20200827Formal Comments.pdf

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JAYME B. SULLIVAN
BOISE CITY ATTORNEY
ABIGAIL R. GERMAINE (ISB No. 9231)
Deputy City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701-0500
Telephone: [phone]
Facsimile: (208) 384-445 4
Email: [e-mail]
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CaseNo. IPC-E-20-15IN THE MATTER OF IDAHO POWER
COMPAI{Y'S APPLICATION FOR A
DETERMINATION OF 2019 DEMAND-SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURRED
CITY OF BOISE CITY'S
FORMAL COMMENTS
COMES NOW, the city of Boise City, herein referred to as "Boise City" and pursuant
to Rule 202 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA
31.01.01.202) and, pursuant to that Notice of Amended Comment Deadlines, Order No. 34739,
filed on August 3,2020, hereby submits its formal written comments and states as follows:
l. Boise City has an interest in ensuring that there is an increase in energy efficiency
programs that would quali$ for funding under Demand-Side Management ('DSM") programs.
This aligns with Boise Crty's goals of increasing energy effrciency as part of its community-wide
goal of 100% clean electricity by 2035 established during 2019 with the Boise's Energy Future
plan. Achieving the goal will be reliant on effectively leveraging energy effrciency programs. This
CITY OF BOISE CITY'S FORMAL COMMENTS - I
will include both existing customer programs, as well as Idaho Power Company ("the Company")
developing and implementing new energy efficiency programs.
2. On March 13,2020, Company frled this Application, Application for Determination of
2019 Demand-Side Management Expenses as Prudently Incurred, which among other items,
describes the Company's evaluation of its current DSM programs and whether they were cost-
effective for the year 2019. Historically, the Company used the total resource cost test ("TRC"),
the utility cost test ("UCT"), and the participant cost test ("PCT"). As directed in case IPC-E-l9-
11, Idaho Power was required to evaluate the cost-effectiveness of future DSM programs with the
UCT as the primary test in the Integrated Resource Plan. In2019, eleven (11) of the sixteen (16)
energy effrciency programs passed the TRC and UCT tests. (Goralski Direct Testimony at l6 and
t7.)
3. Boise City commends the Company on their 2019 DSM and energy efficiency savings
which represent the all-time highest annual incremental energy savings achievement since the
establishment of the Idaho Energy Efficiency Rider in 2002. Notwithstanding this significant
success, the City looks forward to continuing to work with the Company to increase customer
participation in efficiency programs to achieve the energy efficiency savings identified in Boise's
Energy Future. (Goralski Testimony at 2).
4. Boise City recognizes that the Company engages in many outreach, educational,
awareness, and marketing activities that likely result in energy savings experienced by customers
that are not quantified or claimed as part of the Company's annual savings. While the City
acknowledges the challenges of trying to quanti$ energy savings from these types of activities,
CITY OF BOISE CITY'S FORMAL COMMENTS - 2
we believe that the energy savings from these activities are realized, and support future efforts to
better quantiS the extent of the savings (Goralski Testimony at l0).
5. Boise City notes testimony conceming the current negative ending balance of the
Idaho Energy Efficiency Rider on December 31, 2019, and supports efforts for appropriate cost
recovery and adjustments that ensure adequate funding of the Idaho Energy Effrciency Rider
enabling the Company's ability to implement existing programs and deliver new programs, where
appropriate. (Goralski Testimony at l4).
6. Boise City supports the Company's transition of cost-effectiveness testing methods
during the 2020 progftlm year to synchronize with the Company's annual Integrated Resource
Planning (IRP) cycle including the development of a new DSM Potential Study and an evaluation
of immediate opportunities to add measures that are cost-effective under the UCT to existing
programs during 2020 (Goralski Testimony at 16).
7. Boise City notes that while the WeatheizationAssistance for Qualified Customers and
Weatherization Solutions programs did not achieve a 1.0 or greater benefit-to-cost ratio with the
UCT or TRC, the City supports these existing progftlms and encourages the development of
additional programs that create opportunities for energy efliciency improvements and cost savings
for qualified customers (Goralski Testimony at20).
8. As mentioned previously, increases in energy efficiency and demand-side
management programs support Boise City's community-wide clean electricity goals. Boise City
encourages Idaho Power to continue identi$ing opportunities to expand existing, and develop
new, energy efficiency and demand-side management programs. Boise City places particular
interest and emphasis on opportunities for programs that address whole home and building
CITY OF BOISE CITY'S FORMAL COMMENTS - 3
efficiency where multiple energy sources like electricity and natural gas are utilized. Opportunities
to coordinate and deliver these programs in coordination with other utilities should be considered.
Additionally, Boise Crty supports the piloting of programs that emphasize customer behavior
change and target buildings with high potential for energy savings such as multi-family residential
buildings. Finally, considering the local and nation-wide economic impacts of COVID-l9, there
has never been a greater opponunity or more important time to increase and support programs that
have the potential to provide immediate savings and lower long term costs for vulnerable members
of our community and throughout the Company's seruice territory. Boise City respectfully
requests that the Commission support adequate and appropriate funding of the Idaho Energy
Effrciency Rider and support opportunities to expand existing and develop new energy efficiency
and DSM programs.
DATED this 27th day of August2020.4 etu ^;*
Abigail R. Germaine
Deputy City Attomey
CITY OF BOTSE CITY'S FORMAL COMMENTS - 4
CERTIFICATE OF SERVICE
I hereby certiff that I have on this 27th day of August 2020, served the foregoing
documents on all parties of counsel as follows:
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 West Chinden Boulevard
Building 8, Suite 201-A
PO Box 83720
Boise, lD 83720
i an.noriyuki@puc. idaho. eov
LisaNordstrom
Regulatory Dockets
Idaho Power Company
PO Box 70
Boise, lD 83707
lnordstrom@ idahopower. com
dockets@ idahopower. com
Connie Aschenbrenner
Idaho Power Company
PO Box 70
Boise,ID 83707
caschenbrenner@ idahopow er. com
Dayn Hardie
Deputy Afforney General
Idaho Public Utilities Commission
11331 West Chinden Boulevard
Building 8, Suite 201-A
PO Box 83720
Boise, lD 83720
davn. hardie@puc. idaho. gov
V U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
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Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
Attorneys atLaw
505 Pershing Avenue Suite 100
PO Box 6119
Pocatello,ID 83205
CITY OF BOISE CITY'S FORMAL COMMENTS - 5
[e-mail]
Attorneys for ldaho Inigation Pumpers
Association, Inc.
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, OH44107
[e-mail]
for ldaho lrrigation Pumpers Association,
Inc.
tr U.S. Mailtr Personal Deliverytr FacsimileV Electronic Means w/ Consenttr Other:
Peter J. Richardson
RTCHARDSON ADAMS, PLLC
Attorneys at Law
515 North 276 Street
PO Box 7218
Boise, D 83702
peter@richardsonadams. com
Attorneys for Industrial Customers of
Idaho Power
tr U.S. Mailtr Personal Deliverytr FacsimileV Electronic Means w/ Consenttr Other:
Dr. Don Reading
6070 Hill Road
Boise, ID 83703
dreadine@ mindsprine. com
for Industrial Customers of ldaho Power
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
Benjamin J. Otto
Idaho Conservation League
710 North 6ft Street
Boise, lD 83702
botto @ idahoconservation. ore
tr U.S. Mailtr Personal Deliverytr FacsimileM Electronic Means w/ Consenttr Other:
@ Ar*e
Abigail R. Germaine
Deputy City Attorney
CITY OF BOISE CITY'S FORMAL COMMENTS - 6