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HomeMy WebLinkAbout20220415Brady Direct.pdfBEFORE TflE IDAIIO PUBLIC UTILITIES COMMISSION IN THE MATTER Otr" THE APPLICATION OF IDAHO POWER COMPANY EOR AUTHORITY TO IMPLEMENT POWER COST AD.IUSTMENT (.PCA") RATES FOR ELECTRIC SERVTCE FROM 'JUNEtt 2022, TIIROUGH MAY 31, 2423. IDAHO POTIER COMPANY DIRECT TESTIMONY 'JESSICA G. BRADY cAsE NO. IP3-E-22-1,L ) ) ) ) ) ) ) OF 1 2 3 4 5 6 7 8 9 O. PLease state your name, business address, and present position with Idaho Power Company ("Idaho Power" or ttCompany" ) . A. My name is ,Jessica G. Brady. My business address is L221 West Idaho Street, Boise, Idaho 83702. I am employed by Idaho Power as a Regulatory Analyst in the Regulatory Affairs Department. A. Please describe your educational background. A. In May of 2016, I received a Bachelor of Science degree in Economj-cs and a Bachel-or of Arts degree in Spanish from the University of Idaho. I have also attended "Electric Utility Fundamentals & InsighLs," an electric utility course offered through the Western Energy Institute. a. Please describe your work experience. A. In September 202L, I was hired as a Regulatory Analyst in Idaho Power's Regulatory Affairs Department. As a Regulatory Analyst, I provide support for the Company's regulatory activities, including compliance reporting, financial analysis, and the development of revenue forecasts for regulatory filings. I am also responsible for the Company's power cost filings in both Idaho and Oregon. Prior to Idaho Power, I worked for fj-ve years at Clearwater Analytics, a provider of investment accounting and reportlng software. I hel-d various roles at Clearwater BRADY, Idaho 10 11 1,2 13 L4 15 t6 t7 1B t9 20 2L 22 23 24 DI Power 1 Company 25 l- 2 3 4 5 6 7 B 9 Analytics but was pri-marily focused on customer success and relationship management. f gained a breadth of knowledge in investments and the use of proprietary software to streamline the operations of a company's finance and accounti-ng teams. I spent my last year at Clearwater developing a training program focused on providing new hires with the technical skiIIs to be successful in an operations role. O. What is the Company requesting in this case? A. The Company is requesting approval of its 2022-2023 Power Cost Adjustment (*PCA") rates to become effective ,June t, 2022. If approved, the 2022-2023 PCA will result in an increase in total billed revenue of approximately $103.4 million, or 8.27 percent. A. How is your testimony organized? A. My testimony consists of four sections. In the first section, I provide an overview of the PCA. In the second section, I detail the 2022-2023 PCA amount in comparison to last year's PCA amount, identify and discuss the main factors contributing to this change, and present the quantification of the 2022-2023 PCA rates to become effective June t, 2022. fn the third section, I discuss the additional PCA component related to revenue sharing. In the final section, I detail the net customer impact of the 2022-2023 PCA rates if approved as fil-ed. BRADY, DI 2 Idaho Power Company 10 11 t2 13 L4 15 1,6 1,7 18 19 20 21, 22 23 24 25 1 2 3 4 5 6 7 I 9 I. PCA O\TER\EEIT O. What is the purpose of the PCA? A. The PCA is a rate mechanism that quantifies and tracks annual differences between actual Net Power Supp1y Expenses (*NPSE") and the normalized or "base 1eve1" of NPSE recovered in the Company's base rates, resulting in a credit or surcharge that is updated annually on ,June 1. The PCA mechanism uses a l-2-month test period of April through March (*PCA Year") and includes a forecast component and a Balancing Adjustment, formerly referred to as the "true-up" and the "true-up of the true-up". The forecast component represents the difference between the Company's NPSE forecast from the March Operating Plan and base level NPSE recovered in the Company's base rates. The Balancing Adjustment includes a backward-looking tracking of differences between the prior PCA Year's forecast and actual NPSE incurred by the Company, and also tracks the coll-ection of the prior year's Balancing Adjustment. O. Is the Balancing Adjustment new to this PCA BRADY, Idaho 10 11 L2 13 L4 15 T6 t7 1B l_9 20 fi1ing? 2L A.Yes. In Order No. 352901, the Idaho Public 22 Utilities Commission ("Commission") approved a modification r In the l@tter of the AppTication of ldaho Power Company forIbdification of the Power Cost Adjustment l@chanism, Case No. IPC-E-2 1- 38, Order No. 35290 (January 1-0, 2022). DI Power 3 Company 1 to the PCA filing to replace the "true-up" and "true-up of 2 luhe true-up" with a single Balancing Account. The two 3 "true-up" rates previously included in PCA filings are now 4 combined into one "Balancing Adjustment" rate. It should be 5 noted that this modification solely impacts the presentment 6 of the PCA but has no material impact on the rates charged 7 to customers. I Q. How does the PCA mechanism function? 9 A. With the exception of Public Utility l-0 Regulatory Policies Act of L978 (*PURPA") expenses and l-1 demand response incentive payments, the PCA allows the 1"2 Company to pass through to customers 95 percent of the 13 annual differences in actual NPSE as compared with base 1,4 l-evel NPSE, whether positive or negative. With respect to 15 PURPA expenses and demand response incentive paymentsr ds 1,6 actual annual expenses deviate from base level NPSE, the 1,7 Company is allowed to pass 1-00 percent of the difference 18 for recovery or credit through the PCA. The PCA is also 19 the rate mechanism used by the Company to provide customer 20 benefits resulting from the revenue sharing mechanism 21, approved by the Commission in Order No. 340'7L. 22 O. Does the revenue collected from customers 23 through the annual PCA rate contribute toward the Company's 24 earnings? BRADY, DI 4 Idaho Power Company 1 A. No. The PCA mechanism provides for the annual 2 coLlection or refund of net power supply cost differences 3 between actual costs incurred by the Company and the base 4 l-evel NPSE component of base rates. Aside from the 95 5 percent to 5 percent sharj-ng component I just described, 6 the PCA provides for a one-for-one collection or refund of 7 actual net power supply expenses incurredr or to be 8 incurred, to provide safe, reliable electri-c service to 9 customers. 