20110627IIPA Comments.pdf

IDAHO IRRIGATION PUMPE~SEIVED
ASS 0 C I A T ION lOll JUH 24 PH 3: 15
P.o. BOX 2624
1109 W. MAIN, SUITE 300
BOISE, IDAHO 83701-2624PHONE: [phone] FAX: [phone]
June 24, 20 i 1
Jea D. Jewell, Secreta
Idao Public Utilties Commssion
472 West Washigton Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E- i 1-05
Prudency Deteination of Energ Effciency Rider Funds Spent in 20 10
Dear Ms. Jewell:
Idao Irgation Pupes Association (IA) represents individuals, corporations, associations and
businesses intested in providig an inexpensive, reliable electrical supply for Idaho's irrgators.
We appreciate tlis opportty to comment on Idaho Power Company's Application for a Pruency
Detennination of Energy Effciency Rider Funds Spent in 2010.
Idaho Power consistently identifes two objectives for its demad-side maagement (DSM)
programs: achieving all prudent cost-effective energy effciency and demand response to meet its
energ and demand needs; and, (2) providing customers with programs and inonnation to mange
their energy usae.
The company estimates that DSM in 2010 provided about 336 megawatt (MWs) ofload reduction,
alost twce the capacity of its Benett Mountain peaker plant near Mounta Home, Idaho. In its
20 1 1 Inegrated Resource Plan Public Dra, Idaho Power states that "the value of reduced demand
compared with buidig a supply-side capacity resource is nearly twce the value of the cost to nm
the programs." lI A believes such a ret on investment is a prudent use of Rider fuds.
Irgators parcipate in two DSM programs: Irgation Peak Rewards and Irgation Peak Effciency.
Irgation Peak Rewards reduced summer peak by almost 250 megawatts in 2010. The total progra
cost is 'estited at $13 millon of which $1 1 millon was paid in incentives. Irgation load control
provides signficant benefits to Idao Power, but also accounts for signficant cost. We believe that
the benefits of the progr extend beyond the írgators to all ratepayers, the company and
shareh Iders. This progr grew in 2009 and 2010 as IIPA and the company worked collaboratively
to red sign a progr. lIA also believes that ths program has the potential to be more fully
utiliz .
-2-June 24, 2011
Whe IlA will not recommend to the Idao Public Utilties Commission a specifc amount of
expeditu that is prdent, we recognze Idaho Power Company's need to reover their pruent
DSM costs in a timely maner and ar concerned about deficits that may accumulate in tht account.
Timelr cost recover contrbutes to the fiancial well-being of the company.
DPA appreciats the opportty to submit these comments for consideation in ths cae.
,
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Sinc~ly your,~-\d/. -:-'; .. -? ---X /~'./ ~', ;n¿CL~!S..: Tom.inaga ~
J!cutive Diretor