20111116Hirsh Rebuttal.pdf

Benjamin Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idaoconservtion.org
Ri:r!,l'ii-'ì-i~ C _,j .C ! V¡: fJ'
2!'¡.1.".\i ¡16 PM 4= 25
Attorney for the Idao Conservtion League, the NW Energ Coalition, and the Snake River Aliance
BEFORE TH IDAHO PUBliC UTIliTIES COMMISSION
IN THE MAlTR OF THE
APPliCATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND
CHARGES FOR ELECTRIC SERVICE
TO ITS CUSTOMERS IN THE STATE
OF IDAHO.
)
)
)
)
)
)
)
CASE NO. IPC-E-II-08
REBUTTAL TESTIMONY
NANCY HIRSH
November 16, 2011
1 Q. Pleas state your name and reasn for thi tesimony.
2 A. My name is Nancy Hirsh and I am the Policy Director for the NW Energ Coalition. I fied
3 diect testimony in this case on behalf of the NW Energy Coalition, the Idao Conservation
4 League, and the Snake River Allance - collectively the Conservation Paries - On October 7,
5 2011. I offer this rebuttal testimony to respond to the prefied diect testimony of Mr. Higgs of
6 the Kroger Company, and Dr. Readig of the Indusrial Cusomers of Idao Power, and Mr. Lobb
7 and Mr. English of the Idao Commission Staff.
8
9 Q. Pleas resnd to Mr. Higgins' diect testimony.
10 A. Mr. Higgs recommends the Commission reduce fundig for energy efficiency from the
11 curent rider level of 4.75% to 3.4%. Mr. Higgs explais that because the stipulation moves
12 $11.2 milion of demand response payments into base rates, the rider mus be reduced by an
13 equivaent amount to avoid "an unreasonable cost burden on customers."¡ He supports this
14 recommendation with two reasons. Fir, he calculates that applyig a 3.4% rider to the rate
15 increase proposed in the stipulation results in a $1.2 milion increase "relative to pro forma
16 levels.',i Second, Mr. Higgs compares a 3.4% rider to a selection of other western utilties.
17 Neither of these reasns is persuaive.
18 In regards to the level of fundig, Mr. Higgs does not provide any analysis of whether his
19 proposed level is sufficient to meet expected increass in progr activity levels to acquie cost
20 effective energy effciency on behalf of customers. Idao Power's 2011 IRP plans to increas
21 energy efficiency savigs by 15 - 17 aMW through 2021.3 Also, Mr. Higgs does not address the
¡ Higgs Direct at p. 5 In. 5-7.i Higgs Direct at p. 3 In. 11 - 18.
3 Idaho Power 2011 IRP, Table DSM-15 in Appendi C at page 77 (showig the annua forecastedoperational targets from all existing and new energy effciency progrs).
Case No IPC-E-11-08
11/16/2011
1 Hirsh, N. Di - Reb
Conservation Paries
$7,592,938 back balance of prudent DSM spendig Idao Power may recover for prior progrs.4
Nor does he acknowledge the expected increases in Evaluation, Measurement and Verication
efforts puruat to the 2009 Memoradum of Understandig. Instead of recognizing these
planned increases in funding needs, Mr. Higg's proposes to leave DSM fundig at 2010 levels.
Mr. Higg's comparson to other western utilties is not vaid as the sole basis to establish
fundig levels for Idao Power energy effciency programs. Instead, a vad process to establish
fundig levels must consider the potential for cost effective energy efficiency in the servce
terrtory. Comparng rider levels to other utilties without considerig the potential for cost
effective energy efficiency does not provide any useful insight to appropriate DSM fundig levels.
Q. Pleas respnd to Dr. Readig's diect testimony.
A. Dr. Readig states that reducing the rider level from the curent 4.75% to 3.8% "may be an
equitable and justifiable path," but then joins the Staff recommendation to reduce the rider to
4.0%.5 He provides two reasons for his recommendation, neither of which is persuaive. Mr.
Readig notes the Commission made a similar reduction in the Rocky Mountain Power 2010 rate
case. Also, Dr. Reading explais that because $11.3 milion in demand response costs maybe
moved into base rates the Commission should make a dollar for dollar reduction in the rider level
to avoid an overa increase in DSM fundig.6 Neither reason is persuaive.
