20170322Reply Comments.pdf

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An IDACORP Company
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LISA D. NORDSTROM
Lead Gounsel
[e-mail]
March 22,2017
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
47 2 W est Wash i ngton Street
Boise, ldaho 83702
Case No. !PC-E-16-33
Application for Authority to Revise the Energy Efficiency Rider, Tariff
Schedule 91 - ldaho Power Company's Reply Comments
Dear Ms. Hanian:
Enclosed forfiling in the above matter please find an originaland seven (7) copies
of ldaho Power Company's Reply Comments.
Very truly yourls,
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Re
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Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
Idaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom@idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
il::(lElVi:D
,,illlr',,i:i Pi1 h:25
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO REVISE TARIFF
SCHEDULE 91 - THE ENERGY
EFFICIENCY RIDER
GASE NO. |PC-E-16-33
IDAHO POWER COMPANY'S
REPLY COMMENTS
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ldaho Power Company ("!daho Powe/' or "Company") respectfully submits the
following Reply Comments in response to comments filed by the ldaho Conservation
League ('lCL') on March 14, 2017, and the ldaho Public Utilities Commission
("Commission") Staff ("Staff'), the ldaho lrrigation Pumperc Association ("llPA"), and the
City of Boise on March 15, 2017. ldaho Power appreciates the comments provided in
this case and notes that all parties to the case recommend that the Gommission
approve the Company's request to decrease the Energy Efficiency Rider Tariff ("Ride/')
percentage from 4.00 percent to 3.75 percent of base rate revenues, issue a $13 million
IDAHO POWER COMPANY'S REPLY COMMENTS. 1
refund of Rider funds to customers effective June 1, 2017, and eliminate the annual
transfer of $4 million of Rider funds to the PCA effective June 1,2017.
The Company's Reply Comments will respond to (1) the timing of the Rider
percentage change, (2) how rate stability was factored into the recommended change to
the Rider percentage, and (3) Staffs recommendation that the Commission order the
Company to present certain information to the Energy Efficiency Advisory Group
('EEAG").
I. IDAHO POWER'S RESPONSE
Effective Date of Rider Percentage Change
On page four of Order No. 33694, the Commission stated that after review of
Staffs suggested schedule, a March 1,2017, effective date "may not allow enough time
for adequate review and public participation," and suspended the proposed effective
date for "a period of thirty (30) days plus five (5) months."
ln their Comments, both Staff and llPA address the timing of the Rider
percentage change, suggesting effective dates of April 1, 2017, and June 1 , 2017,
respectively. While both ICL and the City of Boise's' comments support the Rider
percentage change, they are silent on the timing of when that change should occur. ln
its application, the Company stated its preference for an effective date of June 1,2017,
for the Rider percentage change; however, in acknowledgement of the views and
preferences expressed by the Parties, the Company agreed to recommend a March 1,
2017, effective date. ldaho Power continues to prefer the Commission issue an order
authorizing the Rider percentage change to take effect on June 1,2017, coincident with
changes resulting from the annual Power Cost Adjustment (.PCA"), Fixed Cost
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
Adjustment ("FCA"), the commencement of seasonal rates, and possible other
proposed rate changes that may occur on that date.
Rate Stability
On page two of its Comments, the llPA invited ldaho Power to address whether
rate stability was addressed in its modeling when determining the proposed Rider
percentage amount. ldaho Power is sensitive to rate stability for its customers and
believes it did appropriately consider this when establishing both the recommended
Rider percentage and one-time refund of Rider funds.
Since the inception of the Rider, ldaho Power has monitored the level of
collection through the rate mechanism with a goa! of matching the leve! of funding with
the level of energy efficiency expenditures over time. Consistent with that goal, the
Commission has authorized changes to the Rider percentage over the years and the
Company has been authorized to collect additional funding through the Company's
annual PCA to fund the Rider, as well as refund surplus Rider funds to customers
through the PCA. See Order Nos. 29026,29784,30560, 30814, and 32426.
As described more fully in its Application, the Company evaluated the forecasted
Rider collection, as we!! as the forecasted funding requirements for the Company's
demand-side management ('DSM') programs and activities for the 2017-2020 time
periods, and the Company believes the 3.75 percent Rider collection wil! adequately
mitigate the further accumulation of surplus Rider balances while still providing
adequate funding for the recovery of al! prudently incurred costs related to the pursuit of
cost-effective energy efficiency during those time periods.
IDAHO POWER COMPANY'S REPLY COMMENTS.3
Reporting of Rider Activity to EEAG
On page five of its Comments, Staff recommends the Commission issue an order
requiring ldaho Power to present to the EEAG, at each meeting, "cunent levels of tariff
Rider funding, expenses, forecasts, and balances." ldaho Power does not believe a
Commission directive is necessary as it already discusses the cunent level of the Rider
funding, expenses, and balances at each EEAG meeting. Attachment 1 to these Reply
Comments contains the 2016 Rider funding, expenses, and balance information that
was shared at the February 16,2017, EEAG meeting. Additionally, ldaho Power files
an update of year-to-date Rider activity with the Commission on a monthly basis; at the
request of Staff, the Company has filed this information voluntarily since May of 2013.
ldaho Power does not, however, regularly discuss its forecasted Rider funding
because this information may be considered confidential, material non-public financial
information that is subject to regulations on disclosure per the United States Securities
and Exchange Commission ("SEC"). By publically providing the forecasted Rider
funding and the Rider collection percentage, one could easily calculate ldaho Powe/s
forecasted revenues, which are confidential. !n order to discuss the type of information
Staff seems to be referring to with the EEAG, ldaho Power would be required, in each
and every meeting, to ask attendees to agree to confidentiality prior to discussing
forecasted funding, and Idaho Power and its employees could be exposed to risks of
disclosure violations under both insider trading and disclosure rules of the SEC. ldaho
Power believes this would be disruptive to the productive work that the Company relies
upon the EEAG for, such as input on enhancing existing DSM programs and
recommendations on implementation of new programs, measures or initiatives. For
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
those reasons, ldaho Power requests that the Commission not accept Staffs
recommendation for an additiona! Commission directive.
Notwithstanding the above, Idaho Power can assure the Commission and Staff
that it will continue to provide updates on the Rider funding, expenses, and balances at
each EEAG meeting. ldaho Power will also, per Staffs request, continue to voluntarily
send the monthly Rider Activity and Balance Report to the Commission so long as it
provides benefit. Further, while ldaho Power does not believe Staff realized it was
recommending that the Commission order ldaho Power to discuss confidential and
material non-public financial information with the EEAG, the Company believes it can
satisfy Staffs wishes by providing an annual update to the EEAG of the three-year
forecasted ending balance of the Rider, which would not need to be done confidentially.
If the EEAG agrees it wishes to see the information, ldaho Power will commit to
providing this information at the Fall EEAG meeting (typically held in November).
Lastly, ldaho Power wil! make the detailed forecasted Rider funding, spending, and
resulting balance information available confidentially to Staff at any time they wish to
review it, pursuantto ldaho Code S 61-610.
[. coNcLusroN
ldaho Power appreciates the opportunity to respond to comments filed in this
case and respectfully requests that the Commission issue an order approving its
Application with the modified Rider percentage change effective date of June 1, 2017.
DATED at Boise, tdaho, this 22nd day of March, 2017.
LISA D. NORDS
Attomey for ldaho
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
M
Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of March 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S REPLY COMMENTS upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Brandon Karpen
Deputy Attomey General
ldaho Public Utilities Commission
47 2 W esl Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho lrrigation Pumpers Association, !nc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
Anthony Yankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
Gity of Boise City
Elizabeth A. Koeckeritz
Deputy City Attorney
Boise City Attorney's Office
150 North Capito! Boulevard
P.O. Box 500
Boise, ldaho 83701 -0050
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IDAHO POWER COMPANY'S REPLY COMMENTS.6
berly Executive Assistant
BEFORE THE
IDAHO PUBLIC UTILITIES GOII'IMISSION
GASE NO. IPC-E-16-33
IDAHO POWER COMPANY
ATTAGHMENT 1
ldaho Power Gompany
ldaho Rider, Oregon Rider, and NEEA Payment Amounts (January - December 2016)
2016 Beginnirg Balance
2016 Funding plus Accnred lnteost as of 12-31-16
Tdal 2010 Fundr
2016 Expenseo as of 12-31-16
Rider Transbr to PCA (IPUC Order 33306)
Ending Balance ar of 12-31-21110
$(6,554,074)
(39,437,692)
('15,991,766)
31,291,579
3,970,036
$fi0,730,1sl)
2016 Beginning Balance
2016 Funding plus Accrued lntsr€st as of 12-31-16
Total 2016 Funds
2016 Expensos as of 12-31-16
Ending Balance as of 1281.mll6
$4,48,2,85
(1,099,211)
s
3,38:1,273
2,15&868
$5,552,1ttl
2016 NEEA Payments as of 12-31-2016
Total
$2,676.387
$2,t16,*7
" Liability Aci:ounts