20230601Direct Maloney.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.
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CASE NO. IPC-E-23-11

IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
RILEY MALONEY
MALONEY, 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 Riley Maloney. My business address 4
is 1221 West Idaho Street, Boise, Idaho 83702. I am 5
employed by Idaho Power as a Regulatory Analyst in the 6
Regulatory Affairs Department. 7
Q. Please describe your educational background. 8
A. I received a Bachelor of Arts degree in 9
Economics from Boise State University in 2013. I have also 10
attended “The Basics: Practical Regulatory Training for the 11
Electric Industry,” an electric utility ratemaking course 12
offered through the New Mexico State University’s Center 13
for Public Utilities, “Electric Utility Fundamentals and 14
Insights,” an electric utility course offered by Western 15
Energy Institute, and “Electric Rates Advanced Course,” an 16
electric utility ratemaking course offered through Edison 17
Electric Institute. 18
Q. Please describe your work experience with 19
Idaho Power. 20
A. In 2020 I was hired as a Regulatory Analyst in 21
the Company’s Regulatory Affairs Department. My primary 22
responsibilities include supporting activities involving 23
tariff administration and regulatory compliance filings. I 24
provide regulatory support to the Company’s operations 25
MALONEY, DI 2
Idaho Power Company
business units to ensure consistent application of the 1
Company’s rules and regulations, authorized by its 2
Commission-approved tariff, and the Idaho Public Utilities 3
Commission’s (“Commission”) Utility Customer Relations 4
Rules. I also act as a liaison for customer service-related 5
issues. 6
Q. What is the purpose of your testimony in this 7
matter? 8
A. My testimony will describe the proposed 9
updates to the Company’s Schedule 31, Agreement for Supply 10
of Standby Electric Service for the Amalgamated Sugar 11
Company, and Schedule 45, Standby Service (collectively, 12
“Standby Service”); Schedule 46, Alternate Distribution 13
Service; Schedule 66, Miscellaneous Charges; Schedule 72, 14
Generator Interconnections to PURPA Qualifying Facility 15
Sellers; and Schedule 95, Adjustment for Municipal 16
Franchise Fees. I will also address the changes and updates 17
being proposed within several of the Company’s service 18
provisions in its “General Rules, Regulations and Rates.” 19
I. SCHEDULES 45 AND 31, STANDBY SERVICE 20
Q. Please describe Schedule 45, Standby Service. 21
A. Standby Service under Schedule 45 is an 22
optional, firm power service offering available to 23
customers who have their own on-site source of electric 24
generation, but request that the Company back up a portion 25
MALONEY, DI 3
Idaho Power Company
of such source of customer-owned generation in the event of 1
an outage. Standby Service was first made available 2
pursuant to Commission Order No. 22887, issued in Case No. 3
IPC-E-89-04, for customers taking large power service and 4
was subsequently updated in Case No. IPC-E-94-05 to include 5
generation and transmission cost components. Since its 6
inception, and because of customers’ expressed interest, 7
Standby Service has subsequently been expanded through 8
various tariff advice filings to also be available to 9
customers taking large general service. The Company 10
currently has two primary service level customers taking 11
Standby Service. 12
Q. What is the benefit of a customer taking 13
Standby Service? 14
A. Because the Company includes the requested 15
amount of capacity within its load forecasts, customers 16
electing to take Standby Service are afforded reasonable 17
assurance of continued electric service during periods of 18
planned or unexpected outages to their on-site generating 19
equipment. 20
Q. Are customers who are eligible required to 21
take Standby Service? 22
A. No. However, in the event an eligible customer 23
does not elect to take Standby Service and their on-site 24
generation goes offline, the necessary amount of backup 25
MALONEY, DI 4
Idaho Power Company
power may not be available for taking from the Company’s 1
system as the Company will not have planned to serve the 2
additional, temporary load within the area. 3
Q. Is the Company proposing any rate adjustments 4
to Schedule 45, Standby Service? 5
A. Yes. Idaho Power reviewed the currently in 6
effect methodology approved by the Commission in past 7
general rate cases and various tariff advice filings and 8
determined it to still be representative of the cost to 9
provide the respective service, with exception to the 10
derivation of standby generation and transmission cost 11
components and excess demand charges. The proposed rate 12
adjustments revise the charges to include the Company’s 13
Open Access Transmission Tariff (“OATT”) rate components 14
and incorporate updated unit cost information resulting 15
from the cost-of-service studies for Schedule 19 Primary 16
Service and Schedule 9 Primary and Secondary Services, as 17
presented on pages 5 – 7 of Exhibit No. 43 to the Direct 18
Testimony of Mr. Paul Goralski. The derivations of the 19
updated charges are included in my workpapers. 20
Q. Please describe Schedule 31, Agreement for 21
Supply of Standby Electric Service for the Amalgamated 22
Sugar Company. 23
A. The Company has a contract with the 24
Amalgamated Sugar Company to provide customized standby 25
MALONEY, DI 5
Idaho Power Company
service. The Company’s initial contract with the 1
Amalgamated Sugar Company to provide standby service was 2
entered into on April 6, 1998, and approved by Commission 3
Order No. 27708, issued in Case No. IPC-E-98-07. Currently, 4
Amalgamated Sugar Company is provided standby service under 5
the provisions of a revised Standby Electric Service 6
Agreement dated December 7, 2005, which was approved by 7
Commission Order No. 29958, issued in Case No. IPC-E-05-37. 8
Q. Is the Company proposing any rate adjustments 9
to the standby charges for Amalgamated Sugar Company under 10
Schedule 31? 11
A. Yes. Idaho Power reviewed the currently in 12
effect methodology approved by the Commission in past 13
general rate cases and found it to still be representative 14
of the cost to provide the respective service, with 15
exception to the derivation of standby generation and 16
transmission cost components and excess demand charges. 17
The proposed rate adjustments revise the charges to include 18
the Company’s OATT rate components and incorporate updated 19
unit cost information resulting from the aforementioned 20
cost-of-service study for Schedule 19 Primary Service. The 21
derivations of the updated charges are included in my 22
workpapers. 23
MALONEY, DI 6
Idaho Power Company
Q. Why is the Company proposing to change how the 1
standby generation and transmission cost component for 2
Schedule 31 and Schedule 45 is derived? 3
A. The Company is proposing to use its OATT rate 4
components within the derivation of Schedule 31 and 5
Schedule 45’s standby reservation charges to remain 6
consistent with the methodology most recently relied upon 7
when determining its special contracts’ rates, as addressed 8
by Company Witness Mr. Paul Goralski. 9
Q. Please describe the excess demand charge and 10
the changes to the charge’s derivation being proposed 11
within Schedules 31 and 45. 12
A. Excess demand charges are incurred when a 13
customer taking Standby Service exceeds their total amount 14
of contract demand during a billing period. The proposed 15
excess demand charge is derived from the Company’s OATT 16
rate components and represents the annual cost for an 17
incremental megawatt accessed at those OATT rate 18
components, collected each day over one month. Any excess 19
demand charges assessed to a customer will continue to be 20
in addition to all standby demand charges and energy 21
charges incurred for the additional amount of load 22
consumed. 23
// 24
MALONEY, DI 7
Idaho Power Company
II. SCHEDULE 46, ALTERNATE DISTRIBUTION SERVICE 1
Q. What is Alternate Distribution Service? 2
A. Alternate Distribution Service is an optional 3
service offering for commercial and industrial customers 4
desiring redundancy and, in the event of a distribution-5
related outage, automatic switching of electric service to 6
an alternate distribution circuit serving their premises. 7
This service was first made available pursuant to 8
Commission Order No. 22887, issued in Case No. IPC-E-89-04, 9
for customers taking large power service or large general 10
service. The Company currently has six customers taking 11
Alternate Distribution Service. 12
Q. What is the benefit of a customer taking 13
Alternate Distribution Service? 14
A. Alternate Distribution Service provides 15
customers an extra measure of reliability that does not 16
exist with only one source of distribution service. Absent 17
on-site backup generation, a customer’s operations may 18
cease in the event of a distribution-related outage 19
affecting the distribution circuit serving their premises. 20
Though not guaranteed, Alternate Distribution Service may 21
minimize the chance of a customer’s operations from being 22
disrupted in such a scenario. 23
Q. Is the Company proposing any rate adjustments 24
to Schedule 46, Alternate Distribution Service? 25
MALONEY, DI 8
Idaho Power Company
A. Yes. After reviewing the currently in effect 1
methodology approved by the Commission in past general rate 2
cases, the Company found the method to continue to be 3
reasonable, with one exception. When reviewing the 4
methodology used to derive the Capacity Charge, the Company 5
identified that generation and transmission-related 6
capacity cost components had previously been inadvertently 7
included. As such, the Capacity Charge being proposed as 8
part of this case corrects for this and does not include 9
any generation or transmission-related capacity cost 10
components. 11
The proposed Capacity Charge rate includes updated 12
unit cost information resulting from the cost-of-service 13
study for Schedule 19 Primary Service. Additionally, the 14
Company proposes to update the mileage charge and average 15
distribution line length covered by Schedule 19 customers’ 16
rates utilizing the same methodology previously relied 17
upon. 18
The updated Capacity Charge is derived by summing 19
the Distribution demand revenue requirement for 20
Substations, Primary Lines, and Primary Transformers for 21
Schedule 19 Primary Service ($7,435,654; $11,058,271; and 22
$1,575,448, respectively), and dividing this sum by the 23
total billed kilowatt (“kW”) of 5,315,392. The respective 24
revenue requirement for each of these facilities and total 25
MALONEY, DI 9
Idaho Power Company
billed kW can be found on page 7 of Exhibit No. 43 to the 1
Direct Testimony of Mr. Goralski, and the derivation of the 2
updated Capacity Charge using these amounts is included in 3
my workpapers. 4
Q. Please describe Schedule 46’s mileage charge 5
and the methodology used to derive it. 6
A. Schedule 46’s mileage charge is intended to 7
recover the distribution facilities’ ongoing operating and 8
maintenance expenses based upon the proportion of capacity 9
committed and length of line constructed to provide 10
alternate distribution service to an individual customer. 11
To derive this charge, the Company determined the per-mile 12
cost to build a three-phase overhead distribution circuit, 13
applied the facilities charge rate for facilities installed 14
more than 31 years, as proposed below, and then divided by 15
the three-phase overhead distribution circuit’s total 16
capacity. 17
III. SCHEDULE 66, MISCELLANEOUS CHARGES 18
Q. How did you approach updating the Company’s 19
Schedule 66’s charges? 20
A. I started by reviewing the methodology that 21
was relied upon for each charge’s most recent update to 22
determine whether that methodology continued to reasonably 23
reflect the requirements to provide the respective type of 24
MALONEY, DI 10
Idaho Power Company
service. To the extent circumstances have changed since the 1
charge was last updated, I developed a new recommendation. 2
Q. How do you propose to update the Current 3
Transformer Charges within Schedule 66? 4
A. The proposed Current Transformer Charges 5
simply update the cost of materials to better reflect and 6
recover the Company’s current costs of supplying the 7
respective services. The methodology used to derive the 8
proposed Current Transformer Charges was most recently 9
reviewed by the Commission in 2010 as part of Tariff Advice 10
No. 10-01. 11
Q. Why is the Company proposing to remove the 12
option for customers to request the installation of non- 13
Advanced Metering Infrastructure current transformer 14
metering? 15
A. The Company predominately installs Advanced 16
Metering Infrastructure (“AMI”) meters within its service 17
area and has generally stopped procuring non-AMI capable 18
meters. Because of this, the Company is proposing to strike 19
the option to install non-AMI current transformer metering 20
to avoid customer confusion. In areas where a customer-21
requested current transformer is installed but AMI 22
functionality is not available, an AMI capable meter would 23
still be installed but the AMI-specific functionality would 24
not be utilized until possible. 25
MALONEY, DI 11
Idaho Power Company
Q. Why is the Company proposing to increase its 1
customer-requested Special Meter Test charge? 2
A. This charge was last updated during Case No. 3
IPC-E-94-05 and was based on the then-applicable hourly 4
labor rate for the Company’s meter technicians. As such, 5
the Company is proposing to update the charge from $30 to 6
$85 to be more representative of the Company’s current 7
labor cost for providing the service. However, pursuant to 8
Section 4, Meter Tests, of Rule D of the Company’s tariff, 9
Customers will continue to be provided one Special Meter 10
Test free of charge every twelve months, and a Special 11
Meter Test charge will be refunded in instances where the 12
average registration error of the tested meter exceeds plus 13
or minus two percent. 14
Q. Please describe the Service Establishment 15
Charge within Schedule 66. 16
A. The Service Establishment Charge is assessed 17
when a customer desires to initiate a new service contract 18
with the Company at a location where the Point of Delivery 19
is already energized. This charge is intended to recover 20
the costs associated with recording or updating the 21
customer’s pertinent information into the Company’s 22
customer information system and initiating service. 23
Compared to the existing Service Establishment Charge 24
amount of $20, the proposed Service Establishment Charge 25
MALONEY, DI 12
Idaho Power Company
amount of $30 is more reflective of the Company’s current 1
costs for performing the necessary work. 2
Q. Has the methodology used to derive the 3
proposed Service Establishment Charge been modified? 4
A. No. The methodology used to derive the Service 5
Establishment Charge remains largely the same as of that 6
approved in Case No. IPC-E-03-13, which is the last time 7
this charge was updated. The only adjustment made in 8
deriving the proposed Service Establishment Charge is 9
updating the type of employees that perform the respective 10
work and weighting their differing hourly costs 11
accordingly. 12
Q. Please describe the Continuous Service Charge 13
within Schedule 66. 14
A. The Continuous Service Charge provides 15
property managers a cost-effective option to have electric 16
service at their properties automatically transfer into 17
their names when tenants request their service be 18
discontinued. By requesting to implement a continuous 19
service arrangement, property managers can automatically 20
retain electric service between tenants to prevent damage 21
from occurring and to have electricity available for 22
maintenance and/or marketing of their property. 23
Additionally, property managers electing to receive this 24
service are also provided notice from Idaho Power each time 25
MALONEY, DI 13
Idaho Power Company
service is transferred into their name, electric service at 1
the property is subject to termination, or a tenant’s 2
application for electric service is denied. Idaho Power 3
also provides enrolled property managers with an annual 4
inventory of all their properties where an active 5
continuous service arrangement exists. 6
Q. Is there benefit to the Company in offering 7
property managers a continuous service arrangement? 8
A. Yes. When property managers request a 9
continuous service arrangement, there is less of a need for 10
them to contact the Company each time a tenant requests to 11
discontinue service. As a result, Company resources are 12
optimized as those representatives can handle other 13
customer needs. 14
Q. How was the proposed Continuous Service Charge 15
amount determined? 16
A. Using the methodology approved in Case No. 17
IPC-E-05-28, the Company proposes to continue pricing the 18
Continuous Service Charge at 50 percent of the proposed 19
Service Establishment Charge amount, or $15, to balance the 20
costs of operating the offering while still maintaining an 21
incentive to encourage participation amongst property 22
managers. 23
Q. Please describe the Field Visit Charge within 24
Schedule 66. 25
MALONEY, DI 14
Idaho Power Company
A. The Field Visit Charge is designed to recover 1
costs incurred by the Company when a Company representative 2
is dispatched to connect or disconnect service, but due to 3
customer action, the Company representative is unable to 4
complete such action at the time of visit. This charge is 5
applicable to non-collection as well as collection-related 6
visits to customers’ premises. 7
Q. Has the methodology used to derive the 8
proposed Field Visit Charge been modified? 9
A. No. The methodology used to derive the Field 10
Visit Charge is nearly the same as that approved in Case 11
No. IPC-E-03-13, which is the last time this charge was 12
updated. The only adjustment made in deriving the proposed 13
Field Visit Charge amounts is removing administrative 14
support costs because no administrative support work is 15
currently required within a Field Visit’s scope of work. 16
The proposed $25 and $45 Field Visit Charge amounts are 17
more reflective of the Company’s current costs incurred in 18
respect to visiting a customer’s premises with the 19
intention of connecting or disconnecting service but being 20
unable to do so because of customer action. 21
Q. Please describe the Service Connection Charges 22
within Schedule 66. 23
A. A Service Connection Charge is assessed 24
anytime a customer desires to initiate a new service 25
MALONEY, DI 15
Idaho Power Company
contract with the Company at a location where the Point of 1
Delivery is currently disconnected from the Company’s 2
system and remote connection is not available. Like the 3
Service Establishment Charge, the Service Connection Charge 4
also seeks to recover the costs associated with recording 5
or updating the customer’s pertinent information into the 6
Company’s customer information system, as well as having to 7
dispatch Company personnel to physically connect and 8
initiate service. Compared to the existing Service 9
Connection Charge amounts of $20 and $40, the proposed 10
Service Connection Charge amounts of $30 and $50, 11
respectively, are more reflective of the Company’s current 12
cost for performing the necessary work. 13
Q. Will a customer be charged both the Service 14
Establishment Charge and a Service Connection Charge? 15
A. No. Because the Service Connection Charge 16
includes the costs associated with the tasks of service 17
establishment plus the cost to physically connect service, 18
only the Service Connection Charge is assessed. 19
Q. Why are there differing Field Visit and 20
Service Connection Charges based on customer class? 21
A. The Field Visit and Service Connection Charges 22
remain bifurcated to continue reflecting the difference in 23
skill level required of the employee(s) dispatched to 24
perform the requested type of work, which is generally 25
MALONEY, DI 16
Idaho Power Company
dependent on the voltage at which each customer class 1
typically takes service. 2
Q. Can customers request connection of service 3
outside of the Company’s normal business hours? 4
A. Yes. The charges by rate schedule outlined 5
within Attachment 1 to the Company’s application include 6
two after-hours blocks and their associated charges. The 7
block-hour structure remains the same as that currently in 8
place; however, the charges have been updated to be more 9
reflective of the Company’s current costs for performing 10
the work during the respective hours. 11
Q. Why does the Company continue to propose 12
block-hour Service Connection Charges? 13
A. As first approved in Case No. IPC-E-03-13, the 14
block-hour methodology recognizes the higher cost of 15
serving customer requests for connection after normal 16
working hours due to the overtime rate paid to employees 17
during these hours. Additionally, during the third block-18
hours of 9:01 p.m. to 7:29 a.m., two employees may be 19
dispatched for safety reasons. The proposed block-hour 20
Service Connection Charges continue to reflect the 21
Company’s costs to serve customers based on the time of day 22
that a customer requests the Company provide connection of 23
service. 24
MALONEY, DI 17
Idaho Power Company
Q. Why are the proposed Service Connection 1
charges priced at a slight premium for the second and third 2
block-hours? 3
A. Some of the Company’s currently approved 4
second and third block-hour Service Connection Charges, 5
last updated in Case No. IPC-E-03-13, include a slight 6
premium, which is intended to encourage customers to 7
request the service be performed within normal working 8
hours at the lower price. The Company has found after-hour 9
time frames can pose safety concerns for the Company’s 10
employees. 11
Q. Please describe the Remote Service Connection 12
Charge within Schedule 66. 13
A. The Remote Service Connection charge is 14
assessed anytime a customer requests connection of service 15
at a location where the Point of Delivery is currently 16
disconnected from the Company’s system, but a meter with 17
remote connect capability has been installed. Unlike the 18
Service Establishment or Service Connection Charges, the 19
Remote Service Connection Charge only includes the cost of 20
back-office operations necessary to remotely connect and 21
re-establish service; no field-related costs are incurred 22
and therefore are not included within the derivation of the 23
proposed Remote Service Connection Charge. 24
MALONEY, DI 18
Idaho Power Company
Q. How many locations within the Company’s 1
service area can be remotely connected? 2
A. As of the end of 2022, the Company has 3
installed approximately 41,500 meters equipped with remote 4
connect/disconnect functionality within its Idaho service 5
area. Additionally, the Company continues to objectively 6
identify locations where deployment of remote 7
connect/disconnect capable meters can reduce costs paid by 8
all customers, via the Company incurring lower annual 9
operating expenses, as well as increase the satisfaction of 10
customers residing at these locations through the provision 11
of faster, more predictable, and cheaper connection of 12
service. 13
Q. Why has the Remote Service Connection Charge 14
decreased compared to the currently approved charge? 15
A. Likely as a result of technological 16
advancements and process improvements, the cost of 17
performing remote service connections has decreased on a 18
per transaction basis compared to that of the current 19
charge, which was implemented and approved as part of Case 20
No. GNR-U-14-01. 21
Q. In his testimony on page 13, Company Witness 22
Mr. Matthew Larkin refers to a forecast to Account 451’s 23
Miscellaneous Service Revenues based on the proposed 24
MALONEY, DI 19
Idaho Power Company
changes to Schedule 66. Can you please explain the basis 1
for this forecasted amount? 2
A. Yes. The workpapers accompanying my testimony 3
detail the difference in revenues from Schedule 66’s 4
current charge amounts to the proposed charge amounts for 5
these services. 6
Q. Please describe Schedule 66’s proposed 7
Fractional Period Minimum Billing amounts. 8
A. “Fractional Period Minimum Billings” specifies 9
the minimum bill requirements for each service schedule 10
when service is taken for a partial billing period. The 11
minimum bill amounts have been updated to be more 12
reflective of each customer class’s allocated costs 13
associated with bill preparation and meter reading. 14
The proposed Fractional Period Minimum Billing 15
amounts are informed based on each customer class’s 16
respective cost-of-service unit cost for meter reading and 17
customer accounting expenses multiplied by the proportion 18
of functionalized customer accounting expenses for 19
providing customer records to the total functionalized 20
customer records expense. Mr. Goralski’s Exhibit Nos. 37 21
and 43 contain the information to derive the functionalized 22
customer account expense proportion, and each customer 23
class’s meter reading and customer account expense unit 24
costs, respectively. 25
MALONEY, DI 20
Idaho Power Company
Q. What monthly rates is the Company proposing 1
for facilities charges? 2
A. The Company is proposing to update the monthly 3
facilities charge rates to the following: 4
Table 1 Proposed Facilities Charge Rates
Rate Schedule
Installed 31 Years
or Less
Facilities
Installed More
Than 31 Years
Schedule 15
Schedule 19
Schedule 24
Schedule 29
Schedule 32
Schedule 41
Schedule 45
Schedule 46
1.66%
1.38%
1.38%
1.38%
1.38%
1.17%
1.38%
1.38%
1.66%
0.61%
0.61%
0.61%
0.61%
1.17%
0.61%
0.61%
5
Q. Please describe the individual cost components 6
that are used to derive the Company’s facilities charges. 7
A. The cost components used to derive the 8
Company’s facilities charges are the same components 9
included in the Company’s revenue requirement for like 10
facilities. Descriptions of each cost component are as 11
follows: 12
MALONEY, DI 21
Idaho Power Company
Rate of Return – Idaho Power’s cost of financing its 1
original investment in facilities. This uses a weighted 2
average of the Company’s cost of debt and cost of equity. 3
The facilities charge methodology uses a level payment 4
stream to simplify the rate calculation and the 5
administration of the facilities charge. The Rate of 6
Return used to determine the facilities charge will be the 7
Rate of Return ordered by the Commission in this case. 8
Booked Depreciation – The straight-line annual 9
depreciation of assets based on a levelized 31-year basis. 10
Income Taxes – The tax that Idaho Power pays on the 11
amount of revenue received from the equity portion of the 12
Rate of Return. 13
Property Taxes – The tax that Idaho Power pays for 14
its distribution facilities. Each dollar the Company 15
invests beyond the Point of Delivery is assessed property 16
taxes. 17
Other Taxes (Regulatory Fees) – The taxes and fees 18
that Idaho Power pays to the Idaho Public Utilities 19
Commission and Oregon Public Utility Commission. A portion 20
of these fees are tied to the Company’s distribution 21
investment which includes facilities installed beyond the 22
Company’s Point of Delivery. 23
Operation and Maintenance Expenses – Includes all of 24
Idaho Power’s costs to operate and maintain its 25
MALONEY, DI 22
Idaho Power Company
distribution facilities. This cost component represents an 1
average maintenance rate for all distribution equipment. 2
Administration and General Expenses – Represents an 3
expense based on total Administration and General expense 4
as a percentage of total plant investment. 5
Working Capital – Working Capital is the carrying 6
cost of inventory. Working Capital is based on the cost of 7
capital to finance the distribution facilities inventory 8
and the property taxes that the Company pays on its 9
inventory. 10
Insurance – The insurance rate reflects the 11
additional cost Idaho Power incurs for insurance premiums 12
resulting from facilities installed beyond the Company’s 13
Point of Delivery. This insurance rate covers property, 14
casualty, and worker’s compensation. It does not cover 15
facility replacement costs for failed facilities. 16
Q. Is the Company proposing changes to the 17
methodology used to derive facilities charges? 18
A. No. The Company proposes to rely on the same 19
methodology and cost components that the Commission 20
approved in Case No. IPC-E-11-08. 21
Q. What are the proposed percentage amounts for 22
each cost component by rate class? 23
A. The proposed percentage amounts used to derive 24
the proposed facilities charge rates are as follows: 25
MALONEY, DI 23
Idaho Power Company
Table 2 Facilities Charge Cost Components
Cost Components Rate 15
Rates
9/19/24/29/
32/45/46 Rate 41
4.85%4.85%4.85%
3.23%3.23%3.23%
1.16%1.16%1.16%
0.36%0.36%0.36%
(Regulatory Fees)
0.04%0.04%0.04%
Maintenance
7.37%3.95%1.46%
General
2.32%2.32%2.32%
0.34%0.34%0.34%
0.30%0.30%0.30%
(ΣLines 1-9)
20.0%16.5%14.0%
11 Monthly Rate
(Line 10/12)
1
Q. What cost components have contributed to the 2
proposed reduction in the facilities charge rate for 3
facilities installed 31 years or less? 4
MALONEY, DI 24
Idaho Power Company
A. Decreases in the Company’s requested overall 1
rate-of-return and income and property tax rates are the 2
primary drivers for the reduction in the proposed 3
facilities charge rate for facilities installed 31 years or 4
less. 5
Q. What cost components have driven the proposed 6
increase in the facilities charge rate for facilities 7
installed more than 31 years? 8
A. Increased working capital costs; and slightly 9
elevated administrative and general expenses, and 10
distribution-related operations and maintenance costs; have 11
driven the proposed increase in the facilities charge rate 12
for facilities installed more than 31 years. 13
Q. What is the estimated change in the Company’s 14
revenue from the proposed facilities charge rates? 15
A. Overall, the Company estimates that its 16
proposed facilities charge rates will result in a reduction 17
in revenue received through facilities charges of 18
approximately $184,400 per year. 19
IV. SCHEDULE 72, GENERATOR INTERCONNECTIONS TO PURPA 20
QUALIFYING FACILITY SELLERS 21
Q. What is the purpose of Schedule 72, Generator 22
Interconnections to Public Utility Regulatory Policies Act 23
of 1978 (“PURPA”) Qualifying Facility Sellers? 24
MALONEY, DI 25
Idaho Power Company
A. Similar to how Rule H of the Company’s tariff 1
outlines the requirements for customers seeking to 2
