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HomeMy WebLinkAbout20210415Blackwell Direct.pdfBETORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF TTIE APPLICATION OT IDAI{O POIIER COMPANY FOR AUTITORITY TO IMPLEMENT POWER COST ADJUSTIIEN! ('.PCA") RATES rOR ELECTRIC SERVICE TROM JUNEL, 202L, TIIROUGH MAY 31, 2022. IDAHO POWER COMPANY Df,RECT TESTIMONY OF NICOLE A. BLACIffiELL CASE NO. rPC-E-21_-10 1 Q. Please state your name, business address, and 2 present position with Idaho Power Company ("Idaho Power" or 3 "Company"). 4 A. My name is Nicole A. Blackwell. My business 5 address is 122L West Idaho Street, Boise, Idaho 83702. T 6 am employed by ldaho Power as a Regulatory Consultant in 7 the Regulatory Affai-rs Department. 8 Q. Please describe your educational background. 9 A. In May of 20L0, I received Bachelor of Science 10 degrees in Finance and Economics from the University of 11 ldaho. I have also attended "The Basics: Practical !2 Regulatory Training for the Electric Industry, " an electric 13 utility ratemaking course offered through New Mexico State 1,4 University's Center for Public Util-ities, "E1ectric Utility 15 Fundamentals & Insightsr" an electric utility course t6 offered through the Western Energy Institute, and Edison L7 Electric Institute's "Electric Rates Advanced Course." l-8 O. Please describe your work experience with 19 Idaho Power. 20 A. In January 20t6, I was hired as a Regulatory 2L Analyst in Idaho Power's Regulatory Affairs Department, and 22 in 2021- I was promoted to my current posj-tion of Regulatory 23 Consultant. As a Regulatory Consultant, I provide support 24 for the Company's regulatory activities, including 25 compliance reporting, financial analysis, and the BLACKWELL, DI 1 Idaho Power Company l- development of revenue forecasts for regulatory filings. 2 Q. Vihat is the Company requesting in this case? 3 A. The Company j-s requesting approval- of its 4 2021,-2022 Power Cost Adjustment ("PCA") rates to become 5 effective June I, 2021. If approved, the 2021,-2022 PCA 6 will result i-n an increase in total billed revenue of 7 approximately $39.1 milIion, or 3.36 percent. 8 Q. How is your testimony organized? 9 A. My testimony consists of four sections. In the 10 first section, I provide an overvj-ew of the PCA. In the 11 second section, I detail the 2021,-2022 PCA amount in 12 comparison to last year's PCA amount, identify and discuss 13 the main factors contrj-buting to this change, and present 1,4 the quantification of th,e 2021-2022 PCA rates to become L5 effective June I, 2021. In the third section, I will t6 discuss the additional PCA component related to revenue sectJ-on, I detail the net customer1,7 sharJ-ng. impact of In the final the 2021-2022 PCA rates if approved as filedr.8 19 20 21, 22 I. O. What is the the mechanism functi-on? A. The PCA is a PCA OVER\IIETT purpose of the PCA and how does rate mechanism that quantifies 23 and tracks annual differences between actual Net Power 24 Supply Expenses (*NPSE") and the normalized or "base 1eveI" 25 of NPSE recovered in the Company's base rates, resulting in BLACKWELL, DI 2 Idaho Power Company l- a credit or surcharge that is updated annually on ,June 1. 2 The PCA mechanism uses a 12-month test period of April 3 through March ("PCA Year") and includes a forecast 4 component and a True-up component ("True-up"). The 5 forecast component represents the difference between the 6 Company's NPSE forecast from the March Operating Plan and 7 base level NPSE recovered in the Company's base rates. The I True-up component includes a backward-looking tracking of 9 differences between the prior PCA year's forecast and 10 actual NPSE incurred by the Company. The True-up contains 11 a second component that tracks the col-lection of the prior 12 year's True-up amount, referred to as the "True-up of the 13 True-up. " 14 With the exception of Public Utility Regulatory 15 Policies Act of L97B (*PURPA") expenses and demand response 16 incentive payments, the PCA allows the Company to pass L7 through to customers 95 percent of the annual- differences 18 in actual NPSE as compared with base 1eve1 NPSE, whether 19 positive or negative. With respect to PURPA expenses and 20 demand response incentive payments, as actual annual 2l expenses deviate from base level NPSE, the Company is 22 allowed to pass 100 percent of the difference for recovery 23 or credit through the PCA. The PCA is also the rate 24 mechanism used by the Company to provide customer benefits 25 resulting from the revenue sharing mechanism approved by BLACKWELL, DI 3 Idaho Power Company 2 3 4 5 6 7 8 9 1 the Idaho Public Utilities Commission ("Commission") in 11 Order No. 3407L. O. Does the revenue collected from customers through the annual PCA rate contribute toward the Company's net .income? A. No. The PCA mechanism provides for the annual collection or refund of net power supply cost differences between actual costs incurred by the Company and the base level NPSE component of base rates. Aside from the 95 percent to 5 percent sharing component I just described, the PCA provides for a one-for-one collection or refund of 1,2 actual net power supply expenses incurredr or to be to provide safe, reliable electric service tol-3 incurred, 15 customers. O. What are the components of the PCA base leve1 NPSE? A. The PCA base level NPSE includes the following FERC accounts: Account 501, Fuel (coal); Account 536, Water for Power; Account 547, Euel (gas); Account 555, Purchased Power; Account 565, Transmission of Electricity by Others; and Account 447, Sales for Resale (t1pica11y referred to as surplus sales). The PCA base level- expense component for FERC Account 555 includes costs of both PURPA and non-PURPA (market) purchases. Per Order No. 32426, the Company 1,6 1,7 1B 19 20 2L 22 l_0 1,4 23 24 BLACKWELL, DI 4 Idaho Power Company 25 1 2 3 4 5 6 7 I 9 adjusts FERC Account 555 to also include demand j-ncentive payments who participate in programs. that the Company provides to response customers 10 any of its three demand response :tI. 202L-2022 PC,A O. What is the total PCA collection that would result under the 2021,-2022 PCA rates proposed by the Company in this case? A. The 2021-2022 PCA rates would result in total PCA coll-ection of $109.3 mil1ion. This represents an increase in total bilIed revenue of $39.1 million for the upcoming year, an increase of 3.36 percent. O. Have you prepared a table that details the $39.1- million revenue impact by component? A. Yes. Table 1- presents a separation of the BLACKWELL, DI 5 Idaho Power Company 11 T2 13 1,4 15 1,6 $39.1- million j-ncrease into each component included in the L7 Company's proposed rates. 