20100423Comment (ICL).pdf

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PO Bo 84, Bo Il 83701
20345.6933
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iOin p,PR 23 AM t~5
Idao Public Utilties Commission
PO Box 83720
Boise) ID 83720-0074
Apri 23) 2010
RE: IPC-E-10-04: In the Matter of the Application of Idao Power Company for Authority to
Fund its Continued Participation in the Northwest Energy Efficiency Alance for the Period
2010-2014.
Honorable Commissioners)
Please consider the followig comments of the Idao Conservation League. As Idao's larest
state-based conservation organization) we represent over 9)500 members many of whom are
customers of Idaho Power. As customers of Idao Power and residents of the Northwest
generally) ICL and its members have a deep interest in promoting the efficient use of our energy
resources in order to protect clean air) water) and open space.
ICL supports the mission of the Northwest Energ Effciency Allance - to ((mobilze the
Northwest to become increasingly energy efficient for a sustaiable future.)) ICL appreciates Idao
Power's continued support for the market trasformation that NEEA works to achieve. By
workig at the upstream end of the energy marketplace) Idao Power) through NEEA) can capture
long-term gas in efficiency through improved appliance standads and buidig codes)
promoting new technologies and business practices) and supporting utilty based efficiency
programs. Whe attributing specific energy savigs arsing from these activities is dificult) ICL
believes that real savigs do occur. ICL applauds the Staff and Commission)s repeated explanation
that efficiency investments benefit al cusomers by avoidig costly new generation resources.
However) we also highight three issues we believe the Commission should address in this matter.
First) Idao Power requests to roughy double the amount of their contribution to NEEA. ICL
acknowledges this increase is based on the NEEA business plan) which Idao Power paricipated in
forming. However) ICL believes that as spendig rises so should the rigor of progr evauation)
measurement and verification. The Commission should require Idao Power to make publicly
avaable the third-pary management and fiscal audits discussed on page 14 of their Application
and page 3 of the Regional Agreement.
Second) in addition to the management and fiscal audits) the Commission should requie third
pary evauation) measurement) and verification of the projected energ savigs attributed to
Idaho from NEEA progrs. Whe ICL wholehearedly supports investments in energ
efficiency) these investments must result in cost effective energy savigs. Although not specificaly
an !ssue in this matter) ICL is concerned about the curent piecemeal approach to prudency
reviews.
Between 1997 and 1999) the Commission determined NEEA expenses were prudent followig
thid pary audits. See Order 27877 and 2821 1. For the years of 2000 throug 2004) the
Commission found the NEEA expenses prudent basd on what appears to have been detaied
analysis and documentation in the application. See Order 28333. For the years 2005 throug
2009) the Commission approved using Energ Effciency Rider funds for NEEA) but specificaly
did not make a prudency determination. See Order 29784. In the 2008 Genera Rate Case) the
Commision approved a stipulation that NEEA expenditures for 2002 throug 2007 were
prudent. See Order 30740. On March 15) 2010) Idao Power applied for a prudency
determination for funds sent durg 2008 - 2009) but the Commission ha yet to take any action
in this matter. See Case No. IPC-E-I0-09. ICL is concerned that since 1999, it seems that the
Commission has not requied thid pary verication of NEEA's energ savigs when makg
prudency determination. ICL believes that third pary veriication fosters public confidence and
support for energy efficiency investments and thereby addresses many of the concerns rased by
customers and other paries in this and related matters.
Thd, whie Idao Power intends to pay NEEA dues out of Energy Effciency Rider funds) the
application does not discuss how this wi affect other efficiency progrs. Staff comments that
Idao Power is "already obligated to paricipate)) in NEEA becaus this Commission has directed
them to purue all cost effective energ efficiency. One of the drvers causing the increase in
NEEA dues is the increased opportunities for cost effective effciency identified in The Northwest
Power and Planning Council 6th Power Plan. See NEEA 2010 - 2014 Business Plan) Appendi 6;
see also Application of Rocky Mountai Power to Increase the Customer Efficiency Servce Rate
at 14) Case No. PAC-E-I0-03.
ICL is concerned that the increas in fundig for NEEA may reduce the funds avalable for other
cost effective efficiency investments with more immediate impacts. If curent energy efficiency
fundig proves to be insufficient) Idao Power may seek an increas of the Energy Efficiency
Rider at a time when the public is faced with a myrad of other piecemeal rate increases. ICL
maitains that energy efficiency is the leas cost resource avaiable and believes Idao power should
focus investments in this sector. However, we are also cognizant of the ne~tive public reaction to
Idao Power's curent piecemeal rate fiings. Instead) ICL believes the Commission should require
Idao Power to address effciency in a comprehensive manner that includes the amount of the
Rider) prudency review of prior spndig, and examination of the entire suite of efficiency
progrs.
In closing, ICL reiterates our support for NEEA's market trasformation goals and encourages the
Commission to approve Idao Power's continued paricipation. We commend the Commission
for recognizing the vaue that all ratepayers receive from efficiency investments beyond any diect
paricipation in individua progrs. With these comments, ICL hopes to encourge a more
rigorous and comprehensive approach to effciency that fosters better public understandig
throug reliable verication and a holistic approach. We look forward to continuig to work with
Staff) the Commission) Idao Power) and other parties to aggessively pursue the least cost) least
risk resource avaiable - effcient us of our vauable energy resources.
Be jamin Otto
Energ Assciate) Idao Conservtion Leagu