20250314APPLICATION.pdf

qN WIDAW POWER.
MEGAN GOICOECHEA ALLEN
Corporate Counsel RECEIVED
mgoicoecheaallen(aD_idahopower.com March 14, 2025
Idaho Public
Utilities Commission
March 14, 2025
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-25-12
In the Matter of the Application of Idaho Power Company for a Determination
of 2024 Demand-Side Management Expenses as Prudently Incurred
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Application and the Direct
Testimony of Quentin Nesbitt in support of the Application in the above-entitled matter.
Due to the voluminous nature of the attachments to the Application, the Company is
posting the PDF files to the secure FTP site. The login information will be provided
separately.
A Word version of the testimony will also be sent in an email for the convenience of
the Reporter.
In addition, four (4) copies of the Application, Direct Testimony, and the DSM 2024
Annual Report will be hand delivered to the Commission.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
U%r I.
Megan Goicoechea Allen
MGA:cd
Enclosures
P.O.Box 70(83707)
1221 W.Idaho St.
Boise,ID 83702

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]
mgoicoecheaal len(o-)_idahopower.com
Attorney 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-25-12
DETERMINATION OF 2024 DEMAND-SIDE )
MANAGEMENT EXPENSES AS ) APPLICATION
PRUDENTLY INCURRED. )
Idaho Power Company ("Idaho Power" or "Company"), in accordance with
Commission Rule of Procedure' 52, et. seq., and Order No. 29419,2 submits its Demand-
Side Management 2024 Annual Report ("DSM 2024 Annual Report") and makes
Application to the Idaho Public Utilities Commission ("Commission") for an order
designating Idaho Power's expenditures of$25,922,708 in Idaho Energy Efficiency Rider
("Rider") funds and $8,950,583 of demand response program incentives funded through
base rates and tracked annually through the Power Cost Adjustment ("PCA") mechanism,
for a total of $34,873,291, as prudently incurred demand-side management ("DSM")
expenses.
Hereinafter cited as RP.
2 In the Matter of the Petition Filed by Idaho Power Company for Modification to Two Prior Orders to
Permit Consolidation of the Company's Conservation and Demand Side Management(DSM) Reporting
Requirement into a Single Consolidated Report, Case No. IPC-E-03-19, Order No. 29419, p. 2 (Jan. 14,
2004).
APPLICATION - 1

In support of this Application, Idaho Power offers the Direct Testimony of Quentin
Nesbitt ("Nesbitt Testimony") filed contemporaneously herewith and represents as
follows:
I. INTRODUCTION
1. It is well-established that the Commission considers the promotion of cost
effective energy efficiency and demand-side management an integral part of least-cost
electric service:3 "The Commission has consistently stated that cost-effective DSM
programs are in the public interest and has admonished electric utilities operating in the
state of Idaho to develop and implement DSM programs in order to promote energy
efficiency."4
2. Like the Commission, Idaho Power believes that energy efficiency and
demand response are an important and necessary part of a balanced approach to
meeting system energy needs and endeavors to provide customers with programs and
knowledge through its DSM programs to help them use electricity wisely. The Company's
energy efficiency portfolio includes a broad array of programs available to its customers
in energy efficiency, demand response, and education.
3. Energy efficiency programs are available to all customer segments in Idaho
Power's service area and focus on reducing energy use by identifying homes, buildings,
equipment, or components for which an energy-efficient design, replacement, or repair
can achieve energy savings. Some energy efficiency programs include behavioral
3 See, e.g. In the Matter of the Investigation of Financial Disincentives to Investment in Energy Efficiency
by Idaho Power Company, Case No. IPC-E-04-15, Order No. 30267, p. 13 (Mar. 12, 2007).
4 In the Matter of the Idaho Power Company's Application for an Order Designating the Energy Efficiency
Rider Funds Spent by the Company During 2008-2009 as Prudently Incurred Expenses, Case No. IPC-E-
10-09, Order No. 32113, p. 8 (Nov. 16, 2010).
APPLICATION - 2

