20210315Goralski Direct.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-21-03
AUTHORITY TO IMPLEMENT FIXED COST )
ADJUSTMENT (“FCA”) RATES FOR )
ELECTRIC SERVICE FROM JUNE 1, )
2021, THROUGH MAY 31, 2022. )
)
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
PAWEL P. GORALSKI
GORALSKI, DI 1
Idaho Power Company
Q. Please state your name, business address, and 1
present position with Idaho Power Company (“Idaho Power” or 2
“Company”). 3
A. My name is Pawel P. Goralski and my business 4
address is 1221 West Idaho Street, Boise, Idaho 83702. I 5
am employed by Idaho Power as a Regulatory Consultant in 6
the Regulatory Affairs department. 7
Q. Please describe your educational background. 8
A. In May of 2007, I received a Bachelor of 9
Business Administration degree in Finance from Boise State 10
University in Boise, Idaho. I have also attended “The 11
Basics: Practical Regulatory Training for the Electric 12
Industry,” an electric utility ratemaking course offered 13
through the New Mexico State University’s Center for Public 14
Utilities, “Electric Utility Fundamentals and Insights,” an 15
electric utility course offered by Western Energy 16
Institute, and “Electric Rates Advanced Course,” an 17
electric utility ratemaking course offered through Edison 18
Electric Institute. 19
Q. Please describe your work experience with 20
Idaho Power. 21
A. In 2017, I was hired as a Regulatory Analyst 22
in the Company’s Regulatory Affairs Department, and in 2020 23
I was promoted to my current position of Regulatory 24
Consultant. My primary responsibilities include supporting 25
GORALSKI, DI 2
Idaho Power Company
the Company’s class cost-of-service activities, supporting 1
activities associated with demand-side management (“DSM”), 2
and I have been the Company’s witness supporting its annual 3
Fixed Cost Adjustment (“FCA”) calculation and corresponding 4
rates. 5
Q. What is the purpose of your testimony? 6
A. The purpose of my testimony is to describe the 7
Company’s request to implement its annual FCA rates in 8
conformance with Idaho Public Utilities Commission 9
(“Commission”) Order No. 32505 (Case No. IPC-E-11-19), 10
which approved the FCA as a permanent rate mechanism for 11
the Residential and Small General Service customers. The 12
Company is seeking authority to collect the 2020 FCA 13
deferral balance of $38,315,499 through its proposed 2021-14
2022 FCA rates, which is an increase of $2,816,643 from the 15
current FCA deferral balance of $35,498,856. This 16
represents a 0.38 percent increase over current authorized 17
billed revenue for the Residential and Small General 18
Service classes. 19
Q. How is your testimony organized? 20
A. My testimony will discuss four areas related 21
to the FCA mechanism and Schedule 54, Fixed Cost 22
Adjustment. First, I will discuss the need for the FCA 23
mechanism itself, and second, how the Company engaged with 24
Commission Staff (“Staff”) to address concerns raised in 25
GORALSKI, DI 3
Idaho Power Company
the 2019 FCA filing.1 Third, I will summarize the FCA 1
mechanism itself and how it is determined, including 2
determination of the 2020 FCA amount. Lastly, I will 3
discuss the calculation of the FCA rates the Company is 4
proposing to be effective June 1, 2021, through May 31, 5
2022. 6
I. BENEFIT OF FIXED COST ADJUSTMENT MECHANISM 7
Q. Why is the FCA mechanism necessary? 8
A. The existing two-part rate design for 9
Residential and Small General Service customers collects a 10
significant portion of the class’s fixed costs through the 11
volumetric energy rate. The FCA is a true-up mechanism 12
that “decouples,” or separates, billed energy sales from 13
revenue in order to remove the financial disincentive that 14
exists when the Company invests in DSM resources and 15
activities. Under the FCA, rates for Residential Service 16
(Schedules 1, 3, 4, 5, and 6) and Small General Service 17
(Schedule 7 and 8) customers are adjusted annually to 18
recover or refund the difference between the level of fixed 19
cost recovery authorized by the Commission in the Company’s 20
most recent general rate case and the level of fixed cost 21
recovery that the Company received based upon the actual 22
1 In the Matter of the Application of Idaho Power Company for Authority
to Implement Fixed Cost Adjustment (“FCA”) Rates for Electric Service
from June 1, 2020, through May 31, 2021, Case No. IPC-E-20-14, filed
March 13, 2020.
GORALSKI, DI 4
Idaho Power Company
billed energy sales during the previous calendar year. 1
Q. Is the FCA mechanism effective? 2
A. Yes. The existence of the FCA has limited the 3
financial disincentive that would otherwise exist for the 4
Company to invest in DSM resources and energy efficiency 5
activities for the Residential and Small General Service 6
classes. The mechanism has produced the intended result -- 7
on a cumulative basis since the Company’s 2011 general rate 8
case (2012 through 2020), Idaho Power has achieved claimed 9
Idaho Residential energy efficiency savings totaling 10
approximately 430,000 megawatt-hours (“MWh”). That energy 11
savings achievement demonstrates Idaho Power’s ongoing 12
commitment to energy efficiency over this time period, an 13
expectation of the Commission when it approved the FCA as a 14
permanent mechanism in 2012.215
Q. What level of incremental annual energy 16
efficiency savings was achieved in 2020? 17
A. Idaho Power achieved 196,809 megawatt-hours 18
(“MWh”) of savings system-wide, the second-highest savings 19
