20220504Application.pdf

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Lisa D. Nordstrom
AnDICOIPComrf,
P.O. Bor r0 (t3707)
1221 W. ld.ho St.
Bok ,lD &t702
I D:J +. {'i'l-,. . ii U'iilJ
USA D. NORDSTROiII
Lerd Counsel
[e-mail]
May 4,2422
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Buifding 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. !PC-E-22-15
Application of ldaho Company for Modifications to Schedule 79,
Weathe rization Assista nce for Qu al ifi ed Customers
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Application in the above-
entitled matter.
lf you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
&, !.Y^1.t.-*,
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]
I nordstrom@ida hopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILIT!ES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
MODIFICATIONS TO SCHEDULE 79,
WEATH ERIZATION ASSI STANCE FOR
QUALIFIED CUSTOMERS.
CASE NO. IPC-E.22-15
APPLICATION
ldaho Power Company ("ldaho Power" or "Company"), in accordance with ldaho
Code S 61-503 and RP 52, hereby respectfully applies to the ldaho Public Utilities
Commission ("Commission") for an order authorizing modifications to Tariff Schedule 79,
Weatherization Assistance for Qualified Customers ("Schedule 79"). The update will allow
the Company to utilize the program's carryover funds to pay up to 100 percent of HVAC
upgrades on homes that were previously weatherized under Schedule 79 but did not
receive HVAC upgrades. The objective of this proposa! is to proactively address the
growing amount of surplus funds that have accumulated as a result of the COVID-19
pandemic, supply chain limitations, and labor shortages. This proposal will serve to
benefit qualifying low-income customers and was developed through mutual and
extensive collaboration with the Company's Energy Efficiency Advisory Group (.EEAG')
and other stakeholders. The tariff changes are outlined in Attachment 1 to this Application.
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APPLICATION - 1
ln support of this Application, ldaho Power represents as follows:
I. PROGRAM HISTORY
1. ldaho Power Company began offering the Low-income Weatherization
Assistance ('LIWA") program in 1989 in conjunction with the State of ldaho's
Weatherization Assistance Program ('WAP'). Through the LIWA program, the Company
provided supplementary funding to state designated Community Action Partnership
("CAP") agencies for the weatherization of homes occupied by qualified low-income
customers as well as buildings occupied by non-profit organizations. The program was
renamed Weatherization Assistance for Qualified Customers ('WAQC') in 2005.
Currently, the Company oversees the program in ldaho through five regional CAP
agencies: Eastern ldaho Community Action Partnership ("E!CAP"), El Ada Community
Action Partnership ("EL ADA'), Metro Community Services ("Metro Community"), South
Centra! Community Action Partnership ('SCCAP"), and Southeastern ldaho Community
Action Agency ('SEICAA').
2. The WAQC program has gone through several changes since its inception
in 1989. Significant program modifications were made in 2004 following the May 2004
issuance of Commission Order No. 29505 in Case No. IPC-E-03-13. The Commission
directed the Company to increase the $0.2 million of annualprogram funding by $1 million
through June 2007. The Commission also directed the Company to carry fonuard to the
following year any unpaid funds; to negotiate with Community Action Partnership
Association of ldaho ('CAPAI') regarding structural modifications to the program; and to
report annually on program activities in a separate report outside of the Company's
Demand-Side Management Annual Report.
APPLICATION - 2
3. Shortly after the Commission issued Order No. 29505, the Company
entered into discussions with CAPAI and its member agencies to negotiate several
modifications to the program. The Company signed new contracts with each of the CAP
agencies effective August 1, 2004. The new contracts served to allocate the increased
funding as well as to put into process the program modifications.
4. ln addition to the contract modifications, the Company implemented several
internal changes related to program operation. The invoice payment process was
automated, and enhancements were made to the Company's program database. The
structuralchanges more closely aligned the Company's program with the State of ldaho's
WAP specifications and allowed the CAP agencies to more effectively administer the
program. A new program specialist primarily dedicated to overseeing the operation of this
program was hired in2004.
