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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OT IDAHO POWER
COMPANY' S APPLICATION EOR
AUTHORITY TO DECREASE ITS RATES
FOR ETECTRIC SERVICE TOR COSTS
ASSOCIATED WITH THE BOARDMAN
POWER PLANT.
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cAsE NO. rPC-E-20-32
IDAHO POWER COTI{PAI{Y
DIRECT TESTIMONY
OF
RYAN N. ADELMAN
1 Q. Please state your name and business address.
2 A. My name is Ryan Adel-man. My business address
3 is 1221 West Idaho Street, Boise, Idaho 83702.
4 Q. By whom are you employed and i-n what capacity?
5 A. I am employed by Idaho Power Company ("Idaho
6 Power" or "Company") as the Vice President of Power Supply.
7 Q. PLease describe your educational background.
8 A. I graduated in 7996 from the Unlversity of
9 ldaho, Moscow, Idaho, receiving a Bachelor of Science
10 Degree in Civil Engineering. I am a registered
1-1 professional engineer in the state of Idaho. In 2018, I
L2 earned a Master of Business Administration Degree through
13 Boise State Unlversity's Executive MBA program. In 2019, I
14 completed the Energy Executive Course through the
15 University of Idaho.
L6 O. Please describe your work experience with
1"7 f daho Power.
18 A. From 2004 to 2008, I was employed by Idaho
19 Power as an engineer in Power Production's Civil
20 Engineering Group. In 2008, I became an Engineering
2I Leader, initially responsible for the Langley Gul-ch power
22 plant project, and later for the Power Production Civil
23 Engineering Department. In 2015, I was promoted to Senior
24 Manager of the Projects Department where I managed the
25 Project Management and Cost and Controls group. In 2018, I
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1 led the Company's Southeast fdaho area as a RegJ-onal
2 Manager. In 2019, I was promoted to Vice President of
3 Transmj-ssion and Distributj-on Engineering and Construction,
4 l-ater renamed to Planni-ng, Englneering and Construction. In
5 2020, f transitioned to my current position, Vice President
6 of Power Supply, where my responsibilities include
7 supervj-sion over Idaho Power's jointly-owned coal assets,
8 load serving operations, and merchant activities.
9 Q. What is the purpose of your testimony in this
10 proceeding?
l-1 A. The purpose of my testimony is to describe the
72 Boardman power plant ("Boardman") investments made after
l-3 ,June L, 20L2, and the prudence of those investments.
14 0. Have you prepared any exhibits detailing the
15 investments made sj-nce June L, 20L2?
1-6 A. Yes. Exhibit No. 3 details Idaho Power's
!7 share of the investments made at Boardman between June L,
18 2A12, and June 30, 2020. Projects over $40,000 include a
l-9 project description and investment purpose classification
20 for environmental compliance, the safe and economic
2L operation of the plant, or for reLiability. Exhibit No. 4
22 presents the comparison of Boardman budgeted capital
23 investments and actual- capital j-nvestments at the plant
24 Ievel.
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I. BACKGROI'IID
O. P1ease describe the time period for which
Idaho Power is requesting prudence of Boardman investments.
A. In Case No. IPC-E-19-32, Idaho Power requested
a prudence determination on incrementa.l- Boardman
investments,
June L, 20L2,
established.
or those investments made at the plant after
when the Boardman bal-ancing account was
The Company's prudence reguest included
actual Boardman investments through December 31, 2018. The
Idaho Public Utllities Commission ("Commission") issued
Order No. 34519 in the case deferring a prudence
determination on the actual costs incurred since June L,
201,2, until a later filing to all-ow the Company additional
time to document the costs were prudently incurred. Idaho
Power's request for a prudence determination in this case
is for aII Boardman-related investments made during the
June 1, 2AL2, through June 30, 2020, time period.
0. Why is Idaho Power requesting a prudence
determination for investments made through June 30, 2020?
A. Cessation of Boardman coal--fired operations is
approaching and, as described in the testimony of Company
witness, Matthew T. Larkin, Idaho Power is proposing to
remove from customer rates the levelized revenue
requirement associated with all Boardman investments.
Therefore, a prudence determination on all- actual Boardman
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investments to-date is necessary.
rI. CAPITAT BTIDGET I}I\/OLVEMEIIII
O. As a 10 percent owner in the plant, is Idaho
Power involved 1n the decision-making process related to
capital investments?
