Attch40_IPCE0113_Comments_LAWFund.pdf

COMMENTS -- 1
William M. Eddie (ISB# 5800)
Laird J. Lucas (ISB# 4733)
LAND AND WATER FUND OF THE ROCKIES
P.O. Box 1612
Boise, ID 83701
[phone]
fax: [phone]
[e-mail]
Express Mail:
1320 W. Franklin St.
Boise, ID 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION )
OF INCREASED DEMAND-SIDE MANAGEMENT )
PROGRAMS AND THE FUNDING OF THOSE )CASE NO. IPC-E-01-13
PROGRAMS FOR IDAHO POWER COMPANY )
________________________________________________)
COMMENTS OF IRU, IRC, NWEC, AND MARY MCGOWN
Idaho Rivers United, Idaho Rural Council, Northwest Energy Coalition, and Mary
McGown (“Intervenors”) strongly support the re-establishment of demand-side management
(DSM) programs for Idaho Power. Given the unstable electricity marketplace and Idaho Power's
projected need for additional resources, implementation of effective DSM through increased
energy efficiency will provide critically needed system reliability, as well as protection to
consumers against increases in electricity rates. Now more than ever, effective DSM is strongly
in the public interest.
Intervenors believe it is critically important that a DSM program be approved as soon as
possible, and at least prior to winter 2001-02, in order to address the concerns raised by the
Commission in Order No. 28722 with respect to residential customers using electric space
heating. The programs approved should strongly emphasize increased energy efficiency, rather
COMMENTS -- 2
than curtailment, to provide long-term benefits to ratepayers. We request initial approval of such
a program as proposed by Idaho Power, with the modifications and monitoring tools suggested
herein. However, Intervenors have serious concerns with several aspects of the Company’s
proposed DSM program, including the following:
 Planning, monitoring and verification: Intervenors request that the Commission
direct the Company to initiate an independent study evaluating all cost-effective DSM
opportunities in Idaho Power’s service territory. This study, as well as a detailed DSM Plan,
would be submitted to the Commission 90 days after approval of the initial program, at which
time the Commission and the public could review the overall DSM package as necessary to
ensure reasonable and prudent delivery of DSM services.
 Funding : A funding level of 0.5% of revenues is below the level of DSM investment
now undertaken by other regional utilities, and is insufficient to ensure implementation of all
cost-effective DSM opportunities. Intervenors request the tariff rider funding level be increased
to 1.5% of revenues initially, with a planned ramp-up to 3% of revenues over a three year period,
and that the rider continue in effect indefinitely.
 Public process: We request the Commission order Idaho Power to conduct
deliberative polling, or similar procedures to elicit informed public opinion for development of
the Company’s next Integrated Resource Plan, on issues such as rates, energy supply, energy
efficiency and renewables.
 Incentives for DSM: Intervenors request that the Commission initiate proceedings to
evaluate the establishment of incentives for DSM, including through performance-based
incentives, or through a de-coupling mechanism.
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I.INCREASED DSM IS STRONGLY IN THE PUBLIC INTEREST
Improved energy efficiency is vital to a rational, balanced energy policy. Better use of
energy – not simply curtailment -- provides great economic benefits for ratepayers. The
American Council for an Energy Efficient Economy (ACEEE) notes that without the tremendous
gains in energy efficiency gains since 1973, Americans “would have spent at least $430 billion
more on energy purchases in 2000.” Testimony of Patrick Quinlan, ACEEE at Department of
Energy Public Hearings, Washington DC, June 26, 2001.
The Idaho Statesman recently reported that Idahoans have the highest per capita energy
use of any state in the nation. The PUC also recently approved Idaho Power’s largest rate
increase in its history, in large part to cover the Company’s purchases of power on the wholesale
market. Giving ratepayers the tools to use energy more efficiently will lessen the burden of such
rate increases and help forestall the need for future rate increases. Idaho Power’s proposed DSM
programs, outlined in Appendix 3 to its Compliance Filing, indicate an estimated levelized total
resource cost of between 2 and 4¢ per kWh – well below recent rates on the wholesale electricity
market, and below current production costs for most generation facilities.
Greater energy efficiency fosters a more reliable power system. Reducing demand on the
system leaves it less vulnerable to supply shortages and price spikes and helps relieve capacity
constraints on the transmission and distribution system. When utilities have difficulty meeting
demand, it is a signal that our energy policy is out of balance. The response to this situation
must include an increased focus on DSM. DSM efforts in already-efficient California have been
responsible for massive energy savings, which have helped prevent rolling blackouts in that state
this year. By June 2001, reductions had reached almost 4,800 megawatts, a drop of more
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than 12 percent in peak electricity use from June 2000.
Improved efficiency reduces the total costs of energy services to residences, business, and
institutions, and provides a growing benefit to the economy over time. Future electric energy
and capacity costs can be avoided through demand-side measures, and the value of these avoided
cost savings is likely to be far greater than the total costs of implementing a well-designed DSM
portfolio. Targeted DSM measures can also reduce the need for expensive transmission
infrastructure upgrades. Moreover, reduced energy consumption by individuals and businesses
reduces energy bills and creates further economic benefits in addition to reduced costs to the
utility.
In Utah, an energy efficiency advisory committee created by the Utah Public Service
Commission sponsored a study to identify cost-effective DSM opportunities in that state. See
Attachment 1, (Nichols, D. and Von Hippel, D., An Economic Analysis of Achievable New
Demand-Side Management Opportunities in Utah, March 2001). The study identified a suite of
DSM opportunities that are estimated to result in 680 MW of peak demand savings by 2006.
The package of DSM is estimated to have a total resource cost of $370 million and result in
capacity and energy resource savings of $1.44 billion for a net benefit of $1.08 billion (year 2000
dollars) and a benefit-to-cost ratio of 3.9 to 1.
Greater energy efficiency and load management will flatten demand peaks. Attachment 2
(ACEEE, Electric System Reliability and the Critical Role of Energy Efficiency). This will
reduce the need for costly wholesale power purchases by utilities. It may also allow Idaho
Power to operate its system more efficiently by operating at a higher load factor.
Reduced demand peaks will also decrease impacts of Idaho’s hydropower system on
recreation, water quality, and threatened and endangered fish. Peaking operations are among the
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most environmentally damaging aspects of hydropower operations due to extreme fluctuations in
river flows.
Energy production from hydropower dams is largely responsible for the decline of Snake
River salmon and steelhead. Energy production from fossil fuels is a major cause of air pollution
and global warming, and has significant impacts on land and water resources. Improved energy
efficiency and load management is truly a win-win scenario for ratepayers who enjoy both
environmental and economic benefits.
II. COMMENTS ON IPC’S PROPOSED DSM PROGRAM, AND PROPOSED
MODIFICATIONS
Planning, Monitoring, and Verification
Careful analysis for DSM planning, as well as monitoring and verification of DSM
expenditures and programs, are of critical importance to ensure that customer dollars are
prudently spent. Intervenors believe DSM program goals can best be defined in terms of actual
energy savings, expressed in reduced total consumption and reduced peak demand attributable to
DSM efforts. Unfortunately, we lack information that might inform a reasonable system-wide
demand-savings goal for the first year of a program. Initiation of the comprehensive study
requested herein would allow for the creation of achievable system-wide DSM goals into the
future. Until system-wide goals can be determined, program-by-program performance targets
would help in evaluating Idaho Power’s DSM efforts.
While approving an initial DSM program, the Commission should direct Idaho Power to
promptly fund and initiate an independent study identifying cost-effective DSM opportunities in
its service territory. Intervenors have attached a sample of the type independent study we believe
would be of great value in Idaho Power’s service territory. See Attachment 1 (discussed supra).
An assessment of end uses and markets in all rate classes to establish which technologies and
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practices are suitable for the Idaho market, and therefore should be promoted through new
programs, would provide needed technical and economic grounding to any comprehensive DSM
program.
The total resource cost perspective is the best approach to use in evaluating the cost-
effectiveness of DSM programs, since it compares the total incremental costs of the program
(including private costs incurred by customers, such as their share of efficiency technologies net
of any rebates) with their total resource benefits in terms of avoided costs of electricity
generation, transmission, and distribution. Avoided costs also provide an important benchmark in
determining what level of financial incentives to participating customers are warranted in view
of the level of resource savings. Other benefits of DSM, including reduced impacts to the
environment and direct economic benefits to customers who reduce energy consumption, are
more difficult to quantify, yet are important to recognize.1
The Commission should also direct Idaho Power to file, within 90 days of initial program
approval, a DSM Plan detailing technical measures to be promoted, program design features,
implementation schedules and budgets, target participation levels over time, and estimated
impacts on electricity use. Also included would be plans for monitoring program progress, as
well as plans for independent evaluations of the impacts and cost-effectiveness of each program

1 The Pacific Northwest Electric Power Planning and Conservation Act defines
the term “cost-effective” in a way that captures some of these aspects. A “cost-effective”
measure or resource “must be forecast – (i) to be reliable and available within the time it
is needed, and (ii) to meet or reduce the electric power demand . . . at an estimated
incremental system cost no greater than that of the least-cost similarly reliable and
available alternative measure or resource, or any combination thereof.” The Act defines
“system cost” as “an estimate of all direct costs of a measure or resource over its effective
life, including, if applicable, the cost of distribution and transmission to the customer and
. . . waste disposal costs, end-of-cycle costs, and fuel costs (including projected
increases), and such quantifiable environmental costs and benefits as the Administrator
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as participation levels grow. The DSM Plan would include provisions for regular reporting on
this activity and results. Naturally, data and information developed for the requested
independent study would be useful in developing the DSM Plan, and vice versa.
Intervenors support the concept of using an Energy Advisory Group to assist in ongoing
DSM planning and implementation. The group should be composed of a cross-section of the
community. Members should be drawn from the following constituencies: (1) one member
from each rate class; (2) Commission staff; (3) Company staff; (4) a member appointed by the
Community Action Agencies; and (5) a member appointed by the Northwest Energy Coalition.
Funding
Intervenors support the basic structure of using a tariff rider to provide a steady funding
source for DSM programs. However, we believe a funding level of 0.5% of revenues is
insufficient. Intervenors request that the PUC increase the funding to a level commensurate with
DSM investment by most other investor-owned utilities in the Northwest. Specifically,
Intervenors recommend that the Commission approve a DSM tariff rider of 1.5% of revenues
initially, ramping up to 3% of revenues within three years of program implementation, and that
the tariff rider continue in effect indefinitely. Intervenors believe this level of funding will help
ensure that all cost-effective DSM opportunities in Idaho Power’s service territory are fully
explored.
DSM investment by other investor-owned utilities in the Northwest is generally far
higher than proposed by Idaho Power, and certainly higher than found in the 1999 study cited by
the Company. Compliance Filing at 7. The Commission recently approved Avista’s request to
increase DSM investment from 1% to 1.95% of revenues. Order No. 28750. This amount

determines . . . are directly attributable to such measure or resource.” 16 U.S.C. § 839a
COMMENTS -- 8
includes Avista’s contributions to the Northwest Energy Efficiency Alliance. Although Idaho
Power cites Avista as “one of the leaders in energy efficiency spending,” in fact Avista’s DSM
investment level is comparable to or below most other investor-owned utilities in the Northwest.
In Oregon, all investor-owned utilities except Idaho Power will be subject to a 3% charge
for public purpose programs starting March 1, 2002, once that state’s restructuring law takes
effect. ORS § 757.612(3). Monies collected will be used for various programs: 1.7% of
revenues will be used for DSM programs, and about 0.5% for renewable energy development. A
significant portion of the remaining approximate 0.8% of revenues will also be spent on DSM
and related activities for low-income weatherization, schools, housing, and other programs. Id.
Montana now utilizes a program similar to Oregon’s forthcoming system: each utility
pays 2.4% of their 1995 revenues for a universal system benefit charge (USBC), and that money
is used to pay for different programs approved by the Montana Public Service Commission
(Montana PSC). For example, Montana Power’s total obligation at this level is almost $8.6
million per year, based on 1995 revenues of approximately $356 million. Montana PSC, Order
5986g (1999). The Montana PSC allocated these USBC funds as follows: $5.4 million for
conservation programs, with a good portion of remaining funds also used for low-income
weatherization services. Id. at 33.
The Utah Public Service Commission approved four new PacifiCorp DSM programs in
June 2001, with projected DSM budgets equal to roughly 1.5% of Utah Power’s annual
revenues. See Attachment 3 (Testimony of Brian Hedman, Utah Power, Transcript of
Proceedings, Utah PSC Docket No. 01-035-01, Salt Lake City, August 1, 2001, page 624). In
addition, discussions are underway among PacifiCorp and stakeholders for rolling out additional

(4).
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programs. The Utah PSC is still evaluating the exact funding mechanism to support these
approved programs. In its Washington State service area, PacifiCorp’s tariff rider is set to
collect an amount that is equivalent to 1.5% of annual revenues. Id. at 623.
In short, other investor-owned utilities in the region are, or soon will be, funding DSM
programs at far higher levels than proposed by Idaho Power. It is prudent to increase the funding
level for Idaho Power’s DSM programs to 1.5% of revenues separate from NEEA and low-
income assistance funding. Adding these other programs, Idaho Power’s initial DSM investment
level would approximately match Avista’s.
