20170110Comments.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 10177
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
H~CEIVED
7011 J,.;: 10 PH \: 30
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF )
IDAHO POWER COMPANY FOR AUTHORITY ) CASE NO. IPC-E-16-30
TO CONSOLIDATE ANNUAL REPORTING )
REQUIREMENT. ) COMMENTS OF THE
) COMMISSION STAFF
) __________________ )
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Camille Christen, Deputy Attorney General, and in response to the Notice of
Notice of Application and Modified Procedure issued in Order No. 33669 on December 13,
2016, in Case No. IPC-E-16-30, submits the following comments.
BACKGROUND
On November 23 , 2016, Idaho Power Company petitioned the Commission to amend
Order No. 29505 to change the requirement that the Company's Weatherization Assistance for
Qualified Customers (WAQC) report be filed separately from the Company's Demand-Side
Management (DSM) Annual Report, and to allow the Company to include this information in the
DSM Annual Report going forward. Petition at 1. The Company requests approval of this
proposal by February 1, 2017, with the consolidated reporting to begin with the March 15, 2017
DSM Annual Report. Id. at 4.
STAFF COMMENTS 1 JANUARY 10, 2017
The Company explains that in Order No. 29505 (Case No. IPC-E-03-13), the
Commission required the Company to file an annual W AQC report separately from the DSM
Annual Report. Id. at 2.
It is the Company's belief that the separate reporting requirement was imposed to allow
the Commission to more easily monitor the DSM and weatherization programs, which were
relatively small at the time of the Order, but expected to grow significantly. Id.
The Company states that since 1989, it has filed conservation or DSM reports that
included information on the weatherization program. Id. It has filed annual DSM reports since
2011, which include a W AQC chapter containing similar content to that provided in the annual
W AQC report. Id. The Company also states that the DSM and W AQC annual reports cover the
same annual reporting periods. Id. at 3.
The Company states that all W AQC reporting requirements established in Order No.
29505 will continue to be satisfied by including the W AQC information as part of the DSM
Annual Report. Id. The Company explains that consolidating the W AQC report information
into the DSM Annual Report will eliminate duplicative reporting and reduce costs .
The Company states that it has consulted with certain parties on the proposal to
consolidate the W AQC report into the DSM Annual Report, and that the parties (Commission
Staff, the Executive Director of the Community Action Partnership Agency of Idaho, and
members of the Energy Efficiency Advisory Group) were supportive. Id.
The Company requests to include the required W AQC report information in the DSM
Annual Report filed on March 15th each year, and to eliminate the requirement to file a separate
W AQC report ( currently filed on April 151). The Company requests approval of this proposal by
February 1, 2017, with consolidated reporting to begin in the 2016 DSM Annual Report to be
filed on March 15, 2017. Id. at 6, 7.
STAFF ANALYSIS
Staff agrees that the separate W AQC Report provides information currently included in
the DSM Annual Report and appreciates the Company's proposal to consolidate its WAQC
reporting in its DSM Annual Report. Staff believes that customers are best served by eliminating
redundant reports because it could reduce costs, while continuing to provide the same program
information specified in Order No. 29505.
STAFF COMMENTS 2 JANUARY 10, 2017
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's request to include the
required W AQC report information in the DSM Annual Report going forward, starting with the
2016 DSM Annual Report.
Respectfully submitted this I 0-r,,-day of January 2017.
Technical Staff: Stacey Donohue
Donn English
i :umisc/comments/ipce l 6.30ccsdde comments
STAFF COMMENTS 3
amille Christen
Deputy Attorney General
JANUARY 10, 2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10rn DAY OF JANUARY 2017,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-16-30, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
POBOX70
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets(iv.idahopower.corn
CERTIFICATE OF SERVICE