20100319Reply Comments.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 1 8
IDAHO BAR NO. 3283
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2m 0 ll~R '9 AM 9: 23
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
PRUDENCY DETERMINATION OF
ENERGY EFFICIENCY RIDER FUNDS
SPENT IN 2002-2007
)
) CASE NO. IPC-E-09-09
)
) REPLY COMMENTS OF
) COMMISSION STAFF
The Staff of the Idaho Public Utilties Commission, by and through its Attorney of
Record, Weldon B. Stutzman, Deputy Attorney General, submits the following reply comments.
Staff appreciates the thoughtful comments fied by the Snake River Allance, the
Northwest Energy Coalition, the Industrial Customers of Idaho Power (ICIP), and the Idaho
Conservation League. Staff believes the Stipulation, its attched Memorandum of
Understanding (MOU), and the filed testimony of Lynn Anderson sufficiently present Staffs
perspective on the issues in this case and that it is generally unecessary to restate Staffs
positions. Staff nonetheless wil briefly address ICIP's mistaken assertion that Staff is
recommending the Commission ". . . unconditionally approve the (MOU). . ." and that Staff
believes that compliance with the MOU is sufficient showing of demand-side management
(DSM) prudency.
In the opening paragraph of ICIP's March 1 filed comments, it ". . . urges the
Commission not to unconditionally approve the (MOU)." In support of its request, at the bottom
of page 3, it states that ". . . the (MOU) only contains weak requirements for the analysis of the
prudency of (DSM) expenditures. . . ." At the bottom of page 3 and top of page 4, ICIP states
REPL Y COMMENTS OF
COMMISSION STAFF 1 MARCH 19,2010
that Staff expectations include cost-effectiveness evaluations from different perspectives, but
does not require that DSM programs be cost-effective to receive Staffs support for prudency.
First, Staff does not request that the Commission approve the MOU. Second, the
MOU is not intended to serve as a prudency sufficiency tool. In other words, utility compliance
with the specific but limited requirements in the MOU wil not, by itself, result in a Staff
recommendation of a DSM prudency finding. Instead, Staff wil continue to examine the
prudency of all DSM expenditures including those for planing, implementing and evaluating
measures and programs. It is true that Staff does not require that all measures and programs
actually prove to be cost-effective after they are implemented in order for Staff to recommend
that they be found prudent. Instead, Staff requires that all measures and programs have a goal
and reasonable expectation of cost-effectiveness from each of three perspectives, i.e., total
resource, utility and paricipant. Staff recognizes that due to unforeseeable and constantly
changing circumstances not all prudently planed and implemented DSM programs wil work as
cost-effectively as originally expected.
Respectfully submitted this \ ~ day of March 2010.
J'Weldon B~to~
Deputy Attorney General
N:IPC-E-09-09 _Reply Comments _ ws Ja
REPL Y COMMENTS OF
COMMISSION STAFF 2 MARCH 19,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF MARCH 2010,
SERVED THE FOREGOING REPLY COMMENTS OF COMMISSION STAFF, IN
CASE NO. IPC-E-09-09, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
LISA D NORDSTROM
BARTON L KLINE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: InordstromßYidahopower.com
bklineßYidahopower .com
DARLENE NEMNICH
JOHN R GALE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dnemnich§idahopower.com
rgale§idahopower.com
~\:~
SECRETARY
CERTIFICATE OF SERVICE