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HomeMy WebLinkAbout20241008Tariff.pdf ON QAFIO R® Connie Aschenbrenner -�I Rate Design Senior Manager caschenbrenner(a-)-idahopower.com RECEIVED VIA ELECTRONIC FILING 2024 September 19 PM 4:35 IDAHO PUBLIC UTILITIES COMMISSION September 19, 2024 Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Tariff Advice No. IPC-TAE-24-03 Compliance with Order No. 36042 (IPC-E-23-11) Dear Commission Secretary: Idaho Power Company ("Idaho Power" or "Company") hereby submits this Tariff Advice in compliance with Order No. 36042 issued by the Idaho Public Utilities Commission ("Commission") in Case No. IPC-E-23-11. In that order, the Commission approved a Stipulation and Settlement that moved the existing obligations for funding in the amount of $1.2 million for income-qualified weatherization and $125,000 for low- income education from the base rate revenue requirement to recovery through the Idaho Energy Efficiency Rider ("Rider").' The Stipulation and Settlement also provided for the Company to work with Commission Staff ("Staff") and Community Action Partnership ("CAP") 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."2 Based on that direction, Idaho Power makes this compliance filing and respectfully requests that the Commission issue an order (1) approving the Company's proposed changes to both the Weatherization Assistance for Qualified Customers ("WAQC") and Easy Savings programs, (2) approving the proposed changes to Schedule 79, effective November 15, 2024, and (3) acknowledging the Company has satisfied its compliance obligation to work with Staff and the CAPs to develop implementation and ongoing ' In the Matter of the Application for Idaho Power Company for Authority to Increase Rates and Charges for Electric Service in the State of Idaho and for Associated Regulatory Accounting Treatment, Case No. IPC-E-23-11, Stipulation and Settlement at 7 (Oct. 27, 2023). 2 Id. Commission Secretary Idaho Public Utilities Commission September 19, 2024 Page 2 of 7 administrative details for the WAQC and Easy Savings programs. With this filing, the Company submits the following tariff sheet for revision: First Revised Sheet No. 79-1 Canceling Original Sheet No. 79-1 PROGRAM BACKGROUND & MODIFICATIONS Over the course of the last several months, Idaho Power has worked with Staff, the CAPS, and the Idaho Department of Health and Welfare ("IDHW") to develop recommended changes to the ongoing implementation of the WAQC and Easy Savings programs. I. WAQC Background Idaho Power initially offered its Low-income Weatherization Assistance ("LIWA") program in 1989 in conjunction with the State of Idaho's Weatherization Assistance Program. Through the LIWA program, the Company provided supplementary funding to state designated CAP agencies for the weatherization of homes occupied by qualified low-income customers as well as buildings occupied by qualified non-profit organizations. The program was renamed WAQC in 2005. The WAQC program has gone through several changes since its inception in 1989. Of note, the program funding was initially increased as a result of Order No. 29505 (issued in Case No. IPC-E-03-13), where the Commission directed the Company to increase the $0.2 million of annual program funding by $1 million through June 2007, and to carry forward to the following year any unpaid funds.3 Through cases filed in 2007, 2011, and 2012, the Commission reviewed the annual funding levels and carryover provisions and reaffirmed those program elements.4 3 In the Matter of the Application of Idaho Power Company for Authority to Increase its Rates and Charges for Electric Service to Electric Customers in the State of Idaho, Case No. IPC-E-03-13, Order No. 29505 at 32 (May 25, 2004). 4 In the Matter of the Joint Application of Community Action Partnership Association of Idaho, Inc. and Idaho Power Company for the Authority to Continue the Present Funding Level for Weatherization Assistance as Authorized by Order No. 29505, Case No. IPC-E-07-09, Order No. 30350 at 4 (June 15, 2007). In the Matter of the Application of Idaho Power Company for Authority to Increase it Rates at Charges for Electric Service to its Customers in the State of Idaho, Case No. IPC-E-11-08, Order No. 32426 at 36 (December 30, 2011). Commission Secretary Idaho Public Utilities Commission September 19, 2024 Page 3 of 7 In 2022, recognizing the need to address the growing amount of carryover funds that had accumulated as the result of the COVID-19 pandemic, supply chain limitations, and labor shortages, the Company, in Case No. IPC-E-22-15, proposed to modify the WAQC program to include a re-weatherization option. Under the re-weatherization option, the Company proposed to use carryover funds to pay for up to 100 percent of HVAC upgrades in homes that had previously been weatherized through WAQC (within a rolling 14-year period) and did not receive an HVAC replacement. In Order No. 35583, the Commission approved the addition of re-weatherization to the WAQC program.5 Under the WAQC program Idaho Power allocates the $1.2 million annually to five regional CAP agencies: Eastern Idaho Community Action Partnership ("EICAP"), El Ada Community Action Partnership ("EL ADA"), Metro Community Services ("Metro Community"), South Central Community Action Partnership ("SCCAP"), and Southeastern Idaho Community Action Agency ("SEICAA"). The initial allocation is determined on a prorated basis, which is based on poverty level and population in the area each agency serves. Additionally, CAP agencies can transfer up to $50,000 annually to another CAP, upon mutual agreement. The allocation method and transfer eligibility provisions are outlined in the agency contracts that are executed between Idaho Power and each agency. There is also a pooled account that allows for $50,000 of the allocated funds to be used to pay for up to 100 percent of the cost to weatherize qualified non- profits. Currently, Idaho Power's funding is limited to an average annual cost per dwelling weatherized of up to $6,000, which it was increased in 2013 and has remained unchanged since that time.6 As currently provided for in Schedule 79, the Company may fund up to 85 percent of the total cost provided that at least 15 percent is funded by the Department of Energy ("DOE"). Ten percent of the total annual allocated funds are earmarked for agency administration. Services must be invoiced in the year they occur, and unspent funds are carried over year to year. In the Matter of the Commission's Inquiry into the Cost-Effectiveness and Funding of Low-Income Weatherization Programs and Energy Conservation Programs for Electric Utilities, GNR-E-12-01, Order No. 32788 at 9 (April 12, 2013). 5 In the Matter of Idaho Power Company's Application for Authority to Modify Schedule 79— Weatherization Assistance for Qualified Customers, Case No IPC-E-22-15, Order No. 35583 at 4 (Nov. 4, 2022). 6 The maximum annual average cost per dwelling weatherized has been negotiated through agency agreements and was not established by a Commission Order. Commission Secretary Idaho Public Utilities Commission September 19, 2024 Page 4 of 7 Stakeholder Engagement Per the Stipulation and Settlement in Case No. IPC-E-23-11, the Company met with Staff and CAP agencies, as well as IDHW, 7 to determine administrative details for its WAQC program going forward. Idaho Power held its initial WAQC stakeholder working session on July 31, 2024. In attendance were Staff, IDHW, EL-ADA, SCCAP, Metro Community, and SEICAA. The stakeholders participated in robust discussions and provided feedback on programmatic administration. Stakeholders agreed that the current $1.2 million funding level is sufficient and, in light of the source of the funds changing from base rates to the Rider, were supportive of removing future carryover of program funds. While supportive of the Company no longer tracking a "carryover," stakeholders sought flexibility when invoicing for projects that may take place at the end of the year, as the timing of work completed may not align with funds expended. Stakeholders also recommended that the transfer limit between CAP agencies be increased to allow for more flexibility in getting funds spent. Further, stakeholders expressed support for a modification to the $6,000 annual average job cap. Through the discussion, stakeholders supported tying the Idaho Power maximum average annual cost per dwelling weatherized to the annual DOE average job cost cap. The stakeholders recognized that the DOE average job cost cap is adjusted annually,8 and so tying the Idaho Power maximum average annual cost per dwelling weatherized to the DOE average job cost cap would provide a reasonable mechanism to keep up with rising costs. For the re-weatherization option, stakeholders expressed an interest in expanding eligibility to include other electric equipment, in addition to HVAC. The purpose of this expansion would be so funds could be utilized to complete needed weatherization upgrades for targeted homes. For example, a home may need HVAC upgrades but to complete the upgrades they may need to additionally upgrade their electrical service panel. Expanding equipment eligibility options for re-weatherization would allow the funds to be better utilized for their intended purpose of re-weatherization. The Company held an additional meeting with Staff on August 8, 2024, to review the Company's proposed modifications, answer any additional questions Staff had, and discuss the Company's next steps. Finally, the Company presented the proposed changes for the WAQC program at its Energy Efficiency Advisory Group ("EEAG") meeting on August 14, 2024. EEAG members were encouraged by the stakeholder engagement and generally supportive of the proposed changes. IDHW was also included in these meetings as it oversees the state's allocation of DOE funds. 