1B 1 2 3 4 5 5 7 I 9 Table I Revenue lmpact by Component Line No. Rate Component 202G2021PCAI 2021-2022PCA2 Difference 1 2 3 PCA Forecast PCA True-up s 113,084,63s 5(42,892,181) s L26,944,108 s (17,641,9s4) S 13,8s9,473 5 2s,2s0,227 PCATotal g 70,192,45s S 1o9,3oa$4 $ 39,1@,700 0. What are the maln factors driving the revenue change requested in this case? A. The increase in this year' s PCA is primarily attributed to a smaller credit to customers through the true-up component. This year's PCA true-up reflects a credit to customers of approximately $17.6 milIion, which is $25.3 mi-Ilion, or 59 percent, less than Last year's PCA true-up credit of $42.9 million. This year's lower true-up credit balance demonstrates that actual- power supply costs for the 2020-2021, PCA Year were more in line with forecast power supply costs included in last year's PCA forecast than the forecast-to-actuals variance from the 20L9-2020 PCA Year. As a result, the true-up credit is smaller than last year and is drj-ving an increase in the PCA. 1 Because Table 1 contains the expected b1IIed revenue impact to customers, the *2020-2021 PCA" column reflects approved 2020-2021 PCArates applied to the June 2021 through May 2022 sales forecast, and will not tie to the specific dol-l-ar amounts approved in the 2020 PCA filing. 2 The *2Q27-2022 PCA" column reflects the Company's proposed rates applied to the June 202L through Vlay 2022 forecast, and may not tj-e exactly to the figures listed in the Company's testimony due to the rounding of rates to six digits. BLACKWELL, DI 6 Idaho Power Company 10 11 1-2 13 14 15 L6 1 The increase in this year's PCA forecast component 2 is attributed to lower expected hydro qeneration and higher 3 market energy prices, which are resulting in increased 4 reliance on thermal generation and decreased market power 5 purchases. Additionally, this year's PCA forecast reflects 6 higher PURPA expense. These drivers will be discussed in 7 detail later in testimony. I A. PCA Forecast. 0 How is the PCA forecast amount determined?9 10 11 t2 13 1-4 15 16 L7 18 19 20 2t 22 A. As described previously, the PCA forecast component represents the difference between the Company's forecast of NPSE for the upcoming April - March test year and base 1evel NPSE recovered in the Company's base rates. O. What is the Company's determination of the system-1evel difference between currently approved base leve1 NPSE3 and the forecast of NPSE for the 202L-2022 PCA Year? A. The system-leve1 forecast of NPSE for the 202L-2022 PCA Year is $442t357,407, which is $136,672,538 higher than the currently approved base level NPSE of $305,684,859. Table 2 presents the system-Ieve1 differences between currently approved base level NPSE and the forecast of NPSE for the 202L-2022 PCA Year by FERC s fn the Matter of the Application of Idaho Power Company forAuthority to Establish a New Base Level- of Net Power Supply Expense, Case No. IPC-E-13-20, Order No. 33000 (March 21, 2074) . BLACKWELL, DI 7 Idaho Power Company 23 1 account. a What is the basis for the forecast of NPSE for the 202L-2022 PCA Year? A The forecast of NPSE for the 2027-2022 PCA Year is based on the Company's March 25, 2021, Operating Plan. a. How is the NPSE forecast developed for the Company's Operating Plan? A. The Operating Pl-an is prepared monthly and represents a forecast of the Company's monthly NPSE for the following 18-month period; however, for the PCA, the Company includes only the 12 months that correspond to the PCA Year. The Operating PIan is developed by simulating the dispatch of the Company's generation resources for each month, segmented by heavy Ioad and Iight load hours. The dispatch considers a current forecast of forward market 2 3 4 5 6 7 B 9 10 11 L2 l_3 L4 15 L6 BLACKWELL, DI 8 Idaho Power Company Table 2 2021-2022 PCA FORECAST (Tota! System) Line No.Base NPSE Forecast DifferenceFERC Account 1 2 3 4 5 5 95% Sharine Accounts Account 501, Coal Account 535, Water for Power Account 547, Other Fuel Account 555, Purchased Power Non-PURPA Account 555, 3rd Party Transmission Account t147, Surplus Sales S 108,503,180 S 2,380,597 S 33,3G7,5G3 S 62,606,593 S 5,455,955 S (s1,73s,1s3) s 118,562,796 ss os S 57,235,044 SS 748oo,s3o Ss 4853,909 s S Qs,842,22s1 S 10,059,616 (2,380,597) 23,857,48t L2,t93,937 (502,046) 25,892,928 7 8 100% Sharing Accounts Account 555, PURPA S Account 555, Demand Resoonse lncentives S 133,853,869 7L.2s2.26s S 205,133,741 SS 7.613.612 S 71,279,872 (3.638.5s3) 5 L60,s78/3s S 229,610,0s4 S Sg,O3r,arg 9 Total s 30s.684.859 s 442.3s7.407 s 136.672.s38 L7 1 energy prices, available hydro generation, coal and natural 2 gas prices, and any existing hedge transactions. The 3 system load forecast is then analyzed against the resulting 4 monthly heavy load and light load dispatch to determine a 5 monthly load and resource balance. Any identified resource 6 deficiency is assumed to be filled with market energy 7 purchases or natural gas to fuel the Langley Gulch power 8 plant ("Lang1ey Gulch"), based on economics and availabl-e 9 generating capacity at Langley Gulch. Economically 10 dispatched generation above the system load forecast 11 represents surplus energy sa1es. The forecast of monthly L2 NPSE and generation for the 202t-2022 PCA Year, as 13 determined in the Company's March 25, 2021,, Operating P1an, 1,4 is provided in Exhibit No. 1 . 