20220824Reply Comments.pdf

<Emr.
ANDACORPOOMBNY
P.O. Box 70 (&1707)
t2ll W. H.ho 5t.
Boisc, lD S1702
.- I r' ..liLISA D. NORDSTROM
load Counsel
[e-mail]
August 24,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-22-08
!n the Matter of the Application of ldaho Power Company for a Determination
of 2021Demand-Side Management Expenses as Prudently lncurred
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Reply Comments in the
above-entitled matter.
lf you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly youns,
X*!.ff^*t^-*,
Lisa D. Nordstrom
LDN:sg
Enclosures
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]
ln ord strom@ ida h ooowe r. com
Attorney for ldaho Power Company
BEFORE THE !DAHO 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. |PC-E-22-08
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) on August 3,2022, and the City of Boise City
('Boise City") on August 2,2022.
I. REPLY COMMENTS
ln its Comments, Staff concludes the Company's programs are generally well
managed and recommends the Commission approve $35,054,668 in DSM-related
expenditures including $27,921,690 in ldaho Energy Efficiency Tariff Rider expenses
(which includes an adjustment of $650 to reflect the exclusion of a duplicate sales tax
expense) and $7,132,978 in Demand Response ("DR") program incentives. ln their
Comments, Boise City also indicates a positive view of ldaho Power's 2021 Demand-Side
IDAHO POWER COMPANY'S REPLY COMMENTS.l
Management ('DSM') achievements, signals support for an increase in the Idaho Energy
Efficiency Rider ("Ride/') percentage, and addresses several other recommendations to
be explored with the Energy Efficiency Advisory Group ("EEAG'). ln these Reply
Comments, the Company briefly responds to issues and recommendations raised by Staff
and Boise City.
A. DSM Proqram Manaqement
Both Staff and Boise City acknowledge ldaho Power continues to make
improvements and adjustments to its DSM portfolio. The Company is committed to
continuing to work with EEAG to identiff potentia! cost-effective energy efficiency and DR
program improvements and offerings. These EEAG discussions will be informed by
current energy efficiency program operations, the Company's energy efficiency Potentia!
Study, the lntegrated Resource Plan analysis, the DR Potential Study, and the
Company's ann ual cost-effectiveness review.
The Company appreciates Staffs comments concerning cost assignment between
educational and marketing efforts, and direct energy efficiency measures, specifically with
regard to the Welcome Kits measure "where the intent of the kits is to educate and
market."l ln their comments, Staff suggests that "the Company provided sufficient
evidence that Welcome Kits often lead new ldaho Power customers to pursue other EE
programs" and encouraged the Company to reduce costs for the kits where possible and
focus the intent of the program on marketing and education.z ldaho Power believes the
Welcome Kits component of the Educational Distributions program is a valuable tool in
educating and promoting energy efficiency across its service area. The Company
appreciates Staffs comments and will continue to consult with EEAG to identiff ways to
1 StaffComments at 82 ld. at8.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
reduce costs for the Welcome Kits, as well as to explore ways to improve the measure to
focus on marketing and education.
B. Enerqv Efficiencv Rider Balance
ldaho Power appreciates Boise City's support for appropriate cost recovery of the
current under-collected Rider balance and support for a Rider percentage increase over
the current 3.10 percent approved in Order No. 34871. The Company notes that the
under-collected Rider balance has improved as DSM related expenses declined in 2021
as compared to 2020 due to the decrease in the number of Commercial & lndustrial
Custom Projects, prolonged suspension of on-site work for several programs related to
COVID-19, and supply chain disruptions impacting labor and materials needed for timely
project completion for various programs. While ldaho Power does not have a filing
planned to modiff the Rider collection at this time, it will continue to monitor the balance
and stands by its commitment to pursuing all cost-effective energy efficiency regardless
of the Rider balance as expressed in previous cases and stakeholder discussions.3
il. coNcLustoN
ldaho Power appreciates the ongoing collaboration with Staff, EEAG, and
interested stakeholders to continually improve its energy efficiency offerings. The
Company respectfully requests that the Commission issue an Order finding ldaho
Power's expenditures of $27,921 ,690 in Rider funds and $7,1 32,978 of demand response
program incentives, for a total of $35,054,668 as prudently incurred DSM expenses.
3 ln the Mafter of ldaho Power Company's Application for Authority to Reylse the Energy Efficiency Rider, Tariff
Schedule 97, Case No. IPC-E-20-33, Reply Comments, p. 1-2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
DATED at Bobe, ldaho, this 24b day of August2022.
X; !.7(^*t^*-,
LISA D. NORDSTROM
Attomey for Idaho Power Company
IDAHO POWER COMPATIYS REPLY COMMENTS - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 24th day of August 2022, I served a true and
correct copy of ldaho Power Company's Reply Comments upon the following named
parties by the method indicated below, and addressed to the following:
&r"i.
Stacy Gust, Regulatory Administrative
Assistant
Commission Staff
Riley Newton
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., BIdg No.8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
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City of Boise
Ed Jewell
Boise City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701-0500
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Bo ise C itvAttornev@citvofbo ise. o rq
Wil Geh!
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701 -0500
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FTP SiteX Email:[e-mail]
IDAHO POWER COMPANY'S REPLY COMMENTS - 5