20191127Answer to Petition for Clarification.pdf

Beniamin J. Otto (lSB No. 8292)
710'N 6s Street
Boise, ID 83701
Ph: (208) J45-6933 x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR A DETERMINATION
OF 2OT8 DEMAND-SIDE
MANAGEMENT EXPENCESAS
PRUDENTLY INCURRED
RECEIVED
Z0l9NOY 2? Pt{ 2: I I
CASE NO. IPC-E.Ig-II
IDAHO CONSERVATION LEAGUE
ANSWT,RTO PETITION FOR
CLARIFICATION
',i'r ,rr,l-lC
- S'Lru':iil'ttSSION
BEFORETHE IDAHO PUBLIC UTILITIES COMMISSION
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The Idaho Conservation League hereby replies to Idaho Power Company's Petition for
Clarification of Order No. 34469. The Idaho PUC Rules of Procedure 31.01.01.325 does not
describe an intervenor's ability to reply to a Petition for Clarihcation. Rule 331 that covers
Petitions of Reconsideration provide seven days for cross petitions or answers. IDAPA
310.01.01.33 t. Idaho Power filed their petition on November 21,2019.ICL's answer, filed
November 27,2019 is timely pursuant to IDAPA 31.01.01.017.
Idaho Power's petition states: "While it may be implied from final Order No. 34469
("Order"1,t Idaho Power petitions for clarification that the Idaho Public Utilities Commission
("Commission") intends for ldaho Power to apply the Utility Cost Test (UCT') perspective only
when evaluating demand-side management ('DSM") resources in inlegrated resource planning to
ensure that it fully understands the Commission's direction."
ICL submits the Commission's Order is clear and there is no need to read any unspoken
implication to the decision. The entire docket was about energy conservation programs and not
generation resources. ICL never argued to apply the UTC to generation resources because doing
so would have been outside ofthe scope of this docket and, further, doing so doesn't make sense
IPC-E-19-11 1 November 27,2019
ICL Ansu'er to Petition for Clarification
in the Integrated Resource Planning context. The cost elflectiveness tests address whether a
standalone program is a prudent use of ratepayer dollars. Integrated Resource Planning compares
altemative methods to provide overall utility service to customers. Assessing individual
programs and comparing diverse resources are very different questions with distinct processes.
Applying the UTC framework to assess energy conservation options in the Integrated Resource
Plan process merely means using the costs to the utility as the cost of the resource and using the
load shape of the resource to compare against other options. The issue with energy conservation
is the appropriate costs to consider when the utility and the customer share the costs. Because
Idaho Pou'er only considers generation resource they own or contract with for utility planning
the costs to the utility are already clear for generation resources.
In sum: Commission Ordcr 34469 speaks for itself. The entire docket lbcuscd on energy
conservation programs and not generation souroes.
Benjamin J. Otto
ldaho Conservation League
IPC-E-19-11
ICL Answer to Petition lbr Clarification
November 27 .201()2
Respectfully submitted this 27'h day ol'Novembcr 2019.
CERTIFICATE OF SERVICE
I hereby certiry that on this 27th day ofNovember, 2019, I delivered true and correct
copies of the foregoing ANSWER TO PETITION FOR CLARIFICATION to the following
persons via the method of service noted:
Hand deliveri.:
Diane Hanian
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Idaho Power
Lisa D. Nordstrom
Connie Aschenbrenner
Idaho Power Company
1221 West State Street
Boise, Idaho 83702
[e-mail]
[e-mail]
[e-mail]
City of Boise
Abigail R. Germaine
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
[e-mail]
IPC-F,-I9-l I
ICL Answer to Petition lbr Clarilication
-)November 27. 2019
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Benjamin l. Otto