15 O. How does the Company's forecast of system- t6 level NPSE for the 2021,-2022 PCA compare to the system- L7 leve1 forecast included in last year's PCA? 18 A. Table 3 compares this year's 2021,-2022 PCA 1,9 forecast of NPSE to last year's PCA forecast by FERC 20 account. As detailed in this table, the PCA forecast on a L}:e 202L-2022 PCA Year is2tfor 22 total system basis $442,357,407 , which forecast amount of is $1-5,452 ,686 higher than last year's $426, 904 ,7 2L . BLACKWELL, DI 9 Idaho Power Company 23 Tabh 3 PCA Forecast Comparison Expenses (Total Systeml Line No. 2020-202t Forecast 202,'-2022 ForecastFERC Account Difference 1 2 3 4 5 6 95% Sharine Accounts Account 501, Coal Account 535, Water for Power S Account547, Other Fuel S Account 555, Purchased Power Non-PURPA S Account 565, 3rd Party Transmission S Account 447, Surplus Sales S s 102,s34012 s t78,s62,796 5 L6,028,783 1,500,000 s 42,599,258 s 99,849,920 s 5,058,450 s (16,076,860) s 0s 57,235,044 s 74800,530 s 4853,909 s Qs,842,2251 s (1,500,000) L4,535,776 (15,049,389) (2O4,54tl. (9,75s,36s) 7 8 100% Sharine Accounts Account 555, PURPA Account 555, Demand Response lncentives s 225,464,790 s 229,510,054 5 4,145,264 s 193,826,319 5 205,L33,74L 5 77,307,422 s 7.513,612 s 7,6L3,5L2 s 9 Total PCA Forecast s 201,439,93L s 2L2,747,353 s t7,3O7,422 5 426,9o4,72L S M2,357,4o7 S rs,+sz,sgsl_ 2 3 4 5 6 7 8 9 a. What general conclusions can be drawn from the information contained in Table 3? A. When viewed by category, the 95 percent sharing accounts have increased approximately $4.1 mil-lion from last year's forecast, while the 100 percent sharing accounts have increased approximately $11-.3 million over last year's forecast. O. What factors are contributing to the major differences presented in Tab1e 3? A. Forecast expenses included in the 95 percent sharing accounts are expected to increase by 2 percent as compared to last year, from $225,464t'790 to $229,610,054. Due to a reduction in forecast hydro generation and higher forecast market energy prices, the Company expects to rely BLACKWELL, DI 10 Idaho Power Company 10 11 L2 13 1,4 15 1 more on thermal- generation to serve load and is expected to 2 decrease market power purchases. 3 Q. Please elaborate on the changes in the 95 4 percent sharing accounts for this year's forecast as 5 compared with last year's forecast. 6 A. In addition to lower forecast hydro 7 generati-on, which will be discussed in detail later, higher 8 forecast market energy prices are contributing to increased 9 generation at the Company's thermal plants. For Lhe 2021- 10 2022 PCA Year, forward market prices range from a 1ow of 11 10.35 per MWh to a high of $78.80 per MV0h compared to a Iow 12 of $4.85 per MWh and a high of $45.85 per MWh for last 13 year's PCA. As a result of higher market energy pri-ces, t4 thermal- generation becomes more economic, wherein the 15 average per-uni-t costs of natural gas and coal-fired 15 generation are $24.45 per MWh and $32.94 per MIatrh, t7 respectively. Accordingly, natural gas expense is expected 18 to increase 34 percent as compared to last year's forecast, 1,9 from $42,599,268 to $57,235,044, and coal fuel expense is 20 expected to increase 16 percent, from $102,534,012 to 2t $118,562,796. 22 The increase in forecast market energy prices is 23 also causing a $15r049,389 decrease in non-PURPA purchased 24 power, a 17 percent decrease from last year's forecast. includes market power BLACKWELL, DI 11 Idaho Power Company 25 Non-PURPA purchased power expense L purchases, as well as power purchase agreements ("PPAs"). 2 The decrease in forecast non-PURPA purchased power is 3 primarily related to market power purchases, whj-ch are 4 expected to decrease from $41,404,265 in last year's PCA 5 forecast to $24,654,472 in this year's PCA forecast, a 40 6 percent decrease. 7 The reduction in forecast hydro generation is also I resulting in lower surplus sales volumes. However, as a 9 result of higher market energy prices, surplus sales l-0 revenue is expected to increase 61 percent compared to last 11 year, from $L6,076,860 to 525,842,225. Eor the 2021,-2022 12 PCA Year, the average forecast market sales price is $34.25 13 per MWh compared with $15.14 last year, a 126 percent L4 i-ncrease. 15 Finally, this year's PCA forecast does not include L6 water lease expense whereas last year's PCA forecast 1,7 included $1.S mil-l-ion in water lease expense. The Company 18 does not anticipate procuring a water lease for this PCA L9 Year due to weaker snowpack conditions in the Upper Snake 20 basin and the decreased availability of water. 2l O. What factors are contributing to the change in 22 the 100 percent sharing accounts? 23 A. Forecast expenses included in the 100 percent 24 sharing accounts are expected to increase by 6 percent as 25 compared to last year, from $201,439,931 to $21,2,747,353. BLACKWELL, DI T2 Idaho Power Company 1 With regard to the 100 percent sharing accounts, forecast 2 PURPA costs increased by $11.3 million as compared to Iast 3 year's forecast, while forecast demand response incentive 4 payments did not change. 5 Q. Is the increase in forecast PURPA costs 6 related to increased generation output from PURPA projects? 