20240725Comments.pdf

RECEIVED
Thursday, July 25, 2024
IDAHO PUBLIC
Matthew A. Nykiel (ISB No. 10270) UTILITIES COMMISSION
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 ) CASE NO. IPC-E-24-11
OF IDAHO POWER COMPANY FOR A )
DETERMINATION OF 2023 DEMAND-SIDE ) INTERVENOR COMMENTS
MANAGEMENT EXPENSES AS ) OF THE IDAHO
PRUDENTLY INCURRED ) CONSERVATION LEAGUE
INTRODUCTION
COMES NOW the Idaho Conservation League ("ICL") before the Idaho Public Utilities
Commission ("PUC" or"Commission")with the following Comments on Idaho Power
Company's ("Idaho Power" or"Company") application in the above captioned matter. ICL
submits these comments pursuant to Commission Rule of Procedure 203, IDAPA 31.01.01.203,
Order No. 36178 granting ICL intervenor status in this docket, and the Notice of Modified
procedure, Order No. 36232.
ICL is a member of Idaho Power's Energy Efficiency Advisory Group ("EEAG") and
receives regular updates on the Company's energy efficiency and demand response programs.
ICL supports the continuation and further development of energy efficiency(`BE") and
demand-side management("DSM")programs as a critical component of a least-cost resource
portfolio. Idaho Power's EE and DSM portfolios continue to provide cost-effective energy
system benefits to participants and its whole customer base. Idaho Power's incremental
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Idaho Conservation League—Intervenor Comments

efficiency savings continue to excede the technically achievable savings modeled in the 2023
IRR' The Company's DSM programs are also steady,providing 240 MW of demand reduction
with 316 MW of capacity. We look forward to the continued growth of these programs in the
aggregate, rebounds and adjustments to stalled offerings, and further education and outreach as
the Company and customers adapt to a new period of demand growth.
Accordingly, and in recognition of the Company's efforts and clear presentation of costs
and value, ICL recommends the Commision designate the full amount of the Company's 2023
DSM expenses as prudently incurred. The remainder of these comments will address a number
of Idaho Power's efficiency and DSM programs.
COMMENTS
I. Low- and Limited-Income Weatherization Programs
ICL supports the Company's continuation and funding of the Weatherization Assistance
for Qualified Customers ("WAQC") and Weatherization Solutions for Eligible Customers
("Solutions")programs. We single out our support for these because the standard UTC, TRC,
and PCT tests fail to capture each program's full value. The Commission has long identified that
low-income weatherization programs offer hard to capture health, safety, good will, and
economic benefits that reach the Company's customer base.Z But the maintenance of these
programs also ensures fairness and access to available energy efficiency programs that would
otherwise be unavailable or prohibitively expensive to income-qualified customers. Indeed,
income qualified customers pay for these programs through the efficiency rider.' Fairness
'Application at 6,Thompson,DI at 8.
2 Order No.32788,Case No.GRN-E-12-01.
s Order No.36042,IPC-E-23-11; Stipulation and Settlement at 7.
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Idaho Conservation League—Intervenor Comments

requires that customers have access to programs they pay. The maintenance of low- and
income-qualified weatherization programs acknowledges the financial thresholds these
customers face to participate in efficiency programs and other cost-saving utility programs.
ICL recommends that the Commission direct Idaho Power to continue to work with its
partners and the Community Action Partnership Agencies ("CAP" or"Agencies")to increase
program cost effectiveness. Company's filing briefly touches on the program's cost effectiveness,
noting in the Thompson, DI that"due to the costs of comprehensive whole-house weatherization,
it is difficult for the value of savings to outweigh the costs."'This is true over the lifetime of the
programs, and frequent discussion in EEAG provides further information on recent
cost-effectiveness trends not present in the Company's application. As reported to the EEAG,
lingering supply chain and labor issues have delayed home retrofits and program participation,
driving up costs and reducing the volume of projects. The Company and CAP agencies have the
capacity and relationships to resolve these issues, and we recommend the Commission direct the
Company to continue its weatherization programs for income-qualified customers and seek
process improvements. We note that the Company agreed in the settlement of its 2023 rate caseto
hold meetings with the various CAP agencies and Staff to address funding backlogs and
implementation details.' We look forward to the results of those meetings and discussion with the
Company.
II. Multifamily Energy Savings Program
ICL supports the development of the Company's new Multifamily Energy Savings
Program. This offering expands the Company's existing residential and commercial programs
into areas previously overlooked. Early enrollments are encouraging and we look forward to
'Thompson,DI at 23.
s Stipulation and Settlement at 7,IPC-E-23-11.
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Idaho Conservation League—Intervenor Comments