5. ln order No. 30350 issued in 2007, the Commission directed that 'ldaho
Power shall continue its annual funding of this program at $1.2 million per year," which
remains the current level of funding for the program. ln January of each year, the
Company continues to renew its contract with each agency detailing the funding
allotment, billing requirements and program guidelines for both qualiffing homes and non-
profit organizations.
II. WAQC PROGRAIII OVERVIEW
6. The WAQC program provides financial assistance to regional CAP
agencies in ldaho Power's service area. This assistance helps fund weatherization costs
of electrically heated homes occupied by qualified customers who have limited incomes.
Weatherization improvements enable residents to maintain a more comfortable, safe, and
APPLICATION - 3
energy-efficient home while reducing their monthly electricity consumption and are
available at no cost to qualified customers who own or rent their homes. These customers
also receive educational materials and ideas on using energy wisely in their homes. Local
CAP agencies determine participant eligibility according to federal and state guidelines.
The WAQC program also provides limited funds to weatherize buildings occupied by non-
profit organizations that serve primarily specia! needs populations, regardless of heating
source, with priority given to electrically heated buildings.
7. Annually, ldaho Power verifies a portion of the homes weatherized under
the WAQC program through two methods. The first method uses ldaho's monitoring
processes for weatherized homes. The state of ldaho hires the quality-control inspector,
who ensures measures were installed to Department of Energy ("DOE') and state WAP
specifications. Utility representatives, weatherization personnel from the CAP agencies,
CAPAI, and a Building Performance lnstitute-certified quality control inspector review
homes weatherized by each of the CAP agencies.
8. For the second verification method, ldaho Power contracts with two
companies that employ building performance specialists to veriff the installed measures.
After verification, any required follow-up is done by CAP agency personnel. ldaho Power
reports the activities related to the WAQC each March in the Company's Demand-Side
Management Annual Report per Order No. 33702.
III. PROGRAII FUNDING. CARRYOVER. & ACTIVITY
9. The base funding for the WAQC program is $1,212,534 annually, which
does not include carryover from the previous year. ldaho Power's agreements with CAP
agencies include a provision that identifies a maximum annualaverage cost per home up
APPLICATION - 4
to a dollar amount specified in the agreement between each CAP agency and ldaho
Power. The intent of the maximum annual average cost allows the CAP agency flexibility
to service some homes with greater or fewer weatherization needs. !t also provides a
monitoring tool for ldaho Power to forecast year-end outcomes. The average cost per
home weatherized is calculated by dividing the totalannual ldaho Power production cost
of homes weatherized by the total number of homes weatherized that the CAP agencies
billed to ldaho Power during the year. This excludes CAP agency administration fees that
are equalto 10 percent of ldaho Power's per-job production costs. The maximum annua!
average cost per home in the 2021 agreement was $6,000.|n 202'1, ldaho CAP agencies
had a combined average cost per home weatherized of $5,592.
10. As directed by the Commission on page 32 of Order No. 29505, "[a]ny
unpaid funds shall carry over and be available in the next year." ln 2021, ldaho Power
made $1,861 ,402available to ldaho CAP agencies, of which $048,868 were unspentfrom
2020. Of the funds provided, $990,416 were paid to ldaho CAP agencies, while $870,985
were accrued for future funding in 2022. Chart 1 shows the base funding plus the
carryover funds that combine to make the annual budget of the WAQC program since
2015.
