20220818Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9917
i. =l ii -,
Street Address for Express Mail:
1 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO MODIFY SCHEDULE'T9-
WEATHERIZATION ASSISTANCE FOR
QUALIFIED CUSTOMERS
CASE NO.IPC.E.22.15
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission ("Staff'), by and through its Attomey
of record, Dayn Hardie, Deputy Attorney General, submits the following comments.
BACKGROUND
On May 4,2022,Idaho Power Company ("Company" or "ldaho Power") applied for
Commission authorization to modiff Schedule 79-Weatherization Assistance for Qualified
Customers ("Schedule 79" or "WAQC"), to include re-weatherization projects for qualiffing
customers. The Company requested its Application be processed by Modif,red Procedure.
The Company has experienced an increase in carryover funds during the past two years
due to COVID-19, supply chain issues, and labor and staffing shortages. In202l, the Company
made $1,861,402 avallable to Idaho Community Action Partnerships ("CAP") agencies, with
$648,868 of those funds carrying over from 2020. Of the funds available in202l, $990,416
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1STAFF COMMENTS AUGUST 18,2022
were paid to Idaho CAP agencies, while 5870,985 carried over to 2022. The2022 WAQC
budget exceeds $2 million due to the addition of carryover funds.
The Company's Application is designed to address the increasing amount of carryover
funds that have accumulated, and to give CAP agencies flexibility in using those funds to help
low-income customers without impacting the current WAQC program structure.
STAFF ANALYSIS
Staff reviewed the Company's Application, proposed tariff changes, eligibility
requirements, and responses to Production Requests. Additionally, Staff reviewed prior cases
and associated Commission Orders related to the WAQC program. Staff believes the
Company's request to utilize carryover funds to pay up to 100 percent of Heating, Ventilation,
and Air Conditioning ("HVAC") upgrades on homes that were previously weatherized under
Tariff Schedule 79,btt that did not receive HVAC upgrades, is reasonable and should be
approved by the Commission.
Staff s recommendation of approval of the modifications to Schedule 79 should not be
construed as a determination of prudence for any particular WAQC program expenditure. Staff
will review the prudency of Demand-Side Management ("DSM") expenditures, including
WAQC and other low-income programs in the Company's annual prudency cases.
Weatherization Assistance for Qualified Customers Program Overview
The WAQC program provides funds through base rates to CAP agencies for the
weatherization of electrically heated, low-income households. The program is vetted with stake
holders though the Energy Efficiency Advisory Group ("EEAG") and through DSM annual
reports. While the program does claim savings, the primary goal of the program is to increase
the energy efficiency, comfort, and safety of low-income households, while providing
educational materials on further reducing energy usage and costs. The WAQC program has an
annual base fundingof $1,212,534. The current WAQC tariff structure states that at least l5
percent of the total costs of weatherizing homes must be funded by Department of Energy
("DOE"), and homes previously weatherized using DOE funding are ineligible for additional
weatherization projects for 14 years following the initial weatherization.
2STAFF COMMENTS AUGUST 18,2022
Re-Weatherization Projects Proposal
The Company proposes to modifr Schedule 79 with the purpose of funding 100 percent
of re-weatherization projects using carryover funds. With the carryover balance's large growth
lui.2020, the EEAG met and discussed options to use these funds. Based on stakeholder
feedback, the re-weatherization projects were selected because, prior to 2015, heat pump
replacements were not common practice in the WAQC program, and many of the homes
weatherized before 2015 would receive heat pumps if they were weatheizedtoday. EEAG
presentations claim health, safety, comfort, and reduced energy costs as benefits that otherwise
may be unaffordable. Staff supports the EEAG conclusion that high efficiency heat pump
systems would be a benefit to low-income households.
Customers are only eligible for re-weatherization if they have previously received
assistance through the WAQC Schedule 79 weatherization program but did not receive an
FryAC replacement. If approved, the Company would report the re-weatherization project
results in its annual DSM report. Staff analyzed the Company's proposal and found the re-
weatherization projects are a generally well-planned and presented option to help reduce the
large carryover balance.
Customer Eligibility
The Company estimates that there are approximately 1,000 homes eligible for re-
weatherization based on their previous receipt of weatherization assistance between 2008 and
2014 without ever receiving HVAC upgrades and state and federal income guidelines under the
parent WAQC program. Response to Production Request No. 2. Staff beHeves this is an
appropriate method of establishing customer eligibility for the re-weatherizationprogram.
