20240725Staff Comments.pdf

RECEIVED
Thursday, July 25, 2024 3.08.02 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR A ) CASE NO. IPC-E-24-11
DETERMINATION OF 2023 DEMAND-SIDE )
MANAGEMENT EXPENSES AS )
PRUDENTLY INCURRED ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Adam Triplett, Deputy Attorney General, submits the following
comments.
BACKGROUND
On March 15, 2024, Idaho Power Company ("Company") requested that the Commission
determine if $30,323,272 in Idaho Energy Efficiency Rider ("Rider") funds and $8,455,107 in
demand response ("DR") program incentives (for a total of$38,778,379)were prudently incurred
in 2022. The Company requested its Application be processed by Modified Procedure.
On April 17, 2024, the Commission issued a Notice of Application and Notice of
Intervention Deadline, setting a deadline for interested parties to file a petition to intervene. Order
STAFF COMMENTS 1 JULY 25, 2024

No. 36145. The NW Energy Coalition, South Central Community Action Partnership, Idaho
Conservation League, and City of Boise intervened. See Order No. 36718.
On June 18, 2024, the Commission issued a notice of Modified Procedure, setting a July
25, 2024, public comment deadline and a Company reply deadline of August 8, 2024. Order No.
36232.
The Company's Application also included the Demand-Side Management 2022 Annual
Report ("Annual Report"). Supplement 1 to the Annual Report shows the results of the cost-
effectiveness tests for each program and Supplement 2 contains program evaluations and
customer surveys and reports.
STAFF ANALYSIS
DSM Portfolio
The Company reported that its Demand-Side Management("DSM")portfolio was cost-
effective in 2023 with a Utility Cost Test("UCT")ratio of 2.06. The programs in the portfolio
captured a total of 139,683 Megawatt-hours ("MWh") of energy savings—representing a 20%
decrease from 2022. These savings included an estimate of 23,914 MWh of savings attributable
to the Northwest Efficiency Alliance ("NEEA"). Application at 6. At a sector level, the
Company's Commercial &Industrial ("C&I")programs continue to provide the majority of
savings with 86,813 MWh. Next, the Residential sector captured 24,394 MWh of savings.
Finally, the Irrigation sector contributed 4,563 MWh of savings. Of the Company's sixteen
offerings across all sectors, five are not cost-effective. Annual Report Supplement 1 at 14. In
general, Staff believes the Company's DSM programs are well managed and cost-effective. The
comments below detail Staff s analysis of the Company's DSM expenses, DSM changes from
Commission orders, program cost-effectiveness, and other topics. Staff notes that the lack of
comment on any portion of the Company's DSM offerings should not be construed as approval
or support.
Financial Review
Staff audited the Company's 2023 Rider expenses, which included a sampling and
reviewing of more than 90 transactions across the Company's programs. The Company's
expenses were well-documented, and controls were in place and adjusted as needed to regulate
STAFF COMMENTS 2 JULY 25, 2024

