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HomeMy WebLinkAbout20191017Larkin Direct.pdfR EC E IVTD ?CIlt 0[T I 7 Pll h: 3h i;l'l"liLi t:'Ll*LlC .r rri ,'i"i-:i {l0i"il*illj$l0N BEFORE THE ]DAHO PUBLIC UTIL]TIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY' S APPLICATION EOR AUTHORTTY TO DECREASE ITS RATES FOR ELECTR]C SERV]CE FOR COSTS ASSOCIATED WITH THE BOARDMAN POWER PLANT. CASE NO. IPC_E-19_32 IDAHO POWER COMPANY DIRECT TEST]MONY OF MATTHEW T. LARKIN ) ) ) ) ) ) ) 1 2 3 4 trJ 6 1 B 9 U. present position with "Company"). A. My name address is L22L West am employed by Idaho fdaho Power Company ("Idaho Power" or Please state your name, business address, and is Matthew T. Larkin. My business Idaho Street, Boise, Idaho 83102. Power as the Revenue Requirement I 10 Senior Manager in the Regulatory Affairs Department. O.Please descri-be your educational background. A. I received a Bachel-or of Business Administration degree in Einance from the Unj-versity of Oregon in 2001. In 2008, I earned a Master of Business Administration degree from the University of Oregon. I have al-so attended electric utility ratemaking courses, including the ELectric Rates Advanced Course, offered by the Edlson Electric Institute, and Estimation of El-ectricity Marqinaf Costs and Application to Pricinq, presented by National Economic Research Associates, Inc. O. Pl-ease describe your work experience with Idaho Power. A. I began my employment with Idaho Power as a Regulatory Analyst in January 2009. As a Regulatory Analyst, I provided support for the Company's regulatory activities, lncluding compliance reporting, financial analysis, and the development of revenue forecasts for regulatory filings. 11 t2 13 74 15 76 t1 1B 19 20 2t )) 24 LARKIN, Df Idaho Power 1 Company 1 In January 2074, I was promoted to Senior Regulatory 2 Analyst where my responsibilities expanded to include the 3 development of complex cost-rel-ated studies and the 4 analysis of strategic regulatory issues. 5 Since becoming the Revenue Requirement Senior 6 Manager in March 20L8, I have overseen the Company's 7 regulatory activities related to revenue requirement, such I as power supply expense modeling, jurisdi-ctional separation 9 studies, and Idaho Power's Open Access Transmission Tariff 10 f ormul-a rate. 11 r. OVERVTEST 72 What is Idaho Power's request in thls case? 13 The Company is requesting authorization to 74 decrease customer rates to reflect the incremental annual 15 levellzed revenue O A the requirement pursuant to the cost recovery Boardman power plant ("Boardman") approvedL6 22 approach for by the Idaho PubIic Utilities Commlssion ("Commission") int1 18 Order No. 32451.Speci ficaIly, find that aII79 the Commission (1) 20 investments through December 31, 27 incurred, (2) approve an through 2020 at Boardman Idaho Power is requesting actual Boardman 20L8, were prudently to forecasted investments included in the levelized update to be 23 revenue requirement mechanism established by Order No. 24 32451, and (3) decrease customer rates $1.06 million to 25 reflect the decrease i-n collections associated with the LARKIN, DI Idaho Power 2 Company 1 Boardman levelized revenue requirement effective January l, 2 2020, which equates to an overall decrease of 0.09 percent. 3 Q. How is your testimony organized? 4 A. My testimony begins with a summary of the 5 Boardman balancing account mechanism approved with Order 6 No. 32451 and the Boardman i-ncremental annual levefized 7 revenue requirement approved with Order No. 32549. My I testimony then summarizes the requested reduction of $1.06 9 million to the Boardman levelized revenue requlrement 10 currently in customer rates, with a requested effective 11 date of January 7, 2020, including updates to refl-ect the 12 (1) decrease in the annual Ievelized revenue requirement of 13 $38,922, (2 ) galn of $251 ,0'l'l associated with an Asset 74 Purchase Agreement (*APA") with Portland General- Electric 15 ("PGE"), (3) true-up of $473,097 in over collection of L6 prior years' revenues, and (4 ) over col-l-ection of $295, 158 L1 in prevj-ous years' revenue requirement amounts. 1B Do you have any exhlbits? 19 Yes. Exhiblt No. 1 to my testimony provides a 20 summary of the updated levelized revenue requirement cal-culations by cost category and compares the amount to the l-evel-ized revenue requirement approved with Order No. 32459 that is currently included in customer rates. Exhibit No. 2 provides the quantification of the true-up associated with prior years' revenue col-l-ections. 2t 22 23 24 25 o A LARKIN, DT Idaho Power 3 Company 1 2 3 4 5 6 1 x 9 II. BACKGROT'IID O. Pl-ease describe Boardman. A. Boardman is a pulverized-coal plant located in north-central Oregon. It went into service in 1980 and consists of a single generating unit. Idaho Power owns a 10 percent interest , or 58.5 megawatts (net dependable capacity), in Boardman. After adjusting for routine schedul-ed maintenance periods and estimated forced outages, the Company's share of the plant's annual energy generating capability is approximately 50 average megawatts. PGE has a 90 percent ownership. As the majority partner of the pIant, PGE operates the Boardman facility. Cessati-ons of coal--fired operations at Boardman, which was approved by federal and state regulators in 2010 and 2011, wil-l occur December 31, 2020. O. Did Idaho Power update customer rates to 10 11 L2 13 74 15 t6 l7 reflect Boardman's early cessation of coal-fired 18 operations? 19 A. Yes. On September 26, 2017, in Case No. IPC- 20 E-11-18, Idaho Power fil-ed an application wj-th the 27 Commission requesting an order (1) accepting the Company's 22 accounting and cost recovery plan for the early shutdown of 23 Boardman and (2) allowing the Company to establish a 24 balancing account to track shutdown-related costs and 25 benefits. In February 2072, the Commission issued Order LARKIN, Df Idaho Power 4 Company 1 2 3 4 5 6 1 B 9 No. 32451 authorizing the Company account to track the incremental to establ-ish a balancing costs and benefits 10 associated with the early shutdown of Boardman. 0.Please describe the Boardman balancing account mechanism. A. The balancing account tracks the incremental costs associated with the accel-erated Boardman end-of-Iife date, including (1) the return on undepreciated capital investments at Boardman until its shutdown, (2 ) the accelerated depreci-atj-on associated with Boardman j-nvestments, and (3) decommissioning costs related to the11 12 Boardman shutdown. Each of these revenue requirement 13 components are subsequently "levelized" by calculating the 74 present value of each of the individual j-tems and 15 converting the values into an annuity or level payment 16 stream from customers over the remaining fife of Boardman l7 using a return on equity of 9.5 percent, dS approved in 18 Order No. 32451. 19 The Boardman balancing account smooths revenue 20 requirement impacts of the early Boardman retirement over 27 the remaining years of the plant's life and provides an 22 opportunity for ful-l recovery of Boardman-related costs by 23 Boardman life end. In addition, it more closely aligns 24 the cost recovery perlod with the remaining operating l-ife 25 of the p1ant, resulting in a better matching of cost LARKIN, DI Idaho Power 5 Company 1 recovery from customers who benefit from the plant's 2 operatj-ons while mitigating the risk of future customers 3 bearing the costs of a plant that will no longer be providing service. 0. When were costs tracked in the Boardman bal-ancing account first reflected in customer rates? A. On February 15, 2072, in Case No. TPC-E-12-091 Idaho Power 4 5 6 1 U 9 recovery of requested authority to the l-evelized revenue 10 with Boardman's 2020 end-of-life increase rates to begin requirement associated The Company replaced the 11 then current non-Ievellzed base rate revenue recovery 72 associated with Idaho Power's existing investment 1n 13 Boardman with a levelized revenue requirement that is 14 tracked in the Boardman bal-ancing account. On May 7J , 15 2072, the Commission issued Order No. 32549, 76 L1 1B l9 20 27 22 23 implementation of the cost recovery Order No. 32457 and increasing the requj-rement by $7,525, 501 ef fective reflect the new levelized Boardman u changes in requirement A. SINCE No. approach Company's June t,2012, to revenue requirement. Has Idaho Power adjusted customer rates for the Boardman annual fevelized revenue authori zrnq approved in annual revenue Order No. 32459 was issued? On March L2, 20t3, pursuant to Order Nos Idaho Power filed 1ts Boardman Power Plant24 32457 and 32549, 25 Annual Review report for the year ending 2072. The Company LARKIN, DI Idaho Power 6 Company 1 dld not request to adjust rates at that time because the 2 difference in the updated Boardman levelized revenue 3 requirement did not warrant a rate change and any 4 differences are tracked in the Boardman balancing account 5 for future collection from or refund to customers. Idaho 5 Power committed to conti-nue to revi-ew the Boardman 7 bal-ancing account annually and update the quantification of 8 the Boardman leve1ized revenue requj-rement. Idaho Power t has fil-ed its Boardman Power Plant Annual Revi-ew each year L0 since then and has not requested to adjust rates. 11 O. Did the U.S. Tax Cuts and Jobs Act of 2071 L2 ("Tax Act") impact the total- Boardman level-ized revenue 13 requirement? 74 A. Yes. Idaho Power's income tax expenses and 15 deferred tax liabillties included in the Boardman level-ized 16 revenue requirement amounts were calculated in accordance 71 with the Internal Revenue Code 18 signed into law on December 20 22, the of 1986. The 2071, amends reduction in Tax Act, sections of the federalL9 the 7986 code, most notably 27 corporate income tax rate from 35 percent to 2t percent. However, all changes to the Boardman levelized revenue requirement resulting from provisions of the Tax Act were cal-cul-ated and determlned with Order No. 34071 in Case No. GNR-U-18-01, the Commission's investigation into the impact of federal tax code revisj-ons on utility costs and 22 23 24 25 LARKIN, DI Idaho Power 1 Company 1 2 3 4 5 6 1 B 9 ratemaking, and were reflected in revenue requj-rement amounts approved in that case. Therefore, tax rates incl-uded 1n the revenue requirement calculations in this flling reflect those tax rates in effect prior to the Tax Act. III. THE BOARDInN LE\IELIZED RE\rENt E REQUIREMENT MECHAIIISM O. How was the levelized revenue requirement approved wlth Order No. 32549 determined? A. The level-ized revenue requirement is determined by calculating the present value of the revenue requirement of each of the individual- balancing account items and converting the val-ues into a level payment stream from customers over the remaining recovery period. Order L4 No. 32549 approved of $1.53 an incremental revenue requirement 10 11 t2 13 15 increase million, leve I i zed76 Boardman-related for a total Idaho jurisdictional revenue requirement of 71 18 t9 20 2L 22 23 24 25 $5, 1'7 4,'194. The $5. 17 million levef ized revenue requirement incl-uded (1) all- Boardman-related plant investments as of May 31, 20L2, which was based on actual plant balances through December 3L, 207L, and forecasted plant balances from January 7, 20L2, through May 3L, 2012, (2) projected additions to the Boardman plant from June 2012 through 2020, and (3) estimated decommissioning and salvage costs. LARK]N, DI Idaho Power B Company 1 2 3 4 5 6 1 B 9 O. You stated Idaho Power's annua] review of the Boardman balancing account indicated the difference in the updated Boardman levelized revenue requirement did not warrant a change to customer rates. Why is the Company proposing to update the l-evel-ized revenue requirement now? A. Idaho Power is proposing to update the Boardman levelized revenue 2020, because the plant cessation of coal-fired account contains true-up operations and amounts that L5 requirement nearing its effective January 7, December 31, 2020, the balancing reflect a refund due10 11 l2 13 2t ZL Z5 24 to customers. The Company wants to appropriately match rate recovery with the useful- l1fe of the p1ant. 0. Will this be the last ad3ustment to the Boardman level-ized revenue requi-rement the Company will-t4 15 make? 76 A No. The intent of Idaho Power's request in 71 this case i-s to update the Boardman annual levelized 18 revenue requlrement to reflect the most current bal-ancing 19 account amounts now that cessation of coal--fired operations 20 is