20240808Reply Comments.pdf

MPOWER.
An IDACORP Company
MEGAN GOICOECHEA ALLEN
Corporate Council
mgoicoecheaallen(aD_idahopower.com
August 8, 2024
RECEIVED
Thursday, August 8 2024
IDAHO PUBLIC UTILITIES
VIA ELECTRONIC FILING COMMISSION
Monica Barrios-Sanchez, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
RE: Case No. IPC-E-24-11
In the Matter of Idaho Power Company's Application for a Determination
of 2023 Demand-Side Management Expenses as Prudently Incurred
Dear Ms. Barrios-Sanchez:
Attached for electronic filing is Idaho Power Company's Reply Comments in the above-
entitled matter. If you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours, r
Megan Goicoechea Allen
M GA:cd
Enclosures

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
mgoicoecheaallenCa�,idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-24-11
DETERMINATION OF 2023 DEMAND-SIDE )
MANAGEMENT EXPENSES AS ) IDAHO POWER COMPANY'S
PRUDENTLY INCURRED. ) REPLY COMMENTS
Idaho Power Company ("Idaho Power" or "Company") respectfully submits the
following Reply Comments in response to Comments filed by Idaho Public Utilities
Commission ("Commission") Staff ("Staff"), the City of Boise City ("Boise City"), the Idaho
Conservation League ("ICL"), and NW Energy Coalition and South Central Community
Action Partnership ("NWEC/SCCAP") (collectively called "Parties") on July 25, 2024.
I. REPLY COMMENTS
In its Comments, Staff concludes that the Company's Demand-Side Management
("DSM") programs are well managed and cost-effective' and recommends the
Staff Comments at 2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 1

Commission approve $30,323,272 in Idaho Energy Efficiency Tariff Rider ("Rider")
expenses and $8,455,107 in Demand Response ("DR") program incentives.2 Staff also
provides recommendations on program management and evaluation. All other Parties
recommend a prudence determination from the Commission as well.3 In addition, Boise
City provides recommendations for additional programmatic offerings, and
NWEC/SCCAP offers recommendations for programmatic improvements. In these Reply
Comments, the Company responds to the issues and recommendations raised by
Parties.
A. Weatherization for Income Qualified Customers
Boise City, ICL, and NWEC/SCCAP commented on the Company's low-income
weatherization programs, the Weatherization Assistance for Qualified Customers
("WAQC") program, and the Weatherization Solutions for Eligible Customers
("Weatherization Solutions") program. Specifically, Boise City encourages the Company
to ensure its income-qualified programs are set up to leverage the forthcoming federally
funded Home Efficiency and Home Electrification and Appliance Rebate programs, which
it suggests "will increase the impact of the Company's weatherization programs, improve
cost-effectiveness, and reduce the energy burden for vulnerable community members."4
ICL states that the Commission has long identified that these programs provide benefits
that are hard to capture in traditional cost-benefit analyses like health, safety, good will,
and nontraditional economic benefits.5 NWEC/SCCAP also cites benefits associated with
low-income weatherization that traditional cost-effectiveness tests do not capture,
2 Staff Comments at 14.
3 Boise City Comments at 5, ICL Comments at 4, and NWEC/SCCAP Comments at 9.
a Boise City Comments at 3.
a ICL Comments at 2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2

including reduced arrearages, health and safety benefits (including savings on medical
expenses), job support, savings that can be used in other segments of the economy, and
fewer days of missed work.6 Additionally, they mention that certain energy efficiency
measure may have high costs but also yield greater savings.' For these reasons
NWEC/SCCAP suggest that the Company increase its annual average per project cap in
the WAQC program and re-evaluate that cap every three years.$
Staff, Boise City, and ICL express support for Company efforts to improve cost-
effectiveness.9 When considering cost-effectiveness, it is important to understand that
Idaho Power funds are paid directly to the Community Action Partnership ("CAP")
agencies to perform work that is determined by the State of Idaho Weatherization
Assistance Program guidelines. Therefore, Idaho Power's ability to improve cost-
effectiveness is limited to reducing labor costs associated with program administration.
The high costs of comprehensive whole-house weatherization compared to the relatively
low Company administration costs provides limited intervention that would result in
improved cost-effectiveness. Given the limited opportunities for Company action to
influence cost-effectiveness and recognizing that traditional cost-effectiveness tests fail
to capture the full benefits of these programs, the Company requests that the Commission
consider permanently exempting them from the traditional utility cost-effectiveness
analysis.
As noted by both Staff and ICL,10 in the Company's 2023 General Rate Case
("GRC"), IPC-E-23-11, the Commission approved an all-party settlement that
6 NWEC/SCCAP Comments at 5-6.
NWEC/SCCAP Comments at 6.
8 NWEC/SCCAP Comments at 9.
s Staff Comments at 7, Boise City Comments at 5, and ICL Comments at 3.
10 Staff Comments at 7 and ICL Comments at 3.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3