components. Savings from energy efficiency programs are measured on a kilowatt-hour
or megawatt-hour ("MWh") basis.
4. The goal of Idaho Power's demand response programs is to minimize or
delay the need to build new supply-side peaking resources, and the demand response
portfolio currently has a capacity of more than 8.5 percent of its all-time system peak load
available to respond to a system peak load event during the summer. In 2024, the
Company utilized all or portions of its three demand response programs: A/C Cool Credit,
Flex Peak Program, and Irrigation Peak Rewards. Demand response is measured both
by the actual demand reduction in megawatts ("MW") achieved during events, as well as
the potential demand reduction if all programs were used at full capacity.
5. The Company strives to ensure it offers DSM programs that offer value to
its customers and increase the DSM savings available to it. In 2024, Idaho Power
achieved 16.4 average megawatts ("aMW") of incremental energy efficiency savings,
including estimated energy efficiency market transformation savings through Northwest
Energy Efficiency Alliance ("NEEA") initiatives, which represents enough energy to power
approximately 12,596 average homes in Idaho Power's service area for one year. Nesbitt
Testimony at 9. From its three demand response programs, Idaho Power achieved a total
non-coincident demand reduction of 257 MW from an available capacity of 323 MW
during the 2024 program season. Nesbitt Testimony at 10-11.
6. In addition to the education customers get through participation in specific
incentive programs for energy efficiency, Idaho Power educates customers on energy
efficiency in many other ways including presentations, trainings, workshops, and trade
shows. DSM 2024 Annual Report at 11-12. The Company sponsors significant customer
APPLICATION - 3

educational outreach and awareness activities, promotes codes and standards, and
focuses marketing efforts on saving energy—none of which are quantified or claimed as
part of Idaho Power's annual DSM savings, but are likely to result in energy savings that
accrue to Idaho Power's electrical system over time. Nesbitt Testimony at 10.
7. As the Commission previously noted, "DSM benefits depend on constantly
evaluating opportunities and identifying ways to improve available programs."5 To this
end, Idaho Power devotes significant resources to maintain and improve its energy
efficiency and demand response programs and actively works to both improve the cost
effectiveness of existing DSM programs and explore the addition of new DSM offerings
for customers.
8. Idaho Power strives to ensure that DSM funds collected from customers are
utilized to support the pursuit of cost-effective energy efficiency and demand response
programs, with the limited exception of certain policy considerations. This goal is achieved
by applying a multi-step process. Prior to the actual implementation of energy efficiency
or demand response programs, Idaho Power performs a preliminary cost-effectiveness
analysis to assess whether a potential program design or measure will be cost-effective
from the perspective of customers as well as the Company. Idaho Power measures cost-
effectiveness under three tests: the Utility Cost Test ("UCT"), the Total Resource Cost
("TRC") test, and the Participant Cost Test ("PCT"). A review of each test allows for an
economic assessment of the life-cycle costs and benefits of a DSM investment from the
perspective of DSM program participants, Idaho Power, and non-participating customers.
5 In the Matter of the Application of Idaho Power Company for a Determination of 2020 Demand-Side
Management Expenses as Prudently Incurred, Case No. IPC-E-21-04, Order No. 35270, p. 8 (Dec. 27,
2021).
APPLICATION - 4

Nesbitt Testimony at 16.
9. The Company's 2023 general rate case and the 2023 Integrated Resource
Plan ("IRP")7 resulted in various changes to the Company's DSM programs that impacted
the 2024 program year. More specifically, the settlement approved by Order No. 36042
in the Company's 2023 general rate case made two changes to funding in the Idaho Rider:
(1) shifting $1,324,853 associated with income-qualified weatherization and low-income
education funding from base rates to the Rider and (2) shifting about $3.5 million of Rider
funded labor costs into base rates. In addition, beginning with the 2024 program year, the
Company transitioned to using avoided cost from its most recently acknowledged IRP to
those contained in it most recently filed IRP for purposes of DSM planning, evaluations,
and analyses.8 The 2023 IRP also contained changes to seasons and hours of highest
risk that have led to changes in the DSM program savings shapes.
II. CONTENTS OF THE DSM 2024 ANNUAL REPORT
10. Idaho Power's DSM 2024 Annual Report, which is included as Attachment
1 to this Application, is submitted in compliance with the reporting requirement set forth
in Commission Order No. 29419 in Case No. IPC-E-03-19. The Company's actions, as
detailed in the DSM 2024 Annual Report, demonstrate the conscientious work Idaho
Power undertook to expend funds wisely to further DSM activities over the course of the
last year.
11. The DSM 2024 Annual Report consists of the main document (with
6 In the Matter of the Application of Idaho Power Company for Authority to Increase Its Rates and
Charges for Electric Service in the State of Idaho and for Associated Regulatory Accounting Treatment,
Case No. IPC-E-23-11, Order No. 36042 (Dec. 28, 2023) (approving settlement stipulation).
In the Matter of Idaho Power Company's 2023 Integrated Resource Plan, Case No. IPC-E-23-23, Order
No. 36233 (Jun. 18, 2024).
8 In the Matter of Idaho Power Company's Application for a Determination of 2023 Demand-Side
Management Expenses as Prudently Incurred, Case No. IPC-E-24-11, Order No. 36331 (Sept. 26, 2024).
APPLICATION - 5