APPLICATION - 5
Chart 1. Annual WAQC Budget by Annual Allotnent and Garryover 2015-2022
WAQC Annual ldaho Budget with Carryover 2015 -2022
s2,000,000
s1,s00,000
s38,1s9
sl,ooo,ooo
ss00,000
So 2015 2016 2011 2018 2019
I Annual Allotment I Carryover (from prior year)
2020 202L 2022
-gpsnd
11. The increase in oarryover over the past couple of years has been primarily
driven by COVID-19 in-home activity restrictions, supply ctain limitations, and labor
shortages limiting the number of homes CAP agencies weatherized. To help keep
weatherization crews and customers safe from exposure to COVID-I9, CAP agencies
suspended weatherization activities for ldaho Power's WAQC program in March 2020,
and most resumed work starting in May 2020. The DOE also required CAP agencies to
follow Centers for Disease Contro! and Prevention ("GDC') and DOE COVID-l9
guidelines. Various CAP agencies performed certain weatherization activities under CDC
and DOE guidelines throughoul 2021. Because weatherization personnel provided
services for the state WAPs between March and December, ldaho Power partnered with
CAP agencies within its service area to leverage state and federal funding along with its
funding.
APPLICATION.6
12. Chart 2 illustrates the decrease in the number of homes weatherized by the
WAQC program in 2020 and 2021 as compared to 2017-2019. The decrease in the
number of homes weatherized is directly conelated with the increase in carryover funds
for the WAQC program with the 2022budget exceeding $2.0 million.
Chart 2. Number of WAQC Homes Completed by Year 2017-2021
WAQC Number of Homes Completed 2077-2027
250
190 193
2018 20L9 2020 2027
IV. RE.WEATHERIZATION PROJECTS PROPOSAL
13. The Company's re-weatherization proposal is designed to address the
increasing amount of carryover funds that have accumulated over recent years and to
proactively provide CAP agencies flexibility in using those funds to improve low-income
customers' living conditions and their quality of life. This proposal does not impact the
current WAQC program structure and can be considered a separate addition to the
program.
14. ldaho Power is requesting a change to Schedule 79 that will allow the
Company to fund up to 100 percent of re-weatherization proiects using only the program's
carryover funds for HVAC upgrades. ln collaboration with stakeholders, the Company is
proposing to define "re-weatherization projects" as homes that have previously been
weatherized through WAQC within a rolling 14-year period and did not have an HVAC
195
151
115
200
150
100
50
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0
2077
APPLICATION. T
replacement or had an inoperable heat system. Under the current tariff structure, at least
15 percent of the total cost of qualiffing conservation measures must be funded by the
DOE, and DOE funds cannot be used at the same site within a rolling 14-year period.
Therefore, re-weatherization projects will not utilize DOE funds and sites weatherized with
DOE funds within a rolling 14-year period willnot be eligible for re-weatherization. Homes
outside of the 14-year period would be able to requaliff forthe standard WAQC program.
ldaho Power estimates that there are approximately 1,000 homes eligible for re-
weatherization.
15. Eliqibilitv. The full list of eligibility requirements developed and discussed
with stakeholders is provided as Attachment 2 to this Application. Generally, eligible
customers would include those who previously qualified for the WAQC program but did
not receive an HVAC replacement at the time. Some of the requirements in Attachment
2 may be subject to change once re-weatherization projects begin and more information
is gathered through stakeholder collaboration and feedback.
16. Fundinq. The Company proposes that re-weatherization projects only be
funded by surplus carryover funds that have accumulated in accordance with Order No.
29505. As shown in the charts above, the accumulation of carryover funds has increased
over the past two years due to a decrease in the number of homes weatherized. Re-
weatherization projects will only be considered and completed if carryover funds are
available. lf carryover funds are not available, the standard WAQC program remains
available to qualified customers. This proposalalso does not prohibit the standard WAQC
program from using carryover funds.
APPLICATION. S
17. The Company will work with the CAP agencies to appropriately prioritize
projects and account for the type of funding utilized for both standard WAQC projects and
re-weatherization projects. lf approved, the Company will report the re-weatherization
project results in its Demand-Side Management Annual Report.
