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HomeMy WebLinkAbout20171114White Direct.pdfRECEIVED ?0l1HOY lh Plt h: 25 , r l,?i'li ttii'!l8t'o* BEFORE THE ]DAHO PUBLIC UTILITIES COMM]SSION IN THE MATTER OF IDAHO POWER COMPANY' S APPLICATION TO ESTABLISH A METHOD OF RECOVERY FOR COSTS ASSOC]ATED W]TH PARTICIPATION ]N THE WESTERN ENERGY IMBALANCE MARKET. IDAHO POWER COMPANY DIRECT TESTIMONY OF TAM] WHITE CASE NO. IPC-E-17_76 ) ) ) ) ) ) ) 1 2 3 4 5 6 1 9 0.Please state your name, busi-ness address, and present position with Idaho Power Company ("Idaho Power" or "Company"). A. My name is Tami White and my business address is 1,221, West Idaho Street, Boise, Idaho 83702. f am employed by Idaho Power as the Senior Manager of Revenue Requirement in the Regulatory Affairs Department. O. Please describe your educational background. A. I earned a Bachelor of Business Administration degree in Accounting from California State UnJ-versity, Stanislaus. I have attended various el-ectric utility courses, including "E1ectric Utility System Operationr " a course offered through Professional- Training Systems, Irrc., and "Overview of System Operations" presented by the Western Electricity Coordinating Council. In 201,4, I attended the Utility Executive Course at the University of Idaho. O. Pl-ease describe your work experience with Idaho Power. A. I began my employment with Idaho Power in 7999 as a Financial Analyst in the Company's Delivery Finance Support area where I provided accounting and financial support services to the Delivery Business Unit. In 2005, I was promoted to Finance Team Leader where I was responsible for leading a group of Einancial- WHITE, DI 1 ldaho Power Company 10 11 72 13 74 15 t6 L1 1B 79 20 27 22 23 24 25 1 Analysts, Accountants, and Accountj-ng Specialists in 2 providing accounting and fj-nancial support services to the 3 Operations Business Unit. I was responsible for all 4 aspects of the monthly accounting closing process for the 5 Operations Business Unit and for the monthly billing and 6 settlements processes for transmission sal-es and purchases, 7 whol-esafe energy transactions, Public Utility Regulatory B Policies Act of 7918 transactions, large special contracts, 9 and joint use transactions. 10 While working in Operations Finance Support, I was 11 involved in the development of the Company's Federal Energy L2 Regulatory Commission (*FERC") Open Access Transmission 13 Tariff ("OATT") formula rate for transmission services. 14 In October 2070, after 11 years in finance, I 15 accepted a position as Manager of FERC and Regional Affairs 76 in the Regulatory Affairs Department. In this position, f 77 was responsible for managing regulatory activities, such as 18 the preparation and filing of Idaho Power's OATT rates for L9 transmission service, supervising participation and 20 settlement negotiations of Bonneville Power Adminlstration 21, rate cases, and creating analyses that form the basis for 22 Idaho Power's FERC regulatory strategy. 23 In January 2072, I was promoted to Senior Manager of 24 Rate Design. As Senior Manager of Rate Design, I was 25 responsible for the Company's rate design activities, such WHITE, Df Idaho Power 2 Company 1 as regulatory ratemaking and compliance filings, tariff 2 administration, and the development of varj-ous pricing 3 strategies and policies. 4 Tn March 2011, I accepted a 12-month cross-trainJ-ng 5 assignment as Senior Manager of Revenue Requirement. As 6 Senior Manager of Revenue Requirement, I oversee the 7 Company's regulatory activities related to revenue 8 requirement, such as power supply expense modeling, 9 )urisdictional- separation studies, and Idaho Power's OATT 10 rate. 11 O. What is the Company requesting in this case? \2 A. Idaho Power expects to begin participating in 13 the western Energy Imbal-ance Market ("EIM") begj-nning in 1,4 April 2018, dt which time benefits from Idaho Power's 15 participation-in the form of reduced net power supply 1,6 expenses (*NPSE")-wiIl begin accruing on behalf of 71 customers. The Company is requesting that the Idaho Public 18 Utilities Commission ("Commission") authorize a proposed 19 interim method for recovering j-ncremental EIM-related costs 20 that are being incurred to achieve the EfM-related 27 benefits. 