20141222ICIP Comments.pdf

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Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N.27ft Street
Boise,ldaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
ere g@ richardsonadams. com
Attorneys for the Industrial Customers of ldaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF THE ) CASE NO.IPC-E-14-38
APPLTCATION OF IDAHO POWER )
COMPANY FOR AUTHORITY TO FUND ) COMMENTS OF THE INDUSTRIAL
ITS CONTINUED PARTICIPATION TN ) CUSTOMERS OF IDAHO POWER
THE NORTHWEST ENERGY )
EFFICIENCY ALLIANCE THROUGH )
THE ENERGY EFFICIENCY RIDER. )
)
Pursuant to Notice Application and Notice of Modified Procedure issued by the Idaho
Public Utilities Commission ("Commission") issued on November 26,2014, the Industrial
Customers of Idaho Power ("ICIP") by and through their attorney of record, Peter J. Richardson,
hereby provides the following comments. Idaho Power Company ("ldaho Power" or the
o'Company") seeks approval to continue its participation in the Northwest Energy Efficiency
Alliance (NEEA) through the energy efficiency rider for the 201 5-2019 period.
Idaho Power filed its Application on October 19,2014 seeking authority to continue
participation and funding of NEEA's 2015-2019 business plan. Idaho Power's share of the
COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
IPC-E-14-38
PAGE I
2015-2019 budgeted activities and associated administrative expenses is not to exceed
S13,450,835. fldaho Power Company Application, IPC-E-14-38, p.9.] The Company has
reached agreement with NEEA not to fund four specific programs; Industrial Technical Training,
Existing Building Renewal and Commercial Real Estate, Specific Market Transformation
Activities, and Associate Administration Expenses. Opting out of these four program reduces
Idaho Power's NEEA costs by $1,634,322 over the five year future period. Idaho Power's share
of funding NEEA is reduced by $614,393 annually for the 2015 - 2019 time frame over the
funding level for the past five years. [d]
Industrial Technical Trainins
The Company states it is opting out of NEEA's industrial technical training classes
because,
Idaho Power believes it can provide industrial technical training classes to its
customers at a lower cost than what NEEA can offer. The Company believes it is better
positioned to understand the profiles of its industrial customers than NEEA and can more
effectively promote training that is tailored to the specific needs of its industrial
customers. Idaho Power has established relationships with its industrial customers
through outreach by its Major Customer Representatives, its Energy Efficiency Advisory
Group ("EEAG"), its energy effrciency programs, and demand response program. [Direct
Testimony of Warren Kline, Idaho Power, IPC-E-14-38, p.l l.l
The firm providing the training for NEEA in the 2010 through2014 period was Ecova.
Ecova is a firm headquartered in Spokane, Washington that specializes in resource savings for its
clients. The firm was founded in 1996 by a group of ex-Washington Water Power account
executives. Through a series of mergers and acquisitions it is now a subsidiary of GDF Suez that
owns a significant share of the same French parent company, Suez Environmental, that owns
United Water Boise. The cost for the five year period 2010-2014 for NEEA's industrial
COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
rPC-E-14-38
PAGE 2
technical trainings and attendee fee subsidy was $986,658 including administrative and overhead
costs. For this five year period ldaho Power's share for the training was $317,554 with $145,010
paid directly to Ecova for attendee fee subsidies. There were 44 in-class training sessions over
the past five year period that included a total of 833 Idaho Power service area attendees. In
addition 30 webinars were offered with 127 participants from the Company's service area.
fldaho Power's Response to Staff s First Production Request No. I , IPC-E- I 4-38.]
Idaho Power has not yet established the topics, nor has it estimated number of
participants, for technical trainings for the five year period beginning in 2015. The Company
states it will not limit the number of seats (NEEA's trainings were limitedto 25 seats per
session) and will also link all related documents on ldaho Power's web site for customers to
view. The anticipated cost savings for providing the trainings is estimated to be $64,120 over the
years 201 5-2019. [Idaho Power's Response to Staff s First Production Request No. 9, IPC-E-14-
38.1
Conclusion
The ICIP believes technicaltraining is an important element in ldaho Power's
conservation portfolio. It has found the trainings valuable and applauds the Company's intention
to continue the program. The ICIP supports the Company leaving NEEA for this program and
providing the training itself rather than relying on NEEA. Idaho Power has a unique knowledge
of the industrial customers in its service territory and will be able to tailor the classes and
webinars to better address its customers' specific needs. Posting training materials and webinar
presentation on the Company's website will help provide a wide dissemination of the materials.
The ICIP believes limiting training sessions to 25 participants is too restrictive and concurs in the
COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
IPC-E-14-38
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Company's decision to remove the attendance cap. The ICIP looks forward, should the Idaho
Commission approve the Application, to participating in the technical training sessions provided
by ldaho Power.
CERTIFTCATE OF SERVICE
I hereby certify that on the22 day of December 2014, copies of the foregoing Comments
of the Industrial Customers of Idaho Power were hand delivered to:
Lisa Nordstrom
Theresa Drake
Idaho Power Company
l22l West Idaho
Boise, Idaho 83702
E-Mail:lnordstrom@ idahopower.com
tdrake@ idahopower.com
Qere, N)O,rtr)
Nina Curtis
Admini strative Assistant
COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
IPC-E-14-38
PAGE 4
zuCHAI(DSON ADAMS,
PeterS. Richardson on behalf of the
Industrial Customers of Idaho Power