Ultimately, the question of how much DSM investment is just and reasonable in Idaho
Power’s service territory will be answered through a comprehensive independent study on cost-
effective DSM opportunities and development of a DSM Plan, as requested herein. Intervenors
believe that scarce DSM program funding should be spent on programs that provide cost-
effective energy savings, and that far more cost-effective DSM opportunities exist in Idaho than
could be funded with the initial 1.5% of revenues tariff rider level requested herein. Intervenors
seek this initial funding to ensure adequate resources are available to begin developing the
business infrastructure necessary to implement all cost-effective DSM opportunities over time.
Pending completion of the requested study and DSM Plan, Intervenors believe the most
prudent course is for the Commission to approve a DSM tariff rider at 1.5% of revenues, with a
planned ramp-up to 3% of revenues, to be effective indefinitely.
Public Opinion
In claiming to be conflicted over “how to provide a meaningful level of conservation
programming while avoiding rate impact concerns,” Idaho Power relies on a June 2001 survey,
which partly found that “over half of customers interviewed indicated they would not be willing
COMMENTS -- 10
to pay a slightly higher rate to fund energy efficiency programs.” Compliance Filing at 7.2
Intervenors believe this survey asked the wrong questions and may not accurately indicate
informed customer opinion.
First, Idaho Power appears to have asked a premature question in its attempt to elicit
customer opinion on DSM spending. Before being able to respond to the blunt question of
whether they would pay more for efficiency programs, customers need to understand the relative
costs of alternatives to meeting demand – i.e. what are the varying costs of providing different
combinations of new rate-based generation facilities, market purchases of electricity, and DSM
programs. Further, it is unclear whether surveyed customers were informed of the environmental
and overall system benefits of effective DSM programs.3
The Company does not state how its survey was performed, however results from
deliberative polling4 undertaken by Texas utilities indicate that customer willingness to spend
money on energy efficiency and renewables significantly increases after the customers are more
thoroughly informed on these subjects. For example, a representative study group in Houston
2 Idaho Power’s survey immediately followed the PUC’s approval of a large rate increase
for all classes. Customers were just beginning to feel the sting of this rate increase, and thus
naturally might have a negative reaction to further rate increases.
3 Since DSM involves up-front investments to capture streams of savings which
grow over time, there often is some upward pressure on rates during a period of program
ramp-up. However, the mid- to long-term rate impact of DSM depends critically upon
the rate at which avoided electric supply costs are increasing. Since the electricity
industry is now experiencing upward cost pressures, there may be a net benefit to rates
from DSM, as well as benefits to system reliability, the environment, and economic
interests of rate payers who save money through reductions in energy use. Use of a rate
impact measure test, while not a primary measure of cost-effectiveness, could assist the
Company in resolving customer concerns over rate impacts.
4 Deliberative polling is a method of obtaining informed public opinion on any
issue. Representative samples of a population learn more about the selected topic
through discussions among themselves, and with the help of experts in the field. As
indicated by the results from Texas, significant before-and-after differences in opinion
are sometimes found.
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was initially reluctant to pay for efficiency and renewables programs. However, after a weekend
seminar with a neutral panel of experts, the group was willing to add an average $6.50 to their
monthly bill to support renewable energy, and another $3 for efficiency programs. See
Attachment 4 (Environmental Defense, February 4, 1998). Results of this deliberative polling
effort are being analyzed for a National Renewable Energy Laboratory report, which should be
available in coming months.
Likewise, in 1999 BPA reviewed public opinion surveys from the Northwest and across
the nation, and concluded that “a strong majority of consumers supports utility investments in
conservation and renewable resources” and that “consumers say they would be willing to pay
more to ensure that their utilities invest in those ‘green’ resources.” Attachment 5 (Abstract of
BPA, Renewable Resources and Conservation: What Consumers Want, 1999).
Intervenors strongly support public participation and integration of public opinion into
energy policy decisionmaking, however it appears that Idaho Power’s survey was not a scientific
approach to eliciting informed public opinion on DSM investment. We request that the
Commission order Idaho Power to conduct deliberative polling or other procedures to elicit
informed public opinion and input on issues of rates, energy supply, conservation, and renewable
energy as part of the Company’s next Integrated Resource Plan development. This effort should
not be funded through any DSM tariff rider as may be approved by the Commission, but rather
included in the cost of IRP development. Because the type of questions asked can cause wild
variations in polling results, Intervenors believe it is critically important that any polling efforts
be conducted by an independent third party with oversight from the Energy Advisory Group.
