20090206SRA Comments.pdf

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Jean Jewell
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kmiler~snakeriverallance. org
Thursday, February 05,20099:15 AM
Jean Jewell; Beverly Barker; Gene Fadness; Ed Howell
PUC Comment Form
A Comment from Ken Miller follows:
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Case Number: IPC-E-08-11
Name: Ken Miller
Address: PO Box 1731
City: Boise
State: ID
Zip: 83701
Daytime Telephone: [phone]
Contact E-Mail: kmiller~snakeri veralliance. org Name of Utility Company: Idaho Power Add to
Mailing list: .!
Please describe your comment briefly:
This comment was also faxed to the PUC.
Feb. 5, 2009
TO: Jean Jewell
Idaho Public Utilities Commission Secretary
472 West Washington
Boise, ID 83702
FROM: Ken Miller
Snake River Alliance
Box 1731
Boise, ID 83701
Ph: [phone]
RE DOCKET IPC-E-08-11: IN THE MATTER OF THE APPROPRIATE DISPOSITION OF IDAHO POWER COMPANY'S
S02 EMISSION PROCEEDS TO FUND AN ENERGY EDUCATION PROPOSAL
Dear Ms. Jewell:
Please accept the following comments on behalf of the Snake River Alliance relative to the
Commission's docket, IPC-E-08-21.
The Snake River Alliance is an Idaho-based non-profit organization established in 1979 to
address Idahoans' concerns about nuclear safety issues. In early 2007, the Alliance expanded
the scope of its mission by launching its Clean Energy Program. The Alliance's energy
initiative includes advocacy for renewable energy resources in Idaho; expanded conservation
and demand-side management programs offered by Idaho utilities and the Bonneville Power
Administration; and local, state, regional, and national policies and initiatives that
promote sustainable and affordable energy policies. The Alliance is pursuing these programs
on behalf of its members, many of whom are customers of Idaho's regulated utilities, who are
interested in promoting clean and affordable energy ini tiati ves.
The Alliance appreciates the efforts by the Public Utilities Commission's interest in this
unique docket, and the willingness by Commissioners and PUC staff to consider the multiple
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proposals before it with regard to the most effective use of the S02 emissions proceeds at
issue. It is our hope that, as additional S02 allowances are sold, the Commission will
continue to consider using a portion of the proceeds to further fund and develop energy
education initiatives such as that proposed by the Idaho Energy Education Project (IEEP). The
Alliance also recognizes and appreciates the efforts put into this docket by PUC staff, IEEP,
Idaho Power Co., the Idaho Office of Energy Resources, and the Department of Education.
The Alliance has supported the proposals advanced by IEEP since the initiation of this
docket. We consider it of paramount importance that, given the amount of money available, the
energy education initiatives to be funded through this docket have the least amount of
overhead or administrative costs as possible, and that students be involved in these programs
to the maximum amount possible.
While the Alliance appreciates the suggestions advanced by, the Office of Energy Resources
(OER) and the Department of Education (DOE), we are concerned about the level of
administrative costs as well as the amount of funds that would be targeted for curriculum
development, given that much of the education material is already available.
The Alliance was impressed by Idaho Power's Jan. 9 presentation and all three of the concepts
advanced by the Company. We believe Concept 1, expanding mini home audits for students, is
creative and has significant educational possibilities. likewise, Concept 2, which would
allow students to actively participate in putting the results of energy audits to use and
also to use regional workshops to train students and teachers, is a sound idea and well worth
exploring. While we agree that Concept 3 (Solar4RSchools) is a very good idea, we believe
those funds might be better used to support the first two Concepts. An al ternati ve might be
to explore ways to expand participation in the existing Solar4RSchools program and to pursue
the ideas contained in Concept 3 with such entities as the Bonneville Environmental
Foundation.
As important as the programs are, the Alliance agrees with IEEP that it is equally important
that an advisory committee, the framework for which can be established by the Commission as
part of this docket, should be established to monitor the programs. While we recognize these
programs are a logical extension of much of the demand-side management efforts already in
place at Idaho Power, we believe such an advisory committee is best suited to accept and
screen proposals by schools or school districts, working in concert with the Company. Such an
advisory panel (which needn't add to existing bureaucracy and which was referred to by IEEP
as an "Idaho Energy Education Board") would also be ideally sui ted to review the performance
of the programs to ensure they are accomplishing what they were designed to do.
In summary, the Alliance has long been impressed by the creativity and enthusiasm shown by
Mr. Bill Chisholm and IEEP, and we believe IEEP should be a key component to the execution of
these energy education programs. At a minimum, should Idaho Power's concepts be adopted in
whole or in part by the Commission, we would urge the Commission to include in its order some
sort of reporting requirement to the entity charged with executing these programs. Such a
report and evaluation would be helpful in determining whether the programs are effective, and
also in identifying other possible programs that could be implemented should additional funds
become available.
As mentioned above, the Alliance also urges the Commission to consider using a portion of
future S02 allowance sales proceeds to continue some level of funding for these energy
education and participatory programs. It is probable that additional proceeds will be
generated by future allowance sales, and the Alliance agrees with the Commission's order
addressing the distribution of these proceeds on the customary 90-10 split similar to that
employed in PCA cases.
Respectfully submitted,
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Ken Miller
Clean Energy Program Director
Snake River Alliance
[phone]
Box 1731
Boise, ID 83701
kmiller~snakeri veralliance. org
The form submitted on http://www.puc.idaho.gov/forms/ipuc1/ipuc.html
IP address is 70.102.111.178
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