Dr. Readig is correct that in Rocky Mountai Power's 2010 rate cae the Commission, in
it~ final order, reduced the rider level in concert with movig demand response incentives into
power costs. But the facts in this Idao Power case are distinct from that Rocky Mountai ca.
4 See Exhibit 802, Idaho Power's Response to the First Production Requests of the Idaho
Conservation League, N. w: Energy Coalition, and Snake River Allianæ at Request No 4a.5 Readig Direct at p. 31 In. 20 - p. 32 In. 3.
6 Readig Direct at p. 31 In. 11 - 17. Dr Readig refers to Idao Power's application for the $11.3
milion amount. The Stipulation fied in this case moves $11,252.265 in demand response
incentive payments into base rates.
Case No IPC-E-11-08
11/16/2011
3 Hirsh, N. Di - Reb
Conservtion Paries
The record in the Rocky Mountai case did not include any information about the level of DSM
fundig necess to support existing and planed new progrs. In contrast, my diect and
rebuttal testimony in this cas provides factua support to increase the overa size of the Idao
Power's DSM fundig pie by shifting some costs into rates whie maitaiing curent rider leveL.
Just like Mr. Higgs, Dr. Readig does not provide evidence that his recommendation
provides sufficient fundig to meet planned DSM progr activities. A dollar for dollar
reduction results in overal DSM fundig remaiing at 2010 levels despite plans to increase
progr activities identified in the 2011 IRP, increase EM&V, and recover the back balance owed
to Idao Power. In fact, Dr. Readig calculates that maitaiing the rider at 4.75% wil generate
an additional $7.5 milon for energy efficiency progrs. Ths is roughy equa to the remaiing
back balance owed to Idao Power--a balance customers pay a 1 % interest rate on.7
Dr. Reading's recommendation to reduce the rider level is not supported by persuaive
analysis nor is it in the public interest. In fact, Dr Readig's testimony provides another reason
for maitaining the curent rider level-it allows Idaho Power to collect the back balance so that
ratepayers do not incur a 1 % interest chage.
Q. Pleas respond to Mr. I.bb's diect tesimony.
A. Mr. Lobb recommends the Commission reduce the curent rider level from 4.75% to 4.0%
for two reasons. He explais that DSM fundig throug both bas rates and the tarff rider at
4.0% "wi be significantly greater than needed to support exising Company DSM progrs.''6 .
Mr. Lobb then defers to staff witness Donn English for thi analysis. I wil review Mr. English's
testimony later. Mr. Lobb also explais repeatedly that reducing the tarff rider "helps mitigate the
7 See Exhibit 802, at Request 4b.
8 Lobb Direct at p. 19 In. 25 - p. 20 In. 3.
Case No IPC-E-11-08
11116/2011
4 Hirh, N. Di - Reb
Conservtion Paries
increase in base rates(.)"9 Whe mitigating base rate increases is a laudable goal, reducing energ
efficiency fundig is not an appropriate means to achieve this end. As the Commission has stated
before energy efficiency fundig provides "powerful tools customers can use to mitigate the
impact of rate increases.''¡o Instead of reducing fundig for these tools, the Company's curent
application to retur $30 milion to ratepayers under the accumulated deferred investment tax
credits mechanism is an appropriate, and far larger, tool to mitigate base rate increases. II
Q. Pleas respond to Mr. Engli's diect testony.
A. Mr. English does provide some analysis to support the staffs recommendation to reduce the
rider level, but this analysis is not persuaive. The main flaw in Mr. English's analysis is that he
compares 2010 DSM fundig levels, not expense levels. Mr. English explais "Staff understands
the need to provide the Company with a consistent revenue stream to better match the expenses
charged to the Energy Efficiency Rider account."12 Movig demand response and custom
efficiency payments into base rates is a solid first step because it provides a means to track
revenues and expenses going forward for these programs. But maitaiing the rider at 4.75% is
another critical step to better match revenues with actua and expected expenses for cost effective
energy effciency and related activities.