appendices) and two supplements. The main report provides details for each of the
Company's DSM programs including program descriptions, 2024 performance results,
program activities, expenditures and cost-effectiveness ratios, marketing efforts,
customer satisfaction, and evaluation results if applicable. Supplement 1: Cost-
Effectiveness ("Supplement 1") to the DSM 2024 Annual Report provides detailed cost-
effectiveness data for each program and includes a table that reports expenses by
funding source and cost category. Supplement 2: Evaluation ("Supplement 2")to the DSM
2024 Annual Report includes an evaluation and research summary, the evaluation plan,
Energy Efficiency Advisory Group ("EEAG") meeting notes, links to NEEA evaluations,
copies of Integrated Design Lab reports, research and survey reports, evaluation reports,
and other reports related to DSM activities. Each of these evaluations reflects Idaho
Power's continued commitment to review and evaluate program value and cost
effectiveness on an ongoing basis.
III. 2024 DSM PROGRAM PERFORMANCE
12. In 2024, Idaho Power offered its customers a wide range of energy
efficiency and demand response programs, participated in market transformation efforts
through NEEA, and offered several educational initiatives and other activities. Table 1 on
page 4 of the DSM 2024 Annual Report contains a list of Idaho Power's DSM programs
by sector, operational type, and location. The table illustrates the broad suite of programs
that Idaho Power offers to its customers in energy efficiency and demand response.
13. As explained in more detail in the Nesbitt Testimony filed
contemporaneously with this Application, Idaho Power's annual energy savings combined
with NEEA estimated annual energy savings resulted in an incremental energy efficiency
savings of 16.4 aMW, which exceeded the economic technical achievable potential
APPLICATION - 6

included in Idaho Power's 2023 IRP of 12.2 aMW. Nesbitt Testimony at 9.
14. On a system-wide basis, Idaho Power achieved 143,599 MWh of
incremental annual energy efficiency savings in 2024, which includes 119,098 MWh from
Idaho Power's energy efficiency programs and an estimated 24,501 MWh9 of energy
efficiency market transformation savings through NEEA initiatives. Nesbitt Testimony at
7-8. The 2024 savings results consisted of 24,472 MWh from the residential sector,
90,336 MWh from the commercial/industrial sector, and 4,290 MWh from the irrigation
sector. DSM 2024 Annual Report at 6, Table 2.
15. In the 2024 program year, several of the Company's DSM programs
outperformed their savings and participation as compared to the 2023 program year.
Overall energy efficiency portfolio savings increased by 5,815 MWh. The increase in
savings can largely be attributed to the Commercial and Industrial ("C&I") New
Construction program option, which increased its total savings by 7,519 MWh. Nesbitt
Testimony at 9. Appendix 3 of the DSM 2024 Annual Report contains a complete list of
program and sector-level savings. Additionally, the Company engages in significant
educational awareness activities and marketing efforts that are likely to result in energy
savings experienced by customers but are not quantified or claimed as part of Idaho
Power's annual savings.
16. Idaho Power's energy efficiency portfolio remained cost-effective as more
fully explained below, resulting in a 1.72 benefit/cost ratio when evaluated from a UCT
perspective, a 1.64 benefit/cost ratio when evaluated from a TRC test perspective, and
9 Because Idaho Power will not receive final 2024 savings from NEEA until the second quarter 2025, the
NEEA-attributable savings is an estimate provided to Idaho Power by NEEA.
APPLICATION - 7