10 A. What are the components of the PCA base leve1 11 NPSE? 12 A. The PCA base leve1 NPSE includes the following 13 Federal Energy Regulatory Commission ("FERC") accounts: L4 Account 501, FueI (coaI); Account 535, Water for Power; 15 Account 547, FueI (gas); Account 555, Purchased Power; 1,6 Account 565, Transmission of Electricity by Others; and I7 Account 447, Sales for Resale (typically referred to as 18 surplus sales). 19 The PCA base 1evel expense component for FERC 20 Account 555 includes costs of both PURPA and non-PURPA 2L (market) purchases. adjusts FERC Account Per Order No. 32426, the Company 22 23 24 incentive payments who participate in programs. that the Company provides to any of its three demand response 555 to also include demand BRADY, Idaho response customers DI Power 5 Company 25 1 2 3 4 5 6 1 B 9 rr. 2022-2023 PCA A. What is the total PCA col-lection that woul-d resul-t under the 2022-2023 PCA rates proposed by the Company in this case? A. The 2022-2023 PCA rates would resul-t in total PCA collection of $216.9 mil-l-ion. This represents an increase in total billed revenue of $103.4 million for the upcoming year, an increase of 8.27 percent. O. Have you prepared a tabl-e that detail-s the $103.4 mil-Iion revenue impact by component? A. Yes. Table 1 presents a separation of the $103.4 million increase into each component included in the Company's proposed rates. o.Vilhat are the main factors driving the revenue 10 11 L2 13 1-4 15 1,6 1-7 1B 19 change requested A. The in this case? r_ncrease to an increase 1n both the Balancinq Adjustment. The component is attributed to in this year's PCA is attributed forecast component and the increase in this year's forecast lower expected hydro generation, BRADY, DI Idaho Power 6 Company Table 1 Revenue lmpact by Component Line No. Rate Component 2021-2022PCA 2022-2023PCI Difference 1 2 3 4 4 PCA Forecast PCA Balancinc Adiustment s s 131,825,063 (18.320.281) 5 L78,79s,L45 s 38.564.487 s s 46,970,081 56.984.758 PCA Total Revenue Sharinc s s 113,504,783 0 s 217,4s9,632 S (s58,771) s s 103,954,849 (s68,77]-1 Total Revenue ImDact s 113.s04.783 s 216.890.861 s 103.386.078 20 1 2 3 4 5 6 7 B 9 higher market energy prices, and higher natural gas prices, which will be discussed in detail- l-ater in this testimony. Thls year's PCA Balancinq Adjustment is approximately $38.7 miIlion, which is $57.0 mil-l-ion higher than last year's Bal-ancing Adjustment, which was a credit of $18.3 milIion. This year's Balancing Adjustment demonstrates that actual power supply costs for the 2021,- 2022 PCA Year were higher than the forecast power supply costs included in last year's PCA forecast. A. PCA Forecast.10 11 1,2 o. A. How is the PCA forecast amount determined? As described previously, the PCA forecast l_3 component forecast represents the difference between the L4 of NPSE for the upcoming April - March L5 and base Ievel NPSE recovered in the Company's base rates. 16 O. What is the Company's determination of the l7 system-level difference between currently approved base 18 level NPSE2 and the forecast of NPSE for the 2022-2023 PCA 1,9 Year? 20 A. The system-Ievel forecast of NPSE for the 21 2022-2023 PCA Year is $498,834,556, which is $193,I49,687 22 higher than the currently approved base level NPSE of 23 $305,684,869. Tab1e 2 presents the system-Ievel 2 In the l@tter of the AppTication of ldaho Power Company forAuthority to EstabTlsh a New Base Level of Net Power SuppJy Expense, Case No. IPC-E-13-20, Order No. 33000 (March 21, 201,41. Company's test year BRADY, DI Idaho Power 7 Company 1 differences between currently approved base level- NPSE and 2 the forecast of NPSE for the 2022-2023 PCA Year by EERC 3 account. Table 2 2022-202, PCA FORECAST (Total System) Line No.FERC Account Base NPSE Forecast Difference 1 2 3 4 5 6 95% Sharins 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 447, Surplus Sales S s s s s s 108,503,180 2,380,s97 33,357,563 52,605,593 s,455,955 (51,735,1s3) S 151,179,100 So s 86,983,s66 S 99,906,480 s 5,149,239 s (6s,08s,848) s s s s s s 42,675,980 (2,380,s97) 53,616,003 37,299,881 (306,716) (13,3s0,69s) 7 8 s 160,578,735 s 278,132,598 s 117,553,853 100% Sharinq Accounts Account 555, PURPA Account 555, Demand Response lncentives s s 133,853,869 lL,252,265 s 212,s86,0s8 S 8,11s,900 s s 78,732,189 (3,136,36s) 9 Total s 30s,584,869 s 498,834,ss5 s 193,149,687 4 5 6 7 B 9 O. What is the basis for the forecast of NPSE for the 2022-2023 PCA Year? A. The forecast of NPSE for the 2022-2023 PCA Year is based on the Company's March 31, 2022, Operating P1an. O. 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 monthl-y NPSE for the following 1B-month period; however, for the PCA, the Company includes only the 12 months that correspond to the 10 11 1,2 13 t4 BRADY, DI Idaho Power B Company 15 L PCA Year. The Operating Plan is developed by simulating 2 the dispatch of the Company's generation resources for each 3 month, segmented by heavy load and light load hours. The 4 dispatch considers a current forecast of forward market 5 energy prices, available hydro generation, coal- and natural 6 gas prices, and any existing hedge transactions. The 7 system load forecast is then analyzed against the resulting B monthly heavy load and light load dispatch to determine a 9 monthly load and resource balance. Any identified resource 10 deficiency is assumed to be filled with market energy 1l- purchases or natural gas to fuel the Langley Gulch power t2 plant ("Langley Gulch"), based on economics and available 13 generati-ng capacity at Langley Gulch. Economically L4 dispatched generation above the system load forecast 15 represents surplus energy sales. The forecast of monthly 1,5 NPSE and generation for the 2022-2023 PCA Year, as 17 determined in the Company's March 31, 2022, Operating PIan, 18 is provided in Exhibit No. 1. L9 O. Please explain how the Company modeled Bridger 20 Units 1 and 2 Ln the March 3L, 2022 Operating Plan, in 2L 1ight of the ongoing Bridger Regional Haze compliance 22 discussions. 