20191218ICL Comment.pdf

Beniamin I. Otto (ISB No. 8292)
710'N 5fi Street
Boise, ID 83701
Ph: [phone]x12
Far [phone]
[e-mail]
Attorney for the Idaho Conservation kague
IlECEIVED
ll9 DtC lB Pll l:51
BEFORETHE IDAHO PUBLIC UTILITIES COMMISSION
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The Idaho Conservation League recommends the Commission approve Idaho Power's
request to continue participating in the Northwest Energy Efficiency Alliance (NEEA). Our
comments below are informed by the fact that council for ICL also sits as the Public Interest
Representative on NEEA's Board ofDirectors. The NEEA Board elects one representative from
the four-state region to a three-year term. Council for ICL served an initial term from 2015-2019
and the Board recently reelected him for another term. In this volunteer position, he serves on
the Strategic Planning Committee and the Finance and Audit Committee, both of which play
primary rolls in developing and implementing the strategic and business plans. The common
public interest across NEEA's four-state region is the same as that articulated by the Idaho
Commission - utilities should pursue all cost-effective conservation measures. Idaho Power's
collaboration through NEEA is an essential part of this pursuit.
NEEA's work to influence product makers, distributors, and service providers at a
national scale ensures Idahoans have access easy and affordable access to energy efficient
products and services. NEEA's work testing and improving consumer marketing practices, also in
close coordination with local utilities, leverages Idaho Power's other conservation efforts. One of
the most cost-effective conservation measures is to build homes ef6ciently at the outset. Here
NEEA's expertise and impact in improving Idaho's building and energy codes is unmatched in
our state. By developing new conservation measures, improving consumer uptake, and instilling
conservation into codes NEEA delivers cost-effective energy savings that a single utility could
never accomplish alone.
IPC-E-19-34
ICL COMMENT
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
FUND INTS CONTINUED
PARTICIPATION IN THE
NORTHWEST ENERGY EFFICEINCY
ALLIANCE THROUGH THE ENERGY
EFFICIENCY RIDER FOR 2020-2024
CASENO. IPC.E.I9-34
IDAHO CONSERVATION LEAGUE
COMMENT
I December 18, 2019
Respectfully submitted this ISth day of December 2019,
Benjamin f. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I hereby certify that on this l8'h day ofDecember, 2019, I delivered true and correct
copies of the foregoing COMMEN'| to the following persons via the rnethod of se noted:
Ilenj in l. Ottofl l.t't
Electronic Mail:
Idqho Public Utilities Commission
Diane Hanian, Commission Secretary
lohn Harnmond, Deputy Attorney General
[e-mail]
john.hammond@puc. idaho. gov
Idaho Pou'er
Lisa D. Nordstrom
Theresa Drake
I [e-mail]
[e-mail]
[e-mail]
I While IPC's Application refers to Testinrony frorn Mr. Richins and Mr. Pengilly, that testimony is not posted to
the commission websile, nor lrlaho Poter's.
IPC-E- l9-34
ICL COMMENl'December I 8, 20192
Because NEEA focuses upstream ofthe end consumer to influence other parts ofthe
product and service supply change, the energy saving results will always be different than
consumer focused programs. The essence of market transformation, NEEA's clear goal for the
past 20 years, is to fill the pipeline with new products and services that will deliver future energy
savings. NEEA programs succeed when a new product or service is mature enough for local
utilities to irnplement consumer facing incentives and programs. This sharing of responsibilities
between NEEA's focus on upstream actors and local utilities focus on downstream programs
appropriately balances the risks and rewards of innovation for the benefit ofend consumers.
As always, ICL is focused on cost-effective energy conservation. Like all forwardJooking
conservation programs funded by Idaho Power, we recommend the Commission approve
continued participation in NEEA. The annual DSM review process provides a forum to ensure
the ongoing cost-effectiveness ofall Idaho Power funded conservation activities.r Continuing to
collaborate with NEEA is the first step in pursuing all cost-effective conservation opportunities.