near. However, as I wifl the Company will of-Iife that will Ievelized revenue customers pay no discuss later in my testlmony, costs through Boardman's end- refl-ected in a final annual still incur need to be 25 related costs. fn addition, the Boardman level-ized revenue requi-rement computation to ensure more or no l-ess than actual Boardman- LARKIN, Df Idaho Power 9 Company 1 ) 3 4 5 6 7 U 9 requirement amounts approved with Order No. an estimate for anticipated decommissioning costs. An adjustment to customer rates will- 32549 include and salvage required to with those be true-up amounts Boardman rv. actual decommissioning and salvage costs collected from customers when decommissioning of is complete. THE LEVELIZED REVENT'E REQUIREMENT QUAI{TIFICATION 10 I What is the updated levefized revenue requirement the customers ? Company is proposing to be recovered from A. Updating the Boardman l-evelized revenue requirement components results in an annual level-ized revenue requirement of $5,135,872 on an Idaho jurlsdictional basis, or an annual decrease to the Idaho jurisdictional levelized revenue requirement of $38,922. Exhibit No. 1 summarizes the changes to the l-evelized revenue requirement on a system basis by component and presents the Idaho jurisdictional share of each. O. Pl-ease describe the updates to the Boardman l-evelized revenue requirement components. A. Idaho Power is proposing to update all three components of the l-evelized revenue requirement computation: the revenue requirement associated with all- Boardman-related plant investments as of May 31, 2072, the revenue reguirement on incremental j-nvestments made after 11 L2 13 l4 15 L6 L1 1B 79 20 27 22 23 24 25 LARKIN, DI Idaho Power 10 Company 1- May 31, 2072, and the decommissioning and salvage cost estimate. 0. What is the Company's update to the levelized revenue requirement component associated with existing Boardman-related plant investments as of May 31, 2012? A. The revenue requirement component related to existing investments is based on the Boardman-related plant bafances in effect prior to the establishment of the 2 3 4 5 6 1 B 9 Boardman balancing account, reflecting existing at May 31, 20L2. fn Case No. IPC-E-72-09, the acceferated depreciation expense was based on a investments 10 approved net plant December12 balance that included actual plant values as of 13 31, 20L7, and 2072. Idaho forecasted reserve balances through May 37, 11 L4 15 76 71 1B 79 20 2t )) 23 24 Power exist ing balances Boardman miflion. investment as of May net plant has updated the revenue requj-rement on component to incl-ude actual plant 31, 20L2. As of May 31, 20L2, the investment was approximately $22.51 O. How does this compare to the Boardman-related net plant investments approved in Case No. IPC-E-72-09? A. In Case No. IPC-E-72-09, the Commission approved Boardman-related net plant investments of approximately $27.65 mil-]ion, or approximately $920,000 Iess than actual Boardman-related plant investments at May 25 31, 20L2. LARKIN, DI Idaho Power 11 Company 1 2 3 4 5 6 1 B 9 O. Is Idaho Power proposing any additional updates to the levelized revenue requirement on existing i-nvestments ? A. Yes. Subsequent to Order No. 32549, Idaho Power discovered an error in the calculatj-on of the present value of the revenue requirement on The formula embedded in the models existing investments. used in prior years' annual- reviews was incorrectly discounting requirement for 2072, or the first year of the revenue the l-evel-1zed 10 revenue requirement determinatj-on. The effect of this 11 error was an inappropriate 12 the year 13 Company BoardmanL4 to the base discounting year of the Commission Review for of i-nvestments to analysis. The of this error in its the year ending in the prr_or flrst notified the Power Plant Annua1 15 2071.1 Idaho Power has corrected the error 76 quantificatlon of the j-ncremental l-evel-lzed revenue l1 requlrement associated with Boardman in this case. 18 O. What is the resulting 1evelized revenue 19 requirement on exj-sting investments as of May 31, 2072, 20 incl-uded in the leve1ized revenue requirement calcul-atlon? 