proper payment of incentives and other costs. Additionally, the Company's internal review
process identified and corrected mistakes prior to the filing of its DSM reports. Based on Staff s
audit, the Company's DSM rider expenses appear to be prudent.
The Company's internal review process identified three prior year-end adjustments to its
2022 Rider expenses. The first prior year adjustment of$6,998 was associated with the C&I
Energy Efficiency (`BE")program where an expense should have been charged to O&M instead
of the Idaho Rider in 2022; this amount must be added back to the rider expenses to avoid
understating the 2023 prudence request. The second prior-year adjustment of$1,289 is
associated with Idaho activity for the Residential Energy Efficiency Education Initiative that was
incorrectly charged to O&M instead of the Rider in 2022. The correction adding the expense to
the Idaho Rider was made in 2023, and that amount therefore needs to be subtracted from the
2023 prudence request because it was already deemed prudent by the Commission in the 2022
request. The final adjustment of$89,680 was associated with a program administration fee the
Company paid in 2022 that was refunded in 2023 due to services not rendered. The correction to
reduce the Idaho Rider expenses was made in 2023; therefore, that amount needs to be added
back to avoid understating the 2023 prudence request.
In preparation of filing its case, the Company also identified two current year-end
accounting adjustments to the Rider for 2023, and the corrections were made after the 2023 year-
end financial books were closed. The first current-year adjustment results in a reduction of
$1,771, which was related to expenses associated with the Irrigation Peak Rewards Program that
should have been charged to O&M, rather than the Idaho Rider. The second adjustment results
in an additional $194 associated with the Residential New Construction program where the
expense was initially charged to the Oregon Rider instead of the Idaho Rider.
Staff calculated the DSM Rider account balance as of December 31, 2023, in Table No.
1,below:
Table No. 1 Tariff Rider Reconciliation:
2023 Idaho Power Beginning Rider Balance (Underfunded) $ (3,767,319)
2022 Tariff Revenue $ 34,676,000
Interest on Tariff Rider Balance $ 21,141
Total Funds Accrued $ 34,697,141
2023 Reported Expenses $ (30,229,460)
STAFF COMMENTS 3 JULY 25, 2024

Prior Year-End Accounting Adjustments
2022 Commercial & Industrial Overhead Adjustment $ (6,998)
2022 Residential Energy Efficiency Education Adjustment $ 1,289
2022 Residential Energy Efficiency Overhead Adjustment $ (89,680)
Current Year-End Accounting Adjustments
2023 Irrigation Peak Rewards Adjustment $ 1,771
2023 Residential New Construction Adjustment $ (194)
2023 Total Prudent Expenses $ (30,323,272)
2023 Ending Balance $ 606,550
Table No. 1 shows that as of December 31, 2023, the EE Rider balance was over-funded
by $606,550. It also shows that the year before, the Rider was underfunded by $3,767,319.
Over the past three years, Rider funding has exceeded expenses by approximately $3 million
each year. In Order No. 36067, in the Company's 2023 general rate case, the Commission
approved an all-party settlement that reduced the EE Rider rate from 3.1%to 2.35%to properly
align Rider revenues with expenses. Staff will continue to monitor the balance of the Rider.
DSMLabor Expense
In Order No. 33908, Case No. IPC-E-17-03, the Commission ordered a 2% cap on wage
increases charged to the Rider. In Reconsideration Order No. 34874, the Commission ordered
that "the Company shall apply the 2% cap for DSM labor expense increases to the actual average
wage per FTE based on the prior year's average wage per FTE." The Company has complied
with this Commission order. The Company is requesting $3,449,976 in 2023 DSM labor
expense be collected through the Rider, which would be the 2% cap above their last year's labor
costs, even though their actual labor expense in 2023 totaled$3,625,290. The Company's
request is $175,313 under their actual labor costs, in order to comply with Commission order.
In the 2023 General Rate Case ("GRC"), IPC-E-23-11, the Company requested to shift
labor cost out of the EE rider and move them into base rates with the rest of Idaho Power labor
costs. In Order No. 36042 the Commission approved the change. The 2023 program year will
be the last year that DSM labor costs will be funded by the EE Rider.
STAFF COMMENTS 4 JULY 25, 2024

