20241115Reply Comments.pdf

"%6h-NIQAHO POVER.
MEGAN GOICOECHEA ALLEN RECEIVED
Corporate Council Friday, November 15, 2024
mgoicoecheaallen(d-)idahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
November 15, 2024
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
RE: Case No. IPC-E-24-39
In the Matter of Idaho Power Company's Tariff Advice in Compliance
with Order No. 36042 Related to Changes to Schedule 79 —Tariff Advice
No. IPC-TAE-24-03
Dear Commission Secretary:
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,
Megan Goicoechea Allen
MGA:sg
Enclosure
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

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]
mgoicoecheaallenCo)idahopower.com
Attorney for Idaho Power Company
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 ) IDAHO POWER COMPANY'S
79 — TARIFF ADVICE NO. IPC-TAE-24-03 ) REPLY COMMENTS
Idaho Power Company ("Idaho Power" or "Company") respectfully submits the
following Reply Comments in response to Comments filed by the Idaho Public Utilities
Commission ("Commission") Staff ("Staff") on November 7, 2024. In its Comments, Staff
concludes that it generally supports Idaho Power's proposed changes. However, Staff
also noted that Commission Order No. 36331, issued on September 26, 2024, in IPC-E-
24-11 provided additional commentary on some of these topics.' Based on its review of
the Company's application, discovery, and the recently issued Order No. 36331, Staff
recommends that the Commission: (1) deny the Company's request to match the
maximum annual average cost per home to the Department of Energy ("DOE") maximum
and instead approve a one-time increase to $8,495; (2) approve the Company's other
' Staff Comments at 2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 1

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 Community Action
Partnership ("CAP") Agencies to develop implementation and ongoing administrative
details for the Weatherization Assistance for Qualified Customers ("WAQU) and Easy
Savings programs.2 In these reply comments, the Company briefly responds to Staff's
comments regarding the maximum annual average cost cap.
I. REPLY COMMENTS
Staff recommends that the Commission approve a one-time increase to the annual
average cost per home weatherized to match the current DOE job cap of$8,495 because
it believes that the increase will provide increased opportunity to capture savings and
flexibility for CAP agencies. However, Staff also recommends that the Commission deny
the Company's request to tie the annual average job cap to DOE job cap increases
because tying the Company's cap to the DOE cap represents a potential risk that should
be monitored to provide clarity to the Commission's concerns expressed in Order No.
36331. In that Order the Commission declined a similar request to raise the cap because
of uncertainty of how much additional savings a raised cap would allow. Based on this
Staff further recommends that the Company collect and provide additional detail on the
incremental savings that the CAP Agencies are able to capture under the increased cap
as part of its annual Demand Side Management report to support potential future requests
to increase the cap further.'
Idaho Power appreciates Staff's thoughtful analysis of its proposal to raise the cap
and tie it to the DOE cap in future years. While the Company believes that its proposal to
2 Id. at 4-5.
' Id. at 4.
IDAHO POWER COMPANY'S REPLY COMMENTS -2

allow the project cost cap to fluctuate with the DOE cap is reasonable, it understands the
Commission and Staff's desire to review future updates to the cap. Accordingly, the
Company is supportive of Staff's recommendation to approve a one-time increase to
$8,495, and while it may be difficult to quantify incremental savings due to the nature of
whole-home billing analysis that is used and to discern which projects might not have
moved forward without the cap increase, Idaho Power will commit to collect and provide
additional detail on the incremental savings that the CAP Agencies are able to capture,
where possible, as part of any future potential requests to increase the cap further.
II. CONCLUSION
Idaho Power appreciated the collaboration with the CAP Agencies and Staff to
work to improve its WAQC and Easy Savings Programs. The Company respectfully
requests that the Commission issue an Order approving: (1) a one-time change in the
average annual project job cost cap to $8,495, (2) the Company's remaining proposed
changes to its WAQC and Easy Savings programs as filed, (3) the proposed changes to
Schedule 79, effective December 1, 2024, and (4) finding that 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.
DATED at Boise, Idaho, this 15t" day of November 2024.
Akr
I xtIuqNL
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 15th day of November 2024, 1 served a true and
correct copy of Idaho Power Company's Comments the following named parties by the
method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Dayn Hardie U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8 FTP Site
Suite 201-A (83714) X Email Dayn.Hardie(a�puc.idaho.gov
PO Box 83720
Boise, ID 83720-0074
Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS -4