20220831Idaho Power Comments.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

August 31, 2022

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. GNR-E-22-02
In the Matter of the Soft Lights Foundation Petition for the Regulation of Light
Emitting Diode Streetlights

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Comments in the above-
entitled matter.

If you have any questions about the attached document, please do not hesitate to
contact me.

Sincerely,

Lisa D. Nordstrom

LDN:sg
Enclosure

RECEIVED
Wednesday, August 31, 2022 3:04:29 PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S COMMENTS - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE SOFT LIGHTS
FOUNDATION PETITION FOR THE
REGULATION OF LIGHT EMITTING
DIODE STREETLIGHTS.
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CASE NO. GNR-E-22-02

IDAHO POWER COMPANY’S
COMMENTS

Idaho Power Company (“Idaho Power” or “Company”) respectfully submits the
following Comments in response to the Soft Light Foundation’s (“Petitioner”) Petition for
the Regulation of Light Emitting Diode Streetlights (“Petition”). Idaho Power supports the
comments filed by both Avista Corp. on August 8, 2022, and Rocky Mountain Power on
August 16, 2022, and requests the Idaho Public Utilities Commission (“Commission”)
dismiss the Petition. The Company’s comments are as follows:
I. Background
Idaho Power's lighting services are provided through two tariff schedules,
Schedule 15 and Schedule 41. Schedule 15 is applicable to electric service provided for
the outdoor dusk to dawn lighting of commercial, industrial, and residential customer
IDAHO POWER COMPANY’S COMMENTS - 2
grounds, yards, driveways, and premises. All light fixtures under Schedule 15 are owned
and maintained by the Company.
Schedule 41 is applicable to electric service provided for lighting of public streets,
public alleys, public grounds, and thoroughfares to improve visibility for drivers, as well
as to illuminate outdoor pedestrian walkways. Schedule 41 provides three service options
for street lighting customers:
Option “A” ("Schedule 41A") provides for Idaho Power-owned and Idaho Power-
maintained street lighting systems. Street lighting systems under this option are not
metered and customers pay monthly lamp charges based on their choice of standard
wattage lamps.
Option “B” (“Schedule 41B”) provides a service option for customers choosing to
own their lighting system, but who opt for Idaho Power to provide maintenance of those
systems. Option “B” is closed for new service and will no longer be available to customers
after September 30, 2023.
Option “C” ("Schedule 41C") provides a service option for customers choosing to
own and maintain their lighting system. Option “C” allows customers with non-metered
lighting systems to provide their own maintenance without being charged for Idaho
Power-provided maintenance. Option “C” also provides greater flexibility to customers as
they are not limited to the light fixture offered by Idaho Power; rather, the customer can
install lighting systems not offered by the Company.
There are currently about 54,000 streetlights under Schedules 15 & 41 in the
Company’s service area.

IDAHO POWER COMPANY’S COMMENTS - 3
II. Company-Owned Streetlight LED Conversion Project
On September 30, 2019, the Commission approved Idaho Power’s Application to
Modify Schedules 15 & 41 for Light Emitting Diode (“LED”) Technology.1 The Company’s
transition to LED lights is expected to be completed by September 2023 with the project
currently 68% complete.
Idaho Power continues to stand by its rationale for converting all Company-owned
high-pressure sodium and metal halide light technology, collectively referred to as High
Intensity Discharge ("HID"), streetlights to LED for the reasons summarized below:
 HID lighting technology is expected to reach a point of technical
obsolescence in the coming years.
 Technological advances and improving economics are making LED lighting
options more cost competitive as compared to HID technologies.
 LED lights use less energy, operate with lower maintenance costs, and
provide improved lighting quality.
 The Company believes adopting of LED lighting options will serve the best
interests of its customers.
LED lighting provides several advantages over traditional HID lighting options
including using less energy, reduced maintenance costs, and better lighting quality.
Based on the customer feedback received during the development of the LED conversion
project, as well as the feedback received as the project has progressed, the
aforementioned advantages have led to increased customer satisfaction.

1 In the Matter of Idaho Power’s Application for Authority to Modify Schedule 15, Dusk to Dawn Customer
Lighting, and Schedule 41, Street Lighting Service, to Allow for Light-Emitting Diode Technology, Case
No. IPC-E-19-17, Order No. 34452 (Sept. 30, 2019).

IDAHO POWER COMPANY’S COMMENTS - 4
A. Energy Efficient
LED light fixtures are more energy efficient than HID lighting systems because they
use less energy to produce the same or better light quality. Idaho Power estimates an
annual reduction in energy consumption of approximately 748,581 megawatt-hours once
the conversion from HID to LED technology is completed. This reduction in energy
consumption has and will result in net power supply expense savings that flows back to
customers through the Power Cost Adjustment ("PCA") mechanism.
The Company has offered Demand-Side Management lighting programs to
customer in its service area since 2002. The Commission has reviewed these programs
on an annual basis and has deemed the vast majority of expenses associated with these
programs as prudent. The prudence determination takes into account the cost-
effectiveness of the lighting measures, and for a lighting measure to be cost-effective, it
has to be more efficient than what it is replacing to generate a savings value greater than
its cost in the cost-effectiveness calculation. Therefore, after decades of evolving lighting
measures and offerings by utilities and organizations throughout the Pacific Northwest,
that have also included frequent state regulatory reviews, it is considered industry
standard that LEDs are energy efficient.
B. Reduced Maintenance Costs
LED light fixtures also have lower maintenance costs than HID lighting systems
because the operating life of an LED is longer than that of an HID bulb. Assuming an L70
rating of 100,000 hours and 4,059 burn hours annually, the projected life of the specified
LED light fixtures is approximately 24.6 years (100,000 hours/4,059 hours per year burn
time). By comparison, Idaho Power's most commonly installed 100W high pressure
IDAHO POWER COMPANY’S COMMENTS - 5
sodium vapor bulb has an expected life of approximately 20,000 hours, roughly 20
percent of the expected life of an LED fixture.
C. Lighting Quality
LED lights provide better light quality. LED lights project light in a focused pattern,
directing light more precisely where it is needed. In addition, the color temperature of the
light appears whiter with better color rendition thus providing greater clarity than the
yellow hues of high-pressure sodium vapor lighting. The result is more uniform light
coverage, with less glare and fewer dark spots, which improves visibility due to better
lighting quality.
D. Less Environmental Impact
An additional benefit to LED lighting fixtures is that they can be recycled whereas
high pressure sodium lamps, which make up most of Idaho Power's current street lighting
systems, cannot be recycled and require special handling for disposal. According to a
report prepared for the U.S. Department of Energy, "LEDs contain no mercury and require
no special handling for disposal.”2
III. Idaho Power Response to Petitioner’s Arguments
In support of Idaho Power’s recommendation that the Petition be dismissed, the
Company briefly addresses the Petitioner’s requested relief.
A. FDA Approval Prior to LED Installation
As outlined above, and already approved by the Commission in Order No. 34452,
the Company’s LED conversion project is in the best interest of its customers. Idaho

2 Navigant Consulting, Energy Savings Estimates of Light Emitting Diodes in Niche Lighting Applications
at 7 (January 2011).
www1.eere.energy.gov/buildings/publications/pdfs/ssl/nichefinalreport_january2011.pdf
IDAHO POWER COMPANY’S COMMENTS - 6
Power’s conversion to LED lighting is more than two-thirds complete, and it is not
reasonable to wait for FDA approval prior to the installation of additional LED streetlights.
The Petitioner explicitly states that “In 2018, the FDA posted the statement on the FDA's
website, ‘LEDs (Light Emitting Diodes) are different from laser diodes and are not subject
to the Federal laser product performance standard.’ This statement does not clarify
whether LEDs have never been regulated by the FDA, or if the FDA had been previously
regulating LEDs under Part 1040.10 but has now stopped regulating LEDs within Part
1040.10.”3 Therefore, having the Commission take action on something that may never
be addressed by the FDA is unreasonable. The Company supports the Commission
taking action when concrete evidence, recommendations, and/or laws are directed from
regulatory agencies or governing bodies.
B. Inform Consumers via Utility Websites that LEDs Have Not Been FDA-
Approved
The Company does not believe it to be necessary to inform Customers that LEDs
have not been approved by the FDA on its website and that the FDA has not developed
regulations for LEDs. This is currently not a requirement from health agencies, and at this
juncture, it would likely only lead to customer confusion. Even assuming the Petitioner’s
concerns were correct, and the utilities posted the desired notices on their websites, it
would have little practical effect because LED streetlights generally make up a very small
percentage of the average person’s daily LED light exposure.

3 Petition at 2.
IDAHO POWER COMPANY’S COMMENTS - 7
C. Inform Consumers via Utility Websites that LED Light Is “Low-Quality” and
Not Energy Efficient
For the reasons summarized above, and outlined in Case No. IPC-E-19-17, the
Company disagrees that LED light is a low-quality light and not energy efficient. Idaho
Power supports the contrary that LED light is better quality and more energy efficient on
top of providing additional benefits such as lower maintenance costs due to longer fixture
life. Therefore, the Company does not support informing customers on its website about
LED facts it believes to be false.
D. Inform Consumers via Utility Websites that LEDs Cause “Significant
Negative Health Effects”
Although it does not believe LED lighting impairs public health and safety, Idaho
Power does not claim to be an expert on health-related matters associated with LED
lighting. However, as a public utility providing essential electric service to its customers,
the Company believes this item is out of both the Commission’s and Company’s purview.
If the negative health claim is indeed true, warnings should be directed by
governing public health agencies such as the U.S. Food and Drug Administration rather
than an economic regulator like the Commission. Therefore, informing customers on
Idaho Power’s website of potential negative health effects associated with LED light is
premature and possibly misleading.
IV. CONCLUSION
For the reasons stated above, Idaho Power respectfully requests the Commission
dismiss the Petition.

IDAHO POWER COMPANY’S COMMENTS - 8
DATED at Boise, Idaho, this 31st day of August 2022.

________________________________
LISA D. NORDSTROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S COMMENTS - 9
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 31st day of August 2022, I served a true and
correct copy of Idaho Power Company’s Comments upon the following named parties by
the method indicated below, and addressed to the following:

Commission Staff
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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Soft Lights Foundation
Mark Baker
Soft Lights Foundation
9450 SW Gemini Drive PMB 44671
Beaverton, OR 97008

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Avista Corp.
Patrick Ehrbar
Avista Corp.
1411 East Mission
P.O. Box 3727
Spokane, Washington 99220-0500

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Rocky Mountain Power
Emily L. Wegener
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
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________________________________
Stacy Gust, Regulatory Administrative
Assistant