A. Yes. As the plant operator, portland General
Electric (*PGE") manages the capital budget for Boardman.
However, the Company is and always has been actively
involved in the decision-making process in al-I matters
associated with Boardman capital investments. V(hile pGE,
as the operator, vets and analyzes the need for specific
capital replacements as they arise to continue reliabl_e and
safe operation of the plant, Idaho Power regularly
participates in discussions of the capital j-nvestment
forecast prepared by PGE, influencing the investments
ulti-mately made.
O. P1ease describe the Company, s participation in
the Boardman capital investment discussions.
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t9 A. There are two types of meetings in which
20 projected capital investments at Boardman are discussed:
27 Asset Management Plan ("AMP") meetings and Ownership
22 meetings.
AMP meetings23 generally occur on an annual basis and
24 are hel-d with PGE and Idaho Power personnel, and Boardman
staff, to discuss upcoming capital25 plant management and
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1 projects identified by PGE corporate and plant engineering
2 personnel. The intent of the meeting is for both Idaho
3 Power and PGE personnel- to ask questions of the plant
4 personnel, most often the subject matter experts, dnY
5 details surrounding the forecasted capital investments
6 j-ncluding the justification, timing and cost. The open
7 dialog between the partners and the plant personnel Ieads
8 to a refj-ned, cost-effective forecasted capital spend.
9 The Ownership meetings, which occur annually at a
l-0 minimum, also may include discussions of capital projects,
11" both actual and upcoming, though the agendas often cover a
12 broad range of Boardman-related topics and may not always
13 discuss the forecasted projects in great detail.
74 0. As a mj-nority owner, does Idaho Power have any
15 contractual rights to vote on items such as capital spend?
16 A. Yes. Under Section 3 of the Agreement for
L7 Construction, Ownership and Operation of the Number One
18 Boardman Station on Carty Reservoir dated October 15, L976,
19 as amended ("Boardman Agreement"), the Company may appoint
20 one member to the Operatlng Cornmittee who has the right to
21 vote Idaho Power's ownership share on matters such as
22 capital additions budgets. If a matter is disapproved by
23 Idaho Power, the Company will notify the Operating
24 Committee of such item, stati-ng the reason why and an
25 acceptable alternative. A Project Consultant is then
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appointed by PGE to determine if the capital investment is
consistent with Prudent Utility Practice. Idaho Power has
maintained a positive and constructive working relationship
with PGE and plant personnel, who have been open to
discussion of capital addition budgets, The Company has not
been required to exercise its contractual rights specific
to capital spend under the Boardman Agreement.
III. BC'ARDUEN INITESXT{E}ITS SINCE 2OI2
O. Have you identified the investments made at
Boardman during the ,Iune l, 2012, through ,June 30, 2020,
time perlod?
A. Yes. Exhibit No. 3 presents Idaho Power's
share of the investments made at Boardman between June !,
2012, and June 30, 2020. In addition, for those projects
over $40r000, the Company has included a project
description and investment purpose classification as
environmental compliance, the safe and economic operation
of the plant, ot reliability.
Environmental Coup].iance Inveatnents
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2L environmental
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23 Boardman since
24 compliance:
installat ion
(1)
June 7, 20L2,
SO2 controls
of a serdage lagoon liner. The
What investments have been made for
compliance since June l, 2AL2?
There have been two investments made at
that were for
modifications,
environmental
and (2)
first was a
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1 known investment in emissions controls that was required
2 even after the Environmental- Protection Agency (*EPA')
3 approved PGE's Boardman shut-down plan with coal-fired
4 operations to cease in 2020. Through the Best Available
5 Retrofit Technology ("BART") rulemaking process, the Oregon
6 Regional Haze State Implementation Plan ("Oregon RHSIP"),
7 and per the Oregon Department of Envj-ronmental Quality
B ("DEQ") Title V Operating permit and Acid Rain permit, SOz
9 emissions must be controlled and monitored. The
10 investments included the addition of a dry sorbent
11 i-njection system to control sulfur emissions from Boardman,
12 as required by BART and the Oregon RHSIP. At the time, SO2
13 emissions were approxJ-mately 0. 90 lblMMBtu on a 3O-boil-er
1,4 operating day rolling average, well above the emissions
15 limit of 0.40 Ib/MMBtu by JuIy 1, 2014, and 0.30 l-blMMBtu
16 by July 1, 2018.
1,7 O. l{as a dry sorbent injection system the only
18 option for controlling sulfur emissions?
