20070201NWEC Comment.pdf

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Jean Jewell
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bill~eddielawfirm.com
Wednesday, January 31 , 2007 9:09 AM
Tanya Clark; Jean Jewell; Gene Fadness; Ed Howell
PUC Comment/Inquiry Form
A Comment from NWEC c/o William Eddie follows:
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Case Number: 1PC-E-06-
Name: NWEC c/o William Eddie
Address: 610 SW Alder St., Suite 910
City: Portland
State: OR
Zip: 97205
Home Telephone: [phone]
Contact E-Mail: bill&eddielawfirm. com
Name of Utility compa~~Idaho Power Company
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Please describe your question or comment briefly:
January 31, 2007
Jean Jewell, Commission Secretary
Idaho Public Utili ties Commission472 W. Washington St.
Boise, 1D 83702
Re: Comments on IPC-E-06-32
Dear Ms. Jewell:
I submit these comments on behalf of NW Energy Coalition for the Commission
consideration of Idaho Power Company s Demand Side Management Incentive Pilot Program
DSM Incentive PilotH ) in case IPC-E-06-32.
The NW Energy Coalition is a non-profit regional alliance of over 100 diverse
environmental, civic, consumer, low-income customer advocacy groups, energy efficiency and
renewable energy businesses, and progressive utilities in Idaho, Montana, Washington and
Oregon. NW Energy Coalition s main address is: 219 First Ave South, Suite 100, Seattle,WA 98104.
NW Energy Coalition recommends approval of the DSM Incentive Pilot as filed by IdahoPower. The Coalition was an active participant in the workshops held in the IPC-E-04-15docket, which evaluated both a fixed-cost adjustment mechanism, and performance incentivesfor DSM. A stipulation for a fixed-cost adjustment mechanism is currently pending before
the Commission. While the workshops did not result in a written stipulation or agreement
for a specific DSM incentive program, we believe the DSM Incentive Pilot filed by Idaho
Power is fully reflective of the workshop discussions. We believe Idaho Power has made a
good faith effort to respond to the concerns raised in the workshops.
The Coalition has long believed that electric utilities should be rewarded for providing
excellent customer service and securing the least-cost and least-risk resources for its
customers. The DSM Incentive Pilot is consistent with that goal.
One of the main criticisms of DSM performance incentives is that they tend to place
enormous importance on the audit of the DSM program s actual energy savings. The ENERGY
STAR Homes program is a good choice for the underlying DSM program subject to the Pilot
because of the active involvement of the Idaho Energy Division. The program s level of
success will be transparent.
In addition, the DSM Incentive Pilot is structured such that Idaho Power will need to show
excellent performance in order to share in the net benefits of the program. The Northwest
Energy Efficiency Alliance ("NEEAH ) market-share goals are significantly higher than the
Company s level of performance in 2006. If the Company s 2007 performance is better
than 2006, but not up to the NEEA goals, no penalty or incentive payment will occur. The
Coalition believes this "bandingH approach is appropriate because of the dynamic nature of
the construction industry.
Last, the Company proposes a reasonable approach to exclude costs incurred by the NEEA
when calculating the ENERGY STAR program s net benefits in Idaho. Viewed narrowly, it
can be argued that NEEA's expenditures to design the ENERGY STAR program and provide
training should be included in calculating total resource costs today. But NEEA's costs
are incurred for the purpose of transforming the housing market in future years. The
intent of NEEA's work is to ensure that new homes built five or more years from now are
inherently more efficient due to the ENERGY STAR program s success.
It is our understanding that NEEA will not report or take credit for energy savings
achieved at ENERGY STAR homes constructed with a utility incentive, such as the $750incenti ve paid by Idaho Power. In future years, NEEA will calculate and take credit for
the energy savings achieved by the broad market transformation that will occur. While
Idaho Power and other utilities which run ENERGY STAR homes incentive programs today will
also have contributed to that long-term market transformation, they will not be able to
rightly claim continued energy savings from that transformation. Therefore, for purposes
of accounting of energy savings and expenditures, there is symmetry and balance in
allocating 100% of current-year savings to utilities that run an ENERGY STAR incentive
program, and allocating 100% of market transformation savings to NEEA.
Thank you for considering these comments.
William M. Eddie
Attorney for NW Energy Coalition
610 SW Alder, Suite 910
Portland, OR 97205
Ph: 503-542-5245
Fax: [phone]
The form submited on http://www.puc.idaho.gov/forms/ipucl/ipuc.html
IP address is 63.229.136.
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