27 A. The result is a total l-evel-ized revenue 22 requirement on existing Boardman-related investments at May 23 37, 2012, of $3,936,546 on an Idaho jurlsdictional- basis. I Eited in compliance with Order No. 32549 (Case No. IPC-E-12-09), March 23, 20L8, pp. 3-4. LARKIN, DI fdaho Power L2 Company 1 2 3 4 5 6 1 B 9 O. How does this compare to the level-ized revenue requirement on existing investments currently included in customer rates? A. The updated leve1ized revenue requirement on existing j-nvestments is an increase of approximately $400,000 primarily due to higher than forecasted plant investments through May 31, 2072. O. What changes is the Company proposing to the revenue requirement on incremental investments made after May 31, 20L2? A. The l-evelized revenue requirement component related to incremental- investments captures alI plant investments made at Boardman after May 31, 20L2, or when the Boardman balancing account was established. The ldaho jurisdictiona1 Boardman-related levelized revenue requirement of $5,174,794 approved with Order No. 32549 included $1.1 mil-l-ion associated with new plant investments 10 11 12 13 74 15 I6 l1 1B 19 20 2t 22 Z3 24 25 forecasted to be forecasted plant between June 7, most recent forecast Idaho jurisdictional made after May 3L, 2072. Updating the investments with actual- investments made 20L2,through December 31, 2078, and the of investments for 2079, results in an levelized revenue requirement of LARKIN, DI 13 Idaho Power Company $753,452, or a decrease of approximately $370,000. O. Why has Idaho Power excluded a forecast for new Boardman-related plant investments made in 2020? 1 2 3 4 5 6 1 U 9 A. with repairs forecast for ZCTO. O. The Company anticipates any costs associated in 2020 will be expensed, therefore the Boardman-related plant investments in 2020 is How does the amount of actual investments made between June 7, 2072, through December 31, 20L8, compare to computation of the with Order No.Ievelized revenue requirement approved ')') tr, / o) A The levelized revenue requirement approved 11 wlth Order No. 32549 included incremental plant investments 72 after June 7, 2072, of $8.01 million. However, actual 13 investments made between June 7, 20t2, through than $3 million investments are December 31, L4 expected to 76 $50, o0o . investments77 i-ncremental result in a decrease in the Idaho 18 jurisdictional level-ized revenue requirement of 19 approximately $370,000. 20 O. Please summarize the incremental investments 27 made at Boardman sj-nce the balancing account mechanism was 22 establlshed June L, 2012. 23 A. The Environmental Protection Agency approved 24 PGE's Boardman shutdown plan with coal-fired operations but required investments have25 ceasing on December 3L, 2020, what was forecasted and included in the 10 20l1l were $a anticipated. be fess than 9B million, more Eorecasted 2019 l-ower than 15 The lower than forecasted LARKIN, DI Idaho Power 74 Company 1 2 3 4 5 5 1 B 9 been made and normaf maintenance repairs have been performed to the Revenue of Exhibit keep the plant Requirement on No. 7, capital operationaf. As can be seen in Incremental fnvestments sectlon additions made at the Boardman plant 20r4. remained under $300,000 in aII years except 2013 and I will summarize the i-nvestments over $300,000 that 10 were made since June 7, 2012 In 2013, obsolete and unsupported variable frequency drives that are a part of the draft fans were replaced, dD emergency repair to col-d reheat piping was made, and the shop warehouse, which provides needed work space for equipment repair and overhaul- and allows plant personnel to perform the necessary maintenance activities, required an expansion. Investments for sul-fur dioxide controls, upgrading to a dry sorbent injection technology, and fj-re protection equipment, were made in 20L4. O. Is Idaho Power proposing any updates to the levellzed revenue requirement associated with decommissioning and salvage costs? A. Yes. Idaho Power's initial estimate of the decommissloning and salvage costs was determined by applylng the Company's 10 percent ownership percentage to the decommissioning study performed by Bl-ack & Veatch for PGE and compl-eted in 