interconnect to the Company’s distribution system, Schedule 3
72 details the Idaho Commission’s process and requirements 4
for non-utility generators contracting, or seeking to 5
contract, with the Company to interconnect a PURPA-6
qualifying generation facility in order to sell electric 7
energy to the Company. 8
Q. What updates does the Company propose within 9
Schedule 72? 10
A. Outside of the various edits intended to 11
better clarify Schedule 72’s existing provisions, the 12
Company is proposing to modify Schedule 72’s vested 13
interest provisions so that they are consistent with 14
provisions currently existing for the same within Rule H of 15
the Company’s tariff. 16
Q. Why do the vested interest provisions in 17
Schedule 72 and Rule H currently differ? 18
A. Prior to Case No. IPC-E-94-05, the bulk of the 19
Company’s existing Rule H practices were included within 20
its tariff under Schedule 71 which, in many respects, was 21
very similar to Schedule 72 as it currently exists. 22
However, as part of Case No. IPC-E-95-18, the Commission 23
approved modifications to Rule H’s vested interest 24
provisions to achieve greater simplicity of administration. 25
MALONEY, DI 26
Idaho Power Company
Similar vested interest modifications were, however, not 1
simultaneously incorporated into Schedule 72. 2
Q. What challenges do the existing Schedule 72 3
vested interest provisions present? 4
A. The existing vested interest provisions under 5
Schedule 72 require the Company to collect a vested 6
interest charge not only for the entity that originally 7
funded the interconnection facilities’ construction cost, 8
but also for all “Additional Applicants” that have 9
subsequently connected and who also hold a vested interest. 10
This practice is not only complex to administer, but it 11
often results in numerous and minimal vested interest 12
refund checks being sent to “Additional Applicants.” 13
Q. What vested interest provisions does Idaho 14
Power now seek to add to or update within Schedule 72? 15
A. Idaho Power proposes to update Schedule 72’s 16
vested interest provisions to allow for only one seller, 17
person or entity to hold a vested interest at a time in a 18
section of interconnection facilities. Additionally, the 19
Company proposes to add an option for an “Additional 20
Applicant” to pay the current vested interest so that they 21
may in-turn hold a vested interest in the interconnection 22
facilities and therefore be eligible to receive refunds. 23
Finally, the Company proposes to limit the total amount and 24
number of refunds that a Schedule 72 vested interest holder 25
MALONEY, DI 27
Idaho Power Company
is eligible to receive to be no more than 80 percent of 1
their original interconnection cost, until receipt of four 2
vested interest refunds has occurred, or until eligibility 3
to receive vested interest refunds has expired, which is 5 4
years after the date the Company completes construction of 5
its portion of the interconnection facilities. These 6
proposed updates will allow for Schedule 72 and Rule H’s 7
vested interest provisions to be applied and administered 8
in a consistent manner. 9
V. SCHEDULE 95, ADJUSTMENT FOR MUNICIPAL FRANCHISE FEES 10
Q. Please explain the updates being proposed 11
within Schedule 95. 12
A. Schedule 95 lists all franchise fees that 13
Idaho Power currently pays to Idaho municipalities, which 14
range from 1 percent to 3 percent of amounts billed for 15
electric service to customers residing within the corporate 16
limits of each listed municipality. When there is a change 17
to a municipality’s franchise fee amount, the Company files 18
a tariff advice with the Commission to update the franchise 19
fee rate listed in Schedule 95. 20
Schedule 95 also lists the municipal ordinance 21
number for the municipality’s franchise agreement with 22
Idaho Power. When an existing franchise agreement expires 23
and the Company enters into a new franchise agreement with 24
the municipality, the new franchise agreement will contain 25
MALONEY, DI 28
Idaho Power Company
a new number for the municipal ordinance that approved the 1
new franchise agreement. In these cases, if the franchise 2
fee rate under the new franchise agreement did not change, 3
the Company has not historically filed a tariff advice with 4
the Commission merely to update the ordinance number. 5
Instead, the Company has typically only filed a tariff 6
advice if a municipality’s franchise fee rate changes as 7
part of a new franchise agreement. 8
Idaho Power is proposing to update all ordinance 9
numbers listed in Schedule 95 where the currently listed 10
ordinance number has been replaced by a new franchise 11
agreement with a new ordinance number, but the new 12
ordinance number was not previously updated in Schedule 95 13
because the new franchise agreement did not include a 14
change in the franchise fee rate. 15
Going forward, the Company intends to include updated 16
municipal ordinance numbers as part of any tariff advice 17
where it provides new or updated franchise fee rates. 18
VI. IDAHO POWER’S GENERAL RULES AND REGULATIONS 19
Q. How did you arrive at the proposed changes to 20
the Company’s General Rules and Regulations? 21
A. The changes I propose to the Company’s General 22
Rules and Regulations are the result of collaborative 23
efforts between representatives from various business units 24
MALONEY, DI 29
Idaho Power Company
within the Company, as well as from guidance by Company 1
Witness Ms. Connie Aschenbrenner. 2
Q. Do you intend to discuss each of the proposed 3
changes to the tariff? 4
A. No. While a number of the changes I discuss 5
are substantive in nature, a significant number of other 6
changes are “form” or “housekeeping” in nature only and do 7
not materially change the scope, effect, or application of 8
the respective rules and regulations. The specific changes 9
to the service provisions I address are detailed within 10
Attachment 2 to the Company’s application. These revisions 11
are shown in legislative format within Attachment 2 so that 12
parties reviewing them will be able to readily identify the 13
proposed changes. 14
Rule B 15
Q. What changes is the Company proposing be made 16
to Rule B (Definitions) of its tariff? 17
A. Rule B of the Company’s tariff has been 18
modified to better clarify the Company’s definition of a 19
“Premises.” 20
Q. Why does the Company believe modification to 21
its definition of “Premises” is required? 22
A. With the recent increase in the number of 23
prospective developments constructed in the Company’s 24
service area, some developers have expressed confusion 25
MALONEY, DI 30
Idaho Power Company
regarding the Company’s service requirements - specifically 1
regarding what constitutes a “Premises” and whether such 2
Premises can be served at more than one Point of Delivery. 3
By more thoroughly detailing the criteria that the Company 4
uses to define a Premises, developers are provided a 5
clearer understanding of the Company’s existing service 6
requirements, which are in place to serve customers most 7
cost-effectively. This modification will further enable 8
developers to initially design and construct their 9
buildings in conformance with the Company’s service 10
requirements, thereby reducing possible post-construction 11
confusion and retrofits. 12
Rule C 13
Q. What change is the Company proposing to Rule C 14
(Service and Limitations) of its tariff? 15
A. The Company proposes that Section 2 of Rule C, 16
Supplying of Service, be clarified to highlight that the 17
construction of any necessary line extensions or the 18
installation of service facilities will only be performed 19
in conformance with the Company’s construction standards. 20