V. STAKEHOLDER INPUT
18. ln developing the proposal in this case, the Company collaborated with
weatherization personnel from CAP agencies, CAPAI, and its EEAG. All parties
recognized the growing amount of carryover funds and mutually agreed to proactively
address the situation in a way that would enhance the WAQC program to the benefit of
low-income customers. The Company believes the collaborative efforts, and resulting
proposal, is consistent with the Commission's expectations as outlined on page 32 ot
Order No. 29505: "Furthermore, we believe ... the CAP agencies should be allowed to
submit reimbursements up to the fullcost of weatherizing a home, [...1, and other program
design changes should be negotiated between ldaho Power and CAPAI.'
19. Through several formal and informal meetings and conversations, the
Company has incorporated substantial stakeholder input into the proposal with the
objective of using the excess carryover funding to the benefit of low-income customers
outside of the current WAQC program structure. Options were discussed at both the
November 2021 and February 2022 EEAG meetings with the current proposal outlined in
this Application receiving the majority of the EEAG stakeholders' support.
VI. MODIFIED PROCEDURE
20. ldaho Power believes that a technical hearing is not necessary to consider
the issues presented herein and respectfully requests that this Application be processed
APPLICATION - 9
under Modified Procedure, i.e., by written submissions rather than by hearing. RP 201,
ef. seg.
VII. COMMUNICATIONS AND SERVICE OF PLEADINGS
21. Communications and service of pleadings with reference to this Application
should be sent to the following:
VIII. REQUEST FOR RELIEF
22. As described in greater detail above, ldaho Power respectfully requests
that the Commission issue an order accepting the proposed tariff changes to Schedule
79, Weatherization Assistance for Qualified Customers, to include re-weatherization
projects.
Respectfully submitted this 4th day of May 2022.
Lisa D. Nordstrom
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
I nord strom@idahopowe r.com
dockets@ idahopower.com
Connie Aschenbrenner
Zack Thompson
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
X* !.7(^1.t,-*,
LISA D. NORDSTROM
Aftorney for ldaho Power Company
APPLICATION - 10
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 4h day of May 20221 served a true and correct
copy of IDAHO POWER COMPANY'S APPLICATION upon the following named parties
by the method indicated below, and addressed to the following:
Commission Stafl
Dayn Hardie
Deputy Attomey General
ldaho Public Utilities Gommission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Eaetern ldaho Communlty Action
Partnership
Jay Doman
Chief Executive Officer
P.O. Box 51098
ldaho Falls, lD 83405
El-Ada Gommunity Action Partnerchlp
Tim Lopez
Chief Executive Officer
701 E.44h Street, #1
Boise, lD 83714
tletro Comm unity Services
Grant Jones
Chief Executive Officer
4307 Sky,tvay Drive
Caldwell, lD 83605
South Gentral Gommunity Action
Partnership
Ken Robinette
Chief Executive Officer
P.O. Box 531
Twin Falls, lD 83303
South Eastern Idaho Community Action
Agency
Shantay Bloxham
Chief Executive Officer
641 North 8th Ave.
Pocatello, lD 83201
_Hand Delivered_ U.S. Mail_ Ovemight Mail
_ FA)(X Email [e-mail]
Hand Delivered_ U.S. Mail
_ Overnight Mail
_ FAXX Email [e-mail]
_Hand Delivered_ U.S. Mail_ Ovemight Mail
_ FA)(X Email [e-mail]
_Hand Delivered
_ U.S. Mail
_ OvemQht Mail_ FAXX Email [e-mail]
_Hand Delivered_ U.S. Mail_ Overnight Mail
_ FAXX Email [e-mail]
_Hand Delivered_ U.S. Mail
_ Overnight Mail
_ FAXX Email [e-mail]
APPLICATION.ll
Communlty Aodon Partrrchlp
fusoclaffon of ldaho
Evie Scrivner
Chief Exscuthro Offiocr
3350 W. Amedcana #980
Bobo, lD ffi7ffi
Hand Delhrered
-
U.S. Mall
_ Ovcmbht Mell_FN(X Email [e-mail]
\to o1 &,F*,
Stecy Gu8t, Reguhffiy Adminbfattue
Asshhnt
APruCATION - 12
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-22-15
IDAHO POWER COMPANY
ATTAGHMENT 1
TARIFF SCHEDULE 79
(Clean & Legislative)
SCHEDULE 79
(cLEAN)
ldaho Power Company First Revised Sheet No. 79-1
Cancels
|.P.U.C. No. 29. Tariff No. 101 OrioinalSheet No. 79-1
SCHEDULE 79
WEATHERIZATION ASSISTANCE
FOR QUALIFIED CUSTOMERS
AVAILABILIry
Funding under this schedule is available to state designated Community Action Partnership
(CAP) agencies throughout the Company's service area within the State of ldaho participating in the
State of ldaho Weatherization Assistance Program administered by the ldaho Department of Health
and Welfare. Funding under this schedule is subject to the provisions of the signed Agreement
between the individual CAP agencies and the Company.
