20231115Direct Wil Gehl in Support of Stipulation and Settlement.pdf

JAYME B. SULLIVAN
BOISE CITY ATTORNEY

Darrell Early ISB No. 4748
Ed Jewell ISB No. 10446
Deputy City Attorney
BOISE CITY ATTORNEY’S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Email: [e-mail]

Attorneys for the Intervenor

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
IN THE STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY ACCOUNT
TREATMENT.
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CASE NO. IPC-E-23-11

DIRECT TESTIMONY OF WIL GEHL

IN SUPPORT OF SETTLEMENT STIPULATION ON BEHALF OF THE CITY OF BOISE
CITY

NOVEMBER 15, 2023

RECEIVED
Wednesday, November 15, 2023 3:19:06 PM
IDAHO PUBLIC
UTILITIES COMMISSION

GEHL, DI 1
City of Boise
I. IDENTIFICATION 1
Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS FOR THE RECORD. 2
A. My name is Wil Gehl and my business address is 150 North Capitol Boulevard, Boise, 3
Idaho. 4
Q. WHERE ARE YOU EMPLOYED? 5
A. I am employed by the city of Boise City (“Boise City”) as the Energy Program Manager 6
in the Department of Public Works. 7
II. PURPOSE AND SUMMARY 8
Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY? 9
A. I discuss Boise City’s support for the October 27, 2023, Stipulation and Settlement 10
(“Proposed Settlement”) entered into by Idaho Power Company (“Company”), the Idaho 11
Public Utilities Commission (“Commission”) Staff, and all Intervenors in this 12
proceeding, collectively referred to as the “Parties”. 13
Q. PLEASE SUMMARIZE THE TOPICS COVERED BY YOUR TESTIMONY. 14
A. First, I describe the settlement process and summarize significant provisions of the 15
Proposed Settlement. I then explain Boise City’s support for the Proposed Settlement and 16
why Boise City believes it is in the public interest. 17
Q. PLEASE SUMMARIZE YOUR RECOMMENDATIONS. 18
A. I recommend the Commission adopt the Proposed Settlement as agreed to by the Parties. 19
The Proposed Settlement represents a compromise between all Parties, including a 20
significantly lower revenue requirement and corresponding rate increase than originally 21

GEHL, DI 2
City of Boise
proposed by the Company and beneficial modifications to rate design and rate spread. 1
Boise City believes the Proposed Settlement is in the public interest. 2
III. SETTLEMENT SUMMARY 3
Q. HAVE YOU REVIEWED THE OCTOBER 27, 2023, PROPOSED SETTLEMENT 4
AND THE COMPANY’S ACCOMPANYING SUPPORTING TESTIMONY? 5
A. Yes. 6
Q. PLEASE SUMMARIZE THE SETTLEMENT PROCESS AND BOISE CITY’S 7
PARTICIPATION? 8
A. The Parties met for a series of settlement conferences beginning on September 18, 2023 9
and concluding on October 5, 2023. Parties presented positions and engaged in 10
discussions on the Company’s application and proposed rate increase as well as 11
additional proposals on cost-of-service, rate design, rate spread, energy efficiency and 12
other items. Boise City participated in all settlement meetings and presented its analysis 13
and proposals to be considered by Parties in the context of the broader settlement 14
discussions. Boise City was particularly concerned with the potential impacts on 15
residential customers from this proceeding. While Parties were not able to reach 16
agreement on all revenue requirement modifications or all proposals made by intervenors, 17
the Parties reached a compromise position, resulting in an overall revenue increase of 18
$54.7 million or approximately 4.25% average rate increase and an authorized Idaho 19
jurisdictional rate base of $3,816,351,478. 20
Q. IN ADDITION TO THE REVENUE REQUIREMENT, PLEASE SUMMARIZE 21
KEY PROVISIONS OF THE PROPOSED SETTLEMENT? 22