23 A. In light of ongoing discussions with the U.S. 24 Environmental Protection Agency regarding the Wyoming 25 Regional Haze State Implementation Plan (*SIP"), Idaho BRADY, DI 9 Idaho Power Company 1 2 3 4 5 6 7 8 9 10 11 L2 13 L4 15 L6 17 18 19 20 21, 22 23 24 25 26 Power adjusted the availability of Bridger Units 1 and 2 within the March Operating Plan. Specifically, the Company modeled Bridger Unit 2 Lo be available for dispatch at a 25 percent level from June - October 2022 to reflect ongoing uncertainty related to these discussions. For the remaining months within the PCA year, Unit 2 is modeled at availability levels that meet the overall plant emj.ssions limits and annual emissions cap as required per the revised SIP. Bridger Unit 1- operations were modeled as available for dispatch at the revised approved SIP leve1s for the entire 2022-2023 PCA year. a. How does the Company's forecast of system- 1eve1 NPSE for the 2022-2023 PCA compare to the system- 1evel forecast included in last year's PCA? A. Tabl-e 3 below compares this year's 2022-2023 PCA forecast of NPSE to last year's PCA forecast by FERC account. As detailed in this tabIe, the PCA forecast on a total system basis for the 2022-2023 PCA Year is $498,834,556, which is $56,477,L49 higher than last year's forecast amount of $442,357,407. BRADY, Idaho DI Power 10 Company 1 Table 3 PCA Forecast Comparison Expenses (Total Systeml line No.FERC Account Difference 2021-2022 Forecast 2022-2023 Forecast L 2 3 4 5 5 95% Sharins Accounts Account 501, Coal Account 536, Water for Power Account 547, Other Fuel Account 555, Purchased Power Non-PURPA Account 565, 3rd Party Transmission Account 447, Surplus Sales s S s $ s s L18,562,796 s0s 57,235,044 s 74,800,530 s 4,853,909 s 125,842.2251 s 151,179,150 s0s 85,983,566 s 99,906,480 s 5,149,239 s (6s.08s.848) s 32,615,355 0 29,748,522 25,105,950 295,331 {.39,243.6231 7 8 100% Sharins Accounts Account 555, PURPA Account 555, Demand Response lncentives s 229,510,0s4 s 278,L32,s98 5 48,522,s44 s S s s 205,133,74L 7,673,5t2 s 212,s86,0s8 s 8,11s,900 7,452,3t7 s02,288 9 s 212,747,353 s 220,70L,958 s 7,954,505 $ 442,3s7,407 s 498,834,ss6 s SS,qt,UgTotal PCA Forecast 3 4 5 6 1 8 9 O.What general conclusions can be drawn from the information contained 1n Table 3? A. When vj-ewed by category, the 95 percent sharing accounts have increased approximately $48.5 mill-ion from l-ast year' s forecast, while the 100 percent sharing accounts have increased approximately $8.0 mi1l1on over last year's forecast. O. What factors are contributing to the major differences presented in Table 3? A. Forecast expenses included in the 95 percent sharing accounts are expected to increase by 21 percent as compared to last year, from $229,610,054 to $278tL32r598. BRADY, Dr 11 Idaho Power Company 10 11 1,2 13 L4 1 2 3 4 5 6 7 B 9 Due to a reduction in forecast hydro generation, higher forecast market energy prices, and higher forecast naturaf gas prices, the Company expects to rely more on coal generation to serve load and is expected to increase off- system surplus sales. O. Please elaborate on the changes in the 95 sharing accounts for this year's forecast as forecast.with last year's A In addition to lower forecast hydro 1-0 generation, which will- be discussed in detail later in testimony, gas prices Company's higher forecast market energy prices and natural are contributing to increased generation at the coal plants, as well- as increased off-system l4 surplus sales. For the 2022-2023 PCA Year, the average forecast market purchase price is $49.11 per megawatt-hour ('MWh"), compared to $21.34 per MWh last year, an i-ncrease of B0 percent. In addition, the per-unit cost of natural gas for the 2022-2023 PCA Year is $34.03 per MWh, an increase of 39 percent compared to last year. As a result of higher market energy prices and natural gas prices, coal generation becomes more economic. The average per-unit cost of coal- fired generation is $29.7 4 per MWh, which is a 10 percent decrease from last year. Accordingly, expenses from market purchases are expected to increase 91 percent as compared 1_5 L6 L7 l_8 19 20 2L 22 23 24 percent compared 11 1,2 13 BRADY, DI Idaho Power L2 Company 25 l- to last year's forecast, natural gas expense is expected to 2 increase 52 percent, and coal fuel expense is expected to 3 increase 28 percent. 4 The increase in forecast market energy prices is 5 also resul-ting in hi-gher surplus sales revenue. Surplus 6 sales revenue is expected to increase 1-52 percent compared 7 to last year, from $25,842,225 Lo $65,085,848. For the B 2022-2023 PCA Year, the average forecast market sales price 9 is $51.73 per MWh compared with $34.23 last year, a 51 10 percent increase. 11 O. What factors are contributing to the change in 1"2 the 100 percent sharing accounts? 13 A. Forecast expenses included in the 100 percent L4 sharing accounts are expected to increase by 4 percent as 15 compared to last year, from $2L2,747,353 Lo $220,701,958. 1,6 Forecast PURPA costs increased by $7.45 million as compared L7 to l-ast year's forecast and forecast demand response 18 incentive palrments increased by $0.5 mill-ion as compared to 19 last year. 20 O. Is the increase in forecast PURPA costs 21, related to increased generation output from PURPA projects? 22 A. fn part. Table 4 details changes between last 23 year's respect PCA forecast and this year's PCA forecast with generation in MVCh. As shown in Tabl-e anticipated to increase by 10r 708 BRADY, Dr 13 Idaho Power Company 24 to forecasted 25 4, PURPA generation is l_ 2 3 4 Mwh, or less than PURPA expense is PURPA contracts, MWh, compared to 1- percent. largely the The 4 percent increase in result of price escalation j-n for which the average cost is $69.96 per $67 .75 l-ast year. Table 4 PCA Forecast Comparlson Generation (Total System-Mwhl line No.FERC ACCount 2O2L-2022 Forecast 2022-202? Forecast Difference 7 2 3 4 Hydro 6,690,890 5,972,743 17L8,L47l 95% Sharins Accounts Account 501, Coal Account 547, Other Fuel Account 555, Purchased Power Non-PURPA 3,599,2L9 2,340,994 L,478,696 5,093,043 2,556,322 1,s80,326 L,483,825 2L5,328 101,630 5 95% Sharing Accounts L4,109,799 L5,192,435 1,082,636 lfi)% Sharins Accounts Account 555, PURPA 3,027s05 3,038,613 10,708 6 1fi)% Accounts 3,027,905 3,039,513 10,708 Total Generation L7,137,7M 18,231,048 L,093,344 7 95% Sharinr Accounts Account 447, Surplus Sales 754,975 1.258.195 503.220 8 Total Load L6,382,729 L6,972,853 590,L24 5 6 7 B 9 o.$Ihat other general conclusions can be drawn from the information in Table 4? A. Compared to last year' s forecast, hydro generation is expected to decrease 718r 147 MWh, or 11 percent. The decrease in hydro generation, combined with an increase in market energy prices and natural gas prices, is driving an increase in coal-fired generation and surpl-us- sales. Coal-fired generation is projected to increase L,483r825 MWh compared to last year, or 41 percent and 10 11 L2 13 BRADY, DI Idaho Power L4 Company 1,4 1 surplus-sales volumes are expected to increase 503r220 l,tfrilh,, 2 or 67 percent. 