20191127Cross-Petition .pdf

MATT HUNTER (lSB No. 10655)
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P.O. Box 83720
Boise, ID 83720-0074
Tele: [phone]
FAX: [phone]'162
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Street Address for Express Mail:
I l33l W. Chinden Blvd
Building 8, Suite 201-A
Boise, Idaho 837 14
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 20I8 DEMAND.SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRI.],D
CASE NO. IPC.E-Ig.I1
COMMISSION STAFF'S
CROSS-PETITION FOR
CLARIFICATION OF ORDER
NO.34469
The Staff of the Idaho Public Utilities Commission cross-petitions the Commission for
an Order clarifying Order No. 34469. Specifically, Staff requests the Commission clarify the
change in cost-effectiveness test is intended to only apply to demand-side management (DSM)
resources for integrated resource planning.
BACKGROUND
On March 15,2Ol9,Idaho Power Company applied for a Commission order finding
that the utility prudently incurred its 2018 DSM expenses. The Company also asked the
Commission to find that including "all cost-effective DSM resources in the Company's long-term
resource planning process, from a total resource cost [TRC] perspective, will lead to the most
economic planning outcome and best serve the public interest." Application at 2.
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STAFF'S CROSS-PETITION I
The Commission issued a Notice of Application and Notice of Intervention that
required interested persons to file any petitions to intervene by April 29,2019. Sae Order No.
34301 . Idaho Conservation lrague (ICL) and the City of Boise (Boise City) filed the only petitions
to intervene, and thc Commission granted both petitions. .lee Order Nos. 34306 and 34328.
On May 23,2019, the Commission issued a Notice of Modified Procedure and sct
comment deadlines. Order No.34338. Commission Staff, ICL, and Boise City filed comments,
and Idaho Power filed reply comments.
The Comments
Staff recommended the Commission "decline the Company's request to use the [TRC]
perspective in its integrated resource planning because that perspective includes costs that Idaho
Power does not incur to provide electric service." Staff Comments at 5. Staffnoted that it "believes
the UCT [utility cost test] is the most appropriate test for rcsource planning because the key
question it answers is whether utility system costs will be reduced." 1d. at 8.
Boise City's comments focused on Idaho Power's request to use the TRC as its primary
means to evaluate the cost effectiveness of the Company's DSM programs during integrated
resource planning. Boise City Comments at 3-7. Boise City opposed using the TRC as the primary
means of evaluation, favoring the UCT instead. 1d. at 4. Boise City encouraged the Company to
principally rely on the UCT when deciding what energy efficiency programs to offer. 1d "[U]sing
the UCT ... would likely ... increase [the] energy efficiency programs that would qualify for
funding." ft/. at 7.
ICL echoed Staff and Boise City in opposing the use of the TRC as the primary
perspective for integrated resource planning. ICL Comments at 6-9. Like Staff and Boise City,
ICL prefened the UCT. Id
Idaho Power's Reply Comments
In its reply comments, the Company responded to Staff, Boise City, and ICL's support
ofthe UCT as the primary test for integrated resource planning. Curiously, Idaho Power's primiuy
argument against the UCT was that it would increase costs for customers if it was used as the
primary test to evaluate supply-side resource acquisition-an issue not raised in the Company's
Application or any party's comments. Company Reply Comments at 2-6. The Company reiterated
its request that the Commission find that Idaho Power "should continue to rely on thc TRC test
2STAFF'S CROSS-PETITION
perspective when evaluating the amount of energy efiiciency included in long-term resource
planning." Id. at l0 (emphasis added).
The Commission's Order
On October 3 l, 2019, the Commission issued Order No. 34469. The Commission found
that "the UCT perspective is the appropriate perspective for integrated resource planning because
it includes only those costs and benefits that the utility incurs to provide service." Rejecting Idaho
Power's request that the Commission find that use of the TRC would lcad to the most economic
planning outcome, the Commission focused its discussion on DSM and, specifically, energy
efficiency programs. Thc Commission's findings and dccision did not mention supply-side
resources. The Commission ordered Idaho Power to "use the UCT perspective for integrated
resource planning."
It!4hp Power's Petition for Clarification
On November 2l , 2019, Idaho Power hled a Petition for Clarification in which it asked
the Commission to clarify "that the change in cost-effectiveness test is intended to apply to energy
efficiency resources in the resource planning context, not all supply-side resources." Company's
Petition at 3. The Company noted that all parties discussed the test perspectives in the context of
energy efficiency. /d. Additionally, the Company again argued-as it did in its reply comments-
using the UCT as the primary perspective fbr evaluating supply-side resources would shift costs
to the Company's customers. Id. at 5-6.
CROSS-PETITION
Staff cross-petitions the Commission to clarify that Order No. 34469 applies only to
DSM resources for integrated resource planning. This case has been from the beginning about
DSM resources, and each party (except fbr Idaho Power in its reply comments) argued in the
context of DSM. Idaho Power correctly notes that its Application requested "the Commission find
the inclusion of all cost-effective DSM resources in the Company's long-term resource planning
process, from a [TRC] perspective, will lead to the most economic planning outcome and best
serve the public interest." Petition for Clarification, footnote 7 (emphasis added).
STAFF'S CROSS-PETITION 3
Which cosfeffectiveness perspective is the appropriate perspective for evaluating the
cost effectiveness of supply-side resources for integrated resource planning is a question for a
different case. If Idaho Power wants this question answered, Staff recommends the Company file
a separate proceeding.
Respcctfully submitted thrs L7 Xay sf November 2019
Matt Hunter
Deputy Attorney General
4STAFF'S CROSS.PETITION
I HEREBY CERTIFY THAT ONTHISTHIS 27TH DAY OF NOVEMBER 2019,
I SERVED THE FOREGOING STAFF'S CROSS-PETITION, IN CASE NO. IPC-E-19-
I I, VIA ELECTRONIC MAIL & U.S. MAIL, POSTACE PRE-PAID, TO THE FOLLOWING:
LISA D. NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
P.O. BOX 70
BOISE, ID 83707-0070
E-mail: lttorrlstr()ni (a, i(lilhr)l)()\\ cr'.c()[r
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7iO N 6TH STREET
BOISE, ID 83702
E-mail lr('ll,)ul i\l, rll, r!r rrt \L r \ irl iOtl. (,l
ABIGAIL R GERMAINE
BOISE CITY ATTORNEY'S OFFICE
P.O. BOX 500
BOISE, ID 83701-0500
E-MAIL:ernlrinc @)cit oltroisc,or
WUlA,
Keri J. Ha
Legal Assistant to Matt Hunter
5STAFF'S CROSS-PETITION
CE,RTIFICATE OI.' SERVICE
tor&Ug,rdlho!gwc!.qel]]
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
P.O. BOX 70
BOISE rD 83707-0070
E-mail: cirschcrttrlt'rt1g1Qj!ulrrrPol! !l!.!leLrl