Mr. English states in his testimony ((Idao Power has routinely spent more on DSM
programs than it has collected throug the DSM Rider."13 Despite this recognition, he then
calculates that, after removig expenses for demand response and custom efficiency inæntives,
9 Lobb Direct at p. 2 In. 15-17, p. 19 In. 17-18, p. 20 In. 11-14 and In. 19-23; English Direct at p.
6 In. 20 - 22.
10 Order No. 30560 at 6, IPC-E-08-03 (citing Order No. 29026 at 20)
II See Order No. 32394, IPC-E-11-22 Notiæ of Idaho Power's Application for an Extended and
Modifed Accunting Order to Amorize Additional Accumulated Deferred Income Tax Credits.
12 English Direct at p. 6 In. 9 - 12.
13 English Direct at p. 5ln 13-14.
Case No IPC-E-11-08
11116/2011
5 Hirh, N. Di - Reb
Conservtion Paries
the rider, in 2010, provided fundig of $18,159,357. But Idao Power spent over $26,000,000.14
Mr. English also notes severa additional expenses that wi be charged to the energy effciency
rider account, includig $8 million in the unrecovered back balance.ls Ths brigs the revenue
stream needed to match expenses to $34 milion jus to maitai 2010 progr levels.
Mr. English goes on to explai that a 4.0% would generate $34.8 milion in 2011.16 Ths
leaves roughy $800,000 in headroom for expected growth in cost effective DSM programs and
related activities. One area of growig costs is increasing levels of evaluation measurement and
verication. In response to discovery requests, the Staff states they ((lack sufficient information
from which to quatify the cost of retaiing a thid partyevaluator.',17 Idao Power intends to
increas spending on thid pary evauators by $145,000 in 2011.IS Mr. English properly notes
another source for growig costs--increasing paricipation in existing and new progrs identified
in the 2011 IRP .19 In a discovery response, the Staff explains that Idao Power has increased
progr expenses by $740,951 in only the first three quarter of 201 1.20 Furher, Idao Power's
2011 IRP plans to increase energy efficiency gains by roughy 15 aMW per year.21
Since the curent rider revenue does not match curent expenses that provided 21 aMW in
201022, maintaiing the rider at 4.75% in a critical step to providig a consistent revenue stream
to better match expenses chaged to the energy efficiency rider account. Any ((headroom" created
by the staff proposal is already swallowed by maintaining 2010 progr levels, returing the back
14 English Direct at p. 5 In 14-17.
15 Englsh Direct at p. 5 In. 5-7.
16 English Direct at p. 5 In. 17-18.
17 See Exhibit 803 Staff Respone to the First Production Requests of ICL, NWEC, and SNA at
Request No. 3c.IS See Exhibit 803 at Request No 2.
19 English Direct at p.5 In. 24 - p. 6 In. 6.
20 See Exhibit 803, at Request No 1.
21 Idaho Power 2011 IRP, Table DSM-15 Appendi C at p. 77 (showing the annua forecasted
operational targets from al existing and new energy effciency progrs)22 Idaho Power 2010 DSM Annual Report at p. 8 (system number).
Case No IPC-E-11-08
11116/2011
6 Hirsh, N. Di - Reb
Conservtion Paries
balance, increasing EM&V spendig, and supporting already incured and furher expected
program growth in 2011 and 2012.
Q. Do you have any concludig remarks?
A. The testimony of Mr. Higgs and Dr. Readig do not provide analytical or factua support for
their recommendations. The Staff witnesses do provide some analysis, but their recommendation
does not ((provide ample revenue for expansion of DSM progrs as claied by Mr. English, nor
is it ((significantly greater than needed to support existing Company DSM programs" as claied
by Mr. Lobb. Accordigly, the Commission should maitai the rider level at 4.75% as this level,
along with movig certai costs into base rates, does provide a consistent revenue stream to better
match forecated DSM expenses.
Case No IPC-E-11-08
11/16/2011
7 Hirh, N. Di - Reb
Conservtion Paries
Benjamin Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservation .org
Attorney for the Idao Conservtion League, the NW Energ Coaltion, and the Snake River Allance
BEFORE THE IDAHO PUBliC UTIliTIES COMMISSION
IN THE MAlTR OF THE
APPliCATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND
CHARGES FOR ELECTRIC SERVICE
TO ITS CUSTOMERS IN TH STATE
OF IDAHO.
