20100301ICL.pdf

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Conservation League
PO Box 84, Boise, ID 83701
208.345.6933
Idaho Public Utìlties Commission
PO Box 83720
Boise, ID 83720-0074
March 1, 2010
RE: In the Matter of the Application of Idao Power Co. for a Prudency Determination of
Energy Efficiency Rider Funds Spent in 2002-2007, Cas No. IPC-E-09-09
Honorable Commissioners:
Thank you for the opportunity to comment on the Application of Idao Power Company for a
Prudency Determination of Energy Efficiency Rider Funds Spent in 2002-2007. For thirty-four
years, the Idaho Conservtion League has been Idao's voice for clean water, clean air, and
wilderness-values that are the foundation to Idaho's extraordinary quaity of life. As Idao's
largest state-based conservation organization we represent over 9,500 members, many of whom
have a deep personal interest in protecting our clean air, clean water, and quaity of life.
Energy conservtion is the quickest, cheapest, and cleanest way to meet Idao's energy needs. It is
imperative that utìlties invest in all cost effective energy efficiency and demand side management
(DSM) programs before buiding new generation. ICL applauds Idao Power for its increased
investment in effciency and DSM programs over the past severa years and looks forward to
seeing existing programs grow and new progrs developed. As efficiency and DSM progrs
increase, it is necessary for utìlties to develop and follow protocols to evaluate their progress.
Evaluation and verification are essential to ensurng programs are achieving actua savings and are
cost effective. The proposed stipulation and memorandum of understanding (MOU) are an
important first step in accomplishing this goal.
Proper evaluation and verification can only be accomplished if it is properly funded. Idao Power
curently spends about 1.5% of its DSM budget on evaluation and verification, but the Company
should be spending 5-6% of the budget on evaluation. ICL also strongly recommends that a third
pary be required to evaluate the programs in order to avoid an inherent conflict of interest.
Ratepayers can feel more secure about investments in DSM if they can be certain the programs are
achieving cost effective savings.
ICL's final comment on the stipulation and MOU pertains to process. ICL is pleased to see
collaboration between the utìlties to develop a fraework to evaluate DSM programs, but ICL
believes broader participation in this process can furher the collective goal that Idao investor
owned utilities are achieving al cost effective savings from energy efficiency and DSM. Customer
groups and other stakeholders could have provided valuable input durng the prudencyworkshops
and should have been invited to paricipate.
Thank you for the opportunity to comment on this application. If you have questions about our
interest in this matter, please contact me at [phone] ext. 12 or at
bbridgeaPidahoconservtion .org.
Sincerely,
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Betsy Bridge
Energy Efficiency Associate
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