3 Q. What is causing the decrease in expected hydro 4 generatj-on of 7L8,147 MVlh? 5 A. The decrease in expected hydro generation is 5 mainly due to lower projected inflows into Brownlee 7 reservoir. The March Operating Plan used in this year's 8 PCA forecast projects April through ,July inflows into 9 Brownlee of 2.9 million acre-feet ("MAF") as compared to 10 4.2 I,IAE used to determine last year' s PCA forecast, a tL decrease of 31 percent. Expected inflows into Brownlee L2 were higher for last year's PCA forecast as a resuLt of 13 better snowpack conditions, which provide for sustained L4 runoff and increased hydro generation during the spring and 15 summer months. 1,6 Additionally, this year's PCA forecast reflects 17 weaker reservoir storage condj-tions, as compared to last 18 year's forecast. The March Operating Plan used in this 19 year's PCA demonstrates that available storage in the 11 20 reservoirs above Brownlee is 76 percent of normal and at 51 2t percent of capacity, compared to last year's 2021 March 22 Operating PIan, in whj-ch storage was 113 percent of normal 23 and at 75 percent of capacity. Together weaker snowpack 24 conditions and carryover as compared to the prior year are BRADY, DI 15 Idaho Power Company L 2 3 4 5 6 7 8 9 resulting in the 11- percent reduction in forecast hydro generation for th.e 2022-2023 PCA Year. O. How are the forecasted NPSE differences presented in Table 2 used to determine the 2022-2023 PCA forecast component to be collected from Idaho customers? A. T}:e 2022-2023 PCA forecast component reflects the Idaho jurisdictional share of the forecasted NPSE differences presented in Table 2, adjusted for the PCA sharing provisions. The Idaho jurisdictional share of the forecast NPSE differences is determined by applying a ratio of forecast firm Idaho jurisdictional sales to forecast firm system-Ieve1 sales to the system-1evel NPSE differences. 1_0 1-1 L2 1-3 L4 A. What is the Company's forecast of system-1eveI 15 firm sales and Idaho jurisdictional firm sales for the 16 2022-2023 PCA Year? 1.7 A. Eor the 2022-2023 PCA Year, Idaho Power has 18 forecast system-Ievel firm sales to be 15r 690,546 MlVh and 19 ldaho jurisdictional firm sales to be 14,992,046 MWh, or 20 95.55 percent of the system Ievel. 2L O. What is the Company's determination of the 22 2022-2023 PCA forecast component to be collected from fdaho 23 customers? 24 A. 'II:,e 2022-2023 PCA forecast component to be 25 coll-ected from Idaho customers j-s $178,795t544. Table 5 BRADY, Idaho DI Power l_6 Company 1 2 3 presents the determination of the 2022-2023 PCA forecast component by individual- PCA expense and revenue category. B. Bal.ancing Adjustneat. a. What is this year's quantification of the Bal-ancing Adjustment? A. The Bal-anclng Adjustment is detailed in the PCA deferraf report, attached hereto as Exhibit No. 2. This report compares actual NPSE amounts to actual power cost collections monthly, with the differences accumulated as a deferral balance. The balance at the end of March 2022, with interest applied, was $38,669t525 as shown on row 100 of Exhibit No. 2. The approximate $38.7 mil-Iion represents 4 5 6 '1 B 9 10 11 1,2 13 BRADY, DI Idaho Power l7 Company Table 5 2022-2023 PCA FORECAST Line No.FERC Account Difference from Base Difference After Sharinc 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 447, Surplus Sales (From Table 1) s 42,67s,980 s (2,380,s97) S s3,616,003 5 37,299,887 s (305,716) S (13,3s0,59s) s s s s s s 40,542,18L (2,26L,s67l. 50,93s,202 3s,434893 (291,380) (12,583,150) s s S s s s 38,737,356 (2,150,888) 48,567,709 33,857,430 .278,4081 (t2,1L8,5471 7 s 117,ss3,863 $ 771,676,770 s 106,704,6s8 100% Sharinq Accounts Account 555, PURPA Account 555. Demand Resoonse lncentives s s 78,732,189 (3.136.3651 s s 78,732,L89 (3.135.355) s s 75,227,25L (3.136.36s) 9 Total s 193.149.587 s 787.27L,994 s t78.79s,s44 1,4 1 2 3 4 5 6 7 8 9 an increase to customer rates in this year's PCA Balancing Adjustment. O. To what factors do you attribute the accumulation of the approximate $38.7 million deferral- balance? A. The approximate $38.7 million deferral balance was primarily driven by a decrease in actual hydro generation from expected as well as higher than forecast market purchases, offset by higher surplus sales. ActuaL hydro generation for the 202L-2022 PCA year totaled 5,268,002 MWh, d 21 percent decrease from last year's forecast of 6,6901890 M[rIh. Actual purchased power totaled 4,079r834 MWh, a 176 percent increase from last year's forecast. Actual surplus sales volumes totaled L,373r 630 MWhr Errr increase of 82 percent from 754,975 MWh. Actual natural gas prices were also higher than forecast, driving a 55 percent increase in natural gas fuel expense. Although natural gas prices were higher than forecast, the Company's reliance on natural gas generation did not decrease as it was needed to serve Load due to Iower than expected hydro generation expected temperatures during l'h,e 202L 0. Please elaborate on the and higher than summer season. changes in actual versus forecast generation and PCA Year. expense for the 2021-2022 10 11 1,2 13 L4 15 16 t7 18 l-9 20 2t 22 23 24 BRADY, Idaho DI Power 18 Company 25 1 A. Last year's PCA forecast included an average 2 market sal-es price of $34.23 per MWh. The actual average 3 market sal-es price for the 2021-2022 PCA year was $57.70 4 per MVflh, a 69 percent increase. As a result of the 5 difference in forecast and actual market sales prices, as 6 wel-l- as economic opportunity during the spring and winter 7 months of Lhe 202L-2022 PCA year, actual surplus sales B volumes were 82 percent higher than forecast. Surplus sales 9 revenue total-ed $79,257,653, which was 201 percent higher 10 than forecast revenues of $25r842,225. 11 Coal--fired generation totaled 3,241,970 MWh, which L2 was 10 percent lower than forecast, and actual coal fuel 13 expense was $104.5 mi11ion, 12 percent .l-ower than forecast. 1,4 Coal-fired generation was lower than forecast due to the 15 increase in market energy purchases and increase j-n natural- 16 gas generation. L7 Natural gas generatJ-on totaled 2,719,869 MWh for the 18 2021-2022 PCA Year, which was 378,875 MWh, or L6 percent, 1,9 higher than forecast. Due to natural gas prices being 20 higher than expected, actual natural qas expense totaled 2l $88,941,596, which was 55 percent higher than forecast. 22 While natural gas prices were higher than forecast, the 23 Company's reliance on natural gas generation increased 16 24 percent as it was needed to meet 1oad, as wel-I as make off- 25 system sales when it was economic, as noted prevj-ously. BRADY, Dr t9 Idaho Power Company 1 While both purchased power and surplus sales 2 increased, surplus sale volumes were highest in off-peak 3 spring and winter months, and purchased power was highest 4 in summer months, where hot temperatures caused 5 continuously higher than forecast peak loads. 6 Q. Were there any items included in this year's 7 Balancing Adjustment in addition to actual NPSE incurred 8 durj-ng the April 202L through March 2022 period? 9 A. Yes. Per Commission Order No. 34100, Idaho 10 Power included its actual costs of Western Energy Imbalance 11 Market (*EIM") participation for ApriL 2021 through March L2 2022 j-n the Balancing Adjustment. Benefits associated with 13 EIM participation are embedded j-n actual NPSE experienced L4 over that same period. l-5 A. Please summarize the conditions of Order No. 16 34100 as they pertain to EIM cost recovery through the 202I 1,7 PCA. 18 A. Per the terms of the settlement stipulation 1,9 (*EIM Stipulation") approved by Order No. 34100, Idaho 20 Power agreed to include an EIM-related monthly revenue 21- requlrement in its monthly PCA deferral calculation based 22 on actual EIM participation costs commencing April L, 201-8. 23 The Company also agreed to apply a soft cap to EIM-related 24 revenue requirement incl-uded in the PCA deferral equal to 25 annual EIM benefits as reported by the California BRADY, Idaho DT Power 20 Company 1 Independent System Operator (*CAISO") for the corresponding 2 period. 3 Q. Is the ElM-related revenue requirement 4 included in the April 2021 through March 2022 PCA deferral 5 under the soft cap of annual CAlSO-reported benefits for 6 that same period? 7 A. Yes. Eor the April 2021 through March 2022 8 period, the EIM-related revenue requirement totaled $2.9 9 miI1ion, while CAISO reported EIM benefits for ldaho Power 10 of approximately $40 million from April through December 1l- (CAISO' s first quarter 2022 report has not yet been 1,2 published) . Therefore, the Company's ElM-related revenue 13 requirement is less than the soft cap agreed to in the EIM L4 Stipulation. 15 O. Does Idaho Power believe the EIM has provided L6 net benefits to customers since joining in April 20lB? I7 A. Yes. While Idaho Power believes the CAISO 18 benefit calculation overstates esti-mated benefits to Idaho t9 Power's system, the Company believes customers have 20 realj-zed significant net benefits since the Company's entry 2L into the EIM in April 20L8. As discussed in the Company's 22 May 24, 20L9, Report of EIM Benefits and Costs of 23 Participation, filed in Case No. IPC-E-16-L9, Idaho Power 24 has developed a more precise methodology for determining 25 EIM benefits that uses inputs specific to the Company. BRADY, D] 2T Idaho Power Company l_ 2 3 4 5 6 7 B 9 Based on this methodology, the Company believes benefits achieved between April 2021, and December 202L are approximately $16 million (benefits for the first quarter of 2022 are not yet available). This level of EIM benefits compared to the ldaho-jurisdictional EIM costs of $2.9 milIion, demonstrates a net benefit to the Company and, ultimately, its customers. C. PCA Rate tion. O. How i-s the rate for the forecast portion of the PCA for April 2022 through March 2023 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 1,, 2022, through May 31, 2023 ("System- 1evel Sales Eorecast") i and (2) 100 percent of the difference between PURPA-related expenses quantified in the Operating Plan and those quantified in the Company's last approved update of NPSE, divided by the Company's System- l-eveI Sa1es Forecast; and (3) 1-00 percent of the difference between the Idaho jurisdictional demand response incentive payments quantified in the Operating Plan and those quantified in the Company's last approved update of NPSE, 10 11 L2 13 1,4 15 L6 17 18 1,9 20 2T 22 23 BRADY, DI Idaho Power 22 Company 24 1- divided by the forecast of Idaho jurisdictional- firm sales 2 for ,June L, 2022, through May 3L, 2023. 3 Q. What is the rate for the forecast portion of 4 the PCA for April 2022 through March 2023? 5 A. The rate for non-PURPA expenses is 0.7L17 6 cents per kilowatt-hour (*kwh"), which is calculated by 7 multiplying $1-17,553,863 from Table 2 by 95 percent and B then dividing it by the System-leve1 Sales Forecast of 9 15,690,546 MV0h (($117,553,863 * 0.95) / 15,690,546) = 10 $7 .I1.7 /MWh = 0.7L1,7 cents/kWh) . The rate for PURPA 11 expenses is 0.5018 cents per kWh, which is calculated by 1,2 dividing $78,732,189 from Table 2 by the 15,690,546 MWh l-3 ($78,732,189 / 15,690,546 MVilh : $5.018/MWh : 0.5018 L4 cents/kWh). The rate for demand response incentive 15 payments is a negative 0.0209 cents per kwh, which is t6 calculated by dividing the negative $3,136,365 from Table 2 17 by the forecast of Idaho jurisdictional firm sales of 18 t4,992,046 MWh (-$3,136,365 / 1-4,992,046 MI/{h = -$0 .209/tmh 19 : -0,0209 cents/kWh) . The forecast portion of the PCA rate 20 is L.L926 cents per kwh, which is calculated by adding the 2t non-PURPA expense of 0.711,7 cents per kWh to the PURPA 22 expense of 0.5018 cents per kWh to the demand response 23 incentive payment of negative 0.0209 cents per kWh (0. 7L1,7 24 + 0.5018 + -0.0209 = 1.1926 cents/kwh). BRADY, Idaho DI Power 23 Company 1 2 3 4 5 6 7 8 9 0. How did you compute this year's Balancing Account rate? A. As shown in Exhibit No. 2, this year's Balancing Adjustment of the PCA is approximately $38.7 miIlion, whi-ch, when divided by the Company's forecast of Idaho jurisdictional sales of 14,992,046 MWh, results in a rate of 0 .2579 cents per kWh ($38, 669,526 / 14,992,046 : $2.57 9/MWh : A.2579 cenrs/kWn) . O. What is the resulting PCA rate when you comblne all the PCA components described previously? A. The unlform PCA rate comprises (1) the 1,.1,926 cents per kWh for the 2022-2023 projected power cost of serving firm loads under the current PCA methodology and 95 percent sharing, and (2) the 0.257 9 cents per kWh for the 202L-2022 Balancing Adjustment of the PCA. The sum of these two components is a 1.4505 cents per kWh charge for all rate classes. III. ADDITIONAI, PCA REITE ADiN'STMEIITS 19 A. Revenue Shanr-D.ct 20 O. When was the originally established? A. The revenue revenue sharing mechanism sharing mechanism was originally 10 11 1,2 13 1,4 15 t6 L7 1B 21, 22 23 established in Case No. IPC-E-09-30 and approved in Order 24 No. 30978, effective for the years 25 the revenue sharing mechanlsm has 2009-201,1,. S j-nce then, been modified and BRADY, DI Idaho Power 24 Company