19 A. No. Wet and dry scrubber systems are an
20 option, but they are more costly and could not be installed
2l in time to meet the July 1, 201,4, deadline. With a lower
22 capital cost and shorter design and installation period,
23 the dry sorbent injection system was the investment
24 selected to comply with BART.
25 0. What was the second project required for
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l- environmental compliance?
2 A. The second environmental compliance
3 investment was the installation of a sewage lagoon liner as
4 a result of the Water Pollution Control Facil-ities ("WPCF")
5 permit. The permit dictated that the onsite clay-lined
6 sewage lagoons would be evaluated and reconditioned as
7 necessary to continue service for Boardman. At the time
8 the permit was issued, two of the three sewage lagoons used
9 clay liners that were visually evaluated and determined to
10 required reconditioning or relining per the WPCF permj-t and
1-1 Oregon DEQ regulations. This project relined one of the
12 two clay-Iined ponds identified with a nevr synthetic Iiner
13 system.
14 O. Were any alternatives to the installation of a
15 synthetic liner system considered?
16 A. Yes. An alternative to the synthetic liner
tl system would have been the reconditioning of the existing
18 clay liner. This practice invol-ves temporarily removing
19 the clay liner and re-grading the material- to establish a
20 new impermeable 1ayer. Depending on the conditions,
2l additional clay may be required to achieve regulatory
22 requj-red permeability levels. Due to the level of testing
23 required to know for certain the reconditioning work
24 required, it is unknown what the cost of the reconditioned
25 clay Iiner would be. In addition, the Oregon DEQ
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2 lagoons. And fina11y, the synthetic Iiner reduces ongoing
3 maintenance work required to mitigate vegetation growth
4 that damages clay liners.
5 Q. How much have the environmental compliance
6 i-nvestments contributed to the additions at Boardman since
7 June L, 20L2?
8 A. At $2.8 million, the SO2 controls
9 modifications were Idaho Power's largest investment at
10 Boardman since June L, 2012. The sewage lagoon liner was
1l- approximately $41,000, for a total of $2,819,836 in
L2 environmental compliance investments.
13 Plant Operation Safety Investaents
L4 0. How many of the identified projects were
associated with the safe and economic operation of the
plant?
A. There hrere six projects associated with the
safe and/or economic operation of the plant, three specific
to the safety of plant personnel, and three specific to the
economic operation of the plant.
O. Please describe the projects specific to the
safety of plant personnel.
A. The first was associated with an evaluation
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that began in
the Boardman
2008 of the shop and warehouse space
crews for maintenance and the storage
used by
of large
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1 spare components on the turbine deck. With the new
2 environmental and emissions controls installation on the
3 horizon, it was determined the available work space in the
4 plant would become more limited as the area would fill with
5 more new components, requiring even more maintenance.
6 Inadequate shop and warehouse space carried a risk of
7 damaging spare parts due to contamination from maintenance
8 activities happening beside them while also leading to
9 inefficient work practices, potentially extending outages.
10 This safety i-nvestment, completed in 2013, totaled
11 approximately $210,000.
12 O. What were the additional- safety-related
13 investments?
L4 A. The remaining safety investments were
15 associated with the combination of two projects, the
t6 upgrade of the fire protection system and the installation
77 of a fire detection system, totaling approximately
18 $300,000. The existing system was installed when the plant
1,9 went commercj-al in 1980 and lacked several protective
20 functions. The hardwired panel had push buttons and
2l indicating lights and was no longer able to show a new
22 a1arm on the system if one already existed, decreasing the
23 operator's awareness of the status of the plant while also
24 requlring a series of manual actions. When evaluating the
25 system, it was also determined fire detection sensors on
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the generator step-up transformers needed to be replaced
and connected to the fire detection system.
0. Why were the fire detection sensors
disconnected from the fire detection system?
A. The transformer deluge system was having
sensor failure problems and had been removed from the
automatic operation because it was causing the plant to
increased risktrip. This put the main transformer at an
if a fire were to occur while also potentj-ally slowing the
response time to extinguish a fire. At the time of the
evaluation, it was determined the replacement cost for the
loss of the transformer alone was over $3 million.
O. Did the evaluation of the fire protection and
fire detection systems identify any additj-onal issues of
concern?
