20220315Application.pdf

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An IDACORP Companv
PO. Box 70 (83707)
1221 W. ldaho 5t.
Boise, lD 83702
Jil:
LISA D. NORDSTROM
Lead Counse!
[e-mail]
March 15,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re Case No. IPC-E-2?-OB
!n the Matter of the Application of ldaho Power Company for a Determination
of 2021 Demand-Side Management Expenses as Prudently lncurred
Dear Ms. Noriyuki
Attached for electronic filing, pursuant to Order No. 35058, is ldaho Power Company's
Application and the Direct Testimony of Robert Z. Thompson in support of the Application
in the above entitled matter. Due to the voluminous nature of the attachments to the
Application, the Company is posting the PDF files to the secure FTP site. The login
information will be provided separately.
A Word version of the testimony will also be sent in a separate email for the
convenience of the Reporter.
ln addition, seven (7) copies of the Application, Direct Testimony, and the DSM 2021
Annual Report will be hand delivered to the Commission.
!f you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
"(* !.("1-+r"-*,
LDN:sg
Enclosures
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom @idahopower. com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2021 DEMAND.SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. IPC-E-22-08
APPLICATION
ln accordance with RP 052 and RP 201, et. seg., Idaho Power Company ("ldaho
Powe/' or "Company") submits its Demand-Side Management 2021 Annual Report
("DSM 2021 Annual Report") and makes Application to the ldaho Public Utilities
Commission ("Commission") for an order designating ldaho Power's expenditures of
$27,922,U0 in ldaho Energy Efficiency Rider ("Ride/') funds and $7,132,978 of demand
response program incentives funded through base rates and tracked annually through
the Power Cost Adjustment ('PCA') mechanism, for a total of $35,055,318, as prudently
incurred demand-side management ("DSM") expenses.
In support of this Application, ldaho Power represents as follows:
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APPLICATION. 1
I. INTRODUCTION
1. "The Commission has consistently stated that cost-effective DSM programs
are in the public interest and has admonished electric utilities operating in the state of
Idaho to develop and implement DSM programs in order to promote energy efficiency."
Case No. IPC-E-10-09, Order No. 32113 at 8, citing Order Nos. 29784 and 29952. To
further the Commission's objective, ldaho Power informs its customers of a wide range
of opportunities to participate in DSM activities and provides information that allows them
to use electricity wisely. Through DSM programs, ldaho Power seeks to provide
customers with programs and knowledge to help them manage their energy use and to
utilize cost-effective DSM resources to meet the Company's electrical system's energy
and demand needs.
2. ln 2O21, ldaho Power achieved 16.4 average megawatt-hours ("aMW') of
incremental energy efficiency savings, including Northwest Energy Efficiency Alliance
("NEEA') estimated energy savings, which exceeded the economic technical achievable
potential included in the 2021 IRP of 15.4 aMW. DSM 2021 Annual Report at 1. The
2021 savings represent enough energy to power approximately 12,600 average homes
in ldaho Power's service arealor one year.
3. However, it was a challenging year due to residual impacts of COVID-19,
the resulting supply chain issues, higher labor and material costs, and the maturity of the
residential lighting market. The C&l Custom Projects option, which provides
approximately 40 percent of the portfolio savings, returned savings comparable lo 2O17
and 2018 as opposed to the record setting years of 2O19 and 2O2O. Direct Testimony of
Robert Z. Thompson ("Thompson Testimony") at 9-1 1. Consequently, the 2021 savings
APPLICATION - 2
of 143,971 megawatt-hours ("M\Nh'), which includes the estimated savings from the
NEEA, decreased by 54,461MWh compared to the 2020 savings of 198,433 MWh-a 27
percent year-over-year decrease. The savings from Idaho Power's energy efficiency
programs alone, excluding NEEA savings, was 126,102 M\[/h in2021and 180,818 M!ryh
in 2O2O-a 30 percent year-over-year decrease. DSM 2021 Annual Report at 1.
4. ldaho Power saved an estimated 17,870 M\ /h1 of energy efficiency market
transformation savings through NEEA initiatives. Thompson Testimony al6-7. From its
demand response programs, ldaho Power achieved a total demand reduction of 313
megawatts ('MW') from an available capacity of 384 MW during the 2021 program
season. Thompson Testimony at 12-13.
