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HomeMy WebLinkAbout20230601Direct Griffin.pdf BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC SERVICE IN THE STATE OF IDAHO AND FOR ASSOCIATED REGULATORY ACCOUNTING TREATMENT. ) ))) )) CASE NO. IPC-E-23-11 IDAHO POWER COMPANY DIRECT TESTIMONY OF SARAH GRIFFIN GRIFFIN, DI 1 Idaho Power Company Q. Please state your name, business address, and 1 present position with Idaho Power Company (“Idaho Power” or 2 “Company”). 3 A. My name is Sarah Griffin. My business 4 address is 1221 West Idaho Street, Boise, Idaho 83702. I am 5 employed by Idaho Power as Vice President of Human 6 Resources (“HR”). 7 Q. Please describe your educational background. 8 A. I currently hold a Bachelor of Art degree in 9 English from the University of Utah, and an Executive 10 Master of Business Administration degree from Boise State 11 University. I have been a member of the Society for Human 12 Resource Management since 1997 and have held both the 13 Professional and Senior Professional certifications, 14 although these are no longer active. I was appointed to the 15 Idaho Personnel Commission in 2017 and the Idaho Workforce 16 Development Council in 2019 and have been reappointed to 17 both positions. 18 Q. Please describe your work experience with 19 Idaho Power Company. 20 A. I possess nearly 30 years of experience 21 working in HR, with over 15 years of experience in the HR 22 department at Idaho Power. Between 1996 and 2007, I served 23 various HR roles at Delta Dental, Thoratec Corporation, and 24 NPS Pharmaceuticals, culminating in my role as Corporate HR 25 GRIFFIN, DI 2 Idaho Power Company Manager at Boise Cascade. I began my employment with Idaho 1 Power in October 2007 as an HR Professional where my role 2 was to provide guidance to leaders in managing performance, 3 developing and delivering leader and employee training, and 4 conducting workplace investigations. Since my initial hire, 5 I have served in increasingly broad and expansive roles, 6 including HR Leader, HR Manager, and Director of HR, 7 ultimately moving into my current role of Vice President of 8 HR in October 2019. 9 Q. What is the purpose of your testimony? 10 A. The purpose of my testimony is to provide 11 justification for the labor and total compensation costs 12 included in the Company’s test year. I will describe the 13 Company’s overall compensation philosophy and explain why 14 the level of compensation requested in this case is 15 necessary to provide safe, reliable, affordable electricity 16 to customers. As part of this discussion, I will also 17 provide the justification for the requested increase in 18 cost recovery related to the Company’s pension plan, which 19 serves as a key component of Idaho Power’s overall 20 compensation package. 21 Q. How is the remainder of your testimony 22 organized? 23 A. My testimony consists of seven sections that 24 address the current labor market, the components of Idaho 25 GRIFFIN, DI 3 Idaho Power Company Power’s total compensation or “Total Rewards” package, and 1 how those components are determined. My testimony then 2 concludes with a summary of costs related to Total Rewards 3 included in the Company’s filing. 4 • Section I: Idaho Power’s Total Rewards 5 Philosophy 6 • Section II: Current Labor Market Challenges 7 • Section III: Base Wage Benchmarking 8 • Section IV: Incentive Compensation 9 • Section V: Benefits Benchmarking 10 • Section VI: Retirement Benefits 11 • Section VII: Total Rewards Costs in 2023 Test 12 Year 13 I. IDAHO POWER’S TOTAL REWARDS PHILOSOPHY 14 Q. Please provide a general discussion of Idaho 15 Power’s Total Rewards philosophy. 16 A. Idaho Power’s Total Rewards philosophy is to 17 provide a balanced, competitive, and sustainable total 18 compensation and benefits package, ensuring it attracts and 19 retains high-quality employees and motivates them to 20 achieve performance goals that benefit customers at a fair 21 and just cost. Maintaining a competitive Total Rewards 22 package allows the Company to recruit and retain a highly 23 skilled workforce that possesses a deep knowledge and 24 understanding of the complex energy business that builds 25 GRIFFIN, DI 4 Idaho Power Company and becomes more valuable as employees gain more experience 1 over time. The competitiveness of Idaho Power’s Total 2 Rewards package also supports the Company’s intent to 3 maintain a flexible workforce that can easily adjust work 4 duties and assignments to meet changing demands and 5 operational needs. In support of this philosophy, the 6 Company monitors its Total Rewards package, and adjusts it 7 accordingly in order to maintain a market-competitive total 8 compensation package. 9 Q. What are the components of Idaho Power’s Total 10 Rewards package? 11 A. The Total Rewards package is comprised of base 12 wages and “at-risk” incentive pay, as well as competitive 13 benefits programs including health and welfare, retirement 14 and other benefits. 15 Q. How often is the Company’s Total Rewards 16 package reviewed? 17 A. While certain components of the Company’s 18 Total Rewards package are reviewed annually, a 19 comprehensive benchmarking analysis that evaluates the 20 total cost of Idaho Power’s employee benefits (as a 21 percentage of pay) as compared to peer utility companies is 22 performed biennially. Table 1 below summarizes the 23 frequency of review for the various components of the 24 Company’s Total Rewards package, as well as the actions 25 GRIFFIN, DI 5 Idaho Power Company that are taken based on each review. I will describe each 1 of these review processes in greater detail later in my 2 testimony. 3 Table 1: Total Rewards Review Frequency by Component 4 Total Rewards Component Review Frequency Outcome Salary Structure Annually Benefits Programs Annually Compensation position every 5-7 years or adjustment, up or 5 Q. How does Idaho Power analyze whether it is 6 providing market-competitive compensation and benefits? 7 A. Idaho Power’s compensation benchmarking 8 process evaluates positions on an ongoing basis, with the 9 goal of a comprehensive review occurring approximately 10 every 5-7 years, particularly for positions that have a 11 significant number of incumbents, to ensure that Idaho 12 Power maintains market-competitive compensation levels and 13 remains an employer of choice. 14 Q. What data sources does Idaho Power rely on for 15 these analyses? 16 A. The Company uses a variety of data sources in 17 the compensation benchmarking process. Non-exempt1 trade 18 positions are typically benchmarked against intermountain 19 1 “Exempt” positions refer to non-hourly, salaried positions, while “non-exempt” positions are paid on an hourly basis. GRIFFIN, DI 6 Idaho Power Company utility peer contract data. The Company also participates 1 in and purchases data from Willis Towers Watson’s (“WTW”) 2 Energy Services Middle Management, Professional and Support 3 Compensation Survey to benchmark management, professional 4 exempt, office-based non-exempt, and other non-exempt 5 support roles. 6 Q. What is WTW and how does Idaho Power utilize 7 their survey data? 8 A. WTW is a nationally recognized HR consulting 9 firm, and the Energy Services Middle Management, 10 Professional and Support Compensation Survey is the most 11 widely used salary survey in the utility industry. WTW also 12 provides a biennial review of the cost to Idaho Power of 13 providing benefits (as a percentage of pay) compared to the 14 corresponding costs incurred by a peer group of “Energy 15 Services” and “General Industry” companies. Benefits 16 reviewed and benchmarked include health, retirement, and 17 other services, including time off and disability programs. 