7 A. In part. Table 4 details changes between last 8 year's PCA forecast and this year's PCA forecast with 9 respect to forecasted generation in MWh. As shown in Table 10 4, PURPA generation is anticipated to increase by 51r350 11 MWh, or less than 2 percent. The 6 percent increase in 12 PURPA expense is largely the result of price escalation in 13 PURPA contracts, whereby the average cost is $67.75 per L4 MWh. Table 4 PCA Forecast Comparison Generation ffotal System-Mwh) Line No.FERC Account 202G202t Forecast 202,-2022 Forecast Dlfference 1 2 3 4 Hydro 7,34L,7L7 6,590,890 (650,827) 95% Sharing Accounts Account 501, Coal Account 547, Other Fuel Account 555, Purchased Power Non-PURPA 2,972,154 1,973,546 2.@5,454 3,s99,2L9 2,34O,994 L.478.696 627,064 367,448 (616.758) 5 95% Sharing Accounts 74,382,811. 1.4,L09,799 (273,072l. 1fi)% Sharing Accounts Account 555, PURPA 2,976,554 3,027,905 51,3s0 6 1fi)% Accounts 2,976,554 3,027,905 51,350 (221.,72t!,Total Generation L7,359,425 L7,L37,704 7 95% Sharine Accounts Account 447, Surplus Sales L,O62,077 754,975 (307,102) 8 Total Load L6.297.348 L6.382.729 85,381 BLACKWELL, DI 13 Idaho Power Company 15 1 Q. What other general conclusions can be drawn 2 from the information in Tab1e 4? 3 A. Compared to last year's forecast, hydro 4 generation is expected to decrease 5501 827 MWh, or 9 5 percent. The decrease in hydro generation j-s driving a 5 decrease in surplus sales volumes of 30711-02 MWh, or 29 7 percent. As discussed previously, the decrease in forecast B hydro generation is also resulting in an increase in 9 thermal generation. Coal-fired generation is project.ed to l-0 increase 621,054 MWh compared to last year, or 21 percent, 11 while natural gas generation is expected to increase L2 3671448 MWh, or l-9 percent, compared to l-ast year. l-3 Additionally, non-PURPA purchased power is expected to L4 decrease by 6161758 MWh, or 29 percent. As discussed 1-5 earlier, higher forward market prices are contributing to L6 increased economic dispatch of the Company's thermal plants L7 for load service and reducing market power purchases. 18 a. What is causj-ng the decrease in expected hydro 19 generation of 650,827 MWh? 20 A. The decrease in expected hydro generation is 2! mainly due to lower projected inflows into Brownlee 22 reservoir. The March Operating Plan used in this year's 23 PCA forecast projects April through July inflows into 24 Brownlee of 4.2 million acre-feet ("MAE") as compared to 25 4.6 MAF used to determine last year's PCA forecast, a BLACKWELL, DI 1,4 Idaho Power Company 1 decrease of 9 percent. Expected lnflows into Brownlee were 2 higher for last year's PCA forecast as a result of better 3 snowpack conditions, which provide for sustained runoff and 4 increased hydro generation durj-ng the spring and summer 5 months. 5 Additionally, this year's PCA forecast reflects 7 weaker reservoir storage conditions, as compared to last B year's forecast. The March Operating Plan used in this 9 year's PCA demonstrates that available storage in the 11 10 reservoirs above Brownl-ee is 1-13 percent of normal and at 11 75 percent of capacity, compared to last year's 2020 March 12 Operating P1an, in which storage was 125 percent of normal 13 and at 82 percent of capacity. Together weaker snowpack t4 conditions and carryover as compared to the prior year are 15 resulting in the 9 percent reduction in forecast hydro 16 generation for the 2027-2022 PCA Year. 1,7 O. How are the forecasted NPSE differences 18 presented in Table 2 used to determine the 2021-2022 PCA 1,9 forecast component to be collected from Idaho customers? 20 A. The 202L-2022 PCA forecast component reflects 27 the Idaho jurisdictional share of the forecasted NPSE 22 differences presented in Table 2, adjusted for the PCA 23 sharing provisions. The Idaho jurisdictional share of the 24 forecast NPSE differences is determined by applying a ratio 25 of forecast firm Idaho jurlsdictional sales to forecast BLACKWELL, DI 15 Idaho Power Company t- 2 3 4 5 6 't I 9 fj-rm system-Ievel sales to the system-Ieve1 NPSE differences. l-0 O. $Ihat is firm sales and Idaho 2O2L-2022 PCA Year? A. For the forecast system-leve1 Idaho jurisdictional 95.41 percent of the A. What is the Company's forecast of system-level jurisdictional firm sales for the 2021-2022 PCA Year, Idaho Power has firm sales to be 15,131,418 Mlllh and firm sales to be 1,4,436,951 MWh, or system leveI. the Company's determination of the 11 202L-2022 PCA forecast component to be coll-ected from ldaho L2 customers? 13 A. Th,e 2021-2022 PCA forecast component to be L4 collected from Idaho customers is $126,939,705. Table 5 15 presents the determination of the 202L-2022 PCA forecast 1,6 component by individual PCA expense and revenue category. BLACKWELL, DI 76 Idaho Power Company 1 Table 5 2021-2022 PCA FORECAST Line No.FERC Account Difference from Difference After Base Sharing ldaho Allocation 1 2 3 4 5 6 95% Sharins Accounts Account 501, Coal Account 536, Water for Power Account 547, Other Fuel Account 555, Purchased Power Non-PURPA Account 555, 3rd Party Transmission Account 1147, Surplus Sales (From Table 1) S 10,059,G1G S s (2,380,597) s S 23,867,481 S S 12,193,937 Ss (602,046) ss 2s,892,928 s 9,555,635 12,26t,5671 22,674,L07 LL,584,240 157L,944!, 24,598,282 9,7L8,026 (2,L57,7711 27,633,463 Ll,052,574 (545,594) 23,469,327 s s s s s s 7 8 100% Sharine Accounts Account 555, PURPA S Account 555, Demand Response lncentives S s 69,031,319 s 65,579,753 5 62,569,925 68,008,433 (3,638,6s3) 71,279,872 s (3,538,5s3) s 7!,279,872 5 (3,638,5s3) s 9 Total s 136.672.s38 s L33,220.972 s 126.939.7052 3 4 5 6 1 B 9 B. |rrue-up and Erue-up of the trrue-up. a. What is this year's quantification of the True-up? A. The True-up portion of the PCA is detailed in the deferral expense report, attached hereto as Exhibit No. 2. This report compares actual NPSE amounts to actual power cost col-lections monthly, with the differences accumulated as a deferral balance. The balance at the end 11 of March 202L, with interest 10 as shown on row applied, was negati-ve 104 of Exhibit No. 2. The12 13 L4 15 $22,t56,186, approximate to customers O. accumulation negative $22.7 million represents a refund due in this year's PCA True-up. To what factors do you attribute the of the approximate negative $22.1, million16 BLACKV,IELL, DI L1 Idaho Power Company 11 deferral balance? 