Benjamin I. Ono (lSB No. 8292)
710 N 6e Street
Boise, ID 83701
Ph: [phone] x 12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation lrague
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
FUND INTS CONTINUED
PARTICIPATION IN THE
NORTITWEST ENERGY EFFICEINCY
ALLIANCE THROUGH THE ENERGY
EFFICIENCY RIDER FOR 2020-2024
RECEIVED
:0l90EC lB Plt lrSl
)
)
)
)
)
)
)
CASENO. IPC-E-I9-34
IDAHO CONSERVATION LEAGUE
COMMENT
The Idaho Conservation League recommends the Commission approve Idaho Power's
request to continue participating in the Northwest Energy Efficiency Alliance (NEEA). Our
comments below are informed by the fact that council for ICL also sits as the Public Interest
Representative on NEEA's Board of Directors. The NEEA Board elects one representative from
the four-state region to a three-year term. Council for ICL served an initial term from 2016-2019
and the Board recendy reelected him for another term. In this volunteer position, he serves on
the Strategic Planning Committee and the Finance and Audit Committee, both of which play
primary rolls in developing and implementing the strategic and business plans. The common
public interest across NEEA's four-state region is the same as that articulated by the Idaho
Commission - utilities should pursue all cost-effectiye conservation measures. Idaho Power's
collaboration through NEEA is an essential part of this pursuit.
NEEA's work to influence product makers, distributors, and service providers at a
national scale ensures Idahoans have access easy and affordable access to energy efiEcient
products and services. NEEA's work testing and improving consumer marketing practices, also in
close coordination with local utilities, leverages Idaho Power's other conservation effors. One of
the most cost-effective conservation measures is to build homes efficiently at the outset. Here
NEEA's expertise and impact in improving Idaho's building and energy codes is unmatched in
our state. By developing new conservation measures, improving consumer uptake, and instilling
conservation into codes NEEA delivers cost-effective energy savings that a single utility could
never accomplish alone.
IPC-E-19-34
ICL COMMENT December 18, 2019
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
I
Because NEEA focuses upstream ofthe end consumer to influence other parts ofthe
product and service supply change, the energy saving results will always be different than
consumer focused programs. The essence of market transformation, NEEA's clear goal for the
past 20 years, is to fill the pipeline with new products and services that will deliver future energy
savings, NEEA programs succeed when a new product or service is mature enough for local
utilities to implement consumer facing incentives and programs. This sharing of responsibilities
between NEEA's focus on upstream actors and local utilities focus on downstream programs
appropriately balances the risks and rewards of innovation for the benefit ofend consumers.
As always, ICL is focused on cost-effective energy conservation. Like all forward-looking
conservation programs funded by Idaho Power, we recommend the Commission approve
continued participation in NEEA, The annual DSM review process provides a forum to ensure
the ongoing cost-effectiveness ofall ldaho Power funded conservation activities.r Continuing to
collaborate with NEEA is the first step in pursuing all cost-effective conservalion opportunities.
Respectfully submitted this 18'h day of December 2019,
Benjamin l. Otto
Idaho Cor.rservation League
CERTIFICATE OF SERVICE
I hereby certify that on this l8'h day of December, 2019, I delivered true a
copies of the foregoing COMMENT to the following persons via the method of s
Electronic Mail:
nd correct
noted:
Benj in J. Ottoarn
Irlcrho Ptthlic Utilities Comniss m
Diane Hanian, Commission Secretary
John Hammond, Deputy Attorney General
[e-mail]
[e-mail]
ldaho Pov,er
Lisa D. Nordstrom
Theresa Drake
I [e-mail]
[e-mail]
[e-mail]
I While IPC's Application reiers to Testinrony fionr Mr. Richins and Mr. Pengilly, that testimony is not posted to
the conrrnission rvebsite. nor ldaho Porver's.
1 December 18, 2019
IPC-E- l9-34
ICI, COMMENT