20210823Reply Comments.pdf

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McDOWELL RACKNER GIBSON PC
419 SW I ls Ave, Suite 400 | Portland, OR 97205
Aonu LowNevM(W)Wffi26
*[e-mail]
August 23,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Commission Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
Boise, ldaho 83720-007 4
Case No. IPC-E-21-04
ln the Matter of ldaho Power Company's Application for a Determination of 2020
Demand-Side Management Expenses as Prudently lncurred
Dear Ms. Noriyuki:
Attached for eleclronic filing, pursuant to Order No. 34781, in the above matter please find
ldaho Power Company's Reply Comments.
lf you have any questions about the enclosed document, please do not hesitate to contact me.
Sincerely,
Adam
cc: !PC-E-21-04 Service List (via email)
Enclosure
main: 503 595 3922 | fax: [phone] | www.mrg-law.com
419 SW llbAve, Suite 400 | Portland, Oregon 97205-2605
Re:
ADAM LOWNEY (lSB No. 10456)
McDowell Rackner Gibson PC
419 SW 11th Avenue, Suite 400
Portland, OR 97205
Telephone: [phone]
Facsimile: [phone]
[e-mail]
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ idahopower. com
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2O2O DEMAND.SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
cAsE NO. IPC-E-21-04
IDAHO POWER COMPANY'S
REPLY COMMENTS
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ldaho Power Company ("ldaho Powe/' or "Company") respectfully submits the
following Reply Comments in response to Comments filed by the ldaho Public Utilities
Commission ("Commission") Staff ("Staff'), and the city of Boise City ("Boise City") on
August 2,2021.
I. REPLY COMMENTS
ln its Comments, Staff recommends the Commission approve $47,008,618 in
expenditures related to Demand-Side Management ("DSM") including V0,474,884 in
ldaho Energy Efficiency Tariff Rider ("Ride/') expenses (which includes an adjustment of
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
$2,159 to reflect the exclusion of an expense that should have been allocated to the
Company's Oregon jurisdiction) and $6,533,734 in Demand Response ("DR") program
incentives. Staff also provided positive feedback on overall program management and
offered potential items to explore with the Energy Efficiency Advisory Group ("EEAG"). ln
their Comments, Boise City commends ldaho Power on its 2020 DSM achievements,
signals support for an increase in funding for the Rider, and recommended programmatic
topics to be explored with the EEAG. ln these Reply Comments, the Company briefly
responds to items raised by Staff and Boise City.
A. Enerov Efficiencv Rider Balance
ldaho Power appreciates Boise City's support for appropriate cost recovery of the
current under-collected Rider balance and for a Rider adjustment that may increase
funding above the current funding leve!. \Mile ldaho Power believes an adjustment to the
Rider collection percentage may ultimately be warranted, the Company takes into
consideration the timing and impact of other rate adjustments, especially during the
difficult environment created by the COVID-19 pandemic. At this point in time, the
Company does not anticipate taking near-term action with a filing to modify the Rider
collection but will continue to monitor the balance. As expressed in previous cases,l
stakeholder discussions, and through its actions, ldaho Power is committed to funding all
cost-effective energy efficiency regardless of the Rider balance.
1 ln the Matter of ldaho Power Company's Application for Authority to Rew.se the Eneryy Efficiency Rider, Tariff
Schedule 97, Case No. IPC-E-20-33, Reply Comments, p. 1-2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
B.Northwest Enerov Efficiencv Alliance ("NEEA"| Evaluation. Measurement.
and Verification ("EM&V")
ldaho Power's customers have funded its participation in NEEA since 1997, and
between 1997 and 2020,ldaho Power's allocated portion of NEEA savings were 407,509
megawatt-hours or 46.52 average megawatts. ln its comments, Staff stated it "is
concerned that NEEA claims savings it is not directly responsible for producing" and
highlighted that "if savings from codes and standards are removed, NEEA would not be
cost-effective.'2 \Mrile the Company believes its customers benefit from participation in
NEEA, in Case No. IPC-E-19-34, the Company highlighted concerns regarding the
amount of savings attributed to codes and standards, the allocation methodology of
savings to ldaho Power customers, and cost-effectiveness impacts of declining avoided
costs as it pertained to participation in the 2020-2024 NEEA cycle.3 Further, newly
negotiated terms in the 2020-2024 Funding Agreement help ensure the Company can
terminate funding for the remainder of the funding cycle if concerns regarding cost-
effectiveness materialize.a The Company supports Staffs recommendation that an
independent EM&V should be conducted to clarify (1) the savings NEEA claims, (2) the
allocation of those savings to its member utilities, and (3) the cost-effectiveness of those
savings to the member utilities.
ln Order No. 35129, the Commission recently directed Avista "to conduct an
independent EM&V to clariff the NEEA claimed savings."s The Company intends to
2 Staff comments, p. 103 ln the Matter of ldaho Power Company's Application for NEEA Agreement 2020-2024, Case No. !PC-E-
19-34, Richins Direct, p. 9.4 ln the Matter of ldaho Power Company's Application for NEEA Agreement 2020-2024, Case No. IPC-E-
19-34, Application, Attachment 3, Section 2, p.1-2.
s ln the Matter of Avista's Applications for a Prudency Determination for its 2018'2019 Electic and Gas
Energy Efficiency Expenditure,s, Case Nos. AVU-E-20-13 and AVU-G-20-08, Order No. 35129, p. 9.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
coordinate with Avista, to the extent possible, on contracting and co-funding an
independent evaluator to veriff savings that will inform the cost-effectiveness of NEEA
participation.
As directed by the Commission in Order No. 34556, if the Company ultimately
concludes NEEA is no longer a cost-effective resource, prudent, or in the best interest of
rate payers, it will notiff the Commission as soon as possible.6
C. Stakeholder Collaboration
Parties acknowledge generally that ldaho Power continues to make improvements
in its implementation of cost-effective energy efficiency. The Company is committed to
continuing to work with the EEAG to improve program implementation, development,
delivery, and the pursuit of new energy efficiency opportunities. Over the course of the
next several EEAG meetings, ldaho Power will bring program specific items raised by
Boise City and Staff to the EEAG for discussion and to consider potential solutions.
t!. coNcLUStoN
ldaho Power respectfully requests that the Commission issue an Order finding
ldaho Power's 2020 DSM expenditures of $40,474,884 in Rider funds and $6,533,734 ol
DR program incentives, for a total of $47,008,618, as prudently incurred.
Respectfully submitted this 23'd day of August 2021.
ADAM LOWNEY
LISA D. NORDSTROM
Attorneys for ldaho Power Company
6 ln the Matter of ldaho Power Company's Application for NEEA Agreement 2020-2024, Case No. IPC-E-
19-34, Order No. 34556, p. 7.
IDAHO POWER COMPANY'S REPLY COMMENTS -4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 23rd day of August 2021,1 served a true and
correct copy ldaho Power Company's Reply Comments upon the following named parties
by the method indicated below, and addressed to the following:
Gommission Staff
Matt Hunter
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A(83714)
PO Box 83720
Boise, lD 83720-0074
lndustrial Customer of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
710 N.6th Street
Boise, ldaho 83702
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IDAHO POWER COMPANY'S REPLY COMMENTS.l
Clty of Boise
Mary Grant
Deputy GityAttorney
Boiee Ci$Attoney's ffice
150 N. Capito! Blvd.
P.O. Box 500
Boise, ldaho 83701{500
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boisecifu attornev@cfuofboise. oro
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Alisha Till, Paralegal
TDAHO POI'VER COMPAI.IYS REPLY COMMENTS .2