20040618Application.pdf

William M. Eddie (ISB #5800)
ADVOCATES FOR THE WEST
O. Box 1612
Boise, ID 83701
ph: [phone], ext. 3
fax: (208)' 342-8286
billeddie(q)rmci.net
Fi:ECEIVED illiLED
ZOHtr JON PrJ 12:
:;;.
t:...
; ;;
U;; ii'uTILIllEsj c'of~~~fl SSION
Street Address
1320 W. Franklin St.
Boise, ID 83702
Attorney for Petitioner NW Energy Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
OF FINANCIAL DISINCENTIVES TO
INVESTMENT IN ENERGY EFFICIENCY BY
IDAHO POWER COMPANY
Case No. IPC- E-04-
PETITION
In compliance with Order No. 29505 (Case No. IPC-03-13), and pursuant to
Rules of Procedure 33 and 53 (IDAPA 31.01.01.033 and .053), NW Energy Coalition
hereby petitions the Idaho Public Utilities Commission to initiate workshop proceedings
to investigate financial disincentives which hinder Idaho Power s investments in cost-
effective energy efficiency resources. See Order 29505 at pp. 68-69.
Petitioner NW Energy Coalition is a non-profit organization incorporated in
Washington, which promotes energy conservation and renewable energy resources
consumer and low-income protection, and fish and wildlife restoration on the Columbia
and Snake Rivers. NW Energy Coalition has numerous organizational and individual
members in Idaho, and was an intervenor in the 2003-2004 Idaho Power general rate case
(Case No. IPC-03-13).
PETITION -- ORIGINAL
SUPPORTING POINTS AND AUTHORITIES
Order No. 29505 provided, in relevant part:
The Commission has determined that a proceeding to assess financial
disincentives inherent in Company-sponsored conservation programs is
. appropriate and should proceed by informal workshops. The Commission
specifically directs the parties to address possible revenue adjustment
when annual energy consumption is both above and below normal. The
parties should also consider how much adjustment is necessary to remove
DSM investment disincentives and whether (and to what extent)
performance-based incentives such as revenue sharing could or should be
incorporated into the resolution of this issue. The Commission is
interested in proposals that could provide Idaho 'Power the opportunity to
share and retain benefits gained from efficiencies, especially where
efficiencies are derived from innovation and the use of new technologies. .
.. In short, the Commission believes opportunities exist for improvements
in operating efficiency that would benefit the Company shareholders and
its customers, and we encourage the parties to creatively consider the
options for a performance based mechanism to present to the Commission.
The parties to the agreement are directed to propose a workshop schedule
and initiate a proceeding.
Order 29505 at pp. 68-69.
Counsel for NW Energy Coalition has conferred with Staff, Idaho Power, and the
Industrial Customers of Idaho Power (ICIP) to obtain agreement on workshop timing and
procedures. NW Energy Coalition, Staff, Idaho Power Company, and ICIP agree to
proceed as follows:
A series of three (3) informal workshops is anticipated, to be concluded by
December 15 2004. The first workshop will be held starting at 9:30 AM until
approximately 12:30 PM on August 24, 2004, at Idaho Power Company, 1221 West
Idaho Street, Boise, Idaho. Dates and locations for further workshops will be determined
While the Commission s Order spoke directly to removing barriers to efficiency
investment, NW Energy Coalition believes the same principles apply to investment in
clean distributed generation.
PETITION -- 2
at this initial meeting. NW Energy Coalition will provide direct notice of such
workshops to all parties to case number IPC-03-13.
Idaho Power Company has generously agreed to underwrite the costs of a
facilitator for the workshops. In order to advance discussions, Idaho Power Company has
also agreed to circulate a "white paper" analysis of the issues identified by the
Comp1ission in Order No. 29505 to Staff, NW Energy Coalition, and ICIP (and other
parties who may request the analysis), by July 24, 2004.
Apart from the initiation of this new proceeding, no specific actions or orders are
requested of the Commission at this time. If no party seeks specific actions or orders of
the Commission by December 15 2004, NW Energy Coalition will provide a status
report to the Commission no later than that date to update the Commission on the status
of the investigative workshops.
CONCLUSION
NW Energy Coalition requests the Commission grant this Petition to initiate the
investigative proceeding as described in Order 29505, and as set forth above.
Dated: June 18 , 2004 Respectfu ly submitted
William M. Eddie
On behalf of NW Energy Coalition
PETITION -- 3
CERTIFICATE OF SERVICE
I hereby certify that on this 18th day of June 2004, true and correct copies of the
foregoing PETITION were delivered to the following persons via hand delivery (for
Commission and Idaho Power recipients) and U.S. Mail (for all others):
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W.Washington
Boise, ID 83702
Lawrence Gollomp
Assistant General Counsel
S. Dept. of Energy
1000 Independence Ave., SW
Washington, DC 20585
Lisa Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Dean Miller
McDevitt & Miller
O. Box 2564
Boise, ID 83701
Barton Kline
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Conley Ward
Givens Pursley
601 W. Bannock St.
O. Box 2720
Boise, ID 83701-2720
John R. Gale
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
. Brad Purdy
2019 N. 17th St.
Boise, ID 83702
Peter Richardson
Richardson & O'Leary
O. Box 1849
Eagle, ID 83703
Michael Kurtz
Kurt J. Boehm
Boehm, Kurtz & Lowry
36 E. Seventh St., Suite 2110
Cincinnati, OH 45202
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ID 83703
William Eddie
Randall Budge
Racine, Olson, et al.
201 E. Center
O. Box 1391
Pocatello, ID 83204-1391