22 O. How is your testimony organized in this case? 23 A. My testimony in this case first reviews Idaho 24 Power's pJ-anned participation in the western EIM as 25 detailed in the Company's filing and addressed by the wHrTE, Df 3 Idaho Power Company 1 Commissi-on's Order No. 33706 in Case No. IPC-E-16-19. Next, I wil-I provide updated estimated costs associated with Idaho Power's participatlon in the western EIM. FinalJ-y, I will describe Idaho Power's proposed interim method for recovery of incremental- costs associated with participation in the western EIM and describe the estimated Idaho jurisdictional- revenue requirement impact. I. BACKGROT'IID 2 3 4 5 6 1 a 9 10 O -t1. What is an EIM? An EIM is a real--time market to dispatch WHITE, DI Idaho Power 11 economic blds vol-untarily offered by participating 72 resources to efficlently balance supply, transfers between 13 bal-ancing authority areas, and load. An EfM solves sub- 74 hourly imbalances through an automated five-minute energy 15 dispatch service across a broad footprint with more L6 deployable resources available, providing a more l7 economically efficient method for maintaining ba1ance. 18 In an EIM, afl bal-ancing authority areas begin the 19 hour with matched generation and forecasted load. As 20 imbalances occur within the hour, resources within the EIM 2I can voluntarily provide bids to dispatch their facil-ities 22 to manage these imbal-ances. The market operator of the EIM 23 uses advanced market systems to look across the expanded 24 EIM region to determine the l-east-cost order of generation 25 dispatch and issues an operating target for each 4 Company 1 participating resource, resulting in the most economj-cal 2 bids avail-able to meet these imbal-ances. The real--time 3 optimization process determj-nes the least-cost mj-x of 4 resources and dispatches them to resol-ve these j-mbalances 5 while also respecting llmits on the transmission system to 6 alleviate overl-oads or congestion. 1 Q. What is the western EIM? 8 A. The western EIM is a vol-untary EIM service 9 that was implemented by the California Independent System 10 Operator (*CAlSO") and PacifiCorp on November l, 2014. 11 Since then, NV Energy, fnc.; Puget Sound Energy; Arj-zona 72 Public Service Company; and Port.land General- Efectric 13 Company have entered the market. L4 O. How will participation in the western EIM 15 benefit Idaho Power's customers? 1,6 A. As reported by CAISO in its quarterly Western 77 EIM Benefits Reports, participation in the western EIM is 18 resulting in real,, sustainabl-e cost savings in the form of 19 reduced annual NPSE for participants. Moving from the 20 current hourly market structure to a sub-hourly, five- 2l minute imbalance market l-eads to increased surplus sales 22 opportunities as wel-l- as net cost savings from increased 23 access to others' lower-cost generation, translating into 24 reduced NPSE. 25 WHITE, DI 5 Idaho Power Company 1 Even without the requested ratemaking treatment in 2 this case, the benefits of reduced NPSE will- accrue 3 directly to Idaho Power customers through the true-up 4 component of the existing Power Cost Adjustment (*PCA") 5 mechanism, beginning in April 2078. Because the PCA tracks 6 differences in NPSE for recovery from or refund to 7 customers, the cost savings benefits of EIM participation B w1l-l automatically be provided to customers through the 9 PCA. 10 O. Please summarize the Company's request in Case 11 No. IPC-E-I6-79. 12 A. In Case No. IPC-E-16-I9, the Company requested 13 the Commission (1) acknowledge the potential for long-term 14 benefits related to Idaho Power's participation in the 15 western EIM, (2) authorize the establ-ishment of a 76 regulatory deferral account to track incremental costs tl associated with western EIM participation, and (3) 18 authorize the Company to recover, in a future rate 19 proceeding, the estimated incremental costs of joining the 20 western EIM. 2L At that time, the Company estimated that it woul-d 22 j-ncur $1.73 mil-lion of start-up costs, $9.36 million of 23 additional capital expenditures, and $4.68 mil-l-ion of 24 incremental- ongoing operations and maintenance ("O&M") 25 costs through 2020 to participate in the western EIM. The WHITE, DI 6 Idaho Power Company 1 Company's 10-year net present val-ue revenue requirement 2 analysis filed in that case showed that partj-cipation in 3 the western EIM wiII reduce its net revenue requirement and 4 thus provide a net benefit to customers. 5 The Company al-so noted that under currently approved 6 regulatory practices, most of the benefits of reduced NPSE 7 (gS percent of the Idaho jurisdictional- share) will 8 automatically flow directly to customers through the PCA 9 mechanism, while the addi-tional start-up, capital, and 10 ongoing O&M costs, without additional ratemaking treatment, 11 would be borne by shareowners. !2 O. Did the Company request recovery of any of the 13 additional- costs to participate in the western EIM as part 1,4 of Case No. IPC-E-16-79? 15 A. No. Idaho Power requested authority to defer 1,6 to a regulatory asset account the incrementaf costs 11 associated with participatj-on in the western EIM, and 18 requested assurance that Idaho Power's prudently incurred 19 expenses rel-ated to its participation in the western EIM 20 woul-d be recoverable in a future rate proceeding. The 21, Company did not request recovery of the incremental costs 22 of participation at that time, but indicated on pages L2-13 23 of Mr. Tatum's testimony in that case that it may be 24 necessary to implement an interim rate mechanism for cost 25 recovery to provide for proper matching of costs and 1 Company WH]TE, Idaho D] Power 1 benefi-ts in customer rates upon commencement of the the western EIM. outcome of Case No. IPC-E-L6-L9? 