implemented certain changes impacting its DSM programs. More specifically, the
Commission-approved Settlement Stipulation states in pertinent part:
Additionally, the Parties agree that the existing obligations for $1.2 million
for income-qualified weatherization and $125,000 for low-income education
are to be moved from base rate revenue requirement to recovery through
the Rider, resulting in a reduction to the base rate revenue requirement of
$1,324,853. The Company commits to work with Staff and the Community
Action Partnership agencies to develop implementation and ongoing
administration details, including funding levels, for both programs, which
could be presented for Commission approval in Idaho Power's next
demand-side management prudence filing or other compliance filing."
In conformance with the Settlement Stipulation, the Company has undertaken to
work with CAP agencies and Staff to address certain matters related to its DSM programs.
To this end, the Company held a meeting on July 31, 2024, where stakeholders convened
to discuss implementation and ongoing administrative details associated with WAQC.
Participants included Staff, Idaho Department of Health and Welfare, and several CAP
agencies, including El Ada Community Action Partnership, South Central Community
Action Partnership, Metro Community Services, and Southeastern Idaho Community
Action Partnership. During the meeting, the stakeholders discussed a number of issues
including the sufficiency of the current $1.2 million; implications of shifting funding from
base rates into the Rider; the treatment of transfers between agencies; evaluation of
increasing the annual average project cap; and the continuation of funding available for
qualified non-profits through the program. The Company is committed to continued
collaboration with the stakeholder group and does not believe it is necessary for the
Commission to issue an order with direction on the programmatic elements of these
programs at this time. Following remaining stakeholder engagement, Idaho Power will
"Case No. IPC-E-23-11, Stipulation and Settlement at 7.
IDAHO POWER COMPANY'S REPLY COMMENTS - 4

submit a filing seeking Commission approval for necessary updates to Schedule 79,
Weatherization Assistance for Qualified Customers and any programmatic changes it
intends to implement.
B. DSM Programs Recommendations
The Parties had several specific recommendations around ways to improve the
Company's non-income qualified DSM offerings, including:
• Staff expressed concern that the Home Energy Reports ("HERS") program
design excludes the participation of customers assigned to the control group
and that these customers do not have the opportunity to benefit from the
program despite contributing to the recovery of program funds through the
Rider. Staff recommends that the Company explore alternatives to allow
these customers to participate in the HERS program should they want to.12
• Boise City recommends that the Company consider an electric vehicle
charging incentive, targeted at commercial customers, to encourage
charging at off-peak times. 13
• Boise City also recommends and that the Company evaluate increasing
point-of-sale rebates and incentives for energy efficiency measures to
ensure they are as accessible as possible to residential customers.14
• NWEC/SCCAP recommends the Company use efforts to expand the use of
HERS (including adding additional test and control groups) and find ways to
better reach the rental housing market.15
12 Staff Comments at 7.
13 Boise City Comments at 4.
14 Id.
15 NWEC/SCCAP Comments at 3-4.
IDAHO POWER COMPANY'S REPLY COMMENTS - 5

• NWEC/SCCAP also recommends Idaho Power consider how it can ensure
customers who take advantage of beneficial electrification do not invest in
inefficient appliances.16
Idaho Power appreciates the thoughtful assessment of its DSM programs and is
committed to exploring the ideas raised by each of the parties. The Company is also
committed to bringing any potential programmatic changes to its Energy Efficiency
Advisory Group ("EEAG") for further discussion and input prior to implementation.
C. Evaluation Recommendations
Staff provided two recommendations specific to program evaluation. First, Staff
expressed concern that the Company uses the same estimated savings values for
contractor-installed and self-installed smart thermostats in its Heating and Cooling
Efficiency Program, which may not reflect actual savings because contractor-installed
smart thermostats save more than self-installed. Staff recommends that the Company
evaluate the savings of contractor-installed and self-installed smart thermostats in its next
evaluation.17 The Company is supportive of this recommendation and is committed to
undertake this effort in its next evaluation of the program.
Second, Staff raises concerns that the use of simulated energy savings does not
represent the actual energy savings impact on the Company's system and recommends
that the Company conduct a follow up impact evaluation of its Residential New
Construction ("RNC") Program using billing data from both the time construction is
finished and when occupation begins in order to quantify energy savings, the results of
16 NWEC/SCCAP Comments at 4.
17 Staff Comments at 8-9.
IDAHO POWER COMPANY'S REPLY COMMENTS - 6

