20170720Comments.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17tr St.
Boise,ID. 83702
[phone] (Land)
(208) 484-ee80 (Cell)
bmpurdy@.hotmail.com
Attorney for Petitioner
Community Action Partnership
Association of Idaho
TN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2016 DEMAND-SIDE
MANAGEMENT EXPENDITURES AS
PRUDENTLY INCURRED.
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CASE NOS. IPC-E-I7-03
COMMLINITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO'S COMMENTS
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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COMES NOW,Intervenor Community Action Partnership Association of Idaho
(CAPAD and in response to OrderNo. 33737, issued by the Commission in this proceeding on
March 30,2017, submits the following comments in response to the Application filed by Idaho
Power Company (*Idaho Power" or the "Company'') seeking a finding of prudence by the
Commission for all the following DSM investments: l) $31,321,862in DSM investrnents
recovered through the Company's Energy Efficiency Funds; 2) $7,059,420 of demand response
program incentives funded through base rates tracked through the Company's PCA mechanism
and; 3) $1,860,901 of incremental DSM labor expenses incurred during 20ll-2016 and not yet
deemed prudent by the Commission. The foregoing investments for which the Company seeks a
prudence determination total $40,242,182.
ICAPAI COMMENTS IN RESPONSE TO IPC APPLICATION: CASE IPC-E-17-03
Although Idaho Power's objective is to obtain a determination by this Commission that
the entirety of its DSM investments, as described above, were prudently incurred, CAPAI limits
these comments to the Company's Low Income Weatherization Assistance Program or "WAQC"
(Weatherization Assistance for Qualifi ed Customers).
I. BACKGROUND-COMPANY'S APPLICATION
The Company declares that its 2016 energy savings totaled 42,260 MWh from its
residential class, 88,161 MWh from its commercial/industrial sector, in addition to savings
achieved through Northwest Energy Efficiency Alliance ("NEEA") initiatives. Idaho Power
states that it enrolled enough participants in demand response progftrms to achieve 392 MW of
load shedding capacity, and that the programs ultimately reduced demand by 378 MW.
In support of its Application, Idaho Power included its 2016 DSM report with
attachments, as well as the testimony of Ms. Connie Aschenbrenner with exhibits. [n addition,
supplements to the 2016 DSM report were included in the Company's filing. Supplement 1 to
the 2016 DSM report provides the methodologies by which the Company calculated the cost-
effectiveness of its DSM programs and includes a table reporting expenses by funding source
and cost category. The 2016 DSM report examines Idaho Power's program expenditures,
marketing, cost-effectiveness, and evaluations. In addition, there is a section that describes other
programs and activities not tied to direct energy savings.
Finally, the Company's DSM report lists the benefit/cost methodologies utilized in
previous annual DSM reports including the Total Resource Cost test (TRC); the Utility Cost test
perspective (UC); the Participant Cost Test (PCT) perspective, and; the Ratepayer Impact
Measure (2M) perspective.
2CAPAI COMMENTS IN RESPONSE TO IPC APPLICATION: CASE IPC-E-17-03
II. TESTIMOI\'Y OF IDAHO POWER WITNESS
COIYNIE ASCHENBRENNER
Like the Company's Application and associated Supplements, the testimony of Idaho
Power witness Aschenbrenner identifies the Company's various DSM programs, including
WAQC, and the cost-effectiveness of those programs. Ms. Aschenbrenner also provides a
substantive evaluation of other DSM programs. Regarding WAQC, the relevant testimony of
witress Aschenbrenner can be found beginning onp.Z2,ln.l2 throughp.25,ln.25, where she
discusses both WAQC and the "Solutions" program.
As revealed in Exhibit No. 2 to Ms. Aschenbrenner's testimony, neither WAQC nor
Solutions are currently cost-effective without taking into account "other benefits to [WAQC] that
are difficult to quantiff, such as health and safety measures." See, Testimony of Aschenbrenner,
p. 23, lns. 6-8. Exhibit No. 2 to Ms. Aschenbrenner's testimony shows the following scores for
WAQC and Solutions under the cost-methodologies discussed earlier:r
PROGRAM TRC UTC
wAQC
SOLUTIONS
0.6s
0.70
0.73
0.59
Ms. Aschenbrenner noted that these programs have recently seen some improvement. As
noted earlier, she pointed out that there are other benefits derived from WAQC that are difficult
to quantifu, but very real just the same. Though not specifically stated by Ms. Aschenbrenner,
other examples include the fact that providing weatherization to low income customers reduces
their bills and that, therefore, they will be more likely to remain current in paying their accounts,
thereby reducing collection and past due costs, they are more likely to remain customers of Idaho
' There is no cost-effectiveness score for these programs under the PCT because low income customers who receive
weatherization measures through them comes at no cost to the customers.
aJCAPAI COMMENTS IN RESPONSE TO IPC APPLICATION: CASE IPC-E-17-03
Power, the reduction of the number of accounts that are ultimately written off as uncollectible,
and so on.
