20230601Direct Thompson.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS RATES
IN THE STATE OF IDAHO AND FOR ASSOCIATED REGULATORY TREATMENT.
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CASE NO. IPC-E-23-11

IDAHO POWER COMPANY DIRECT TESTIMONY
OF ROBERT Z. THOMPSON

Thompson, DI 1
Idaho Power Company
Q. Please state your name and business address. 1
A. My name is Robert Z. Thompson. I go by my 2
middle name, and therefore, Zack Thompson is my preferred 3
name. My business address is 1221 West Idaho Street, Boise, 4
Idaho 83702. 5
Q. By whom are you employed, and in what 6
capacity? 7
A. I am employed by Idaho Power Company (“Idaho 8
Power” or “Company”) as a Regulatory Analyst in the 9
Regulatory Affairs Department. 10
Q. Please describe your educational background. 11
A. In May of 2008, I received a Bachelor of Arts 12
degree in Business, Organizations, and Society with a minor 13
in Economics from Franklin & Marshall College in Lancaster, 14
Pennsylvania. In May of 2014, I received a Master of 15
Business Administration degree with a specialization in 16
Finance from Louisiana State University in Baton Rouge, 17
Louisiana. I have also attended “The Basics: Practical 18
Regulatory Training for the Electric Industry,” an electric 19
utility ratemaking course offered through the New Mexico 20
State University’s Center for Public Utilities, “Electric 21
Utility Fundamentals and Insights,” an electric utility 22
course offered by Western Energy Institute, and “Electric 23
Rates Advanced Course,” an electric utility ratemaking 24
course offered through Edison Electric Institute. 25

Thompson, DI 2
Idaho Power Company
Q. Please describe your work experience with 1
Idaho Power. 2
A. In 2020, I was hired as a Regulatory Analyst 3
in the Company’s Regulatory Affairs Department. My primary 4
responsibilities include supporting activities associated 5
with demand-side management as well as rate design for the 6
small general service, large general secondary service, 7
lighting, and irrigation customer classes. 8
Q. What is the purpose of your testimony? 9
A. The purpose of my testimony is to describe 10
proposed changes and updates to Schedule 7, Small General 11
Service (“Schedule 7”), Schedule 9, Large General Secondary 12
Service (“Schedule 9S”), Schedule 24, Agricultural 13
Irrigation Service (“Schedule 24”), Schedule 15, Dusk to 14
Dawn Customer Lighting (“Schedule 15”), Schedule 41, Street 15
Lighting Service (“Schedule 41”), Schedule 42, Traffic 16
Control Signal Lighting Service (“Schedule 42”), and 17
Schedule 40, Non-metered General Service (“Schedule 40”). 18
Q. Are you sponsoring any exhibits? 19
A. Yes. I am sponsoring the following exhibits: 20
Exhibit Description 21
Exhibit No. 57 Calculation of Proposed Rates 22
Exhibit No. 58 Typical Monthly Billing Comparison 23

Thompson, DI 3
Idaho Power Company
I. SMALL GENERAL SERVICE & LARGE GENERAL SERVICE 1
(SECONDARY) 2
A. Schedule 7, Small General Service 3
Q. What is the revenue requirement to be 4
recovered from Schedule 7 customers? 5
A. The annual revenue requirement to be recovered 6
from Schedule 7 and Schedule 8 customers is $20,108,644 as 7
shown on page 5 of Company Witness Mr. Paul Goralski’s 8
Exhibit No. 48, which represents the capped 12.91 percent 9
increase in overall collection from the class. 10
Q. What is the present rate structure for Small 11
General Service under Schedule 7? 12
A. Customers taking service under Schedule 7 pay 13
a monthly Service Charge, a monthly seasonal Energy Charge 14
for the first 300 kilowatt-hours (“kWh”) used, and a 15
separate seasonal Energy Charge for all usage over 300 kWh 16
in a month. Summer Energy Charges begin on June 1 of each 17
year and end on August 31 of each year while the non-summer 18
Energy Charges begin on September 1 of each year and end on 19
May 31 of each year. Schedule 7 customers do not have a 20
Demand Charge. 21
Q. Please describe the proposed rate design 22
adjustments for Schedule 7. 23
A. The Company is not proposing any structural 24
changes to the Schedule 7 rate design. However, the Company 25

Thompson, DI 4
Idaho Power Company
is proposing to make three updates. The first update is 1
increasing the service charge to $20.00, or an increase of 2
$15.00, to move closer to the class cost of service. The 3
second update is “flattening” the inclining energy block 4
tiers to move closer towards flat energy rates. The third 5
update is moving the summer seasonal rates from June 1 to 6
August 31 to June 1 to September 30, or a three-month 7
summer season to a four-month summer season, as explained 8
by Company Witness Ms. Connie Aschenbrenner in her 9
testimony. 10
Q. What did Idaho Power consider in making its 11
$20.00 service charge proposal for Schedule 7 customers? 12
A. Beyond moving closer to cost of service, a 13
primary focus was placed on maintaining a smooth transition 14
if customers move from Schedule 7 to Schedule 9S because 15
they exceed the eligibility criteria for continued service 16
under Schedule 7. 17
Q. Have you prepared an exhibit that illustrates 18
the rate design proposal for revenue recovery under 19
Schedule 7? 20
A. Yes, the rate design proposal for Schedule 7 21
is included on page 1 of Exhibit No. 57. 22
Q. Have you prepared an exhibit that illustrates 23
the impact of the proposed rate adjustments on Small 24
General Service customers? 25

Thompson, DI 5
Idaho Power Company
A. Yes, page 1 of Exhibit No. 58 shows the 1
billing comparison between Schedule 7 existing rates and 2
proposed rates for typical billing levels. 3
B. Schedule 9, Large General Service 4
Q. What is the revenue requirement to be 5
recovered from customers taking Secondary Service under 6
Schedule 9? 7
A. The annual revenue requirement to be recovered 8
from customers taking Secondary Service under Schedule 9 is 9
$272,747,096 as shown on page 5 of Mr. Goralski’s Exhibit 10
No. 48, which represents a 1.08 percent increase in overall 11
collection from the class. 12
Standard Service Rate Design 13
Q. What is the current rate structure for 14
Schedule 9S? 15
A. The current rate structure for Schedule 9S 16
includes a two-tier declining block Energy Charge along 17
with a block Demand Charge and a block Basic Charge. Under 18
this rate structure, the first block Energy Charge applies 19
to the first 2,000 kWh of usage per month and the second 20
block Energy Charge applies to all usage greater than 2,000 21
kWh per month. 22
Under the Demand Charge, the first rate block 23
applies to the first 20 kilowatts (“kW”) of Billing Demand 24
and the second block applies to all additional kW. For the 25

Thompson, DI 6
Idaho Power Company
Basic Charge, the first rate block applies to the first 20 1
kW of Basic Load Capacity and the second block applies to 2
all additional kW. 3
Q. Have you prepared an exhibit that illustrates 4
the rate design proposal for revenue recovery under 5
Schedule 9 Secondary Service? 6
A. Yes, the rate design proposal for Schedule 9 7
Secondary Service is included on page 3 of Exhibit No. 57. 8
Q. What changes is the Company proposing to the 9
Schedule 9S structure? 10
A. The Company is proposing to: (1) change the 0-11
20 kW basic load capacity charge (“BLC”) and demand charge 12
blocks to assess a single rate for all kW, and (2) move 13
from declining block energy rates to flat energy rates for 14
both the summer and non-summer seasons. 15
Q. What other changes is the Company proposing 16
for Schedule 9S? 17
A. The Company is proposing to increase the 18
service charge to $25.00, or an increase of $9.00, to move 19
closer to the class cost of service. The Company is also 20
proposing moving the summer seasonal rates from June 1 to 21
August 31 to June 1 to September 30, or a three-month 22
summer season to a four-month summer season, as explained 23
by Ms. Aschenbrenner in her testimony. Finally, for all 24
non-service charge rate components, the Company is 25

