20050307Reply Comments.pdf

BARTON L. KLINE ISB #1526
Idaho Power Company
O. Box 70
Boise , Idaho 83707
Telephone No. [phone]
FAX Telephone No. [phone]
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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 AUTHORITY TO
REVISE THE ENERGY EFFICIENCY
RIDER, TARIFF SCHEUDLE 91
REPLY OF IDAHO POWER
COMPANY TO THE COMMENTS
OF THE COMMISSION STAFF AND
, THE NW ENERGY'COALITION
CASE NO. IPC-04-
Idaho Power Company ("Idaho Power" or "the Company ) hereby submits
the following comments replying to the comments offered in this matter by the Staff of
the Idaho Public Utilities Commission ("Commission Staff") and by the NW Energy
Coalition ("Coalition ) on February 16 , 2005.
The Company appreciates the support of its request to increase the
Energy Efficiency Rider ("Rider ) expressed in the comments of both Commission Staff
and the Coalition. Although the Company does not concur with the parties on all of the
issues raised in their comments, it is notable that there is universal agreement among
REPLY COMMENTS OF IDAHO POWER COMPANY -
the commenters that the Rider should be increased to 1 ./0 effective June 1 , 2005, in
order to provide funding for expanded demand-side management ("DSM") programs.
That being said , the Company believes a few comments are needed to
correct some inaccuracies and clarify statements made in Commission Staff and
Coalition comments in order to ensure that the record in this case is complete and
accurate.
Commission Staff
In describing Company witness Brilz s Exhibit 2 , Commission Staff commented
that the effect of the Company s credit balance with the Northwest Energy Efficiency
Alliance ("Alliance ) is only partially included in the cash flow analysis (Commission Staff
comments, page 3). This statement is not correct. Although the Company and
Commission Staff took different approaches to incorporate the benefit of the Alliance
balance into their analyses , both analyses fully include th~ effect of the credit balance.
The different approaches used by the Company and Commission Staff result in cash
flow timing differences. However, the Company believes Commission Staff'
methodology produces reasonable results.
NW Enerqy Coalition
In their comments the Coalition refers to a study performed by Quantum
Consulting for Idaho Power in which both the peak and base load energy efficiency
potential within the Company s residential and commercial customer classes were
assessed. The Coalition s comments imply that the Company used the "low-level
scenario" from this study in its 2004 Integrated Resource Plan ("IRP"
).
The Company
actually used a "moderate-level scenario" in its 2004 RP process. Quantum
REPLY COMMENTS OF IDAHO POWER COMPANY - 2
Consulting performed two assessments for Idaho Power during 2003 and 2004. The
first assessment, referred to as the Phase I study, focused on summer peak demand
reduction potential within the Company s residential and commercial sectors. The
findings from the Phase I study were presented to the Company and the Energy
Efficiency Advisory Group ("EEAG") in January 2004. The Company used the results of
the Phase I study in its 2004 IRP and targeted the "moderate-level scenario" detailed in
the study in identifying the level of peak-related DSM to be targeted. The second
assessment, referred to as the Phase II study, was initiated as a result of a request from
members of the Company s Integrated Resource Plan Advisory Council ("IRPAC") and
focused on overall energy efficiency potential within the Company s residential and
commercial sectors. The findings from both the Phase I and Phase II studies were
combined into a single document and presented in draft final version form to the
Company and the EEAG in October 2004. The draft final version of the study
performed by Quantum Consulting was also provided to members of the IRPAC. The
final version of the study, dated November 2004, was filed with the Commission as a
supplement to the 2004 IRP filing (Case No. IPC-04-18) on December 15 , 2004. The
details of the "moderate-level scenario" resulting from the Phase I assessment and used
in the 2004 IRP can be found on page 4-16 of the final version of the study.
The Company believes that the final report provided by Quantum Consulting
provides useful information on the potential DSM opportunities within the reside~tial and
commercial sectors and concurs with the Coalition that the results of the study should
be considered as part of the 2006 IRP process.
REPLY COMMENTS OF IDAHO POWER COMPANY,. 3
Respectfully submitted this 4th day of March , 2005.
Wriu-"
BARTON L. KLINE
Attorney for Idaho Power Company
REPLY COMMENTS OF IDAHO POWER COMPANY - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 4th day of March , 2005 , I served a true
and correct copy of the within and foregoing REPLY COMMENTS OF IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Donovan Walker
Deputy Attorney General
Idaho Public Utilities Commission
P. O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
Nancy Hirsh
NW Energy Coalition
219 1st Avenue South, Suite 100
Seattle, Washington 98104
Hand Delivered
S. Mail
Overnight Mail
FAX
~Mu-'
BARTON L. KLINE
CERTI FICA TE OF SERVICE