20241107Staff Comments .pdf

RECEIVED
Thursday, November 7, 2024 1:49:04 PM
IDAHO PUBLIC
UTILITIES COMMISSION
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
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 TARIFF ADVICE IN ) CASE NO. IPC-E-24-39
COMPLIANCE WITH ORDER NO. 36042 )
RELATED TO CHANGES TO SCHEDULE 79 )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Dayn Hardie, Deputy Attorney General,
submits the following comments.
BACKGROUND
On December 28, 2023, the Commission issued Order No. 36042 approving an all-party
settlement in Case No. IPC-E-23-11. As part of this settlement, the Company committed to
working with Staff and the Community Action Partnership ("CAP") agencies to develop
implementation and ongoing administration details, including funding levels, for the Company's
low-income weatherization programs, which could be presented for Commission approval in the
Company's next demand-side management("DSM")prudence filing or other compliance filing.
Pursuant to the directives in Order No. 36042, the Company met with Staff, the Idaho
Department of Health and Welfare, and CAP agencies on July 31, 2024, to update the
STAFF COMMENTS 1 NOVEMBER 7, 2024

implementation and administration of the Weatherization Assistance for Qualified Customers
("WAQC") and Easy Savings programs.
On September 19, 2024, the Company submitted Tariff Advice No. IPC-TAE-24-03,
requesting:
"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
Community Action Partnership agencies to develop implementation and
ongoing administrative details for the WAQC and Easy Savings programs."
Tarif Advice No. IPC-TAE-24-03 (Case No. IPC-E-24-39).
The Company filed a proposed Schedule 79 and requested a November 15, 2024,
effective date.
On October 281h, 2024, the Commission issued Order No. 36369, (1) treating the
Company's tariff advice as an Application, (2) issuing a Notice of Application, (3) issuing a
Notice of Modified Procedure, (4) suspending the proposed effective date until December 1,
2024, and(5) establishing a November 7, 2024,public comment deadline, and a November 15,
2024, Company reply deadline.
STAFF ANALYSIS
The Company's initial tariff advice describes five proposed modifications to the 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 Department of Energy
("DOE")maximum; and(5)modify the re-weatherization program to allow for other electric
equipment, in addition to Heating, Ventilation, and Air Conditioning ("HVAC") measures, to be
updated. As detailed in a table provided in the Company's Application, most of these changes
can be accomplished through the agreements between the Company and the CAP agencies.
Proposal numbers 1, 2, and 5 also require adjustments to Schedule 79. In general, Staff supports
these proposed changes. However, on September 26th, 2024, Order No. 36331 provided
additional commentary on some of these topics. In the sections below, Staff addresses the
additional concerns in the Commission's recent order and the results of its discovery in this case.
STAFF COMMENTS 2 NOVEMBER 7, 2024

Reweatherization
One of the Primary results of the Stakeholder working meetings is the proposal to expand
the reweatherization pilot to include additional HVAC-related electrical upgrades and water
heaters. While the movement of WAQC funding to the rider on January 1, 2024, has removed
the need to track carryover funds,' the proposed change does not affect the previously
accumulated balance of carry-over funds. A significant balance of unspent funds remains
available to the reweatherization pilot program. Staff believes that this expansion of the existing
program will be important for the continuation of the pilot and could provide additional
opportunity to increase clarity on CAP agency spending.
In 2023, the reweatherization pilot program weatherized 30 homes from an original pool
of 1,000 homes. Response to Production Request No. 1. With the additional spend of the
reweatherization, the WAQC program costs were able to meet its allocation for the first time
since 2019. However, in 2024, the year-to-date participation in the reweatherization option has
decreased to only nine homes. Response to Production Request No. 2. Additionally, the
Company states that the CAP agencies have reached out to most of the 1,000 customers eligible
for reweatherization. Response to Production Request No. 1. Without additional action, Staff is
concerned that the reweatherization pilot may not be able to provide meaningful reduction to the
pre-2024 accumulated unspent funds. The expanded pilot scope will provide additional options
for CAP agencies to reduce the accumulated carry-over funds and benefit low-income customers
in Idaho. In its response to Production Request No. 2, the Company states that it has not
calculated an estimate for the potential pool of homes that would be eligible under the proposal;
however, the list would include all homes eligible to the original pilot that did not receive water
heaters as well as other homes. Staff is comfortable with the increased program scope because it
remains within the bounds of the initial reweatherization pilot. The pilot is not allowed to spend
more than the balance of accumulated carry-over funds and any funds not spent by the pilot
program will be considered when the pilot ends in 2025. The expanded pilot scope may also
provide additional data to provide increased clarity on the concerns listed by the Commission in
Order No. 36331. Staff recommends the Company use the remaining year of the pilot program
'With the WAQC funding moved into the rider any unspent funds will be absorbed back into the rider as an offset.
STAFF COMMENTS 3 NOVEMBER 7, 2024

to collect additional data on how the CAP agencies utilize the opportunity of increased spending
ability.
Maximum Annual Average Cost
In its Application, the Company proposes to tie the annual average project cap to match
the annual DOE average job cap. However, in Order No. 36331, the Commission declined a
similar request to raise the cap because of uncertainty of how much additional savings, if any, a
raised cap would allow. Staff believes that the increased annual average job cap will provide
increased opportunity to capture savings and flexibility for CAP agencies. Due to the timing of
the Commission's Order, the Company's workshops were not able to provide additional clarity
on the Commission's concern. Tying the cap to the DOE job cap represents a potential risk that
should be monitored to provide clarity to the Commission's concerns.
In addition to increasing the annual average job cap, the Company's proposal to tie the
WAQC annual average job cap to the DOE annual average job cap will also result in future
increases. In its Application, the Company explains that the DOE job cap is adjusted annually.
Application at 4. While this does provide a mechanism to account for rising costs, Staff is
concerned that the continually increasing job cap may not be representative of the Idaho CAP
agencies' need for an increased cap. Staff recommends the Commission deny the Company's
request to tie the annual average job cap of the Company's WAQC funding to the annual DOE
average job cap. Instead, Staff recommends that the Commission approve a one-time increase to
the Company's annual average job cap to match the current DOE job cap of$8,495.
Additionally, Staff recommends that the Company collect and provide additional detail on the
incremental savings that the CAP agencies have been able to capture under the increased job cap
as part of its annual DSM report to support potential future requests to increase the cap further.
STAFF RECOMMENDATION
Based on its review of the Company's application, discovery, and analysis detailed
above, Staff recommends that the Commission:
1. Deny the Company's request to match the maximum annual average cost per home to
DOE maximum and instead approving a one-time increase to the annual average job
cap to $8,495;
STAFF COMMENTS 4 NOVEMBER 7, 2024

2. Approve the Company's other requests as filed, with an effective date of December 1,
2024; and
3. Acknowledge the Company has satisfied its compliance obligation to work with Staff
and the Community Action Partnership agencies to develop implementation and
ongoing administrative details for the WAQC and Easy Savings programs
Respectfully submitted this 7th day of November 2024.
Dayn Hardie
Deputy Attorney General
Technical Staff. Jason Talford
I:\Utility\UMISC\COMMENTS\IPC-E-24-39 Comments.docx
STAFF COMMENTS 5 NOVEMBER 7, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF NOVEMBER
2024, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF , IN
CASE NO. IPC-E-24-39, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: caschenbrenner(?idahopower.com
docketsgidahopower.com
PATRICIA JORDAN, SE ARY
CERTIFICATE OF SERVICE