8 The adjustment is based on the Consumer Price Index for the prior year, or 3 percent, whichever is less. Commission Secretary Idaho Public Utilities Commission September 19, 2024 Page 5 of 7 Proposed Programmatic and Tariff Changes In accordance with the Stipulation and Settlement and based on stakeholder feedback the Company proposes the following changes to its WAQC program: (1) eliminate the future carryover of unspent funds from year to year; (2) allow for services rendered in the current year to be invoiced within 60 days of the start of the following year; (3) remove the dollar limit to funds that can be transferred between CAP agencies; (4) match the maximum annual average cost per dwelling weatherized to the DOE maximum;9 and (5) modify the re-weatherization program to allow for other electric equipment, in addition to HVAC, to be updated. As described above, some of the modifications will require changes to Schedule 79, while others have historically been memorialized in agency agreements. For ease of Commission review, the table below provides a summary of each change and how the Company proposes to effectuate the change: Programmatic . Mechanism - Eliminate carryover Schedule 79 & Agency Agreements Allowance for services rendered in current year to be invoiced Schedule 79 & Agency within 60 days of the following year Agreements Remove dollar limit that can be transferred between agencies Agency Agreements Match maximum annual average cost per home to DOE Agency Agreements maximum Modify re-weatherization to allow for other electric equipment, Schedule 79 & Agency in addition to HVAC Agreements II. EASY SAVINGS Background Idaho Power began offering its Easy Savings program in 2009 following Commission Order Nos. 3072210 and 3075411 issued in Case No. IPC-E-08-10. In the orders, Idaho Power was directed to fund energy efficiency education for low-income customers by providing $125,000 to CAP agencies annually, on a prorated basis. At that 9 Currently $8,495. 10 In the Matter of the Application of Idaho Power Company for Authority to Increase its Rates and Charges for Electric Service to its Customers in the State of Idaho, Case No. IPC-E-08-10, Order No. 30722 at 46 (Jan. 30, 2009). " Id. Order No. 30754 at 8 and 9 (March 19, 2009). Commission Secretary Idaho Public Utilities Commission September 19, 2024 Page 6 of 7 time, the Company also established a committee, which includes Staff, the CAPs, and IDHW ("the Committee"), to advise on general program administration of the Easy Savings program. Between 2009 and 2017, the Easy Savings program funds were utilized to distribute energy-saving kits and educational materials to low-income customers. In 2017, the Committee aligned that the Company should modify the Easy Savings program. At that time, the program changed to offering a coupon for a free electric HVAC tune-up and one-on-one education, with the goal of helping the customer learn ways to reduce their energy costs and better maintain their HVAC systems. Today the program continues to offer these coupons and one-on-one education through regional agencies and participating HVAC contractors. The Company's funding obligation has remained unchanged at $125,000 and is distributed to agencies on a prorated basis determined by population and poverty level in each agency's service area. The funds are given to the agencies upfront and unused funds are added to each agency's allotment for the following year. Stakeholder Engagement Per the Stipulation and Settlement in Case No. IPC-E-23-11, the Company met with Staff, CAP agencies, as well as IDHW, to determine the administrative details for its Easy Savings program. The Company held an Easy Savings working session with the Committee on August 29, 2024.12 In attendance were the Community Council of Idaho, SCCAP, SEICAA, EICAP, and IDHW. The Company discussed the existing program administration, presented its proposed changes to the Easy Savings program, and listened to stakeholder feedback. The primary point of discussion was around the timing of when agencies receive funds. Currently, the agencies receive funds upfront and are expected to spend the dollars throughout the program year by distributing coupons and providing one-on-one education; however, this structure presents administrative inefficiencies because of added coordination at agency fiscal offices to return unused funding. In recognition of the challenges presented by the timing of fund allocation, the stakeholders were supportive of modifying the program to allow for payment to be issued after services are rendered (which is similar to WAQC). Proposed Programmatic Changes In accordance with the Stipulation and Settlement