20130820Comments.pdf

Benjamin I. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone]x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPTICATION OF IDAHO POWER
COMPANY FOR A DETERMINTION
OF 2OI2 DEMAND.SIDE
MANAGEMENT EXPENDITURES AS
PRUDENTLY INCURR-ED
tt:,t,,., l\ I !;. or-1 it.i l. .tI,'t:; j11,.1 -:.J I lj i.,j.J
BEFORT THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-I3-08
COMMENTS OF THE IDAHO
CONSERVATION TEAGUE
The Idaho Conservation League (ICL) recommends the Commission find prudent Idaho
Power's 2}l2Demand Side Management (DSM) expenses. Overall, the2012 DSM report
documents another year of delivering a broad array of cost effective energy efficiency and
demand response programs. ICL supports Idaho Power's efforts to add and remove measures and
programs in response to changing energy savings potentials, market penetrations, avoided costs
and consumer demands. ICL also notes that several DSM programs continue to be highly cost
effective - Energy House Calls with a TRC of 4.08, Rebate Advantage with a TRC of 3.51,
Custom Efficiency with a TRC of 2.10, and Easy Upgrades with at TRC of 3.47 . Idaho Power
should double efforts in these programs to achieve greater energy savings.
ICL has a few comments regarding Idaho Power's 2012 DSM report and this application.
Idaho Power identifies 481 A/C Cool Credit switches installed since the temporary
suspension of the program in December of 2012.' ICL agrees with the Company proposal to treat
these costs as essentially plant held for future use. The program continues to be cost effective,
deliver potential demand reductions, and is the most popular and recognized residential DSM
program. When the program returns these switches can deliver cost effective demand reduction.
1 Nemnich Direct at 15 - 17.
IPC-E-13-08
ICL Comments
August 20,2013
Idaho Power identifies two programs as not being cost effective during 2012,
Weatherization Assistance for Qualified Customers, operated along with the CAP Agencies, and
Weatherization Solutions for Eligible Customers for limited income customers.2 While post
program evaluations reduced the energy savings attributable to the programs, ICL believes Idaho
Power acted prudently in 2012. Mrs. Nemnich's testimony describes certain steps the Company
is taking to improve the program delivery and the energy savings estimate tools. ICL looks
forward to continuing to work with stakeholders to improve these programs target at customers
most in need of reduced energy bills.
While Idaho Power continues to operate cost effective DSM progftrms, ICL is concerned
about the Company's pursuit of all cost effective DSM based on certain actions during the 2012
program year. First, ICL is concerned with Idaho Power's abrupt decision to not participate in
the Northwest Energy Efficiency Alliance's (NEEA) upcoming budget cycle. NEEA continues
to deliver cost effective energy savings though complex, regional market transformation
programs. Despite repeated conversation through the Energy Efficiency Advisory Group, of
which ICL is a member, Idaho Power has yet to explain how the Company can deliver market
transformation in Idaho outside of NEEA's progftrms.
In a similar vein, ICL is concerned of reports that Idaho Power is hesitant to participate in
the Energy Efficiency Research Institute at Boise State University. Preforming and supporting
market transformation, research, and development is essential to closing the gap between Idaho's
cost effective energy efficiency potential and acquired savings. ICL urges the Commission to
affirm that supporting these DSM activities that lead to future energy savings is prudent.
ICL is also concerned by Idaho Power's suspension of cost effective demand response
programs. While ICL initially acquiesced in the suspension and participated in the suspension
docket, we believe the rush to suspend the programs was unnecessary. The implication of Idaho
Power's actions is that Demand Response programs are seen as expendable, able to be
eliminated at arry time, despite investing millions of ratepayer dollars to grow the system over
the past ten years. ICL will continue to work in good faith with the stakeholders in the current
workshops to revise the programs. However, ICL urges the Commission to affirm that cost
2 Nemnich at23 -27.
IPC-E-13-08
ICL Comments
August 20,2013
effective Demand Response programs are a prudent use of ratepayer funds and Idaho Power
should leverage the existing investment fully.
Idaho Power's suite of DSM programs continue to provide cost effective opportunities
for all ratepayers to participate in energy saving programs. ICL recommends the Commission
find Idaho Power 2012 DSM expenses as prudently incurred. ICL also urges the Commission to
reaffirm that non-programmatic energy savings through market transformation, research, and
development are an important part of a prudent suite of DSM activities. Also, ICL urges the
Commission to reaffirm that Idaho Power should continue to leverage the existing investment in
cost effective demand response progftrms.
Respectfully submitted this 2}th day of August 2013,
Benjamin J. Otto
Idaho Conservation League
IPC-E-13-08
ICL Comments
August 20,2013
CERTIFICATE OF SERYICE
I hereby certifr that on this 20 th day of August 20I3,I delivered true and correct copies
of the foregoing COMMENTS to the following persons via the method of service noted:
Hand delivery:
Jean Iewell
Commission Secretary (Original and,7 copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail:
Iulia A. Hilton
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
j hilton@idahopower. com
dockets@idahopower. com
Darlene Nemnich
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
ttatum@idahopower. com
Benjamin I. Otto
IPC-E-13-08
ICL Certificate of Service
August 20,2013