which the Company should include in the next possible prudence filing.'$ While the
Company acknowledges that using billing data to quantify energy savings can yield
informative results, it is important to consider the set of available data needed to complete
the analysis. A billing analysis is typically performed in one of two ways: (1) comparing
post-implementation usage to prior usage at the site, or (2) comparing post-
implementation usage to a control group of"like" homes. The first method cannot be used
for RNC projects because there is no usage prior to a new construction project. A "pre-
condition billing analysis" comparing post-implementation usage to modeled data could
be performed with standard methods using data readily available to the Company.
Alternatively, a "matched control billing analysis" would require identifying a set of non-
participating electrically-heated homes with similar characteristics such as home type
(e.g., single-family versus multi-family), HVAC type, conditioned area, number of
residents, and geographic location. The results of a billing analysis on a new construction
program will be subject to the quality of the data and matching process and would
ultimately require more time and resources to conduct.
The Company is not opposed to exploring which of these methods warrants further
consideration; however, it does not believe it is necessary for the Commission to direct it
to complete the additional analysis at this juncture. As it has committed to previously, the
Company typically presents a 2-year evaluation plan to EEAG for input and alignment in
the November meeting.19 Accordingly, the Company plans to work with informally with
18 Staff Comments at 9-10.
19 Case No. IPC-E-19-11,Attachment No.A to Staff's Comments, p.4: "The Company and Staff held a conference
call on February 27,2019, and the Company agreed to create a two-year,forward-looking schedule of evaluations in
the DSM Annual Report. This will give Staff and other stakeholders visibility into the Company's planned evaluation
schedule and help determine the need for additional or more frequent evaluations. Staff believes this is a reasonable
solution and will continue monitoring the evaluation schedule."
IDAHO POWER COMPANY'S REPLY COMMENTS - 7

Staff and will bring a recommendation related to an additional RNC impact evaluation
(which will also consider its impact on program cost-effectiveness), to the November 2024
EEAG meeting, where it will solicit input and feedback before determining the timing and
type of further RNC evaluations along with the holistic 2025-2026 evaluation schedule.
II. CONCLUSION
Idaho Power appreciates the collaboration from Parties to continually improve its
energy efficiency offerings. The Company respectfully requests that the Commission
issue an Order: (1) finding Idaho Power's $30,323,272 in Rider funds and $8,455,107 in
DR program incentives, for a total of$38,778,378, as prudently incurred DSM expenses;
and (2) considering permanently exempting the low-income weatherization programs
from the traditional utility cost-effectiveness analysis.
Respectfully submitted this 8th day of August 2024.
jNr?I W�ict 96
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 8

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8t" day of August 2024, 1 served a true and correct
copy of the within and foregoing Idaho Power Company's Reply Comments upon the
following named parties by the method indicated below, and addressed to the following:
Adam Triplett Hand Delivered
Deputy Attorneys General U.S. Mail
Idaho Public Utilities Commission Overnight Mail
P.O. Box 83720 FAX
Boise, ID 83720-0074 X Email
adam.triplett(cD_puc.idaho.gov
Ed Jewell Hand Delivered
City of Boise City U.S. Mail
150 N. Capitol Blvd. Overnight Mail
P.O. Box 500 FAX
Boise, Idaho 83701-0500 X Email
BoiseCityAttorney(a cityofboise.org
elewell(c)_cityofboise.org
Steven Hubble Hand Delivered
Boise City Dept. of Public Works U.S. Mail
150 N. Capitol Blvd. Overnight Mail
P.O. Box 500 FAX
Boise, Idaho 83701-0500 X Email
shubble(a)cityofboise.org
Matthew Nykiel Hand Delivered
Attorney for Idaho Conservation League U.S. Mail
710 N. 6t" St. Overnight Mail
Boise, ID 83702 FAX
X Email
matthew.nykiel(c�gmail.com
Brad Heusinkveld Hand Delivered
Idaho Conservation League U.S. Mail
710 N. 6th St. Overnight Mail
Boise, Idaho 83702 FAX
X Email
bheusinkveld(a�idahoconservation.org
Benjamin J. Otto Hand Delivered
NW Energy Coalition U.S. Mail
1407 W. Cottonwood Court Overnight Mail
Boise, ID 83702 FAX
X Email
ben nwenergy.org
IDAHO POWER COMPANY'S REPLY COMMENTS - 9

Ken Robinette Hand Delivered
South Central Community Action U.S. Mail
Partnership Overnight Mail
550 Washington Street South FAX
Twin Falls, ID 83303 X Email
ken(o)_sccap-id.org
a4pu- f -
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 10