II. CONTENTS OF THE DSITII 2O2t ANNUAL REPORT
5. ldaho Power's DSM 2021 Annual Report is included as Attachment 1 to this
Application. The DSM 2021 Annual Report satisfies the DSM reporting obligation set
forth in Commission Order No. 29419 in Case No. IPC-E-03-19. The Company's actions,
as detailed in the DSM 2021 Annual Report, demonstrate the conscientious work ldaho
Power undertook to expend funds wisely to further DSM activities.
6. The DSM 2021 Annual Report consists of the main document (with
appendices) and two supplements. The main report provides information on DSM
program descriptions, program performance, expenditures, and marketing efforts.
Supplement 1: Cost-Effecfiveness ("Supplement 1") to the DSM 2021 Annua! Report
shows the results of the cost-effectiveness tests that ldaho Power has calculated for each
program and includes a table that reports expenses by funding source and cost category.
1 Because ldaho Power will not receive afinal2O2l savings report form NEEA until second quarler 2022,
the NEEA-attributable savings is an estimate provided to the Company from NEEA.
APPLICATION - 3
Supplement 2: Evaluation ("Supplement 2") to the DSM 2021 Annual Report contains
copies of ldaho Power's 2021 program evaluations, customer surveys and reports,
evaluations conducted by the Company's third-pafi contractors, ldaho Power's
evaluation plans, general energy efficiency research, and demand response research.
Each of these evaluations reflects ldaho Power's continued commitment to its review and
independent third-pafi program evaluation. Finally, the DSM 2021 Annual Report
contains a description of the Company's DSM strategies tor 2022.
!II. 2021 DSM PROGRAM PERFORMANCE
7. ln 2021, ldaho Power offered its customers a broad portfolio of energy
efficiency programs and demand response programs, participated in market
transformation efforts through NEEA, and offered several educational initiatives and other
activities. DSM 2021 Annual Report at 5, Table 1. As explained in more detai! in the
Thompson Testimony filed contemporaneously with this Application, ldaho Power's
annual energy savings combined with NEEA estimated annual energy savings resulted
in an incremental energy efficiency savings of 16.4 average megawatt-hours ("aMW'),
exceeding the economic technical achievable potential included in ldaho Power's 2021
lntegrated Resource Plan ("lRP"). Thompson Testimony at 7-8.
8. The2021 savings results on a system-wide basis consisted of 21,217 M\ Jh
from the residentialsector, 95,184 MWh from the commercial/industrialsector, and 9,700
M\[/h from the irrigation sector. DSM 2021 Annual Report at 10, Table 4. The C&l
programs contributed 75 percent of the direct program savings. ln the residentia! sector,
Home Energy Reports contributed the largest savings al75 percent and Educational
Distributions contributed the second largest savings at 14 percent, for a combined total
savings of 89 percent. DSM 2021 Annual Report at 8. Appendix 3 of the DSM 2021
APPLICATION - 4
Annual Report contains a complete list of programs and sector-level savings.
9. Idaho Power successfully operated all three of its demand response
programs in 2021. These programs have a capacity of over 10 percent of its all-time
system peak load available to respond to a system peak load event during the summer.
ldaho Power achieved a total demand reduction of 313 MW from an available capacity of
384 MW during lhe 2O21 program season. DSM 2021 Annual Report at 9. This value
represents the maximum realized, non-coincident load reduction from allthree programs.
Because the Company's Load Serving Operations Group utilized the flexibility of the four
irrigation participant groups individually in 2O21 based on system need while taking into
consideration customer impacts, the 313 MW of reduction was lower compared to
previous years because the irrigation program was not fully utilized for any single demand
response event. Thompson Testimony al12-13.
10. Table 1 on page 5 of the DSM 2021 Annual Report contains a list of ldaho
Power's DSM programs by sector, operational type, and location. The table illustrates
the broad suite of programs that ldaho Power offers to its customers in energy efficiency,
demand response, and education. ldaho Power's energy efficiency portfolio was also
cost-effective, resulting in a 2.17 benefiUcost ratio when evaluated from a Utility Cost Test
("UCT') perspective, a2.18 benefiUcost ratio when evaluated from a Total Resource Cost
("TRC') test perspective, and 2.73 benefiUcost ratio when evaluated from a Participant
Cost Test ("PCT') perspective. Thompson Testimony at 6.