18 The Company utilizes WTW’s Benefits Online survey data and 19 benchmarking information from Idaho Power’s benefits 20 consulting firm, KPD, when reviewing benefit programs and 21 cost. 22 Q. How does the Company use the Total Rewards 23 benchmarking information to adjust employee compensation 24 and benefit offerings? 25 GRIFFIN, DI 7 Idaho Power Company A. The Company uses the Total Rewards 1 benchmarking information as the basis for decision-making 2 regarding salary structure adjustments, compensation grade 3 levels and appropriate benefit levels, with the goal of 4 aligning the overall employee total compensation with the 5 market. 6 Q. Does the Company believe that the benchmarking 7 review process for Total Rewards is an effective method for 8 establishing its compensation and benefit levels? 9 A. Yes. The Company believes that the review 10 process for Total Rewards has been successful in 11 maintaining a competitive, cost-effective Total Rewards 12 package that is in line with its industry peers, attracts 13 and retains a quality workforce, and ensures that labor 14 costs included in customer rates are fair, just, and 15 reasonable. 16 II. CURRENT LABOR MARKET CHALLENGES 17 Q. Please generally describe how the labor market 18 has changed since the Company filed its last general rate 19 case (“GRC”) in 2011. 20 A. The electric utility industry is changing at 21 a rapid pace, and along with it so are the needs and 22 expectations of Idaho Power’s employees. In the past, Idaho 23 Power’s compensation and benefits program has been 24 effective in recruiting and retaining talent. However, 25 GRIFFIN, DI 8 Idaho Power Company recently this has become more difficult, particularly for 1 employees with specialized or high-demand skills, and the 2 Company anticipates this trend will continue. In light of 3 these challenges, which I will describe in more detail 4 later in my testimony, ensuring the Company offers a 5 competitive Total Rewards package that emphasizes long-term 6 employment is increasingly important in order to attract 7 and retain a high-quality workforce. 8 Q. What factors have caused the labor market to 9 become more challenging since 2011? 10 A. Multiple factors have caused a paradigm shift 11 in the labor market since 2011. Primary factors impacting 12 Idaho Power have been increased competition for local 13 workers due to remote work options resulting from the 14 COVID-19 pandemic (“pandemic”), historic increases in 15 housing costs in Idaho Power’s service area, and the need 16 to hire and retain talent to operate in an increasingly 17 complex environment, exemplified by new processes such as 18 participation in the Energy Imbalance Market (“EIM”) and 19 more sophisticated resource modeling and planning within 20 the integrated resource planning (“IRP”) process. 21 Q. How did the pandemic impact the ability to 22 attract and retain qualified employees? 23 A. Due to mandatory remote working conditions 24 that resulted from the pandemic, many companies throughout 25 GRIFFIN, DI 9 Idaho Power Company the world transitioned to a higher percentage of full 1 remote or hybrid remote job offerings. While certain hands-2 on positions were less impacted by this change, many in-3 office positions in the Company saw a paradigm shift in the 4 labor market, which directly impacts Idaho Power’s ability 5 to attract and retain high-quality employees. 6 Rather than competing strictly in the local job 7 markets, Idaho Power is now competing for employees with 8 any company throughout the world that offers the ability to 9 work remotely, many of whom are paying wage rates that are 10 much higher and often reflective of those offered in much 11 larger cities. This impact – most acutely felt by 12 Information Technology (“IT”) and Cyber Security positions 13 – comes at a time when technology and security have grown 14 increasingly complex. 15 Q. Has Idaho Power’s workforce changed over the 16 last decade with respect to age and proximity to 17 retirement? 18 A. Yes. At the time of the Company’s last GRC, as 19 of December 31, 2011, approximately 39 percent of employees 20 were eligible to retire within five years while 43 percent 21 of employees had fewer than 10 years of service. As of 22 April 2023, the Company now has approximately 30 percent 23 eligible to retire within five years while more than half 24 GRIFFIN, DI 10 Idaho Power Company of the Company’s employees have fewer than 10 years of 1 service. 2 Q. How have housing costs in Idaho changed since 3 the Company filed its last GRC in 2011? 4 A. According to the most recent House Price Index 5 (“HPI”) Quarterly Report (Q4 2022) issued by the Federal 6 Housing Financing Agency (“FHFA”), Idaho leads the nation 7 in the five-year increase in housing prices, as 8 demonstrated in Figure 1 below. These elevated housing 9 prices serve as an additional hurdle to hiring employees 10 who do not currently reside within the area. 11 Figure 1. 12 Home Price Index Percent Changes, Q4 2022 13 14 Q. How do higher housing costs impact Idaho Power’s 15 ability to hire quality candidates? 16 58.4% 72.8% 104.0% 102.3% 0%20%40%60%80%100%120% USA Mountain Division Idaho Boise FHFA Home Price Index Percent Change in Housing Prices GRIFFIN, DI 11 Idaho Power Company A. For candidates external to Idaho Power’s 1 service area, housing costs serve as a key decision point 2 when evaluating whether to accept a job offer. While Idaho 3 Power prefers to and focuses on hiring locally, many 4 specialized positions require broader recruiting sources, 5 especially in light of the recruiting challenges detailed 6 previously in my testimony. Where Idaho Power was 7 historically able to market Idaho as high quality-of-life 8 and low cost-of-living compared to other states, the 9 historic increase in housing costs has degraded the 10 Company’s ability to market Idaho as low cost-of-living. 11 Q. How have changes in the electric utility 12 industry resulted in the need to hire and retain 13 specialized talent since the Company’s last general rate 14 case? 15 A. As discussed further in the Direct Testimony 16 of Company Witness Ms. Lisa Grow, Idaho Power’s business 17 has become increasingly complex for a number of reasons, 18 including unprecedented customer growth and changing 19 technology that requires talented, long-term employees to 20 operate and maintain. While I am not the Company’s 21 technical expert in these areas, from an HR perspective, 22 implementing and maintaining initiatives such as 23 participation in the EIM, the development of long-term 24 capacity expansion modeling for IRP and resource 25 GRIFFIN, DI 12 Idaho Power Company procurement purposes, and complex billing procedures for 1 increasingly prominent technologies such as rooftop solar 2 all impact Idaho Power’s labor needs. 3 Q. How have the challenges you described impacted 4 Idaho Power’s labor recruitment and retention? 5 A. The challenges above have led to increased 6 difficulty in hiring and retaining employees, as evidenced 7 by the Company’s time-to-fill open positions, the size of 8 qualified applicant pools, and the Company’s employee 9 turnover rates. 