20151023Replacement page 9.pdf

3Iffi*.
An IDACORP Companv
October 21,2015
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-15-19
2015 Integrated Resource Plan - ldaho Power Company's Replacement
Page 9 to Reply Comments
Dear Ms. Jewell:
On October 1 9, 2015,ldaho Power Company ("ldaho Powe/' or "Company") filed its
Reply Comments in the above matter with the ldaho Public Utilities Commission
("Commission"). lt has come to ldaho Power's attention that a citation was inadvertently
omitted on page 9 of its Reply Comments. The Company believes thatthe omission of this
citation led some stakeholders to believe that ldaho Power had changed its policy to
pursue all cost-effective energy efficiency. The Company's position has not changed and it
will continue to pursue all cost-effective energy efficiency. ldaho Power does not and has
not viewed the achievable potential as a "ceiling" for the pursuit of cost-effective energy
savings and will continue to pursue energy efficiency beyond the achievable potentialwhen
possible.
To correct this omission and prevent any potential confusion, ldaho Powerwishes to
replace page 9 of its Reply Comments with the enclosed page. A redlined version of page
9 with the citation is also enclosed for the Commission's and parties'ease of reference.
Therefore, enclosed please find an original and seven (7) copies each of clean and
redlined versions of replacement page 9 to ldaho Power's Reply Comments.
PIease do not hesitate to contact me if you have any questions regarding this
matter.
Very truly yours,
Rrch lv[,*
20tIOCT 2l Pl'l tr: 53
u r r Lir+frsci'b"*i* i l, u' o *
LISA D. NORDSTROM
Lead Counsel
LDN:csb
Enclosures
cc: Service List (w/encls.)
X;* &.v(wl-t -r*,---,
1221 W. ldaho St. (83702)
PO. Box 70
Boise. lD 83707
Lisa D. Nordstrom
signed by Staff and ldaho's investor-owned utilities in January ol 2010 and Order No.
28894 by using the TRC for cost-effectiveness. Additionally, the OPUC directs program
administrators to use the TRC in determining cost-effectiveness of energy efficiency
programs. Order No. 94-590 at 14. Because the IRP addresses system-wide planning,
it would not be prudent to determine two levels of cost-effective energy efficiency
between ldaho and Oregon. More importantly, the IPUC has not precluded the use of
the TRC for determination of cost-effectiveness. The Company believes that in using
the TRC to determine cost-effectiveness, the 2014 Energy Efficiency Potential Study
identified an appropriate level of cost-effective energy efficiency and is compliant with
commission orders in Oregon and ldaho.
ICL disagrees with the level of energy efficiency used in setting the load and
resource balance. ln its Comments, ICL states that ldaho Power could identify the
amount of efficiency between the achievable and cost-effective (economic) level and
that is the amount of energy efficiency the Company should strive to acquire. ICL
Comments at 6.
Not all cost-effective energy efficiency is achievable. There is some leve! of
energy efficiency measures that, regardless if they are cost-effective, will not be
adopted by everyone. ldaho Power believes that the achievable potential as
determined by AEG is just that, achievable, or jthe upper limit for cost-effective energy
efficiency savings."' There is no more "achievable" energy efficiency that is still cost-
effective. Additional energy efficiency potential is a dynamic metric. lf the cost of
acquiring a cost-effective resource increases, it can become no longer cost-effective.
!n its Comments, ICL encourages ldaho Power to improve program design,
marketing, and customer engagement to go beyond the achievable energy efficiency
1 American Council for an Energy-Efficient Economy ("ACEEE"). August 2014 report, "Crackinq
the TEAPOT: Technical. Economic. and Achievable Eneroy Efficiency Potential Studies," paoe 8.
IDAHO POWER COMPANY'S REPLY COMMENTS - 9 REPLAGEMENT PAGE
signed by Staff and ldaho's investor-owned utilities in January of 2010 and Order No.
28894 by using the TRC for cost-effectiveness. Additionally, the OPUC directs program
administrators to use the TRC in determining cost-effectiveness of energy efficiency
programs. Order No. 94-590 at 14. Because the IRP addresses system-wide planning,
it would not be prudent to determine two levels of cost-effective energy efficiency
between ldaho and Oregon. More importantly, the IPUC has not precluded the use of
the TRC for determination of cost-effectiveness. The Company believes that in using
the TRC to determine cost-effectiveness, the 2014 Energy Efficiency Potential Study
identified an appropriate leve! of cost'effective energy efficiency and is compliant with
commission orders in Oregon and ldaho.
ICL disagrees with the level of energy efficiency used in setting the load and
resource balance. !n its Comments, lCL states that ldaho Power could identify the
amount of efficiency between the achievable and cost-effective (economic) level and
that is the amount of energy efficiency the Company should strive to acquire. ICL
Comments at 6.
Not all cost-effective energy efficiency is achievable. There is some level of
energy efficiency measures that, regardless if they are cost-effective, will not be
adopted by everyone. ldaho Power believes that the achievable potential as
determined by AEG is just that, achievable, or "the upper limit for cost-effective energy
efficiency savings."l There is no more "achievable" energy efficiency that is still cost-
effective. Additiona! energy efficiency potential is a dynamic metric. lf the cost of
acquiring a cost-effective resource increases, it can become no longer cost-effective.
In its Comments, ICL encourages ldaho Power to improve program design,
marketing, and customer engagement to go beyond the achievable energy efficiency
1 American Council for an Energy-Efficient Economy ("ACEEE"), August 2014 reporl, "Cracking
the TEAPOT: Technical, Economic, and Achievable Energy Efficiency Potential Studies," page 8.
IDAHO POWER COMPANY'S REPLY COMMENTS - 9 REPLACEMENT PAGE
I HEREBY CERTIFY that on this
correct copy of REPLACEMENT PAGE
COMMENTS upon the following named
addressed to the following:
Commission Staff
KarlT. Klein
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Wash ington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Idaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
Snake River Alliance
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
Sierra Club
Zack Waterman, Director
Sierra Club
503 West Franklin Street
Boise, ldaho 83702
CERTIFICATE OF SERVICE
21't day of October 2015 I served a true and
9 TO IDAHO POWER COMPANY'S REPLY
parties by the method indicated below, and
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Email [e-mail]
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CERTIFICATE OF SERVICE