achievement since the implementation of the Energy 20
21
2 ln the Matter of the Application of Idaho Power Company for Authority
to Convert Schedule 54 - Fixed Cost Adjustment - from a Pilot Schedule
to an Ongoing Permanent Schedule, Case No. IPC-E-11-19, Order No. 32505
(March 20,2012).
GORALSKI, DI 5
Idaho Power Company
Efficiency Rider in 2002.3 This accomplishment was 1
significant, in light of DSM program modifications that 2
were necessary to prioritize customer, vendor, and employee 3
safety during the COVID-19 pandemic. The energy savings 4
claimed are enough energy to power approximately 17,000 5
average homes a year in Idaho Power’s service area. 6
Q. Do claimed DSM savings encompass the entirety 7
of energy savings occurring from Idaho Power’s DSM efforts? 8
A. No. The Company promotes significant customer 9
educational, outreach and awareness activities, promotion 10
of codes and standards, and marketing efforts that are not 11
quantified or claimed as part of Idaho Power’s annual DSM 12
savings, but are likely to result in energy savings 13
experienced by the customer and accruing to Idaho Power’s 14
electric system over time. 15
Q. Did the Commission recognize the potential for 16
unclaimed savings when the FCA was implemented? 17
A. Yes. In the Settlement Stipulation approved 18
by the Commission to establish the FCA,4 Idaho Power made 19
specific commitments in regard to supporting building code 20
improvements and enforcement of such standards, including 21
3 This value includes 180,818 MWh from Idaho Power-managed programs and
an estimated 15,991 MWh of energy efficiency market transformation
savings through Northwest Energy Efficiency Alliance (“NEEA”).
4 In the Matter of the Investigation of Financial Disincentives to
Investment in Energy Efficiency by Idaho Power Company, Case No. IPC-E-
04-15, Order No. 30267.
GORALSKI, DI 6
Idaho Power Company
promotion of Idaho new commercial and residential 1
construction and appliance standards, energy code training, 2
and advocation of enforcement of energy codes. Improved 3
building codes, construction and appliance standards, 4
energy code training and advocation result in savings that 5
are not quantified or claimed by the Company. 6
Q. What are some examples of the Company’s 2020 7
DSM activity for which savings are not quantified? 8
A. The Company’s Fall/Winter and Spring/Summer 9
Energy Efficiency Guides provide season-specific energy 10
efficiency tips such as sealing air leaks in homes, caring 11
for HVAC systems, adding insulation to the attic, replacing 12
furnace filters, using smaller appliances such as a 13
microwave instead of an oven, and information such as an 14
efficiency checklist for home buyers, weatherization 15
recommendations by home age, and a chart of energy savings 16
by upgrade cost for a variety of efficiency measures. 17
Figure 1 below included in the Spring/Summer 2020 Energy 18
Efficiency Guide highlights Idaho Power’s promotion of low 19
or no-cost behavioral changes or measure recommendations. 20
Promotion of these activities results in energy savings to 21
customers, but generally these activities are not incented 22
through the Company’s energy efficiency portfolio, which 23
means savings are not claimed through the Company’s DSM 24
programs. 25
GORALSKI, DI 7
Idaho Power Company
Figure 1 – Pyramid of Savings – Idaho Power Spring/Summer 1
2020 Energy Efficiency Guide 2
3
Idaho Power also frequently promotes energy 4
efficiency tips through social media, with approximately 18 5
percent of total 2020 social media content focused on 6
encouraging energy efficient behavior, program enrollment, 7
and customer engagement. In 2020, social media messaging 8
was modified to focus on sharing energy efficiency tips for 9
GORALSKI, DI 8
Idaho Power Company
customers spending more time at home, and how businesses 1
could save energy while operating with fewer employees, 2
reduced hours, or being closed altogether. 3
Idaho Power’s marketing, education, and outreach 4
efforts are more thoroughly detailed throughout the 2020 5
DSM Annual Report, filed on March 15, 2021, in Case No. 6
IPC-E-21-04. 7
Q. Has the FCA mechanism been effective at 8
removing the financial disincentive that would otherwise be 9
associated with Idaho Power pursuing all cost-effective 10
energy efficiency? 11
A. Yes. The FCA has been and continues to be an 12
effective mechanism that has positioned the Company to 13
continue to grow energy efficiency resources while 14
maintaining a reasonable opportunity to recover its fixed 15
cost of serving residential and small commercial customers. 16
II. STAKEHOLDER ENGAGEMENT IN 202117
Q. Did the Company meet with Staff in advance of 18
this filing? 19
A. Yes. As encouraged by the Commission, “in an 20
effort to collaborate and develop possible rate designs 21
that provide for the opportunity to recover Idaho Power’s 22
fixed costs,”5 the Company met with Staff on January 21, 23
2021, and again on March 1, 2021. 24
5 Case No. IPC-E-20-14, Order No. 34685, p. 2 (PDF p. 8).
GORALSKI, DI 9
Idaho Power Company
Q. Generally, what was the scope of those 1
discussions? 2
A. The Company and Staff discussed Staff’s 3
concerns with the FCA, as raised by Staff in previous 4
filings, and the Company’s position on each of the issues. 5
The Company and Staff also discussed developing 6
additional analysis that could be performed to better 7
understand and quantify the impact of rate design changes 8
on the FCA. 9