2071. In 2075, PGE contracted with CH2M Hill to prepare a decommissioning, demolition, and LARKIN, Df Idaho Power 15 Company 11 t2 13 74 15 T6 71 1B 19 20 27 22 23 24 atr 1 final closure plan for Boardman. The focus of the new plan 2 was to provide pJ-anning guidance, rather than detailed cost 3 estimates. Al-though the plan did not provide updated cost 4 estimates, through the work with CH2M Hill, PGE identified 5 three decommissioning cost elements that coul-d be updated: 5 (1) the elj-mj-nation of Carty reservoir removal costs as the 7 site wil-I remaj-n, (2) transmission assets that wil-1 not I need to be removed, and (3) the Tower Road extension costs 9 will no longer be incurred. The update to the 10 decommissioning costs and expected salvage resulted in a 11 decrease of approxlmately $174,000 in Idaho Power's share L2 of the costs. This decrease equates to a l-evel-ized revenue 13 requirement of approximately $445,8'15 on an Idaho 74 jurisdictional- basis, approximately $60,000 less than the 15 amounts included in the l-evelized revenue requirement 16 approved with Order No. 32549. L7 0. Has PGE initiated any additional 18 decommissi-oning activltles now that Boardman is nearing its 19 end-of-1ife? 20 A. Yes. In 20L8, PGE issued a request for 2l proposal seeking an owner's engineer to complete design and 22 permitting work in preparation for decommissionlng 23 activities in 2019, including capping the ash disposal 24 area, demolishj-ng structures at Boardman (i.e., coal 25 handling systems), remediating the coal yard, and other LARKIN, DI Idaho Power 76 Company 1 Z 3 4 5 6 1 9 selective demolition work across the site (i.e., support buildings, features supporting coal, coal handling, and coal ash handling). With the results, PGE anticipates completing an updated decommissioning cost-estimate study Iater in 2019. 0. What is the resultj-ng total- levelized revenue requirement? A. The Company's proposed update to the fevelized revenue requirement assocj-ated with Boardman incl-udes $3, 936,546 associated with existing investments, $753, 452 related to j-ncremental investments, and $445,8'15 in decommissioning and salvage costs, for a total levelized revenue requirement of $5,135,872 on an Idaho j urisdictional- basis . O. What 1s the existing revenue requirement associated with Boardman that is currently included in the Company's base rates? A. The Idaho jurisdictional levelized revenue requirement approved with Order No. 32549 is $5,174,194. O. How does the total levelized revenue requirement compare to the existing levelized revenue requirement currently in customer rates? A. The total- Idaho jurisdictional levelized revenue requirement of $5.14 mil]ion, Iess the Idaho jurisdictional share of the existing revenue requirement of 10 11 72 13 L4 15 76 71 1B 79 20 27 22 23 24 LARKTN, Df Idaho Power L1 Company 25 1 2 3 4 5 6 1 B 9 $5.17 million, results in an incremental annual- Ievelized revenue requirement of negative $38,922 on an ldaho jurisdictional basis. V. ADDITTONAI REVENITE REQUIREMENT ADin STIT{ENTS Is the Company proposing any additional adjustments to requirement of di s cus sed? the lncremental annual levelized revenue 10 negative $38,922 that have not already been A. Yes. Idaho Power is proposing additional adjustments to the incremental- annual levelized revenue requirement. First, the Company is proposing to add to the incremental annual levelized revenue requirement of negatJ-ve $38,922 the gain associated with the APA between Idaho Power and PGE. In addition, in Case No. IPC-E-72-09, the Company proactively committed to tracking two additional- components: (1) the monthly deviations between forecast revenue collection and actual- revenue collection and (2) deviations between existing fevel-ized revenue requirement calcu1ations and updated levelized revenue requirement cal-cul-ations. Therefore, Idaho Power is proposing to include an adjustment to the Boardman 11 12 13 t4 15 76 71 1B 79 ZU 2t 22 level-ized revenue requirement for both the 23 years' revenue collections and the true-up 24 deviations in levelized revenue requirement 25 col-lected in previous years. true-up of prior associated with