A. Yes. An oil fire risk assessment was
performed on all flammable lubricating and control oil
systems to identify potential release scenarios, sources of
large leaks, and determine the specific conditions
necessary that would permit the safe shutdown of lube oiI,
seal- oil and control- oil systems. Because of the
complexity of piping systems, the assessment was the only
way to fu1ly understand all potential leak points and
identify the potential for an oil-fed fire. The assessment
determined that not only did certain areas of the plant
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have inadequate, aging fire protection, some areas had no
fire protection at al-l. The result was investments in both
the fire protection and fire detection systems.
Econonic Plant Operation Investnents
O. What were the projects specific to the
economic operation of the plant?
A. There were three projects associated with the
economic operation of the plant: two involved the water
treatment system for Boardman, and the third was the
purchase of a pulverizer gear box.
O. Pl-ease describe the water treatment system.
A. The water treatment system is composed of
three sub-systems: the polisher, the demineralizer, and the
raw water. Each sub-system is partially automated, but
they did not communicate with each other, posing logistic
challenges for maj-ntenance upkeep.
O. What is the importance of the water treatment
system?
A. Steam generators require very high purity
water to produce high purity steam to protect turbines from
deposition and corrosion affects. The water treatment
system has four interrelated functions that start with the
raw water system that fil-ters and chlorinates water from
the Carty reservoir to make it suitable for
demineralization. The resul-t is filtered water which is
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1 used j-n the demineralization system where it is deionized
2 to make it suitable for condensate makeup to the boiler.
3 Once the water is demineralized, it j-s tested by the
4 laboratory to ensure it is suitable for makeup to the
5 condensate system. If the water passes testing, it is then
6 transferred to the condensate storage tank where it is
7 further demineralized by a condensate polisher system at
I which point it is then ready for the steam generator.
9 Q. What work was done that resulted in additional
10 investments in the water treatment system?
11 A. The first project since June L, 20t2,
L2 associated with the water treatment system for Boardman
13 automated the three sub-systems allowing them to
L4 communi-cate flows and available storage tank vol-umes to
15 each other. Each of the three systems has its own
1,6 treatment phase, where the water is conditj-oned,
L'l regenerated, and prepared for another treatment. This
l-8 cleaning process generates a waste product that must be
19 contained in the lined evaporatlon ponds while also
20 producing a high volume of rinse water suitable for reuse.
2t The reusable rinse water, between 1 - 1.5 million gallons
22 per month, is no longer sent to the evaporation pond now
23 that the three sub-systems communicate with each other,
24 reducing the evaporation rate of the ponds. In addition,
25 the investment reduced maj-ntenance and capital j-nventory
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1- requirements for the sub-systems.
2 Q. What was the second project involving the
3 water treatment system?
4 A. The second investment was the installation of
5 water recovery from the demineralizing system. The
6 demineralizj-ng system recovers over 250,000 gallons of
7 water each month in the process. Prior to the water
B recovery installation, the used water went to the sump and
9 eventually the evaporation pond.
10 0. How does the water recovery system benefit the
1l- plant ?
L2 A. The project involved the instal-lation of two
13 pumps with piping and valves to recover the demineral-j_zed
14 water used in polisher transfers. This allows for the
15 recirculation of the water back into the demineralizing
l-6 water system, reducing the volume sent to the evaporation
17 pond.
18 A. Were any alternatives to the water treatment
19 system considered?
2A A. Yes. The plant coul-d have continued to use
2l the exi-sting system at higher maintenance costs, increasing
22 approximately 15 percent each year, until 2015, dt which
23 time a mandatory upgrade would have been required. In
24 addition, in 2014, it was expected an additj_onal lined
25 evaporation pond wouLd become necessary too, Et an
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1 estimated cost of $500r000. In addition, because the water
2 has already had its organic constituents removed,
3 processing and chemical costs were reduced. The investment
4 in the water recovery system was the }owest cost
5 alternative. The Company's share of the investment costs
6 of the two water treatment system projects was
7 approximately $100,000.
I Q. What was the third project specific to the
9 economic operation of the plant?
10 A. The final project associated with the economic
11 operation of the plant, at a cost of approximateJ-y $48,000
L2 to Tdaho Power, invo1ved the purchase of two used
13 pulverizer gear boxes to facilltate the fabrication of a
14 single like-new spare gearbox. This gearbox was then
15 placed into service to allow for maintenance on the aging
16 gearboxes that were in service at the time. In total,
L] $665,838 has been spent on the safe and economic operation
18 of the plant since 'June L, 2412.
l-9 Pla,nt Reliabilitv Invegtments
20 O. How many of the projects identified were
associated with reliability?
