Noztary Puffic f pr I{ahq
ResidingtrOT4.?l
.Da-
Puautc
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-15-14
IDAHO POWER GOMPANY
/
NOE, DI
TESTIMONY
EXHIBIT NO.3
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DA}IO POTVER COTPAI{Y
ADDITIONAL INVESTMENT TAX CREDIT ANALYSIS
Fslhr Twrlv. Ionth. EnrLd D.cmb63l, mla
ffi
..,sunlRYoFnEsulnt...
TOTALgIIEf patp tD&ler
2,955,893,456 2.829,257,997 55.7%
DEVELOPMENT OF NET INCOME
OPEMTING REVENUES
RETALSAI-ESREVENUES(lnd,l,l0.1 R.v) t79,717,133 &10,056,t57 DinciArrign
OTHER OPERATING REVENUES 11,1,097,4!3 '100,ts4,663 95.,4%
TOTAL OPERATING REVENUES 903.t1,4,i166 9.4t.7t1.5.(}
rOTALtME[ EHC pABolt
Saptant r A@.tionr/Raliq
ffi
1,079,,112,163 OincrA.dga'1,46,194,130 95.,1%
't.227.606.302
OPERATING EXPENSES
OPERATONAilANTENANCEEXPENSES 63,I,97,646
DEPRECIATION EXPENSE gi},647,321
AMORTIZATION OF LIMITED TERM PLANT 5,230,127
TAXES OTHER THAN INCOME 2,1,6Et,065
REGULATORY OEBITS,/CREDITS 55,236
PROVISION FOR DEFERRED INCOME TAXE .It,76O,E2O
INVESTiTENT TAX CREDIT ADJUSTUENT (21,1,533)
FEDERAL INCOilE TAXES 16,291,0,a7
STATE lNCOrrE rAXES /i,E36,75E
TOTAL OPERATING EXPENSES 794,5i10,1E0
199,271,271
4,706,167
203,961,'til4
79:t,771,663
120,297,175
8,686,8't2
2t,596,E71
0
26,73:t,175
30.76t
(t,220,511\
6,6E7,5E1
976,59,t,137
251,012,'165
6,779,917
25?,792,OA2
17,162,704
(2,505,723)
2?2,145,67
76,1?'t,263
196,277,EO4
196,277,804
1,753,771, t34
11.19%
05.4%
95.7%
e5.7%
93.2%
0.0%
x.2%
05.7%
97-1%
96.E%
e5.6%
95.0%
95.7% (L 10)
95.9% {L 3(r)
05.?% (L 10)
95.7% (Llo)
501,92 t,319
t0,7t1,808
5,007,465
23,012,060
0
1t,05,t,144
(20s,37E)
15,E,J7,237
,1,6E2,03,4
75t,123,52t
191,66E,012
4,,t99,1 79
I 96,157.101
95.,t%
95.7%
95.7%
93.2%
0.0%
96.2%
95.7%
97.1%
96.E%
95.8%
1,1 30,280,1 25
1 55,359,997
1.2A5,610,122
E32,1E1,422
125,740,568
6,S86,000
31,748 230
7s,651
27 ,779.567
41,511
(7,,t1 3,733)
6 908,583
1,024,045,E2E
261,594,294
7,O92,887
268,687,1E1
17,930 898
(2,61 1,623)
28.t,006,,{57
79 580,631
2U,125,825
2U,125,425
1.832,268,616
fl.16%
1 7,1,065,519
183,226.E62
192,388.205
OPERATING INCOME
AOO; IERCO OPERATING INCOME
OPERATING INCOME BEFORE OTHER INCOME AN
AOD: AFUDC EOUITY
ADD: OTHER INCOilE ANO DEDUCTIONS
INCOUE BEFORE INTEREST CHARGES
LESS: INTEREST CHARGES
NET INCOME
ACTUAL YEAR.END RESULTS. BEFORE ITC AOJUSTMENT
EARNINGS ON COMITION STOCK
COMMON EOUITY AT YEAR END
RETURN ON YEAR.END COMUON EqUTY
EARNINGS ON COMMON STOCK @ 0.50 ROE
EARNINGS ON COUMON STOCK @ 10 ROE
EARNTNGS ON COMMON STOCK @ 10.50 ROE
ACTUAL YEAR.END RESULTS - AFTER ITC ADJUSTMENTI
INVESTiIENT TAX CRED]T ADJUSTMENT
ADJUSTED EARNINGS ON COMMON STOCK
ADJUSTED COMMON EOU]TY AT YEAR.ENO
ADJUSTED RETURN ON YEAR.END COMiION EOUtrY
16C,501,256 (14.t'9.5%)
175,377,113 (Lrl4' r0%)
lEil,l/6,969 (1.14' 10.5%)
(32,784,030) (L4l-Lil3) / (1-9.5%)
163,493,775
1,720.987,104
9.50%
lDAtlO RETtlRl{ Oil COIXOil EQUTY (Um aal <t5*
AODITIONAL ITC AOJUSTMENT (Annurliz,It L 5,1 L nre.tivr. lh.n 0; il po3iliv!, ihln rmLr of 154 or 325,000.000
lDAl{O RETT RN ON COXION EQUTY (Lln. aa} >lot[
IDAHO EARNINGS GREATER THAN 'IO% ROE BUT LESS THAN 'I0.5%
lDAl€ RETtnil ON COITON EqUTY (Um,L) >10.t*
INCREUENTAL IOAHO EARNINGS GREATER THAN IO.5O% ROE
Ord.r *tAA;
ROE b.ts.n '10%-,l0.5% -CUSTOUER SHARE - 509( (R.duction to 6trr)
ROE b.tEcn '10%-10.5% -COMPANY SHARE - 50%
ROE groltlrthfi 10.5% (ln@mnttl) - CUSTOMER SHARE - 75% (Otlllt io P.ntion b.hn6)
ROE gc.tlr th.n i0.5% (ln@mntll) -COI{PANY SHARE - 25%
0
9,743,173 (LsGL19y(!-10%)
1 s,55s,'t 23 (1,(!150)/(1-10.5%)
4,E7't,5E6
it,87'1,5t6
10,166,3,13
_9r3!9J!l_
23,298,296
Exhibit No. 3
Case No. !PC-E-15-14
K. Noe, IPC
Page 1 of 1
PEp.Gd by: K.hy Nor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-15-14
IDAHO POWER COMPANY
NOE, DI
TESTIMONY
EXHIBIT NO.4
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Exhibit No. 4
Case No. IPC-E-15-14
K. Noe, IPC
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