Thompson, DI 7
Idaho Power Company
proposing rates that represent a 30 percent incremental 1
movement towards the costs to serve that rate component. 2
Q. Have you prepared an exhibit that shows the 3
bill impact for the proposed Schedule 9S rate design? 4
A. Yes. Pages 2 through 4 of Exhibit No. 58 show 5
the billing comparison between the Schedule 9S existing 6
rates and proposed rates for typical billing levels. As 7
can be seen from this exhibit, generally for each Demand 8
level, the higher load factor customers will see a decrease 9
in their overall bills as compared to low load factor 10
customers that will see an increase. For the Demand levels 11
below 20 kW, customers will generally see bill decreases 12
based on the removal of the 0-20 kW BLC and Demand blocks. 13
Optional Time-of-Use Service Schedule 14
Q. How did you develop the proposed optional 15
Schedule 9S time-of-use (“TOU”) service offering? 16
A. The optional Schedule 9S TOU service offering 17
will incorporate the same structure as the proposed 18
Schedule 9S standard service offering described above 19
except that instead of seasonal flat energy charges there 20
will be seasonal time-differentiated energy rates which 21
include on-, mid-, and off-peak blocks for the summer and 22
non-summer seasons. Ms. Aschenbrenner explains in greater 23
detail in her testimony the rationale for offering 24
customers the optional TOU Service under Schedule 9S. 25

Thompson, DI 8
Idaho Power Company
Q. What definition for on-, mid-, and off-peak 1
does the Company propose for Schedule 9S? 2
A. The proposed TOU periods will mirror those 3
proposed for the other large general and large power 4
service schedules, as described by Company Witness Mr. 5
Grant Anderson. Accordingly, the proposed definition of the 6
TOU periods for the summer season are: 7
• On-Peak: 7:00 p.m. to 11:00 p.m. Monday through 8
Saturday, except holidays 9
• Mid-Peak: 3:00 p.m. to 7:00 p.m. and 11:00 p.m. 10
to 12:00 a.m. Monday through Saturday, except 11
holidays 12
• Off-Peak: 12:00 a.m. to 3:00 p.m. Monday through 13
Saturday and all hours on Sunday and holidays 14
For the non-summer season, the Company proposes to change 15
the definition of the TOU periods to the following: 16
• On-Peak: 6:00 a.m. to 9:00 a.m. and 5:00 p.m. to 17
8:00 p.m. Monday through Saturday, except 18
holidays 19
• Mid-Peak: 9:00 a.m. to 12:00 p.m., 4:00 p.m. to 20
5:00 p.m., and 8:00 p.m. to 10:00 p.m. Monday 21
through Saturday, except holidays 22
• Off-Peak: 10:00 p.m. to 6:00 a.m. and 12:00 p.m. 23
to 4:00 p.m. Monday through Saturday and all 24
hours on Sunday and holidays 25

Thompson, DI 9
Idaho Power Company
Q. Have you prepared an exhibit that illustrates 1
the rate design proposal for the optional TOU service under 2
Schedule 9S? 3
A. Yes, the rate design proposal for the optional 4
TOU service under Schedule 9S is included on page 4 of 5
Exhibit No. 57. 6
II. IRRIGATION 7
A. Schedule 24, Agricultural Irrigation Service 8
Q. What is the revenue requirement to be 9
recovered from Schedule 24? 10
A. The annual revenue to be recovered from 11
Schedule 24 customers is $183,423,605, as shown on page 5 12
of Mr. Goralski’s Exhibit No. 48, which represents the 13
capped 12.91 percent increase in overall collection from 14
the class. 15
Q. What is the current rate structure for 16
Schedule 24? 17
A. Service under Schedule 24 is classified as 18
being either “in-season” or “out-of-season.” The in-season 19
for each customer begins with the customer’s meter reading 20
for the May billing period and ends with the customer’s 21
meter reading for the September billing period. The out-22
of-season encompasses all other billing periods. 23
For the in-season, customers pay a higher monthly 24
Service Charge than during the out-of-season to encourage 25

Thompson, DI 10
Idaho Power Company
customers to continue service throughout the out-of-season 1
period. 2
Customers pay both an Energy Charge and a Demand 3
Charge for metered usage in-season. The Energy Charge 4
utilizes a load-factor pricing mechanism by separating 5
charges into two energy blocks. The first block charges 6
irrigation customers a monthly rate per kWh for the first 7
164 kWh per kW of demand. The second block charges 8
customers a lower monthly energy rate per kWh for all other 9
energy use to encourage installation of energy efficient 10
irrigation systems with reduced demand and longer hours of 11
operation. Customers pay an in-season Demand Charge only. 12
During the out-of-season, customers pay a flat Energy 13
Charge per kWh for all energy use. 14
Both Secondary Service and Transmission Service are 15
available under Schedule 24, although no customers are 16
currently taking Transmission Service. 17
Q. What is Idaho Power’s rate design proposal for 18
Schedule 24? 19
A. The Company is proposing one structural change 20
to the Schedule 24 rate design along with one update. The 21
structural change includes removing the in-season load 22
factor energy pricing and only charging a flat rate per 23
kWh, which is the same structure as the out-of-season 24
energy charge. The current in-season load factor energy 25

