20150507SRA Comments.pdf

SNAKE FIIVEFIALLIANGE:,:
IErAHo's NUCLEAR \ruarcHDoG 8' CLEAN ENEFGY Aoro"+Tq. ,, ^ .,/-li'r t'rl ,':.,, r,:rt '- /
IPC-9,-15-06
From: Ken Miller, Clean Energy Program Director, Snake River Alliance
Re: Snake River Alliance Comments In the Matter of the Application of Idaho Power Company for a
Determination of 20t4 Demand-Side Management ("DSM") Expenses As Prudently Incurred.
On behalf of our members throughout Idaho Power's Idaho and Oregon service areas, the Snake River
Alliance appreciates the opportunity to provide its comments on the above-referenced case, filed with the
Public Utilities Commission ("PUC" or "Commission") on March L3,2015. These comments are submitted
to the Commission in response to its Notice of Application, Notice of Intervention Deadline, and Notice of
Modified Procedure, 0RDER N0. 33273.
The Alliance supports, without seeking modification but while desiring to bring certain issues to the
attention of the PUC, Idaho Power's application to recover its 20L4 DSM expenses as having been
incurred prudently and in the general interest of its customers.
The Alliance believes Idaho Power continues to make good progress toward the maturation of its DSM
programs, which were nearly non-existent at the beginning of this century. We recognize that ldaho
Power's DSM programs have been an important part of regional efforts in the Pacific Northwest to
achieve significant energy efficiency goals. There have been times, as recently as within the past decade,
when in our view Idaho Power's commitment to energy efficiency and demand response programs has
for good reason called into question.
The DSM Rider
The Alliance understands that in this docket the PUC may be asked to reduce the rate of bill-payer
collections through the energy efficiency rider (the "rider'). Should the Commission be asked to do so, we
urge it to resist such efforts because any reduction in the existing DSM rider is premature, as there is
much more room to improve and expand the Company's DSM programs. Keeping a positive balance in
the account allows for greater opportunities to increase energy efficiency on Idaho Power's system, and
therefore reduce the need to burn coal and natural gas.
Box425 | Pocareu-o,lD 83204 | ?C,A.?33.7212
WWW.SNAKEP IVERALLIANCE.ORG
I
Fi{ h: 2h
: rl. '.,". ,::,..r -L'.- i
May 7,20L5
To: Idaho Public Utilities Commission
Box1731 [ Borsr,lD 83701 I 208.344.9161
DSM rider balances rise and fall due to a number of circumstances, including but not limited to economic
conditions that impact overall electricity consumption and also improvements in the energy efficiency of
certain consumer appliances and other devices and, as we are witnessing, climatic changes that Idaho
Power and other Idaho electricity providers are experiencing nationwide, as Idaho Power acknowledged
in its most recent first quarter 2015 10-Q filing to the U.S. Securities and Exchange Commission:
"ldaho Power is also actively monitoring various pending environmental regulations, including the
U.S. Environmental Protection Agency's proposed rule under Section 111(d) of the Clean Air Act, that
may have a significant impact on its future operations. Given the uncertainties regarding the
outcome, timing, and compliance plans for these environmental matters, Idaho Power is unable to
estimate the financiol impact of these regulations but does believe thatfuture capital investmentfor
infrastructure and modificotions to its electric generating facilities to comply with these regulations
could be significont "
The Alliance has expressed appreciation for Idaho Power's acknowledgment of the impacts of pending
environmental regulations that will impact its operations. It is significant in this docket because these
impacts will be significant and programs such as the DSM programs Idaho Power is operating and plans
to develop in the future may reduce the company's exposure to risk resulting from forthcoming
environmental regulations.
Idaho Power Could Improve Customer Participation on DSM Issues
When Idaho Power was asked (pp. 33-34 - Direct Testimony, Darlene Nemnich) in her direct testimony,
"What opportunities exist generally for external parties to provide input and guidance to Idaho Power's
DSM efforts, Ms. Nemnich responded, in part:
"ln2002,ldaho Power created the EEAG to provide a forum to gather ideas and suggestions from
customers and special interest representatives about formulating and implementing DSM
programs. Members include customer representatives from residential, irrigation, commercial,
and industrial sectors, as representatives for senior citizens, limited income individuals,
environmental organizations, state Agencies, the Idaho Public Utilities Commission, the Public
Utilities Commission of Oregon, and Idaho Power..."
We believe Idaho Power's history with its DSM programs, its input from its EEAG, and input from this
Commission and from stakeholders has helped shape Idaho Power as a more forward-looking electric
utility on issues of energy efficiency and demand response, and bill-payers across its service territory are
realizing benefits as a result of its DSM efforts.
The Alliance's Ask to the Commission is to Protect Bill-Payers from Future Increases
As the Commission knows, one of the most important components of its energy program is how utility
and PUC decisions impact all bill payers. In that spirit we raise two points that we know the PUC is
already processing:
An efficiency rider balance can be high enough that it does what it was intended to do even in
Idaho - reduce revenues to a utility and thereby direct the utility to pursue a recovery mechanism
such as a fixed cost adjustment.
0r, that efficiency rider balance may be so low that it should actually be reduced to lower the
burden on customers.
We believe more can be done to inform Idaho Power customers about the company's DSM offerings, and
that those programs could be better conveyed to customers. We also believe the company has received
that message as a result of previous dockets, including in Order 33161 on November 4, 20t4, and the
Errata to Order No. 33161 issued on November 7,20L4.
It is not our goal to unwind what we believe is a compelling DSM prudency case by Idaho Power, and we
believe our Commission as well as ldaho Power agrees. The Alliance always appreciates an opportunity
to endorse the good efforts of ldaho's electric utilities. We once again appreciate the opportunity to
recommend approval of Idaho Power's application in this case, and also of its concerns about the long-
term impacts of any energy efficiency decisions we as a state make going forward.
Respectfully submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
P.O. Bo 1731
Boise,lD 83701
[phone]
[e-mail]
Hand Delivered
fean fewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise, lD 83702
Via E-Mail
Lisa D. Nordstrom
Idhao Power Company
PO Box 70
Boise, lD 83707-0070
f-rit,
Lnordstrom@ idahopower.com
Zachary L. Harris
Idaho Power Company
PO Box 70
Boise, lD 83707-0070
Email:
[e-mail]