Changes from Other Cases
In 2023, the Company's GRC and Integrated Resource Plan("IRP") filings implemented
several changes that affect its DSM programs. Due to the timing of these filings, the impacts of
these changes will be realized in the 2024 program year. Staff will review the impacts of these
changes as they appear in next year's prudence filing.
First, in its 2023 IRP, Case No, IPC-E-23-23, the Company implemented changes to its
avoided cost practices and load shape time blocks for DSM programs. The Company previously
evaluated its DSM programs using avoided cost averages provided by the most recently
acknowledged IRP. After discussions with its stakeholders, the Company has changed its policy
to use avoided costs provided by the most recently filed IRP. Staff believes that this change will
allow DSM programs to reflect the Company's system and planning process more closely.
The IRP also included updated seasons and hours of highest risk that have led to a change
in the DSM program savings load shapes. Currently, the Company assigns savings to five-time
blocks with different values based on when the savings of the measure occur.1 The 2023 IRP's
forecasted increase to risk in winter months has expanded the current non-summer mid and off-
peak time blocks into the off-season low-risk block for shoulder months and the winter low,
medium, and high-risk blocks. In the 2023 IRP filing, Staff disagreed with the Company's
practice of excluding battery and DR resources when establishing the hours of highest risk. Staff
continues to meet with the Company to discuss and resolve concerns detailed in its Comments in
Case No. IPC-E-23-23.
Additionally, in its 2023 GRC, Case No, IPC-E-23-11, the settlement approved by Order
No. 36042 made two changes to funding in the EE rider. The approved settlement shifted a total
of$1,324,853 in income-qualified weatherization and low-income education funding from base
rates into the EE rider and approximately $3.5 million of EE rider funded labor costs into base
rates, as discussed earlier. Settlement at 7.
' Summer On-Peak,Summer Mid-Peak,Summer Off-Peak,Non-Summer Mid-Peak,and Non-Summer Off-Peak
STAFF COMMENTS 5 JULY 25, 2024

Program Management
Multi-Family Energy Efficiency
On November 1, 2023, the Company launched a revised Multifamily Energy Efficiency
program. The Company previously offered a similar program that was closed in December 2022
due to challenges maintaining the cost-effectiveness of the program. Since that time, the
Company has worked with its Energy Efficiency Advisory Group ("EEAG")to develop a
revised Multifamily offering. In response to Production Request No. 21, the Company describes
that the revised offering has changed from a direct install program where upgrades were
provided at no cost to the customer, to a rebate program similar to the Company's C&I DSM
programs. Staff will review the revised offering as data becomes available in 2024.
Shade Tree Project
The Company's Shade Tree Project offers no-cost shade trees and educational materials
to residential customers to encourage planting in locations that will shade homes during summer
months and reduced energy used on cooling. In 2023, the measure received updated mortality
rates and heating impact assumptions from a third-party impact evaluation that resulted in the
measure becoming not cost effective with a UCT of 0.31, or 0.33 when not including evaluation
expenses. Because the Company has already committed to the purchase of trees for the program
in 2024, the Company continued to operate the Shade Tree Project until their final event in May
2024 and has since discontinued the program.
Home Energy Reports
The Home Energy Reports ("HERs")program is designed to encourage customers to
engage in energy-efficient behaviors through periodic home energy reports. The Company
contracts with a third party to deliver quarterly reports detailing customers' energy use compared
to similar homes along with suggestions on how to reduce their energy usage. In 2023, the
HERs program contributed 17,659,087 kWh of savings which is more than twice the savings of
the other residential sector programs combined.
At the end of 2023, the Company's contract with their third-party vendor ended. The
Company has contracted with a new vendor for the 2024 program year which includes an
additional treatment group of approximately 25,000 customers. While the program is offered to
STAFF COMMENTS 6 JULY 25, 2024