1 A. The approximate negative $22.1 million 2 deferral balance was largely driven by unpredictable 3 changes in market energy prices and the resulting variation 4 between forecast prices and actual prices. Because actual 5 market energy prices were higher than expected, it resulted 6 in higher than forecast surplus sales revenue and coal fuel 7 expense. The increase in market energy prices also 8 resulted in higher than forecast market power purchase 9 expense. Actual natural gas prices were also higher than 10 forecast driving an increase in natural gas fuel expense. l-1 Although actual market energy prices and natural gas prices L2 were higher than forecast, the Company's reliance on market 13 power purchases and natural gas generation did not decrease 1,4 as they were needed to serve load due to lower than 15 expected hydro generation. L6 0. P1ease eLaborate on the changes in actual l7 versus forecast generation and expense for the 2020-2021, l-8 PCA Year. L9 A. Last year's PCA forecast included an average 20 market sales price of $15.14 per MWh. The actual average 2L market sales price was $34.45 per MWh, a 128 percent 22 increase. As a result of the difference in forecast and 23 actual market sales prices, actual surplus sales volumes 24 were 77 percent higher than forecast and surplus sales BLACKWELL, DI ].8 Idaho Power Company l- revenue totaled $641583,553, which was 302 percent higher 2 than forecast surplus sales revenue of $L6,0761860. 3 Coal-fired generation totaled 3,794,008 MWh, which 4 was 28 percent higher than forecast, and actual coal fuel 5 expense uras $18.3 mi11ion, or 18 percent, higher than 6 forecast. Coal-fired generation was higher than forecast 7 due to the increase i-n market energy prices, making it more 8 economic for l-oad service and surplus sa1es. 9 The increase in market energy prices contributed to 10 higher than forecast purchased power expense. The actual 11 average market purchase price for the 2020-202t PCA year 72 was $30.45 per M[rIh, a 12 percent increase from the average 13 forecast price of $27.14 per MWh. Market power purchases t4 totaled 11 583,605 MWh, which was 4 percent higher than 15 forecast. As a result, market purchased power expense was 16 $48,225,1"68 compared to $41",404,266 included in the 17 forecast, reflecting a 16 percent increase. 18 Natural gas generation totaled 2,1,12,933 MWh for the L9 2020-2021 PCA Year, which was 139,387 MWh, or 7 percent, 20 higher than forecast. Due to natural gas prices being 21, higher than expected, actual natural gas expense totaled 22 $54,873,821, which was 29 percent higher than forecast. 23 Although actual market energy prj-ces and natural gas 24 prices were higher than forecast, the Company's reliance on 25 these resources increased, 4 percent and 7 percent, BLACKWELL, Dr 19 Idaho Power Company 1 respectively, as they were needed to meet l-oad due to the 2 reduction in hydro generation. Actual hydro generation for 3 the 2020-2021 PCA year was 6,786,206 MWh, which was 555,511 4 MWh, or 8 percent, less than forecast. 5 Fina11y, actual water for power expense was $480,000 6 compared to forecast expense of $1.5 mi11ion. Due to 7 weaker-than-expected hydrologic conditions in the Upper 8 Snake Basin last year and the resulting decrease in water 9 availability, the Company was not able to procure as much 10 leased water as expected. 11 O. P1ease explain the water lease the Company 12 entered into in 2020. 13 A. In 2020, Idaho Power entered into an agreement t4 to purchase rental poo1. price of $24 water from the Water District 1 supplemental 15 t6 1,7 shown on line 18 The agreement totaled 20r 000 acre-feet at a per acre foot for a total cost of $480,000r ds 26 of Exhibit No. 2. The water was delivered 19 20 21. 22 23 above American Fa1Is and flowed through Idaho Power's system, passing Milner Dam between September 15, 2020, and September 25, 2024, a. How did the water lease impact hydro generation? A. Based on the actual daily water flow, the Company estimated that hydro generation from the water BLACKWELL, DI 20 Idaho Power Company 24 1 2 3 4 5 6 7 B 9 lease totaled 20,756 MWh, resulting in a price of approximately $23.13 per MWh. Did the water l-ease expense and associateda increase in hydro generation benefit customers? A. Yes. Idaho Power was able to reduce market purchases during this time by using the leased water and running additional water through the Hells Canyon Complex. The purchase of leased water at $23.13 per MWh compared favorably with the average price paid for market purchases during the month, which was approximately $61.55 per MVilh. This additional hydro generation also contributed to Idaho Power's ability to sel1 into high-priced hours to the benefit of customers. The average price for market sales during the month was $55.98 per MWh, compared to the cost of the leased water at $23.13 per MWh, resulting in net revenue from surplus sa1es. A. Were there any items included in this year's True-up in addition to actual NPSE incurred during the April 2020 through March 202L period? A. Yes. Per Commission Order No. 34100, Idaho Power included its actual- costs of Western Energy Imbalance Market ("EfM") participation for April- 2020 through March 202L in the True-up. Benefits associated with EIM participation are embedded in actual NPSE experienced over that same period. BLACKWELL, DI 21. Idaho Power Company t-0 11 1,2 13 14 15 16 l7 r-8 1-9 20 21 22 23 24 25 1 Q. Please summarize the conditions of Order No. 2 341,00 as they pertain to EIM cost recovery through the 202t 3 PCA. 4 A. Per the terms of the settlement stipulation 5 ("EIM Stipulation") approved by Order No. 34100, Idaho 6 Power agreed to include an ElM-related monthly revenue 7 requirement in its monthly PCA deferral calculation based 8 on actual EIM participation costs commencing April L, 201"8. 