A. Two of the 16 projects over $401000 were
investments in rel-iability and an additionaf six projects
were a combination of reliability and safety investments.
The largest single investment made since ,June l, 20L2, was
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1 the result of a water hammer, or hydraulic shock, event in
2 July 2013. The event caused the col-d reheat pipe supports
3 to break, dropping the piping and creating structural
4 damage. Boardman went into a forced outage, eliminating
5 the immediate safety hazard, so that t.he col-d reheat pipe
6 could be replaced and realigned. The plant was insured for
7 an event of such magnitude and insurance proceeds helped
8 reduce Idaho Power's share of this project to a cost of
9 approximately $200,000. The next required reliability
10 investment was associated with the upgrade of the control-
11 system of the ash handling system.
L2 A. What is an ash handling system?
13 A. The ash handling system transfers coal ash,
L4 the residual from burning coal that includes solid
15 materials, away from boilers for disposal. ReguJ-ations are
16 in place for the safe and efficient transfer and the
L7 systems vary for the different coal ash residuals. The
18 Boardman ash handling system controls three systems: the
19 fIy ash handling system, the bottom ash handling system,
20 and the economizer ash handling system.
21, The existlng Boardman control system had been
22 running the ash handling system for over 30 years, and was
23 the original- plant equipment. The equipment had been
24 discontinued by the manufacturer and spare parts on the
25 market were limited. Because this system removes all the
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l- ash produced by the boiler and precipitator and stores it
2 safeJ-y, it can be detrimental to plant operations if a
3 failure occurs. This project upgraded the input/output,
4 logic controllers and communication in the ash handling
5 system.
6 Q. Please describe the projects that were a
7 combination of reliability and safety investments.
8 A. The projects that were a combination of
9 reliability and safety investments involved the replacement
10 of variable speed drives and control room chillers and the
1l- purchase of miscellaneous pumps, valves, and motors. The
L2 largest of the investments was the replacement of variable
13 speed drives. Boardman's four induced draft fans, which
L4 are 31500 horse power each, have variable speed drives to
15 control furnace draft, allowing the motor to run at a
16 slower speed, increasing energy efficiency. The existing
11 variabre speed drives were aging and becoming increasingly
18 unieliabl-e. In addition, spare parts were no longer
19 availabre from the manufacturer. within six months, the
20 plant experienced two separate fairures of the variab]e
2L speed drives, reducing Boardman, s capability while also
22 creating a safety hazard. As a result, two of the four
23 varlab1e speed drives were replaced in 2013, and the
24 remaining two in 2074, for a total- reliability and safety
25 investment of approximately $340,000.
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1 Q. Were any alternatives to the variabl-e speed
2 drives considered?
3 A. Yes, it is possible to run the fans without
4 the variable speed drives however, an energy efficiency
5 savings resulting from the variable speed drive would be
6 lost and the cost to reconfigure the fans was estimated to
7 be approximately $200,000.
I Q. What was the purpose for the replacement of
9 the control room chillers?
10 A. In 2013, the chillers that provide cooling for
11 the control room and the cable spreading room tripped. The
L2 chj-Ilers were old and mechanical parts were no longer
13 available. The plant personnel were keeping the chillers
14 operating on maintenance creativity for several years,
15 cobbling together parts. There hras concern if they tripped
15 again, they would no Ionger be repairable. In addition,
L7 the chillers were using a refrigerant that is no longer
l-8 made in the United States, maklng it more difficult and
19 costly to obtain.
20 0. What happens if the chillers are not in
2L working order?
22 A. If the chillers failed, the control room would
23 be unhabitable in the hotter months, creating a safety
24 issue for plant personnel. In the cable spreading room,
25 which must be kept below certain temperatures, a chiller
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failure could cause the plant to trip due to the loss of
the distributed control system, creating a reliability
issue. The control .room chiller replacement was $61r235.
0. Were there any other investments associated
with a combination of reliability and safety?
A. Yes. 7n 2012, 2AL4, and 20L6, the Company
invested 940,448, $42,062, and $54r838, respectively, in
miscellaneous pumps, valves and motors, necessary to
maintain functionality, reliability and the safety of the
plant. The projects are referred to as blanket projects
and are intended to capture unexpected failures at the
p1ant.
O. Why are they referred to as blanket projects?
A. Bl-anket projects were created as the plant was
nearing its end-of-Iife when specific capital projects were
no longer occurring as often and, therefore, forecasted
spend was minimal. The blanket project identification is
intended to capture capital issues that arise, typically
equipment fail-ures, at which time the plant wlll assign a
new budget identification and work order for the capital
investment. With these three blanket projects, the total
investment in projects associated with a combination of
reliability and safety investments was $542t"182.
Eorecaet to Aatua1 Investoent Conparison
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You indicated Exhibit No. 4 presents a
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1- comparison of Boardman budgeted capital investments and
2 actual capital investments. What is the purpose of the
3 comparj-son of forecast and acLual investments?
4 A. fn Case No. IPC-E-19-32. in their prudence
5 review, Commission Staff reguested a comparison of the
6 actual- investments by project as detailed in the Company's
7 records with the budgeted investments included as part of
8 PGE' s forecast for Boardman. The information was not
9 readily available for Staff's review because of
10 difficulties compiling the data and, therefore, there was
l-1 insufficient time to review this detail in that case.
L2 0. Why was it difficult to prepare the
13 compari-son?
lA A. As part of the Boardman Annual Reviews filed
15 with the Commission pursuant to Order Nos. 32457 and 32549,
16 the Company presented the capital budget by project for
L7 Boardman over its remaining life, as prepared by PGE. The
l-8 resul-ts of this budget were used to estimate the levelized
l-9 revenue requirement assocj-ated with incremental investments
20 made after June 1, 2012. Each year, Idaho Power updated the
2l incremental investments to include actuals through year-end
22 and revised forecasted investments for the remaining life
23 of Boardman using the latest budget from the pIant.
24 Forecast information from PGE was utilized because it
25 reflected the most accurate and readily-availabl-e
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lnformation at the time the Boardman Annual Reviews were
prepared.
However, because the budget information was prepared
by PGE, both the Aflowance for Funds Used During
Construction and overhead rates differ from Idaho Power's,
and the timing at which the costs are incurred varied as
Idaho Power records the investment when billed, or with a
one-month Iag, resulting in differing in-service dates of
the projects between the partners. As a result, comparing
actual project spend recorded by the Company to forecasted
project spend provided in the Boardman Annual Reviews did
not result in a conslstent comparison from whlch budget*to-
actuals variances cou.l-d be determined on a project-by-
project basis.
To remedy this issue and assist in Commission
Staff's review, Idaho Power requested from PGE the total
plant l-evel actual capital addition spend by project for
Lhe 2012 through 20L9 time period. The Company added to
this data the capital budget by project as previously
reported in the Boardman Annual Reviews and computed the
variance between the two. The detail is presented in
Exhibit No. 4.
O. You indicated Idaho Power updated the budget
in the Boardman Annual Review filings with the most recent
capital forecast from the p1ant. What budget amounts is the
ADELMAN, DI 2I
Idaho Power Company
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1 Company presenting in Exhibit No. 4?
2 A. Exhibit No. 4 presents the budget contained in
3 the Boardman Annual Review from the prior year, e.g. the
4 2074 budget amounts presented were included in the 2013
5 Boardman Annual Review as the forecast of investments for
6 20]-4.
7 Q. Were there any other complexities with
B preparing the comparison?
9 A. Yes. Another complexity is associated with
10 the difficulty forecasting capital additions at a plant
11 nearing its end-of-Iife. Because the plant reduced capital
t2 spend to include only that required for environmental
13 compliance or to maintain reliability or safety for only
l-4 eight more years, the budget often did not identify
15 specific capital projects. As a resuLt, Idaho Power has
L6 separated the actual to budget. comparison in three
L7 categories within Exhibit No. 4: (1) planned projects, l2l
18 blanket projects, and (3) unplanned projects.
79 0. Pl-ease describe the categories for which the
20 Company has presented the project level detail-.
2L A. Planned projects are those projects for which
22 the plant anticipated and budgeted. Bl-anket projects, as I
23 described earlier in my testimony, were created as the
24 plant was nearing its end-of-Ilfe when specific capital
25 projects were no longer occurring as often. The blanket
ADELMAN, DI
Idaho Power
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Company
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)tr,
project identification is intended to capture capital
issues that arise, typically equipment failures, at which
time the prant will assign a new budget identification and
work order for the capital i-nvestment. These new budget
identifications and work orders appear in the unplanned
projects section of Exhibit No. 4.