2 3 4 5 6 1 9 Company's O. A. participation in What was the Commission Order No. 33706 issued 1n Case No rPC-E-16-19: o Determined that the Company's joining the western EIM 1s reasonabl-e and in the public interest; o Required Idaho Power to provide evi-dence of any benefits it is receiving and how those benefits are being passed on to customers once participation in the western EIM begins; o Determined that a deferra] account is the 13 appropriate mechanism to capture the 10 11 l2 74 15 76 t1 1B 79 20 27 22 23 24 initial- start-up costs time as benefitsof joining the western EIM until begin to flow to customers, and reasonable to all-ow the Company expenses associated with joining def erral account,' o Determined that period for the deferred start-up such found it fair, just, and to record the start-up O&M the western EIM to a a 10-year amortization costs was reasonable; o Eound it fair, just, and reasonabl-e to al-low the Company to record expenses to the deferral- account until the earl-ier of when the Company begins recovery of western EIM costs and the deferral balance or the end of 2078; WH]TE, DI Idaho Power U Company 25 1 2 3 4 5 6 1 B 9 o Declined to apply a carrying charge to deferred amounts; and o Declined to provide pre-approval for recovery of Idaho Power's estimated incremental- costs of joining the western EIM. II. EIM COST UPDATES the that O. Has the Company updated its quantlfication of incremental start-up, capital, and ongoing O&M costs wil-l- be incurred due to its participation in the 2016 2017 2018 10 western EIM? 11 A. Yes. In total, current cost estimates have t2 decreased to $13.71 mi11ion, a reduction of $2.06 mil1ion 13 from the $15.77 mil-l-ion initiall-y estimated in Case No. 14 IPC-E-16-L9. The updated estimates are summarized in the 15 tabl-e bel-ow: EIM Incremental Cost Estimates in millions of dollars As filed in case 2019 2020 Total IPC-E-I6-19 $ Chanse Capital Software Metering Total Capital Operation and Maintenance Start-up costs Ongoing O&M Total O&M $ 0.00 0.00 7.88 $ 1.48 7.96 9.36 (1.40) $ 0.21 0.04 $3.8 r r.97 $ r.83 0.r0 $ 0.00 $ 0.00 5.85 $ 2.tl (2.03) 0.63 0.25 5.78 r.93 0.00 0.00 0.34 0.00 0.86 0.00 0.87 0.79 0.00 1.42 0.00 1.47 2.07 3.68 1.73 4.68 0.34 ( 1.00) (0.66)0.34 0.86 1.66 1.42 1.47 s.7s 6.41 76 71 1B Total projected costs $_qi59 $q,.10l $.].I9 The changes in estimated costs j-ncreased capitalized meterlng $ 1.42 $ r.47 $ 13.7r $ rs.77 $___p.00) are due primarily to costs, which were more than WHITE, DI 9 Idaho Power Company 1 2 3 4 5 6 1 B 9 offset by reduced capitalized software costs and lower than expected ongoing incremental O&M costs. III. TNTERIM METTIOD FOR RECOVERY OF COSTS O. Please describe the Company's proposal in this case for interim recovery of incremental- costs associated with participation in the western EIM. A. The Company will- begin to participate in the western EIM in April 2078, dt which time, under currently established regulatory mechanisms, the benefits of participation wil-l accrue to customers through l-ower actual- NPSE included in the PCA. To most accurately match the timing of benefits and costs of participation in the western EIM, the Company proposes to adjust its PCA forecast to reflect the anticipated reduction in NPSE resulting from EIM participation and to inc1ude the revenue requirement associated with the j-ncremental costs of EIM participation as a temporary rate component in Schedul-e 55, Power Cost Adjustment ("Schedule 55"), until- these costs and benef its can be ref l-ected i-n base rates. O. Please explain how the costs associated with EIM participation would be coll-ected through Schedul-e 55. A. Idaho Power proposes to incl-ude the annual revenue requirement recovery through a 55, similar to how associated with EIM-refated costs for component under Schedule and Energy Efficlency 10 11 T2 13 74 15 76 T1 1B 79 20 2t 22 23 24 temporary rate revenue sharing WHITE, Idaho DI Power 10 Company 25 1 Rider transfers have been incl-uded in Schedule 55 in recent 2 filings. 3 Q. Why does the Company believe it is appropriate 4 to util-ize Schedufe 55 for interim cost recovery of EIM- 5 related costs? 6 A. The benefits of EIM participation are in the 7 form of reduced NPSE, and in the interim these benefits 8 wiII be reflected in the forecast portion of the PCA rate, 9 which is col1ected through Schedul-e 55. The Company l-0 believes it is appropriate to recover the EIM-rel-ated costs 1l- incurred to achj-eve those NPSE benefits through the same 12 rate schedul-e. Using Schedul-e 55 for interim cost recovery 13 of EIM-related costs wil-l- al-so provide administrative 74 efficiencies. 15 Has Idaho Power quantified the revenue 16 71 1B 27 22 23 24 O. requirement proposing to A. associated with ElM-rel-ated costs it is recover through Schedule 55? Yes. Based on the current cost i-nformation 79 discussed earlier in my testimony, the estimated Idaho 20 j urisdictional- revenue June 2078 through May No. 1. requirement is $3.57 million using a shown in Exhibit201,9 test period, as O. Under the Company's current PCA methodology, only 95 percent of the benefits associated with EIM participation will- flow to customers. Will the Company WHITE, Df Idaho Power 11 Company 25 1 include 100 percent of the costs assocj-ated with EIM 2 participation in Schedule 55? 