10 Q. What does the time-to-fill metric measure? 11 A. Time-to-fill measures the number of days it 12 takes to fill an open position, from the date a job 13 requisition is posted to the date a new hire accepts the 14 position. 15 Q. How have Idaho Power’s time-to-fill open 16 positions and the size of qualified applicant pools changed 17 in recent years? 18 A. The Company has experienced longer hiring 19 times in recent years, with a time-to-fill rate increasing 20 from an average of 38 days in 2019 to 43 days in 2022. 21 Although this change may appear small, the compounded 22 effects of a longer time-to-fill rate and smaller candidate 23 pools for job postings have impacted Idaho Power’s ability 24 to hire qualified candidates in a timely manner. 25 GRIFFIN, DI 13 Idaho Power Company Q. Can you provide some examples of the smaller 1 candidate pools for job postings, as indicated in the 2 previous response? 3 A. Yes. For example, Idaho Power’s external 4 Journeyman Lineworker postings received an average of 22 5 applicants in 2020 compared to fewer than six in 2022. For 6 more technical positions, this decrease has been even more 7 dramatic. The System Administrator positions that were 8 posted in 2020 had an average candidate pool size of 73, 9 while the same position posted in 2022 had an average 10 candidate pool size of fewer than nine. Further, Engineer 11 postings averaged over 50 candidates in 2020 compared to 12 fewer than 20 in 2022 13 Q. Are these hiring challenges unique to Idaho 14 Power? 15 A. No. In an article dated May 11, 2023, the 16 Idaho Press reported that the City of Boise is experiencing 17 similar hiring challenges and has a 10 percent vacancy 18 rate. The article further states that “in Idaho, there are 19 1.5 jobs per each available person.”2 20 Q. How has increased scarcity in candidate pools 21 impacted Idaho Power? 22 2 'Has not resolved itself': City of Boise still facing job vacancies | Local News | idahopress.com GRIFFIN, DI 14 Idaho Power Company A. Due to relatively limited candidate pools, the 1 Company has had to resort to hiring at an entry level for 2 many professional positions where someone with more 3 experience is needed to fill the position but there are no 4 or a limited number of candidates. This has particularly 5 been the case for technical positions where there were not 6 sufficient qualified applicants or the salary requirements 7 of qualified applicants could not be met. This results in 8 additional training resources and time to get candidates up 9 to speed in the position and makes retention of these 10 workers even more critical as they gain valuable knowledge 11 and experience. This further supports the need to emphasize 12 long-term retention in the Company’s Total Rewards package, 13 exemplified by the structure of the Company’s defined 14 benefit pension plan. 15 Q. How has the Company’s turnover rate changed as 16 a result of the current labor market? 17 A. The labor market forces detailed above have 18 resulted in increased turnover rates in recent years. The 19 overall voluntary turnover rate, which includes both 20 regular voluntary terminations and retirements, increased 21 by 49 percent from 2012 to 2022. The Company’s voluntary 22 turnover rate (excluding retirements) as of December 31, 23 2022 nearly doubled compared to prior to 2020. According to 24 exit interview data, 48 percent of these employees left the 25 GRIFFIN, DI 15 Idaho Power Company Company for more pay and/or additional advancement 1 opportunities. Furthermore, these statistics are not unique 2 to Idaho Power. Within the Idaho Press article referenced 3 previously, the City of Boise HR Director Sarah Borden 4 stated that last January “45 percent of non-retirees said 5 that either compensation or cost of living was driving them 6 to make this decision (to leave).”3 7 Q. Has Idaho Power experienced a corresponding 8 increase in declined job offers? 9 A. Yes. The number of declined offers more than 10 tripled from 2020 to 2022. The majority of these declined 11 offers were situations where either salary requirements 12 could not be met or there were competing offers that were 13 beyond what the Company could provide. 14 Q. How has Idaho Power responded to the changing 15 labor market and the challenges it presents? 16 A. In light of these challenges, Idaho Power has 17 modified its recruiting approach with the ultimate goal of 18 attracting and retaining a talented workforce while keeping 19 costs low for customers. First, where Idaho Power formerly 20 was able to rely solely on local sources for its job 21 postings, the Company has expanded its use of nationwide 22 job boards to help promote and target qualified candidates 23 and has attempted to source candidates through resumé 24 3 Id. GRIFFIN, DI 16 Idaho Power Company databases. Additionally, in the post-pandemic era in which 1 many job seekers prioritize remote work opportunities, 2 Idaho Power began offering hybrid work options for 3 qualified positions. 4 Q. How do these challenges impact the Company’s 5 Total Rewards philosophy? 6 A. Given these challenges, now more than ever, 7 offering an attractive Total Rewards package is crucial not 8 only for the hiring of high-quality employees, but for the 9 retention of employees as well. It is vital that Idaho 10 Power’s Total Rewards package can attract quality employees 11 who will serve as long-term productive members of the 12 Company’s workforce. Given challenges in hiring, it is even 13 more crucial that the Company’s Total Rewards package 14 incents long-term employment, highlighting the need for the 15 Company’s defined benefit pension plan that I will detail 16 later in my testimony. In its entirety, the setting of a 17 competitive Total Rewards package is crucial to the ability 18 of Idaho Power to cost-effectively maintain safe and 19 reliable service. Each component of the Total Rewards 20 package - Base Wages, Incentive Pay, Benefits, and Pension 21 – will be detailed in Sections III through VI of my 22 testimony, respectively. 23 III. BASE WAGE BENCHMARKING 24 Q. What are base wages? 25 GRIFFIN, DI 17 Idaho Power Company A. Base wages are the base level compensation an 1 employee receives as part of the Company’s Total Rewards. 2 For non-exempt employees, base wages are determined by an 3 hourly wage applied to hours worked, while for exempt 4 employees base wages reflect the employee’s annual base 5 salary. 6 Q. How does Idaho Power determine the market-7 based pay structure for a job? 8 A. Base compensation is established when a job is 9 created using peer utility wage data obtained from salary 10 surveys and union contracts, along with similar internal 11 positions already matched to market data. These reviews 12 typically involve at least three years of wage data to 13 ensure that compensation trends are considered and to 14 prevent frequent changes to position wages based on one to 15 two years of data. 16 In addition to market survey data, the job 17 evaluation process includes a review of the basic education 18 and experience requirements, physical requirements, and 19 behavioral competencies for the position. This proactive, 20 comprehensive review ensures the Company has accurate, 21 competitive, and safe job requirements and descriptions. 22 Q. Please describe the standard the Company uses 23 to set base wages. 24 GRIFFIN, DI 18 Idaho Power Company A. The Company has a grade and step pay system. 