APPLICABILITY
Funding under this schedule is applicable to qualiffing energy conservation measures installed
in single- and multi-family residential dwellings, including mobile homes, which are electrically heated
(Qualifying Dwellings). Funding is also applicable to qualiffing energy conservation measures installed
in buildings which are occupied by private, non-profit organizations which serve primarily low-income
clientele, and which have obtained a 501(cX3) tax exempt status (Qualifying Buildings). Energy
conservation measures installed in Qualifying Dwellings and Qualiffing Buildings must meet the
specifications of the State of ldaho Weatherization Assistance Program.
GRANTS TO AGENC]ES
The Company will determine the amount of annual grant funds available to each participating
CAP agency each year in accordance with the provisions of the Agreement. Funds will be distributed
to a participating CAP agency upon demonstration by the agency that qualifying conservation
measures have been installed in a Qualifying Dwelling or Qualifying Building. Grant funds made
available to a CAP agency but not distributed to that agency during the current year may be carried
forward to the next year.
ln addition to weatherization funds, the Company will provide to each CAP agency an
administrative payment equal to 10 percent of the portion funded by the Company for each Qualiffing
Dwelling or Qualifying Building for which weatherization was completed with the assistance of
Company funds.
Qualifoinq Dwellinos: The Company grant funds may be used to fund up to 85 percent of the
total cost of qualifying conservation measures installed in a Qualiffing Dwelling provided at least 15
percent of the total cost of qualiffing conservation measures is funded by the Department of Energy,
except in the case where carryover funds are being used for re-weatherization. Re-weatherization
applies to homes that were previously weatherized under Schedule 79 within a rolling 14-year period.
For those homes, the program's carryover funds may be used to pay up to 100 percent of HVAC
upgrades.
Qualifuinq Buildinos: The Company grant funds may be used to fund the installation of
weatherization measures in Qualifying Buildings in accordance with the provisions of the Agreement.
The Company provided funds may be used to fund up to 100 percent of the total cost of qualiffing
conservation measures installed in Qualiffing Buildings.
IDAHO
lssued per Order No.
Effective -
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
SCHEDULE 79
(LEGISLATIVE)
ldaho Power First Revised Sheet No. 79-1
|.P.U.C. No. 29. Tariff No. 101 Orioinal Sheet No. 79-1
SCHEDULE 79
WEATHERIZATION ASSISTANCE
FOR QUALIFIED CUSTOMERS
AVAILABIL!TY
Funding under this schedule is available to state designated Community Action Partnership
(CAP) agencies throughout the Company's service area within the State of ldaho participating in the
State of ldaho Weatherization Assistance Program administered by the ldaho Department of Health
and Welfare. Funding under this schedule is subject to the provisions of the signed Agreement
between the individual CAP agencies and the Company.