11. COVID-19 continued to impact the Company's DSM activity in 2021, as
some activity was still suspended through large portions of the year that included person-
to-person interactions such as installers in customer homes, in-person trade shows, in-
person vendor trainings, and contractors working at business sites. These actions were
APPLICATION - 5
necessary, prudent, and continued to be in the best interest of customers, employees,
and contractors' safety. The Company also made operationa! adjustments to several
programs to provide program offerings while maintaining appropriate safety protocols.
The Tables on Page 6 of the DSM 2021 Annua! Report summarize the status of the
individual programs and how they were affected by COVID-19 during 2021.
12. The pandemic's impact on the nation's supply chain also slowed work in the
Company's C&l and lrrigation programs. Customers experienced labor and material
constraints, as well as overall increases in costs, making it more difficult and expensive
to complete projects timely. Therefore, even if the pandemic did not directly affect the
Company's ability to perform on-site work in a given program during 2021, it continued to
have an impact on each of the Company's DSM programs in some way. Thompson
Testimony at 11-12.
IV. 2021 DSM EXPENSES AND ADJUSTMENTS
13. Funding for the ldaho DSM programs in 2021 came from several sources.
The ldaho Rider funds are collected directly from customers on their monthly bills at 3.10
percent of their base rate revenues. Additionally, the ldaho demand response program
incentives are included in base rates and tracked annually through the PCA. Energy
efficiency and demand response-related expenses not funded through the Rider are
included in ldaho Power's ongoing operations and maintenance ('O&M') costs.
14. ln 2021, the Company's total system-wide expenditures on DSM-related
activities totaled $38,353,506. DSM 2021 Annua! Report at 10, Table 4. This figure
includes expenditures for Oregon and other O&M expenses that are not before the
Commission as part of this prudence request. ln this filing, ldaho Power seeks a
determination that a total of $35,055,318 were prudently incurred in 2021 ($27,922,340
APPLICATION.6
in Rider expenses and $7,132,978 in demand response program incentives). This is a
decrease of $12,554,703, or31 percent, in Rider-funded expenses compared to the DSM
expenses reviewed in last year's prudence case, and this is primarily due to the decrease
in large projects participating in the C&l Program Custom Projections option. Thompson
Testimony at 15. A summary of the 2021 program expenditures by program, customer
sector, and funding source for which the Company is seeking a prudence determination
is provided as Exhibit No. 1 to the Thompson Testimony.
15. ldaho Power made three prior-year and three current-year accounting
adjustments that were necessary to accurately account for the tolal2021 DSM expenses
for purposes of the prudence determination in this case. Thompson Testimony at 15-18.
ldaho Power has included each of these adjustments in Exhibit No. 1 to the Thompson
Testimony. The first prior-year adjustment of $2,159 was completed in 2020 to
appropriately allocate an invoice to the ldaho jurisdiction at 95 percent rather than 100
percent; this amount must be added back to avoid understating the 2021 prudence
request. The second prior-year adjustment reversed a credit of $57 that was incorrectly
applied to the ldaho Rider during 2020 instead of the Company's Green Power program,
which is a non-Rider funded program; this amount must be removed from the 2021
balance because it was already deemed prudent by the Commission in the 2020
prudence filing. The third prior-year adjustment was a reversing entry of $15,910 for the
Small Business Direct lnstall ('SBDI') program that is excluded from the 2021 DSM
expenses as it was already deemed prudent by the Commission in the 2020 prudence
filing.
APPLICATION - 7
16. The firct current-year adjustment adds $1,356 of expenses associated with
ldaho activity forthe Residential New Construction Program thatwere incorrectly charged
to the Oregon Energy Efficiency Rider in 2021. The second current-year adjustment
reduces $1,044 of expenses associated with the Commercial & lndustrial program that
should have been charged to the Oregon Rider instead of the Idaho Rider. The final
current-year adjustment of $7,260 (2021 SBDI) corrects a duplicate transaction to remove
it from lhe 2021 prudence request.
