20170314Comments.pdf

Benjamin l. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
REVISE THE ENERGY EFFICIENCY
RIDER, TARIFF SCHEUDLE 91.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-16-33
THE IDAHO CONSERVATION
LEAGUE
COMMENTS
The Idaho Conservation League (*ICL") supports Idaho Power's request to adjust the
Schedule 91 Energy Efficiency Rider. ICL has consistently advocated for sufficient funding to
achieve all cost effective energy efficiency. Here Idaho Power proposes to reduce the rider
percentage by 0.25o/o. Based on our review we believe the resulting funding level is sufficient to
support current and future energy efficiency activities.
Our position is founded on two pillars:
We believe Idaho Power's forecast of future energy efficiency rider revenues and program
expenses is reasonable. We support forecasting budgets for several years because annual
program expenses can be lumpy as a result of large, complex industrial and commercial
efficiency projects.
We have repeatedly heard from all stakeholders that the appropriate metric in Idaho is the
pursuit of all cost effective energy efficiency. To the extent this utility pursuit requires
additional funding, the efficiency rider budget does not limit utility actions.
ICL also supports Idaho Power's request to end the annual $4 million transfer from the
Rider account to the Power Cost Adjustment. We agree this transfer is a relict of previous
adjustments to the efficienry rider and demand response investments. With the adjustment to the
Rider in this case, this transfer is no longer necessary.
IPC-E-16-33
ICL Comments I March 14,2017
ICL supports Idaho Power's proposed refund to customers of $13 million in unspent
energy efficiency dollars. We always prefer that a utility spend efficiency dollars on efficiency
programs. Here, we support reducing the efEcienry rider level because we recognize there is a
current mismatch between funding collected and expenses incurred for Idaho Power. We support
this one-time refund in order to reset the account balances and clarifr the funding and program
spending going forward. A significant part of ICL's support relies on Idaho Power's documented
efforts to expand efficiency marketing and energy savings. We are pleased both of these metrics
continue to trend upward.
In prior years, the unspent efficienry funding was used to offset power cost increases. ICL
is specifically opposed to this practice. Using efEciency funding to mask power costs hides the
true cost of power from customers thereby preventing them from making informed choices
about energy use. Secondly, ICL opposes using customer funds collected for a specific purpose,
here energy efficiency, for an entirely different purpose, power costs. If the Commission or other
parties wish to address power cost volatility the Power Cost Adjustment docket is the appropriate
forum.
ICL recognizes and appreciates Idaho Power's effiort to improve and expand energy
efficiency programs over the past few years. Based on our review we believe the proposal here
strikes the appropriate balance between program funding and expected investments. Accordingly,
we urge the Commission to approve Idaho Power's application.
DATED this 14th day of March2017.
Respectfully submitted,'/2A'4-
Benjamin J. Otto
Idaho Conservation League
IPC-E-16-33
ICL Comments 2 March 14,2017
CERTIFICATE OF SERVICE
I hereby certifr that on this l4th day of Mar ch 20L7 ,I delivered true and correct copies of
the foregoing COMMENTS to the following persons via the method of service noted:
Hand delivery:
Iean Jewell
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
(Original and seven copies provided)
Electronic Mail:
Lisa D. Nordstrom
Regulatory Dockets
Tami White
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
[e-mail]
[e-mail]
Eric l. Olsen
ECHOHAWK & OLSEN, PLLC
505 Preshing Ave., Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
elo@,echohawk.com
Anthony Yankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
Elizabeth A. Koeckeritz
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701
[e-mail]
IPC-E-16-33
ICL Comments
Za-
Benjamin I. Otto
3 March 14,2017