20100301NWEC.pdf

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NW ition
February 26, 2010
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I Ç)Jean D. Jewell, Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
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Baron L. Kline
Lisa D. Nordstrom
Idaho Power Co.
PO Box 70
Boise, ID 83707-0070
Case No. IPC-E-09-09, In the Matter of the Application of Idao Power
Co. for a Prudency Determination of Energy Effciency Rider Funds
Spent in 2002-2007
Please accept these comments of the NW Energy Coalition in support of the
Application fied by Idaho Power and the Stipulation jointly fied by
Commission staff and the Company.
As energy efficiency resources become a larger par of utilty resource
portolios and the investment of funds to acquire those resources become
more significant it is crucial that utilities develop and use common, or at
least consistent, protocols to evaluate, measure, verify and report savings
and costs of demand-side management (DSM) program delivery. This
enhanced focus wil help ensure the cost-effective delivery 9f this resource
and increase the credibilty of DSM savings for reducing i6ads. The
proposed stipulation and memorandum of understanding provides an
importt initial framework for developing an enhanced EM& V program.
We recommend, as has been started with the MOU, that the three investor-
owned electric utilties continue to collaborate, where appropriate, on
research, field monitoring and data collection, and market characterization
studies. These collaborative efforts can reduce costs and increase collective
understading of the resource and its delivery. We also recommend that
the Commssion keep in mind that thorough and effective EM&V wil have
costs associated with it at a level greater than currently budgeted by Idaho
Power. It is our understading that Idaho Power is allocating 1- 1.5% of the
current DSM budget for evaluation. Wayne Shirley with the Regulatory
Assistance Project suggests that a more comprehensive and thorough
EM&V program would require a budget that is between 3.5-6% of the DSM
budget.
Since 2002, the NW Energy Coalition has been an active member of Idaho
Power's Energy Effciency Advisory Group. As par of our role on the
EEAG we review program budgets, savings estimates, paricipation rates,
program design and proposed changes to program design to faciltate more
effective delivery. While our parcipation in the EEAG does not constitute
a prudence review, it does give us sufficient confdence to support the
stipulation recommendation to find the company's program expenditures
prudent.
The Memorandum of Understading contains a framework for filing DSM
annual reports. The Coalition did not have the benefit of partcipating in the
workshop and hearng the dialogue among the MOU signatories as to
rationale behind some of the evaluation and cost-effectiveness
recommendations. That said the general format outlined in the MOU seems
to present the narative and data in a very systematic and orderly manner.
While the MOU Attchment No. 1 is only for informational purposes we
are concerned that PUC sta are recommending the addition of the
ratepayer impact test to the cost-effectiveness screens used by the utilties.
Over the past ten years, use of the ratepayer impact test has been reduced as
a screen for determning the cost-effectiveness of a program because it
looks only at rate impacts rather than a comprehensive view that includes
benefits from a measure or program including bil reductions.
We are pleased to see provision Number 7 in the MOU in support of
expenses without direct energy savings. The Coalition believes that utility
driven education, outreach and market research are critical to the success of
a utilty's full portolio of offerings as well as individual programs. And
finally, we recommend the Commission, Idaho Power and other interested
pares look to the Northeast Energy Efficiency Partership's EM&V Forum
for protocols and information that can help improve this effort -
http://neep.org/emv-forum/about -emv-forum.
Thank you for the opportunity to provide these comments. As the process
for further refining the DSM reporting and evaluation template goes
forward, the Coalition would like to partcipate in a more active maner.
Particularly around the items raised by PUC sta as to their expectations
outlined in Attachment No. 1.
Sincerely,
~~
Nancy Hirsh
Policy Director
811 First Ave., #305
Seattle, W A 98119