20190409NW Energy Coalition Comments.pdf

Diego Rivas
NW Energy Coalition
l10l 8ft Ave
Helena, MT 59601
[e-mail]
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPAI\TY FOR )
AUTHORITY TO REVISE THE ENERGY )
EFFICIENCY RIDE& TARIFF )
SCHEDULE 91 )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC-E.19.06
COMMENTS OF THE
NW ENERGY COALITION
Please accept the following comments on behalf the NW Energy Coalition, an
alliance of more than 100 environmental, civic, and human service organizations,
utilities, and businesses in Washington, Oregon, Idaho, Montana and British Columbia.
The Coalition has been deeply engaged in energy efficiency issues for over 35 years and
believes this cheapest, cleanest and most readily available resource will continue to meet
growing demand well into the future.
First, the Coalition would like to applaud Idaho Power for its ongoing
commitment to energy efficiency and demand response. While total energy savings
dropped slightly in 2018 as comparedto 2017, the Coalition understands that changes in
cost-effectiveness and the timing of completion of large commercial projects can have
impacts to total acquisition. We are encouraged to see that Idaho Power once again met
and surpassed its target as laid out in the 2017 lntegrated Resource Plan, which it has
done every year since 2002.
However, the Coalition is concemed that the request to reduce the energy
efficiency rider by a full percentage point may be an extreme reaction to decreased
savings, and hence, spending. As evidenced in the IPC 2018 DSM Annual Report, had
energy savings reached the same level as was achievedin20lT, spending would have
likely been near equivalent to the funds collected via the 3.75% rider. (Idaho Power
indicates in its rider adjustment application that the rider had a collected surplus balance
of approximately $5.3 million. Figures in the annual report indicate the spending was in
the neighborhood of $5 million less in 2018 as comparedto 2017). This is due to the
large percentage of rider dollars that are spent on incentives, leading to a fairly
proportional result of spending and savings. As such, a proposed decrease in collection
and spending necessarily equals a decrease in energy efficiency targets and acquisition.
The Coalition understands that Idaho Power is concerned about energy efficiency
acquisition due to the 2020lighting standards, eliminating the utility's ability to claim
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savings from a large part of the current lighting portfolio. Idaho Power is not alone in this
dilemma, and many utilities, as well as energy efficiency advocates, contractors, and
others are attempting to find ways to ensure that utility efficiency acquisition helps
ensure the transition to the new lighting standards happens quickly and that utility efforts
go deeper into the supply curve of economically available resources.
While IPC has achieved great success with energy efficiency lighting incentives,
it will be incumbent on the utility over the next decade to find new ways to meet and
exceed levels of savings achieved over the past decade. Idaho Power in its application
indicates that a reduction of the energy efficiency rider by a full one percent would save
the average customer $0.83 per month - or less than $10 per year. While we are
committed to affordability, we believe the benefits of targeting new energy efficiency
possibilities outweigh the savings of less than a dollar a month. Collectively, these funds,
totaling $10.4 million could be put to great use benefiting customers.
For example, utilities across the country are exploring the pay-for-performance
model P4P, whereby payments are made for metered energy savings rather than deemed
or modeled savings. The Energy Trust of Oregon and Seattle City Light have recently
moved their P4P programs from the pilot phase to full implernentation. Puget Sound
Energy has just launched a pilot commercial building P4P program.
Under P4P, a building's baseline energy usage is measured. The building owner
and/or tenants then make energy efficiency upgrades and controls, systems optimization
improvements, or conservation-based behavioral changes. The building is then paid for
energy delivered to the grid via savings compared to the baseline, rather than receiving
rebates. Usually, P4P contracts are multi-year where the utility buys saved energy every
year from the building.
P4P has been shown to appeal to large customers who are struggling with the
economics of getting deeper savings from their building beyond the "one and done"
energy efficiency incentive/rebate programs. Furtherrnore, under traditional incentive
based programs, once the payment is made, customers do not have strong financial
incentives to maintain or further their energy savings. Under P4P, however, persistent
and ongoing energy savings provides value for both the utility and the customer.
Cost-effectiveness is determined via the amount paid per kwh of savings. It is
estimated that five to seven million dollars would be adequate to conduct a3-5 year pilot
project.
With increasing loads and regional concerns over resource adequacy, the
Northwest Power and Conservation Council is continuing to rely on energy efficiency -
and its many benefits - to be the bedrock of the regional resource portfolio. Slashing the
energy efficiency rider at this point in time is inconsistent with the company's
conservation potential assessment and the gap between achievable and economic energy
savings. Instead, IPC should continue to work with EEAG to develop a new portfolio of
programs that targets hard to reach markets, P4P for large commercial buildings, lighting
transition, and any measures that are economic but not currently in the utility acquisition
effort. We encourage tdaho Power and the ldaho Public Utilities Commission to not
abandon this lowest cost resource and seek alternatives to replace savings from lighting
proglams.
Given that there exists a means to retum customer money via the PCA, the
Commission should take a cautious approach to EE rider reduction. The Coalition
believes that no reduction in the EE rider is warranted at this time and the utility should
continue to work with stakeholders to find cost-effective means of procuring energy
efficiency. Should the Commission choose to reduce the rider, however, we advise a
reduction of 0.25Yoto 3.5o/o.
Thank you for the opportunity to comment. We look forward to continue working
with Idaho Power on the new wave of energy efficiency acquisition.
{ilil
F. Diego Rivas
Senior Policy Associate
NW Energy Coalition