reviewing program effectiveness and participation within the EEAG and later filings by the
Company. Idaho Power's outreach and solicitation of feedback on this project was consistent,
appreciated, and should serve as a model for program introduction or overhauls.
III. Energy Efficiency Advisory Group
The EEAG remains a high functioning group. Its regular meetings and presentations by
Idaho Power staff greatly eases program legibility and oversight. The relatively small size and
consistent membership of the EEAG makes for good continuity between meetings and the
maintenance of professional relationships and the group settled into a hybrid virtual and in
person meeting cycle that seems to meet most parties' needs. Idaho Power staff regularly solicit
feedback that is frequently reflected in program offerings and later presentations. ICL sees the
EEAG as a key outreach component of the Company's EE and DSM programs; we look forward
to its continuing good order and evolution.
IV. Commendations
ICL commends the continued professionalism and quality of the Idaho Power energy
efficiency and demand response teams. All deserve recognition, with thoughts toward particular
individual contributions and good leadership. ICL offers its thanks.
CONCLUSION AND RECOMMENDATIONS
ICL offers these Comments in support of Idaho Power's energy efficiency and demand
side resource portfolio and to acknowledge the efforts of its Staff. ICL is encouraged by the
maintenance and growth of the overall portfolio and the addition of the new Multifamily Energy
Savings Programs. We recommend the Commission: (1)Authorize the full amount of
$38,778,378 of DSM expenses requested in the Company's application as prudently incurred, (2)
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Idaho Conservation League—Intervenor Comments

Issue an order maintaining funding for income-qualified weatherization programs and directing
the Company and its partners to resolve funding backlogs.
Submitted this 25th day of July 2024.
s/Matthew A. Nykiel
Matthew A. Nykiel
Attorney for the Idaho Conservation League
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Idaho Conservation League—Intervenor Comments

CERTIFICATE OF SERVICE
I hereby certify that on this 25th day of July 2024, I delivered true and correct copies of
the foregoing COMMENTS to the following persons via the method of service noted:
Is/Brad Heusinkveld
Brad Heusinkveld
Idaho Conservation League
Electronic Mail Only (See Order No. 35058):
Idaho Public Utilities Commission City of Boise
Monica Barrios-Sanchez Ed Jewel
Commission Secretary Deputy City Attorney
[e-mail] Boise City Attorney's Office
[e-mail]
[e-mail]
Commission Staff [e-mail]
Adam Triplett
Deputy Attorney General Steve Hubble
Idaho Public Utilities Commission Boise City Dept. of Public Works
[e-mail] [e-mail]
Idaho Power Company NW Energy Coalition I SCCA
Megan Goicoechea Allen F. Diego Rivas
Lisa D. Nordstrom NW Energy Coalition
Attorneys for Idaho Power 1101 8th Ave.
1221 W. Idaho St. Helena, MT 59601
Boise, ID 83702 [e-mail]
[e-mail]
[e-mail] Ken Robinette
[e-mail] South Central Community Action
Partnership
Connie Aschenbrenner 550 Washington Street South
Zach Thompson Twin Falls, ID 83303
[e-mail] [e-mail]
[e-mail]
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-11 Page 6
Idaho Conservation League—Intervenor Comments