While not a change in existing practice and already implied 21
given the Company’s ownership and ongoing responsibility 22
for the operation and maintenance of all such facilities, 23
the proposed language simply makes the requirement 24
MALONEY, DI 31
Idaho Power Company
explicitly clear in instances where a customer may desire 1
use of an alternative construction standard. 2
Rule D 3
Q. What changes is the Company proposing be made 4
to Rule D (Metering) of its tariff? 5
A. Aside from relocating reference to certain 6
services’ funding mechanism from Schedule 66 to within Rule 7
D itself, the Company is proposing to eliminate its 8
optional, Off-site Meter Reading Service offering. Second, 9
the Company proposes to update how costs are recovered for 10
certain customers requesting receipt of optional, Load 11
Profile Metering services, as well as including a general 12
waiver and release of liability for such services. Finally, 13
the Company seeks to remove offering its optional, Surge 14
Protection Device Service and update certain meter reading-15
related verbiage to reflect technological advancements. 16
Q. Why is the Company proposing to require work 17
order costs within Rule D for the installation of Secondary 18
Service voltage transformers? 19
A. Secondary Service voltage transformers are 20
infrequently installed and are typically only requested 21
when a customer prefers to be served at a non-standard 22
voltage. Because the cost and type of voltage transformer 23
installed for each request may differ, the Company believes 24
it reasonable to require work order costs for these 25
MALONEY, DI 32
Idaho Power Company
installations to better recover the cost of installation 1
from the customer requesting the service be provided. 2
Q. Why is the Company proposing to eliminate its 3
optional, Off-site Meter Reading Service? 4
A. Following the Company’s installation of AMI 5
meters throughout its service area, as approved by the 6
Commission in IPC-E-08-16, nearly all customers’ meters 7
innately contain the capability to be remotely read. 8
Because of the Company’s standardization of installing AMI 9
meters, the need for a subscription-based offsite meter 10
reading offering has become obsolete. 11
Q. How does the Company currently recover costs 12
when customers request to receive Load Profile Metering 13
services? 14
A. Under the current monthly subscription-based 15
model, customers requesting to receive Load Profile 16
Metering services pay a fixed upfront charge for the 17
installation of the new metering equipment and an ongoing 18
monthly charge thereafter. The ongoing monthly charge 19
intends to recoup the installed facilities’ incremental 20
costs over a levelized three-year period. In the event a 21
customer receiving Load Profile Metering service cancels 22
such service within the first three years, the customer is 23
required to pay a fixed removal fee. 24
MALONEY, DI 33
Idaho Power Company
Q. How does the Company propose it recover costs 1
going forward when requested to provide Load Profile 2
Metering services? 3
A. The Company proposes that work order cost be 4
assessed for the installation and removal, if requested, of 5
Load Profile Metering services. Using a work order cost 6
approach is more consistent with the Company’s tariff for 7
other installations that customers may request, such as 8
those provided for under Rule H, and is better aligned with 9
cost causation principles by removing the Company’s current 10
risk of not recovering the cost of its investment should a 11
customer cancel receipt of Load Profile Metering services 12
within the first 3 years after installation. 13
Q. Why is the Company seeking to add a general 14
waiver and release of liability for Load Profile Metering 15
services? 16
A. Though the Company does not promote the 17
utilization of Load Profile Metering data for customers to 18
automate their operations, the Company has become aware of 19
some customers desiring to use the service for that 20
purpose. As a result of technological advancements allowing 21
for such automation options, and the numerous factors that 22
may impede the Company’s ability to provide Load Profile 23
Metering data reliably or on a prescribed cadence, such as 24
an outage or routine maintenance, the Company believes it 25
MALONEY, DI 34
Idaho Power Company
prudent to include a general waiver and release of 1
liability as part of customers’ receipt of Load Profile 2
Metering services to minimize the risk of damages being 3
sought by customers using the services in an unadvised 4
manner. 5
Q. Why is the Company proposing to remove the 6
option for customers to request Surge Protection Device 7
Services? 8
A. This is no longer a service the Company is 9
positioned to offer. While the provision has been included 10
in the Company’s tariff since 1999, the Company has not had 11
recent success in receiving an acceptable indemnification 12
agreement from surge protection device vendors, as required 13
under the offering’s current provisions. Because third-14
party providers exist that can install whole-house surge 15
protection in a more time-efficient manner, the Company 16
believes it reasonable to remove this optional service 17
offering from its tariff in order to prevent customer 18
confusion and frustration that may occur as a result of 19
customers requesting a service that the Company is not 20
currently positioned to deliver. 21
Q. Please describe the changes proposed under 22
Rule D’s Section 2, Measurement of Energy, and Section 6, 23
Meter Reading. 24
MALONEY, DI 35
Idaho Power Company
A. The verbiage being proposed to these sections 1
incorporates changes to the Company’s meter reading 2
practices made possible through technological advancements. 3
Specifically, the existing verbiage contemplates the 4
Company manually reading meters, typically on an interval 5
of once per billing period. However, because technological 6
advancements in metering equipment have allowed for 7
customers’ meters to be remotely read and at greater 8
interval frequency, the Company has updated the sections’ 9
verbiage to also indicate that multiple meter readings can 10
occur during a customer’s billing period, as well as 11
clarifying the threshold amount of unscaled hourly meter 12
reads required during a customer’s billing period before 13
their bill will be designated as an estimate. 14
Q. Under what circumstances is the Company unable 15
to obtain remote meter readings? 16
A. While infrequent, the Company may not be able 17
to remotely obtain customers’ meter readings due to 18
situations resulting from, but not limited to, a 19
communication outage at the substation, line interference, 20
or maintenance work. 21
Q. Please explain what you mean by “unscaled 22
hourly meter reads.” 23
A. An unscaled hourly meter read is an estimate 24
of a customer’s usage during the respective hour and occurs 25
MALONEY, DI 36
Idaho Power Company
when the Company is unable to infer a customer’s missing 1
hourly usage data based on other known meter readings and 2
usage patterns for such customer at the same premises. 3
Conversely, a scaled hourly read occurs when an hourly 4
meter read is unable to be obtained but, because the delta 5
of unrecorded energy is known, the Company can proportion 6
the total unrecorded amount of consumed energy over any 7
missing intervals based on customers’ historical usage 8
patterns at the premises. 9
Rule E 10
Q. What changes is the Company proposing be made 11
to Rule E (Master Metering Standards) of its tariff? 12
A. Rule E of the Company’s tariff has 13
historically adopted most of the language found in IDAPA 14