APPLICABILITY
Funding under this schedule is applicable to qualiffing energy conservation measures installed
in single- and multi-family residential dwellings, including mobile homes, which are electrically heated
(Qualifying Dwellings). Funding is also applicable to qualiffing energy conservation measures installed
in buildings which are occupied by private, non-profit organizations which serve primarily low-income
clientele, and which have obtained a 501(c)(3) tax exempt status (Qualiffing Buildings). Energy
conservation measures installed in Qualiffing Dwellings and Qualiffing Buildings must meet the
specifications of the State of ldaho Weatherization Assistance Program.
GRANTS TO AGENCIES
The Company will determine the amount of annual grant funds available to each participating
CAP agency each year in accordance with the provisions of the Agreement. Funds will be distributed
to a participating CAP agency upon demonstration by the agency that qualifying conservation
measures have been installed in a Qualifoing Dwelling or Qualiffing Building. Grant funds made
available to a CAP agency but not distributed to that agency during the current year may be carried
fonrard to the next year.
ln addition to weatherization funds, the Company will provide to each CAP agency an
administrative payment equal to 10 percent of the portion funded by the Company for each Qualiffing
Dwelling or Qualifying Building for which weatherization was completed with the assistance of
Company funds.
Qualifuino Dwellinos: The Company grant funds may be used to fund up to 85 percent of the
total cost of qualifying conservation measures installed in a Qualiffing Dwelling provided at least 15
percent of the total cost of qualifoing conservation measures is funded by the Department of Energy,
except in the case where carryover funds are beinq used for re-weatherization. Re-weatherization
aoplies to homes that were previously weatherized under Schedule 79 within a rollino 14-vear period.
For those homes. the proqram's carrvover funds mav be used to pav up to 100 percent of HVAC
uoorades.
Qualifuino Buildinos: The Company grant funds may be used to fund the installation of
weatherization measures in Qualiffing Buildings in accordance with the provisions of the Agreement.
The Company provided funds may be used to fund up to 100 percent of the total cost of qualiffing
conservation measures installed in Qualifying Buildings.
IDAHO
lssued per Order No.€e5eB
Ef fective -{4areh-t+008
lssued by IDAHO POWER COMPANY
, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
cAsE NO. IPC-E-22-15
IDAHO POWER GOMPANY
ATTAGHMENT 2
Weatherization Assistance fo r Qua I ifi ed Customers ("WAQC"}
Re-Weatherization Project Requirements
Customer Elisibilitv:
o ldaho Power Residential account number except for multi-family accounts per ldaho
Weatherization Operation Manual ("lWOM") guidelines.
o Qualified as Low lncome as defined by the federal poverty leveldefined in the current IWOM
guidelines or previously qualified for the WAQC program.
r Home previously weatherized using WAQC funding or any combination of ldaho Power, state,
private, and/or federal funding.. Landlord consent authorizing re-weatherization on rental homes with cost sharing option.
Dwelline Eligibilitv:o Previously weatherized without HVAC replacement or inoperable heat system.o Primarily heated with electricity provided by ldaho Power.
HVAC Reolacement Elisibilitv:
o lnefficient, inoperable, or non-existent electric heating system as deemed by Agency Energy
Auditor.o Follow IWOM standards for HVAC replacement and efficiency upgrades or run heat load
calculator.o Use of licensed/certified HVAC subcontractor and certified Agency crew member.
Final lnspection:
o Final mechanical inspections of equipment installed are required by the authority issuing the
applicable mechanical permit.
o A job completion form will be signed off by the Community Action Partnership ("CAP") Agency
inspector noting consistency with the contractor bid.
Re-Weatherization Funding:o Re-Weatherization projects to be funded with each agency's carryover funds only
Billine and Pavment:. Re-weatherization jobs to be kept separate from WAQC jobs for accounting and
tracking purposes.
Re-Weatherization Fundine:
Production job costs will be limited to a 59,000 maximum annualjob average plus the
administrative fee of tO% of the production cost per job.
Re-Weatherization projects available until carryover funds run out or until the CAP Agency
contracts end in 2025, whichever happens first.
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Attachment 2
Case No. IPC-E-22-15