more customers in 2024, Staff is concerned that the program's design excludes the participation
of certain customers. The current design of the HERS program uses a randomized control trial
protocol to validate savings by comparing statistically identical treatment and control groups.
This methodology is considered standard practice for HERs type programs; however, to produce
valid results, this methodology requires a control group of customers that do not receive reports.
Staff is concerned that customers randomly assigned to a control group do not have the
opportunity to benefit from the program despite contributing to the recovery of the program
through the Rider. In response to Production Request No. 29, the Company states that it has
explored the potential of using a deemed savings for the HERs program to allow participation of
all customers; however, the Company states that this option is problematic as there is not
currently a proven deemed savings that could be used to estimate savings and that an evaluation
of actual savings would be difficult as there may not be enough non-participating customers to
be used as a control group. Staff recommends that the Company continue to explore alternatives
that allow all customers to participate in the HERs program should they want to.
Low Income Weatherization
The Company maintains two low-income weatherization programs, the Weatherization
Assistance for Qualified Customers ("WAQC")program, and the Weatherization Solutions for
Eligible Customers ("Weatherization Solutions")program. In 2023, the WAQC program was
funded through base rates while the Weatherization Solutions program was funded through the
Rider. The Company reports that its low-income weatherization programs remained not cost-
effective in 2023. The WAQC saw an increase in participation and savings; however, increased
costs reduced the UCT to 0.16 or 0.14 when considering the additional costs of the re-
weatherization efforts. The Weatherization Solutions program saw a decrease in participation
and savings leading to a UCT of 0.13. Staff and the Company acknowledge the struggles of
achieving a cost-effective low-income weatherization program. The Company continues to work
to improve the cost-effectiveness of these programs.
In response to the settlement reached in IPC-E-23-11, the Company is expecting
discussions with Staff, Cap agencies, and other stakeholders in the coming months.
Additionally, in its response to Production Request No. 34, the Company states that it is aware of
changes being proposed by the Idaho Department of Health and Welfare that may impact the
STAFF COMMENTS 7 JULY 25, 2024

WAQC program. Staff will review the impact of these changes as information becomes
available.
In 2023, a large balance of unused WAQC funds was carried over from previous years.
In Order No. 35583, the Commission approved the Company's application to allow carryover
funds to be used for re-weatherization projects as a solution to deplete a large pool of built-up
funding. Under these projects, the Company would pay 100% of the upgrade costs for homes
that previously qualified for the low-income assistance upgrades but did not receive HVAC
upgrades. In 2023, the re-weatherization program weatherized 30 homes. These projects cost
$358,306 with an average cost of$10,858 per home. With the additional spend of the re-
weatherization program, the WAQC program spent a total of$1,224,051,just over the annual
allocation of$1,212,534. Staff is encouraged by this increase in funding utilization and will
continue to review the balance of the WAQC program.
Heating and Cooling Efficiency
The Heating and Cooling Efficiency("H&CE")program provides incentives for
residential customers,builders, and contractors for the installation of energy-efficient heating
and cooling measures. Incentives vary depending on the measure which can range from duct
sealing to heat pump systems. In 2023, the program saw a decrease in cost-effectiveness with a
UCT of 0.94. The Company states that the program is not cost effective largely due to decreased
saving assumptions from the Regional Technical Forum("RTF") and that the program is
expected to be cost effective in 2024 due to new IRP avoided costs. Annual Report at 56.
Of the measures offered within the H&CE program, Smart Thermostats had the most
rebates, accounting for 45% of all H&CE rebates. Id. at 56. Rebates for this offering are tracked
according to their installation method; resistance optimized, contractor installed, or self-installed.
Staff is concerned that the Company uses that same estimated savings values for contractor
installed and self-installed thermostats. In its PY2020 impact evaluation of the H&CE program,
the evaluator concluded that contractor installed smart thermostats save more than self-installed
thermostats and recommend that the Company revisit billing analysis in future evaluations. The
evaluation was unable to directly estimate the savings from self-installed thermostats; however,
the aggregated savings of contractor and self-installed smart thermostats saved 229 kWh, while
contractor-installed thermostats alone saved 470 kWh. In response to Production Request No.
STAFF COMMENTS 8 JULY 25, 2024