31.26.01, which contains the Commission’s Master-Metering 15
Rules for Electric Utilities (“Commission’s Master Metering 16
Rules”). As such, most of the proposed updates to Rule E 17
are to simply align the Company’s master-metering rules to 18
the Commission’s Master Metering Rules. Should any of the 19
Commission’s Master Metering Rules be revised as part of 20
the efforts currently taking place within Case No. RUL-U-21
23-03, the Company will modify the proposed language within 22
Rule E accordingly. 23
MALONEY, DI 37
Idaho Power Company
Q. Are there any notable differences in the 1
Company’s Rule E compared to the Commission’s Master-2
Metering Rules? 3
A. No. However, under Section 2(b) of the 4
Company’s Rule E, there is reference to Schedule 3 – 5
Master-Metered Mobile Home Park - Residential Service. This 6
reference is in conformance with Commission Order No. 30754 7
which approved such rate schedule to be used in instances 8
where eligible park operators bill master-metered tenants 9
for electric service. 10
Rule H 11
Q. What changes is the Company proposing be made 12
to Rule H (New Service Attachments and Distribution Line 13
Installations or Alterations) of its tariff? 14
A. First, the Company is proposing to update 15
Section 7 of Rule H’s verbiage regarding the provision of 16
Company-funded allowances. This section has been updated to 17
better clarify that Rule H’s allowances only offset the 18
cost of installed terminal facilities, which is comprised 19
of a transformer and service attachment. 20
Second, the Company is proposing that existing 21
customers be eligible to receive a Company-funded allowance 22
when such customers increase their load and are responsible 23
for upgrading terminal facilities that currently serve two 24
MALONEY, DI 38
Idaho Power Company
or more customers taking residential, general service or 1
irrigation service. 2
Finally, the Company is proposing a handful of edits 3
within Rule H for streamlining and clarity purposes, as 4
well as updating the provisions governing unusual 5
conditions and irrevocable letters of credit to better 6
align with current construction and work order 7
reconciliation timelines. 8
Q. Please describe the Company’s current practice 9
for providing allowances pursuant to Rule H. 10
A. Currently, if installation of a new service 11
conductor is required to serve a new request for service, a 12
Company-funded allowance or salvage credit, whichever is 13
greater, is provided to offset a portion of the new or 14
upgraded terminal facilities’ cost of installation. The 15
amount of the Company-funded allowance provided in these 16
instances is dependent upon the then effective cost of 17
“Standard Terminal Facilities,” whether the request is for 18
single phase or three phase service, and the extent of 19
terminal facilities required to be installed. 20
For example, if a new customer’s service request 21
only requires the installation of a new overhead service 22
conductor, such service conductor’s installation cost will 23
be offset by up to the then effective and applicable 24
allowance amount. Similarly, if a new customer’s service 25
MALONEY, DI 39
Idaho Power Company
request requires the installation of transformation and 1
overhead service conductor, these facilities’ installation 2
cost will be offset by up to the then effective and 3
applicable allowance amount. 4
Any installation costs in excess of a customer’s 5
eligible allowance or salvage credit remains the requesting 6
customer’s responsibility to fund. 7
Q. Are existing customers currently eligible to 8
receive an allowance if their load request requires 9
terminal facilities to be upgraded? 10
A. No. Existing customers increasing their load 11
and necessitating upgraded terminal facilities are 12
currently financially responsible for funding the entire 13
cost, less any applicable salvage credit, of the required 14
upgraded terminal facilities. 15
Q. Why is the Company proposing that existing 16
customers also be eligible to receive a Company-funded 17
allowance under certain circumstances? 18
A. As the Commission noted within Order No. 19
30955, “[d]epending on the geographic configuration of 20
customer locations, transformers can serve multiple 21
customers.” While it is certainly most economical to serve, 22
when possible, multiple customers taking Secondary Service 23
from a single transformer, each customer connected to such 24
“shared” transformer may have otherwise been afforded the 25
MALONEY, DI 40
Idaho Power Company
entirety of an allowance if not but for the geographic 1
configuration that allowed for such sharing of 2
transformation to occur. Further, if each of these 3
customers were served from individual terminal facilities, 4
the need to upgrade said terminal facilities as a result of 5
adding load may have been avoided. 6
Recognizing these factors, the Company believes it 7
reasonable to begin contributing, in qualifying 8
circumstances, towards a portion of the upgraded terminal 9
facilities’ costs, up to the financially responsible 10
customer’s effective allowance amount, given the upgraded 11
terminal facilities will continue serving multiple 12
customers. 13
Q. Why is the Company removing the definition of 14
Point of Delivery within Rule H? 15
A. Defining “Point of Delivery” within Rule H is 16
duplicative of the same definition also existing within 17
Rule B of the Company’s tariff. Because Point of Delivery 18
is frequently used throughout the Company’s tariff, its 19
broad definition is most appropriately included within Rule 20
B to limit potential confusion. 21
Q. Why is the Company proposing to remove 22
reference to a 200-amperage meter base within Rule H’s 23
definition of Standard Terminal Facilities? 24
MALONEY, DI 41
Idaho Power Company
A. Customers are responsible for providing an 1
acceptable meter base to accommodate their requested level 2
of service. Removal of the existing “to serve a 200-3
amperage meter base” verbiage within the definition of 4
“Standard Terminal Facilities” helps eliminate any 5
ambiguity of this requirement and better specifies the 6
facilities installed by the Company and used in determining 7
allowance amounts. 8
Q. Why is the Company proposing to remove “meter” 9
from the definition of Terminal Facilities? 10
A. In accordance with Rule D of the Company’s 11
tariff, meters are typically provided at no cost to 12
customers, unless a customer requests a meter type not 13
required by the Company or necessitates more than one 14
primary voltage meter. As a result, the Company recommends 15
removing reference of a meter within the definition of 16
Terminal Facilities in order to eliminate potential 17
confusion as to which facilities’ costs are offset via a 18
Company-funded allowance. 19
Q. Please explain the Company’s proposed revision 20
regarding Rule H’s Unusual Conditions. 21
A. Because the Company’s reconciliation of a 22
project’s work order can be dependent on external parties’ 23
timely submission of information, a 90-day timeframe to 24
return unencountered unusual conditions amounts can often 25
MALONEY, DI 42
Idaho Power Company
be difficult to achieve. As such, the Company is proposing 1
to adjust the reconciliation timing language to provide 2
flexibility for various types of scenarios while 3
simultaneously also ensuring that once such reconciliation 4
of work order costs has been completed, customers are 5
refunded any eligible amounts within 30 days. 6
Q. Are there any other notable modifications 7
being proposed to Rule H? 8
A. Though infrequently used by customers, the 9
Company is proposing the Commission give Idaho Power 10
