20090205Comments.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
RECEiVED
innq fEB -5 PM 2: 52
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPROPRIATE )
DISPOSITION OF IDAHO POWER )
COMPANY'S S02 EMISSION PROCEEDS TO )
FUND AN ENERGY EDUCATION PROPOSAL )
)
)
)
CASE NO. IPC-E-08-11
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilties Commission, by and through its Attorney of
Record, Donald L. Howell II, Deputy Attorney General, submits the following comments in
response to Order No. 30699 issued on December 11,2008.
BACKGROUND
On April 14, 2008, the Commission issued Order No. 30529 concerning the appropriate
disposition of the proceeds from the sale of Idaho Power Company's sulfu dioxide (S02)
emission allowances in calendar year 2007. In its Order, the Commission reserved $500,000 of
the S02 proceeds to possibly fund an energy education program proposed by the Idaho Energy
Education Project (IEEP). On July 16, 2008, the Commission convened a Status Conference so
that IEEP and other interested parties could provide more detail about developing energy
education programs. On Januar 8, 2009, the Commission convened an Additional Workshop
STAFF COMMENTS 1 FEBRUARY 5, 2009
for Idaho Power to present an overview of its existing energy effciency education efforts and its
energy effciency programs available to schools.
THE INITIAL STATUS CONFERENCE
At the conference held on July 16,2008, the Idaho Offce of Energy Resources (OER)
submitted a proposal for the Commission's consideration. OER indicated that the proposal was
prepared in cooperation with the Idaho Deparment of Education (DOE, aka State Deparment of
Education/SDE) and with Idaho Power Company. Under the OER-DOE proposal, the $500,000
in S02 proceeds would be divided into two equal amounts. Half of the fuds would be used to
develop and implement an energy effciency curriculum for schools. The DOE would ensure
that the energy curiculum would meet Idaho educational "stadards before implementing a
program in K-12 schools statewide." During this curiculum phase, DOE would also determine
the best school grade(s) in which to implement such a program.
DOE envisioned integrating the energy curiculum into classrooms by using the "train-
the-trainer" modeL. Under the OER-DOE proposal, two teachers would be initially selected to
develop the curiculum and those two teachers would then train up to 30 more teachers per
workshop. The agencies estimated having 30 workshops during a two-year period. The agencies
anticipated that administering the education portion of the energy proposal would require 0.8 of a
full-time employee (FTE) for the two-year period.
The second par of the OER-DOE proposal would be to make $250,000 available for
schools in Idaho Power's service territory to implement/construct specific energy effciency
projects. Such measures might include conservation (lighting, heating, building constrction)
projects or energy generation (solar or wind) projects. OER estimated that there are
approximately 62 public school districts in Idaho Power's service terrtory with more than 350
buildings. By augmenting Idaho Power's existing energy efficiency project for schools with the
additional $250,000, OER asserted that the additional fuds will produce greater energy savings
for paricipating schools than relying on Idaho Power's existing programs alone. OER
anticipated that administration of the project component would require 0.5 FTE for one year.
The estimated costs for both components of the OER-DOE proposal are set out below.
STAFF COMMENTS 2 FEBRUARY 5, 2009
Education ComponentDevelop Curiculum $ 80,000
Select 2 Training Teachers 10,000
Train-the-Trainer Workshops 50,000Admin/Overhead 110,000TOTAL $250,000
Project ComponentMarketing $ 13,989
Project Funds 185,000
Admin/Overhead 51,011
TOTAL $250,000
At the initial conference, Idaho Power did not present a proposal or provide additional
detail regarding its existing Community Education Program for schools. Instead, the Company
said it was prepared to support whatever the Commission decided. The Company does have
employees who make presentations at schools in its service territory about utilty matters, safety,
generation and energy efficiency. Idaho Power also provides fuding for energy conservation
projects in schools. The Company indicated that its existing programs "fit very well with the
goals" of the OER-DOE proposaL.
In reaction to the OER-DOE proposal, paricipants generally voiced support for energy
education and offered constructive criticism of the proposal. Others suggested that the school
energy projects should be designed to engage the students at the project schools. Finally, some
paricipants expressed concern about the agencies' estimated administrative costs. The
Commission subsequently scheduled another conference so that Idaho Power could present its
school programs.
THE SECOND CONFERENCE (WORKSHOP)
At the workshop held on Januar 8, 2009, Idaho Power presented an overview of its
existing programs, including energy efficiency education efforts for students, programs to
improve the energy effciencies of school facilties, and "Solar 4R Schools" program. Idaho
Power also presented an Energy Efficiency Education Concept Proposal (Proposal) that would
fully utilze the $500,000 of S02 proceeds over two years. The Company's two-year Proposal
has three pars:
1) Expand the scope and number of mini home audits for students and have more in-depth
follow-up in the classroom. Assemble classroom energy kits that include an actual
kilowattlowatt-hour/volt/amp/etc. meter for each student in the class to take home.
Classroom exercises would teach meter reading, including AMI, and how to calculate
electricity usage in the home by various appliances. Kits would be distributed to about
STAFF COMMENTS 3 FEBRUARY 5, 2009
100 classrooms each year by Idaho Power's five existing community education
representatives. Assuming an average of 30 students per classroom, ths component of
the Proposal would cost $90,000 per year or $180,000 over two years and would not
require any additional Idaho Power personneL.