)
)
)
)
)
)
)
CASE NO. IPC-E-11-08
REBUTTAL TESTIMONY
OF
NANCY HIRSH
EXHIBIT 802
Idao Power's Response to the First Production Requess of the Idao Conservation League,
NW Energy Coaltion, and Snake River Allce
November 16,2011
LISA D. NORDSTROM (IS8 No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS (lS8 No. 8718)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
.Inordstromcmidahopower.com
dwalkercmidahopower.com
jwilliamscmidahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MAnER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC )SERVICE IN IDAHO. )
)
)
)
)
)
)
CASE NO. IPC-E-11-08
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
IDAHO CONSERVATION LEAGUE,
N.W. ENERGY COALITION, AND
SNAKE RIVER ALLIANCE TO IDAHO
POWER
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Production Request of the Idaho Conservation League, N.W.
Energy Coalition, and Snake River Allance to Idaho Power dated October 25, 2011,
herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE. NW. ENERGY
COALITION. AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 1
REQUEST NO. .1.: Please provide the dollar amount Idaho Power has spent
each year on evaluation, measurement and verification of all Demand Side
Management programs for 2008, 2009, and 2010. Please include the total costs for
both internal and extemal reviews as well as labor, overhead, materials, and any other
expenses.
RESPONSE TO REQUEST NO. .1: In 2008, Idaho Power spent $86,856 on
third-part evaluations for its demand-side management ("DSM") programs. In 2009,
the Company spent $206,483 on third-party evaluations for its DSM programs, plus an
additional $139,034 on an energy effciency potential study. In 2010, as stated on page
11 of the Demand-Side Management 2010 Annual Report, the Company spent
$293,000 on third-part evaluations of its DSM programs. Only evaluation expenses for
studies conducted by third parties are directly tracked and accounted for in program
expenses.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY
COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 2
REQUEST NO.2: Please provide Idaho Power's most recently available
forecast of spending for evaluation, measurement and verification of all Demand Side
Management programs for 2011 and 2012.
RESPONSE TO. REQUEST NO.2: In 2011, Idaho Power forecasts that it will
spend approximately $438,000 on third-party program evaluations. In 2012, the
Company forecasts that it wil spend approximately $380,000 on third-part program
evaluations.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Jason 8.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY
COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 3
REQUEST NO.3: Please answer the following regarding Company's evaluation
plan for 2010-2012 found on pages 4-6 of Supplement 2 of Idaho Power's 2010
Demand Side Management Annual Report.
a. Does Idaho Power stil intend to follow the plan as described?
b. Would a reduction in the Energy Effciency Rider level change this
evaluation plan? If the answer is yes, please describe how so. If the answer is no,
please describe how the Company intends to adjust program budgets to maintain the
evaluation plan while stil acquiring all cost effective energy efficiency.
RESPONSE TO REQUEST NO.3:
a. Throughout 2010, Idaho Power made minor revisions to its evaluation
plan. In 2011, Idaho Power has made very few revisions to its plan and those revisions
served to broaden the scope of the evaluations. The Company does not plan any major
changes to the 2012 plan, but if any are anticipated, they wil be included in the
Company's Demand-Side Management 2011 Annual Report.
Program evaluation is an important facet of Idaho Powets DSM operational
activities. Idaho Power has increased the frequency and the breadth of evaluations
since the signing of the Memorandum of Understanding for Prudency Determination of
DSM Expenditures ("MOU"), which specifies the Idaho Public Utilities Commission
("Commission") Staff's expectations of utilties' evaluations. Idaho Power relies on
evaluations by third-party contractors, internal analyses, and regional studies to ensure
the ongoing cost-effectiveness and overall effectiveness of programs through validation
of program processes, energy savings, and demand reduction. The results of Idaho
Power's evaluation efforts are used to enhance or initiate program changes. Annually,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE, NW. ENERGY
COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 4
Idaho Power publishes its evaluation plan for three years in the Demand-Side
Management Annual Report, Supplement 2. As stated in Idaho Power's Demand-Side
Management 2010 Annual Report, on page 13 under "Program Evaluation": "Although
the evaluation plan is expected to be used for scheduling evaluations, the timing of
specific program evaluations wil be based on considerations of program evaluation
needs, and other relevant regional studies."