Thompson, DI 11
Idaho Power Company
rate structure was intended to collect demand related costs 1
in the first block rather than increasing the demand 2
charge. This helped the Company collect some of its fixed 3
costs as long as customers ran their pumps for about 7 days 4
within a month. However, from a customer understandability 5
standpoint, it has sometimes been a source of confusion, 6
particularly because the out-of-season rate does not have 7
the load factor pricing structure. Therefore, the Company 8
is proposing both the in-season and out-of-season 9
volumetric rates have the same structure. 10
The proposed update to the Schedule 24 rate design 11
increases both the in-season and out-of-season service 12
charges from $22.00 and $3.50 to $30.00 and $6.00, 13
respectively, for an increase of $8.00 for in-season and 14
$2.50 for out-of-season, to move closer to the class cost 15
of service. 16
Consistent with the overall rate design objectives, 17
the Company is proposing to move the other non-service 18
charge rate components closer to their cost-of-service with 19
rates that represent a 30 percent incremental movement 20
towards the costs to serve that rate component. 21
Q. Have you prepared an exhibit that illustrates 22
the rate design proposal for revenue recovery under 23
Schedule 24? 24

Thompson, DI 12
Idaho Power Company
A. Yes, the rate design proposal for Schedule 24 1
is included on page 5 of Exhibit No. 57. 2
Q. How were the rates for Transmission Service 3
determined? 4
A. Because no customers take Transmission Service 5
under Schedule 24, once the percentage revenue changes for 6
each rate component were determined for Secondary Service, 7
the same percentage changes were applied to each component 8
for Transmission Service to maintain the same relationship 9
between the service levels that currently exists. 10
Q. Have you prepared an exhibit that shows the 11
billing impact of the rate design on Schedule 24 irrigation 12
service customers? 13
A. Yes, pages 5 through 7 of Exhibit No. 58 show 14
the impact on customers’ bills of the proposed rate 15
adjustments for Schedule 24 Secondary Service. As can be 16
seen page 7 from Exhibit No. 58, with the transition from 17
load factor pricing to flat energy rate pricing and an 18
increased demand charge, customers with the highest 19
percentage increase in annual bills have the lowest average 20
load factors. Because the rate design promotes using the 21
system efficiently, the higher a customer's load factor, 22
the more beneficial the rate structure tends to be. 23

Thompson, DI 13
Idaho Power Company
III. LIGHTING & NON-METERED 1
Q. How have you organized the discussion of the 2
rate design proposals for area lighting, unmetered service, 3
street lighting and traffic control signal lighting? 4
A. The discussion of rate design proposals for 5
lighting will address Schedules 15 (Dusk to Dawn Customer 6
Lighting), 41 (Street Lighting Service), 42 (Traffic 7
Control Signal Lighting Service), and 40 (Non-metered 8
General Service), respectively. 9
A. Schedule 15, Dusk to Dawn Customer Lighting 10
Q. What is the revenue requirement to be 11
recovered from customers taking service under Schedule 15? 12
A. The annual revenue requirement to be recovered 13
from Schedule 15 customers is $1,327,038 as shown on page 5 14
of Mr. Goralski’s Exhibit No. 48 which represents a zero 15
percent increase in overall collection from the class. 16
Q. What is the current rate structure for Dusk to 17
Dawn Customer Lighting under Schedule 15? 18
A. Customers taking service under Schedule 15 are 19
charged on a per lamp basis. Lamps currently served under 20
Schedule 15 include 100, 200, and 400 watt high pressure 21
sodium vapor area lighting, 40, 85, and 200 watt Light 22
Emitting Diode (“LED”) area lighting; 200 and 400 watt high 23
pressure sodium vapor flood lighting, 85, 150, and 300 watt 24