2) Have students assist in energy audits of school facilties and have students make
recommendations for implementing energy efficiency measures. Students would build
and present business cases for their schools' decision makers. Idaho Power's existing
financial incentives for commercial energy effciency would be available to assist in
fuding of student recommendations adopted through this "learing lab" process. The
cost of this new component for marketing, technical assistance, workshops and Y: FTE
for a new program specialist would be $85,000 per year or $170,000 over two years.
3) Include two additional projects in Idaho Power's existing "Solar 4R Schools" program
and provide fuding for additional classroom kits and training. The cost of this
expansion would be $75,000 per year, or $150,000 over two years, for materials and
training. This would double the number of solar installations per year.
STAFF REVIEW
Staff believes that educating students and their parents about energy use, waste,
measurement and costs is the best long-term opportunity to increase energy efficiency. The
Idaho Energy Education Project (IEEP) should be commended for recommending that some of
the S02 fuds be used to involve students in improving the efficient use of energy in their
schools. IEEP's recommendation prompted the Idaho Office of Energy Resources and the State
Deparment of Education to submit a thoughtful proposaL. After reviewing all of the proposals,
Staf believes that Idaho Power's three-par proposal for using $500,000 of S02 fuds for energy
effciency education has the best opportunity to result in cost-effective energy savings for Idaho
Power's customers.
Although Staff believes that Idaho Power's three components have varing likelihoods
for achieving cost-effectiveness, we conclude that all three components have merit. They should
each be implemented as generally suggested in Idaho Power's "Energy Efficiency Education
Concept Proposal" dated 1/8/2009. However, Staff notes that none of the three components in
the Company's proposal include an evaluation process or follow-up report. Post-implementation
STAFF COMMENTS 4 FEBRUARY 5, 2009
evaluations are a necessary par of good program management. It is not clear whether Idaho
Power intended to include an evaluation of the three proposed educational components in its
overall evaluation budget for all of its demand side management (DSM) programs.
Component 1 of Idaho Power's Proposal (to expand the scope and number of existing
mini home audits by distrbuting educational materials, including kilowatt meters, to each
student in a classroom) should provide opportity for the Company to measure any electricity
consumption changes in thousands of students' homes. Staff estimates that about 6,000 students
will paricipate durng the two years of this program. If the student education "pilot" program
proves to produce cost-effective electricity savings, a broader-based program to distribute
kilowatt meters to all interested customers could follow. i However, regardless of whether the
savings from the student "pilot" are measurable and cost-effective in the short-term, the long-
term educational effect of the meters and the classroom instruction will be beneficial, if not
precisely measurable, in the decades that follow.
Component 2 of Idaho Power's Proposal (to initiate energy efficiency audits of school
facilities by students) appears to promise both short-term, measurable energy savings as well as
long-term educational benefits. Although Idaho Power's research revealed that other utilties
cautioned that this type of education program can take several years to fully develop, Staff
believes it has .the potential to produce results consistent with the goals in both IEEP's original
proposal and the OER-DOE joint proposal.
Component 3 ofIdaho Power's Proposal (to expand the existing Solar 4R Schools
program) is the least compellng of the three components in its proposaL. Staffs ambivalence is
because solar generation of electricity is not yet generally a cost-effective energy resource,
especially for buildings where electricity distribution facilties are already in place or are readily
available. However, Staff believes that solar generation will become more cost-effective in the
futue and that solar (or renewable energy) education may be cost-effective in the long-term.
Staff is also aware that Idaho Power proposed in Case No. IPC-E-08-03 that it be allowed to
expand the use of its energy efficiency tariff rider funds to include promotion of small-scale
renewable electricity generation (e.g. photovoltaic) that is claimed to be cost-effective from the
utilty perspective, but not necessarily cost-effective from total resource or paricipant
perspectives. Commission Order No. 30560 denied that request, but stated that Idaho Power,
1 Staff has previously suggested to Idaho's utilties that they consider a broad-based kilowatt meter program.
STAFF COMMENTS 5 FEBRUARY 5, 2009
Staff and other paries should discuss the idea fuher. Staff believes that it is more appropriate
to expand the Solar 4R Schools program using a portion of the S02 fuds than it would be to
allow Energy Effciency Rider fuds to knowingly be used for resources that are not yet cost-
effective for paricipants. Staff contends that it is important for Rider fuds to be used only for
programs that are cost-effective not only from the utility perspective but also from the total
resource and paricipant perspectives to avoid risking the credibilty of all of its rider-fuded
programs.
STAFF RECOMMENDATION
In sumary, Staff recommends that the Commission allow Idaho Power to use S02
fuds of $500,000 plus the accumulated interest to implement its three-par proposal in
approximately the maner suggested in its "Energy Efficiency Education Concept ProposaL."
Staff also recommends that the Company be required to evaluate the short-term cost-
effectiveness and long-term potential of these programs in a maner consistent with good
program management.
Respectfully submitted this ~ day of Februar 2009.
l~i~
Deputy Attorney General
Staff: Lyn Anderson
i:umisc/commentsipce08. I Idhla
STAFF COMMENTS 6 FEBRUARY 5, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF FEBRUARY 2009,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-08-11, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bkline(ßidahopower.com
Inordstrom(ßidahopower .com
JOHN R GALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: rgale(ßidahopower.com
~~SECRETA~ -=
CERTIFICATE OF SERVICE