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Home My WebLink About20120326Application for Funding.pdfNancy Hirsh RECEIVED NW Energy Coalition 2012 MAR 26 PM 3 37 811 lstAVC. Suite 305 Seattle, WA 98104 IDAHO PUB! lf-- UTiliTIES COMMISSION BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ) CASE NO. IPC-E-11-19 IDAHO POWER COMPANY FOR AUTHORITY) TO CONVERT SCHEDULE 54— FIXED COST ) APPLICATION FOR ADJUSTMENT - FROM A PILOT SCHEDULE ) INTERVENOR FUNDING FOR TO AN ONGOING PERMANENT SCHEDULE ) NW ENERGY COALITION The NW Energy Coalition ("Coalition"), pursuant to Idaho Code § 61-617A and IDAPA 31.01.01.161-165 submits the following application for intervenor funding. On November 29, 2011 in Order No 32402, the Commission granted the Coalition's request for intervention. I.Idaho Code § 61-617A and IDAPA Rule 31.01.01.161 Requirement Idaho Power Corporation, is a regulated public utility with gross Idaho intrastate, annual revenues exceeding three million, five hundred thousand dollars ($3,500,000.00). II.IDAPA Rule 31.01.01.162 Requirements 1.Itemized list of Expenses The attached Exhibit A is an itemized list of expenses incurred by the NW Energy Coalition in this proceeding 2.Statement of Proposed Findings The Coalition asks this Commission to approve Idaho Power's application to make the Fixed Cost Adjustment (FCA) mechanism permanent largely in its current form Also, the Coalition asks the Commission to grant this request for intervener funding to support the Coalition's efforts in reviewing the case, participating in the settlement negotiations and reply comments 3.Statement Showing Costs This application is to support the Coalition's efforts in reviewing the case, participating in the NW Energy Coalition -Intervenor Funding, IPC-E-1 1-19 March 22, 2012 settlement negotiations, and filing reply comments. The Coalition's Policy Director, Nancy Hirsh, reviewed the initial Idaho Power filing and testimony, traveled to Boise from Seattle to participate in the settlement discussions on January 27, reviewed production requests and initial comments from all the parties before filing reply comments on March 15. The Coalition requests $700.85 in intervenor funding, as shown in Exhibit A, for expert analysis time and travel costs. Both the hours expended and costs incurred are reasonable for this complex case. 4.Explanation of Cost Statement The NW Energy Coalition is a nonprofit organization supported solely through grants from charitable foundations and membership dues. The Coalition has eleven member organization's based and working in Idaho. In this proceeding, the Coalition represents the interests of these member groups in promoting energy efficiency throughout the Idaho Power service territory. The Coalition's Policy Director is based in our Seattle, WA office. 5.Statement of Difference The reply comments filed in this case demonstrate that the Coalition's proposed recommendation is different than the proposed finding of Commission Staff. The Coalition's reply comments raised concerns about the approach recommended by Staff as undermining the fundamental intent of the FCA mechanism. While Staff represented their modification as a modest adjustment to the FCA mechanism, the Coalition detailed why this "modest" change would in fact reduce recovery of fixed costs and maintain the incentive to sell more kWh. The Coalition's reply comments supported the comments filed by the Idaho Conservation League and the public comments submitted by the Snake River Alliance in that they found that the FCA mechanism should be made permanent as it is currently structured 6.Statement of Recommendation The Fixed Cost Adjustment (FCA) addresses a very specific problem - recovery of fixed costs is linked to sale of electricity, encouraging 'increased use and discouraging investments in energy NW Energy Coalition - Intervenor Funding, IPC-E-1 1-19 March 22, 2012 efficiency or any other program (like distributed generation) that reduces electricity throughput. By calculating the per-customer revenues needed to cover specific fixed costs, the FCA removes the disincentive for demand-side investments that help customers use less electricity. The FCA also helps ensure the Company's timely recovery of the fixed system costs regardless of sales volumes. 7. Statement Showing Class of Customer The Coalition has eleven member organization's based and working in Idaho In this proceeding, the Coalition represents the interests of these member groups in promoting energy efficiency throughout the Idaho Power service terntory. IN CONCLUSION, the NW Energy Coalition respectfully requests the Commission grant this application. DATED this 22th day of March 2012. Respectfully submitted, _A4 Nancy Hirsh Policy Director, NW Energy Coalition NW Energy Coalition - Intervenor Funding, IPC-E-11-19 March 22, 2012 EXHIBIT A Costs Associated with Nancy Hirsh, Policy Director, NW Energy Coalition Seventeen hours at $31.25 per hour = $531.25 • Review Idaho Power application and testimony 3 hours • Review IPC response to Commission Staff Production Request 1 hour • Meet with parties regarding settlement on January 29 2.5 hours • Review all party comments filed March 1 4 hours • Prepare and file Coalition reply comments 5 hours • Prepare Coalition application for intervenor funding 1.5 hours Total Hours 17.0 Travel from Seattle to Boise, January 26, 2012 - Settlement Talks with Commission Staff and all Parties $169.60 Total request for intervenor funding = $700.85 NW Energy Coalition - Intervenor Funding, IPC-E-11- 19 March 22, 2012 CERTIFICATE OF SERVICE I hereby certify that I have this 22th day of March 2012 served the foregoing APPLICATION FOR INTERVENOR FUNDING FOR THE NW ENERGY COALITION to the following via the method of service noted: Electronic Mail and Hard Copy: Jean Jewell Commission Secretary Idaho Public Utilities Commission 427 W. Washington St. Boise, ID 83702-5983 Electronic Mail: Jason B. Williams Lisa D. Nordstrom Michael J. Youngbood Zachary L. Harris Idaho Power Co. 1221 W. Idaho St. Boise, ID 83707 jwi!1iams,idahopower.com 1nordstrom(21idahopower.com myoungb!ood(2iidahopower.com zharris(à)idahopower.com Benjamin J. Otto Idaho Conservation League 710N. 6th St. Boise, ID 83701 botto(Ei)idahoconservation.org Richard E. Malmgren Sr. Asst. General Counsel Micron Technology Inc. 800 S Federal Way Boise, ID 83716 rema1mgrenmicron.com Thorvald A Nelson Frederick J Schmidt Brian T Hansen Mary V York Hol!and & Hart LLP 6380 S. Fiddlers Green Cir Suite 500 Greenwood Village, CO 80111 tne!son@hollandhart.com fschmidt@hollandhart.com bhansen@hollandhart.com myorkhollandhart.com lnbuchanan@hollandhart.com ------------------------ Nancy Hirsh NW Energy Coalition - Intervenor Funding, IPC-E-11-19 March 22, 2012