20110921ICL Comment.pdf

Benjamin Otto (ISB# 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservation.org
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2011 SEP 20 PM 4: 52
UTi
Attorney for Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLIACTION OF IDAHO POWER )
COMPAN FOR THE APPROVAL OF )
AN ENERGY EFFICIENCY INCENTIVE )
AGREEEMENT BETWEN IDAHO )
POWER COMPANY AND THE IDAHO )
OFFICE OF ENERGY REOURCES )
CASE NO. IPC-E-1l-16
COMES NOW, the Idaho Conservation League ("ICL") in support of this application. The
Idaho Offce of Energy Resources ("OER") k-12 Energy Efficiency Project is a great success for
Idaho and its school children. As a member of the oversight board for this project, ICL
paricipated in its design and implementation. After conducting a thorough energy audit of
schools around the state OER wisely choose to distrbute the available fuds broadly by focusing
on upgrading the lighting in school buildings. As par of these energy audit OER contrctors
uncovered many examples of inadequate and poorly operating heating, cooling and ventilation
systems. Not only were these HV AC systems needlessly costing schools money in wasted
energy, they led to poor air quality in our children's classrooms. Going forward Idao must find
a means to rectify these know problems. ICL believes this agreement is a good star.
ICL's support for this application is premised on the following interpretation of the
proposaL. As OER invests in effciency upgrades at schools, they may become eligible for
incentive payments under Idaho Power progrms. OER wil deposit any incentives collected in a
dedicated account and earmarked for additional projects at public schools within Idaho Power's
1 September 20, 2011
service terrtory. Idaho Power wil hold the account and will not collect any caring charge or
administrative fee for doing so. Other than the 10% administrative fee collected by OER, they
wil invest all the federal fuds and any incentive amounts in effciency upgrades at public
schools served by Idaho Power. The only change ICL suggests is to cap OER's administrative
fee at some reasonable amount, such as $100,000 per year.
ICL does not believe this proposed strctue presents any problems of free ridership. The
initial investment of federal fuds is causing effciency projects to happen that would not have
otherwise. We know this because of the drastic cuts to school budgets recently. Any incentive
payments trggered by the initial investment wil be dedicated to additional efficiency projects at
schools above and beyond those projects fuded by the initial investment of federal fuds.
Again, because of tight school budgets, it is highly likely that additional effciency projects wil
not occur without some level of fuding support. Thus, the strctue of this agreement is causing
more energy efficiency to occur than would happen in the absences of the incentive payments.
This is a proper use of Idaho Power energy efficiency incentives. The k -12 energy
efficiency program includes a robust pre and post measurement of the cost effectiveness of each
project. Based on this analysis ratepayers and regulators can be confident the incentive
payments will be used for cost effective, and thus prudent, investments in energy effciency.
Also, since this spending wil occur in 2011 or later, all stakeholders wil have the opportity to
ensure the prudency of any investments in futue proceedings.
DATED this 20th day of September 2011.
Benjamin J. Otto
Idaho Conservation League
2 September 20, 2011