20210802Formal Comments.pdf

JAYME B. SULLIVAN
BOISE CITY ATTORNEY
MARY GRANT (ISB No. 8744)
Deputy City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email : [e-mail]
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-21-04IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2O2O 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 Modified Procedure, Order No. 35069, filed on June
8,2021, hereby submits its formal written comments and states as follows:
1. Boise City has an interest in ensuring there is an increase in energy efficiency programs
that qualiff for funding under Demand-Side Management ("DSM") programs and participation in
such programs. This aligns with Boise City's goals of pursuing increased energy efficiency as part
of its community-wide goal of 100% clean electricity by 2035.
2. Boise City commends Idaho Power Company ("Company") on their 2020 DSM
and energy efficiency savings, achieving the 2nd highest annual savings since the establishment of
CITY OF BOISE CITY'S FORMAL COMMENTS - 1
the Idaho Energy Efficiency Rider in2002. This is particularly impressive when considered in the
context of the COVID-I9 pandemic and its impacts on program offerings and administation.
3. Boise City notes testimony conceming the current negative ending balance of the
Idaho Energy Efficiency Rider on December 31, 2020, and supports ef[orts for appropriate cost
recovery. Boise City supports additional review of required adjustments for adequate Idaho
Energy Efficiency Rider funding, and that allow the Company to pursue all cost-ef[ective energy
efficiency, potentially above the increased Idaho Energy EfEciency Rider percentage authorized
in Commission Order No. 34871. (Goralski Testimony at l8).
4. Boise City recommends the Commission direct the Company, in collaboration with
the Energy Efficiency Advisory Group (EEAG), to specifically address strategies to increase
participation and ensure the benefits of energy efficiency reach residential customers who would
have participated in the programs suspended due to COVID-I9 (Goralski Testimony at 8). The
348,700 kwh savings reported in the Company's DSM Annual Report Supplement 1: Cost-
Effectiveness, for the seven (7) programs suspended due to COVID-l9 (Easy Savings, Energy
House Calls, Home Energy Audit Program, Multi-Family Energy Savings Program, Shade Tree
Project, Weatherization Assistance for Qualified Customers, and Weatheization Solutions) is only
22.6% of the savings achieved by those programs in 2019. While Boise City recognizes the
Company's success maintaining an overall cost-effective energy efficiency portfolio during
COVID-19, there is an opportunity to achieve increased savings going forward if the waitlists and
backlog of demand for suspended residential programs can be efficiently met.
5. Boise City recommends the Company evaluate additional residential energy
efEciency measures to better align residential DSM progrzm offerings with the opportunities
identified in the 2020 Energy Efficiency Potential Study ("Potential Study"). The achievable
CITY OF BOISE CITY'S FORMAL COMMENTS .2
energy efficiency potential identified in the Potential Study informed the Company's 2021
Integrated Resource Plan ("IRP") and utilized the utility cost test (*UCT") as the primary measure
of cost-effectiveness, as directed in Order No. 34469. Implementing the results of the Potential
Study into residential DSM program offerings will ensure future DSM spending aligns with the
IRP, fully implementing the UCT in both planning and delivery of energy-efficiency as a least-
cost and least-risk resource.
6. Outside of income-eligible weatherization programs, the Company currently offers
no incentive for wall cavity or ceiling insulation despite the 1,358 MWh energy saving potential,
rqresenting more than 60/o of the total energy efficiency potential. (2020 Energy EfEciency
Potential Study Table 5-6). Insulation installation, behavioral programs, or other measures would
encourage a whole-home approach to energy conservation that empowers customers to take a more
active role generating energy savings while maintaining comfort.
DATED this 2"d day of August 2Al.
Mary Grant
Deputy City Attorney
CITY OF BOISE CITY'S FORMAL COMMENTS .3
CERTIFICATE OF SERVICE
I hereby certifu that I have on this 2nd day of August 2021, served the foregoing documents
on all parties of counsel as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,lD 83702
j an.noriyuki @puc. idaho. eov
Lisa Nordstrom
Idaho Power Company
PO Box 70
Boise,ID 83707
lnordstrom@idahopower. com
dockets@idahopower. com
Connie Aschenbrenner
Idaho Power Company
PO Box 70
Boise,ID 83707
caschenbrenner@idahopower. com
Adam Lowney
McDowell Rackner Gibson PC
419 SW I lft Ave. Suite 400
Portland, OR 97205
[e-mail]
Peter J. Richardson
Richardson, Adams, PLLC
515 N 27ft St.
Boise,lD 83702
peter@ri chardsonadams. com
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dreadin g@mindsprin g. ore
tr U.S. MailO Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
tr U.S. MailO Personal Deliverytr Facsimileg Elechonic Means w/ Consent
O Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ ConsentD other:
tr U.S. Mailtr Personal DeliveryO Facsimileg Electronic Means d Consenttr Other:
tr U.S. MailD Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
CITY OF BOISE CITY'S FORMAL COMMENTS - 4
Benjamin J. Otto
Idaho Conservation League
710N.6ft St.
Boise,ID 83702
botto @i datro conservation. org
EI U.S. Mailtr Personal Deliverytr Facsimi[sg Electronic Means w/ Consenttr Other:
Mary Grant
Deputy City Attomey
CITY OF'BOISE CITY'S FORMAL COMMENTS . 5