20231115Direct Bradley Heusinkveld in Support of Stipulation and Settlement.pdf

IDAHO PUBLIC UTILITIES COMMISSION, Case No. ICP-E-23-11
ICL; Settlement Testimony of B. Heusinkveld
Matthew A. Nykiel (ISB No. 10270)
710 N. 6th St.
Boise, Idaho 83702
Phone: [phone]
Email: [e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC
SERVICE IN THE STATE OF IDAHO AND
FOR ASSOCIATED REGULATORY
TREATMENT
)
)
)
)
)
)
)
)
CASE NO. IPC-E-23-11
TESTIMONY IN SUPPORT OF SETTLEMENT STIPULATION
OF BRADLEY J. HEUSINKVELD
FOR THE IDAHO CONSERVATION LEAGUE
November 15, 2023
RECEIVED
2023 NOVEMBER 15, 2023 4:18PM
IDAHO PUBLIC
UTILITIES COMMISSION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

HEUSINKVELD, DI
Idaho Conservation League
Page 1
I. INTRODUCTION AND TESTIMONY
Q. Please state your name.
A. My name is Bradley J. Heusinkveld.
Q. Please state your employer, business address, and position.
A. I am the Energy Policy Associate for the Idaho Conservation League. My business
address is 710 N. 6th Street, Boise, Idaho.
Q. Please describe your educational and professional background.
A. I hold a Batchelor of Science Degree in Chemistry from the University of Puget
Sound and Juris Doctorate from Lewis & Clark Law School. Prior to pursuing a law degree,
I worked as an analytic chemist, first under contract for the Environmental Protection
10 CERCLA Emergency Response program in Seattle, Washington, and
then for Glorietta Geoscience, Inc., a hydrogeology consulting firm in Santa Fe, New
Mexico.
Integrated Resource Planning, efficiency program development, and other avenues for
energy and decarbonization advocacy. I frequently engage in utility dockets at the Idaho
brought by Intermountain Gas Company and Avista Corporation in the past calendar year. I
advise my colleagues at ICL on energy and regulatory matters as they intersect with other
with colleagues across the Pacific and Intermountain West on regional energy advocacy.
//
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

HEUSINKVELD, DI
Idaho Conservation League
Page 2
My organizational goal is to promote access to affordable and reliable energy that
ensures the quality of life of Idahoans by protecting clean air, clean water, resilient
landscapes and critical to all, a stable climate system.
Q. Have you previously testified before the Commission?
A.
General Rate Case, AVU-E-23-01, at technical hearings before the Commission on August
2, 2023. My testimony was limited in scope to the written responses of Lauren McCloy, a
colleague employed by the Northwest Energy Coalition.
Q. What is the purpose of your testimony in this proceeding?
A. The purpose of my testimony is to support the settlement stipulations agreed to by
all intervenor parties
-E-23-11. Intervenor parties (collectively,
Parties are:
The Company filed a proposed
settlement agreement and an accompanying motion with the Commission on October 27,
settlement and recommends the Commission adopt it without material alteration or
conditions.
//
//
//
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

HEUSINKVELD, DI
Idaho Conservation League
Page 3
Q. Do you believe the settlement is in the public interest and meets fair, just, and
reasonable standards.
A. Yes. Parties agreed to the proposed settlement following extensive negotiations and
, work papers, discovery, and data requests.
Importantly, all Parties agreed to the settlement in its totality. Staff and intervenors
collectively represent a diverse set of customer groups and interests. Reaching an agreeable
compromise between all twelve Parties necessitated balancing these interests, while
ICL believes the settlement is a fair compromise and in the public interest. Parties arrived at
moderate reductions in revenue requirement, rate of return, revenue adjustments, and
reasonable alterations to rate design elements. Broadly, these adjustments would reduce bill
impacts to customers, more equitably spread revenue burdens between customer classes,
gradually change rate design elements, and better align cost allocation to system costs. We
believe the
application.
Q. How did the Parties arrive at settlement?
A. Settlement meetings with the Company began on September 18, 2023 followed by a
series meetings between Staff and intervenors. All parties attended, in person or remotely.
While the contents of the negotiations remain confidential under Commission Rule 272, the
parties extensively negotiated the multitude of issues presented by the C
application, resulting in several iterative settlement proposals. Individual parties supported
positions with various analyses and sample work papers, some of which are incorporated
into the proposed settlement before the Commission. Over three weeks of meetings
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

HEUSINKVELD, DI
Idaho Conservation League
Page 4
concluding on October 5, 2023, Parties and the Company gradually moved towards the
broad contours of a prospective agreement while addressing individual issues and
navigating inherent tensions and trade-offs between party positions. Staff and all the
intervenor parties aligned around a wholistic offer, which the Company accepted before
drafting and revising the proposed settlement and motion delivered to the Commission on
October 27, 2023.
Q. Did ICL advocate for any settlement provisions?
A. Yes. During negotiations ICL advocated for several positions and, at times,
supported the requests of other parties. In other instances, we withheld commentary or
deferred to the positions and analysis of others. To reach agreement, we moderated our
positions to accommodate other parties and the Company.
Q. How does the Settlement Address the Idaho Conservation Leagues interests?
A. aims to promote energy efficiency and renewable integration
as steps toward decarbonization. We believe the proposed settlement offers a marked
improvement If adopted by the
Commission, the settlement would more gradually increase monthly customer charges, an
issue we focused on in previous dockets before the Commission, as it impacts rate payer
interests in efficiency, intraclass equity, and its relation to long term resource planning and
,
commitment to develop a revenue neutral bill protection program, and engagement with
parties on examining cost of service methodologies. Additionally, the settlement allows the
Company to better utilize investment tax credits, support demand side management
programs, and manage its efficiency programs.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

