clarification.pdf

Telephone [phone], FAX [phone]
LARRY D. RIPLEY
Senior Attorney

June 7, 2002

Ms. Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074

Re: Idaho Power Company’s Petition For Clarification Of Order No. 29026
Relating To Carrying Costs For Dsm Programs
Case Nos.: IPC-E-02-02 and IPC-E-02-03

Dear Ms. Jewell:

Enclosed herewith for filing with the Commission are an original and seven (7)
copies of Idaho Power Company’s Petition For Clarification Of Order No. 29026 Relating To
Carrying Costs For DSM Programs.

I would appreciate it if you would return a stamped copy of this transmittal letter
for our file.

Very truly yours,

/s/

Larry D. Ripley

LDR:dkd
Enclosure

IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION OF ORDER
NO. 29026 RELATING TO CARRYING COSTS FOR DSM PROGRAMS, Page 1
LARRY D. RIPLEY ISB #965
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]

Attorney for Idaho Power Company

Street Address for Express Mail:

1221 West Idaho Street
Boise, Idaho 83702

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR AN ) CASE NO. IPC-E-02-02
ENERGY COST FINANCING ORDER AND ) IPC-E-02-03
AUTHORITY TO INSTITUTE AN ENERGY )
COST BOND CHARGE. )
) IDAHO POWER COMPANY’S
) PETITION FOR CLARIFICATION
IN THE MATTER OF THE APPLICATION ) OF ORDER NO. 29026
OF IDAHO POWER COMPANY FOR ) RELATING TO CARRYING
AUTHORITY TO IMPLEMENT A POWER ) COSTS FOR DSM PROGRAMS
COST ADJUSTMENT (PCA) RATE FOR )
ELECTRIC SERVICE FROM MAY 16, 2002 )
THROUGH MAY 15, 2003. )
)

Idaho Power Company (“Idaho Power” or “the Company”) herewith
petitions for clarification of Order No. 29026 pursuant to RP 325 for the following
reasons:
Under service date of May 13, 2002, the Commission in this proceeding
issued Order No. 29026. In that Order the Commission provided for the funding of
Demand Side Management programs. The Commission has projected that the

IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION OF ORDER
NO. 29026 RELATING TO CARRYING COSTS FOR DSM PROGRAMS, Page 2
Company would generate approximately $2.6 million annually for the funding of DSM
programs. In preparation for meetings with the Energy Efficiency Advisory Group and
reviewing potential DSM programs, the Company requests further clarification of the
Commission’s Order relating to the funding of DSM programs.
Because there will necessarily be a mismatch in the timing of the receipt
of DSM funds and the expenditures on DSM programs, the Company believes that the
application of a carrying charge to the DSM fund balance (either positive or negative) is
appropriate.
Accordingly, the Company requests clarification that the Commission
intended, that to the extent DSM programs are funded by Idaho Power in advance of
funds being generated through the tariff rider, that the Company would be entitled to
recover interest as to this early funding. Conversely, if the Company obtains funds
which are not expended for any DSM program, it would pay interest. The Company
would recommend that the carrying charge be at an interest rate of six percent (6%).
The Commission in Order No. 29026, when discussing DSM programs
stated at Page 21 the following:
“The Commission is particularly concerned about DSM programs
for the Residential Class. As discussed in further detail below, the return
to a uniform residential rate will eliminate the less costly rate designed to
provide a reasonable rate for basic electrical service necessary for
customer health and safety….****….. We see the merit of the three efforts
(Energy Code Support, Public School Energy Efficiency and Residential
New Construction Pilot) cited by Idaho Power in its May 2, 2002 DSM

IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION OF ORDER
NO. 29026 RELATING TO CARRYING COSTS FOR DSM PROGRAMS, Page 3
report as beneficial programs that could be quickly developed and
deployed. However, we believe residential DSM dollars are better spent
on CFL coupon programs and pilot programs that can be expanded to the
entire customer base rather than education alone. We also direct the
Advisory Group and Idaho Power to investigate the implementation of a
cost-effective, compact fluorescent light bulb (CFL) program that utilizes
coupons toward their purchase or direct distribution by the Company….***
Although we appreciate the initiative shown by the ICIP’s request to
allow the industrial class to self-direct its DSM funds, the Commission
finds it more appropriate to retain oversight of the expenditure of funds
collected by this tariff rider. We encourage representatives of the
industrial class to participate in the Energy Efficiency Advisory Group to
ensure the DSM dollars collected by this tariff rider will also benefit their
class.”
* * * *
The Commission in its Ordering paragraphs then provided:
“IT IS FURTHER ORDERED that Idaho Power consult the Energy
Efficiency Advisory Group regarding the need to initiate a comprehensive
DSM study of the IPC service territory relative to the priority for DSM funds
to identify: (1) cost-effective DSM opportunities in each customer class;
(2) estimated costs to fully fund those opportunities; and (3) opportunities
for reductions in peak loads as well as reductions in total energy
consumption.”

IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION OF ORDER
NO. 29026 RELATING TO CARRYING COSTS FOR DSM PROGRAMS, Page 4
Individuals within Idaho Power have interpreted the above comments and Order by the
Commission differently. Recognizing that the funds available from the DSM rider are
limited, the Company is unsure whether it should devote the funds derived from the
DSM rider essentially to residential programs in the first year, or whether the Company
should attempt to devise programs for each customer class, based upon the amount of
funds derived from each customer class. It is the Company’s intention to recommend to
the Energy Efficiency Advisory Group that the DSM expenditure for the first year be
focused primarily on the residential class. Again, however, the Commission’s Order can
be interpreted that the Commission desired the institution of cost effective DSM
programs concurrently for all customer classes. With funding, of course, being limited,
the Company’s DSM efforts for any particular class would be diluted to the extent
funding is diverted to the other classes of customers. Accordingly, the Company looks
for additional guidance from the Commission as to what the Commission desires, in so
far as the institution of initial programs are concerned. To the extent possible, the
Company would request an Order by the Commission as soon as possible so that the
Commission’s Order On Clarification would be available for the July meeting of the
Energy Efficiency Advisory Group.
The Company requests, pursuant to RP 325, the Commission clarify that
the Commission desired the early implementation of DSM programs and that the
Company is entitled to recover its pre-funding of these programs with a carrying charge
in the amount of six percent (6%). Conversely, if the Company obtains funds which are
not expended for any DSM program, it would pay interest. The Company would
recommend that the carrying charge be at an interest rate of six percent (6%).

IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION OF ORDER
NO. 29026 RELATING TO CARRYING COSTS FOR DSM PROGRAMS, Page 5
Further, the Company requests clarification from the Commission as to
how the institution of essential DSM programs should be accomplished, i.e. should the
Company focus on the residential class in the first year, or should it create a program
for each class where it can be demonstrated that the DSM program proposed is cost
effective.
Respectfully submitted this 7th day of June, 2002.

/s/

LARRY D. RIPLEY
Attorney for Idaho Power Company

CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 7th day of June, 2002, I served a true and
correct copy of the above and foregoing IDAHO POWER COMPANY’S PETITION FOR
CLARIFICATION OF ORDER NO. 29026 RELATING TO CARRYING COSTS FOR
DSM PROGRAMS upon the following named parties by the method indicated below,
and addressed to the following:

Lisa D. Nordstrom x Hand Delivered
Deputy Attorney General U.S. Mail
Idaho Public Utilities Commission Overnight Mail
472 W. Washington Street FAX
P.O. Box 83720
Boise, Idaho 83720-0074

John Hammond x Hand Delivered
Deputy Attorney General U.S. Mail
Idaho Public Utilities Commission Overnight Mail
472 W. Washington Street FAX
P.O. Box 83720
Boise, Idaho 83720-0074

R. Scott Pasley Hand Delivered
Assistant General Counsel x U.S. Mail
J.R. Simplot Company Overnight Mail
P.O. Box 27 FAX
Boise, Idaho 83707

David Hawk Hand Delivered
Director, Energy Natural Resources x U.S. Mail
J.R. Simplot Company Overnight Mail
P.O. Box 27 FAX
Boise, Idaho 83707

Peter J. Richardson Hand Delivered
Richardson & O’Leary, PLLC x U.S. Mail
99 East State Street, Suite 200 Overnight Mail
P.O. Box 1849 FAX
Eagle, Idaho 83616

William M. Eddie Hand Delivered
Land and Water Fund of the Rockies x U.S. Mail
P.O. Box 1612 Overnight Mail
Boise, Idaho 83701 FAX

/s/
______________________________________
LARRY D. RIPLEY