20150507Comments.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
gre g@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
TN THE MATTER OF THE
APPLICATION OF TDAHO POWER
COMPANY FOR DETERMINATION OF
20 I 4 DEMAND-SIDE MANAGEMENT
("DSM") EXPENDITURE AS
PRUDENTLY INCURRED
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E.15.O6
COMMENTS OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER
COMES NOW, the Industrial Customers of ldaho Power ("ICIP") pursuant to that
Notice Application and Notice of Modified Procedure issued by the Idaho Public Utilities
Commission ("Commission") on April 14,2015, and hereby provides the following comments
on Idaho Power Company's ("Idaho Power" or the "Company") application for approval of
prudently incurred 2014 demand-side management ("DSM") expenditures. On March 13,2015,
Idaho Power filed its Application for an order designating $33,495,385 in demand-side
management expenses, including $25,554,688 in Idaho Energy Efficiency Rider ("Rider")
expenses and $7,940,697 in demand response program expenses as prudently incuned. If the
Commission finds the DSM expenses are prudently incurred, it should allow the Company to
COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
rPC-E-15-06
PAGE 1
recover the expenditures in customer's rates. On the other hand, any imprudently incurred
expenses should be disallowed and those costs bome by the utility's shareholders.
COMMERICAL AND TNDUSTRIAL ENERGY EFFECIENCY PROGRAMS
The ICIP have participated in and encouraged Idaho Power's energy efficiency programs
("E8") in the past and support and encourage continuance of the programs in the future. The
commercial and industrial demand-side programs are not only important to ICIP members, but
also for the conservation efforts of the Company as a whole and all of its rate payers. Idaho
Power's Application states the primary driver for the 33 percent increase in energy savings, on a
system wide basis, for 2014 over 20131 was in the industrial sector.
6. On o system-wide basis, Idaho Power achieved i,38,670 megawatt-hours (.MWh") of
incremental annual energ/ efficiency savings in 2014. This value includes I18,670 MWhfrom
Idaho Power's energl fficiency programs and an estimated 20,000 MWh of energt fficiency
market transformation savings through NEEA initiatives. The increase in the 2014 savings was
driven primarily by industrial sector program savings and to a lesser degree from the residential
sector.2
Forthe Commercial and Industrial classes combined, (Schedules7,9, and l9) energy
efficiency progftrm expenditures totaled $11,582,269 which purchased a total energy savings in
the amount of 78,939,605 kwh.3 Therefore the Commercial and Industrial classes were 57%o of
total EE expenditures but contributed 66oh of the energy savings.
Among the Commercial and Industrial EE programs, in terms of energy savings, the Custom
Efficiency progftrm was by far the most successful. It had the largest energy savings in20l4
with 50,363 MWh (the next highest program was Easy Upgrades with l9,l l8 MWh).4 Custom
Efficiency was also one of the most cost effective programs on Idaho Power's system.
' Direct Testimony of Idaho Power witness Darlene Nemnich, p. 3.' Idaho Power Application, IPC-E-15-06, p. 3, citations omitted.
' Idaho Power 2014 DSM Annual Report, Table 2, p., 12.n Id, at Table I l, p. I l.
COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
IPC-E-ls-06
PAGE 2
Idaho Power applies four Cost/Benefit (C/B) measures to the MWh savings to determine the
cost effectiveness of each progftrm in the Company's DSM portfolio. Custom Efficiency is one
of only three programs, along with the lrrigation Efficiency and Home Products programs, to
have all four C/B measures (UC, TRC, PCT, RIM) greater than one. Thus, by any test used, it is
cost effective. Of the three programs with all four measures over 1.0, the Custom Efficiency
saves by far the most energy on a MWh basis with 50,363 MWh, verses Irrigation Efficiency
with 18,464 MWh, and Home Products with 652 MWh.s
Therefore, the energy effrciency program offered by tdaho Power to the ICIP members, as
well as other business customers, has been shown to the most effective in terms of the amount of
electric power saved in a cost effective manner. The ICIP appreciates Idaho Power's efforts with
these programs and encourages the Company to not only continue but expand these types of cost
effective energy conservation programs.
THE DSM RIDER PROJECTED SURPLUS
According to the testimony of Company witness Darlene Nemnich, the adjusted Energy
Efficiency Rider balance, as of December 31, 2014, is a negative $781,078.6 This balance is the
result of 2014 collections, with interest, of $38.1 million, expenditures of $25.6 million, and the
Commission authorized transfer of $20.0 million to the 201412015 PCA. At the current level of
Rider accrual and rate of DSM expenditures, the Rider account will end 2015 with a surplus of
$l1.7 million.
This surplus in the account is becoming an ongoing pattern. In Case No. IPC-E-14-05
(201412015 PCA) the Company projected, "an estimated surplus of $9.8 million at May 31,
2Ol5- .7 The 2015 estimated surplus is nearly $ 12 million. This pattern should concern the
Commission. Chronic surpluses (or deficits for that matter) suggest there are systemic problems
in management of the funds. If there are more cost effective DSM opportunities available, then
the ICIP encourages the Company to acquire those opportunities with the funds it has been
entrusted for those purposes. The ICIP is willing to work with the Company, the Commission
5 lbid, Supplement l, Table 3, p. 13.
6 Nemnich, DI Table 7, p. 18.
7 Direct Testimony of Idaho Power witness Timothy Tatum, IPC-E-14-05, p.27 .
COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
IPC-E-15-06
PAGE 3
Staff, and other stake holders to pursue additional cost effective DSM programs.
RESPECTFULLY SUBMITTED this Tthday of May 2015.
RICHARDSON ADAMS, PLLC
Peter J. Richardson on behalf of
the lndustrial Customers of ldaho Power
CERTIFICATE OF SERVICE
I hereby certify that on the 7th day of May 2015, copies of the foregoing Comments of
the Industrial Customers of Idaho Power in Docket No. IPC-E-15-06 were hand delivered to:
",PN{)tfu
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, ID 83702
botto@idahoconservation. org
Lisa Nordstrom
Idaho Power Company
1221 West Idaho
Boise,Idaho 83702
[e-mail]
[e-mail]
Darlene Nemnich
Idaho Power Company
P.O. Box 70
Boise,Idaho 83702
dnemnich@idahopower. com
Karl Klein
Deputy Attorney General
Idaho Public Utilities Commission
47 2 W est Washington (83 702)
P.O. Box 83702
Boise, Idaho 83720-007 4
[e-mail]. gov
Administrative Assistant
COMMENTS OF THE TNDUSTRIAL CUSTOMERS OF IDAHO POWER
IPC-E-15-06
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