9 The Company also agreed to apply a soft cap to ElM-related 10 revenue requirement included in the PCA deferral equal to 11 annual EIM benefits as reported by the California L2 Independent System Operator ("CAISO") for the corresponding 13 period. L4 O. Is the ElM-related revenue requirement 15 included in the April 2020 through March 2021, PCA deferral 16 under the soft cap of annual CAISO-reported benefits for L7 that same period? 18 A. Yes. Eor the April 2020 through March 2021 19 period, the EIM-rel-ated revenue requJ-rement totaled $3.2 20 mj-llion, while CAISO reported EIM benefits for Idaho Power 2L of approximately $21- million from April through December 22 (CAISO's first quarter 202L report has not yet been 23 published) . Therefore, the Company's EIM-related revenue 24 requirement is less than the soft cap agreed to in the EIM 25 Stipulation. BLACKWELL, DI 22 Idaho Power Company 1 2 3 4 5 6 7 I 9 a. Does Idaho Power believe the EIM has provided net benefits to customers since joining in April 20L8? A. Yes. While Idaho Power believes the CAISO benefit calculation overstates estimated benefits to Idaho Power's system, the Company believes customers have realized significant net benefits since the Company's entry into the EIM in April 20L8. As discussed in the Company's M,ay 24, 2OL9, Report of EIM Benefits and Costs of Participation, filed in Case No. IPC-E-16-1"9, Idaho Power has developed a more precise methodology for determining EIM benefits that uses inputs specific to the Company. Based on this methodology, the Company believes benefits achieved between April 2020 and December 2020 are approximately $14 million (benefits for the first quarter of 2021, are not yet available). This leve1 of EIM benefits compared to the ldaho-jurisdictional EIM costs of $3.2 milIion, demonstrates a net benefit to the Company and, ultimately, its customers. O. What is this year's True-up of the True-up? A. This year's True-up of the True-up balance i-s $4,5L9,61-4, as shown on row 124 of Exhibit No. 2. 0. What is the combined effect of the True-up and the True-up of the True-up in this year's PCA? A. The sum of the negatj-ve $22.1 million associated with the True-up and the $4.5 million associated BLACKWELL, DI 23 Idaho Power Company 10 11 t2 13 L4 15 1,6 L7 l_8 L9 20 2t 22 23 24 25 1 2 3 4 5 6 7 I 9 with the True-up of the True-up represents an approximate $17.6 mil-Iion credit to customers. 0. How does this year's combined True-up and the True-up of the True-up compare to last year's amount? A. The combined True-up and the True-up of the True-up for the last PCA Year was negative 542,648,447, ds compared with this year's amount of negative $17,637,772. While this year's true-up reflects a credit to customers, it is approximately 59 percent less than the credit customers are currently receiving through last year's true- up, and ultimately refl-ects an increase in billed revenue of $25 ,01.L,27 5 . C. PCA Rate Detenmination. O. How is the rate for the forecast portion of the PCA for April 2021 through March 2022 determined? A. The rate for the forecast portion of the PCA is equal to the sum of (1) 95 percent of the difference between the non-PURPA expenses quantified in the Operating Plan and those quantified in the Company's last approved update of NPSE, divided by the Company's forecast of system firm sales for June L, 2021,, throuqh May 31, 2022 ("System- leve1 SaIes Eorecast") i and (2) 100 percent of the difference between PURPA-related expenses quantified in the Operating PIan and those quantified in the Company's last approved update of NPSE, divided by the Company's System- BLACKWELL, D] 24 Idaho Power Company 10 11 L2 13 t4 15 t6 t7 18 1-9 20 2L 22 23 24 25 1 level Sa.l-es Eorecast; and (3) 100 percent of the difference 2 between the Idaho jurisdictional demand response incentive 3 payments quantified in the Operating PIan and those 4 quantified in the Company's last approved update of NPSE, 5 divided by the forecast of Idaho jurisdictional firm sales 6 for June L, 2021, through May 31, 2022. 7 Q. What is the rate for the forecast portion of 8 the PCA for April 202t through March 2022? 9 A. The rate for non-PURPA expenses is 0.4334 10 cents per kilowatt-hour ('kwh"), which is calculated by 11 multiplying 969,031,319 from Table 2 by 95 percent and then L2 dividing it by the System-Ieve1 Sales Eorecast of 13 l-5,131,418 MVih ( ($59,031,319 * 0.95) / 15,131 ,41,8) : L4 $4.334/lqwfr : 0.4334 cents/kWh) . The rate for PURPA 15 expenses is 0.47LL cents per kwh, which is calculated by 1.6 dividing $71.,279,8'72 from Table 2 by the 15,131,418 MVlIh t7 ($2t,279,872 / 15,131,418 MWh: $4.711lMWh :0.471,1 18 cents/klrilh) . The rate for demand response incentive 1,9 payments is a negative 0.0252 cents per k$ih, which is 20 calculated by dividing the negative $3,638,653 from Table 2 2t by the forecast of Idaho jurisdictional firm sales of 22 L4,436,951 MWh (-$3,638,653 / 14,436,951 MWh : -$0.252lUWrr 23 - -0.0252 cents/kwh) . The forecast portion of the PCA rate 24 is 0.8793 cents per klrlh, which is calculated by adding the 25 non-PURPA expense of 0.4334 cents per kV[h to the PURPA BLACKWELL, DI 25 Idaho Power Company 1 expense of 0.4711, cents per kWh to the demand response 2 incentive payment of negative 0.0252 cents per kwh (0.4334 3 + 0.4711 + -0.0252: 0.8793 cents/kwh). 4 Q. How did you compute this year's True-up rate? 5 A. As shown in Exhibit No. 2, this year's True-up 6 component of the PCA is approximately negative $22.1, 7 million, which, when divided by the Company's forecast of 8 Idaho jurisdictional sales of 14,436,951 Mt^trh, results in a 9 rate of negative 0.1535 cents per kWh (-$22,1,56,786 / 10 L4,435,951 : -$1.535/Mv[h = -0.1535 cents/kwh) . 