20130523ICL Comments.pdf

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Idaho Conservation League 0
1k)liox 844,Boise,11)83701 —
208,345.6933
May 22,2013
Idaho Public Utilities Commission
472 West Washington Street
Boise,Idaho 83702
Re:IPC-E-13-11,Custom Efficiency Incentive Payments Accounting Order
Commissioners,
The Idaho Conservation League (ICL)supports Idaho Power’s application.ICL maintains
that accounting for the Custom Efficiency program incentive payments as a regulatory asset with
a carrying charge set at Idaho Power’s authorized rate of return is a fair,just,and reasonable.
Further,this accounting treatment better aligns the Company’s economic incentives with this
Commission’s directive to pursue all cost effective energy efficiency.ICL looks forward to
addressing this proposal in a future rate case.
Beyond aligning the regulatory framework with the Commission’s policy directives,
accounting for Custom Efficiency payments as a regulatory asset relieves pressure on the energy
efficiency rider account.Returning to the system of collecting Custom Efficiency payments
through the Energy Efficiency rider will result in an underfunding of energy efficiency through at
least August 2014.’Because of this,ICL urges the Commission to increase the energy efficiency
rider concurrently with approving this application to a level sufficient to bring the account to
balance within one year.In short,ICL recommends the Commission align regulation with policy
and provide timely cost recovery for prudent energy efficiency measures.
Respectfully,
Benjamin Otto
Energy Associate
Idaho Conservation League
‘Idaho Power Application at Attachment 2.