amounts LARKIN, DI Idaho Power 18 Company 1 2 3 4 q 6 1 B Y O. Pl-ease describe the APA between Idaho Power and PGE. A. In 2074, Idaho Power and PGE entered into an APA for the conveyance and sale of a partial- interest in certain Boardman components and common facilities necessary or convenient to the operation of PGE's Carty Generation Station,2 collectively referred to as "Shared Eacilities." The purchase price associated with the APA for of Shared Facilities at Boardman was $620,205, the purchase resulting in shown in 2074 actual 10 a gain Exhibit of $264,060 on a total system basis, as No. 1. Idaho Power has included in the11 72 13 L4 15 L6 I1 1B L9 ZU 2t pJ-ant balances a book value of the reductlon of $356,745 to reflect the net Shared Eacilities conveyed to PGE. In addition, the Company is proposing to provide the Idaho jurisdictional portion of the gain associated with the sal-e of the Shared Facllities, or $251,071, to customers as part of the request in this case. This amount is refl-ected on the Conveyance of Shared Facilities Gain fine of Exhibj-t No. 1. O. Please describe the true-up associated wlth prior years' revenue coll-ections. 22 A Idaho Power proactively committed to tracking col-l-ecti-on23 the monthly deviations between forecast revenue 2 The Carty Generatinq Station j-s a new 44O-megawatt, natural gas- fired plant that was constructed next to the Boardman coal-fired p1ant. PGE owns and operates the facility whi-ch came online in JuIy 2016. LARKIN, DI Idaho Power 19 Company 1 2 3 At 5 6 1 B 9 and actual revenue coll-ection. The Company is proposing to lncl-ude an adjustment reflecting the true-up associated wlth amounts collected from June L, 2072, through September 30, 20L9, that is a result of actual Idaho jurlsdictional sales vol-umes that were higher than forecasted volumes over the same period. Order No. 32549 approved an incremental annual revenue requirement of $I,525,501 effective June l, 20L2, and Idaho Power adjusted base rates accordingly using forecasted annual sales of 13,172,433 megawatt-hours. The Company has compared actual- sales from June L, 20L2, through September 30, 20L9, to the forecasted used to establish rates in 2012. II What is the Company's quantification of the revenue coll-ections ?true-up associated with A. As can be prior years' 10 11 72 13 14 15 seen on Exhibit No. 2, at September 76 30, 2079, the total over collection associated wlth higher 11 safes volumes is $473,09'1. Idaho Power is proposing to add 1B thls over coll-ection to the updated incremental level-ized L9 revenue requirement effective January 7, 2020. The totaf 20 2t 22 O What is the true-up associated with the 23 l-evelized revenue requirement amounts collected in previous 24 years? over collection of $473,091 Pri-or Year Collections Iine is reflected on the True-Up of of Exhibit No. 1. LARKIN, DI Idaho Power 20 Company 25 1 Z 3 4 5 6 1 o 9 A As described earlier in my testimony, the updated annual with Boardman l-evelized revenue requirement associated is $38,922 lower than what the Company is currently collecting from customers, meaning customers will have paid $38,922 per year more than the updated l-evelized revenue requirement indicates the Company should have collected. The true-up is computed by converting the annual- incremental l-evelized revenue requirement of negative $38,922 to a monthly amount, or an over col-Iection of $3,244 per month, and multiplying it by the 91-month in previous years $1,058,255. 10 11 collection period from June I, 20L2, through December 31, 12 2079. The resul-t is a true-up of $295,158. This amount is 13 reflected on the True-Up of Levelized Revenue Requirement L4 line of Exhibit No. 1. 15 O. Pl-ease summarize the additional- adjustments L6 Idaho Power is proposing be added to the updated levelized 77 revenue requirement. 