20141222SRA Comments.pdf

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December 22,20t4
To: Idaho Public Utilities Commission
From: Ken Miller, Clean Energy Program Director, Snake River Alliance
Re: IPC-E-I 4-38 - Snake River Alliance Comments In the Matter of The Application of Idaho Power
Company For Authority to Fund Its Continued Participation in the Northwest Energy Efficiency Alliance
Through the Energy Efficiency Rider for the Period 20L5-20L9.
0n behalf of our members throughout Idaho Power's service area and pursuant to Commission Order No.
33185, the Snake River Alliance appreciates the opportunity to provide its comments on Idaho Power's
application to continue its funding of the Northwest Energy Efficiency Alliance (NEEA) through the
existing Energy Efficiency Rider.
The Application
As noted in the Commission's Order 33185, this is ldaho Power's fourth request to authorize its
continued participation in NEEA. In the prior three applications, the Commission deemed Idaho Power's
NEEA participation prudent. With some reservations as described more fully below, the Alliance believes
this instant application for continued NEEA participation, proposed to be funded by the Energy Efficiency
Tariff Rider, is also prudent and we recommend that the Commission approve Idaho Power's application.
Idaho Power asserts that its current application describes the main components of the NEEA Business
Plan for 2015-20L9. Idaho Power identifies the NEEA activities that the Company believes will benefit its
customers most, including: [1) Activities of the University of Idaho Integrated Design Lab; (2) Top Tier
Trade Ally Advanced Training; (3) Commercial lighting initiatives, (4) Residential retail product portfolio
and [5) Residential new construction. Idaho Power estimates its 5-year funding will be $13,450,835, or
8.97 percent of NEEA's $145-$165 million budget for 2015-20L9.
NEEA is a nonprofit entity funded by Northwest utilities, the Energy Trust of Oregon, and the Bonneville
Power Administration to promote energy efficiency throughout the Northwest through market
transformation initiatives and by leveraging its energy efficiency investments with those of its partner
funders. Idaho Power states in its application (P. 5) that the total resource cost target for NEEA's portfolio
is equal to or less than 3.5 cents per kilowatt-hour.
Box 425 | Pocareu-o, lD 83204 | 2C8.233.7212
WWW,SNAKER IVERALLIANCE.OFG
Box173'l I Borse,lD 83701 1208.344.S'161
NEEA is deservedly recognized for helping to secure significant energy savings since 1997.ldaho Power
states in its application (P. 2) that its participation in NEEA "enables it to influence the direction of
NEEA's activities to bring direct benefit to its customers. From 1997-2013, Idaho Power's allocated
portion of NEEA savings was246,7 53 megawatt-hours or 28.2 aMW."
Alliance Comments
Idaho Power's current application is distinguished from its prior NEEA funding applications in large part
by the Company's original plan to cease its NEEA funding - a stance the Alliance strongly opposed and
one that drew similar concerns by Idaho Power's regulators in both Idaho and Oregon. Idaho Power
acknowledges that its participation in NEEA delivers significant savings to its customers.
While we credit Idaho Power and NEEA with successfully negotiating elements of accountability resulting
in a Regional Energy Efficiency Agreement, we have been troubled by Idaho Power's initially balking at
continuing to fund NEEA. All Idahoans benefit from NEEA's innovative, market-transforming, energy-
saving programs regardless of which utility serves them. Until the Regional Energy Efficiency Agreement
was crafted, Idaho Power's approach was that it could better implement energy efficiency measures
targeted specifically to its customers. Still, the Alliance believed that severing its ties to NEEA conflicted
with the notion of a region-wide energy efficiency entity.
Idaho Power has chosen not to fund certain programs and activities:
- Existing building renewal and commercial real estate,$627,730;
- Industrial technical training,$t38,076;- Specific market transformation activities including marketing resources, market channel
development and stakeholder support and coordination fas defined in AppendixLZ of the NEEA
20L5-20L9 Business PlanJ for all initiatives, estimated at$794,388;
- Associated administrativeexpenses, $LLg,126.
Furthermore, as a condition of its continued NEEA participation, Idaho Power notes in its application (P.
8) that early termination of the agreement is possible in any of three instances: 1) If regulatory bodies
disallow recovery of expenses incurred in the Agreement; 2) "upon the implementation of restructuring
legislation or other legislation which eliminates the responsibilities of Idaho Power to provide benefits
under a public purpose charge;" and 3) if there is a change to NEEA Bylaws to which Idaho Power does
not agree.
We are not aware of any prospective legislation that would liberate Idaho Power from "responsibilities to
provide benefits of a public purpose charge," nor can we envision circumstances to trigger such
legislation.
In direct testimony (P. 3) Idaho Power Senior Vice President of Customer Operations Warren Kline said
that "ldaho Power can better leverage its market transformation investment by building on NEEA's
pooled resources suppliers, market research and program design in the four-state area." Mr. Kline further
stated (P. 4) that "ldaho Power's participation in NEEA enables it to influence the direction of NEEA's
activities to bring direct benefit to Idaho customers." We agree, and that being the case we were alarmed
when Idaho Power signaled its preference for an "a la carte" approach in which it decides which
programs to participate in through its funding as described by Mr. Kline (P. 5): "After several years of
discussion between Idaho Power and NEEA to develop a lower cost/higher value funding mechanism
failed to yield results, Idaho Power gave notice of it intent to cease participation once the 201,0-20L4
funding cycle ended." Mr. Kline added: "ldaho Power believed that some of the programs and services
offered under the NEEA funding model duplicated services that the Company could perform at a lower
cost of more effectively."
We are relieved that "multiple meetings were held between NEEA's executive team members and Idaho
Power representatives during20L3 to further explore Idaho Power's desire to optimize the value derived
from NEEA on behalf of its customers." Ultimately, those meetings and the NEEA Alternative Funding
Model Working Group Committee led to revisions to NEEA's Business Plan and funding model that were
acceptable to Idaho Power, which we believe is committed to a robust energy efficiency regime.
Conclusion
The Alliance has been and continues to be a strong supporter of NEEA's market transformation efforts,
which benefit all utiliry customers in the Northwest including those of ldaho Power. We are grateful that
Idaho Power was able to reconsider its earlier decision to withdraw its NEEA funding upon the end of the
20L0-2014 funding cycle. The Alliance appreciates this opportunity to provide its views on this important
issue, and we recommend that the Commission approve Idaho Power's application.
Respectfully submitted,
Ken Miller
Snake River Alliance
Hand Delivered
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, lD 83720-0074
Via Email
Lisa Nordstrom
Theresa Drake
Idaho Power Company
P0 Box 70
Boise, lD 83707-0070
[e-mail]
tdrake@ idahopower. com
Ken Miller
Clean Enerry Program Director
Snake RiverAlliance
P.O. Bo 773L
Boise,ID 83701
(z08l 344-eL6L
kmiller@ snakeriverall iance.org
HAnd Delivered
fean |ewell
Commission Secretary
Idaho Public Utilities Commission
4T2W.Washington St.
Boise,lD 83702