44, the Company states that it has considered lowering or removing the incentive for units not
installed by a contractor. However, the Company opted to lower the incentive for both
installations. Staff s review of the RTF workbooks used to estimate savings for the smart
thermostat measure discovered that the workbook uses the same energy savings value for
contractor installed thermostats as self-installed thermostats. Additionally, the RTF workbook
labels all but one of the smart thermostat measure applications as "planning" and explains that
this is because of uncertainty in savings from this delivery mechanism and/or due to lack of
data.2 Staff believes that by using the same value for both installation methods, the Company
may be overstating the savings from this measure. Staff recommends that the Company evaluate
the savings of self-installed and contractor-installed smart thermostats in its next evaluation of
the H&CE program.
Rebate Advantage
The Rebate Advantage helps customers purchase new, energy-efficient manufactured
homes by providing tiered incentives. In 2023, the Company reports that the Rebate Advantage
was not cost-effective with a UCT of 0.98. The Company states that it expects the program will
be cost-effective in 2024 with updated avoided costs. Id. at 74.
Residential New Construction Evaluation
On January 1, 2024, a third-party evaluator("Evaluator") completed an impact evaluation
of the PY2022 Residential New Construction Program("Evaluation"). This is the program's
first evaluation since it transitioned from a pilot program in 2021. From its review, Staff is
concerned with the methodology and simulated savings basis of the Evaluation.
The Evaluation's stated objectives include "verifying that reported model output savings
and tracked savings match and providing ex-post realization rates for project" among others.
The Evaluation describes model output savings as the savings estimate from the REM/Rate
model output report that is entered into the AXIS database by the Evaluator. The Evaluation
describes tracked savings as the savings data retrieved from the AXIS database by the Company
2"Planning UES measures are those that the RTF does not consider reliable but have sufficient energy savings
potential to justify additional research. These measures require an RTF-approved research strategy,designed to
identify data needs and analysis required to advance the measure to the Proven category."2020 RTF Guidelines.
STAFF COMMENTS 9 JULY 25, 2024

and reviewed for errors. Staff believes that this methodology has compared the model output
savings of the REM/Rate model to itself, and therefore has not provided useful or meaningful
results as an impact evaluation.
Additionally, Staff is concerned with the use of simulated energy savings as a basis for an
impact evaluation. In response to Production Request No. 40, the Company states that it has not
identified a reason to perform analysis with billing data as the program is based on well founded
and documented practices. While necessary for the Company to forecast the energy savings of
the new home, a simulation does not necessarily represent the actual energy saving impact on the
Company's system. In response to Production Request No. 37, the Company references the
RTF's Standard Savings Estimation Protocol: New Homes ("Protocol")used to determine
savings for new construction projects. The Protocol describes the uncertainties in the REM/Rate
model from three major areas: hot water, appliances, and REM heating energy estimates. For
the hot water and appliance measures, the Protocol inherits uncertainty from the measures related
to unit energy savings estimate. For the REM heating energy estimates, it is noted that savings
estimates from the REM/Rate model may significantly differ from actual savings. Protocol at
31. Further, the Protocol describes research activities recommended to improve the reliability of
energy savings estimates. "Research for space heating is needed because it is unclear how well
REM/RateTM-estimated heating energy differences correspond to actual heating energy savings"
and"The RTF recommends one or more program evaluations to validate program savings
estimates with the highest degree of rigor that is practical." Id. at 36 and 37. Staff believes that
the 2022 impact evaluation has not validated program savings estimates with a high degree of
rigor as recommended by the Protocol.
Staff recommends that the Company conduct a follow-up impact evaluation of the
Residential New Construction Program using billing data to quantify the energy saving impacts
to the Company's system and the results included with the next possible prudence filing. In
response to Production Request No. 39, the Company notes that the presence of billing data does
not indicate that the household is occupied and representative of regular consumption. Staff
recognizes this potential issue with a billing analysis and recommends that the impact evaluation
consider data from both the time construction finishes and from when occupation begins.
Additionally, the Company should include recent data from the 2023 program year data and, if
STAFF COMMENTS 10 JULY 25, 2024