18 A. AtI three adjustments result in a refund to 79 customers. When added to the reduction of $38,922 in the 20 Idaho jurisdictional annual l-evelized revenue requirement, 27 the Shared Facil-ities gain of $251 ,0'17, the $473,091 in 22 over collection of prior years' revenues, and the $2951 158 of fevelized revenue requirement amounts resul-ts in a total refund to customers of 23 in over collection 24 25 LARKIN, DI Idaho Power 27 Company 1 2 3 4 5 6 1 9 VI. RECOMMENDED RATE}IAI(ING TREATMENT O. Why is the Company proposing a January L, 2020, effectj-ve date for the requested rate decrease? A. Idaho Power acknowl-edges the Company is requestlng a rel-atively expedited review of its request in thls case. However, while the reduction in the annual l-evelized revenue requj-rement resulting from updated costs is minimal, adding to it the gain associated with the sale of the Shared Eacilities and both true-ups associated with coll-ections of revenue requirement amounts since June 7, 2012, results in a customer refund of $1.06 million. The Company believes it is reasonable and appropriate to provide this refund to customers over Boardman's final- year of coal-fired operations, ensuring the appropriate matching of rate recovery wlth the useful life of the plant. In addition, Idaho Power has been keeping the Commission apprised of changes to the Boardman fevelized revenue requirement through the Company's Boardman Power Pl-ant Annual Review since the first report was filed in 10 11 72 13 74 15 76 71 1B 19 20 27 March 201-3 and annually thereafter 22 proposing that the request in this 23 Boardman Power Pl-ant Annual Review The Company is case suffice for the for 24 20L9, dS to not provide the Commission 25 the year endj-ng with duplicate LARK]N, DI Idaho Power 22 Company 1 Z 3 4 5 6 7 8 9 information already provided as part of Idaho Power's request 1n this case. O. How does the Company propose to al-l-ocate the decrease associated with Boardman Ievelized revenue requirement of $1,058,255 to each cl-ass of customers? A. The Company requests that the approximately $1.06 mi-11-ion associated with Boardman level-ized revenue requirement be refunded to all customer classes through a uniform percentage decrease to aII base rate components except the service charge.10 11 72 13 74 15 76 71 1B 19 20 27 )) z3 24 25 O. presents under the A. presents customer decrease $38 ,922, PGE, (3) Has the Company prepared a the revenue spread results for proposed aflocationCompany's Yes.Attachment No. 1 to schedule that each customer class methodol-ogy? the Application a summary of the class. VII. in the annual levelized revenue proposed revenue lmpact for each CONCLUSION a. Please summarize your testimony. A. Pursuant to the Boardman balancing account mechanj-sm approved with Order No. 32451, Idaho Power is proposing to reduce the collections associated with the Boardman levelized revenue requirement to refl-ect the (1) as sociated requirement of with an APA with(2) gain of $25I,01'l true-up of $473,091 1n over coll-ection of prior LARKIN, DI Idaho Power 23 Company L 2 3 4 5 6 1 B 9 v A years' revenues, and (4) over col-lection of $295,158 in previous years revenue requirement seeks approval of the adjustment of to rates effective date of January 1 to an overalf decrease of 0.09 percent amounts. Idaho Power negative $1.06 million , 2020, which equates Does this complete your testimony? Yes, it does. 10 11 t2 13 74 15 L6 11 1B 79 ZU 2t 22 23 24 LARK]N, DI Idaho Power 24 Company 25 1 2 3 4 5 6 1 8 9 ATTESTATION OF TESTIMONY STATE OF IDAHO SS. County of Ada 10 It Matthew T. Larkin, having been duly sworn to testlfy truthfully, and based upon my personal knowledge, state the following: I am employed by Idaho Power Company as the Revenue Requirement Senior Manager in the Regulatory Affairs Department and am competent to be a witness in this proceeding. f declare under penalty of perjury of the laws of the state of Idaho that the foregoing pre-filed testimony and exhibits are true and correct to the best of my information and belief. DATED this 17th day of October 20L9. 11 72 13 74 15 76 71 1B L9 20 2t Matthew T. Larkin 22 23 SUBSCRIBED AND SWORN to before me this 17th day of 24 October 20L9. 25 26 21 2B 29 o No ary Pub for Idaho Boise, IdahoResiding a My commission expires:72/20/2020 LARKIN, DI Idaho Power 25 Company KIMBERLY K. TOWELL coMMtsstoN #16958 NOTARY PUBLIC STATE OF IDAHO BEFORE THE IDAHO PUBLIG UTILITIES COMMISSION CASE NO. 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