b. No. The level of Idaho Energy Effciency Rider ("Ridet') funding does not
and has not determined Idaho Power's level of spending and/or evaluation of its DSM
efforts.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Jason 8.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY
COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 5
REQUESTNO.4: Page 127 of Idaho Power's 2010 Demand Side Management
Annual Report indicates the Idaho Energy Efficiency Rider was underfunded by
$17,592,938. In Order No. 32331, the Commission found all 2010 DSM spending was
prudent.
a. What is the most recent balance in the Idaho Energy Efficiency Rider
account for expenses incurred in 2010 but yet to be recovered by the Company?
b. If ratepayers owe the Company for prudently incurred energy efficiency
expenses does the Company collect an interest charge on this amount? If so, how
much?
c. If ratepayers owe the Company money for prudently incurred energy
efficiency expenses does the Company plan to recover these funds in a single year or
over several years?
BESP()NSET()BEguEsr NO.4:
a. As of the end of 2010, the Idaho Energy Effciency Rider account
unfunded balance was $17,592,938. This balance was considered prudently incurred
by the Commission in Order No. 32113. Through Case No. IPC-E-10-27, Order No.
32245, Idaho Power was allowed to place $10 milion of this $17 milion of the Idaho
Energy Effciency Rider account unfunded balance from 2010 into the 2011 Power Cost
Adjustment ("PCA") for recovery. The amount included in the PCA is anticipated to be
fully recovered by the end of May 2012. The remaining prudently incurred Rider
expenses from 2010 of $7,592,938 wil be recovered by current year Rider funding.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE, NW. ENERGY
COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 6
b. Idaho Power is currently allowed to collect or pay 1 percent annual interest
on the balance of the Energy Efficiency account depending on whether it has a positive
or negative balance. Under Commission Order No. 32109, Idaho Power is directed to
collect andlor pay 1 percent annual interest on all customer deposits in 2011.
c. Although timely cost recovery for DSM expenses is one of Idaho Powets
goals, as a practical matter, this is somewhat diffcult. The Company's ultimate goal
with Rider funding is to match revenue with expenses over time. However, revenues
and expenses wil not match in a single year.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY
COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 7
REQUEST NO.5: Idaho Power's 2011 Integrated Resourc Plan forecasts
increasing energy effciency acquisitions from both existing and new programs or
measures. Please describe the method for quantifying these projections.
RESPONSE TO REQUEST NO.5: Idaho Powets methods of projecting future
energy effciency acquisitions from both existing and new measures are explained in
detail on pages 39-41 of the Company's 2011 Integrated Resource Plan. Copies of
pages 39-41 are attached.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 15th day of November 2~1.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY
COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER ~ 8
Benjamin Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservtion.org
Attorney for the Idao Conservtion Leage, the NW Energ Coaltion, and the Snake River Alance
BEFORE THE IDAHO PUBliC UTIliTIS COMMISSION
IN THE MAlTR OF THE
APPliCATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND
CHARGES FOR ELECTRIC SERVICE
TO ITS CUSTOMERS IN THE STATE
OF IDAHO.
)
)
)
)
)
)
)
CASE NO. IPC-E-11-08
REBUTTAL TESTIMONY
OF
NANCY HIRSH
EXHIBIT 803
Staff Response to the First Production Requests of ICL, NWC, and SNA
November 16,2011
DONALD L. HOWELL, II
KARL T. KLEIN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
POBOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NOS. 3366/5156
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
'~'J rw'." r;, 1\1 -: t '-j1".i.I" I..' , "
i I I- 1-'" I: 0 I2ul1 nO\ J Ti
I '
'\1'11 I'il i..
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY)
TO INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE IN IDAHO. )
)
)
)
)
)
)
CASE NO. IPC-E-1l-8
COMMISSION STAFF'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE IDAHO CONSERVA nON
LEAGUE, N.W. ENERGY
COALITION, AND SNAKE
RIVER ALLIANCE
The Staff of the Idaho Public Utilties Commission, by and through its attorneys of record,
Donald L. Howell, II and Karl T. Klein, Deputy Attorneys General, responds as follows to the Idaho
Conservation League, N.W. Energy Coalition and Snake River Allance's First Production Request to
Commission Staff.