11 The True-up of the True-up rate is calculated by 1,2 dividing $4,519,614 (also from Exhibit No. 2) by the 13 forecast of Idaho jurisdictional sales of 1,4,436,951 MWh, 14 which results j-n a rate of 0.0313 cents per kwh ($4,519,61,4 l-5 / tq,436,951 = $0.313/MWh : 0.0313 cents/kwh) . 16 O. What i-s the resulting PCA rate when you L7 combine all the PCA components described previously? 18 A. The uniform PCA rate comprises (1) the 0.8793 L9 cents per kWh for the 202L-2022 prolected power cost of 20 serving firm loads under the current PCA methodology and 95 2L percent sharing, (2\ the negative 0.1535 cents per kWh for 22 the 2020-2021 True-up portion of the PCA, and (3) the 23 0.0313 cents per kWh for the True-up of the True-up. The 24 sum of these three components is a 0.7511" cents per kwh 25 charge for all rate classes. BLACKWELL, DI 26 Idaho Power Company 1, 2 3 4 5 6 7 B 9 III. ADDIEIONAIJ PCA RATE ADJuSIIIIENES A. Revenue Sharinqt A. Ialhen was the originally established? A. The revenue revenue sharing mechanj-sm sharing mechanism was originally established in Case No. IPC-E-09-30 and approved in Order No. 30978, effective for the years 2009-201L. Since then, the revenue sharing mechanj-sm has been modified and extended three times.4 Most recently, the revenue sharing mechanism was extended indefinitely, with modifications, in Order No. 34071 in Case No. GNR-U-18-01. O. What are the provisions of the current revenue sharing mechanism? A. In Case No. GNR-U-18-01, the Company filed a motion to approve a settl-ement stipulation (*2018 Stipulation") extending the sharing mechanism indefinitely, with modifications. The Commission approved the 20LB Stipulation in Order No. 340'7L. Per the terms of the 2018 Stipulation, if the Company's actual year-end Return on Equity ("ROE") for the Idaho jurisdiction exceeds 10 percent, all amounts up to and incl-uding a 10.5 percent ROE will be shared between customers and the Company on an 80 percent and 20 percent basis, respectively, to be provided as a rate reduction to BLACKVIELL, Dr 27 Idaho Power Company 10 11 L2 13 t4 15 16 17 18 19 20 21, 22 23 24 a Order Nos. 32424, 33749 and 34071. 1 become effective at the time of the subsequent year's PCA. 2 Tf the Company's Idaho jurisdictional ROE exceeds 10.5 3 percent, al1 amounts in excess of 10.5 percent will be 4 shared 55 percent with Idaho customers as a rate reduction 5 to become effective with the subsequent year's PCA, 25 6 percent will be shared with Idaho customers in the form of 7 an offset to amounts in the Company's pension balancing 8 account, and 20 percent will be apportioned to the Company. 9 With regard to the amortization of Accumulated 10 Deferred fnvestment Tax Credits ("AD]TC"), the 20LB 11 Stipulation allows the Company to accelerate the L2 amortization of ADITC, in an amount up to $45 miIlion, to 13 achieve a maximum 9.4 percent Idaho jurisdictional ROE if 14 the Company's year-end actual results fall below that 15 amount for any year beginning ,January 1, 2020. Idaho Power 1,6 may use up to $25 million of additional amortization of t7 ADITC per year, provided the total, cumulative amount of 18 ADITC does not exceed 945 miIlion. Per the 20Lg t9 Stipulation, once the Company has fu11y amortized the $45 20 million of ADITC, revenue sharing will ceasel however, 2L Idaho Power may at any time request to replenish the total 22 amount of ADITC it is permitted to amortize, and if 23 approved by the Commission, revenue sharing would continue. 24 O. Did the revenue sharing mechanism result in 25 any action following the 2009-2019 fiscal years? BLACKWELL, DI 28 Idaho Power Company 1 2 3 4 5 6 7 8 A. Yes. The Company's earnings in each year from 20Lt through 20L5, as well as 2018, resulted in revenue sharing with customers totaling $L26.2 m11l-ion, either as a direct rate offset in the PCA or as an offset to amounts that would have otherwise been collected in rates. The Company's earnings Ln 2016, 20L7 and 2019 were below the revenue sharing threshold. These amounts are detailed in Table 6. 9 Table 6 2009-2018 Revenue Sharlnr Line No.Revenue Sharins Comoonent 2d)9.2011 2012-20,.4 201s-2019 1 2 3 4 5 6 7 Available ADITC For Use ROE Threshold 5G50 Sharing Threshold 75-25 Sharing Threshold Customer Benefits (S Millions): Reduction to Rates Offset to Pension Balancins Account S45 Million 9.5% 10.5% N/A S45 Million 9.5% 10.0% 10.5% S45 Million 10.0% N/A L0.o% izt.t S20.3 S22.8 s47.8 s8.2 s0.0 8 Total Sqt.t s70.6 S8.2 Sr2G.2 10 O. Did the Company's year-end 2020 financial 11 results warrant any action rel-ated to the existing sharing 72 agreement per the terms of the 201,8 Stipulation? 13 A. No. The Company's year-end 2020 financial 14 results yielded an actual- Idaho jurisdictional ROE of 9.98 15 percent, falling below the 10 percent ROE threshold for L6 revenue sharing, and thus resulting in no revenue sharing L'7 with customers. 18 O. Did the Company use the same methodology to L9 determine the ldaho jurisdictional 2020 year-end ROE that 20 was used in prior PCA filings? BLACKWELL, DI 29 Idaho Power Company 1 A. Yes. The methodology used to determine the 2 Company's Idaho jurisdictional 2020 year-end ROE is 3 consistent with the methodology used for the year-end ROE 4 determinations since the inception of the mechanism. 5 Q. Do you have an exhibit demonstrating the 5 application of this methodology? 7 A. Yes. Exhibit No. 3 provides a step-by-step 8 calculation of the Idaho jurisdictional ROE based on year- 9 end 2020 financial results utilizing the Commission- 10 approved methodology from previous PCA filings. 