1 The highest step in any grade is step 13. Each position is 2 assigned a grade as reflective of the market, and the 3 Company standard for remaining competitive is to set the 4 step 13 pay of each grade to be approximately equal to the 5 median pay for a comparable position in the peer-compared 6 market. Targeting the median of market pay is a 7 compensation-setting best practice. It is a conservative 8 approach that allows Idaho Power to manage costs while 9 ensuring the Company is able to provide competitive pay 10 within the grade and step system. 11 Q. How does Idaho Power ensure its base wages do 12 not exceed the market median over time? 13 A. On an annual basis, the Company reviews a 14 variety of data to determine the appropriate General Wage 15 Adjustment (“GWA”) to remain competitive. The Company 16 reviews market survey data from WTW and peer utility 17 contracts, the Consumer Price Index (“CPI”), and other 18 economic data that ultimately informs the recommendation to 19 the Board of Directors for the Company’s GWA. On a longer-20 term basis, Idaho Power performs a comprehensive job review 21 for individual positions to ensure base wages are 22 competitive and appropriate relative to market. 23 Q. Has the Company’s job review process evolved 24 since the last GRC? 25 GRIFFIN, DI 19 Idaho Power Company A. Yes. The Company’s 2011 base wage and total 1 compensation benchmarking analysis focused on five specific 2 positions.4 The information and resulting decisions 3 regarding compensation levels were then used to inform 4 decisions for a broader set of jobs with similar functions 5 referred to as a job category or “job family.”5 6 In 2017, the Company developed a process to expand 7 this review from five specific positions and their 8 associated “job family” to performing a review of all jobs 9 on an ongoing proactive basis. This is in addition to the 10 practice of reviewing jobs when there are significant 11 changes in job responsibilities or market conditions 12 resulting in challenges for the Company in recruiting 13 and/or retaining the talent necessary to provide safe, 14 reliable, and affordable energy to customers. 15 Q. Please generally describe the current job 16 review process. 17 A. Positions are evaluated using market data from 18 third-party salary surveys, primarily from WTW. The Company 19 relies on data specific to the energy services industry, 20 with a focus on information from companies with comparable 21 levels of annual revenue and regulation. Where appropriate, 22 4 These five positions represented approximately 11 percent of the total employees at Idaho Power in 2011 and 2012. 5 The combined number of employees in each of the selected jobs represented approximately 22 percent of the total workforce in 2011 and 2012. GRIFFIN, DI 20 Idaho Power Company peer utility contracts are also reviewed along with similar 1 internal positions. The Company also reviews job postings 2 of peer utilities. 3 Q. Has the Company made progress in reviewing all 4 jobs at Idaho Power using this job review process? 5 A. Yes. While the job review process slowed in 6 2020 due to the impact of the pandemic on the Company’s 7 workforce and HR staff, Idaho Power is currently 8 progressing through its full review of all positions within 9 the Company. The table below shows the number of jobs that 10 have been reviewed since implementing this new process in 11 2017. When this program was implemented, the Company 12 focused first on jobs with the highest number of 13 incumbents, rather than smaller or single incumbent 14 positions. 15 Figure 2. 16 Job Review Completion Progress, 2017 – Current 17 18 Job Review Completion Progress Complete In Progress Remaining GRIFFIN, DI 21 Idaho Power Company As of 2023, there are 665 total distinct jobs in the 1 Company. Of those, reviews for 417 are complete, 4 are in 2 progress, and 244 remain. 3 Q. What changes have occurred as a result of the 4 Company’s broader job review? 5 A. As shown in the chart below, the majority of 6 the jobs reviewed were on-market, indicating that Idaho 7 Power’s wage-setting process is functioning as intended. 8 For jobs that were found to be above market, employees are 9 placed into a reduction-in-grade program that brings them 10 into alignment with the lower rate of the new reduced grade 11 of the position. When positions are determined to be below 12 market, the incumbents are generally moved to the 13 equivalent step of the position’s new grade. 14 Figure 3. 15 Comprehensive Job Review Results by Category 16 17 0%10%20%30%40%50%60%70% Above Market Below Market On Market Job Review Results by Category GRIFFIN, DI 22 Idaho Power Company Q. What has been the recent trend for wages and 1 salaries in the marketplace? 2 A. Data indicates that wages and salaries are 3 generally increasing in the marketplace. The Company 4 reviews several factors to determine appropriate increases 5 based on what is trending in the market, including salary 6 budget surveys, union contract negotiations, and cost-of-7 living and economic factors. 8 Q. Have you observed any recent trends in salary 9 budget surveys and union contract negotiations? 10 A. Yes. Recent salary survey projections for 11 merit and salary structure movement showed an increase over 12 prior years. Union contract annual adjustments, as well as 13 market adjustments for many positions were negotiated at an 14 all-time high, with several peer utilities granting 15 increases in the double digits for certain roles. As shown 16 in Table 2 below, first year contract wage increases for 17 lineman ranged from 7-18 percent. 18 Table 2: Peer Utility Wage Increases for Lineman 19 Northwest Peer Utilities Old Hourly Rate 1,2 New Hourly Rate1,3 Avista $48.63 $55.39 13.90% Northwestern $48.24 $51.94 7.70% NV Energy $52.38 $62.18 18.70% Pacific Power $48.91 $56.03 14.60% Rocky Mountain Power $49.29 $54.40 10.40% 1) All data collected from publicly available job postings or union contracts 20 2) Hourly rate effective final year of old union contract 21 3) Hourly rate effective first year of new union contract 22 23 GRIFFIN, DI 23 Idaho Power Company Q. Have you observed any changes in cost-of-1 living and economic factors impacting employee 2 compensation? 3 A. With respect to cost-of-living and economic 4 factors, CPI indicates a continued upward trend through 5 2022, as indicated in Table 3 below, with inflation spiking 6 in 2021 and 2022 relative to prior years. In 2022 alone, 7 CPI in the Mountain Division CPI-U (“Urban”) increased 9.6 8 percent. 9 Table 3: Consumer Price Index, 2018–2022 10 Consumer Price Index – CPI-U (12 mo. Change 2018 2019 2020 2021 2022 Average US City Average 2.30% 1.70% 1.40% 5.40% 8.20% 3.80% West (Includes AK, AZ, CA, CO, HI, ID, MT, NV, 3.40% 2.60% 1.60% 5.30% 8.30% 4.20% 2.80% 2.30% 2.00% 5.70% 8.30% 4.20% (Includes AZ, CO, ID, n/a 2.90% 1.80% 6.00% 9.60% 5.10% 11 As discussed earlier in my testimony, housing prices 12 have increased at a historic rate in Idaho. This is further 13 evidenced in Table 4 below, which shows a 37.06 percent 14 increase in housing costs in 2021, and a 19.13 percent 15 increase in 2022. 16 // 17 // 18 19 20 GRIFFIN, DI 24 Idaho Power Company Table 4: Home Price Index, 2018-2022 1 Home Price Index 2018 2019 2020 2021 2022 2 Q. What is the result of the Company’s general 3 wage benchmarking process in light of these recent trends, 4 and how does this impact the base wage levels reflected in 5 the Company’s filing? 