Ms. Aschenbrenner also concludes that the "WAQC program provides real and
substantial per home savings." Aschenbrenner, p. 22, lns. 23-24. Ms. Aschenbrenner concludes
that "due to the costs of comprehensive whole-house weatheization, it is difficult for the value
of the savings to outweigh the costs." Id., p. 22, ln. 24 through p. 23, ln. l. She further notes that
WAQC is consistent with the Idaho State WeatheizationAssistance Program (*WAP")
guidelines." Aschenbrenner, p. 23, ln. 2 through p. 23, ln. 4. lll4s. Aschenbrenner further notes
that WAQC is offered in coordination with the state WAP under the U.S. Department of Energy
Guidelines and that changes to the program must be made by the state WAP. Aschenbrenner, p.
23, lns. 9-l 1. CAPAI would like to coordinate, either through a formal or informal discussion,
with Idaho Power and members of CAPAI's network to develop a strategy to improve the cost-
effectiveness of WAQC, including addressing the challenge of providing whole house
weatherization and cost sharing with federal flurding sources.
Ms. Aschenbrenner further notes that "Idaho Power continues to work in partnership with
its weatherization managers, stakeholders, and vendors to streamline operations and adjust
offerings to make this program [WAQC] more cost-effective." Id. at p. 23, lns. l2-15. She notes
that new savings values were introduced in 2016 as a result of a billing analysis completed in
2015, and while the program shows cost-effectiveness of less than 1.0 for 2016, the new savings
did improve the cost-effectiveness of WAQC when compared to 2015. Id., p. 23, lns. 15-19.
Ms. Aschenbrenner testified that it is the Company's plan to continue to offer the WAQC
program in the future and will continue its effons to improve the cost-effectiveness of this
4CAPAI COMMENTS IN RESPONSE TO IPC APPLICATION: CASE IPC-E-17-03
progftrm while at the sarne time offering it to the Company's limited-income customers on an
ongoing basis. Id. p. 24 lns. 23-24 through p. 25, lns. l-7.
III. RECOMMENDATION/CONCLUSION
In addition to any recommendations set forth above, CAPAI believes that the Company
has sufficiently justified recovery of its expenditures in the WAQC program and respectfirlly
submits that the Company should be allowed recovery of its related expenditures. Furthermore,
CAPAI is fully dedicated to improving progrirm implementation based on all of the foregoing
considerations and through any other measures that might come to light through an informal
process.
CAPAI appreciates the opportunity to comment on Idaho Power's filing and the
Commission' s consideration of these comments.
DATED, this 2fth day of July,20l7.
Attorney for CAPAI
5CAPAI COMMENTS IN RESPONSE TO IPC APPLICATION: CASE IPC-E-17-03
CERTIFICATE OF SERVICE
I hereby state that on this 20th day of July, 2Al7,I caused a true and correct copy of the
foregoing document to the following via electronic mail:
Diane Hanian
Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise,ID 83702
[e-mail]
Daphne Huang
Deputy Attorney General
Idaho Public Utilities Commission
daphne.huang@puc. id. gov
Lisa D. Nordstrom
Idaho Power Company
P.O. Box 70
Boise,lD 83707-0070
lnordstrom@ idahopower. com
[e-mail]
Connie Aschenbrenner
Idaho Power Company
P.O. Box 70
Boise,ID 83707-0070
[e-mail]
Peter J. Richardson
Industrial Customers of ldaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27thSt
P.O. Box 7218
Boise,Idaho 83702
peter@richardsonadams. com
Benjamin J. Otto
710 N. 6tr St.
Boise, lD 83702
(208) 34s-6933 X t2
botto@idahoconservation. org
6CAPAI COMMENTS IN RESPONSE TO IPC APPLICATION: CASE IPC-E-17-03