and based on stakeholder feedback the Company proposes to implement minor changes to its Easy Savings program. The Company proposes the annual funding cap remain unchanged at$125,000; 12 During the Company's August 8, 2024, meeting with Staff, Idaho Power previewed the changes it would be proposing to the Easy Savings program. Commission Secretary Idaho Public Utilities Commission September 19, 2024 Page 7 of 7 however, in recognition that funding will be provided through the Rider rather than base rates, the Company proposes to require the CAP agencies to invoice the Company for payment of redeemed coupons, rather than receive payment upfront. This change will improve administrative efficiency and will ensure that customer funds are only expended after services have been performed. Further, this modification eliminates the need to track "carryover" as the agencies will have access of up-to their annual allocation. These programmatic modifications will require changes to agency agreements. CONCLUSION The Company is appreciative of the opportunity to work with Staff, the CAP agencies, and IDHW in identifying programmatic changes that can enhance the CAP agencies' ability to provide critical weatherization and low-income education services to Idaho Power's customers, while also providing for administrative efficiencies. Idaho Power believes the above-described changes proposed are minor relative to the size and maturity of the WAQC and Easy Savings programs. Because this is a compliance filing, and the Company has engaged in extensive stakeholder outreach and consultation with Commission Staff, Idaho Power recommends that this tariff advice be reviewed pursuant to Staff's ministerial responsibility described in Rule of Procedure 133 and 134 without modified procedure or formal process. An order received in advance of November 15, 2024, will allow for the Company to negotiate new agency agreements in advance of the 2025 program year for both WAQC and Easy Savings. The Company respectfully requests the Commission issue an order (1) approving the Company's proposed changes to both the WAQC and Easy Savings programs, (2) approving the proposed changes to Schedule 79, effective November 15, 2024, and (3) acknowledging the Company has satisfied its compliance obligation to work with Staff and the CAPS to develop implementation and ongoing administrative details for the WAQC and Easy Savings programs. Very truly yours, Connie Aschenbrenner Rate Design Senior Manager CA:sg Enclosure Idaho Power Company First Revised Sheet No. 79-1 Cancels I.P.U.C. No. 30, Tariff No. 101 Original Sheet No. 79-1 SCHEDULE 79 WEATHERIZATION ASSISTANCE FOR QUALIFIED CUSTOMERS AVAILABILITY Funding under this schedule is available to state designated Community Action Partnership (CAP) agencies throughout the Company's service area within the State of Idaho participating in the State of Idaho Weatherization Assistance Program administered by the Idaho Department of Health and Welfare. Funding under this schedule is subject to the provisions of the signed Agreement between the individual CAP agencies and the Company. APPLICABILITY Funding under this schedule is applicable to qualifying energy conservation measures installed in single- and multi-family residential dwellings, including mobile homes, which are electrically heated (Qualifying Dwellings). Funding is also applicable to qualifying energy conservation measures installed in buildings which are occupied by private, non-profit organizations which serve primarily low-income clientele, and which have obtained a 501(c)(3) tax exempt status (Qualifying Buildings). Energy conservation measures installed in Qualifying Dwellings and Qualifying Buildings must meet the specifications of the State of Idaho Weatherization Assistance Program. GRANTS TO AGENCIES The Company will determine the amount of annual grant funds available to each participating CAP agency each year in accordance with the provisions of the Agreement. Funds will be distributed to a participating CAP agency upon demonstration by the agency that qualifying conservation measures have been installed in a Qualifying Dwelling or Qualifying Building. Grant funds made available to a CAP agency but not distributed to that agency during the current year may be invoiced within 60 days after year end for those services provided within the prior year. In addition to weatherization funds, the Company will provide to each CAP agency an administrative payment equal to 10 percent of the portion funded by the Company for each Qualifying Dwelling or Qualifying Building for which weatherization was completed with the assistance of Company funds. Qualifying Dwellings: The Company grant funds may be used to fund up to 85 percent of the total cost of qualifying conservation measures installed in a Qualifying Dwelling provided at least 15 percent of the total cost of qualifying conservation measures is funded by the Department of Energy, except in the case where carryover funds are being used for re-weatherization. Re-weatherization applies to homes that were previously weatherized under Schedule 79 within a rolling 14-year period. For those homes, the program's carryover funds may be used to pay up to 100 percent of HVAC, domestic water heaters, or upgrades to other equipment used for heating ventilation, air conditioning or water heating. Qualifying Buildings: The Company grant funds may be used to fund the installation of weatherization measures in Qualifying Buildings in accordance with the provisions of the Agreement. The Company provided funds may be used to fund up to 100 percent of the total cost of qualifying conservation measures installed in Qualifying Buildings. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. 36042 Timothy E. Tatum, Vice President, Regulatory Affairs Effective— November 15, 2024 1221 West Idaho Street, Boise, Idaho Advice No. 24-03 Idaho Power Company GFigiRal-First Revised Sheet No. 79-1 Cancels I.P.U.C. No. 30, Tariff No. 101 Forst RevisecOriginal Sheet No. 79-1 SCHEDULE 79 WEATHERIZATION ASSISTANCE FOR QUALIFIED CUSTOMERS AVAILABILITY Funding under this schedule is available to state designated Community Action Partnership (CAP) agencies throughout the Company's service area within the State of Idaho participating in the State of Idaho Weatherization Assistance Program administered by the Idaho Department of Health and Welfare. Funding under this schedule is subject to the provisions of the signed Agreement between the individual CAP agencies and the Company. APPLICABILITY Funding under this schedule is applicable to qualifying energy conservation measures installed in single- and multi-family residential dwellings, including mobile homes, which are electrically heated (Qualifying Dwellings). Funding is also applicable to qualifying energy conservation measures installed in buildings which are occupied by private, non-profit organizations which serve primarily low-income clientele, and which have obtained a 501(c)(3) tax exempt status (Qualifying Buildings). Energy conservation measures installed in Qualifying Dwellings and Qualifying Buildings must meet the specifications of the State of Idaho Weatherization Assistance Program. GRANTS TO AGENCIES The Company will determine the amount of annual grant funds available to each participating CAP agency each year in accordance with the provisions of the Agreement. Funds will be distributed to a participating CAP agency upon demonstration by the agency that qualifying conservation measures have been installed in a Qualifying Dwelling or Qualifying Building. Grant funds made available to a CAP agency but not distributed to that agency during the current year may be invoiced within 60 days after year end for those services provided within the prior year.Garrmed f„pNard to the Rext yeaF. In addition to weatherization funds, the Company will provide to each CAP agency an administrative payment equal to 10 percent of the portion funded by the Company for each Qualifying Dwelling or Qualifying Building for which weatherization was completed with the assistance of Company funds. Qualifying Dwellings: The Company grant funds may be used to fund up to 85 percent of the total cost of qualifying conservation measures installed in a Qualifying Dwelling provided at least 15 percent of the total cost of qualifying conservation measures is funded by the Department of Energy, except in the case where carryover funds are being used for re-weatherization. Re-weatherization applies to homes that were previously weatherized under Schedule 79 within a rolling 14-year period. For those homes, the program's carryover funds may be used to pay up to 100 percent of HVAC, domestic water heaters, or upgrades to other equipment used for heating ventilation, air conditioning or water heating. upgrades. Qualifying Buildings: The Company grant funds may be used to fund the installation of weatherization measures in Qualifying Buildings in accordance with the provisions of the Agreement. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. 36042 36042 Timothy E. Tatum, Vice President, Regulatory Affairs Effective—daRuary-4November 15, 2024 1221 West Idaho Street, Boise, Idaho Advice No. 24-03 Idaho Power Company nralFirst Revised Sheet No. 79-1 Cancels I.P.U.C. No. 30, Tariff No. 101 Ciro ReviseclOriginal Sheet No. 79-1 The Company provided funds may be used to fund up to 100 percent of the total cost of qualifying conservation measures installed in Qualifying Buildings. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. 36042 36042 Timothy E. Tatum, Vice President, Regulatory Affairs Effective—danuaFy4November 15, 2024 1221 West Idaho Street, Boise, Idaho Advice No. 24-03