20220901Reply Comments.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
September 1, 2022
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-22-15
Application of Idaho Company for Modifications to Schedule 79,
Weatherization Assistance for Qualified Customers
Dear Ms. Noriyuki:
Attached for electronic filing is Idaho Power Company’s Reply Comments in the
above-entitled matter.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
Lisa D. Nordstrom
LDN:sg
Enclosures
RECEIVED
2022 September 1, AM 11:25
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S REPLY COMMENTS - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
MODIFICATIONS TO SCHEDULE 79 –
WEATHERIZATION ASSISTANCE FOR
QUALIFIED CUSTOMERS.
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CASE NO. IPC-E-22-15
IDAHO POWER COMPANY’S
REPLY COMMENTS
Idaho Power Company (“Idaho Power” or “Company”) respectfully submits the
following Reply Comments in response to Comments filed by the Idaho Public Utilities
Commission (“Commission”) Staff (“Staff”) on August 18, 2022, and the City of Boise City
(“Boise City”) on August 12, 2022.
I. Reply Comments
In their Comments, both Staff and Boise City recommend approval of the
Company’s proposed modifications to Schedule 79 - Weatherization Assistance for
Qualified Customers (“WAQC”). In these Reply Comments, the Company briefly responds
to recommendations provided by both Staff and Boise City.
A.The Company Agrees with Staff’s Notification Recommendation.
In their comments, Staff “recommends the Company notify the Commission when
surplus funds run out or provide the balance of unspent funds within six months of CAP
agency contract expirations in 2025.”1 Idaho Power appreciates Staff's recommendation
and commits to notifying the Commission when surplus funds run out or, if funds are still
available, to provide the balance of unspent funds within six (6) months of the CAP agency
contract expirations in 2025. The Company is committed to continuing discussions with
CAP agency personnel, CAPAI, and the Energy Efficiency Advisory Group (“EEAG”) to
evaluate other potential opportunities that can address the carryover fund balance before
2025.
B. The Company Agrees with Boise City’s Carryover Funding Reallocation
Flexibility Recommendation.
Idaho Power agrees with Boise City’s recommendation “that surplus carry-over
funding made available for re-weatherization to each CAP agency be subject to review
and potential re-allocation each contract year at the Company's discretion.”2 The
Company commits to adopting Boise City’s recommendation and will add a re-
weatherization review and a potential reallocation of carryover funding, only for re-
weatherization projects, to its normal CAP agency funding process. Idaho Power will
continue to allocate and distribute the base WAQC funds on a pro rata basis. The
Company believes reviewing and potentially reallocating the carryover funding provides
additional flexibility and will ensure the funds are deployed in the best interest of
customers.
1 Staff Comments at 4-5.
2 City of Boise City’s Formal Comments at 2.
IDAHO POWER COMPANY’S REPLY COMMENTS - 2
IDAHO POWER COMPANY’S REPLY COMMENTS - 3
II. CONCLUSION
Idaho Power appreciates the collaborative effort from all stakeholders involved in
this process and believes it resulted in an option that will use the carry-over funding to the
benefit of customers that need it most in the Company’s service area. The Company
respectfully requests that the Commission issue an Order approving Idaho Power’s
Application, the proposed Schedule 79, Staff’s notification recommendation, and Boise
City’s carryover funding reallocation recommendation.

DATED at Boise, Idaho, this 1st day of September 2022.

________________________________
LISA D. NORDSTROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S REPLY COMMENTS - 4
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 1st day of September 2022 I served a true and
correct copy of Idaho Power Company’s Reply Comments upon the following named
parties by the method indicated below, and addressed to the following:

Commission Staff
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074

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City of Boise City
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701

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Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
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________________________________
Stacy Gust, Regulatory Administrative
Assistant