20220207Comments.pdf

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JAYME B. SULLTVAN
BOISE CITY ATTORNEY
Ed Jewell ISB No. 10446
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email : ej ewell(a)cityofboise. ore
[e-mail]
Attorney for Intervenor
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BEFORE THE
IDAHO PUBLIC UTILITIES COMN{ISSION
Case No. IPC-E-21-32IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR APPROVAL
TO MODIFY ITS DEMAND RESPONSE
PROGRAMS CITY OF BOISE CITY'S
COMMENTS
The city of Boise City ("Boise City") submits these formal comments on the application
submitted by Idaho Power Company ("Company") for approval of its proposed modifications to
it its existing demand response programs. Boise City submits these formal comments pursuant to
Rule 203 of the Commission's Rules of Procedure, IDAPA 31.01.01.203, and pursuant to the
Notice of Modified Procedure, Order No. 35266, issued by the Commission on December 21,
202t.
l. Boise City commends the Company on continuing to develop, implement, and evaluate
demand response (DR) programs, particularly with the customer outreach and engagement
challenges faced during the COVID-I9 pandemic. Boise City recognizes the unique and
important benefits that DR delivers to all customers and supports the continuation of
CITY OF BOISE CITY'S COMMENTS - I
robust, accessible, and cost-effective DR measures. Boise City is encouraged by the
Company's efforts to align DR with the Company's highest-risk hours, informed by the
2021Integrated Resource Plan. Application at 6. Boise City also commends the Company
and other parties involved in negotiating the terms of the settlement agreement approved
by Commission Order No. 32923 in 2013, as continued program operation has facilitated
this robust demand side resource significantly contributing to meeting growing system
capacity resource needs.
2. While Boise City recognizes and agrees with the Company's analysis of the need to align
the DR program with the highest-risk hours identified in the tRP to ensure effectiveness
utilizing the ELCC method, Boise City is concerned that the proposed updated program
design may limit Irrigation Peak Rewards program participation, despite the higher
monthly fixed incentive and variable incentive. Boise City recommends the Company
continue to work directly with current and past lrrigation Peak Rewards participants to
understand how to make the program as attractive and easy to participate in as possible
while continuing to cost-effectively provide DR capacity during critical peak hours.
3. Boise City supports the Company's proposed removal of DR program marketing
limitations. Application at 13. With this limitation lifted, Boise City recommends Idaho
Power work with EEAG to intentionally market the A/C Cool Credit program to high-
energy burden households, multi-family housing, customers who recently received bill
payment assistance, and other customers who would more significantly benefit from the
financial benefits of program participation. Additionally, Boise City recommends ldaho
Power evaluate marketing strategies that would help funher align DR program
CITY OF BOISE CITY'S COMMENTS - 2
participation with locations within the Company's service territory that face capacity
constraints due to recent growth or additional infrastructure needs.
4. Boise City recommends Idaho Power identiff and evaluate opporhrnities to leverage smart
thermostats installed through the Company's residential heating and cooling effrciency
program as a future strategy to expand DR program participation and capacity without
deploying additional load control devices. The American Council for an Energy-Efficient
Economy's 2019 report "lntegrated Energy Efficiency and Demand Response Programs"
identified both administrative and program cost savings opportunities as well as increased
overall progrtlm satisfaction by pursuing an integrated approach to energy efficiency and
demand response through an enabling technology like a smart thermostat. DAN YoRK,
Gnecn Rnr & Conpr WarERS, AMERTcAN Cor.JNCrL FoR AN ENpncv ErFrcrENT EcoNoMy,
IurecRareD ENERGv ErrtcrcNcv AND DEMAND RESroNSE Pnocneus, p. 6, available at
https://www.aceee.ore/sites/default/files/publications/researchreports/u l906.pdf (last
visited February I, 2022).
5. Boise City recommends the Commission approve the Company's proposed modifications
to the DR programs to be implemented in the 2022program season.
DATED this 7th day of February 2022.
P&,r,tt
Ed JewellL)
Deputy City Attorney
CITY OF BOISE CITY'S COMMENTS - 3
CERTIFICATE OF SERVICE
I hereby certiff that I have on this 7th day of February 2022, served the foregoing
documents on all parties of counsel as follows:
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, D 83720-0074
i an.noriwki(Enuc. idaho. eov
tr U.S. Mailtr Personal Deliverytr FacsimileV Electronic Means w/ ConsentO Other:
Lisa D. Nordstrom
Connie Aschenbrenner
Idaho Power Company
l22lW. Idaho St. (83702)
PO Box 70
Boise,ID 83707-0070
lnordstrom(E idahopower. com
dockets@idahopower. com
caschenbrenner@ idahopower. com
tr U.S. Mailtr Personal DeliveryO Facsimileg Electonic Means w/ Consenttr Other:
Riley Newton
Deputy Attorney General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg No. 8
Suite 201-4 (83714)
PO Box 83720
Boise, D 83720-0074
rilev.newton(a)puc. idaho. eov
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
PO Box 6119
Pocatello,ID 83205
elofdechohawk.com
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
Lance Kaufrnan
Aegis Insight
4801 W. Yale Ave.
Denver, CO 80219
I ance(rD ae gisinsi eht. com
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
CTTY OF BOISE CITY'S COMMENTS - 4
Benjamin J. Otto
Emma E. Sperry
Idaho Conservation League
710 N. 6ft St.
Boise, lD 83702
botto@ idahoconservation. org
esperry@idahoconservation. ore
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
Peter J. Richardson
Richardson, Adams, PLLC
515 N 271h. St
PO Box 7218
Boise, lD 83702
peter(E richardsonadams. com
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
Dr. Don Reading
6070 Hill Road
Boise, ID 83703
dreadinq@mindsprine. com
tr U.S. Mailtr Personal Delivery
O Facsimileg Electronic Means w/ Consenttr Other:
Jim Swier
Micron Technology, [nc.
8000 S. Federal Way
Boise, lD 83707
[e-mail]
O U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street Suite 3200
Denver, CO 80202
darueschho ff@hol landhart. com
tnelson@hol landhart.com
awj [e-mail]
aclee@hollandhart. com
sl [e-mail]
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ ConsentO Other:
Michelle Steel
Paralegal, City of Boise
CTTY OF BOISE CITY'S COMMENTS - 5