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Comments on Idaho Power’s Proposed Programs
Intervenors largely support the proposed potential programs suggested by Idaho Power.
We believe selected programs should strike a balance strongly favoring market transformation
(i.e. long-lasting energy efficiency improvements), but should also provide for load management
resource acquisition (such as interruptible industrial power supply or remote control air
conditioner shut-off programs) in order to better control peak demand.5 On initial approval of a
DSM program, Idaho Power should primarily address the Commissions concerns with respect to
customers using electric space heating, and follow with programs for all rate classes prioritized
on cost-effectiveness and ease of implementation. In the long-term, a balanced approach
focusing on installation of persisting efficiency technologies is preferable.6
The Company’s Compliance Filing includes an initial assessment of what demand-side
measures may provide cost-effective electricity savings. From the outline of potential
conservation measures contained in Appendix 3 of the Filing, it appears that only preliminary
work has been done on the program designs to market and deliver DSM. Appendix 3 conflates
the various technical elements of an overall DSM strategy – what the key efficiency technologies
are, their likely incremental costs and electricity savings, and the program design elements (i.e.,
what marketing and incentive approach to apply to increase market penetration of the given
conservation measure).
5 About 30-35% of the typical utility's transmission, distribution and generation
investment is necessitated by peak loads, which cover less than 5% of the hours of the
year. Thus, peak load management programs can be extremely cost-effective. Managing
peak loads also provides strong environmental and recreational benefits from reduced
need for load-following at hydropower dams.
6 Intervenors also support steadily increasing funding for the Community Action
Agencies in their work with low income customers.
COMMENTS -- 13
Idaho Power includes an outline of a strategy to reduce winter peak demand associated
with residential electric space heating. The Company assumes that improvement of the thermal
performance of electrically heated housing (to obtain a roughly estimated 5000 kWh savings per
house) would be realized by reduced interest rate financing at 6.9%. There is no analysis
showing that this inducement will suffice to obtain the savings estimated. Stronger inducements
are possible: loans at lower interest rates, grants, and rebate programs. Given the Commission’s
direction to reduce winter heating load, it would appear that a stronger program design should be
considered for this end-use.
The Company’s estimated energy savings and costs for other programs likewise appear to
need further review. The estimate of savings from higher-efficiency central air conditioning
(“CAC”) systems is quite low at only 400 kWh per year, while the estimated incremental
installed cost of a higher-efficiency CAC is extremely low at less than $200 each. In the area of
residential compact fluorescent lamps (“CFLs”), the economic savings calculations appear to
omit the avoided purchase cost of the several incandescent lamps that are needed during the long
lifetime of just one CFL. These are minor points at this stage of planning, however the
incremental cost and savings estimates for the residential measures must be viewed as just that --
estimates. The commercial and industrial measures are sketched even more roughly, and likely
these must be viewed as mere placeholder proxies for actual technologies and measures.
Idaho Power suggests that “industrial efficiency measures will be structured for
maximum customer flexibility and participation where customers may propose and manage all
efficiency efforts.” Compliance Filing at 5. Such flexibility is a desirable feature that
contributes to higher participation and electricity savings. Intervenors believe the industrial
COMMENTS -- 14
customers have the potential to achieve significant energy savings, and that such savings can
only be realized through custom design and installation projects.
However, it is not clear what criteria the Company would apply in the custom
components of its commercial/industrial DSM offerings. The Company needs to specify what
cost-effectiveness yardstick would be applied, as well as how any rebate incentive would be
calculated in light of avoided costs, equipment lifetime, and the customer’s own internal payback
from the efficiency investment. These elements are alluded to in Appendix 7 of the Filing, but
not spelled out. Further, monitoring and verification of DSM efforts at the industrial are
critically important. Additionally, consideration should be given to implementing programs for
industrial customers through performance-based contracting. Attachment 6 (Schiller et al.,
Public Benefit Charge Funded Performance Contracting Programs – Survey and Guidelines,
Lawrenence Berkeley Laboratory, August 2000 (Abstract and Introduction only)).
Public education and marketing must be a strong component of any DSM program, but
these strategies are not spelled-out in the Company’s filing. Tremendous DSM potential could
be wasted if customers do not understand the available options. The first year of implementation
should involve significantly higher levels of education and marketing spending than is expected
for subsequent years.
In summary, the Company has provided the Commission with a preliminary discussion of
some major types of DSM measures and programs. Intervenors believe the proposed DSM
measures could be effective in reducing demand, however more information is needed to
determine the most cost-effective strategy for implementing DSM in Idaho through the long-
term, and more planning is needed over the next several months to develop a well-grounded
DSM package.
COMMENTS -- 15
Incentives for DSM
Intervenors seek a regulatory framework that supports sustained utility investment in
cost-effective DSM, including appropriate incentives for Idaho Power to obtain meaningful
demand reductions, while also providing protections for ratepayers in the event the Company’s
DSM performance does not meet expectations. However, we recognize that the current energy
market may itself provide substantial incentives for the Company to obtain meaningful demand
savings from DSM, as conserved energy potentially could be sold on the wholesale market at
high value.
Under Idaho Power’s current rate design, the utility operates under the basic business
incentive to maximize sales. However, the Company continues to be a regulated monopoly, and
therefore should be awarded based on the quality and affordability of electric service provided to
its captive customers. Numerous western utilities, including PacifiCorp and Puget Sound
Electric (PSE) in Oregon, as well as Pacific Gas & Electric and Southern California Edison, have
proposed de-coupling mechanisms to break the link between commodity sales and revenues. In
Washington, PSE in the early and mid-1990’s operated under de-coupling mechanism, which
was at least partly responsible for a very successful and cost-effective DSM program. Portland
General Electric now operates under an Energy Efficiency Adjustment, which includes a lost
revenue recovery mechanism. 7
7 Designation of a third party non-profit or governmental DSM manager, funded through
system benefits charges, would be another means of ensuring that utilities’ basic incentives to
maximize sales do not influence their DSM efforts. Through legislative and PUC action, the
Energy Trust of Oregon has been established to manage conservation and renewable resources
funds pursuant to SB 1149/ORS 757.612(3). This system shifts the burdens of DSM
management from the utility to the third-party, naturally eliminating the utility’s disincentives
for DSM. Further, the third party may be able to leverage DSM funding through foundation or
government grants. Intervenors raise this issue as a possible long-term solution to state-wide
DSM management in Idaho.
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If the full economic, social, and environmental benefits of DSM are to accrue, the
Commission should seek ways to encourage utilities to not only invest in DSM, but also to
obtain results from DSM implementation. Financial awards based upon performance, de-
coupling, or other incentive mechanisms could be incorporated into the existing annual power
cost adjustment proceedings. For the long-term stability and success of DSM programs in Idaho
Power’s service territory, other incentives may be warranted.
Intervenors request the Commission initiate proceedings to evaluate establishment of a
de-coupling system or other DSM incentives for Idaho Power. See generally Attachment 7
(Nichols, D., Regulatory Incentives for Demand-Side Management, Review for West Kootenay
Power’s DSM Incentive Committee, Tellus Institute, 1999) (attachments excluded).
CONCLUSION
Intervenors request immediate approval of a DSM program subject to the funding,
monitoring, and accountability provisions outlined herein. Intervenors request that Idaho Power
be ordered to file an independent study evaluating cost-effective DSM opportunities in its service
territory, as well as a detailed DSM Plan, 90 days from approval of the initial program.
Intervenors request approval of a DSM tariff rider funded at a level 1.5% of revenues, with a
planned ramp-up to 3% of revenues over a three year period. Intervenors request that the
Commission order Idaho Power to conduct deliberative polling or other means of eliciting
informed public opinion on issues of rates, energy supply, conservation, and renewable energy as
part of the Company’s next Integrated Resource Planning process. Finally, Intervenors request
that the Commission initiate proceedings to evaluate implementation of a DSM incentives
mechanism.
COMMENTS -- 17
Dated: September 3, 2001 Respectfully submitted,
______________________________
William M. Eddie
Land and Water Fund of the Rockies
On behalf of:
Idaho Rivers United
Idaho Rural Council
Northwest Energy Coalition
Mary McGown
COMMENTS -- 18
CERTIFICATE OF SERVICE
I hereby certify that on this __th day September 2001, true and correct copies of the
foregoing COMMENTS were delivered to the following persons via the method of service
noted:
Via Hand-Delivery:
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Lisa Nordstrom
Deputy Attorney General
427 W. Washington St.
Boise, ID 83702-5983
Via U.S. Mail:
Larry D. Ripley
Betsy Galtney
Idaho Power Company
P.O. Box 70
Boise, ID 83707-0070
_____________________________
Lola Eijckelhof