l- extended three times.3 Most recently, the revenue sharing 2 mechanism was extended indefinitely, with modifications, in No. GNR-U-18-01. a. What are sharing mechanism? A. In Case the provisions of the current revenue No. GNR-U-18-01, the Company filed a 3 4 5 6 7 B 9 Order No. 34071 in Case 10 motion to approve a settlement stipulation (*2018 Stipulation") extending the sharing mechanism indefinitely, with modifications. The Commission approved the 20L8 Stipulation in Order No. 3407L. Per the terms of the 201,8 Stipulation, if the Company's actual year-end Return on Equity (*ROE") for the Idaho jurisdiction exceeds 10 percent, all amounts up to and including a l-0.5 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 become effective at the time of the subsequent year's PCA. If the Company's Idaho jurisdictional ROE exceeds 1-0.5 percent, all amounts in excess of 10.5 percent will be shared 55 percent with Idaho customers as a rate reduction 2L to become effective with the subsequent year's PCA, 25 fdaho customers in the form of22 percent will be shared with 23 an offset to amounts in the Company's pension balancing 20 percent will be apportioned to the Company.24 account, and 11 L2 13 14 15 t6 L7 l-8 1,9 20 BRADY, DI Idaho Power 25 Company 3 Order Nos. 32424, 33149 and 34071. 1 2 3 4 5 6 7 8 9 With regard Deferred Investment to the amortization of Accumulated Tax Stipulation amortization of ADITC, achieve a maximum 9.4 percent Idaho jurisdictional ROE if the Company's year-end actual results fa11 below that amount for any year beginning January 1, 2020. Idaho Power may use up to $25 million of additional amortization of ADITC per year, provided the total, cumulative amount of ADITC does not exceed $45 miIIion. Per the 2018 Sti-pulation, once the Company has fully amortlzed the $45 million of ADITC, revenue sharing will cease; however, Idaho Power may at any time request to replenish the total amount of ADfTC it is permitted to amortize, and if approved by the Commission, revenue sharing would continue. O. Did the revenue sharing mechanj-sm result in any action following the 2009-2020 fiscal years? A. Yes. The Company's earnings in each year from 20Lt through 20L5, as well as 2018, resulted in revenue sharing with customers totaling $126.2 million, either as a direct rate offset in the PCA or as an offset to amounts that would have otherwi-se been collected in rates. The Company's earnings in 20L6, 20L7, 20L9, and 2020 were below the revenue sharing threshold. These amounts are detailed in Table 6 below. BRADY, DI 26 Idaho Power Company all-ows the Credits (*ADITC"), the 2018 Company to accelerate the in an amount up to $45 mi11ion, to 10 11 1"2 13 1.4 15 t6 1,7 18 19 20 2L 22 23 24 25 Table 6 2W9-2O2O Revenue Sharing Line No.Revenue Sharing Component 2m9-2011 20L2-20,4 2015-2020 1 2 3 4 5 5 7 Available ADITC For Use ROE Threshold 5G50 Sharing Threshold 75-25 Sharing Threshold Customer Benefits (S Millions): Reduction to Rates Offset to Pension Balancing Account S45 Million 9.SVo los% N/A S45 Million 9.SYo 10.0% to.5% S45 Million 70.0% N/A to.o% 527.L s20.3 522.8 s47.8 Ss.z s0.0 8 Total 547.4 s70.5 s8.2 iL26.2 1 2 3 4 5 6 7 I 9 O. Did the Company's year-end 202L financial resul-ts warrant any actj-on rel-ated to the existing sharing agreement per the terms of the 2018 Stipulation? A. Yes. The Company's year-end 202L financial- results ylelded an actual- Idaho jurisdictj-onal ROE of 10.02 percent, above the 10 percent ROE threshold for revenue sharing, and thus resulting in a revenue amount to be shared with customers after tax gross-up of $568,77L. O. Did the Company use the same methodol-ogy to determj-ne the Idaho jurlsdictional 2021 year-end ROE that was used in prlor PCA filings? A. Yes. The methodology used to determj-ne the Company's fdaho jurisdictional 2021 year-end ROE is consistent with the methodology used for the year-end ROE determinations since the inception of the mechanism. O. Do you have an exhiblt demonstrating the application of this methodology? BRADY, DI 21 Idaho Power Company 10 11 72 13 L4 15 t6 t7 1B 1 A. Yes. Exhibit No. 3 provides a step-by-step 2 calculation of the Idaho jurisdictional ROE based on year- 3 end 2021, financial results utilizing the Commission- 4 approved methodology from previous PCA filings. 5 Q. What is the revenue sharing amount to be 6 included in Lhe 2022-2023 PCA? 7 A. As detailed in Exhibit No. 3, the 2021 Idaho 8 jurisdictional ROE was L0.02 percent. As quantified on line 9 53 of Exhibit No. 3, in 202L, the Company's earnings 10 exceeded an Idaho jurisdictional ROE of 10 percent by 11 $527,962. Per the terms of the 20LA Stipulation, 80 percent L2 of the $527,962 should be shared with customers as a direct 13 reduction to PCA rates effective June 1, 2022. Applying the L4 B0 percent sharing provision to the $527,962 yields a 15 customer-allocated sharing amount of $422,369. After tax t6 gross-up, the revenue sharing amount to be applied to 1-7 customer bilIs is $568,771,. 18 O. How does the Company propose to al-locate the L9 $568r771 revenue sharing to customer classes? 20 A. The Company proposes to allocate the revenue 21, sharing benefit to customer classes utilizing the same 22 methodology as in past cases, i.e., based on each class's 23 proportional share of forecasted base rate revenues for the 24 upcoming PCA rate effective year, whj-ch in this case is 25 ,June L, 2022, through May 3L, 2023. BRADY, DI Idaho Power 28 Company 1 2 3 4 5 6 7 8 9 O. Have you provided an exhibit detailing the class allocation utilizing this methodology? A. Yes. Exhibit No. 4 details the class allocation of the $568,771 revenue sharing benefit. As j-n column G of Exhibit No. 4, each customer classdisplayed receives a decrease of approximately 0.05 percent relative to current base revenues. O. How does the Company propose to include the class-all-ocated revenue sharing benefits in rates? A. Except for the special contracts for Micron Technology, Inc., the U.S. Department of Energy, and the ,J.R. Simplot Company - Pocatello, Idaho Power proposes to include the class-a1located revenue sharing benefits on a cents-per-kWh basis applied to the 2022 PCA rates effective ,June L, 2022, through May 31, 2023. Column F of Exhibit No. 4 contains the rates proposed for inclusion in each class's PCA rate. O. What is the Company's proposal for providing revenue sharing benefits to its special contract customers? A. Consistent with the methodology used to share 2011-2015 and 20IB revenues, the Company