3 A. No. Idaho Power is proposing to include only 4 95 percent of the Idaho jurisdictional revenue requlrement 5 for recovery under Schedule 55. This results in $3.39 6 mill-ion ($3.57 million x 95 percent $3.39 mil-l-ion) to be 7 coll-ected f rom Idaho customers. 8 Q. Please describe the EIM costs that are 9 included 1n the revenue requirement presented in Exhibit 10 No. 1. ll A. The EIM-rel-ated costs inc]uded in the revenue 12 requj-rement computation consist of the return on net rate 13 base (at the Company's currently authorized rate of return) 74 from the capital investment required to participate in the 15 western EIM, depreciation and amortization expense, taxes, 16 ongoing incremental O&M expenses, and amortization of L'l deferred start-up costs. In accordance with Order No. 18 33706, the revenue requirement computation includes a 10- 19 year amortization of deferred start-up costs beginning June 20 t, 201,8, allowing the continued deferral of expenses 21 associated with EIM participation until- cost recovery 22 begins. 23 O. Wil-l the revenue requirement associated with 24 EIM-related costs be updated annually? 25 WH]TE, DI Idaho Power 72 Company 1 2 3 4 5 6 1 I 9 A Yes. Each year the Company will estimate the annual revenue requirement Idaho-allocated basis, to associated with EIM costs, on an be recovered through Schedule 55. The Company proposes to update Schedule 55 rates annually with rates going into effect on June 1. O. How does Idaho Power propose to allocate the revenue requirement associated with EIM participation to each class of customers? A. The Company is proposing to collect the 10 revenue requirement through a uniform cents-per-kilowatt- 11 hour ("kwh") rate, in the same manner that forecasted EIM 12 benefits will be applied to customer rates. For 13 il1ustrative purposes, the Company has provided an example 74 of Schedule 55 modified to include this rate component as 15 Exhibit No. 2. Based on 95 percent of the $3.57 mil-lion !6 Idaho jurisdictional revenue requirement, or $3.39 milllon, 1,7 and the Company's normalized Idaho jurisdictional forecast 18 sal-es for the June 20LB through May 2019 test period of 79 74,295,406 megawatt-hours ("MWh"), the EIM cost recovery 20 rate included on Schedule 55 would be 0.0231 cents per kwh 27 ( ($3,393,272 / 74,295,406 MWh) $0.231A/MWb : 0.0237 22 cents/kwh). Please note that the sample Schedule 55 23 provided as Exhibit No. 2 ts for i1Iustrative purposes only 24 and is intended to demonstrate the Company's proposal to 25 collect ETM-related costs through Schedule 55. The Company WHITE, Idaho DI Power 13 Company 1 ) 3 4 q 6 1 B 9 is not proposing any rate changes to Schedule 55 at this time. O. Please explain how forecasted EIM benefits will be included in customer rates. A. The Company proposes to estimate EIM benefits on an annual basls and incl-ude the benefits as an offset to the PCA forecast of NPSE. The forecasted EIM benefits will 10 be captured is recovered demonstrated Schedule 55 O. A. in the forecast portion of the PCA rate, which from customers on a cents-per-kWh basis, ds in the Projected Power Cost section of inc]uded as Exhibit No. 2. How will EIM benefits be estimated? For the first year of participation, the assumed to equal the estimated 11 l2 13 L4 15 76 L'7 1B t9 20 estimated benefits costs, resulting in a net zero impact to NPSE and customer gai-ns experience in the EIM, lt forecast of EIM benefits for wiII be determining information the forecast rates. As the Company intends to update this inclusion in subsequent PCA filings. EIM benefits The method of will incorporate WH]TE, DI Idaho Power from quarterly EIM benefits reports received 27 from CAISO as well as any other availab1e pertinent data. 22 O. Has the Company updated its analysj-s of the 23 benefits that may be derived from participation in the EIM? 24 A. No. The Energy and Environmental Economics, 25 Inc. ("E3") study used to estimate EIM benefits has not t4 Company 1 2 3 4 5 6 1 U 9 been updated from TPC-E-1 6-79 - O. What A. E3'S the original study used in Case No estimate of EIM benefits? scenario estimated savings of annually on a system basis. 10 was E3's basel-ine approximately $4. 