11 TV. ![ET CUSTOMER IMPACT 1,2 O. What is the revenue impact of the requested PCA rate when compared with PCA rates currently in effect? A. Attachment 2 Lo the Application filed contemporaneousl-y with my testimony provides a detailed description of the overall revenue impact of this filing on each customer cfass. As shown in Attachment 2, applying the requested PCA rates to expected customer sales for the .Tune 2021, through May 2022 test year results in a PCA increase of $39.1 million. 13 1,4 15 L7 18 16 19 20 21,0 A 22 includes 23 . Have you prepared a the proposed PCA rates? . Yes. Attachment 1 revised Schedule 55 that to the Application is a the proposed PCA rates in24 revised Schedule 55 and includes BLACKWELL, DI 30 Idaho Power Company 25 clean and legislative formats. 1 Q. Should the Commission approve the Company's 2 computation of the PCA rates? 3 A. Yes. The Commission should approve the 4 Company's computation of the PCA rates. The calculation of 5 the PCA rates follows the methodoloEy that was approved in 6 Order Nos. 30715, 33307, and 3407L. If approvedr the ZAZL- 7 2022 PCA will result ln an i-ncrease in total bilIed revenue I of approximately $39.1 mi11ion, or 3.36 percent. 9 O. Does this conclude your testlmony? 10 A. Yes, it does. BLACKWELL, DI 31 Idaho Power eompanli' l- DECLARAUON OF NICOLE A. BI.ACKrTELL 2 l, Nicole A. B1ackwe11, declare under penalty of 3 perjury under the laws of the state of ldaho: 4 1,. My name is Nicole A. Blackwell. I am 5 employed by Idaho Power Company as a Regulatory Consultant 6 in the Regulatory Affairs Department. 7 2. On behalf of Idaho Power, I present this 8 pre-filed direct testimony and Exhibit Nos. 1-3 in this 9 matter. L0 3. To the best of my knowledge, my pre-filed 11 direct testimony and exhibits are true and accurate. 1,2 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 Pub1ic 15 Utilities Commission and is subject to penalty for perjury. LG SIGNED this 15th day of April 202L, at Boise, Idaho. 77 18 Signed: BLACKWELL, Dr 32 Idaho Power Company e BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. 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IPC-E-21-10 IDAHO POWER COMPANY BLACKWELL, DI TEST!MONY EXHIBIT NO.2 (EXCEL SPREA DS H EEr ArS O ATTACH ED TO EMATL) -+-- rc I .fr ._fi L ....j]j]gE ...jg]@ ......@ ..j!@ .....@ ..jagsI ..j@ ..J4 --+--- YtuhdGb __f__ I _f- r!!,!! J Fffih:I. I ffi rc ..........l!@ .........110,06 ..-.re re-:ffi ..ffi ..ffi ffi -taa, --+-+--- ....je]4l=g BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION cAsE NO. IPC-E-21-10 IDAHO POWER COMPANY BLACKWELL, DI TESTIMONY EXHIBIT NO.3 (EXCEL SPREA DSH EEr AtS O ATTACH ED TO EMATL) IDAHO FOWERCOUPANY ADDMONAL INVESTTENT TAX CREDIT ANALYSIS For tho Twelvo lrlonths Ended December 31, 2020 .r.suffitrEsufrcr.. TOTAL COMINED ilTE BASE Td& lEIq 3,530,6i!8,329 D6!O 3,3U2,211,25A D&p, s5.8% p.llo-r 96.1% 05.896 96.094 03.3% 83.1% 98.s% 95.896 98.7* 08.7* Exhibit No.3 Case No. IPC-E-21-'10 N. Blackwell, IPC Page 1 of 1 lddbhbr!l {{ TOTAL AYSTEI S€ptmbd Allo€toBrRrtiog 1,116,558,S67 Olr6d Aslgn 't07,€0,555 05.6* 1 ,2U,O15 ,522 Dallo 780,058,586 155,52,{,06} 7,400,073 30,818.,t36 1,,l07,,155 $,137,7271 2,70l,,@8 25.476.127 0,2u,171 1.013,101.S€6 OPEMTING RffiNUES RfrAIL SES RMNUES (hlff.l R.v) OTHER OPERATING REVENUES TOTI OPEMTING REVENUES 800,037,053 132,A73,81 1.028.010.9r7 857,137,508 Di@tA$lgn '127,@0,415 95.696 w,137,923 1.1@.068.(x3 1 75,2d),99a 'l,3il4,t@,041 OPEUTING INCOME ADD: ERCO OPEilTING INCOME 227,451,415 6,24i,0e4 2.1,142,58 5,e62,E92 OPEilTING*ENSES EERATON A MNTEMNCE *ENSES DEPRECIATION EXPENSE ArcRTZATION OF LIMTED TERM PUNT TilESOTHER THAN INCOffi reGULATORY OEBfiSrcREOITS PROVISION FOR DEFERRED INCOre TreS INVESTMENT TU CREDIT ANUSTMEM FEOEru INCOME TilES STATE INCOME TreS TOTAL OPEilTING UPENSES @0,E54,801 121,712,62.1 5,775,5,10 25,044,411 970,127 5,327,100 1,702,32 '15.717,(E6 3,369,422 801,259,502 589,990,584 'r6,640I@ 5,535,0@ 24.106.170 E06,515 5,2,15,587 1,680,(x6 15.520,,170 3,315,556 702,955,355 05.'t* 05.8!a 06.016 93.3% 8i).'l* 08.5t6 05.8* 08.7!6 98.7* 9,ltrz.,ln 192.,314,7& 7,727,5't3 33,047,@3 1,332,529 (o,233,',t271 2,820.Eeg 24,2U,174 0,280258 1,064.r07.455 DSELOPMENT S NET INCOME RETURN ON ER{ND COMMN EOUfr OPEilTING INCilE BEFORE OTHER INCOME AND DEDUCTIONS ADO: AFUOC EOUITY ADD: OTHER INCOMEAND DEDUCTDNS INCOME SEFORE INTEREST CffiRGES LESS: INTEREST CURGS 233,89?,,r09 227,145,1@ 288,373,8@ 29,550,610 2,698,E67 274,874,9O7 28,320,008 2,@S,007 so.7* 95.8r,6 (L t0) e0.7% (L 33) 320,@32n a7,w,lg 300.80,r,9,(2 8i,,740,700 279,571,58 8,142,211 270,853,526 8,02't,381 224,50r'273 236,38ilrit6 218.202.O1A 95.5% 95.8* (L r0) 05.896 (11 0) 212,947,803 (144.9.4%) 228,5a0,q8 (La4.t09S) 2$,t67,0r8 (1,9. 10.5*) (14,467,s87) (Lii&113), (1-e.4%) 211,5A7,U9 2,250,*t2,110 0.,10* 95.5* NET NCOME 233,231,513 224,65237 e.e7%9.08J6 233,231,513 2,303,83/r,455 226,06,5237 2.26.1@.O27 ACTUI ER€ND RESULTS.SEFORE trC ADJUSTMENT ARNNGS ON COMMONST@K MMIDN EQUTTY AT ER END EARNINGS ONCOMMONSTOCK O O,E ROE aRNN6 ON COMrcN SIOC( @ i0 ROE aRNNGS ONCOMrcN STOCK Q to.S RG ACTUI BR€ND RESULTS.AFTER trC AUUSTMENT: IWESTMENT TAX CREOtr AUUSTMENT AA'USTEO EARNINGS ON COMM STOCK A().'USTED COMN EOW AT YEAR€NO ANUSTED RETURN ON ER{ND COIi'ON EOW F lDAllO RETURN Ot{ COllIoil EQUEY(Llm it6) <9.4% ADDTPML trC ADJUSTMENT (AnnusH) tr L g b n.g.h, hs 0; tr pdE, h.n mrhr ot Lg or t25.m,m 0 F [r^tlo RETURN Ot{ COIIox EQUITY (Um /la) >lor IDArc ARNN6 GREATER TUN TffiROEBW LESTMN 10.5%o (143-r-4ey(r-r0*) F IOAHO RETURT{ Ol{ COllIO]{ EQUrY(Lln. ia6) t10.5% INCREMENTAL IDAHO EARNINGS GRATERTHAN 1O.S% ROE 0 (14$r50y(1r0.5%) ,.. Ord.r ,3aorl : ROE M 10!b10.5% {USTilER SHARE. &9a (Rdffi b nE) ROE M 10!b10.5% 4ilPAW SURE. A% ROE g@Btun 10.5% (lnffidd)- CUSTOi/€:R SURE. S% (Rducbn b rc) ROE guufr.n 10.5% (lnffiobD - CUSTOER SURE - 25% (ffi b Pa$n b.bn€) ROE smgtun 10.5% (lffid) {OMPANY SURE. A% Afrs Td 0