20100319Comments.pdf

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Jean Jewell
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kmiller(§snakeriverallance.org
Friday, March 19, 2010 3:22 AM
Jean Jewell; Beverly Barker; Gene Fadness
PUC Comment Form
A Comment from Ken Miller follows:
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Case Number: IPC-E-09-28
Name: Ken Miller
Address: Box 1731
City: Boise
State: ID
Zip: 83701
Daytime Telephone: [phone]
Contact E-Mail: kmiller~snakeriveralliance.org Name of Utility Company: Idaho Power Add to
Mailing List: yes
Please describe your comment briefly:
March 19, 2010
TO: Jean Jewell
Idaho Public Utili ties Commission Secretary
472 West Washington
Boise, ID 83702
FROM: Ken Miller
Snake River Alliance
Box 1731
Boise, ID 83701
Ph: [phone]
RE DOCKET IPC-E-09-28: IDAHO POWER COMPANY'S APPLICATION FOR AUTHORITY TO CONVERT SCHEDULE 54
- FIXED COST ADJUSTMENT - FROM A PILOT SCHEDULE TO AN ONGOING PERMANENT SCHEDULE
COMMENTS FROM THE SNAKE RIVER ALLIANCE
Dear Ms. Jewell:
Please accept the following comments on behalf of the Snake River Alliance (SRA) relative to
the Commission's docket, IPC-E-09-28.
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 ini tiati ves 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 was granted intervenor status in this case in Order 30973.
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The Alliance supports Idaho Power's request to move its current Fixed Cost Adjustment (FCA)
program from its current pilot status to a permanent schedule. The experience with the
current FCA pilot has proven that such a decoupling of energy efficiency and possible
consequent reduced sales from Idaho Power's revenues is an effective mechanism to promote
energy efficiency by Idaho Power and its customers. We believe the nominal adjustments, or
true-ups, in residential and small-business rates are more than compensated by customers'
reduced energy use. While some have objected to this mechanism because an upward true-up in
rates appears to add to the utility bill, we believe that increase is more than offset by a
reduction in the bill due to the deployment of Idaho Power's demand-side management measures.
This is particularly the case in light of the recent increase in Idaho Power's energy
efficiency tariff rider to 4.75 percent. That Commission-approved increase has resulted in a
significant boost in Idaho Power's efficiency rider account and has spurred impressive growth
in the company's energy efficiency and demand response measures.
While the FCA and the decoupling of fixed costs collection from volumetric energy sales is
but one mechanism to encourage greater energy savings while protecting Commission-approved
utility revenues, we believe Idaho Power's experience with this pilot project has proven it
to be effective in capturing additional energy savings.
We also agree with Idaho Power's request that once the FCA mechanism is made permanent, the
FCA balances for residential and small commercial be separated and are treated as such for
purposes of the fixed - cost adj ustment rate.
Finally, the Alliance does not believe a formal hearing is necessary in this case.
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, ID 83701
kmille~snakeri veralliance. org
The form submitted on http://www . puc. idaho. gov /forms/ipuc1/ipuc. html
IP address is 70.102.111.178
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