5 mil-l-ion Anderson DI, p. 71. O. Why is the Company not proposing to use this amount to estimate June 20tB through May 2019 EIM savings? A. Due to the uncertainty surrounding the level of benefits that wifl be achieved during the first year of participation and the number of assumptj-ons inherent in E3's study, the Company believes that it would be prudent to take a conservative approach to estimating the benefits until- it has actual experience participating in the EIM. The Company also believes the proposal to set EIM benefits equal to costs for the first year of participation is reasonable as EIM benefits will- automatically be trued-up 11 72 13 t4 15 76 71 1B t9 20 2t 22 23 24 through the form accounts of NPSE the existing PCA mechanism. ActuaI benefits, in of reduced NPSE, will accrue through the NPSE of the PCA. Any variance between the PCA forecast and actual NPSE, includj-ng the benefits assoclated with EIM participation, will be captured in the true-up bal-ance of the PCA. 0. Will the EIM-related annua] revenue WHITE, DI Idaho Power 15 Company 25 requi-rement also be subject to a true-up? 1 2 3 4 5 6 1 B 9 A. Yes. The Company wil-l- recal-cufate the revenue requirement annual1y, based on actual- costs, from the prior calendar year for true-up in the subsequent year, j-ncluding changes in rate base. 0. Please elaborate on how the true-up wou1d be calcul-ated. A. In February of each year, the Company wil-l- recalculate the Idaho jurisdictional- revenue requirement based on actual costs and compare it to the revenue requirement included in customer rates. Any under- or over-recovery woul-d be collected or refunded as part of the Schedul-e 55 EIM Participation Cost rate component in the following year, in conjunction with the fol-l-owing year's updated Idaho jurisdictional- revenue requirement. For example, in Eebruary 2019, Idaho Power proposes to submit a compliance filing in this docket to provide an updated revenue requirement computation that incl-udes seven months of actual EIM-related costs (June-December 2018) and five months of forecasted costs (January-May 201,9). Idaho Power wj-1l compare this updated revenue requirement amount 76 Company 10 11 t2 13 74 15 76 71 1B 19 20 27 to the June 20lB through May 2079 revenue requj-rement being would be22 collected in customer rates. Any variance 23 j-ncl-uded for coll-ection or refund beginning June t, 20L9. 24 In addition to cal-culating the revenue requirement true-up 25 in February 20L9, the Company wj-l-l- al-so prepare a revenue WHITE, Idaho DI Power 1 2 3 4 5 6 1 B 9 requirement estimate for the June 20L9 through May 2020 test period. Together, the net of these two components will- be included for recovery through Schedul-e 55, beginnj-ng June 7, 2079. fn February 2020, Idaho Power w111 submit a compliance filing t.o computation for the that wil-f include 12 provide the final- revenue June 2078 through May 2019 months of actual costs. requirement test period Idaho Power 10 will compare this final updated revenue requirement computation to the June 20LB through May 2079 revenue requirement collected through customer rates. Any variance would be included for collection or refund through this mechanism, beginning June 7, 2020. O. Has the Company prepared an exhibit to 11 72 13 \4 15 demonstrate how the annual- true-up will work? 16 A. Yes. Pl-ease see Exhibit No. 3, which provides l1 a numerical example as well as a timel-ine that summarizes 18 the annual- true-up process described above. 19 O. Why is the Company proposing to provide this 20 compliance filing each year in February? 21 A. fdaho Power is proposing to provide Commission 22 Staff ("Staff") and intervening parties this information by 23 the end of February each year to al-l-ow adequate time for 24 review of the prudence of the incurred costs and accuracy 25 of the true-up calculation, as well as the following year's WHITE, DI Idaho Power L1 Company 1 2 3 4 5 6 1 B 9 forecasted revenue requi-rement computation. The Company wil-l- then seek approval of the revenue requj-rement true-up amount and the fol-lowing year's revenue requirement computation as part of the annual- PCA filing. O. What happens in subsequent years? A. Estimated benefits will continue to be included in the PCA forecast as an offset to NPSE, and the revenue requirement associated with EIM-rel-ated costs wil-l be recovered through Schedule 55, updated and trued up annua1ly. Until the EIM benefits and costs are incorporated into base rates through a future rate proceedj-ng, the cost recovery methodology would not change. O. Why not wait for a general rate case to 15 incl-ude the incremental EIM costs in rates at that ti-me? term, the Company envisions that associated with its 15 Over the long 1B 10 11 72 13 74 A L1 both the benefits and costs 79 )n 2t )) participation rates through the timing of woul-d adj ust mechanism for recovery costs and in the western EIM would be refl-ected in base a future rate proceeding. However, because the Company's next regulatory proceeding that base rates is not known, dD interim rate cost is necessary to provide for Z3 proper matching The cost/benefit24 benefits 1n customer rates. matching proposed by the Company in this that the customers who receive the of WHITE, Df Idaho Power 18 Company 25 case will assure 3 4 5 6 7 B 9 1 benefits of Idaho Power's participation in the EIM also pay 2 for the costs to participate. IV. CONCLUSION O. Please summarize the Company's request. A. Idaho Power is requesting authority to establish an interim recovery mechanism for costs associated with participation in the western EIM beginning June 1-, 20L8, through a rate component of Schedule 55. The Company bel-ieves the ratemaking treatment proposed in this case 1s appropriate for several reasons. The proposal closely matches the tlming of the EIM- rel-ated benefits, whi-ch will begin accruing to customers 10 11 L2 13 through reduced NPSE in April 2018, with the recovery of L4 the costs. A1so, with the proposed true-up mechanism for 15 estimated costs, Idaho Power wil-I coll-ect actual- EIM- 76 rel-ated costs and all costs will be subject to 71 review by Staff and approval by the Commission. 