REQUEST NO.1: Please refer to the Direct Testimony of Donn English, pages 5 - 6, where Mr.
English describes the Idaho Power's plans to increase energy effciency activities over 2010 levels.
Please quantify the cost of these increased energy effciency activities.
RESPONSE NO.1: Staff objects to the extent this request asks Staff to speculate. Stafdoe
not know which specific programs Idaho Power intends to implement, or which existing programs
Idaho Power intends to expand. Consequently, Staff cannot quantify the cost of increased
STAFF'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF ICL, NWEC AND SNA i NOVEMBER 15,2011
energy effciency activities. Subject to this objectiont Staff notes that financial information
provided to those present at the Octobe 14,2011 meeting of the Idaho Power Energy Effciency
Advisory Group inicates that Idaho Power ha currently expensed $3 I to 1 0,999 through
September 30,2011 on DSM compared to $35,370,048 for the same period in 2010. Further,
approximately $5. i milion of incentive payments made through the Company's Custom
Effciency program have been capitalized as a regulatory asset. Combining the expenses thrugh
September 30, 2011 with the amount capitalized indicate that Idaho Power has spent $36, i J 0,999 on
DSM through September 30, 201 I, which is $740,951 (2.1%) greter than the same period in 2010.
REQUEST NO.2: Please refer to Idaho Power's 2009 Demand Side Management Potential
Study.
a. Dos the Idaho PUC staff expect Idaho Power to acquire the economic potential for
energy effciency identified in this study?
b. If the answer is yes, please describe how setting the Energ Effciency Rider level at 4%
supports this expetation.
c. If the answer is no, please explain how the Idaho PUC Staff detennines if the Company
is fulfillng the Commissionts directive to acuire all cost effective energy effciency.
RESPONSE NO.2: Staff objects to the extent this request seeks previously unwrtten and
unpublished opinion or policy statements. See RP 225.0 i .a. Subject to this objection, Staff answers
this reuest's subpart as follows:
a. Staff has formed no such expetation. Rather, Sta expects the Company to abide by
Commission Ordr No. 32245, which state tht "Idaho Power should continue to
pursue all cost.effective DSM." See Order No. 32245 at 5.
b. Staf believes that setting the Energy Effciency Rider level at 4% provides the
Company with suffcient revenue to abide by Commission Order No. 32245.
Furtherore, per that Order, should Idaho Power identify additional cost effective
DSM programs, it should "continue to pursue all cost-effective DSM - even in excess
of Energy Efficiency Rider revenues." ld Thus, the Company may exceed the 4%
Rider fund revenue.
STAFF'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF ICLt NWEC AND SNA 2 NOVEMBER 15,2011
c. The Commission did not direct the Company "to acquire all cost effective energ
effciency." Rather, the Commission has direted that Idao Power "should continue
to pursue all cost-effective DSM." Staff believes the Company is making a goo-faith
effort at following the Commission's directive.
REQUEST NO.3: Please refer to Idaho's evaluation plan for 2010 - 2012 found on pages
4 - 6 of Supplement 2 of Idaho Power's 2010 Demand Side Management Annual Report.
a. Does the Idaho PUC Staff believe this evaluation plan is suffcient both in timing and in
the depth of each evaluation?
b. Does the Idaho PUC staff believe the Company should increas the use of third pary
evaluators?
c. Please quantify the Idaho PUC Stafrs understanding of the cost of retaining a third
party evaluator?
RESPONSE NO.3: Staff objects to the extent this request seeks previously unwntten an
unpublished opinion or policy statements. See RP 225.01.a. Subject to this objection, Staff answers
this requests subparts as follows:
a. Yes. Staff believes the Company's evaluation plan is suffcient becaus the plan is
generally consistent with the 2009 Memorandum of Understanding ("MOll) signed
by representatives from Idaho's three Investor Owned Utilties and Commission Staff.
b. Please see Attchment No. 1 of the MOU referenced in the response to Request No.
3(a) for Stafrs position on a utilty's use of third-party evaluators. A copy of the
MOU is attached to this response.
c. Staff lacks suffcient information from which to quantify the cost of retaining a third-
pary evaluator.
STAFF'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF ICL, NWEC AND SNA 3 NOVEMBER 15,2011
DATED at Boiset Idah, this /')l( day of November.
1U f;fL-
Karl T. Klein
Deputy Attorney General
Techical Staff witness: Rady Lobb
i:lIsç:preispip Il.8dkkkl staff respo to ot 1_3.do
STAFF'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF ICL, NWEC AND SNA 4 NOVEMBER 15,201 i
CERTIFICATE OF SERVICE
I hereby certify that on this 16th day of November, 2011 I delivered true and corrct copies
of the foregoing REBUTTAL TESTIMONY OF NANCY HIRSH to the followig via the method
of servce noted:
Han d delivery
Jean Jewell
Commission Secretar (Origial, nine copies, and one CD provided)
Idaho Public Utilties Commission
427 W. Washigton St.
Boise, ID 83702-5983
Electronic Mai Only:
Idaho Power
Lisa D. Nordstrom
Donovan E. Waler
Jason B. Wiliams
Idao Power Company
1221 West Idao Street
Boise, Idao 83707-0070
lnordstrom~idaopower.com
dwale~idaopower.com
lwiliams~idaopower.com
Dr. Don Readig
6070 Hil Road
Boise, Idao 83703
dreadi~mindsprig.com
IIPA
Eric L. Olsen
Racine, Olson, Nye, Budge & Baiey,
Charered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
elo~racinelaw.net
GregW. Said
V.P. Reguatory Affairs
Idao power Company
P.O. Box 70
Boise ID 83707-0070
gsaid~idaopower.com
Anthony Yankel
29814 Lae Road
Bay Vilage, Ohio 44140ton~kel.net
CAPAI
Brad M. Purdy
Attorney At Law
2019 N. 17thst"
Boise, Id 83702
bmpurd~hotmai.com
DOE
Steven A. Porter
Assistant Genera Counsel
Electricity and Fossil Energy
United States Deparment of Energ
1000 Independence Ave. SW
Washigton, DC 20585
Steven.porte~hq.doe.gov
ICIP
Peter J. Richardson
Gregory M. Adams
Richardson & O'lear, PLLC
515 N. 27th Street
Boise, ID 83702
pete~richardsonandolear.com
gre~richardsonandolear.com
Arthur Perr Bruder
Attorney -Advisor
United States Deparment of Energ
1000 Independence Ave. SW
Washigton, DC 20585
Arthur.brude~hq.doe.gov
IPC-E-11-08 1 Certificate of Servce
Mr. Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
detheridge~exeteraciates.com
Kroger
John R Hammond, Jr.
Batt Fisher Pusch & Alderman, LLP
U.S. Bank Plaza, 5th Floor
101 S. Capitol Boulevard, Suite 500
P.O. Box 1308
Boise, ID 83701
E-mai: jrh~battfisher.com
Kur J. Boehm
Boehm, Kurz & Lowr
36 E. Seventh St., Suite 1510
Cincinnati, OH 45202
KBoehm~BKLlawfrm.com
Micon
MarV. York, ISB No. 5020
Holland & Har LL
Suite 1400, U.S. Bank Plaza
101 South Capitol Boulevard
P.O. Box 2527
Boise, Idao 83701-2527
Myork~hollandhar.com
Thorvald A. Nelson
Mark A. Davidson
Holland & Har LLP
6800 South Fiddlers Green Circle, Ste. 500
Greenwood Vilage, CO 80111
Tnelson~hollandhar.com
Madavidson~hollandhar.com
Snake River Allance
Ken Miler, Clean Energy Progr Director
Snake River Allance
P.O. Box 1731
Boise, Idao 83701
Kmile~snakeriveralance.org
NW Energy Coalition
Nancy Hirsh, Policy Director
NW Energy Coalition
811 Fir Avenue, Suite 305
IPC- E-11-08
Seattle, Washigton 98104
Nan~nwenerg.org
Hoku Materials, Inc.
Dean J. Miler
McDEVITT & MILLR LL
420 East Bannock
Boise, Idao 83702
J oe~mcdevitt -miler. com
Heathe~mcdevitt -miler. com
Scott Paul, CEO
Hoku Materials, Inc.
One HokuWay
Pocatello, Idao 83204
Spaul~hokucorp.com
~~-
Benjamin J. Otto
2 Certificate of Servce