A. How do the actuals compare to the budget of
the planned projects?
A. In total, the actual costs of the planned
projects are one percent lower than the budgeted costs for
the same planned projects. Of all projects combJ_ned,
actual costs were six percent higher than budgeted.
However, because of the complexi-tles I discussed, this
budget comparison simpry reflects the variance between the
plant's forecast for the fofrowing year and what actuarly
occurred; it is not a comparison to amounts the Company is
currentl-y recovering in rates. Therefore, it is also
important to review the rdaho power-speciflc actual- to
forecast comparison included in the Boardman leverized
revenue requirement computation, as discussed in Mr.
l,arkj-n's testimony.
0. Ilfhy is the Idaho power-speclfic actual to
forecast comparison incl-uded in the Boardman levelj-zed
revenue requirement computation valuable?
A. At the time the Boardman balancing account was
ADELMAN, DI
Idaho Power
23
Company
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established, the levelized revenue requl-rement associated
with incremental investments included forecasted capital
additions of approximately $8.01 mi11ion. As shown in
Exhibit No. 1 to Mr. Larkj-n's testimony, the most recent
Ievelized revenue requirement computation includes only
$4.99 mlIlion of lnvestments made at Boardman since June l,
2012. The Company has discussed the comparison of actual-
investments to forecasted investments in each of its Annual
Reports noting that since establ-ishment, in only one year
has the actual level- of investments exceeded that
forecasted when the balancing account commenced and it was
simply due the timing of the project completion, as the
project did not close to Idaho Power's records prior to
year-end.
0. Please summarize your testimony.
A. Idaho Power has been required to make
investments at Boardman during the June l, 2012, through
June 30, 2020, time period, and has been actively involved
in the capital spend decision making process at the plant.
Of the 16 projects identified in which Idaho Power's share
of the investments was more t.han $40r000, two projects
totaling $2r8L9,836 were for environmental compliance, six
totaling $665r 838 were for the safe and economic operation
of the p1ant, two totaling 9283,655 were for rel-iability
purposes, and six totaling $542,182 were for a combination
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ADELMAN, D]
Idaho Power
24
Company
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of reliability and safety. AI1 investments addressed in
this filing were prudent and in the public interest.
O. Does this conclude your testimony?
A. Yes.
10
t-1
L2
L3
ADELMAN, DI 25
Idaho Power Company
1 DECT,ARJMION OE RTA}I N. TDEIT(AN
2 I, Ryan N. AdeJ-man, declare under penalty of perjury
3 under the laws of the state of ldaho:
4 1. My name is Ryan N. Adelman. I am employed
5 by ldaho Power Company as the Vj-ce President of power
6 Supply.
1 2. On behalf of Idaho Power, I present this
8 pre-filed direct testimony and Exhibit Nos. 3-4 in this
9 matter.
10 3. To the best of my knowledge, my pre-filed
1l- direct testimony and exhibits are true and accurate.
LZ I hereby declare that the above statement is true to
13 the best of my knowledge and belief, and that I understand
L4 it is made for use as evidence before the Idaho public
15 Utilities Commission and is subject to penalty for perjury.
L6 SIGNED this 21st day of August 2020, at Boise, Idaho.
17
18 Signed:
l-9
ADELMAN, DI 26
Idaho Power Company
1 DECI.ARAIITIfi OE RITN N. TDEIT'TII
2 7, Ryan N. Adelman, declare under penalty of perjury
3 under the laws of the state of fdaho:
4 l. My name is Ryan N. Adelman. I am employed
5 by Idaho Power Company as the Viee Presj-dent. of Power
6 Supply.
7
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2. On behalf of Idaho Power, I present this
pre-fi1ed direct testimony and Exhibit Nos. 3-4 in this
matter.
3. To the best of my knowledge, my pre-filed
direct testimony and exhibits are true and abcurate.
f hereby declare that the above statement is true to
the best of my knowledge and belief, and that f understand
it is made for use as evidence before the Idaho Public
Utilities Commission and is subject to penalty for perjury.
SIGNED this 21st day of August 2020, at Boise, ldaho.
Signed:
ADELMAN, Dr 26
Idaho Power Company
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
GASE NO. IPG.E.2O.32
IDAHO POWERGOMPANY
ADELMAN, DI
TESTIMONY
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GASE NO. IPC-E-20-32
IDAHO POWER COMPANY
ADELMAN, DI
TESTIMONY
EXHIBIT NO.4
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