20220802Comments.pdf

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JAYME B. SULLTVAN
BOISE CITY ATTORNEY
Ed Jewell ISB No. 10446
Deputy City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701-0500
Telephone: [phone]S
Facsimile: [phone]
Email: [e-mail]
ej ewel I @ ciwo fboi se. ore
Attorney for Intervenor
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BEFORE THE
IDAIIO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-22-08IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2O2T DEMAND-SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURRED
CITY OF BOISE CITYIS
FORMAL COMMENTS
The city of Boise City ("Boise City") submits these formal comments on the application
submitted by Idaho Power Company ("Company") for a prudency determination of its 2021
demand-side management expenses. Boise City, pursuant to Rule 203 of the Commission's Rules
of Procedure, IDAPA 31.01.01.203, and pursuant to the Notice of Modified Procedure, OrderNo.
35404, issued on May 13,2022, hereby submits its formal written comments and states as follows:
1. Boise City commends Idaho Power Company ("Company") on their 2021 demand-
side management programs ("DSM"), achieving more than 140,000 MWh of energy savings and
312 MW of non-coincident load reduction from demand response. Boise City recommends the
Commission find the Company's 2021 DSM expenses prudently incurred and supports the
CITY OF BOISE CITY'S FORMAL COMMENTS - I
Commission's continued direction to ensure the Company pursues all cost-effective energy
efficiency and demand response measures across customer classes.
2. Boise City notes testimony concerning the negative ending balance of the Idaho
Energy Efficiency Rider on December 31, 2021. Goralski, Di Testimony at 19. The continued
negative balance year-over-year should be carefully considered by the Company and the
Commission to ensure all cost-effective energy efficiency opportunities are able to be pursued.
Boise City supports efforts to resolve the ongoing negative rider balance, including increasing the
existing Idaho Energy Efficiency Rider percentage authorized in Commission Order No. 34871.
3. Boise City recommends the Company, in collaboration with the Energy Efficiency
Advisory Group ("EEAG"), work to specifically implement strategies to increase participation and
ensrue the benefits of energy efficiency reach residential customers. As noted in Boise City's
comments on the Company's 2020 DSM expenses, COVID-l9 energy effrciency program
suspensions disproportionately impacted residential customers. The City of Boise looks forward
to seeing the impact of Energy House Calls, Home Energy Audits, Multifamily Energy Savings,
and Weatherizationprograms operating at full capacity lri.2022. While continued disruptions due
to COMD-I9 and associated supply chain constraints are outside of the Company's control, these
impacts, coupled witha4D%o decrease inMWhs savedbyresidential customers from2020to2021,
necessitate additional effort by the Company and the EEAG to modify existing programs or
implement new measures to ensure energy savings from the residential sector are capfured. Boise
City is also concerned with the reduction in the overall share of customers participating in energy
efficiency programs from 45Yo n 2020 to 35% n 2021,. While Boise City recognizes the
Company's success maintaining an overall cost-effective energy efficiency portfolio in a
challenging environment, there is opportunity to achieve increased savings going forward if the
CITY OF BOISE CITY'S FORMAL COMMENTS - 2
waitlists and backlog of demand for suspended residential programs can be efficiently met
alongside the development of innovative new offerings.
4. [n reviewing individual energy efficiency programs implemented by the Company
in202l, Boise City offers the following comments:
a. Boise City strongly supports the Company's efforts to design the new retail
lighting buy-down program, specifically working to ensure customers shopping
at neighborhood dollar stores and other markets currently unreached by the
market transfomration in LED lighting can purchase the most efficient lighting
at affordable prices. Boise City recommends the Company use this as a model
to continue to develop programs or specific, targeted outreach that addresses
unique market gaps and access to energy-efficient products and appliances.
b. Boise City recognizes the challenges and continued efforts by the Company to
design a cost-effective residential new construction incentive that is attractive
and accessible to home builders. While the UCT increase in 2021 is
encouraging, the decreased participation from 248 participants in 2020 to 90 n
2021 is concerning. Boise City views this as a critically important program to
ensure the rapid growth in new construction across the Company's service area
is as efficient as possible. Boise City notes the impact evaluation planned for
2023 andrecommends the Company consider expanding the planned evaluation
to include elements of a process evaluation, specifically customer satisfaction
and review of similar program best practices. Boise City continues to support
the Company's implementation and development of this pilot program and
looks forward to supporting future marketing efforts.