Q. Is the Company proposing any modifications to 10
the FCA mechanism in this case? 11
A. No. The Company believes modifications to the 12
FCA should not be considered in isolation, but rather in 13
coordination with an evaluation of rate design changes and 14
the impact that would have on customer bills, fixed cost 15
recovery, and the FCA. Rate design changes have 16
traditionally been addressed in a general rate case, which 17
is the appropriate venue to reset the Residential and Small 18
General Service Fixed Cost per Customer (“FCC”) and Fixed 19
Cost per Energy (“FCE”), allowing for changes in 20
consumption patterns for all customer classes to be 21
reflected through the Company’s cost-of-service analysis. 22
The FCA components, like all rates, are set at a point-in-23
time and the Company continues to believe the structure of 24
the mechanism and the components of it are most 25
GORALSKI, DI 10
Idaho Power Company
appropriately considered holistically when all rates are 1
reviewed. A rate case also provides opportunities to 2
address fixed cost recovery through rate design changes, 3
which likely reduce reliance on the FCA mechanism. As 4
stated previously, the FCA is necessary because the 5
existing two-part rate design for Residential and Small 6
General Service customers collects a significant portion of 7
the class’s fixed costs through the volumetric energy 8
rates. Idaho Power believes that modifications to the FCA 9
should be considered in coordination with an evaluation of 10
rate design changes. 11
Q. Does the Company have near-term plans to 12
evaluate the impact of modifying rate design on the FCA? 13
A. Yes. At the March 1, 2021 meeting, the 14
Company and Staff discussed a potential scope for further 15
studies that could be completed and presented to Staff, 16
other interested parties, and ultimately submitted to the 17
Commission. The Company proposes leveraging the Fixed Cost 18
Report accepted by the Commission in Case No. IPC-E-18-16 19
and conducting further studies to understand the impacts of 20
modifying rate design on the Company’s FCA mechanism. The 21
Company is committed to developing a strawman scope that 22
could be shared with Staff for their input in advance of 23
the Company performing additional analyses. 24
GORALSKI, DI 11
Idaho Power Company
Q. Does the Company believe its proposed plan to 1
complete additional studies related to fixed cost recovery 2
is consistent with the Commission’s directive from Order 3
No. 34685? 4
A. Yes. In its order, the Commission agreed with 5
the Company’s Reply Comments that “thoughtfully implemented 6
rate design” could reduce the Company’s reliance on a 7
mechanism like the FCA and believes such rate design could 8
alleviate the Commission’s concerns about the FCA’s 9
limitations.6 The Commission went on to state: 10
Based on the foregoing, the Commission 11
encourages the Company, Staff and any other 12
interested persons to expand prior efforts to 13
collaborate and develop possible rate designs 14
that provide the opportunity for the Company 15
to recover its fixed costs arising from the 16
provision of electric service to its 17
customers, while ensuring only just and 18
reasonable rates are being charged to 19
customers. The Commission looks forward to 20
reviewing such rate design proposals. 21
22
The Company believes that collaborating with Staff 23
and interested parties to develop additional studies is 24
consistent with the Commission’s directive. 25
III. FCA DETERMINATION FOR CALENDAR YEAR 202026
Q. Please describe the FCA mechanism components 27
and calculation. 28
6 Order No. 34685, p. 2 (PDF p. 7).
GORALSKI, DI 12
Idaho Power Company
A. For both the Residential and Small General 1
Service classes, the FCA mechanism is the same. The 2
formula used to determine the FCA amount is: 3
FCA = (CUST X FCC) – (ACTUAL X FCE) 4
Where: 5
FCA = Fixed Cost Adjustment; 6
CUST = Average Number of Customers, by class; 7
FCC = Fixed Cost per Customer rate, by class; 8
ACTUAL = Actual Billed kilowatt-hours (“kWh”) 9
Energy Sales, by class; and 10
FCE = Fixed Cost per Energy rate, by class. 11
The FCA amount is the difference between the Company’s 12
level of “authorized fixed cost recovery” (CUST X FCC) and 13
the level of “actual fixed cost recovery” (ACTUAL X FCE). 14
Q. Can the FCA deferral balance be either 15
positive or negative? 16
A. Yes. A positive FCA indicates the Company's 17
authorized level of fixed cost recovery is greater than the 18
level of fixed costs recovered through the energy rate, 19
which occurs when energy use per customer has decreased 20
from when the FCA components were established. In a 21
similar fashion, a negative FCA indicates the Company's 22
authorized fixed cost recovery amount is less than the 23
fixed costs determined to have been recovered through the 24
energy rate and results in a refund to customers. 25
GORALSKI, DI 13
Idaho Power Company
Q. Did the FCC and FCE rates used to determine 1
the 2020 FCA deferral balance change from prior years? 2
A. No. The FCC and FCE rates were established in 3
the Company’s most recent general rate case, Case No. IPC-4
E-11-08, and can be found in the Company’s tariff under 5
Schedule 54, Fixed Cost Adjustment. 6
Q. How is the authorized level of fixed cost 7
recovery derived? 8
A. The authorized level of fixed cost recovery is 9
the product of the FCC and the average number of customers, 10
by class. The Company uses a prorated customer count based 11
on the number of active utility service agreements at the 12
end of each month. This approach applies the same 13
methodology that was used to determine customer counts in 14
the Company’s most recent general rate case. The annual 15
average customer count is derived by calculating the 16
average of the 12 monthly prorated customer counts. 17
Q. How is the actual level of fixed cost recovery 18
determined? 19
A. In compliance with Order No. 33295, the actual 20
level of fixed cost recovery is the product of the FCE and 21
the actual billed energy sales for the calendar year, 22
measured in kWh. 23
Q. Does the Company compute a monthly FCA 24
deferral balance? 25
GORALSKI, DI 14
Idaho Power Company
A. Yes. Since 2009, the Company has reported the 1
estimated monthly FCA deferral balance in the monthly FCA 2
Report provided to the Commission. Exhibit No. 1 is a copy 3
of the monthly FCA Report for calendar year 2020 with year-4
end information. 5
Although the FCA is an annual mechanism that is 6
ultimately calculated and determined using customer counts 7
and billed energy sales data for the entire calendar year, 8
a monthly FCA deferral balance is estimated and recorded in 9
the Company’s accounting records to maintain compliance 10
with Generally Accepted Accounting Principles. This 11
estimated monthly FCA deferral balance is provided to the 12
Commission in the monthly FCA Report. 13
Q. Is it possible for the reported monthly FCA 14
deferral balance estimate to differ from the annual amount? 15
A. Yes. Because the monthly FCA deferral balance 16
is computed using monthly customer counts while the annual 17
FCA deferral balance is computed using the average customer 18
count for the year, the sum of the monthly calculations may 19
differ from the annual calculation. 20
Q. How is the reported monthly estimate adjusted 21
to align with the authorized annual amount? 22
A. At year-end, once the annual FCA amount is 23
determined, an adjustment is made to the sum of the 24
previously recorded 12 monthly estimates to align with the 25
GORALSKI, DI 15
Idaho Power Company
annual FCA deferral balance. Because the annual customer 1
count is the average of the 12 monthly customer counts, it 2
is not available until year-end. 3
Q. What adjustment was made to the 2020 monthly 4
estimates to translate to the Company’s single year-end 5
2020 FCA deferral balance? 6
A. To align with the annual FCA amount to be 7
recorded in the Company’s 2020 financial records, an upward 8
adjustment of $164,462 was made for the Residential 9
customer classes, reflected on line 6, column O of Exhibit 10
No. 1. An upward adjustment of $3,463 was made for the 11
Small General Service customer classes, reflected on line 12
20, column O of Exhibit No. 1. The total upward adjustment 13
for both customer classes is $167,925. 14
Q. What is the total amount of the FCA, not 15
including interest? 16
A. The total amount of the FCA for the 17
Residential and Small General Service customer classes, not 18
including interest, is $37,721,898. Exhibit No. 2 shows 19
the calculation of the FCA. The calculation of the FCA 20
uses the average annual customer count and the annual 21
billed sales amount, which are included in Exhibit No. 3. 22
The calculated FCA deferral balance for the Residential 23
customer classes, not including interest, is $36,135,835. 24
An amount of $36,135,836 is found in Exhibit No. 1, line 6, 25
GORALSKI, DI 16
Idaho Power Company
column P. The $1 difference between Exhibit No. 1 and 1
Exhibit No. 2 is due to rounding. 2
The calculated FCA deferral balance for the Small 3
General Service customer classes, not including interest, 4
is $1,586,063. This amount is also found in Exhibit No. 1, 5
line 20, column P. 6
Q. What is the total amount of the 2020 FCA, 7
including interest, the Company is requesting to implement 8
in rates on June 1, 2021? 9
A. The total amount of the 2020 FCA the Company 10
is requesting to begin recovering in rates on June 1, 2021, 11
is $38,315,498.92, reflected on line 32, column W, of 12
Exhibit No. 4. The FCA for the Residential classes is 13
$36,706,199.78 reflected on line 15, column W, of Exhibit 14
No. 4. The FCA for the Small General Service classes is 15
$1,609,299.14 reflected on line 29, column W, of Exhibit 16
No. 4. Exhibit No. 4 and Exhibit No. 1 both contain the 17
same information as the FCA Report sent to the Commission 18
each month; however, Exhibit No. 4 calculates interest from 19
January 2020 through May 2021 while Exhibit No. 1 shows 20
that information only for the 2020 calendar year. 21
Q. What is the significance of these numbers with 22
respect to the Company’s recovery of its fixed costs? 23
A. Because the Residential and Small General 24
Service FCAs are positive numbers, the average use per 25
GORALSKI, DI 17
Idaho Power Company
customer based on actual billed sales for the year were 1
lower than the level established in the Company’s most 2
recent general rate case for both Residential and Small 3
General Service customer classes. In accordance with the 4
approved mechanism, the Residential and Small General 5
Service classes will receive a rate adjustment to allow for 6
recovery of the fixed costs that were not recovered through 7
actual billed energy charges during the year. 8
IV. CALCULATION OF THE 2021-2022 FCA RATE 9
Q. Please describe the calculation of the FCA 10
rates the Company is proposing to go into effect on June 1, 11
2021. 12
A. The FCA rates the Company proposes to go into 13