In response to Production Request No. 10, the Company stated that the CAP agencies
will be responsible for contacting customers who previously qualified for weatherization
assistance but did not receive HVAC upgrades. The re-weatherization project proposal is only
available until2025 or when the carryover funds run out. Staff recommends that providing clear
language to the CAP agencies who will notiff customers about project eligibility and the limited
nature of the project will encourage participation.
JSTAFF COMMENTS AUGUST 18,2022
Program Funding
"In [O]rder No. 30350 issued in2007, the Commission directed that 'Idaho Power shall
continue its annual funding of this program (WAQC) at $1.2 million per year,' which remains
the current level of funding for the program." Application at 3. However, in recent years,
COVID-19 in-home activity restrictions, supply chain limitations, and labor shortages have
limited the number of homes CAP agencies have been able to weatherize, creating a surplus of
carryover funds. The Company proposes to use the $870,985 surplus to fund this re-
weatherization project. This re-weatherization project is set to end in 2025, or when the surplus
funds run out. Conversely, if surplus funds continue to accrue in2023 and2024, they will be
added to the program funds. These surplus funds can also be used for the standard WAQC
program.
Pro gr am Funding Di s tr ibutio n
The WAQC program is currently over-collected by $870,985 and the Company will use
the overage to fund the proposed re-weatherization projects. The Company asserts the average
cost per home will be capped at $9,000. Therefore, this program has enough money for
approximately 100 homes with the current balance, which is approximately ten percent of
eligible homes. The Company explained that the CAP agencies will manage and report the
average job costs to the Company periodically throughout the year. The Company will
communicate any issues with these reports to the CAP agencies. Because the costs of the
weatherized homes are averaged together, the CAP agency has flexibility to service homes with
varying degrees of needs. This is the same process the Company uses in their WAQC program.
Carryover Funds and Reporting
Staff has concerns about the carryover funds allocated to this program. The WAQC
program could potentially continue to have an overage of funds for the next few years, and the
Company's Application for the re-weatherization projects has the proposal expiring in2025. lf
carryover funds continue to increase, Staff expects the Company to continue making adjustments
to eliminate the carryover funds by the contract end date. Staff will continue to monitor the
carryover balance and work with the Company to reduce the carryover balance by 2025.
Additionally, Staff recommends the Company notiff the Commission when surplus funds run
4STAFF COMMENTS AUGUST 18,2022
out or provide the balance of unspent funds within six months of CAP agency contract
expirations l.:r.2025.
For reporting on the re-weatherization projects, the Company stated that the "number of
re-weatherized homes, re-weatherization. costs, and the balance of carryover funds will be
reported as separate line items under the WAQC program section of the Company's Demand-
Side Management ("DSM") Annual Report." Response to Production Request No. 4. This
information will help keep Staff informed of the projects' performance and the amount of
available carryover funds. Staff appreciates the Company's commitment to detailed reporting on
the re-weatherization projects.
STAFF RECOMMENDATIONS
Staff recommends the Commission:
1. Approve the Company's Application;
2. Approve the proposed Tariff Schedule 79, as filed;
Notiff the Commission when surplus funds run out or provide the balance of unspent
funds within six months of CAP agency contract expirations in2025.
lgt'' day of Aug ust2o22Respectfully submitted this
Technical Staff: Laura Conilogue
Taylor Thomas
Kevin Keyt
Curtis Thaden
Jason Talford
i: umisc/comments/ipce22. I 5dhlcttkskctjjt comments
Deputy Attomey General
5STAFF COMMENTS AUGUST 18,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ISTH DAY OF AUGUST 2022,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN CASE
NO. IPC.E.22-15, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE tD 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower. corn
ED JEWELL
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
150 N CAPITOLBLVD
PO BOX 500
BOISE ID 83701-0500
E-MAIL: [e-mail]
boi secityattomey@cityofboi se.org
CONNIE ASCHENBRENNER
ZACK THOMPSON
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL : caschenbrenner@ idahopower. com
zthompson@idahopower. com
WIL GEHL
ENERGY PROGRAM MANAGER
BOISE CITY DEPT OF PUBLIC WORKS
I50 N CAPITO BLVD
PO BOX 500
BOISE ID 83701-0500
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE