20240725Comments.pdf

RECEIVED
Thursday, July 25, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
JAYME B. SULLIVAN
BOISE CITY ATTORNEY
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
Telephone: [phone]
Facsimile: [phone]
Email: BoiseCityAttorneykcityofboise.org
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF Case No. IPC-E-24-11
IDAHO POWER COMPANY FOR A
DETERMINATION OF 2023 DEMAND-SIDE CITY OF BOISE CITY'S
MANAGEMENT EXPENSES AS PRUDENTLY COMMENTS
INCURRED
The city of Boise City ("Boise City") submits these formal comments on the application
submitted by Idaho Power Company ("Company") for a determination of 2023 energy efficiency
and demand response program expenses as prudently incurred. Boise City, pursuant to Rule 203
of the Commission's Rules of Procedure, IDAPA 31.01.01.203, and pursuant to the Notice of
Modified Procedure, Order No. 36232, issued by the Commission on June 18, 2024, hereby states
as follows:
SUMMARY
Boise City commends the Company on continuing to develop, offer, and implement cost-
effective energy efficiency programs and increasing program participation in its existing offerings.
Boise City recognizes the unique and important benefits that energy efficiency delivers to all
CITY OF BOISE CITY'S COMMENTS - I

customers and supports the continuation of robust, accessible, and cost-effective energy efficiency
measures.Boise City is encouraged by the Company's efforts to expand energy efficiency program
participation, including efforts to launch new programs like the Multifamily Energy Savings
Program, and responding to the changing needs for demand response. Application at 7. Boise City
commends the Company on its energy efficiency education and outreach to customers and
stakeholders. Boise City specifically recognizes the Company's efforts to reach low and moderate-
income customers through its Weatherization and Easy Savings programs.
BOISE CITY RECOMMENDS THE COMMISSION FIND COMPANY EXPENSES
WERE PRUDENTLY INCURRED
The Company continues to successfully navigate a rapidly evolving energy efficiency
landscape. Market transformation in lighting and peak energy demand growth necessitate new
approaches in demand-side management. Boise City is encouraged by the Company's overall
portfolio cost-effectiveness and thoughtful approach to updating energy efficiency measure
parameters as needed. Application at 7. The Company's total 139,683 megawatt-hours of energy
efficiency savings in 2023 and 15.9 average megawatt-hours of incremental energy efficiency
savings exceeded the energy efficiency potential from the 2023 IRP and is an overall indication of
the health of the Company's demand-side management programs. Application at 6. Boise City
appreciates the Company's extensive engagement efforts to ensure robust demand response
program participation, resulting in an available capacity of 316 MW in the 2023 program season.
Application at 3. In considering the performance, management, and accountability of the
Company's energy efficiency and demand response programs, Boise City recommends the
Commission find the Company's 2023 expenses prudently incurred.
CITY OF BOISE CITY'S COMMENTS - 2

CONTINUED IMPORTANCE OF WEATHERIZATION FUNDING
The Company's weatherization program offerings for income-qualified customers remain
an important part of the overall energy efficiency portfolio. Boise City recognizes these programs
have limited cost effectiveness but believes they are critical to ensuring the health, safety,comfort,
and economic benefits of energy efficiency reach all segments of the Company's customer base.
Both weatherization assistance for qualified customers ("WAQC") and weatherization solutions
("Solutions") ensure fair and reasonable access to energy efficiency rider-funded demand side
management programs. In the absence of WAQC or Solutions that reduce or remove the upfront
cost to participation, customers with low incomes would not have meaningful access to the energy
efficiency programs they pay into through the energy efficiency rider.
Boise City encourages the Company to continue working to increase the cost-effectiveness
of the income-qualified energy efficiency programs and to ensure the programs are set up to
leverage the forthcoming federally funded Home Efficiency and Home Electrification and
Appliance Rebate programs. Leveraging additional non-rider funding will increase the impact of
the Company's weatherization programs, improve cost-effectiveness, and reduce the energy
burden for vulnerable community members. With WAQC now funded from the Energy Efficiency
rider as an outcome of IPC-E-23-11,Boise City recommends the Commission direct the Company
to continue offering its weatherization programs for income-qualified customers and to seek
Commission approval in its annual demand-side management prudency review if it seeks to
substantively change or end its weatherization programs.
CITY OF BOISE CITY'S COMMENTS - 3

