20100301SRA.pdf

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Jean Jewell
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From:
Sent:
To:
Subject:
kmiller~snakeriveralliance.org
Monday, March 01, 2010 8:04 AM
Jean Jewell; Beverly Barker; Gene Fadness
PUC Comment Form
A Comment from Ken Miller follows:
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Case Number: IPC-E-09-09
Name: Ken Miller
Address: Box 1731
City: Boise
State: ID
Zip: 83701
Daytime Telephone: [phone]
Contact E-Mail: kmiller~snakeri veralliance. org Name of Utility Company: Snake River Alliance
Add to Mailing List: no
Please describe your comment briefly:
March 1, 2010
TO: Jean Jewell, Commission Secretary
Idaho Public Utilities Commission Secretary
472 West Washington
Boise, ID 83702
FROM: Ken Miller
Snake River Alliance
Box 1731
Boise, 10 83701
Ph: [phone]
RE DOCKET IPC-E-09-09: IDAHO POWER COMPANY'S APPLICATION FOR A PRUDENCY DETERMINATION OF
ENERGY EFFICIENCY RIDER FUNDS SPENT IN 202-2007
COMMENTS FROM THE SNAKE RIVER ALLIANCE
Dear Ms. Jewell:
Please accept the following comments on behalf of the Snake River Alliance relative to the
Commission's docket, IPC-E-09-09.
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 efficiency programs offered by Idaho utilities and the Bonneville Power Administration;
and local, state, regional, and national policies and initiatives that advance sustainable
and affordable energy policies. The Alliance pursues these programs on behalf of its members,
many of whom are customers of Idaho Power Company. The Alliance also submits these comments
as an environmental representative to Idaho Power's Integrated Resource Advisory Committee
and as an observer of Idaho Power's Energy Efficiency Advisory Group.
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The Alliance supports Idaho Power's application and the February 2009 Stipulation filed by
Idaho Power and Public Utilities Commission Staff establishing the prudency of the use of
$14,657,971 in Energy Efficiency Rider funds incurred during the 2002-2007 period. The
Alliance also supports, in general, the Memorandum of Understanding that resulted from the
Oct. 5, 2009, demand- side management workshop that Staff hosted with Idaho Power
representati ves and an evaluation consultant. We believe every regulated utility is entitled
to a timely recovery of prudently incurred and independently evaluated, measured, and
verified energy efficiency expenditures.
While the Alliance supports the Company's application and the MOU, we remain curious about
the circumstances surrounding the workshop. To the best of our knowledge, the workshop that
included Staff and Company representatives was not an event that was open to the general
public. While we do not challenge the outcome, we were not aware that the workshop was taking
place and as a result do not have the benefit of assessing the interaction among workshop
participants. As one of Idaho' s nonprofit advocates for energy efficiency and related
policies, we would appreciate the benefit of being able to participate in further discussions
on this issue, should they arise.
Nonetheless, the Alliance continues to be a strong supporter of enhanced DSM programs among
Idaho's regulated utilities and to the extent that this MOU and Idaho Power' s commitment to a
more thorough annual accounting of its conservation programs provides a greater evaluation of
those programs, we see significant value in the agreement. We urge the Commission to embrace
the merits of independent evaluation, measuring, and verification protocols.
We also support adequate funding of our utilities' EM&V procedures. During the course of the
recently concluded Regulatory Assistance Project (RAP) workshops with Idaho Power and other
stakeholders, we were advised that Idaho Power dedicates an average of 1.5 percent of its DSM
budget to EM&V, while RAP representatives suggested an industry average is at least twice
that amount. We are not advocating a precise percentage of DSM funds that should be dedicated
to EM&V, but encourage the Commission to consider that question and whether the current
funding of this important evaluation is adequate. This issue is all the more pertinent in
light of recent increases in Idaho electric utility efficiency tariff riders and the
consequent increases in the rider accounts.
The Alliance is pleased to note the provisions in Section 5 ("Evaluation Section") of the MOU
and in particular the frequency of DSM program reviews, as well as Section 6 ("Program
Specific Section"). And we absolutely agree with the contents of Section 7 ("Expenses Without
Direct Energy Savings") and the ability of Idaho Power to recover as prudently incurred some
expenses that do not directly lead to energy savings. We believe expenses for education and
outreach, for example, are critical to informing Idaho Power customers about the availability
of DSM programs and ultimately the success of such programs.
If you have questions about these comments, please do not hesitate to contact me or the
Alliance at [phone].
Respectfully submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
Box 1731
Boise, 10 83701
kmiller~snakeri veralliance. org
cc via e-mail: Barton L. Kline, Idaho Power Company; Lisa D. Nordstrom, Idaho Power Company;
Ric Gale, Idaho Power Company; Theresa Drake, Idaho Power Company
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