6 A. Since the filing of the Company’s last GRC, 7 Idaho Power has adjusted base wages through annual GWAs, as 8 well as the comprehensive job review process described 9 previously in my testimony. This approach ensures that the 10 Company’s base wages are regularly reviewed, resulting in 11 competitive market-based rates that effectively balance 12 Idaho Power’s ability to attract and retain a quality 13 workforce while keeping costs low for customers. Idaho 14 Power’s annual GWA process has assisted the Company in 15 keeping pace with recent market trends, while the position-16 by-position review has indicated that Idaho Power’s base 17 wages are competitive relative to market for the majority 18 of positions. 19 As shown in the Figure 3 above, for a small 20 proportion of reviewed positions, up or down adjustments 21 have been applied in the event the comprehensive review 22 GRIFFIN, DI 25 Idaho Power Company indicated an adjustment was warranted. The graph also shows 1 that the number of positions that experienced wage 2 decreases is very similar to the number of positions that 3 experienced wage increases, indicating that on average the 4 Company’s benchmarking process is functioning as intended. 5 This process, combined with the market forces 6 described earlier in my testimony, results in total 7 operations and maintenance (“O&M”) base wage costs included 8 in the 2023 test year of $133.7 million. Company Witness 9 Mr. Matthew Larkin discusses the 2023 test year O&M labor 10 forecast in more detail in his testimony. 11 IV. INCENTIVE COMPENSATION 12 Q. What is incentive pay? 13 A. Incentive pay is an “at-risk” part of Idaho 14 Power’s Total Rewards package that is awarded based on 15 performance goals established by the Compensation Committee 16 of the Company’s Board of Directors. Unlike base pay, which 17 is guaranteed, incentive pay will not be paid unless the 18 Company’s performance meets or exceeds predetermined 19 metrics. 20 Q. How is Idaho Power’s incentive pay designed? 21 A. Idaho Power’s incentive plan consists of three 22 components: 1) an electrical network reliability goal, 2) a 23 customer satisfaction goal, and 3) a profit-sharing goal 24 GRIFFIN, DI 26 Idaho Power Company based on net income. The intent of the plan is to focus on 1 key areas where employees can have an impact. 2 Q. Please generally describe the incentive 3 metrics. 4 A. The three metrics are intended to motivate 5 employee performance in ways that positively impact 6 customers. The network reliability goal considers the 7 frequency and duration of customer outages. The customer 8 satisfaction goal is based on the 12-month average of the 9 customer relationship index (“CRI”), which details the 10 Company’s performance through the eyes of the customer. The 11 CRI consists of five specific questions asked of Idaho 12 Power’s customers by an independent survey company and 13 addresses issues such as overall satisfaction, quality, 14 value, advocacy, and loyalty. The profit-sharing component 15 is based on achievement against financial targets, 16 motivating employees to work toward the financial health of 17 Idaho Power, which is necessary to provide safe, reliable, 18 and affordable service. 19 Each component has an identified threshold, target, 20 and maximum, or in other words, a low, medium, and high 21 level of payout based on actual results compared to 22 predetermined metrics. The payout levels are set each year 23 by the Board of Directors to ensure they continue to 24 stretch employee performance in service of customers. 25 GRIFFIN, DI 27 Idaho Power Company Q. Which components of the Company’s incentive 1 plan are included in the Company’s 2023 test year? 2 A. Consistent with prior Commission direction,6 3 Idaho Power has only included the components of incentive 4 pay that the Commission has determined are directly related 5 to identifiable customer benefits, which in this case are 6 network reliability and customer satisfaction. These 7 components are included in the test year at the 2 percent 8 target (medium) incentive level. Idaho Power has excluded 9 any costs related to the profit-sharing component. 10 Q. Has Idaho Power excluded any other components 11 of its incentive pay from its request in this case? 12 A. Yes. Idaho Power has excluded executive 13 incentive pay. This is consistent with Commission treatment 14 of these costs in prior ratemaking proceedings. 15 Q. What is the Company requesting in this case 16 with regard to incentive-related costs? 17 A. As discussed by Mr. Larkin, incentive pay 18 totaling $10.2 million related to the customer satisfaction 19 and reliability components is included in the 2023 test 20 year. 21 V. BENEFITS BENCHMARKING 22 Q. What is Idaho Power’s benefits strategy? 23 6 IPC-E-08-10, Order No. 30722 at 17. GRIFFIN, DI 28 Idaho Power Company A. Idaho Power strives to offer its employees a 1 comprehensive and competitive package of health and 2 welfare, retirement, and insurance benefits programs. As 3 with base compensation and at-risk pay, it is important for 4 the Company to offer a cost-competitive benefits package 5 with features that address the needs of employees and is 6 sufficient to attract and retain well-qualified and skilled 7 employees. As discussed previously in my testimony, 8 benefits that incent long-term employment are crucial in 9 today’s environment. 10 Q. What are the major components of Idaho Power’s 11 benefits package? 12 A. Major components of Idaho Power’s benefits 13 package include health and welfare benefits (medical, 14 prescription, dental, and vision programs), other benefits 15 (disability, life insurance, and flexible time off), and 16 retirement benefits. 17 Q. Does Idaho Power benchmark its total benefits 18 and compare overall benefit costs? 19 A. Yes. The Company monitors its benefit programs 20 on an ongoing basis to ensure the appropriate balance 21 between benefit cost and maintaining a competitive position 22 in the market. 23 Q. What is Idaho Power’s annual benefits 24 benchmark review process? 25 GRIFFIN, DI 29 Idaho Power Company A. On an annual basis, Idaho Power utilizes 1 benchmarking data from WTW’s Benefits Online and the Health 2 Care Financial Report, KPD’s regional and national survey 3 data, and peer utility contracts to address the Company’s 4 benefit plan’s overall cost, offerings, and market 5 competitiveness. For example, medical, dental, and vision 6 premiums are evaluated and generally adjusted each year. 7 Further, the medical plan’s cost-sharing balance target is 8 20 percent employee and 80 percent employer (which is 9 competitive with peer utilities) and annual rates are 10 evaluated and adjusted to align with this target 11 percentage. The results of this review are presented 12 annually to the Board of Directors Compensation Committee 13 and are generally implemented the following year. 14 Q. How does Idaho Power benchmark longer-term 15 benefits? 