effect on June 1, 2021, were calculated by taking the FCA 14
deferral balances for each of the customer classes 15
described above and dividing by the respective class energy 16
sales forecast for the June 1, 2021, through May 31, 2022, 17
time frame (“Test Year”). The forecasted June 1 through 18
May 31 time frame is the same period that has been used 19
historically and is also used for the Power Cost Adjustment 20
mechanism. 21
Q. What has the Company determined the forecast 22
energy sales to be for both the Residential and Small 23
General Service classes? 24
GORALSKI, DI 18
Idaho Power Company
A. The Company’s forecasted energy sales are 1
5,294,175,386 kWh for the Residential classes and 2
136,816,220 kWh for the Small General Service classes. The 3
forecasted energy sales are found in Exhibit No. 5. 4
Q. What are the corresponding FCA rates for the 5
Residential and Small General Service classes based on a 6
combined and equal FCA rate change, as defined in the 7
approved mechanism? 8
A. To recover the authorized level of fixed 9
costs, the FCA rate for the Residential classes would be 10
0.7008 cents per kWh and the corresponding rate for the 11
Small General Service classes would be 0.8864 cents per 12
kWh. The calculation of these rates is also found in 13
Exhibit No. 5. 14
In Order No. 32505, the Commission ordered that the 15
FCA deferral balance will continue to be recovered or 16
refunded equally between the Residential and Small General 17
Service customer classes. Order No. 32505 at 9. Because 18
the Residential and Small General Service classes reduced 19
their energy consumption per customer such that the Company 20
under-collected its authorized level of fixed costs as 21
established in Case No. IPC-E-11-08, each class requires a 22
rate surcharge. 23
GORALSKI, DI 19
Idaho Power Company
Q. What is the difference between the FCA 1
deferral balance currently in amortization and the proposed 2
FCA deferral balance to be collected through the FCA rate? 3
A. In this filing, the Company is proposing to 4
collect rates based on an FCA deferral balance of 5
$38,315,498.92 which is $2,816,643 more than the current 6
FCA deferral balance of $35,498,856. The current deferral 7
balance was approved in Order No. 34685, issued in Case No. 8
IPC-E-20-14, with rates based on that balance effective for 9
the period June 1, 2020, through May 31, 2021. 10
Q. Including the current FCA rates in effect, 11
what is the percentage change in billed revenue as measured 12
from total billed amounts currently recovered from 13
Residential and Small General Service classes? 14
A. The Company proposes to collect the resulting 15
increase of $2,816,643 in the FCA rates effective June 1, 16
2021, through May 31, 2022. This would represent an annual 17
increase of 0.38 percent from current billed revenue for 18
the affected customer classes. The percentage change in 19
billed revenue is found in Exhibit No. 6. This proposed 20
increase results in an approximate $0.37 increase to the 21
monthly bill of a typical residential customer using 950 22
kWh per month. 23
GORALSKI, DI 20
Idaho Power Company
Q. How will the Company incorporate the FCA 1
surcharges for the Residential and Small General Service 2
classes on customers’ bills? 3
A. The Company proposes to continue including the 4
FCA with the Fixed Cost Adjustment line item on Residential 5
and Small General Service customers’ bills. 6
V. CONCLUSION 7
Q. Has Idaho Power met the Commission’s directive 8
from the 2019 FCA filing? 9
A. Yes. As encouraged by the Commission in the 10
2019 FCA filing, Idaho Power met with Staff in early 2021 11
to discuss Staff’s FCA concerns and development of 12
additional analysis that could be performed to better 13
understand and quantify the impact of rate design changes 14
to the FCA. The Company believes its proposed plan to 15
complete additional analysis is consistent with the 16
Commission’s directive to expand prior efforts to 17
collaborate and develop possible rate designs that provide 18
for fixed cost recovery. 19
Q. Please summarize the Company’s request in this 20
filing. 21
A. Idaho Power requests the Commission authorize 22
the Company to implement Fixed Cost Adjustment rates for 23
electric service from June 1, 2021, through May 31, 2022 in 24
the amount of 0.7008 cents per kWh for the Residential 25
GORALSKI, DI 21
Idaho Power Company
classes, and 0.8864 cents per kWh for the Small General 1
Service classes. 2
Q. Does this complete your testimony? 3
A. Yes, it does. 4
5
6
1 ATTESTATION OF TESTIMONY
2
3
4 STATE OF IDAHO )
5 ss
6 County of Ada )
7
8
9 I, Pawel P. Goralski, having been duly sworn to
10 testify truthfully, and based upon my personal knowledge,
11 state the following:
12 I am employed by Idaho Power Company as a Regulatory
13 Consultant and am competent to be a witness in this
14 proceeding.
15 I declare under penalty of perjury of the laws of
16 the state of Idaho that the foregoing pre-filed direct
17 testimony is true and correct to the best of my information
18 and belief.
19 DATED this 15th day of March 2021.
20
21
22
23
„CL C'tfrr °IL
Pawel P. Goralski
24 SUBSCRIBED AND SWORN to before me this 15th day of
25 March 2021.
26
27
28
29
30
CHRISTY LYN DAVENPORT
Notary Public - State of Idaho
0 Commission Number 52970
My Commission Expires Sep 10, 2026
dry ic for Idaho
Residing at Nampa, Idaho
My commission expires 9/10/2026
GORALSKI, DI 22
Idaho Power Company
BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-03

IDAHO POWER COMPANY

GORALSKI, DI

TESTIMONY

EXHIBIT 1
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A B C D E F G H I J
Fixed Cost Adjustment Monthly Report January February March April May June July August
for the year ended December 31, 2020
Residential FCA:
Beginning Balance $0.00 6,986,395.00 13,069,441.00 17,569,077.00 21,588,886.00 23,961,182.00 24,907,078.00 26,515,800.00
Amount Deferred $6,986,395.00 6,083,046.00 4,499,636.00 4,019,809.00 2,372,296.00 945,896.00 1,608,722.00 408,467.00
Ending Balance $6,986,395.00 13,069,441.00 17,569,077.00 21,588,886.00 23,961,182.00 24,907,078.00 26,515,800.00 26,924,267.00
Interest:
Accrual thru Prior Month $--11,646.32 33,433.08 62,720.73 98,709.40 138,652.69 180,172.79
Monthly Interest Rate (Annual 2%)0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%
Monthly Interest Inc/(Exp)$-11,646.32 21,786.76 29,287.65 35,988.67 39,943.29 41,520.10 44,201.84
Interest Accrued to date $-11,646.32 33,433.08 62,720.73 98,709.40 138,652.69 180,172.79 224,374.63
Total Residential FCA:6,986,395.00 13,081,087.32 17,602,510.08 21,651,606.73 24,059,891.40 25,045,730.69 26,695,972.79 27,148,641.63
Small General Service FCA:
Beginning Balance $-189,575.00 339,995.00 482,965.00 688,889.00 835,709.00 971,848.00 1,122,286.00
Amount Deferred $189,575.00 150,420.00 142,970.00 205,924.00 146,820.00 136,139.00 150,438.00 79,794.00
Ending Balance $189,575.00 339,995.00 482,965.00 688,889.00 835,709.00 971,848.00 1,122,286.00 1,202,080.00
Interest:
Accrual thru Prior Month $--316.02 882.79 1,687.89 2,836.27 4,229.40 5,849.47
Monthly Interest Rate (Annual 2%)0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%
Monthly Interest Inc/(Exp)$-316.02 566.77 805.10 1,148.38 1,393.13 1,620.07 1,870.85
Interest Accrued to date $-316.02 882.79 1,687.89 2,836.27 4,229.40 5,849.47 7,720.32
Total Small General Service FCA:189,575.00 340,311.02 483,847.79 690,576.89 838,545.27 976,077.40 1,128,135.47 1,209,800.32
Total Fixed Cost Adjustment $7,175,970.00 13,421,398.34 18,086,357.87 22,342,183.62 24,898,436.67 26,021,808.09 27,824,108.26 28,358,441.95
Entries:
599 X00001 999 182302 (254302)7,175,970.00 6,245,428.34 4,664,959.53 4,255,825.75 2,556,253.05 1,123,371.42 1,802,300.17 534,333.69
599 X00001 999 440301 (6,986,395.00)(6,083,046.00)(4,499,636.00)(4,019,809.00)(2,372,296.00)(945,896.00)(1,608,722.00)(408,467.00)
599 X00001 999 442301 (189,575.00)(150,420.00)(142,970.00)(205,924.00)(146,820.00)(136,139.00)(150,438.00)(79,794.00)
599 X00001 999 421006 (431013)-(11,962.34)(22,353.53)(30,092.75)(37,137.05)(41,336.42)(43,140.17)(46,072.69)
Exhibit No. 1
Case No. IPC-E-21-03
P. Goralski, IPC
Page 1 of 2
1234567891011121314151617181920212223242526272829303132
35363738394041
A B
Fixed Cost Adjustment Monthly Report
for the year ended December 31, 2020
Residential FCA:
Beginning Balance $
Amount Deferred $
Ending Balance $
Interest:
Accrual thru Prior Month $
Monthly Interest Rate (Annual 2%)
Monthly Interest Inc/(Exp)$
Interest Accrued to date $
Total Residential FCA:
Small General Service FCA:
Beginning Balance $
Amount Deferred $
Ending Balance $
Interest:
Accrual thru Prior Month $
Monthly Interest Rate (Annual 2%)
Monthly Interest Inc/(Exp)$
Interest Accrued to date $
Total Small General Service FCA:
Total Fixed Cost Adjustment $
Entries:
599 X00001 999 182302 (254302)
599 X00001 999 440301
599 X00001 999 442301
599 X00001 999 421006 (431013)
K L M N O P
September October November December Adjustment Current Year Total
26,924,267.00 27,331,973.00 30,139,457.00 32,870,894.00 35,971,374.00
407,706.00 2,807,484.00 2,731,437.00 3,100,480.00 164,462.00 36,135,836.00
27,331,973.00 30,139,457.00 32,870,894.00 35,971,374.00 36,135,836.00 36,135,836.00
224,374.63 269,257.38 314,819.78 365,062.25 -
0.1667%0.1667%0.1667%0.1667%0.1667%
44,882.75 45,562.40 50,242.47 54,795.78 -419,858.03
269,257.38 314,819.78 365,062.25 419,858.03 -419,858.03
27,601,230.38 30,454,276.78 33,235,956.25 36,391,232.03 36,135,836.00 36,555,694.03
1,202,080.00 1,276,864.00 1,395,251.00 1,470,659.00 1,582,600.00
74,784.00 118,387.00 75,408.00 111,941.00 3,463.00 1,586,063.00
1,276,864.00 1,395,251.00 1,470,659.00 1,582,600.00 1,586,063.00 1,586,063.00
7,720.32 9,724.19 11,852.72 14,178.60 -
0.1667%0.1667%0.1667%0.1667%0.1667%
2,003.87 2,128.53 2,325.88 2,451.59 -16,630.19
9,724.19 11,852.72 14,178.60 16,630.19 -16,630.19
1,286,588.19 1,407,103.72 1,484,837.60 1,599,230.19 1,586,063.00 1,602,693.19
28,887,818.57 31,861,380.50 34,720,793.85 37,990,462.22 37,721,899.00 38,158,387.22
529,376.62 2,973,561.93 2,859,413.35 3,269,668.37 167,925.00 38,158,387.22
(407,706.00)(2,807,484.00)(2,731,437.00)(3,100,480.00)(164,462.00)(36,135,836.00)
(74,784.00)(118,387.00)(75,408.00)(111,941.00)(3,463.00)(1,586,063.00)
(46,886.62)(47,690.93)(52,568.35)(57,247.37)-(436,488.22)
Exhibit No. 1
Case No. IPC-E-21-03
P. Goralski, IPC
Page 2 of 2
BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-03

IDAHO POWER COMPANY

GORALSKI, DI

TESTIMONY

EXHIBIT 2

2020 Annual Fixed Cost Adjustment Deferral Calculation
Residential
Customer Count 470,548.90
FCC $650.63
Authorized Recovery Amount $306,153,233
Billed Sales in kWh 5,232,692,498
FCE $0.051602
Actual Recovery Amount $270,017,398
Residential FCA $36,135,835
Small General Service
Customer Count 29,208.00
FCC $360.57
Authorized Recovery Amount $10,531,529
Billed Sales in kWh 130,337,688
FCE $0.068633
Actual Recovery Amount $8,945,467
Small General Service FCA $1,586,063
Total FCA $37,721,898
Exhibit No. 2
Case No. IPC-E-21-03
P. Goralski, IPC
Page 1 of 1
BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-03

IDAHO POWER COMPANY

GORALSKI, DI

TESTIMONY

EXHIBIT 3

Month Customer Count Billed Sales
January 464,734.44 541,604,613
February 465,079.27 495,361,159
March 466,254.15 443,339,789
April 467,584.96 382,277,791
May 468,441.19 332,390,749
June 470,034.63 362,287,213
July 470,843.94 416,033,165
August 472,104.87 523,496,886
September 473,264.12 465,939,779
October 474,752.61 341,457,607
November 476,091.81 393,775,908
December 477,400.84 534,727,839
470,548.90 5,232,692,498
Month Customer Count Billed Sales
January 29,013.77 12,933,325
February 28,854.27 12,218,693
March 29,182.35 11,088,983
April 28,968.39 9,156,097
May 29,033.32 8,326,702
June 29,531.62 9,335,939
July 29,134.91 10,404,376
August 29,323.53 12,254,381
September 29,297.54 11,814,181
October 29,359.25 9,842,242
November 29,354.01 10,308,449
December 29,443.06 12,654,320
29,208.00 130,337,688
2020 Monthly Customer Count and Billed Sales
Annual Average
Customer Count
Total Annual
Billed Sales
Annual Average
Customer Count
Total Annual
Billed Sales
Residential Customer Classes
Small General Service Customer Classes
Exhibit No. 3
Case No. IPC-E-21-03
P. Goralski, IPC
Page 1 of 1
BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-03