2.18 benefit/cost ratio when evaluated from a PCT perspective. Nesbitt Testimony at 6-
7.
17. In addition, Idaho Power successfully operated all three of its demand
response programs in 2024, and the demand response portfolio currently has a capacity
of more than 8.5 percent of its all-time system peak load available to respond to a system
peak load event during the summer. Idaho Power achieved a total non-coincident demand
reduction of 257 MW from a total available capacity of 323 MW during the 2024 program
season. Nesbitt Testimony at 10-11. The amount of capacity available for demand
response varies based on weather, time of year, and how programs are used or managed.
The maximum potential reduction capacity (323 MW) is based on an expected maximum
realization rate for participants. DSM 2024 Annual Report at 8.
IV. 2024 DSM EXPENSES AND ADJUSTMENTS
18. Energy efficiency and demand response funding comes from the Idaho and
Oregon Energy Efficiency Riders ("Rider") and Idaho Power base rates. The Rider funds
are collected directly from customers on their monthly bills; the 2024 Idaho Rider was
2.35 percent of base rate revenues pursuant to Order No. 36042. DSM expenses not
funded through the riders are included in Idaho Power's base rates. Idaho demand
response program incentives funded through base rates are tracked through the annual
PCA mechanism.
19. In 2024, the Company's total system-wide expenditures on DSM-related
activities totaled $40,166,589. DSM 2024 Annual Report at 9-10, Tables 3 and 4. This
figure includes expenditures for Oregon and other operations and maintenance ("O&M")
expenses that are not before the Commission as part of this prudence request. In this
filing, Idaho Power seeks a determination that a total of $34,873,291 were prudently
APPLICATION - 8

incurred in 2024 ($25,922,708 in Rider expenses and $8,950,583 in demand response
program incentives). Nesbitt Testimony at 12. A summary of the 2024 program
expenditures by program, customer sector, and funding source for which the Company is
seeking a prudence determination is provided as Exhibit No. 1 to the Nesbitt Testimony.
20. The Company strives to ensure DSM expenses are well-documented and
that controls are in place and adjusted as needed to regulate proper payment of incentives
and other costs. As more fully explained in the Nesbitt Testimony and summarized below,
prior to this filing, the Company's internal review process identified two prior-year and
three current-year accounting adjustments that were necessary to accurately account for
the total 2024 DSM expenses for purposes of the prudence determination in this case.
Nesbitt Testimony at 13-15. Idaho Power has included each of these adjustments in
Exhibit No. 1 to the Nesbitt Testimony.
21. Prior Year Adjustments. The first prior-year adjustment of $1,771 was
related to expenses associated with the Irrigation Peak Rewards program that should
have been charged to O&M, rather than the Idaho Rider in 2023. The correction to reduce
Idaho Rider expenses was made in 2024, and therefore $1,771 needs to be added back
to avoid understating the 2024 prudence request. The second prior-year adjustment of
$194 is associated with the Residential New Construction program where the expense
was initially charged to the Oregon Rider instead of the Idaho Rider in 2023. The
correction adding the expense to the Idaho Rider was made in 2024, and therefore $194
needs to be subtracted from the 2024 prudence request because it was already deemed
prudent by the Commission in the 2023 request. Nesbitt Testimony at 14.
22. Current Year Adjustments. Three current year-end accounting adjustments
APPLICATION - 9

for 2024 were identified through Idaho Power's year-end review of expenses and the
corrections were made after the 2024 year-end financial books were closed. The first
current-year adjustment results in an addition of$5,383 associated with the Home Energy
Audit program where the expenses were initially charged to O&M instead of the Idaho
Rider. The second adjustment results in an addition of$5,523 associated with the Rebate
Advantage program where the expenses were initially charged to O&M instead of the
Idaho Rider. The third adjustment results in a reduction of $2,278 associated with the
Irrigation Peak Rewards program where the expenses were initially charged to the Idaho
Rider instead of O&M. Nesbitt Testimony at 14-15.
V. DSM PROGRAM COST-EFFECTIVENESS
23. The DSM 2024 Annual Report and accompanying Nesbitt Testimony
demonstrate the Company's diligent efforts to ensure that DSM funds collected from
customers are utilized to support the pursuit of cost-effective energy efficiency and
demand response programs and substantiate that Idaho Power's DSM expenses were
prudently incurred. As reflected therein, Idaho Power reviews the cost-effectiveness
results for each program and measure on an annual basis to determine whether a
program should continue or be modified so it remains cost-effective on an ongoing basis.
Energy Efficiency Programs
24. To calculate cost-effectiveness, the DSM 2024 Annual Report uses
benefit/cost methodologies used in previous DSM annual reports, including the UCT, the
TRC test, and the PCT. A review of each test allows for an economic assessment of the
lifecycle costs and benefits of a DSM investment from the perspective of Idaho Power,
DSM program participants, and non-participating customers. Idaho Power calculates
APPLICATION - 10