17. \Mren issuing its determination on the appropriate level of DSM-labor
funded through the Rider in the 2019 DSM prudence evaluation, the Commission stated
that ldaho Power "shall apply lhe2o/o cap to actual average wages per [full-time employee]
going fonlrrard. The baseline for the 2o/o cr,p shall be the prior year's actual average wages
per [full-time employee]." Case No. IPC-E-20-15, Order No. 34874 at 5. ldaho Power's
Rider-funded DSM employee labor expense in 2021 totaled $3,205,211. Thompson
Testimony at 18-19. This amount is appropriately recovered through the Rider as it is
lower than the Commission's authorized labor cost cap detailed in Order Nos. 34874 and
35270. The 2021 DSM labor expense was $28,722 under the cap as detailed in Table 2
of the Thompson Testimony.
V. DSM PROGRAiN COST.EFFECTIVENESS AND EVALUATIONS
18. The DSM 2021 Annual Report and accompanying Thompson Testimony
provides a sufficient basis for the Commission to determine whether Idaho Poweds DSM
expenses were prudently incurred.
19. To calculate cost-effectiveness, the DSM 2021 Annual Report uses
benefiUcost methodologies used in previous DSM annual reports, including the UCT, the
APPLICATION - 8
TRC test, and the PCT. A review of each test allows for an economic assessment of the
lifecycle costs and benefits of a DSM investment from the perspective of ldaho Power,
DSM program participants, and non-participating customers. ldaho Power calculates
cost-effectiveness from the TRC test, UCT, and PCT perspectives at the program level
except for those programs with no customer costs, in which case the PCT is not
applicable. lf a program is not cost-effective under any one of these tests, ldaho Power
seeks EEAG input before making a determination to modify, continue, or discontinue the
program. Thompson Testimony at 20-21. Cost-effective test methodologies are
described in more detail in Supplement 1 to the DSM 2021 Annual Report.
20. While the Commission continues to assess the prudence of DSM
investments under "the totality of the circumstances," the Commission also believes that
public utilities may "emphasize the UCT-and that test's focus on Company-controlled
benefits and costs-to argue whether programs were cost-effective." Case No. IPC-E-
15-06, Order No. 33365 at 9-10. Thus, the Company continues to conduct all three
benefiUcost methodologies while using the UCT perspective as its primary test for
evaluating program cost-effectiveness in ldaho and energy efficiency resources in the
IRP planning cycle.z Thompson Testimony at21-22. ldaho Power continues to engage
EEAG in reviewing benefiUcost analyses for current and potential programs, and the
Company has incorporated EEAG's feedback to develop its ongoing DSM programs.
21. Supplement 1 to the DSM 2021 Annual Report includes detailed results of
the cost-effectiveness tests by program and by measure. As shown in Supplement 1, the
overall DSM portfolio achieved benefiUcost ratios greater than 1.0 from the perspective
2 ln final Order No. 34469, the Commission directed ldaho Power to use the UCT perspective for DSM
programs in the IRP context. Case No. IPC-E-19-11, Order Nos. 34469 at 9 and 34503 at 4.
APPLICATION.9
of all three cost-effectiveness tests. ldaho Power's cost-effectiveness test results for
2021 energy efficiency programs are summarized as follows:
Portfolio Basis. On a portfolio basis, Idaho Power's energy efficiency programs
are cost-effective, passing the UCT, TRC test, and PCT with ratios of 2.17, 2.18, and
2.73, respectively. The Company's energy efficiency programs' customer sector-level
portfolios were also cost-effective from a UCT and PCT perspective with the Residential
Sector having a TRC less than 1.0. Thompson Testimony at23, Table 4.
Proqram Basis. On an individual program basis, 10 of the 16 energy efficiency
programs offered in ldaho for which the Company calculates cost-effectiveness had
benefiUcost ratios greater than 1.0 under the UCT. Thompson Testimony at 25. The
following programs were not cost-effective under the UCT in 2021
. WAQC and Solutions: Two programs that scored less than 1.0 under the UCT
were the Company's Weatherization Assistance for Qualified Customers
("WAQC') and Weatherization Solutions for Eligible Customers ("Solutions").
\Mile these programs are not cost-effective under the UCT, ldaho Power will
continue to offer these programs to its limited-income customers unless the
Commission directs otherwise. Thompson Testimony at26-28. ldaho Power will
also continue to work with EEAG and weatherization managers to identify
opportunities that might improve the cost-effectiveness of these programs.
. Energy House Calls: The Energy House Calls program experienced reductions in
participation due to the COVID-19 pandemic because these programs require
contractors to enter customers' homes. The likelihood of the Energy House Calls
program becoming cost-effective is low because the savings are expected to
APPLICATION. 1O
decline as savings assumptions and avoided costs are updated. After consultation
with EEAG, ldaho Power decided to end the Energy House Calls program and
incorporate the cost-effective duct sealing measure for manufactured homes into
the Heating & Cooling Efficiency program. The Company intends to make this
change by the end of June2022 but willwork through the remaining customers on
the waitlist before ending the program. Thompson Testimony al28-29.
Multifamily Energy Savrngs: The Multifamily Energy Savings program also
experienced significant reductions in participation due to the COVID-19 pandemic
because these programs require contractors to enter customers' homes and did
not see any participation once in-home work resumed in December 2021.
Additionally, the program is facing an expected decline in Regional Technical
Forum ("RTF') savings, which coupled with lower DSM avoided costs, means the
program may not achieve cost-effectiveness going fonlrard. After consultation with
EEAG, the Company intends to convene a group of external and internal subject
matter experts to discuss the issues facing the program, which will include seeking
to identiff whether cost-effectiveness can be improved, or in the alternative, if the
Company should consider ending the program. The Company expects to decide
on the continuation of the program by August 2022. Thompson Testimony a|29.
Home Energy Reporfs: The Home Energy Report program achieved a UCT of 0.57
and a TRC of 0.62 largely due to the relatively short measure life of the reports
and the realized savings coming in lower than what was initially
expected/contracted. The Company plans to conduct an impact evaluation in
2022, and the evaluation may help inform the Company about any needed
a
a
APPLICATION. 11
changes to the program in the future. Additionally, the Company intends to discuss
the program with EEAG, incorporate any updates in RTF behavioralprogram cost-
effectiveness calculations, and potentially decide on the program's future by the
end of 2022. Thompson Testimony at 30-31.
o SBD/; The SBDI program achieved a UCT of 0.99 and a TRC of 1.54, which was
primarily driven by the evaluation costs the program absorbed this year associated
with the 2020 process evaluation completed in 2021. lf the evaluation costs are
removed, the UCT and TRC ratios for the program would be 1.00 and 1.55
respectively. The Company plans to expand the offering to the Capitaland Canyon
regions of its service area in 2022, which may improve cost-effectiveness. ldaho
Power will continue to monitor the SBDI program's cost-effectiveness and will
consult with EEAG prior to making any future program decisions. Thompson
Testimony at 31.
Measures Basis. ln 2O21, ldaho Power evaluated the benefits and costs of 272
measures. Thompson Testimony a|25. The results of these calculations, along with
measure assumption details and source determination, can be found in Supplement 1 to
the DSM 2021 Annual Report.
22. For 2021, ldaho Power determined the cost-effectiveness of its demand
response programs based on the levelized annual cost of a 17O MW deferred resource
over a 2O-year lifespan that was established in the seftlement reached in Case No. !PC-
E-13-14 and subsequently approved in Commission Order No. 32923. The system-wide
cost of operating the three demand response programs was approximately $8.3 million
($7.5 million of incentives and $0.8 million of other costs) in 2021. The amounts
APPLICATION - 12
attributable to the ldaho-only jurisdiction were $7.9 million ($7.1 million of incentives and
$0.8 million of other costs). ldaho Power estimated that if the three programs were
dispatched for the full 60 hours allowed, the tota! costs would have been approximately
$11.1 milliononasystem-widebasis. The2O21 total programcostsarelessthanthe
value of demand from the most recently acknowledged IRP, the Second Amended 2019
lRP, of $19.6 million. Thompson Testimony at31-32.
23. Prooram Evaluations. In addition to the annual cost-effectiveness analysis
the Company conducts for each program, the results of which are included in Supplement
1 to the DSM 2021 Annual Report, ldaho Power solicits and contracts with independent
third-pafi consultants to provide program evaluations. ldaho Power uses the results of
these evaluations to improve its DSM programs, compare Company processes to industry
best practices, and benchmark reported program savings. ln 2O21, these independent,
third-party consultants conducted five program impact evaluations and four program
process evaluations. ldaho Power also completed internal analyses of the three demand
response programs. Thompson Testimony at 34. The Commission can find copies of
these reports and the Company's program evaluation plan for 2022-23 in Supplement2.
24. As the Commission directed on page 9 of Order No. 35720, the Company
is currently working with Avista Corporation on a Request for Proposal to hire a third-party
that will conduct the Evaluation, Measurement, and Verification of NEEA savings and
cost-effectiveness. The Company expects the evaluation to be completed by the end of
2022. Results will be reported in the 2022 DSM Annua! Report or sooner if the Company
determines its participation in NEEA may no longer be cost-effective. Thompson
Testimony at 36-37.
APPLICATION. 13
VI. DSM STRATEGIES FOR 2022
25. 'DSM benefits depend on constantly evaluating opportunities and
identiffing ways to improve available programs." Order No. 35270 at 8. As described on
pages 16-18 of the DSM 2021 Annual Report, ldaho Power is actively working to improve
the cost effectiveness of existing DSM programs and to explore the addition of new DSM
offerings for customers in 2022 and beyond. Some of these activities in 2022 include:
. Launch of a new Lighting Buy-Down program;
. A Find and Fix offering within the C&l Custom Projects program;
. A Compressed Air Leaks offering within the C&l Custom Projects program;
. New C&l Retrofits and New Construction measures with expanded
eligibility;
o lmplementation of a new lndustrial Wastewater Cohort;
o Measurement and Verification for participating Custom Projects Energy
Management customers via the U.S. Department of Energy-sponsored
Technica! Assistance Program; and
. Integrated Design Lab assessment of energy savings potential for Power-
Over-Ethernet lighting, Luminaire Level Lighting Controls demonstration
workshops, and update of digital design tools for use by architects and
engineers.
VII. STAKEHOLDER INPUT
26. ldaho Power relies on input from EEAG to provide a customer and public
interest review of energy efficiency and demand response programs and expenses.
EEAG provides input on enhancing existing DSM programs and on implementing new
APPLICATION - 14
DSM programs. Currently, EEAG consists of members representing a cross-section of
customers from the residential, industrial, commercial, and irrigation sectors, as well as
representatives for low-income individuals, environmental organizations, state agencies,
public utility commissions, and ldaho Power.
27. Normally, EEAG holds quarterly in-person meetings at ldaho Power's
corporate offices and through webinars as needed. Due to COVID-19 safety protocols,
all EEAG meetings were held virtually in 2021, and the Company believes the member
participation and input remains strong in the virtual format. Specifically, ldaho Power
worked with EEAG on developing, designing, and promoting several projects related to
COVID-19, use of WAQC carryover funds, Welcome Kit configuration, and solicited
feedback on demand response program modifications prior to filing the Company's
proposal in Case No. IPC-E-21-32.
VIII. MODIFIED PROCEDURE
28. ldaho Power believes that a technical hearing is not necessary to consider
the issues presented herein and respectfully requests that this Application be processed
under Modified Procedure, i.e., by written submissions rather than by hearing. RP 201,
ef. seg. ldaho Power has, however, contemporaneously filed the Thompson Testimony
in support of this Application. The Company stands ready to present the testimony
supporting this Application in a technical hearing if the Commission determines such a
hearing is required.
IX. COMMUNICATIONS AND SERVICE OF PLEADINGS
29. Communications and service of pleadings with reference to this Application
should be sent to the following:
APPLICATION - 15
zthom pson@ idahopower. com
X. REQUEST FOR RELIEF
30. As described in greater detail above, ldaho Power respectfully requests that
the Commission issue an order designating ldaho Power's 2021 DSM expenses of
$35,055,31 8 as prudently incurred.
Respectfully submitted this 15th day of March 2022.
Lisa D. Nordstrom
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
! n ord strom @ idah opower. com
dockets@idahopower. com
Connie Aschenbrenner
Zack Thompson
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
caschenbren ner@idahopower. com
X,* rt.(r""t-+r"-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
APPLICATION - 16