IDAHO POWER COMPANY

GORALSKI, DI

TESTIMONY

EXHIBIT 4

1234567891011121314151617181920212223242526272829303132
35363738394041
A B C D E F G H I J K L M
Fixed Cost Adjustment Monthly Report January February March April May June July August September October November
for the year ended December 31, 2020
Residential FCA:
Beginning Balance $0.00 6,986,395.00 13,069,441.00 17,569,077.00 21,588,886.00 23,961,182.00 24,907,078.00 26,515,800.00 26,924,267.00 27,331,973.00 30,139,457.00
Amount Deferred $6,986,395.00 6,083,046.00 4,499,636.00 4,019,809.00 2,372,296.00 945,896.00 1,608,722.00 408,467.00 407,706.00 2,807,484.00 2,731,437.00
Ending Balance $6,986,395.00 13,069,441.00 17,569,077.00 21,588,886.00 23,961,182.00 24,907,078.00 26,515,800.00 26,924,267.00 27,331,973.00 30,139,457.00 32,870,894.00
Interest:
Accrual thru Prior Month $--11,646.32 33,433.08 62,720.73 98,709.40 138,652.69 180,172.79 224,374.63 269,257.38 314,819.78
Monthly Interest Rate (Annual 2% for 2020, 1% for 2021)0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%
Monthly Interest Inc/(Exp)$-11,646.32 21,786.76 29,287.65 35,988.67 39,943.29 41,520.10 44,201.84 44,882.75 45,562.40 50,242.47
Interest Accrued to date $-11,646.32 33,433.08 62,720.73 98,709.40 138,652.69 180,172.79 224,374.63 269,257.38 314,819.78 365,062.25
Total Residential FCA:6,986,395.00 13,081,087.32 17,602,510.08 21,651,606.73 24,059,891.40 25,045,730.69 26,695,972.79 27,148,641.63 27,601,230.38 30,454,276.78 33,235,956.25
Small General Service FCA:Beginning Balance $-189,575.00 339,995.00 482,965.00 688,889.00 835,709.00 971,848.00 1,122,286.00 1,202,080.00 1,276,864.00 1,395,251.00
Amount Deferred $189,575.00 150,420.00 142,970.00 205,924.00 146,820.00 136,139.00 150,438.00 79,794.00 74,784.00 118,387.00 75,408.00
Ending Balance $189,575.00 339,995.00 482,965.00 688,889.00 835,709.00 971,848.00 1,122,286.00 1,202,080.00 1,276,864.00 1,395,251.00 1,470,659.00
Interest:
Accrual thru Prior Month $--316.02 882.79 1,687.89 2,836.27 4,229.40 5,849.47 7,720.32 9,724.19 11,852.72
Monthly Interest Rate (Annual 2% for 2020, 1% for 2021)0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%0.1667%
Monthly Interest Inc/(Exp)$-316.02 566.77 805.10 1,148.38 1,393.13 1,620.07 1,870.85 2,003.87 2,128.53 2,325.88
Interest Accrued to date $-316.02 882.79 1,687.89 2,836.27 4,229.40 5,849.47 7,720.32 9,724.19 11,852.72 14,178.60
Total Small General Service FCA:189,575.00 340,311.02 483,847.79 690,576.89 838,545.27 976,077.40 1,128,135.47 1,209,800.32 1,286,588.19 1,407,103.72 1,484,837.60
Total Fixed Cost Adjustment $7,175,970.00 13,421,398.34 18,086,357.87 22,342,183.62 24,898,436.67 26,021,808.09 27,824,108.26 28,358,441.95 28,887,818.57 31,861,380.50 34,720,793.85
Entries:
599 X00001 999 182302 (254302)7,175,970.00 6,245,428.34 4,664,959.53 4,255,825.75 2,556,253.05 1,123,371.42 1,802,300.17 534,333.69 529,376.62 2,973,561.93 2,859,413.35
599 X00001 999 440301 (6,986,395.00)(6,083,046.00)(4,499,636.00)(4,019,809.00)(2,372,296.00)(945,896.00)(1,608,722.00)(408,467.00)(407,706.00)(2,807,484.00)(2,731,437.00)
599 X00001 999 442301 (189,575.00)(150,420.00)(142,970.00)(205,924.00)(146,820.00)(136,139.00)(150,438.00)(79,794.00)(74,784.00)(118,387.00)(75,408.00)
599 X00001 999 421006 (431013)-(11,962.34)(22,353.53)(30,092.75)(37,137.05)(41,336.42)(43,140.17)(46,072.69)(46,886.62)(47,690.93)(52,568.35)
Exhibit No. 4
Case No. IPC-E-21-03
P. Goralski, IPC
Page 1 of 2
1234567891011121314151617181920212223242526272829303132
35363738394041
A B
Fixed Cost Adjustment Monthly Report
for the year ended December 31, 2020
Residential FCA:
Beginning Balance $
Amount Deferred $
Ending Balance $
Interest:
Accrual thru Prior Month $
Monthly Interest Rate (Annual 2% for 2020, 1% for 2021)
Monthly Interest Inc/(Exp)$
Interest Accrued to date $
Total Residential FCA:
Small General Service FCA:Beginning Balance $
Amount Deferred $
Ending Balance $
Interest:
Accrual thru Prior Month $
Monthly Interest Rate (Annual 2% for 2020, 1% for 2021)
Monthly Interest Inc/(Exp)$
Interest Accrued to date $
Total Small General Service FCA:
Total Fixed Cost Adjustment $
Entries:
599 X00001 999 182302 (254302)
599 X00001 999 440301
599 X00001 999 442301
599 X00001 999 421006 (431013)
N O P Q R S T U V W
December Adjustment Current Year Total January February March April May Grand Total
32,870,894.00 35,971,374.00 36,135,836.00 36,135,836.00 36,135,836.00 36,135,836.00 36,135,836.00
3,100,480.00 164,462.00 36,135,836.00 -----36,135,836.00
35,971,374.00 36,135,836.00 36,135,836.00 36,135,836.00 36,135,836.00 36,135,836.00 36,135,836.00 36,135,836.00
365,062.25 -419,858.03 449,959.18 480,060.33 510,161.48 540,262.63
0.1667%0.1667%0.0833%0.0833%0.0833%0.0833%0.0833%
54,795.78 -419,858.03 30,101.15 30,101.15 30,101.15 30,101.15 30,101.15 570,363.78
419,858.03 -419,858.03 449,959.18 480,060.33 510,161.48 540,262.63 570,363.78
36,391,232.03 36,135,836.00 36,555,694.03 36,585,795.18 36,615,896.33 36,645,997.48 36,676,098.63 36,706,199.78 36,706,199.78
1,470,659.00 1,582,600.00 1,586,063.00 1,586,063.00 1,586,063.00 1,586,063.00 1,586,063.00
111,941.00 3,463.00 1,586,063.00 -----1,586,063.00
1,582,600.00 1,586,063.00 1,586,063.00 1,586,063.00 1,586,063.00 1,586,063.00 1,586,063.00 1,586,063.00
14,178.60 -16,630.19 17,951.38 19,272.57 20,593.76 21,914.95
0.1667%0.1667%0.0833%0.0833%0.0833%0.0833%0.0833%
2,451.59 -16,630.19 1,321.19 1,321.19 1,321.19 1,321.19 1,321.19 23,236.14
16,630.19 -16,630.19 17,951.38 19,272.57 20,593.76 21,914.95 23,236.14
1,599,230.19 1,586,063.00 1,602,693.19 1,604,014.38 1,605,335.57 1,606,656.76 1,607,977.95 1,609,299.14 1,609,299.14
37,990,462.22 37,721,899.00 38,158,387.22 38,189,809.56 38,221,231.90 38,252,654.24 38,284,076.58 38,315,498.92 38,315,498.92
3,269,668.37 167,925.00 38,158,387.22 31,422.34 31,422.34 31,422.34 31,422.34 31,422.34
(3,100,480.00)(164,462.00)(36,135,836.00)-----
(111,941.00)(3,463.00)(1,586,063.00)-----
(57,247.37)-(436,488.22)(31,422.34)(31,422.34)(31,422.34)(31,422.34)(31,422.34)
Exhibit No. 4
Case No. IPC-E-21-03
P. Goralski, IPC
Page 2 of 2
BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-03