needed, data from prior program years to have sufficient data to conduct a meaningful
evaluation. Finally, the evaluation should consider any changes to building codes, modeling
practices, or program operations in the selected evaluation period.
Small Business Direct Install
The Company's Small Business Direct Install ("SBDI") historically offered no-cost
lighting upgrades to Idaho's hard to reach small business customers. In March 2023, the
Company closed the offering due to expected cost-effectiveness challenges and having
strategically offered the program to its entire service territory. Before the program was closed,
the Company completed 166 projects capturing 791,512 kWh with a cost-effectiveness of 0.97.
Annual Report at 136.
In its February 2024 and May 2024 EEAG meetings, the Company discussed and
developed a restructured SBDI offering. In response to Production Request No. 17, the
Company describes that its new Small Business Lighting ("SBL") offering will be administered
by the Company, implementing cost-sharing as opposed to 100%reimbursement of costs, and
marketed in stages across the entire service territory rather than a geo-targeted approach. Staff
will review the new SBL offering in the Company's next prudence filing.
Commercial Energy Saving Kits
The Commercial Energy-Saving Kit("ESK")program offers commercial customers kits
containing several energy saving pieces of equipment such as LED lamps, faucet aerators, and an
exit sign retrofit kit. The program is conducted through a contract with a third-party vendor who
mails kits directly to customers. In 2023, the removal of LED light bulb savings and reductions
in savings for the other measures, the offering is expected to no longer be cost-effective. The
Company continued to offer the Commercial ESK's until the contract ended in June 2023. Id. at
125.
C&I Custom Projects
The Company's C&I Custom Projects program("CP") is the biggest program in the
entire EE portfolio in terms of energy savings and incentives paid. For 2023, the CP claimed an
annual energy savings of 60,667 MWh, which was 53% of the Company's EE portfolio. In other
words, this one program accounted for more energy savings than all the other programs put
STAFF COMMENTS 11 JULY 25, 2024

together. Accordingly, the CP is also the most expensive program. It paid out 60% of all
incentives and incurred 43% of the overall portfolio costs.
Because of the magnitude of this program, and due to the custom nature of each project,
Staff audited a selection of the largest projects, examining the approval documentation and
engineering calculations. Staff believes that the custom projects savings are well supported by
third-party scoping evaluations and engineering reports. Additionally, the Company has multiple
levels of verification for incentive payments. Staff appreciates the detailed support the Company
maintains for its custom projects and will continue to review the program's projects in future
prudence filings.
Line Losses
In order to more accurately estimate the energy saved by a program measure, the
Company accounts for line losses in energy savings between the point of generation and the
point of end-use. End-use savings are marked up by the line loss factor, which usually ranges
between five and ten percent. For this report, and many previous ones, the Company has been
using the line loss value determined in a 2012 study. The Company performed a new line loss
study in March 2023, which determined a new lower value. Regarding the next DSM report, the
Company states, "For program year 2024, the Company will utilize the 2023 Line Loss Study
and will remove the transformer core losses from the avoided losses when determining cost-
effectiveness. See Response to Production Request No. 47. Staff agrees with the Company's
intention.
Demand Response
The Company maintains three DR programs designed to reduce load during critical hours
and minimize or delay the need to build new resources. The A/C Cool Credit("ACCC")
program, Flex Peak program, and Irrigation Peak Rewards program are designed to target the
residential, C&I, and irrigation sectors, respectively. In 2023, the Company's DR programs
incurred$8,927,632 in incentive payments funded through base rates. The programs achieved
240 MW of non-coincident demand reduction from its 316 MW of nameplate capacity. Staff
reviewed the Company's DR programs and believes that the programs were well-managed,
effective, and prudent.
STAFF COMMENTS 12 JULY 25, 2024

In Case No. IPC-E-21-32, the Company proposed many changes to the DR programs,
including the removal of the marketing cost cap. The proposed changes were accepted with an
effective date of June 15th, 2022, meaning 2023 was the first full year of marketing expenses. In
2023, the Company spent$139,798 on marketing for its DR programs, 55,274 more than 2022.
Commensurate with the increased spend, the Flex Peak Program saw an increase of 112
participants, 8.4 MW of maximum realized demand reduction, and 8.8 MW of maximum
potential reduction. The Irrigation Peak Rewards program saw an increase of 297 participants
and 32.6 MW of maximum realized demand reduction. The ACCC was the only program that
saw a decrease in participation and demand reduction, however, these decreases are small. The
Company is continuing its awareness campaign for the ACCC program. Staff will continue to
review the expenses and effects of the Company's DR marketing in future prudence filings.
Cost-effectiveness Continuation
In Order No. 36133, the Commission directed the Company to work with Staff and other
Stakeholders to develop and consider alternative methods to evaluate the cost effectiveness of its
DR programs. The Company has been in contact with Staff to coordinate the conversation as
part of a series of workshops including carryover from the Company's 2023 IRP. Staff will
report the results of these discussions in a future prudence filing.
NEEA
In April 2023, the Company in cooperation with Avista Utilities, completed an impact
evaluation of NEEA's cost-effectiveness as directed by the Commission in Order No. 35270.
While the evaluation concluded that the NEEA was cost-effective, it discovered several concerns
and areas for improvement.3 Since the Completion of the evaluation, Staff has been in
communication with the Company to discuss the results and next steps. In Order No. 36076, the
Commission provided feedback stating that if the Company seeks to continue participation in
NEEA, it should demonstrate how NEEA is an effective use of the Company's Idaho Rate Payer
funds. Staff anticipates the Company will file for Commission approval of continued NEEA
3 For details on the evaluation recommendations and related discussion see IPC-E-23-10 Staff Comments.
STAFF COMMENTS 13 JULY 25, 2024

funding by September 1, 2024. Idaho Power Company's Reply Comments (IPC-E-23-10) at 6.
Staff will review the Company's support for continued participation at that time.
STAFF RECOMMENDATION
Based on its analysis Staff recommends that:
1. The Commission find that the Company prudently incurred $38,778,379 in DSM-
related expenses for 2023;
2. The Company continue to explore alternatives that allow all customers to participate
in the HERS program, if desired by the customer;
3. The Company evaluate the savings of self-installed and contractor-installed smart
thermostats in its next evaluation of the H&CE program; and
4. The Company conduct a follow-up impact evaluation of the Residential New
Construction Program using billing data to quantify the energy saving impacts to the
Company's system to be included with the next possible prudence filing.
Respectfully submitted this 25th day of July 2024.
Adam Triplett
Deputy Attorney General
Technical Staff: Jason Talford, Laura Conilogue, Matt Suess
I:AUtility\UMISC\COMMENTS\IPC-E-24-11 Comments.docx
STAFF COMMENTS 14 JULY 25, 2024

CERTIFICATE OF SERVICE
�
I HEREBY CERTIFY THAT I HAVE THIS a DAY OF JULY 2024,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-24-11, BY &MAILING A COPY THEREOF, TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
LISA D NORDSTROM ZACK THOMPSON
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: E-MAIL: caschenbrenner(cr�,idahopower.com
[e-mail] [e-mail]
lnordstromkidahopower.com
[e-mail]
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEYS OFF PO BOX 500
PO BOX 500 BOISE ID 83701-0500
BOISE ID 83701-0500 E-MAIL: shubblekeityofboise.org
E-MAIL: ejewell(cr�,cityofboise.org
[e-mail]
F DIEGO RIVAS KEN ROBINETTE CEO
NW ENERGY COALITION SOUTH CENTRAL COMMUNITY
1101 8TH AVE ACTION PARTNERSHIP
HELENA MT 59601 550 WASINGTON ST SOUTH
E-MAIL: [e-mail] TWIN FALLS ID 83303
E-MAIL: [e-mail]
MATTHEW NYKIEL BRAD HEUSINKVELD
IDAHO CONSERVATION LEAGUE IDAHO CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.nykiel@g!nail.com E-MAIL:
bheusinkveld@idaho conservation.org
PATRICIA JORDAN, E RETARY
CERTIFICATE OF SERVICE