GEHL, DI 3
City of Boise
A. The Parties reached a compromise position reflected in the Proposed Settlement that is 1
based on an agreement to settle all issues in this docket, including rate design, revenue 2
sharing, prudency determinations, rate spread and other issues. The Proposed Settlement 3
sets out a 2-year increase in monthly service charges for residential customers from the 4
currently authorized level of $5 per month to $10 per month in 2024 and $15 per month 5
in 2025. The Proposed Settlement also includes an agreement reached by Parties to 6
modify the Company’s revenue sharing mechanism and the Company’s ability to 7
accelerate amortization of Accumulated Deferred Investment Tax Credits (“ADITC”). 8
The Parties agreed to a rate spread methodology where each customer class below 120 9
percent of cost of service will be increased by at least 0.5 times the overall 4.25 percent 10
increase and the maximum increase will be capped 1.3 times. Any customer class above 11
120 percent of cost-of-service level will see no rate increase. The Parties agreed to use 12
the Company’s cost of service methodology for limited purposes, including establishing 13
an appropriate rate spread. 14
Q. PLEASE EXPLAIN WHY THE PROPOSED SETTLEMENT ADDRESSES THE 15
CONCERNS OF BOISE CITY. 16
A. While the Proposed Settlement and Stipulation entered into by all Parties does not 17
address every issue identified by Boise City in its review of the Company’s application, 18
the Proposed Settlement in its entirety, inclusive of the changes to rate spread, monthly 19
service charges, and revenue sharing mechanisms, reasonably addresses the affordability 20
and clean energy concerns of Boise City in this proceeding. Boise City is extremely 21
sensitive to the impacts of any rate increase on its residents and believes the Proposed 22
Settlement strikes a reasonable balance between maintaining affordability for customers 23
GEHL, DI 4
City of Boise
and ensuring the Company can recover its prudently incurred costs. The Proposed 1
Settlement, if approved by the Commission, would result in approximately 50% smaller 2
overall rate increase compared to the Company’s Application; a smaller and more gradual 3
increase in residential monthly service charges; and improved revenue sharing while 4
maximizing the Company’s opportunity to benefit from investment tax credits secured 5
through clean energy deployment. Additionally, the Proposed Settlement promotes 6
continued investment in energy efficiency and promotes demand-side management 7
program participation. Boise City believes these are a significant benefit to Idaho Power 8
ratepayers, including Boise City residents. 9
Q.DO YOU HAVE ANY ADDITIONAL COMMENTS ON THE SETTLEMENT OR 10
PROCESS? 11
A.Yes. Boise City recognizes the important contributions of the Company, Commission 12
Staff, and Intervenors to effectively reach a settlement in this general rate case. With 13
significant time elapsed since the Company’s last General Rate Case, Boise City 14
appreciates the collaborative and straightforward discussions with all parties to resolve as 15
many contested issues as possible in this proceeding. Boise City looks forward to further 16
engagement with Parties in the proposed workshop series and in future proceedings. 17
IV.RECOMMENDATIONS18
Q.WHAT IS BOISE CITY’S RECOMMENDATION TO THE COMMISSION? 19
A.Boise City recommends the Commission approve the Proposed Settlement as agreed to 20
by the Parties in its entirety, without material change or condition. 21
Q.PLEASE EXPLAIN WHY YOU BELIEVE THE PROPOSED SETTLEMENT IS 22
IN THE PUBLIC INTEREST. 23
GEHL, DI 5
City of Boise
A.Boise City believes the overall result of the Proposed Settlement is a reasonable and fair1
compromise between the Company and its customers. The overall revenue requirement in2
the Proposed Settlement balances customer interests with the Company’s ability to make3
necessary investments to support the safe provision of affordable, clean electricity to its4
customers. Boise City believes the gradual and moderated rate increase resulting from the5
Proposed Settlement is in the public interest.6
Q.DOES THIS CONCLUDE YOUR TESTIMONY?7
A.Yes, thank you.8
CITY OF BOISE CITY’S PETITION TO INTERVENE - 4
CERTIFICATE OF SERVICE
I hereby certify that I have on this _____ day of November 2023, served the foregoing
documents on all parties of record as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Ste. 201-A
Boise, ID 83714
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Chris Burdin
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Ste. 201-A
Boise, ID 83714
[e-mail]
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Lisa Nordstrom
Donovan Walker
Megan Goicoechea Allen
Idaho Power Company
PO Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Tim Tatum
Connie Aschenbrenner
Matt Larkin
Idaho Power Company
PO Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
15th
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CITY OF BOISE CITY’S PETITION TO INTERVENE - 5
Courtney White
Mike Heckler
3778 Plantation Dr. Suite 102
Boise, ID 83703
[e-mail]
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Peter Richardson
Industrial Customers of Idaho Power
Richardson Adams, PLLC
515 N. 27th St.
Boise, ID 83702
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Dr. Don Reading
280 Silverwood Way
Eagle, ID 83616
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Eric Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave. Suite 100
P.O. Box 6119
Pocatello, ID 83205
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Lance Kaufman
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Austin Rueschhoff
Thorvald Nelson
Austin Jensen
Holland & Hart, LLP
555 17th St. Suite 3200
Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
X
X
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CITY OF BOISE CITY’S PETITION TO INTERVENE - 6
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Tom Arkoosh
Arkoosh Law Offices
913 W. River St. Suite 450
Boise, ID 83701
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Matthew Nykiel
Brad Heusinkveld
Idaho Conservation League
710 N. 6th St.
Boise, ID 83702
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Peter Meier
U.S. Department of Energy
1000 Independence Ave., SW
Washington, D.C. 20585
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
F. Diego Rivas
NW Energy Coalition
1101 8th Ave.
Helena, MT 59601
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Benjamin J. Otto
1407 W. Cottonwood Court
Boise, ID 83702
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
X
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CITY OF BOISE CITY’S PETITION TO INTERVENE - 7
Steve W. Chriss
Director, Energy Services
Walmart, Inc.
2608 Southeast J Street
Bentonville, AR 72716
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Jusina A. Caviglia, pro hac vice
Parsons Behle & Latimer
50 W. Liberty St. Suite 750
Reno, NV 89052
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main St. Suite 1300
Boise, ID 83702
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
________________________________
Alison Berriochoa
Paralegal
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