DEVELOPMENT OF NEW ENERGY EFFICIENCY OFFERINGS
Boise City appreciates the Company's efforts to continually monitor, evaluate, and present
new energy efficiency and demand response measures to its Energy Efficiency Advisory Group
("EEAG"). Boise City strongly supports the Company's efforts to launch a new multi-family
energy efficiency program, addressing a significant unmet need in its portfolio. Beyond its current
offerings, Boise City recommends the Company consider and evaluate energy efficiency and
demand measures that encourage the increased and existing electrical loads be as flexible and
beneficial to the system as possible. Specifically, Boise City:
1. Recommends the Company consider a managed electric vehicle charging incentive
offering specifically targeted at commercial customers to ensure charging does not
unnecessarily increase peak load and can be planned as efficiently as possible. A
targeted incentive could complement and increase energy savings and peak demand
avoidance beyond the current price signals inherent in time of use rates.
2. Recommends the Company evaluate the possibility of increased point-of-sale
rebates and incentives to ensure energy efficiency incentives are as accessible as
possible to residential customers.
3. Supports the Company's efforts on its ductless heat pump market transformation
pilot and looks forward to providing feedback on next steps and similar programs
to increase efficient space and water heating options specifically targeted at the
Company's market dynamics.
Boise City appreciates the Company's ongoing efforts to increase energy efficiency and demand
response opportunities and looks forward to providing feedback and collaborating with other
interested stakeholders at EEAG.
CITY OF BOISE CITY'S COMMENTS - 4

CONCLUSION
Boise City appreciates the opportunity to provide comments to the Commission on the
Company's energy efficiency program and continues to support the Company pursuing all cost-
effective increases to its demand side resources. Boise City recommends the Commission:
1. Issue an order designating the Company's 2023 demand-side management expenses as
prudently incurred.
2. Direct the Company to continue offering its Weatherization programs for income-qualified
customers while working to improve their cost-effectiveness where possible.
DATED this 25th day of July 2024.
Ed Jewel
Deputy City orney
CITY OF BOISE CITY'S COMMENTS - 5

CERTIFICATE OF SERVICE
I hereby certify that I have on this 25th day of July 2024, served the foregoing documents
on all parties of counsel as follows:
Monica Barrios-Sanchez ❑ U.S. Mail
Commission Secretary ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 W. Chinden Blvd., Ste. 201-A 0 Electronic
Boise, ID 83714 ❑ Other:
secretgUkpuc.idaho._og_v
Adam Triplett ❑ U.S. Mail
Deputy Attorney General ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 W. Chinden Blvd., Ste. 201-A 0 Electronic
Boise, ID 83714 ❑ Other:
adam.triplettkpuc.idaho.gov
Megan Goicoechea Allen ❑ U.S. Mail
Lisa Nordstrom ❑ Personal Delivery
Idaho Power Company ❑ Facsimile
PO Box 70 0 Electronic
Boise, ID 83707 ❑ Other:
m goicoecheaallen(cr�,idahopower.com
Inordstrom&idahopower
[e-mail]
Connie Aschenbrenner ❑ U.S. Mail
Zack Thompson ❑ Personal Delivery
Idaho Power Company ❑ Facsimile
PO Box 70 Q Electronic
Boise, ID 83707 ❑ Other:
caschenbrenner(&,idahopower.com
zthomp son&idahopower.com
Matthew Nykiel, Attorney ❑ U.S. Mail
Brad Heusinkveld, Energy Associate ❑ Personal Delivery
Idaho Conservation League ❑ Facsimile
710 N. 61h St. 0 Electronic
Boise, ID 83702 ❑ Other:
matthew.nykiel(&,,gmail.com
bheusinkveldn idahocons ervation.org
CITY OF BOISE CITY'S COMMENTS - 6

F. Diego Rivas, Regulatory Counsel ❑ U.S. Mail
NW Energy Coalition ❑ Personal Delivery
1101 81h Ave ❑ Facsimile
Helena, MT 59601 0 Electronic
diego(a,nwenergy.org ❑ Other:
Ken Robinette, Chief Executive Officer ❑ U.S. Mail
South Central Community Action ❑ Personal Delivery
Partnership ❑ Facsimile
550 Washington Street South 0 Electronic
Twin Falls, ID 83303 ❑ Other:
ken(?
sccap-id.org
Michelle Steel
Paralegal, City of Boise
CITY OF BOISE CITY'S COMMENTS - 7