20220812Comments.pdf

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 : BoiseCityAttorney(@cityofboise. ore
ei [e-mail]
Attorney for Intervenor
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO MODIFY SCHEDULE 79-
WEATHERZATION AS SISTANCE FOR
QUALIFIED CUSTOMERS
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CaseNo. WC-E-22-15
CITY OF BOISE CITY'S
FORMAL COMMENTS
The city of Boise City ("Boise City") submits these formal comments on the application
submitted by Idaho Power Company ("Company") to modiff Schedule 79, Weatherization
Assistance for Qualified Customers. 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, Order No.
35478, issued on July 29,2022, hereby submits its formal written comments and states as follows:
l. Boise City commends Idaho Power Company ("Company") on their responsiveness
and proposed approach to proactively address challenges facing the Weatherization
Assistance for Qualified Customer program ("WAQC"). WAQC is a critically
important program that ensures vulnerable community members can access energy
CITY OF BOISE CITY'S FORMAL COMMENTS - I
2.
3.
4.
efficiency programs, reduces household energy burden, promotes safe and efficient
housing, and produces system-wide benefits.
Boise City recommends the Commission approve the Company's proposed
modifications to Schedule 79 proposed in Attachment I to the Company's Application,
with one additional modification detailed below, to ensure all possible re-
weatherization funds are expended by the end of 2025.
Boise City supports the Company's proposed re-weatherization funding measures to
address the surplus carryover funds. Specifically, Boise City is encouraged by the
flexibility introduced by the Company to address rising HVAC replacement costs and
the streamlined approach to re-weatherization that allows local Community Action
Partnership ("CAP") agencies to quickly identiff eligible households and deploy
funding in partnership with qualified HVAC contractors. Boise City supports the
Company's identified target population for re-weatherization and proposal to fund
100% of WAQC re-weatherization work, addressing the population of homes ineligible
for Department of Energy Weatherization Assistance Program funding due to the
rolling I 4-year period.
While Boise City generally supports the Company's re-weatherization proposal,
program eligibility guidelines, and modifications to Schedule 79, Boise City
recommends the Commission introduce additional flexibility and accountability into
the funding allocation process to CAP agencies. Boise City recommends that surplus
carry-over funding made available for re-weatherization to each CAP agency be subject
to review and potential re-allocation each contract year atthe Company's discretion. If
a CAP agency's carry-over balance continues to grow despite the opportunity for re-
BOISE CITY'S FORMAL COMMENTS - 2CITY OF
weatherization, the Company should retain the ability to re-allocate those firnds to other
CAP agencies across the service area that are successfully able to reduce the carryover
balance and produce additional energy savings through re-weatherization. While there
is a need to account for variability in weatherization project slssings or delays outside
of local CAP agency control in the annual base weatherization allocation, assumed
carry-over of funding to the same CAP agency that has gone unspent over several years
is not in the best interest of customers.
DATED this 12th day of August 2022.
Ed
Deputy City Attorney
CITY OF BOISE CITY'S FORMAL COMMENTS - 3
CERTIFICATE OF SERYICE
I hereby certit/ that I have on this 12th day of August 2022, sewed. the foregoing
documents on all parties of counsel as follows:
JanNoriyuki
Commission Secretary
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
i an.noriyuki@puc. idaho. sov
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., BldgNo. 8
suite 201-4 (83714)
PO Box 83720
Boise, lD 83720-0074
[e-mail]. eov
Lisa Nordstrom
Idaho Power Company
PO Box 70
Boise, lD 83707
lnordshom @idahopower. com
dockets@idahonower. com
Connie Aschenbrenner
Zack Thompson
Idaho Power Company
PO Box 70
Boise, ID 83707
caschenbrenner@idahopower. com
zthompson@ idahonower.com
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Michelle Steel,
CITY OF BOISE CITY'S FORMAL COMMENTS .4
Paralegal, City of Boise