IDAHO POWER COMPANY

GORALSKI, DI

TESTIMONY

EXHIBIT 5

FCA Rate Determination
Target Normalized Base FCA Dollars Percent Diff
Combined Option - Different Rates FCA Dollars Energy Revenue Collected Over/Under from Base Rate
Residential $36,706,199.78 5,294,175,386 $478,513,325 $37,102,739.82 $396,540.04 7.75%0.007008
Small General Service $1,609,299.14 136,816,220 $15,640,931 $1,212,759.10 ($396,540.04)7.75%0.008864
Combined $38,315,498.92 5,430,991,606 $494,154,256 $38,315,498.92 $0.00 7.75%
Existing FCA Balance per Order No. 34685 $35,498,856
Proposed 2020 FCA Deferral Balance $38,315,499
FCA Annual Increase (Decrease)$2,816,643
Forecasted Base Rate Revenue $494,154,256
0.57%Annual FCA Difference Percentage of Base Rate Revenue
Exhibit No. 5
Case No. IPC-E-21-03
P. Goralski, IPC
Page 1 of 1
BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-03

IDAHO POWER COMPANY

GORALSKI, DI

TESTIMONY

EXHIBIT 6
Total Percent
Rate Average Normalized Current Adjustments Proposed Change
Line Sch.Number of Energy Billed Mills to Billed Total Billed Mills Billed to Billed
No Tariff Description No.Customers (1)(kWh) (1)Revenue Per kWh Revenue Revenue Per kWh Revenue
Uniform Tariff Rates:
1 Residential Service 1 473,382 5,218,521,002 $531,364,631 101.82 $2,014,349 $533,378,980 102.21 0.38%
2 Master Metered Mobile Home Park 3 21 4,323,473 $420,778 97.32 $1,669 $422,447 97.71 0.40%
3 Residential Service Energy Watch 4 0 0 $0 0.00 $0 $0 0.00 0.00%
4 Residential Service Time-of-Day 5 1,031 17,728,975 $1,741,847 98.25 $6,843 $1,748,690 98.63 0.39%
5 Residential Service On-Site Generation 6 9,689 53,601,936 $5,784,379 107.91 $20,690 $5,805,069 108.30 0.36%
484,123 5,294,175,386 $539,311,635 101.87 $2,043,552 $541,355,187 102.25 0.38%
6 Small General Service 7 29,751 136,618,976 $17,425,852 127.55 $65,987 $17,491,839 128.03 0.38%
7 Small General Service On-Site Generation 8 69 197,244 $26,936 136.56 $95 $27,031 137.05 0.35%
29,820 136,816,220 $17,452,788 127.56 $66,082 $17,518,870 128.05 0.38%
8 Total Residential and Small General Service 513,943 5,430,991,606 $556,764,423 102.52 $2,109,634 $558,874,057 102.90 0.38%
(1) June 01, 2021 - May 31, 2022 Forecasted Test Year (Spring 2021 Forecast)
Summary of Revenue Impact
Current Billed Revenue to Proposed Billed Revenue
Idaho Power Company
Calculation of Revenue Impact
State of Idaho
Fixed Cost Adjustment
Filed March 15, 2021
Exhibit No. 6
Case No. IPC-E-21-03
P. Goralski, IPC
Page 1 of 1