cost-effectiveness from the UCT, TRC test, and PCT perspectives at the program level
except for those programs with no customer costs, in which case the PCT is not
applicable. When an existing program or measure is not cost-effective, Idaho Power
works with EEAG to obtain input before making its determination on continuing,
discontinuing, or modifying an offering. Nesbitt Testimony at 16-17. Cost-effective test
methodologies are described in more detail in Supplement 1 to the DSM 2024 Annual
Report.
25. While the Commission continues to assess the prudence of DSM
investments under "the totality of the circumstances," the Commission also believes that
public utilities may "emphasize the UCT—and that test's focus on Company-controlled
benefits and costs—to argue whether programs were cost-effective."'0 Nesbitt Testimony
at 17. Thus, the Company continues to conduct all three benefit/cost methodologies while
using the UCT perspective as its primary test for evaluating program cost-effectiveness.
26. Supplement 1 to the DSM 2024 Annual Report includes detailed results of
the cost-effectiveness tests by program and by measure, showing that the overall DSM
portfolio achieved benefit/cost ratios greater than 1.0 from the perspective of all three
cost-effectiveness tests in 2024. On a portfolio basis, Idaho Power's energy efficiency
programs were found to be cost-effective, passing the UCT, TRC test, and PCT with ratios
of 1.72, 1.64, and 2.18, respectively. Nesbitt Testimony at 18, Table 4 and Exhibit 2.
27. On an individual program basis, 9 of the 14 energy efficiency programs
offered in Idaho for which the Company calculates cost-effectiveness had benefit/cost
10 In the Matter of the Application of Idaho Power Company for a Determination of 2014 Demand-Side
Management Expenditures as Prudently Incurred, Case No. IPC-E-15-06, Order No. 33365, p. 9-10 (Aug.
28, 2015).
APPLICATION - 11

ratios greater than 1.0 under the UCT. Nesbitt Testimony at 20. The results of these
calculations, along with measure assumption details and source determination, can be
found in Supplement 1 to the DSM 2024 Annual Report. Idaho Power's cost-effectiveness
test results for 2024 energy efficiency programs determined that certain programs --
Weatherization Assistance for Qualified Customers ("WAQC"); Weatherization Solutions
for Eligible Customers ("Solutions"); Shade Tree Project; Heating & Cooling Efficiency
Program ("HC&F); and Small Business Lighting -- were not cost-effective under the UCT
in 2024 as more fully discussed below:
Income Qualified Weatherization
28. Two programs that scored less than 1.0 under the UCT were the Company's
WAQC and Solutions. While these programs are not cost-effective under the UCT, Idaho
Power will continue to offer these programs to its limited-income customers unless the
Commission directs otherwise. Nesbitt Testimony at 21-23. Idaho Power will also
continue to work with EEAG and weatherization managers to identify opportunities that
might improve the cost-effectiveness of these programs.
Shade Tree Project
29. In 2023 it was determined, based on the results of an impact evaluation,
that the Shade Tree Project was no longer expected to be cost-effective going forward.
Accordingly, and with the support of EEAG, the Company ultimately decided to end the
offering after the existing tree supply contract expired. The Company held its last event
in May 2024. The Company did not calculate cost-effectiveness results for the program
because the trees are not large enough to produce recognizable savings until the fifth
year after planting, Idaho Power has not claimed incremental savings associated with the
APPLICATION - 12