Thompson, DI 14
Idaho Power Company
LED flood lighting, and 400 and 1,000 watt metal halide 1
flood lighting. 2
Q. What is the status of the Company’s LED 3
conversion project authorized per Order No. 34452? 4
A. The Company is on schedule to complete its LED 5
conversion project before September 30, 2023. At that time, 6
all lighting fixtures under Schedules 15 and 41 will have 7
been converted to LED fixtures and the Company will no 8
longer support high pressure sodium vapor or metal halide 9
fixtures. 10
Q. Have you prepared an exhibit that illustrates 11
the rate design proposal for Schedule 15? 12
A. Yes. The rate design proposal for Schedule 15 13
is included on page 7 of Exhibit No. 57 which includes base 14
rate increases to recover the proposed revenue requirement. 15
The Company proposes to allocate the class revenue 16
requirement to the rate components based on a separate 17
lighting cost-of-service study (“Lighting Study”) conducted 18
for both Schedules 15 and 41 for each fixture size offered 19
under those schedules. The Lighting Study is contained in 20
my workpapers. 21
Q. Is the Company proposing any other changes to 22
Schedule 15? 23
A. As mentioned above, the Company will have 24
completed its LED conversion project by September 30, 2023. 25

Thompson, DI 15
Idaho Power Company
Therefore, the high pressure sodium vapor and metal halide 1
options are being removed with only the LED area lighting 2
and flood lighting rates remaining in the tariff. 3
B. Schedule 41, Street Lighting Service 4
Q. What is the revenue requirement to be 5
recovered from customers taking service under Schedule 41? 6
A. The annual revenue requirement to be recovered 7
from Schedule 41 is $3,750,417 as shown on page 5 of Mr. 8
Goralski’s Exhibit No. 48, which represents a zero percent 9
increase in overall collection from the class. 10
Q. What is the present rate structure for Street 11
Lighting Service under Schedule 41? 12
A. The current rate structure for Schedule 41 has 13
three service options for street lighting customers as 14
follows: 15
• “A” – Idaho Power-Owned, Idaho Power-Maintained 16 System 17 18
• “B”- Customer-Owned, Idaho Power-Maintained 19 System 20
21
• “C” – Customer-Owned, Customer-Maintained 22 System 23
24
Option “A” provides for Idaho Power-owned and Idaho 25
Power-maintained street lighting systems. Street lighting 26
systems under this option are not metered and customers pay 27
monthly lamp charges based on high pressure sodium vapor 28
lamps of 70, 100, 200, 250 or 400 watts or their LED 29

Thompson, DI 16
Idaho Power Company
equivalents of 40, 85, 140, and 200 watts. The monthly lamp 1
charges under Option “A” reflect the Company’s cost to 2
provide energy, install the street lighting system, and 3
provide ongoing maintenance. 4
Option “B” provides for metered or unmetered 5
Customer-Owned, Idaho Power-Maintained systems using 70, 6
100, 200, 250, or 400 watt high pressure sodium vapor 7
lamps. Option “B” is currently not open to new service and 8
will close by September 30, 2023, per Order No. 34452. 9
Option “C” provides for customers choosing to own 10
and install their own street lighting systems. Under this 11
option, street lighting systems may be metered or non-12
metered. For metered and non-metered systems, maintenance 13
is provided by the customer. 14
Q. Please describe the proposed updates to Option 15
“A”. 16
A. Beyond the proposed rate changes informed by 17
the Lighting Study for Schedules 15 and 41 contained in my 18
workpapers, the Company proposes to remove language 19
referencing “the Accelerated Replacement of Existing 20
Fixtures” as this charge was only related to the LED 21
conversion project and allowed customers to convert to LED 22
fixtures at an additional cost before the Company had them 23
scheduled. The Company also proposes to update the Dark Sky 24
Lighting option to remove the high-pressure sodium vapor 25

Thompson, DI 17
Idaho Power Company
lens and replace with an LED shield with a cost of $27.50 1
for customers who want to alter their LED fixtures for dark 2
sky lighting. The derivation of this value is shown in my 3
workpapers. 4
Q. What changes are being proposed to Option “C” 5
in Schedule 41? 6
A. Beyond the proposed rate changes informed by 7
the Lighting Study for Schedules 15 and 41 contained in my 8
workpapers, no other changes are being proposed for Option 9
“C”. There will continue to be metered and non-metered 10
service for customer-owned, customer-maintained systems. 11
Q. Is the Company proposing any other changes to 12
Schedule 41? 13
A. Yes, the Company proposes to remove all high-14
pressure sodium vapor language and wattages leaving the 15
schedule to only reference LED fixtures and to remove all 16
contents from the tariff associated with Option “B” as this 17
option will be closed by September 30, 2023. 18
Q. Have you prepared an exhibit that illustrates 19
the rate design proposal for Schedule 41? 20
A. Yes, the rate design proposal for Schedule 41 21
is included on pages 8 through 11 of Exhibit No. 57. 22
C. Schedule 42, Traffic Control Signal Lighting Service 23
Q. What is the revenue requirement to be 24
recovered from customers taking service under Schedule 42? 25