HEUSINKVELD, DI
Idaho Conservation League
Page 5
Q. How did ICL evaluate the settlement stipulations?
A. ICL assessed the settlement stipulations in their totality. While we advocated for a
number of provisions, we ultimately agreed to the proposal as a whole, based on its fairness
and compatibility with the public interest.
application and the stipulations are interrelated, and fairness requires delicate balancing and
co-consideration. We believe the negotiations and proposed settlement before the
Commission accommodate this balance, and so offer our support. We would have been
unlikely to accept a bifurcated settlement with some parties agreeing on individual issues
and disagreeing on others. In this instance, an all-parties, all-issues settlement was key to
our evaluation of a fair and just offer.

II. CONCLUSION
Q. What are your recommendations regarding the proposed settlement?
A. I recommend the Commission accept the proposed settlement in whole without
material alteration or condition. It represents a fair compromise between the Company and
P concerns, and accommodates the public interest.
Q. Do you offer other concluding remarks?
A. Yes. I appreciate the efforts of the Staff, Company, and Parties in this matter. In my
opinion, the breadth and complexity of matters in this rate case is impressive and was well
handled. Reaching settlement required respect, tact, and flexibility from all, and it is good to
see commonality emerge from our various posts and perspectives.
Q. Does this conclude your testimony?
A. Yes, it does.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

HEUSINKVELD, DI
Idaho Conservation League
Page 6
DECLARATION OF BRADLEY J. HEUSINKVELD

I, Bradley J. Heusinkveld, declare under penalty of perjury under the laws of the state of Idaho:
1. My name is Bradley J. Heusinkveld. I am employed by the Idaho Conservation
League as Energy Policy Associate.
2. On behalf of the Idaho Conservation League, I present this pre-filed direct
testimony.
3. To the best of my knowledge, my testimony is true and accurate.
I declare that the above statement is true to the best of my knowledge and belief, and that I
understand it is made for use as evidence before the Idaho Public Utilities Commission and is subject
to penalty of perjury.

SIGNED this 15th Day of November 2023 in Boise, Idaho.
Signed :
Bradley J. Heusinkveld

IDAHO PUBLIC UTILITIES COMMISSION, Case No. ICP-E-23-11
Idaho Conservation League Certificate of Service

Page 1
CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of November, 2023, I delivered true and correct
copies of the foregoing TESTIMONY to the following persons via the method of service noted:

/s/ Matthew A. Nykiel

Matthew A. Nykiel (ISB No. 10270)
Attorney for Idaho Conservation League

Electronic Mail Only (See Order No.
35058):

Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
[e-mail]

Commission Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]

Idaho Power Company
Lisa Nordstrom
Megan Goicoechea Allen
Donovan Walker
[e-mail]
[e-mail]
[e-mail]

Tim Tatum
Connie Aschenbrener
Matt Larkin
[e-mail]
[e-mail]
[e-mail]

Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920. N. Clover Dr.
Boise ID, 83703
[e-mail]

Mike Heckler
Courtney White
[e-mail]
[e-mail]

IIPA
Eric Olsen
Echo Hawk & Olsen, PLLC
P.O. Box 6119
Pocatello, ID 83205

Lance D. Kaufman, Ph.D
2623 Blue Bell Pl.
Corvallis OR, 97330
[e-mail]

IDAHO PUBLIC UTILITIES COMMISSION, Case No. ICP-E-23-11
Idaho Conservation League Certificate of Service

Page 2
ICIP
Peter Richardson
Richardson Adams, PLLC
[e-mail]

Dr. Don Reading
280 Silverwood Way
Eagle ID, 83616

Micron Technology, Inc.
Jim Swier
Micron Technology, Inc.
8000 S. Federal Way
Boise ID, 83707

Austin Rueschhoff
Thorvald Nelson
Austin W. Jensen
Holland & Hart, LLP
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

IdaHydro
Tom Arkoosh
Arkoosh Law Office
913 W. River St., Suite 450
P.O. Box 2900
[e-mail]
[e-mail]

City of Boise
Ed Jewel
Daryl Early
Deputy City Attorneys

150 N. Capitol Blvd., PO Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]

Wil Gehl
Boise City Dept. of Public Works
[e-mail]

Federal Executive Agencies
Peter Meier
U.S. Department of Energy
1000 Independence Ave.
SW Washington, D.C. 20585
[e-mail]

Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
[e-mail]

NW Energy Coalition
Diego Rivas
NW Energy Coalition
1101 8th Ave.
Helena, MT 59601
[e-mail]

Benjamin J. Otto
1407 W. Cottonwood Court
Boise, ID 83702
[e-mail]

Walmart, Inc.
Justina A. Caviglia, pro hac vice
Parsons Behle & Latimer
50 West Liberty St., Ste. 750
Reno, NV 89502
[e-mail]

Stephen Chriss
Walmart, Inc.
2608 Southeast J Street
Bentonville, AR 72716
[e-mail]