1B absent the ability to recover j-ncremental- costs 79 20 27 22 23 aALA 25 thorough Fina11y, associ-ated with EIM participation, Idaho Power woul-d suffer negative financial impacts. The costs and benefits of EIM participation should continue to be refl-ected in Schedule 55, until- they can be incorporated into base rates j-n a future proceeding. wHrTE, Dr 79 Idaho Power Company 1 Q. Is there a specific date the Company requests 2 the Commission to consider as it contemplates the schedule 3 for the processing of this case? 4 A. Yes. In order to inc1ude any impacts of this 5 filing in the next PCA filing, the Company respectfully 6 requests the Commission consider a case schedule that would 7 all-ow for an order to be issued by March 31, 201,8. I Q. Do you believe that approval of the Company's 9 request in this case wil-l- serve the public interest and 10 provide Idaho Power a reasonabl-e opportunity to recover its 11 prudently j-ncurred costs rel-ated to its participation in 72 the western EIM? 13 74 15 76 L1 1B 79 20 27 22 A O A Yes, I do. Does this complete your testj-mony? Yes, it does. 23 24 wHrTE, Dr 20 fdaho Power Company 25 1 2 3 4 trJ 6 1 9 ATTESTATION OF TESTIMONY STATE OF IDAHO SS. County of Ada I, Tami White, having been duly sworn to testify truthfully, and based upon my personal knowledge, state the following: I am employed by Idaho Power Company as the Senior Manager of Revenue Requirement and am competent to be a witness in this proceeding. f declare under penalty of perjury of the .l-aws of the state of fdaho that the foregoing pre-filed testimony and exhibits are true and correct to the best of my information and belief. DATED this 14tt day of November 20L7. Tami V[hlte SUBSCRIBED AND SWORN to before me thls 14th day of November 20L7. ;3.S3 t Notary for Residing at:Boise Idaho My commission expires: 02/04/2027 wHrTE, Dr 2L Idaho Power Company 10 11 72 13 t4 15 76 L1 1B 79 20 2L 22 23 24 25 26 27 2B 6otA4, lulr,lc rDa-t I lg DT 10 .4r^LD/H. ;q BEFORE THE !DAHO PUBLIG UTILITIES GOMMISSION cAsE NO. IPC-E-17-16 IDAHO POWER COMPANY WHITE, DI TESTIMONY EXHIBIT NO. 1 ldaho Power Company Western EIM Participation Costs ldaho Jurisdictional Revenue Requirement RATE BASE 612Ot8-Slz0te 1 Electric Plant in Service 2 lntangible Plant 3 Production Plant 4 Total Electric Plant in Service 5 Less: Accumulated Depreciation 5 Less: Amortization of Other Plant 7 Net Electric Plant in Service 8 Less: Accumulated Deferred lncome Taxes 9 Add: Other Deferred Amounts 10 TOTAL COMBINED RATE BASE NET INCOME S 5,598,587 2,077,407 7,6L5,994 28,922 54L,799 7,O45,2-13 814,303 t,965,442S a,ogs,+rz s t,3L7,926 57,844 t,279,357 37,689 1,3L3,409 (2,205,959) (255,368) 1,538,898 (1,538,898) (1,538,898) 1.86% 2,L75,276 7.642 s 3,571,902 9s% s 3,393,212 Exhibit No. 1 Case No. IPC-E-17-'16 T. White, IPC Page 1 of 1 11 Operating Revenues 72 Sales Revenues 13 Operating Expenses t4 Operation and Maintenance Expenses 15 Depreciation Expenses 16 Amortization of Limited Term Plant t7 Taxes Other Than lncome 18 Provision for Deferred lncome Taxes 19 Federal lncome Taxes 20 State lncome Taxes 2t Total Operating Expenses 22 Operating lncome 23 Consolidated Operating lncome 25 Authorized Rate of Return 26 Earnings lmpact 27 Net-to-Gross Tax Multiplier 28 Revenue Requirement ldaho sharing percentage IDAHO EIM COST RECOVERY AMOUNT BEFORE THE IDAHO PUBLIC UTILITIES GOMMISSION GASE NO. IPC-E-17-16 IDAHO POWER COMPANY WHITE, DI TESTIMONY EXHIBIT NO.2 ldaho Power Company enventnfwe[h Revised Sheet No. 55-1 Cancels l.P.U.C. No. 29, Tariff No, lOlTenthEleventh Revised Sheet No. 55-1 SCHEDULE 55 POWER COST ADJUSTMENT APPLICABILITY This schedule is applicable to the electric energy delivered to all ldaho retail Customers served under the Company's schedules and Special Contracts. These loads are referred to as "firm" load for purposes of this schedule. BASE POWER COST The Base Power Cost of the Company's rates is computed by dividing the sum of the Company's power cost components by firm kWh sales. The power cost components are segmented into three categories: Category 1, Category 2 and Category 3. Category 1 power costs include the sum of fuel expense and purchased power expense (excluding purchases from cogeneration and small power producers), less the sum of off-system surplus sales revenue and revenue from market-based special contract pricing. Category 2 power costs include