CITY OF BOISE CITY'S FORMAL COMMENTS - 3
c. The most recent Energy Efficiency Potential Study identified behavior change
programs, like the Company's Home Energy Reports, as having the highest
potential energy savings in the residential sector. Boise City recommends the
Company work to expand the Home Energy Reports program to reach at least
2020 participation levels or higher where practicable. Home Energy Reports,
like the Home Energy Audit program, present a beneficial opportunity to
educate customers on energy efficiency and encourage future program
participation.
d. Boise City appreciates the Company thoughtfully engaging the EEAG in
development of the updated energy efficiency educational distribution welcome
kits. The increased cost-effectiveness of the educational distribution kits,
increasing to 2.39 from 1.45 in 2020, and broad reach to more than 45,000
customers should be built onn2022.
5. While the Commission is asked to evaluate the prudency of 2021 DSM expenses,
Boise City recognizes this proceeding as an important opportunity to engage the Commission,
Company, and other interested stakeholders on the future of the Company's energy efficiency and
demand response offerings. Boise City is encouraged by, and looks forward to, engaging with the
EEAG on the program activities identified for 2022 and beyond. See Demand Side Management
2021 Annual Report at 17. Specifically, Boise City recommends the Company pursue the
development of a multi-family new construction incentive to fuither transform the new
construction market. Boise City also supports the development of the online marketplace,
recognizing point of sale rebates and negotiated buy-downs can decrease up-front capital expenses
for customers and improve access to energy-effrcient products for households with low and
CITY OF BOISE CITY'S FORMAL COMMENTS - 4
moderate incomes. In addition to the new activities identified by the Company, Boise City
recommends the Company evaluate the potential demand response opportunity presented by the
increasing adoption of electric vehicles. While the existing time of use rate may effectively
encourage some customers to avoid on-peak charging, a specific demand response incentive could
help ensure electrification of vehicles produces grid benefits in addition to customer savings and
emissions reductions. Lastly, while not a new program or measure, Boise City encourages the
Company to consider evaluating opportunities, targeting outreach, and presenting achieved
savings at a more local level. Integrating a more granular level of detail into energy efficiency
reporting could support distribution system planning and provide greater insight into local demand
use patterns, offering interesting insights for program implementation and development.
6. In summary, Boise City recommends the Commission find the Company's 2021
DSM program expenses prudently incurred and continues to support the Company's efforts to
implement cost-effective DSM programs that respond to changing market dynamics, supply chain
and workforce constraints, and ongoing impacts from COVID-19.
DATED this 2nd day of August2022.
ry&r*tt
Ba ie*eil
Deputy City Attorney
CITY OF BOISE CITY'S FORMAL COMMENTS - 5
CERTIFICATE OF SERVICE
I hereby certify that I have on this 2nd day ofAugust 2022, served the foregoing documents
on all parties of counsel as follows:
JanNoriyuki
Commission Secretary
11331 W. Chinden Blvd., Bldg No. 8
suite 201-4 (83714)
PO Box 83720
Boise, ID 83720-0074
i an. noriyuki @nuc. idaho. eov
RileyNewton
Deputy Attomey General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, D 83720-0074
[e-mail]. eov
Lisa Nordstrom
Idaho Power Company
PO Box 70
Boise,ID 83707
lnordstrom@ idahopower. com
dockets@ idahopower.com
Connie Aschenbrenner
Zack Thompson
Idaho Power Company
PO Box 70
Boise,ID 83707
caschenbrenner@ idahopower. com
zthompson@ idahopower.com
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Michelle Steel,
Paralegal, City of Boise
CTTY OF BOISE CITY'S FORMAL COMMENTS - 6