trees until that fifth year. Accordingly, 2024 would be the year to report incremental
savings for trees planted in 2020, however in 2020 there were no Shade Tree events held
due to COVID-19 limitations. While there are quantifiable savings accruing to the system
associated with trees planted during and before 2019, it has not been the Company's
practice to claim those incremental savings in future years beyond the fifth year.
H&CE
30. In 2024, the H&CE program achieved a UCT of 0.95 and a TRC of 0.39.
The objective of the H&CE program is to provide customers with energy-efficient options
for space heating/cooling and water heating, offering incentives for the purchase and
proper installation of qualified heating and cooling equipment and services. The main
driver of the H&CE program not being cost-effective in 2024 was lower than anticipated
program participation, which, in turn, resulted in lower program savings during the year.
31. Despite the lower participation and savings, the UCT ratio increased from
0.94 in 2023 to 0.95 in 2024, driven by a general increase in DSM avoided costs as well
as the modifications made to program incentives at the end of 2023.
32. The program reduced the smart thermostat incentive from $75 to $50 at the
end of 2023, noticeably contributing to the lower than anticipated participation. In 2024,
smart thermostats made up 32 percent of the total program participation and 8 percent of
total savings, which is a notable drop from 2023 when smart thermostats made up 45
percent of participation and 14 percent of savings.
33. In 2024, the program removed the offering for upgrading an existing air-
source heat pump. The upgrade offering was popular prior to its removal; in the 2023
program year it had 55 participants. However, the option was removed due to a change
APPLICATION - 13

in the eligibility requirements outlined in the Regional Technical Forum ("RTF") workbook
used to claim savings. Given its prior popularity, Idaho Power plans to assess possibilities
for this incentive to return, likely with different eligibility requirements.
34. Additionally, ductless heat pumps made up 23 percent of the program
participation and 22 percent of the total savings. While the savings assumptions did not
change year over year, the average savings per unit, which are dependent on location,
declined by approximately 8 percent.
35. While the lower savings benefits resulting from the lower-than-anticipated
participation were not enough to outweigh the program costs in 2024, Idaho Power does
expect the program cost-effectiveness to improve going forward. In November 2023,
Idaho Power modified the H&CE program based on the updated RTF savings and the
new DSM avoided costs from the most recently filed 2023 IRP. These changes improved
program cost-effectiveness in 2024, but Idaho Power will review additional modifications
and offerings to further improve the program in 2025. The program will be incurring
evaluation expenses in 2025 and still may not be cost effective for 2025 because of these
expenses.
Small Business Lighting
36. The Company launched the Small Business Lighting in September of 2024.
The program achieved a UCT of 0.25 and a TRC of 0.35. The program was not expected
to be cost-effective in program year 2024, due primarily to its launch being late in the
year, leaving it with only a short window to build awareness and produce savings. Moving
forward, Idaho Power expects the program to be cost-effective as it will be offered for the
entire year in 2025.
APPLICATION - 14

Demand Response
37. For 2024, Idaho Power determined the cost-effectiveness of its demand
response programs based on the methodology approved in Order No. 35336 and more
fully described in the Nesbitt Testimony at 28-29. In 2024, the system-wide cost of
operating the three demand response programs was approximately $9.7 million ($9.2
million of incentives and $0.5 million of other costs). The amounts attributable to the
Idaho-only jurisdiction were $9.4 million ($9 million of incentives and $0.4 million of other
costs). All three of the Company's demand response programs, as well as the demand
response portfolio, had a cost per kilowatt less than the 2024 threshold of $62.39 and
were therefore cost-effective. Nesbitt Testimony at 30-31.
VI. DSM PROGRAM EVALUATIONS
38. In addition to the annual cost-effectiveness analysis the Company conducts
for each program, the results of which are included in Supplement 1 to the DSM 2024
Annual Report and summarized above, Idaho Power solicits and contracts with
independent third-party consultants to provide program evaluations. The Company
generally conducts impact evaluations every three years, and process evaluations for
relatively new programs, or when a program has significant changes. Supplement 2 to
the DSM 2024 Annual Report provides additional information regarding how Idaho Power
evaluates its programs and the final reports for the evaluations conducted in 2024.
39. Idaho Power uses the results of these evaluations to improve its DSM
programs, compare Company processes to industry best practices, and benchmark
reported program savings. In 2024, Idaho Power contracted with several third-party
evaluators to conduct impact and process evaluations as follows:
• Impact evaluation on the Education Distributions program.
APPLICATION - 15