purchased power expense from cogeneration and small power producers. Category 3 power costs include demand response incentive payments. The Base Power Cost is 2.0838 cents per kWh, which is comprised of Category 1 power costs of 1.0927 cents per kWh, Category 2 power costs of 0.9108 cents per kWh and Category 3 power costs of 0.0803 cents per kwh. The Projected Power Cost is the Company estimate, expressed in cents per kWh, of the Category 1, Category 2 and Category 3 power cost components for the forecasted time period beginning April 1 each year and ending the following March 31. The Projected Power Cost is 2.5708 cents per kWh, which is comprised of Category 1 power costs of 1.2815 cents per kWh, Category 2 power costs of 1.2365 cents per kWh and Category 3 power costs of 0.0528 cents per kWh. The forecasted customer benefits associated with ldaho Power's participation in the western Enerqv lmbalance Market are reflected in the Cateqory 1 power cost component of the Proiected Power Cost. TRUE.UP AND P o FTH E TRUE-UP The True-up is based upon the difference between the previous Projected Power Cost and the power costs actually incurred. The True-up of the True-up is the difference between the previous year's approved True-Up revenues and actual revenues collected. The total True-up is 0.2585 cents per kWh. EARNINGS SHARING Order Nos. 30978, 32424, and 33149 directed the Company to share a portion of its earnings above a certain threshold with customers through the annual Power Cost Adjustment. The Company's 2016 earnings were below the prescribed threshold resulting in a credit of 0.0000. Schedule I 3 5 7 9S 9P d per kWh 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Description Residential Service Master Metered Mobile Home Park Residential - Time-of-Day Pilot Plan Small General Service Large General Service - Secondary Large General Service - Primary Exhibit No. 2 Case No. IPC-E-17-16 T. White, IPC Page 1 of3 IDAHO lssued per Order No. 33775 Effective - Jun€-+2O+7 lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho ldaho Power Company Sixth Revised Sheet No. 55-2 Cancels |.P.U.C. No. 29. Tariff No. 101 Fifth Revised Sheet No. 55-2 SCHEDULE 55 POWER COST ADJUSTMENT (Continued) EARNINGS SHARING (Continued) 9T 15 195 19P 197 24 40 41 42 Large General Service - Transmission Dusk to Dawn Lighting Large Power Service - Secondary Large Power Service - Primary Large Power Service - Transmission Agricultural I rrigation Service Unmetered General Service Street Lighting Traffic Control Lighting Monthlv Credit Micron Simplot DOE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 $0.00 $0.00 $0.00 (0.057e) (0.0543) (0.056s) d per kWh (0.1 148) (0.1097) (0.1 107) (0.1463) (0.0864) (0.o7so) (0.0846) (0.2486) (0.0746) (0.0661) (0.062s) (0.0e3e) (0.1032) (0.1633) (0.0730) 26 29 30 REFUND OF ENERGY EFFICIENCY ("EE') RIDER FUNDS The following rate schedules will receive a rate credit associated with the refund of EE Rider funds in the form of a cents per kWh rate. Schedule Description Residential Service Master Metered Mobile Home Park Residential - Time-of-Day Pilot Plan Small GeneralService Large General Service - Secondary Large General Service - Primary Large General Service - Transmission Dusk to Dawn Lighting Large Power Service - Secondary Large Power Service - Primary Large Power Service - Transmission Agricultural lrrigation Service Unmetered General Service Street Lighting Traffic Control Lighti ng Micron Simplot DOE 1 3 5 7 9S 9P 9T 15 195 19P 197 24 40 41 42 26 29 30 Exhibit No. 2 Case No. IPC-E-17-16 T. White, IPC Page 2 of 3 IDAHO lssued per Order No. 33775 Effective - June 1, 2017 lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho ldaho Power Company Fifrh$jlh Revised Sheet No. 55-3 Cancels LP.U.C. No. 29. Tariff No. 101 Eeu#hFifth Revised Sheet No. 55-3 SCHEDULE 55 POWER COST ADJUSTMENT (Continued) ENERGY IMBALANCE MARKET PARTICIPATION COSTS Order No.orovides for cost recovery of the incremental costs associated with ldaho Power's participation in the western Enerqv lmbalance fvlarket. The Enerqv lmbalance Market Participation Cost is 0.0237 cents per kWh based upon the ldaho iurisdictional revenue requirement associated with western Enerqv lmbalance Market participation costs. POWER COST ADJUSTMENT The Power Cost Adjustment is the sum of: 1) 95 percent of the difference between the Projected Power Costs in Category 1 and the Base Power Costs in Category 1;2) 100 percent of the difference between the Projected Power Costs in Category 2 and the Base Power Costs in Category 2; 3) 100 percent of the difference between the Projected Power Costs in Category 3 and the Base Power Costs in Category 3; 4) the True-ups; 5) Earnings Sharing; and 6) the refund of EE Rider funds. The monthly Power Cost Adjustment rates applied to the Energy rate of all metered schedules and Special Contracts are shown below. The monthly Power Cost Adjustment applied to the per unit charges of the nonmetered schedules is the monthly estimated usage times the cents per kWh rates shown below. Schedule Description Residential Service Mastered Metered Mobile Home Park Residential - Time-of-Day Pilot Plan Small GeneralService Large General Service - Secondary Large General Service - Primary Large General Service - Transmission Dusk to Dawn Lighting Large Power Service - Secondary Large Power Service - Primary Large Power Service - Transmission Agricultural lrrigation Service Unmetered General Service Street Lighting Traffic Control Lighting Micron Simplot DOE d per kWh 0.6213 0.6264 0.6254 0.5898 0.6497 0.6611 0.6515 0.4875 0.661s 0.6700 0.6736 0.6422 0.6329 0.5728 0.6631 1 3 5 7 9S 9P 9T 15 195 19P 197 24 40 41 42 26 29 30 EXPIRATION 0.6782 0.6818 0.6796 The Power Cost Adjustment included on this schedule will expire May 31,2018. Exhibit No. 2 Case No. IPC-E-17-16 T. White, IPC Page 3 of 3 IDAHO lssued per Order lrle. 33775 Effective - June-4#e# lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-17-16 IDAHO POWER COMPANY WHITE, DI TESTIMONY EXHIBIT NO.3 Energy lmbalance Market Cost Recovery Revenue Requirement True-up Process Note the omounts presented in this exhibit ore for illustrotive purposes only. June 2018-May 2019 ldaho Jurisdictional Revenue Requirement lnitial revenuerequirementestimate(95%) S 3,393,212 A lncludedinSchedule55ratesJunel,20ls Updated revenue requirement estimate (95%) filed February 2019 (7 months actuals; 5 months estimates) S 3,000,000 True-up S (393,212) B lncluded in Schedule 55 rates June 1, 2019 Final actual revenue requirement (95%) filed February 2020 (12 month actuals) S 2,900,000 cFinalTrue-up $ (100,000)D lncludedinScheduleSsratesJunel,2O2O June 2019-May 2020 ldaho Jurisdictional Revenue Requirement lnitial revenue requirement estimate filed February 2019 (95%l Updated revenue requirement estimate (95%) filed February 2020 (7 months actuals; 5 months estimates) S 3,000,000 E lncluded in Schedule 55 rates June 1, 2019 S 2,9oo,ooo True-up $ (100,000) F lncluded in Schedule 55 rates June 1, 2020 Final actual revenue requirement (95%) filed February 2021 (12 month actuals)s 2,8s0,000 Final True-up s lncluded in Schedule 55 rates June 1, 2021(s0,000) G H +These amounts would also include the initial revenue requirement estimates for June 2O2O-May 2O2L and June 2021-May 2022, respectively, but for purposes of limiting this exhibit to a two-year review of the revenue requirement true-up process, these amounts have been excluded. Exhibit No. 3 Case No. IPC-E-17-16 T. White, IPC Page 1 of 2 Amounts lncluded in Schedule 55 Rates June 2018-May 2019 Schedule 55 Rates June 2019-May 2020 Schedule 55 Rates June 2020.May 2021 Schedule 55 Rates June 2021-May 2022 Schedule 55 Rates Total collected through Schedule 55 Rates Revenue Requirement June 2018- May 2019 June 2019- May 2020 Total Requested Recovery throu8h Schedule 55 Rates S 3,393,2L2 A (393,212) B (100,000) D NA N/A S 3,ooo,ooo E F H (100,000) (s0,000) $3,393,212 2,606,788 (200,000) * (5o,ooo) + s 5,750,000S 2,9oo,ooo c s 2,8s0,000 G Date Documentation Provided lntent April2018 2018 PCA filing, which will include a discussion of the EIM costs being included for recovery through Schedule 55 Seek approval ofthe estimated revenue requirement computation as filed in this case, as well as the resulting EIM cost recovery rate to be included in Schedule 55, beginning June 1, 2018 February 2019 Updated revenue requirement computation for June 2018 - May 2019; includes 7 months actual costs and 5 months estimated costs lnitial estimated revenue requirement comoutation for June 2019 - Mav 2020 Review of the incurred costs and review of the revenue requirement true-up calculation Review of the new estimated revenue reouirement computation April2019 2019 PCA filing, which will include a discussion of the EIM costs being included for recovery through Schedule 55 Seek approval of the revenue requirement true- up amount and the updated revenue requirement computation as provided in February 2019, as well as the resulting EIM cost recovery rate to be included in Schedule 55, hesinnino lrrne 1 2O1 I February 2020 Final actual revenue requirement computation for June 2018 - May 2019; includes 12 months actual costs Updated revenue requirement computation for June 2019 - May 2020; includes 7 months actual costs and 5 months estimated costs Estimated revenue requirement computation for June 2O2O - Mav 2O2L Review of the incurred costs and review of the revenue requirement true-up calculation for both test years Review of the new estimated revenue requirement computation April2020 2020 PCA filing, which will include a discussion of the EIM costs being included for recovery through Schedule 55 Seek approval of the revenue requirement true- up amount and the updated revenue requirement computation as provided in February 2020, as well as the resulting EIM cost recovery rate to be included in Schedule 55, haoinnino lrrne 1 7O7O Energy lmbalance Market Cost Recovery Revenue Requirement True-up Process Exhibit No. 3 Case No. IPC-E-17-16 T. White, IPC Page 2 of 2