proposes to provide the special contract customers a flat dolIar-per- month credit in 1"2 equal portions to serve as a reduction to monthly invoices billed from June 2022 through NIay 2023. The total revenue sharing benefit allocated to the special 10 11 1,2 13 1,4 15 16 1-7 18 t9 20 21, 22 23 24 BRADY, DI Idaho Power 29 Company 25 1 2 3 4 5 6 7 I 9 10 11 L2 13 L4 15 L6 L7 18 19 20 2L 22 23 24 25 contract customers is displayed in column E of Exhibit No. 4. O. Is the Company's rate design proposal for the 2022 revenue sharing benefits consistent with past-approved proposals? A. Yes. rV. ITET CUSTOMER IMPACE O. What is the revenue impact of the requested PCA rate when compared with PCA rates currently in effect? A. Attachmeat 2 to the Application filed contemporaneously with my testimony provides a detailed description of the overall revenue impact of this filing on each customer c1ass. As shown in Attachment 2, applying the requested PCA rates to expected customer sales for the June 2022 through May 2023 test year results in a PCA i-ncrease of $103.4 mi1lion. A. Given the magnitude of the increase for the 2022-2023 PCA, did the Company consider proposing any rate mitigation options? A. Yes. Gi-ven the magnitude of the 2022-2023 PCA increase, I consulted with management to determj-ne what mitigation, if any, the Company should include in this year's PCA filing. O. Eollowing these discussions, is the Company proposing to include any rate mitigation in this filing? BRADY, DI 30 Idaho Power Company 1 A. No. After careful- consideration, I was advised 2 by management to not propose any rate mitigation measures 3 in this case. However, the Company is open to rate 4 mitigation measures if the Commission deems them 5 appropriate. 6 Q. Why is the Company not proposing any rate 7 mitigation in this case? I A. Eirst, the Company believes that customer 9 interests are generally best served by matching cost 10 recovery as closely as possible with the period in which 11 power supply costs are incurred. Additionally, mitigating t2 rate impacts by spreading recovery over multiple years 13 creates the possibility that the deferred collection will L4 result in "rate pancaki-ng" with potential future rate 15 increases, essentially deferring an increase in the current 16 year to create an even larger increase in the future. The 1,7 Company also considered prior Commission orders with regard 18 to rate mitigation measures in the PCA. In orders from the l-9 2008, 2009, 20L3, and 2020 PCA casesa in which rate 20 mitigation was discussed, the Commission declined to adopt 2L any rate mitigation measures, primarily for the same 22 concerns surrounding rate pancaking, appropriate matching 23 of costs and recovery, and the overall intent of the PCA 24 mechani-sm. BRADY, Idaho DI Power 31 Company a Order Nos. 30563, 30828, 32821-, and 34682 1 2 3 4 5 6 7 I 9 O. Would Idaho Power be amenable to j-mplementing rate mitigation measures for the 2022-2023 PCA if the Commission determines such measures are appropriate? A. Yes. While both Idaho Power and the Commission have expressed concerns with rate mitigation measures in the past, the Company would be amenable to discussing such measures in the current filing. A two-year recovery period, for example, would reduce the rate impact from the proposed $103.4 miIlion, or 8.27 percent increase, to an approximate $50 mi11ion, or slightly more than 4 percent, annual increase in collection spread over two years. L0 11 L2 l-3 includes L4 l_5 l_6 L7 18 19 20 21, 22 23 24 a . Have you prepared a the proposed PCA rates? . Yes. Attachment 1 revised Schedule 55 that to the Application is a revised Schedule 55 and includes the proposed PCA rates in clean and legislative formats. 0. Shou1d the Commission approve the Company's computation of the PCA rates? A. Yes. The Commission should approve the Company's computation of the PCA rates. The calculation of the PCA rates follows the methodology that was approved in Order Nos. 30715, 33307, and 34071. If approved, luh,e 2022- 2023 PCA will result i-n an increase in total billed revenue of approximately $103.4 mi11ion, or 8.27 percent. \\ A BRADY, Idaho DI Power 32 Company 25 1 2 3 4 5 6 7 8 9 o. A. Does this conclude your testimony? Yes, it does. 10 11 1,2 13 t4 15 T6 L1 1B t9 20 2t 22 23 24 BRADY, DI 33 Idaho Power Company 25 ]- DECI.ERAITION OF {'ESSICA C. BRADT 2 I, .fessica G. Brady, declare under penalty of 3 perjury under the laws of the state of Idaho: 4 L. My name is Jessica G. Brady. I am employed 5 by Idaho Power Company as a Regulatory Analyst in the 6 Regulatory Affairs Department. 7 2. On behalf of Idaho Power, I present this 8 pre-fi1ed direct testimony and Exhibit Nos. 1-4 in this 9 matter. 10 3. To the best of my knowledge, my pre-fiIed 1-1 direct testimony and exhibits are true and accurate. L2 I hereby declare that the above statement is true to l-3 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 j-s subject to penalty for perjury. L6 SIGNED this 15th day of April 2022, dt Boise, Idaho. L7 w^r 18 Signed: BRADY, DI 34 Idaho Power Company MffiHffiAri[ r. ,G - xlrc'l $, m lhbEm.hdrdk.ll.I*Mh*kk.t.sa-!.EH.ind ![-$rf,EE N,m &ptz 0,s g,g m6 &,8 lllN 3n,61 g,te *In I,m m5{ 5i12.113 2 l@rtg,h.bhTd Boanaa Mr,fiPnrffifd EIFE n3713.4,S m,m716l,H (0)5.9, 218613 6r3t rt4 B,Sa 3,*Jra 3 nxnI 3iS.S m,67,6.tro 2,3r0,!3a71,1&16 xa,u ro.mr.0l0 I a AcMII,dh Eltderhfl(m)rdE4.. ildrYaryhryr(m)IdBre il.c0.s590 t 0t,s214.0 I 217of 9,fi0 5,9 U,O5.8,m t t0.4.!g , r0.mr.6 ! to.{ts.g t I A916 a €,e2c,2l t w8 itisl {t.oL g16 s,Br g.E 10,!40.S I tl,{l2m t tam,g t rarS.als t tttttlal 3 1r.C4,ll6 I .safrtr9,et65 M&,frUt qkroHr7 ED'ly(Vfrh)t ldare ffie Ery(ffi)t0 TdlErpD mSottE.t0Mr)TdEryil Mg,PMkhffiAtur(lfflr)Td EO.il tu3*1t,6,sa tg.ma.e,ls a &3ea3rr,e t u2{0r{2.10r t rs26 ,ze sa1{.rt.s aLN (0)agra I s,ia r rsro I ,..ia t MNe,s.ea! ! a,ro t r,t,il I eia t il,8rr.e6,r?0 a dJ{ t ,Zfr I a,fai,q& a &,?1e , 4,4713,6at5r! 21O:tU4ral,u AUAl,B,m ,4913rgl,r?i t 211,66t.g.a 3 ta@ar45.s6 t tt,L e;a 4r.16a:la,s an,ig tzgla@zn1 a 2t6,&7,S.8 t t8360 t tzio t il.4e74.6,a4 I a4Q t &,93.*,4t0 I 215,$t.E.il | r63il a y]:ot *Nar6.3r I fl,q t e23743.614,& a a,H7,ru,H I rBro I ,zi* t I 1a.76g.S,Aa S at,3tl I 18,20 t *i* t $.rD1@21 t a,$t I 2,Ms.lr0 I ra3il &;6tt 12 tlta a.ut,tr.s I tnpltl.!tr.@ t n6a r,ts6rr,Er t a,s I tlu.@2,1S.S $564flarrs tro.salr,eoqe 24,t9 s,ts,Nt5 tol7 7g,B t bdlt,]fi!t5EEU(mh)ld Ae6. lLEf,aEr[ tl te I 21 ? 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I f1,g tas 1e,o arltD d,r1! a.B rrta 12,8 (im) 6,74 r2rlrl 14,1uoffi os* o@ oM o&i o@i o.@t oM o.@ o& 0@t olG [.@ 2r4fi6 2Fr$.ra 2S$A aialrdra 35.8 orro u&,.t12p121ED^dMDPi&bMi.s.. qq.hb(D BhmiffgffiEtu^he.cdtffiMlrycd* h@ulll@. R.mu.mrd C) 6!t E hlbit No. 2 C@ No. IPC€-22-1t J. BEdy, IPCP.!E 1 ol2 SIrrrE--&fioSqillffi BiffiMO BrdM ^dhffil*eId*ldtuffiDt adbdz@tdcdffil[a.ihb-O&lEtrho {.G.1, ts37 {trit2a7.117$ 28,11S l(tOltG &.ma s,6g 6&fr1f,.*21 2&M'2oies --lfrIFT'. 3.d! us?g 31314 4u6as{ a5ft,4 1npla rgfiil m l@F1 r.rz1fi 1g.l2a r.il@ t,arD 1,8211 tgT.ira m.t[ i.oDs 9ai2 12,fr7 i,t&31 {gmlta ro& i@s m t* 0@* o@ 0M 0& 06 oG oG o&tta" u[mllcc(Dat oat o.6s oG*06 OB 0.6s o@ oGG o@t ooprgqaN*u &1& 00,751.D19) p.gfi!@)rgprr.6 tsffi 6 {lt 18 6 as .A 4t$ E)dlm No. 2Ce No. lPGE.22.1'l J. &!dy, lrc P.g,B2d2 IDAHO POWERCO,IIPANY ADDITIONAL INVESTIIENT TAX CREDIT ANALYSIS Fortt6 Twolyo tonths Endod lrscombp,t?1,20.21 Adrd$tubt rr{Mrllt.,ibtl h2l EAU9.:b TOTAL SYSTEM IDAHO 3,552,703,864 IDAHO * 96.076% TOTAL sYsTEM tDAlg S.ptembrr All6tlon6rRati6ro@ ti12ry " OPEilTING RMNUES t. RETALruS RffiNUES (ld *.1 R.v) 15 OTHEROPEMNNOREWNUES I' TOTA OPEilTING RffiNUES 17 I' OPERANre WENSES 19 OPEilNON E MNreWCE UPENSES D EPRECATION ffENSE 2! MRTBTION S LIMIED ERf Plff 2 TUESOTHERTNINCOME A REGUUTORY DBtrSREDITS 2' PROUSION FOR DEFERREO Iil@ME IreS 6 IMSTUEM Tff CREOIT BUSilEI A FEOEM INCflE TreS 27 STATE INCOME TffiS 6 TOTATOPEUNtrGEPENSES a $ OPEilNre INCilE !1 &0: IERCO OPEMTING INGOME i $ OPEMNNGINCOME BEFMEOTHERINCOMEANODEOUCTIONI a ^DD:trUOC EOulry s rcD:OfrER lrc4E&D mDUCTIoNS 974.391.28:' 143,588.027 1,1 17,979,310 51a7@,74 Dire.i Asbn 136,940,469 95.4% 1.(r9,650.202 1,198,904,622 Dkod A$ien '189,896,371 95.4% 1 .388.630,903 't,252,*3,142 199,1 14.549 1,452,017,631 3.697,810.735 217,377,59 240,197,319 6E3,260,685 123,5n.643 6.256,m0 26,188.106 1,087,3S t (14,885,903) 't'1.?64,544 29, I 56,558 11,4't 1,459 877,316,39r 649,645,4S 118,717,524 6,013.901 24,462,6U 878,35 (14.382,662) 10,a24,447 24,544,231 11.163.398 835.867,704 95.1% 96 1% 96.1% 93.4% 80.8% 96.696 96. t96 97.9% 97.8% 95.5% 917,571.975 165,4{6.697 8,,195,466 30,947,260 1,197,775 (21,55S,910) 11,83eE97 35,047,688 13,298,956 1,162,578,m3 672,4X,@O 1 58.9/m.333 8.166,702 28.908,278 1.209,905 (20,83O,S19) 1 1,370,59ti 34,3't 1,639 13.009,865 1,107,515,477 95.'r % 96. t% 93.4% 80.E* 96.6% 96. t% 97.9% 97.8% INCilE BEFORE IMEREST CffiGES LESS: INTERESTcffiOES 240,662,916 6,715,053 233,79l1* 6,414,821 289,438.88a 8,991,347 281,315,516 8,589,341 95.5% 96.1% (L 10) 237,275,6* 96.1% (LlO) 'to.c8r Exhibit No. 3 Case No. IPC-E-22-11 J. Brady, IPC Page 1 of 1 298,430,236 31,537,344 343.755 289,904,857 30.299.778 333.934 97.1% 96.1% (L 10) 97.1% (L 33) 430,31 1,334 86,853,666 3m,538,570 43,x2,472 $ !7 $ T a1 a 6 6 s tt s $ g $ t a7 I T o at @ 6 g 6 i a 6 o rc 71 n D NET INCOME 243,647,668 9.89% ACru[ Yffi{ND RESULTS . BEFORE TC DUSilEM *NINGON COMMON ST&X COMTd EOUIWAT ff ENO 2,r3,647,668 2,M,724.26 237,275,698 2.368.m5.322 REruRil ON ff+ilO CilMON EOUIry 234.1{8,807 246,472,4n 258.7$.050 U.W.,fi (Lr{z{'9.4%) ztc,to,sl2 (Lr[4 ' 10%) 2i|.,OO.5$ (1,{,{ ' 10.5%) ACTW ff{NO RESULTS - mR rC 0USTmmi IMSTUENT TA CREDIT UUSruENT msTEo ffiNtxGoN @mm slex DUSTED COUMON EOUIW ATff{NO ADJUSED RETURN OT ff{NO COUMON EOUIil (16,206,620) (14&143) / (1-9.4%) 221,069,078 2.35 t ,798.702 rF IDAHO RETURN ON COMMOII EOUIrY (Un. {6) <e.a9a ILg bUfr, hOi ilFtu.htrlbrdLgdl6,m,m 0 lF IOAHO RElURll Ol{ COilMOt{ EOulrY (un.46l >loL IDffiOWNINOSGRATERflN 1095 NOEBW LESSTMN lOS 527,96A (143149y(1-10%) lF IDAHO RETURN Oil COlrtilON EqUITY (Un. /lc) >lo.Sa INCREMENTIIDSO ffiNING GRAER ]il IO,SROE 0 (14+L50y(1-10.596) Pd Ofl,.r t34o7l : ROE tu 1610.5I4USTilER SffiE-& Ed6nb nh) ROE tu t&to.s{oMPNY SffiE-ffi RoEgmrhnlo.*(Iffi)-CUSTOMERSffiE-S*(Rffinbra!) ROE gdrss 10.6$(llmmdl)-CUSTOMER SURE -5% (ffib P.lffi bhno) ROE Fdrhn 10.5* (llffi){wPAW sffi E - ffi 12.,@ 105,59a 0 0 0 527,52 Tu G@ Up 56E,z,l ffixtNG oN coMMoN s@K o e{ RoE ffiNrNS ON COMMON STmKO t0 ROE PEparod by: K6lley N@ ReviMd by: ldaho Power Company C.lqrhtbn of Revenue lmpact Class Allocated Revenue Sharlng 2022-2023 State of ldaho Filed Aprll lt 2022 (A)(B)(c)(D)(E) Percentageof Allocated ldaho Base Revenue Sharing Revenues Benefit (F)(c) Line No Rate Sch. No, Average Number of Customers Normalized Energy (kwh) Current Base Revenue Dollars per kwh Rate Percent Revenue changeTariff Descriotion Uniform Tariff Rates: I Residential Service 2 Master Metered Mobile Home Park 3 Residential Service Energy Watch 4 ResidentialServiceTime-of-Day 5 Residential Service On-Site Generation5 Small GeneralService7 Small General Service On-Site Generation8 Large General Service - Secondary9 Large General Service - Primary10 Large General Service - Transmission 11 Duskto Dawn LiShting 12 Lar8e Power Service - Secondary 13 Large Power Service - Primary 14 Large Power Service - Transmission 15 Agricultural lrrigation Service 15 Unmetered General Service17 Street Lighting 18 Traffic Control tighting 19 Total Uniform Tariffs 1 3 4 5 6 7 8 9S 9P 9T 15 195 19P 197 24 40 4r 42 490,293 21 0 988 72,024 30,3t18 80 37,535 280 4 0 0 Lr4 2 19,120 1,563 2,980 766 5,458,972,074 4,52t,955 0 L7,662,33I 55,895,664 L37,395,7t5 190,425 33M,L76,U0 592,994,508 3,557,L43 5,267,423 0 2,358,498,546 32,893,530 L,897,5L7,Lt9 13,925,301 2?,760,0t4 2,U7,96r 494,239,s46 38&104 0 1,530,838 6,387,494 r5,753,365 24,755 225,029,0U 35,347,188 240,2N L,234,927 0 !2L,99L,234 1,601,499 140,388,800 L,t24,204 3,409,701 L6Z,7U 45.079(, 0.04% 0.00% o.t4% 0.s8% t.44% 0.0096 2o.52% 3.22% 0.02% o.7L% 0.0096 tL.7Z% 0.15% L2.n% 0.10% 0.31% 0.01% (Szg+) (S3,os7) (58,171) (Srr1 (Su5,704) (518,332) (Srzs1 (9543) (563,257) (s831) (S72,8081 (Ssea1 (s1,768) ($al1 (0.00004s) (0.000047) (0.(xrc0s9) (0.0000s9) (0.00003s) (0.000031) (0.00003s) (0.m0u2) (0.000035) (0.000027) (0.00002s) (0.0000381 (0.(xxm42l (0.000074) (0.000030) (0.0s)% (0.0s)% 0.00% (0.0s)% (0.0s)% (0.0s)% (0.0s)% (0.0s)% (0.05)% (0.0s1% (0.0s)% 0.0096 (0.0s)% (0.0s)% (0.0s)% (0.0s)% (0.0s)% (0.0s)% (s2s5,s3s) (0.000047) (s2ou (o.oooo4s) 20 Total Special Contracts 21 Total ldaho Retail Sales Note: (1) June 01, 2OZZ - May 3L,7023 Forecasted Test Year (Spring 2022 Forecast) (2) 19S rate in column (F) set to match 95 rate due to sinSle customer movement between classes, s95,318 3 596,32r 13,920,071,569 7,O7L,974,663 L4,992,0r',6,332 S1,048,8s1,023 S47,8s0,839 s1,095,701,852 95.64% 4.36% 100.00% (ss43,9ss) (S24,815) (Ss58,77U (0.0s)% (0.0s)% (0,0s)% Exhibit No.4 Cass No. IPC-E-22-1 I Paqs 1 of 1