20170316Comments.pdf

Ep.rcL. OmeN
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&OLSEN
505 PERSHTNG AVE., STEI IOO
PO BOX 6l 19
PocArELLo, lD 83205-61 l9
208.478.t624
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WWW.ECHOHAWK,COM
March 15,2017
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tTli:fDiane Hanian, Secretary
Idaho Public Utilities Commission
47 2 W . Washington Street
Boise, ID 83720-0074
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SENT VIA FEDEX OVERNIGHT MAIL
Re Submission of Comments of the Idaho Irrigation Pumpers Associationr lnc. -
Case No. IPC-E-16-33
Dear Commission Secretary Hanian:
In IPC-E-16-33, we submitted the Comments of the Idaho Irrigation Pumpers
Association, Irc., by email today. Enclosed please find the original and seven (7) copies of the
Comments.
Please process the Comments accordingly. Thank you for your kind assistance.
Sincerely,
1',Uo
Monica Sanada
Paralegal
Enclosures
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Eric L. Olsen #4811
Echo Hawk & Olsen, PLLC
505 Pershing, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205-6119
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Idaho Irrigation Pumpers Association, lnc
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO REVISE THE ENERGY
EFFICIENCY RIDER, TARRIFF
SCHEDULE 9I
)) CASENO. rPC-E-16-33
)
)
)
COMMENTS OF THE IDAHO IRRIGATION
PUMPERS ASSOCIATION. INC.
COMES NOW the Idaho Irrigation Pumpers Association, [nc. ("IIPA"), by and through
counsel, Eric L. Olsen of Echo Hawk & Olsen, PLLC, and hereby respectfully makes a written
comment in support of Idaho Power Company's ("IPC") Application for Authority to Revise the
Energy Efficiency Rider (the "Application").
The IIPA has reviewed the Application and supports IPC's proposal to reduce the Energy
Efficiency Rider's ("Rider") collection percentage to 3.75o/o effective 6lll17, the refund of $13
million in Rider funds to 201712018 PCA, and elimination of the annual transfer of $4 million
worth of Rider funds to the PCA. With that said, IPC's projections that the new rider collection
percentage will adequately fund current and foreseeable energy efficiency programs is made
without knowing what additional energy efficiency programs may be actively pursued in the
future as shaped by IPC's anticipated 2017 Integrated Resource Plan ("IRP"). If going forward,
the Rider collection percentage is insufficient and needs to be raised again or bolstered by the
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S COMMENTS IN SUPPORT - 1
funds being transferred to the Rider account from the PCA, this will send mixed messages to
IPC's customers and would be inconsistent with the principle of rate stability.
The IIPA represents southeastern and southern Idaho farmers in electric utility rate
matters before the Commission. A chief concern that the IIPA has for its members is rate
stability. Farmers depend on rate stability in setting their budgets each growing season and an
unexpected increase in electrical rates wreak havoc on a farmer's bottom line, especially in the
current environment of low commodity prices. Thus, the IIPA and its members would be
concemed to have the Rider reduced in2017 and then have it increased in 2018 due to new or
expanded energy effi ciency progrcms.
The IIPA invites IPC to briefly address in its reply comments whether this potential rate
stability concern was addressed in its modeling utilized to determine the proposed Rider amount.
RESPECTFULLY SUBMITTED this 15th day of March, 2017.
ECHO HAWK & OLSEN, PLLC
B
ERIC L.for
Idaho Irrigation Pumpers Association, Inc
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.'S COMMENTS IN SUPPORT - 2
CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of March,2017,I caused to be served a true, correct,
and complete copy of the foregoing document by the method indicated below, and addressed to
the following:
Diane Hanian, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
47 2 W. Washington Street
Boise, lD 83720-0074
Email : [e-mail]. gov
Lisa D. Nordstrom
Idaho Power Company
P.O. Box 70
Boise, ID 83707
E:mail: [e-mail]
[e-mail]
Tami White
Idaho Power Company
P.O. Box 70
Boise, lD 83707
E-mail: [e-mail]
Brandon Karpen
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
E-mail: [e-mail]. gov
Benjamin J. Otto
Idaho Conservation League
710 N. Sixth Street
Boise, lD 83702
E-mail: [e-mail]
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IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.'S COMMENTS IN SLIPPORT - 3
Elizabeth A. Koecheritz
Deputy CityAttorney
Boise City Attorney's Office
P.O. Box 500
Boise,ID 83701-0500
Email: [e-mail]
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Electonic Mait @mail)
L. OLSEN
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S COMMENTS IN SUPPORT .4