• Impact and process evaluations on the Rebate Advantage and C&I Custom
Projects programs.
40. In addition to these third-party evaluations, Idaho Power completed internal
analyses of the Irrigation Peak Rewards, C&I Flex Peak, and A/C Cool Credit demand
response programs. Nesbitt Testimony at 32.
41. The Company's request for a determination of 2023 DSM management
expenses as prudently incurred resulted in additional analysis of its energy efficiency and
demand response programs as directed by the Commission. To that end, the Company
continues to explore alternatives to validating the savings generated by its Home Energy
Reports program that would allow all customers to participate in the program and has
discussed some alternatives with its EEAG. The Company also intends to evaluate the
savings of self-installed and contractor-installed Smart Thermostats during the next
evaluation of the H&CE program as recommended by the Commission. In addition, the
Company has met with Staff to consider alternative cost-effectiveness calculations for its
demand response programs, and based on the outcome of these discussions, the
Company determined that the current method for valuing the maximum avoided cost
threshold was still appropriate. Finally, the Company has pursued a follow-up impact
evaluation of the RNC Program using billing data. However, because the RNC evaluation
results were not complete prior to the preparation of this case, Idaho Power anticipates
filing a supplemental application to submit the results to the Commission. At the time of
the supplemental application, Idaho Power will identify its near-term plan associated with
addressing any findings.
APPLICATION - 16

VII. STAKEHOLDER INPUT
42. Idaho Power relies on input from EEAG to provide a customer and public
interest review of energy efficiency and demand response programs and expenses.
EEAG provides input on enhancing existing DSM programs and on implementing new
DSM programs. Currently, EEAG consists of members representing a cross-section of
customers from the residential, industrial, commercial, and irrigation sectors, as well as
representatives for low-income individuals, environmental organizations, state agencies,
the Commission, and Idaho Power. Nesbitt Testimony at 34.
43. The EEAG generally meets quarterly and, when necessary, additional
meetings are held to address special topics. In 2024, the Company held four EEAG
meetings, two in person with a virtual option and two virtually. The Company believes that
member participation and input remained strong during the 2024 EEAG meetings.
Specifically, Idaho Power worked with EEAG on developing, designing, and promoting
several projects and solicited guidance on a broad range of issues including updates to
the C&I Flex Peak and Irrigation Peak Rewards programs, the new Small Business
Lighting offering, savings validation methods for Residential Home Energy Reports, and
a Bring Your Own Thermostat option being added to the A/C Cool Credit Program. Nesbitt
Testimony at 35-37.
VIII. MODIFIED PROCEDURE
44. Idaho Power believes that a technical hearing is not necessary to consider
the issues presented herein and respectfully requests that this Application be processed
under Modified Procedure, i.e., by written submissions rather than by hearing. RP 201,
et. seq. Idaho Power has, however, contemporaneously filed the Nesbitt Testimony in
APPLICATION - 17

support of this Application. The Company stands ready to present testimony supporting
this Application in a technical hearing if the Commission determines such a hearing is
required.
IX. COMMUNICATIONS AND SERVICE OF PLEADINGS
45. Communications and service of pleadings with reference to this Application
should be sent to the following:
Megan Goicoechea Allen Connie Aschenbrenner
Regulatory Dockets Mary Alice Taylor
Idaho Power Company Idaho Power Company
1221 West Idaho Street (83702) 1221 West Idaho Street (83702)
P.O. Box 70 P.O. Box 70
Boise, Idaho 83707 Boise, Idaho 83707
mgoicoecheaallenCcDidahopower.com caschenbrennerCcDidahopower.com
dockets(c)_idahopower.com mtaylor(c)_idahopower.com
X. CONCLUSION
46. As described in greater detail above, in 2024, the Company believes that it
successfully achieved prudent cost-effective energy efficiency savings and provided
useful and cost-effective demand response programs as determined by the IRP planning
process. As such, Idaho Power respectfully requests that the Commission issue an order:
(1) authorizing that this matter be processed by Modified Procedure and (2) designating
Idaho Power's 2024 DSM expenses of $34,873,291 as prudently incurred.
Respectfully submitted this 14th day of March 2025.
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MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
APPLICATION - 18