20141124_4536.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER REDFORD
COMMISSIONER SMITH
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL

FROM: DAPHNE HUANG
DEPUTY ATTORNEY GENERAL

DATE: NOVEMBER 19, 2014

SUBJECT: IDAHO POWER’S APPLICATION FOR AUTHORITY TO FUND ITS
CONTINUED PARTICIPATION IN THE NORTHWEST ENERGY
EFFICIENCY ALLIANCE; CASE NO. IPC-E-14-38

On October 29, 2014, Idaho Power Company filed an Application requesting
authorization to continue its participation in the Northwest Energy Efficiency Alliance (NEEA)
for the period 2015-2019. The Company requests that its participation be funded by the Energy
Efficiency Tariff Rider, a mechanism initiated in 2002 for recovering costs of Idaho Power’s
demand-side management (DSM) programs. See Order No. 29026. This is the Company’s
fourth request to authorize its continued participation in NEEA.
BACKGROUND
When the Commission first approved Idaho Power’s participation in NEEA in 1997,
it required the Company to defer recovery of its expenditures. Order No. 27045. The
Commission later found that participation in NEEA was prudent, and authorized Idaho Power to
establish a reserve of accumulated revenue sharing balances to reimburse it for deferred NEEA
expenditures from 1997-1999. Order No. 27877. In 2000, the Commission approved Idaho
Power’s continued participation in NEEA from 2000-2004, allowing Idaho Power to recover
participation costs through revenue sharing funds. Order No. 28333.
In May 2005, the Commission increased Idaho Power’s Energy Efficiency Rider so
the Company could expand its energy efficiency programs and continue participation in NEEA
for 2005-2009. Order No. 29784. In March 2009, the Commission approved a stipulation
between Idaho Power and Commission Staff, finding that $4 million Idaho Power paid to NEEA
DECISION MEMORANDUM 2
during 2002-2007 was prudently incurred. Order No. 30740. The Commission again approved
Idaho Power’s 2010 application, authorizing the Company’s continued participation in NEEA for
2010-2014. Order No. 31080. In that Order, the Commission noted that – as recognized by
Idaho Power – “The Commission’s approval of the Company’s continued participation in NEEA,
and the use of Rider funds to pay for that participation, is not a determination of prudency.” Id.
at 5, 7. Rather, “when Idaho Power in the future requests a Commission determination that its
use of Rider funds was prudent, it must demonstrate a sufficient benefit to customers resulted
from the Company’s participation in NEEA.” Id. at 7.
THE APPLICATION
Idaho Power’s current Application describes the main components of NEEA business
plan for 2015-2019. Idaho Power identifies the NEEA activities that the Company believes will
benefit its customers most, including: (1) the activities of the University of Idaho Integrated
Design Lab in Boise; (2) the Top Tier Trade Ally Advanced Training; (3) the commercial
lighting initiatives, (4) residential retail product portfolio; and (5) residential new construction.
Id. at 6. Idaho Power’s Application points out that the Company and NEEA have negotiated an
agreement to help ensure that the Company’s energy efficiency expenditures are prudent – that
is, that they are reasonable and effective. Id. at 6-7. The Regional Energy Efficiency Initiative
Agreement (“Agreement”) is attached to Idaho Power’s Application. Application, Attachment 3.
Subject to the Commission’s approval, Idaho Power has committed to fund NEEA
based on a quarterly estimate of expenses for five years totaling $13,450,835. Id. at 9. This
amount is 8.97% of NEEA’s $145-$169 million budget for 2015-2019.
Idaho Power requests that its Application be processed by Modified Procedure,
supported by the prefiled testimony of Senior Vice President of Customer Operations Warren
Kline. Id. at 10.
STAFF RECOMMENDATION
Staff recommends that the Company’s Application be processed by Modified
Procedure with a 21-day notice and comment period, and a 7-day reply comment period. See
IDAPA 31.01.01.201-204.
DECISION MEMORANDUM 3
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application and Notice of Modified
Procedure establishing a 21-day comment period, followed by a 7-day reply comment period?

Daphne Huang
Daphne Huang
Deputy Attorney General

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