Thompson, DI 18
Idaho Power Company
A. The annual revenue requirement to be recovered 1
from Schedule 42 customers is $224,972 as shown on page 5 2
of Mr. Goralski’s Exhibit No. 48, which represents the 3
capped 12.91 percent increase in overall collection from 4
the class. 5
Q. What is the present rate structure for Traffic 6
Control Signal Lighting Service, Schedule 42? 7
A. Customers taking service under Schedule 42 pay 8
an Energy Charge for each kWh of estimated energy use for 9
non-metered systems and for each kWh of actual usage for 10
metered systems. For non-metered systems, usage is 11
estimated based on the number and size of lamps burning 12
simultaneously in each signal and the average number of 13
hours per day the signal is operated. There is no minimum 14
charge under Schedule 42. 15
Q. Please describe the rate design proposal for 16
Schedule 42. 17
A. The rate design proposal for Schedule 42 is 18
included on page 12 of Exhibit No. 57. The Company is 19
proposing to increase the energy charge to target the 20
proposed capped class revenue increase of 12.91 percent 21
shown on page 5 of Mr. Goralski’s Exhibit No. 48. 22
D. Schedule 40, Unmetered General Service 23
Q. What is the revenue requirement to be 24
recovered from customers taking service under Schedule 40? 25

Thompson, DI 19
Idaho Power Company
A. The annual revenue requirement to be recovered 1
from Schedule 40 customers is $1,352,288 as shown on page 5 2
of Mr. Goralski’s Exhibit No. 48, which represents a 3.24 3
percent increase in overall collection from the class. 4
Q. What is the present rate structure for 5
Unmetered General Service under Schedule 40? 6
A. Customers taking service under Schedule 40 are 7
non-metered but have energy loads and periods of operation 8
which are fixed. Accordingly, a customer’s estimated usage 9
is charged a flat Energy Charge which recovers all costs 10
assigned to the class. The minimum bill for service under 11
Schedule 40 is $1.50 per month. At the Company’s 12
discretion, an Intermittent Usage Charge, per unit, per 13
month, may be charged to municipalities or agencies of 14
federal, state, or county governments having the potential 15
of intermittent variations in energy usage. 16
Q. Please describe the rate design proposal for 17
Schedule 40. 18
A. The rate design proposal for Schedule 40 is 19
included on page 13 of Exhibit No. 57. The Company is 20
proposing to increase the Intermittent Usage Charge from 21
$1.00 to $1.50, or an increase of $0.50, as well as 22
increase the energy charge to target the proposed class 23
revenue increase of 3.24 percent as shown on page 5 of Mr. 24
Goralski’s Exhibit No. 48. 25

Thompson, DI 20
Idaho Power Company
Q. Are any other changes being proposed to 1
Schedule 40? 2
A. No. 3
Q. Does this conclude your testimony? 4
A. Yes, it does. 5
// 6

Thompson, DI 21
Idaho Power Company
DECLARATION OF ROBERT Z. THOMPSON 1
I, Robert Z. Thompson, declare under penalty of 2
perjury under the laws of the state of Idaho: 3
1. My name is Robert Z. Thompson. I am employed 4
by 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 and Exhibit Nos. 57 through 58 8
in this matter. 9
3. To the best of my knowledge, my pre-filed 10
direct testimony and exhibits are true and accurate. 11
I hereby declare that the above statement is true to 12
the best of my knowledge and belief, and that I understand 13
it is made for use as evidence before the Idaho Public 14
Utilities Commission and is subject to penalty for perjury. 15
SIGNED this 1st day of June 2023, at Boise, Idaho. 16
17 Signed: ___________________________ 18
ROBERT Z. THOMPSON 19