20080519Snake River Alliance Comments.pdf

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May 15,2008
TO: Jean Jewell
Idaho Public Utilities Commission Secreta
472 West Washington
Boise,ID 83702
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FROM: Ken Miler
Snake River Allance
Box 1731
Boise,ID 83701
Ph: [phone]
RE DOCKET IPC-E-08-03: IDAHO POWER CO'S REQUEST TO INCREASE
THE COMPANY'S ENERGY EFFICIENCY TARIFF RIDER
COMMENTS FROM THE SNAKE RIVER ALLIANCE
Dear Ms. Jewell:
Please accept the following comments on behalf of the Snake River Allance relative to
IPC-E-08-03.
The Snake River Allance is an Idaho-based non-profit organization established in 1979
to address Idahoans' concerns about nuclear safety issues. In early 2007, the Allance
expanded the scope of its mission by launching its Clean Energy Program. The Allance's
energy initiative includes advocacy for renewable energy resources in Idaho; expanded
conservation and demand-side management programs offered by Idaho utilities and the
Bonnevile Power Administration; and local, state, regional, and national policies and
initiatives that promote sustainable energy policies. The Allance is pursuing these
programs on behalf of its members, many of whom are customers of Idaho Power, who
are interested in promoting energy conservation and efficiency initiatives. On behalf of
its members, the Allance has paricipated in multiple casès and workshops before the
Commission and its staff and has enjoyed a productive relationship with Idaho Power Co.
in recent years.
The Allance believes Idaho Power is on the proper path in expanding its energy
efficiency and demand-side management programs. We believe this application is
welcome, if somewhat overdue, and urge Commission approvaL.
The Company's Request
The Allance fully supports increasing Idaho Power's Energy Efficiency Rider from the
curent 1.5 percent to 2.5 percent of base revenues effective June 1,2008. We have
followed Idaho Power's DSM program over the past few years, although our history with
energy efficiency issues does not date to the company's program's inception in 2002.
Nonetheless, despite our impatience over the pace of these program developments in the
early years, we are mindful that Idaho Power, under the guidance of its Energy Effciency
Advisory Committee, has undertaken welcome expansion of existing programs and
implementation of new ones. The Company is to be congratulated for the maturation of
its DSM programs and for its curent proposal to enhance them. Nonetheless, the
Allance encourages the Company to more aggressively expand its programs to reach the
levels identified by the Northwest Power and Conservation CounciL.
As the Company prepares to update its 2006 Integrated Resource Plan and begin
preparations of its 2009 IRP, we expect significantly higher efficiency and conservation
opportities will be identified. That will only increase the need for additional fuding
and programs. We trust the Company and the Commission will be vigilant to anticipate
those coming needs well in advance so additional adjustments in the Rider level can be
made well before the DSM account is exhausted.
At curent fuding levels and the expansion rate of its programs, the Company will soon
exhaust funding for its programs. Consequently, the increase to 2.5 percent and the
additional fuding for the DSM programs are cntical and must be adopted in a timely
fashion. Even with this increase, however, the Company acknowledges that the DSM
account wil likely face a deficit of approximately $4.2 milion at the end of2010
(APPLICATION at P. 5), depending on when or whether labor, administrative and
Northwest Energy Efficiency Allance (NEA) contnbutions are removed from the Rider
account.
As the Commission is aware, implementation of all cost-effective energy efficiency and
conservation programs are core goals in the 2006 Idaho Energy Plan. Recommendation
E-l in the plan states: "All Idaho utilities should fully incorporate cost-effective
conservation, energy effciency and demand response as the prionty resources in their
Integrated Resource Planing." Approval of the Company request at issue here would
advance implementation of that recommendation.
Yet even with adoption of this 1 percent increase in the Rider and at the rate of
anticipated program expansion, the Company can be expected to once again face a
situation where new program development might be constrained for the lack of Rider
fuds.
Administrative Expenses
The Allance supports the Company's proposal to move the approximately $3.5 milion
in labor and administrative expenses from the DSM account to its rate base to fud labor,
NEEA payments and other costs not directly associated with DSM program development.
Members of the EEAG has recommended this action in the past, and we are pleased to
see the Company propose the transfer in its next general rate case.
Small-Scale Renewables Investments
The Allance supports the Company's proposal to invest some fuds in the DSM program
to support customer investments in renewable energy. As with the rider-funded efficiency
and DSM programs, these investments can reduce the total amount of energy consumed,
including peak demand, and reduce the need for additional resource acquisition or market
purchases.
The Allance's primary concern with this laudable recommendation is that new
investments in such programs as incentives for small-scale solar installations could
siphon scarce funds from the conservation and efficiency programs for which the DSM
rider was created. We would urge that such renewable energy investments - while
welcome and important - are not made at the expense of even more urgent investments in
conservation and effciency programs. We also agree that such investments would require
the Company "depar from its traditional cost-effectiveness critena for Rider-fuded
programs (TIMOTHY TATUM DIRECT at P, 17). Consequently, we would appreciate
the Company providing additional detail on the scope of eligible renewable energy
investments. While we ardently support renewable investments, it is importt that the
definitions for purposes of rider- fuded investments be limited somewhat so nder
collections from customers are not fuding resource investments that would be rate-based
or financed in other ways.
Combining Energy Effciency Rider and Fixed Cost Adjustment on Single Line Item
The Allance has no objections to the Company's proposal to combine these two
relatively small biling items. We assume the Company will adequately explain this
change on customers' bils to avoid confusion as to what constitutes "Energy Efficiency
Services" line item.
Conclusion
The Alliance congratulates Idaho Power and the Commission for recognizing the
importance of utilty DSM programs both to deliver economic benefits to consumers and
also to reduce the need for fuher traditional generation acquisition. Weare confdent the
Company is heeding the counsel of its EEAG - not to mention the desire among its
customers for more energy effciency and conservation measures. And we fully expect
that given the size of this increase at just 1 percent, the period of time between tanff
increases wil be far shorter than the four years that elapsed since the last increase.
Respectfully submitted,I£~~
Ken Miler
Clean Energy Program Director
Snake River Allance
Boise,ID
[phone]
kmilercmsnakeriverallance.org