latitude to determine, on a case-by-case basis, when the 11
Company will accept an irrevocable letter of credit for the 12
estimated cost of unusual conditions. Because of the length 13
of time that it may take to complete the construction and 14
reconciliation of actual costs for certain projects, a 15
customer-provided irrevocable letter of credit could 16
expire, thereby putting the Company at risk of not being 17
able to collect the cost of unusual conditions associated 18
with customer-requested construction work. By having the 19
flexibility of being able to determine when to accept an 20
irrevocable letter of credit, the Company may be able to 21
limit risk of not being able to collect the cost of unusual 22
conditions seemingly “guaranteed” by an irrevocable letter 23
of credit. 24
MALONEY, DI 43
Idaho Power Company
Q. Is the Company proposing to change Rule H’s 1
fixed charges, credits or overhead rate as part of its 2
Application? 3
A. In keeping with Commission Order Nos. 30853, 4
30955 and 32472, the Company submits for the Commission’s 5
review updated Rule H charges, credits and the general 6
overhead rate prior to January 1st of each year. To avoid 7
duplicative efforts and potential customer confusion, and 8
in recognition that the existing charges, credits and 9
general overhead rate were just updated on March 15, 2023, 10
the Company believes it reasonable at this time to defer 11
updating these Rule H charges and credits until its routine 12
annual compliance filing. 13
Rule J 14
Q. What changes is the Company proposing be made 15
to Rule J (Continuity, Curtailment and Interruption of 16
Electric Service) of its tariff? 17
A. Rule J should be updated to include reference 18
to the service voltage ranges described in the current 19
edition of standard C84.1 of the American National 20
Standards Institute – American National Standard for 21
Electric Power Systems and Equipment – Voltage Ratings 22
(60Hz). Because the Company currently adheres to the 23
referenced service voltage standard, inclusion of the 24
reference will not result in a change to how the Company 25
MALONEY, DI 44
Idaho Power Company
operates or designs its system; however, it will provide 1
greater clarity and transparency to customers. 2
Rule L 3
Q. What changes are you proposing be made to Rule 4
L (Deposits) of Idaho Power’s tariff? 5
A. Rule L has been updated to provide the Company 6
flexibility to return a large commercial or special 7
contract customer’s collected deposit, and any accrued 8
interest, early if such customer establishes good credit 9
prior to the deposit being held for 12 months. This change 10
better aligns Rule L’s deposit retention requirements with 11
IDAPA 31.21.01.107.04, which allows for the early return of 12
deposits and accrued interest to residential and small 13
commercial customers. 14
Rule M 15
Q. What changes is the Company proposing be made 16
to Rule M (Facilities Charge Service) of its tariff? 17
A. Section 4 of Rule M has been updated to 18
plainly state that the monthly facilities charge amount 19
assessed for Company-owned facilities installed at the 20
customer’s request on the customer’s side of the Point of 21
Delivery is independent of a customer’s monthly energy 22
usage. The Company also seeks to clarify that a facilities 23
charge customer remains financially responsible for their 24
monthly facilities charge bill until either another 25
MALONEY, DI 45
Idaho Power Company
customer requests to assume responsibility for such 1
facilities charge arrangement, and the Company is agreeable 2
to providing Rule M services to such requesting customer, 3
or the facilities charge customer pays the non-salvable 4
cost associated with the removal of all Company-owned 5
facilities beyond the Point of Delivery. 6
Q. Does the proposed verbiage update to Section 4 7
of Rule M change how the Company assesses facilities 8
charges to customers? 9
A. No. The Company currently bills facilities 10
charges in the manner described within the proposed 11
verbiage within Section 4 of Rule M. This proposed update 12
simply provides customers with greater transparency of the 13
Company’s practices associated with this optional service. 14
VII. MISCELLANEOUS SCHEDULE UPDATES 15
Q. What other schedules is the Company proposing 16
to update as part of its application? 17
A. The Company is proposing to remove schedules 18
that are no longer active, eliminate water and space 19
heating provisions within its residential service 20
schedules, update the past due threshold amount 21
necessitating a Tier 2 deposit under Schedule 24, 22
Agricultural Irrigation Service, and update the Company-23
provided payment amount under Schedule 61, Payment for Home 24
Wiring Audit. 25
MALONEY, DI 46
Idaho Power Company
Q. What schedules is the Company proposing to 1
remove from its tariff? 2
A. The Company is proposing to remove the below 3
listed schedules from its tariff since the schedules are 4
either suspended or unused by customers. 5
• Schedule 4, Residential Service Energy Watch 6
Pilot Plan 7
• Schedule 60, Solar Photovoltaic Service Pilot 8
Program 9
• Schedule 63, Community Solar Pilot Program 10
Q. Why is the Company proposing to remove the 11
space and water heater provisions from its residential 12
service schedules? 13
Q. The Company’s proposal is intended to 14
streamline and simplify its residential service schedules 15
and their respective interconnection requirements. These 16
provisions are also already generally covered within Rule 17
K, Customer’s Load and Operations, of the Company’s tariff. 18
Additionally, the Company’s Customer Requirements for 19
Electric Service document remains updated with relevant 20
provisions, industry standards, and/or best practices. 21
Q. Please explain the update being proposed to 22
Schedule 24’s past due threshold amount necessitating a 23
Tier 2 deposit. 24
MALONEY, DI 47
Idaho Power Company
A. The Company is proposing to increase Schedule 1
24’s past due threshold amount necessitating a Tier 2 2
deposit from $1,000 to $1,500 to better align with the 3
amount of inflation that has materialized since Schedule 4
24’s Tier 2 deposit requirements were first authorized by 5
Commission Order No. 29639, issued in Case No. IPC-E-04-20. 6
Q. Please explain the updated Company-provided 7
payment amount being proposed within Schedule 61. 8
A. The Company proposes to raise the payment for 9
customers who undergo a home wiring audit from $40 to $60. 10
The proposed Company-provided payment amount of $60 is 11
based on escalating the existing payment amount by the 12
amount of inflation that has materialized since the 13
existing payment amount was established as part of Case No. 14
IPC-E-07-08. 15
Q. Does this conclude your direct testimony in 16
this case? 17
A. Yes, it does. 18
// 19
// 20
//21
MALONEY, DI 48
Idaho Power Company
DECLARATION OF RILEY MALONEY 1
I, Riley Maloney, declare under penalty of perjury 2
under the laws of the state of Idaho: 3
1. My name is Riley Maloney. I am employed by 4
Idaho Power Company as a Regulatory Analyst in the 5
Regulatory Affairs Department. 6
2. On behalf of Idaho Power, I present this 7
pre-filed direct testimony in this matter. 8
3. To the best of my knowledge, my pre-filed 9
direct testimony is true and accurate. 10
I hereby declare that the above statement is true to 11
the best of my knowledge and belief, and that I understand 12
it is made for use as evidence before the Idaho Public 13
Utilities Commission and is subject to penalty for perjury. 14
SIGNED this 1st day of June 2023, at Boise, Idaho. 15
16
Signed: _________________________ 17 RILEY MALONEY 18
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