16 A. Every other year, Idaho Power participates in 17 WTW’s Energy Services “BENVAL" Study. BENVAL is a 18 comparison of benefit values among peer utilities with 19 similar revenues. BENVAL provides a complete competitive 20 analysis of the value of a benefit program, including a 21 comparison of the Company’s benefit plan against utility 22 companies of similar sizes. Benefit plan design that 23 affects medical costs can vary greatly, so BENVAL gathers 24 all relevant information related to a company’s healthcare 25 GRIFFIN, DI 30 Idaho Power Company and other benefit plan offerings in order to accurately 1 benchmark them against other peers. For consistency of 2 comparison, the results of the study are typically 3 presented as benefits costs as a percentage of pay. 4 In addition to the Energy Services BENVAL study, the 5 Company also contracts WTW to create a custom BENVAL study 6 that uses all industry survey data and provides an in-depth 7 peer utility comparison of the Company’s health and welfare 8 and retirement benefits design. This information is 9 included in the Company’s analysis of its Total Rewards 10 package and is provided to Idaho Power’s Board of Directors 11 Compensation Committee. The results of this report are used 12 to broadly evaluate the total value and cost of the 13 Company’s benefits and market competitiveness. 14 Q. What is Idaho Power’s peer group in the BENVAL 15 study? 16 A. Idaho Power’s BENVAL peer group consists of 17 upwards of 34 similarly situated energy services companies 18 across the nation, as well as a subset of utility companies 19 of similar size. In 2021, there were 663 All Industry 20 companies included in the analysis, as detailed in Table 5 21 below. 22 // 23 // 24 25 GRIFFIN, DI 31 Idaho Power Company Table 5: BENVAL Survey Participant Composition, 2017-2021 1 Year All Industry Energy 2 Q. According to the most recent BENVAL study, how 3 do Idaho Power’s total benefit costs compare to its energy 4 peer group? 5 A. As can be seen in Figure 4 below, the value of 6 Idaho Power’s total benefits package (health, retirement, 7 and other benefits) for the most recent studies show that 8 Idaho Power’s benefit ratio to pay is 36.3 percent while 9 the Company’s peers are 35.9 percent -- relatively the same 10 total benefit ratio. It is important to note that Idaho 11 Power manages its benefits package as a whole and the 12 BENVAL survey is a useful tool that ensures that the 13 Company’s combined benefit offerings as a percent of pay 14 remain at market even though each component may differ in 15 the peer group. As can be seen in the chart below, Idaho 16 Power’s benefit costs as a percentage of pay are generally 17 consistent with the energy industry. 18 // 19 // 20 21 22 23 GRIFFIN, DI 32 Idaho Power Company Figure 4. 1 Composite BENVAL Results: 2017, 2019, 2021 2 3 4 Q. What benefit cost trends can be seen from the 5 recent BENVAL survey results? 6 A. A review of the data from the 2017, 2019, and 7 2021 studies shows that total benefit costs are rising 8 across the board. As indicated in the prior figure, 9 percentage of pay has increased between surveys from 2017, 10 2019, and 2021. These trends, coupled with the increase in 11 CPI and overall wages discussed earlier in my testimony, 12 indicate that the costs of maintaining a market-competitive 13 benefits package are increasing over time. 14 Q. What has been the Company’s approach to 15 managing rising health and welfare care costs? 16 A. The Company is continually evaluating trends 17 and actively working with KPD and associated third-party 18 0% 5% 10% 15% 20% 25% 30% 35% 40% 2017 2019 2021 Benefit Costs as a Percent of Pay IPC Energy All Industry GRIFFIN, DI 33 Idaho Power Company administrators on strategies to manage overall healthcare 1 costs. These strategies include prescription benefits and 2 formularies, conservative care strategies, case management, 3 medical policy review, and telemedicine. In addition, there 4 is ongoing vendor evaluation and management to ensure the 5 Company is getting the best service at the lowest cost. 6 Q. Given the upward pressure on health and other 7 benefit costs, what is Idaho Power doing to ensure its 8 total benefit costs remain in line with the market? 9 A. The Company continues to benchmark benefit 10 program offerings and costs on an annual basis to ensure 11 its offerings remain in line with market. 12 Q. Are there any final conclusions that can be 13 drawn from the benefits benchmarking information you have 14 provided? 15 A. Yes. As demonstrated by the BENVAL results 16 provided in my testimony, Idaho Power’s total benefits 17 offered as a percentage of pay are in line with the peer 18 utilities, indicating the Company’s benefits package and 19 its underlying benchmarking process are functioning as 20 intended. Additionally, given the labor market challenges 21 discussed throughout my testimony, Idaho Power believes it 22 is prudent to more heavily weight its benefits package 23 toward components that incent long-term employment (i.e., 24 retirement benefits). In light of recent trends in rising 25 GRIFFIN, DI 34 Idaho Power Company costs, Idaho Power has actively managed the costs of its 1 benefit programs while simultaneously ensuring its 2 offerings are competitive, to support the hiring and 3 retention of long-term, quality employees. 4 Q. What is the Company requesting in this case 5 with regard to benefits-related costs? 6 A. The O&M benefits-related costs (excluding 7 pension) included in the 2023 test year are approximately 8 $68.1 million. 9 VI. RETIREMENT BENEFITS 10 Q. What are the components of the Company’s 11 retirement benefits package? 12 A. The Company's retirement benefits package 13 includes three components: (1) a defined contribution or 14 401(k) benefit plan, (2) a defined benefit (pension) plan, 15 and (3) a retiree medical benefit plan. 16 Q. Why are retirement benefits important? 17 A. The retirement benefits package is a 18 significant part of the overall Total Rewards desired by 19 employees that have a long-term view of their employment 20 future. As discussed earlier in my testimony, changes in 21 the labor market have made the hiring of quality, 22 experienced employees more difficult, which is exacerbated 23 by the shift to a younger, more transient workforce. 24 GRIFFIN, DI 35 Idaho Power Company Because of this, retirement benefits that encourage long-1 term employment are more important than ever. 2 Consistent with the high value the electric industry 3 places on long-term planning and reliability, Idaho Power 4 likewise values employees with a long-term perspective as 5 part of its highly skilled workforce. In structuring a 6 retirement benefits package as part of its Total Rewards, 7 the Company strives to have a competitive package that 8 supports employees' financial needs in retirement while 9 appropriately sharing market risk between the Company and 10 its retirees. 11 Q. What is the Company requesting in this case 12 with respect to defined benefit pension plan expense? 13 A. As discussed further in Mr. Larkin’s 14 testimony, the Company seeks approval of $35 million of 15 Idaho jurisdictional pension cost amortization. 16 Q. Why is the defined benefit plan so important 17 to the Company and its employees? 18 A. The Company has placed additional weight in 19 its Total Rewards package on the defined benefit plan 20 because it rewards and incents longevity, which in turn 21 facilitates reduced employee development costs due to the 22 retention of knowledge and expertise. As a result, the 23 Company is able to better maintain the needed skilled 24 GRIFFIN, DI 36 Idaho Power Company workforce with less time and expense incurred for training 1 and developing new employees. 2 Q. What changes have been made to Idaho Power’s 3 retirement plans? 4 A. The Company's retirement benefits package has 5 evolved over the years. Prior to 1984, the Company had just 6 two components to its retirement benefits package: (1) a 7 defined benefit plan, and (2) a retiree medical benefit 8 plan. 9 In 1984, the Company adjusted the overall retirement 10 benefits package to include the third component of a 401(k) 11 benefit plan. With the addition of this component in 1984 12 and adjustment to the other components, the Company has 13 shifted portions of the overall package cost and benefit 14 risks to retirees in order to maintain a competitive risk 15 sharing balance between the Company and retirees. 16 Simultaneously with the inclusion of a 401(k) component of 17 the retirement benefits package, the Company eliminated 18 cost of living adjustments as part of its defined benefit 19 component, thus shifting inflationary market risk to 20 retirees. 21 In 1999, the Company further reduced its 22 inflationary market risk by: (1) capping the Company 23 contribution expenditures toward retiree medical plan costs 24 for employees hired prior to 1999, and (2) eliminating 25 GRIFFIN, DI 37 Idaho Power Company Company contributions toward retiree medical plan costs for 1 employees hired in or after 1999. 2 In 2010, the Company reduced the current defined 3 benefit percentage factor for employees hired on or after 4 January 1, 2011, to 1.2 percent per year from the previous 5 factor of 1.5 percent per year. 6 Q. Why does the Company continue to offer a 7 defined benefit plan when many of its peers have closed 8 their defined benefit plan offerings to new entrants and 9 transitioned to alternative retirement plan options such as 10 enhanced defined contribution plans or 401(k) plans? 11 A. On an ongoing basis, the Company considers 12 alternatives that could provide similar retiree benefits, 13 including retention incentives, but continues to find the 14 defined benefit plan is the least-cost way to provide 15 retirement benefits as part of the Company’s Total Rewards 16 package for employees, which I will address in more detail 17 later in my testimony. The Company also believes the 18 defined benefit plan rewards and incents longevity, which 19 in turn facilitates retention of essential knowledge and 20 expertise in the Company’s employees and reduces 21 development and training costs due to turnover, ultimately 22 resulting in savings for customers. 23 GRIFFIN, DI 38 Idaho Power Company Q. Why does the Company’s defined benefit plan 1 better promote retention relative to a defined contribution 2 plan? 3 A. When an employee separates from the Company 4 before retirement, the defined benefit is frozen and the 5 former employee will not earn any additional benefit from 6 the plan, nor will the value of the earned benefits 7 continue to grow. For a defined contribution plan such as 8 an enhanced 401(k), the result for an employee who 9 separates from the Company before retirement is the 10 opposite of the Company’s defined benefit plan. The growth 11 of a former employee’s 401(k) benefit for work already 12 performed is unaffected by whether they stay with the 13 Company. 14 To state the distinction between the two plans more 15 concisely: a defined pension participant’s already-earned 16 benefits only grow due to staying with the Company and do 17 not grow after separation, while a 401(k) participant’s 18 already-earned benefits at separation from the Company will 19 grow at the same amount as they would have if they had 20 continued employment with the Company due to the growth in 21 the underlying investments. Due to these differences, only 22 the Company’s defined pension plan provides an incentive to 23 remain employed at Idaho Power. 24 GRIFFIN, DI 39 Idaho Power Company Q. How do defined contribution and defined 1 benefit plans differ with regard to plan costs if employees 2 choose to separate from Idaho Power within the first five 3 years of employment? 4 A. Under Idaho Power’s defined benefit plan, if 5 an employee separates before they reach five full years of 6 service they will not be vested in the plan and the 7 separated employee will leave the Company with no pension 8 benefits, which ultimately results in no cost to customers. 9 The highest voluntary turnover rate at Idaho Power is the 10 0-to-5-year group, which results in lower costs for 11 customers from the defined benefit plan compared to other 12 options. Alternately, a defined contribution plan is 13 portable and is required to vest more quickly, so an 14 employee separating from the Company essentially owns the 15 investments, including any Company contribution once 16 vested. Therefore, this would result in higher costs to 17 customers compared to the defined benefit plan if the 18 employee chooses to separate from the Company. 19 To compound this issue, as previously stated in my 20 testimony, there is less incentive to stay with Idaho Power 21 under the defined contribution plan because at the time of 22 separation the investment will continue to grow over time, 23 which matches the pattern that would occur if the employee 24 were to remain employed by the Company. So, under the 25 GRIFFIN, DI 40 Idaho Power Company defined contribution plan, there is less incentive for an 1 employee to stay with Idaho Power long-term, while there is 2 more potential harm to customers in terms of elevated labor 3 costs if the employee chooses to separate within five years 4 of service. 5 Q. Does offering a defined benefit plan cause 6 additional costs for Idaho Power’s customers compared to a 7 defined contribution plan? 8 A. No – the opposite is true. Over the career of 9 an employee, the cost for providing a defined contribution 10 benefit that is roughly the equivalent of a defined benefit 11 plan is more expensive. 12 Q. Has Idaho Power procured an analysis that 13 details the comparative long-term costs and benefits of 14 these plans? 15 A. Yes. Idaho Power asked its third-party 16 actuary, Milliman, to prepare an analysis comparing one of 17 Idaho Power’s Northwest regional peer’s recently negotiated 18 retiree benefit program with its union. Under this plan, 19 the utility will offer new hires after December 31, 2023, 20 an enhanced defined contribution plan that roughly provides 21 the equivalent income replacement to Idaho Power’s current 22 1.2 percent defined benefit plan and defined contribution 23 plan to those that work at the company until age 65. The 24 results of this analysis show the financial cost over the 25 GRIFFIN, DI 41 Idaho Power Company career of a new employee to be roughly 40 percent higher 1 under the enhanced 401(k) plan to provide for the same 2 level of benefits as shown in the following table. 3 Table 6: Employer Cost for Benefit Plans – 4 as a percentage of total pay (salary + bonus) 5 Idaho Power NW Peer Utility * Based on a hire age of 32, bonus percentage of 6%, and defined contribution investment returns of 6.5% pre-retirement and 5% post retirement 6 Q. Did Idaho Power Perform any analysis in 7 addition to Milliman’s enhanced 401(k) plan comparison? 8 A. Yes. In addition to the enhanced 401(k) plan 9 comparison, Idaho Power asked Milliman to re-perform a 10 similar analysis but with actual data as presented in the 11 Company’s last pension-related case (Case No. IPC-E-10-25). 12 The analysis provided by the Company in that case indicated 13 that under a range of economic conditions and investment 14 return scenarios that could occur over a nine-year period, 15 the Company’s defined pension plan was the lowest cost 16 retirement plan option relative to a defined contribution 17 plan. After reviewing this analysis, the Commission 18 accepted Idaho Power’s 2011 retirement benefits package in 19 Order No. 32239. 20 GRIFFIN, DI 42 Idaho Power Company To refresh this analysis, Milliman evaluated all new 1 employees hired after Idaho Power reduced the defined 2 benefit percentage factor for employees hired on or after 3 January 1, 2011, to 1.2 percent per year from the previous 4 factor of 1.5 percent. Milliman compared the costs incurred 5 for those employees for the Company’s current defined 6 benefit plan to a defined contribution plan that provides 7 the same estimated income replacement for employees that 8 work at Idaho Power until retirement, with the goal of 9 resulting in the same total retirement benefits for each of 10 those employees hired from January 1, 2011, through 11 December 31, 2022. 12 Q. What was the result of the analysis performed 13 by Milliman? 14 A. Looking at actual Idaho Power employees that 15 were hired on or after January 1, 2011, through December 16 31, 2022, the current defined benefit plan saved an 17 estimated $36 million in required contributions when 18 compared to the modeled cost of the defined contribution 19 plan. 20 Q. What are the primary reasons for these cost 21 savings? 22 A. There are two primary reasons for the 23 difference: 1) asset returns, and 2) differences in 24 termination benefits. 25 GRIFFIN, DI 43 Idaho Power Company Q. How did expected asset returns differ between 1 defined benefit and defined contribution plans? 2 A. The asset return for the defined benefit plan 3 was assumed to be 7.4 percent, while the defined 4 contribution plan was assumed to earn 6.5 percent during 5 employment and 5 percent during retirement. The defined 6 benefit plan is professionally managed with access to a 7 larger universe of investments, including private illiquid 8 investments that cannot be utilized in a defined 9 contribution plan. 10 In addition, the defined benefit plan can 11 consistently invest for the long-term, resulting in a 12 higher expected long-term rate of return, whereas a defined 13 contribution participant typically chooses to de-risk their 14 investments prior to retirement to avoid short-term market 15 risk. Participants, therefore, typically respond by 16 reducing risk and earnings potential while leading up to 17 and living in retirement. This reduced earnings potential 18 reduces the efficiency of a defined contribution plan as 19 compared with a defined benefit plan and also increases 20 costs to customers. In addition, the defined contribution 21 participant does not have the benefit of sharing longevity 22 risk with all of the other plan participants, so 23 participants will need to save more money prior to 24 retirement. 25 GRIFFIN, DI 44 Idaho Power Company Q. How do differences in termination benefits 1 cause the defined benefit plan to be less expensive? 2 A. In Idaho Power’s defined benefit plan, 3 employees are not vested in their benefit until they work a 4 full five years with the Company. Defined contribution 5 plans are required by law to have faster vesting schedules. 6 For the comparison prepared for Idaho Power, Milliman used 7 a three-year vesting assumption, which is the maximum cliff 8 vesting allowed by law for a defined contribution plan. 9 The Milliman study confirmed what the Company 10 testified would happen in 20107 and also validated the 11 conclusions reached by the Commission in Order No. 32239. 12 This study confirms that defined contribution plans are 13 more expensive than defined benefit plans in achieving 14 similar levels of benefits. As demonstrated by the Milliman 15 studies, Idaho Power’s defined benefit pension plan will 16 continue to save customers money going forward compared to 17 an enhanced defined contribution plan. 18 Q. What is the requested level of cost recovery 19 associated with pension expense in this case? 20 A. Mr. Larkin quantifies and details the 21 requested level of pension-related cost recovery at $35 22 million. 23 7 Id. GRIFFIN, DI 45 Idaho Power Company Q. Do you believe the Company’s current defined 1 benefit plan is in the best interest of the Company, its 2 employees, and customers? 3 A. Yes. Idaho Power’s defined benefit plan serves 4 as a key component of its Total Rewards package. As 5 discussed throughout my testimony, labor recruitment and 6 retention has experienced significant challenges in recent 7 years, and these trends are expected to continue. A defined 8 benefit plan that not only rewards employees at an 9 appropriate level, but does so while encouraging long-term 10 employment, benefits the Company and customers through the 11 retention of a highly skilled workforce and avoided costs 12 associated with hiring, onboarding, and training. 13 VII. TOTAL REWARDS COSTS IN 2023 TEST YEAR 14 Q. What are the expected Total Reward costs for 15 the 2023 test year? 16 A. As shown in Table 7 below, the cost for the 17 Company’s Total Rewards in the 2023 test year is 18 approximately $247.2 million. This is comprised of $133.7 19 million in O&M wages, $68.1 million for O&M benefits, $10.2 20 million for incentive, and $35.2 million for pension. The 21 test year labor costs are discussed more fully in Mr. 22 Larkin’s testimony. 23 // 24 // 25 GRIFFIN, DI 46 Idaho Power Company Table 7: Total Reward Costs – 2023 Test Year 1 Total Reward Component 2023 Test Year O&M Wages* $ 133.7 O&M Benefits* $ 68.1 Incentive $ 10.2 Pension $ 35.2 Total $ 247.2 * Includes DSM wages and benefits 2 Q. What has the Company done to manage its Total 3 Rewards costs since the last GRC? 4 A. As discussed in the testimony of Ms. Grow, the 5 Company manages its labor budget carefully, requiring the 6 vice president responsible for each business unit to 7 approve of unbudgeted positions. This careful management of 8 labor costs is evidenced by the fact that even with adding 9 approximately 117,000 customers between 2012 and 2022, 10 employee headcount has decreased by a total of 17 people 11 over the same period. 12 Furthermore, the Company actively manages labor 13 costs by benchmarking each component of its Total Rewards 14 package to make sure it is competitive with the market and 15 makes adjustments when necessary, while balancing its Total 16 Rewards package to ensure it can attract and retain high-17 quality employees and motivate them to achieve performance 18 goals that benefit customers and shareholders. 19 // 20 GRIFFIN, DI 47 Idaho Power Company Q. Does this conclude your direct testimony in 1 this case? 2 A. Yes, it does. 3 // 4 // 5 6 GRIFFIN, DI 48 Idaho Power Company DECLARATION OF SARAH GRIFFIN 1 I, Sarah Griffin, declare under penalty of perjury 2 under the laws of the state of Idaho: 3 1. My name is Sarah Griffin. I am employed by 4 Idaho Power Company as Vice President of Human Resources. 5 2. To the best of my knowledge, my pre-filed 6 direct testimony is true and accurate. 7 I hereby declare that the above statement is 8 true to the best of my knowledge and belief, and that I 9 understand it is made for use as evidence before the Idaho 10 Public Utilities Commission and is subject to penalty for 11 perjury. 12 SIGNED this 1st day of June 2023, at Boise, Idaho. 13 14 Signed: ___________________ 15 Sarah Griffin 16 17 18 19 20 21 22 23