20230630Direct Drake.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

OF IDAHO POWER COMPANY FOR A DETERMINATION OF 2022 DEMAND-
SIDE MANAGEMENT EXPENSES AS PRUDENTLY INCURRED.

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CASE NO. IPC-E-23-10

IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
THERESA DRAKE
RECEIVED
2023 JUNE 30, 2023 3:08PM
IDAHO PUBLIC
UTILITIES COMMISSION
DRAKE, DI 1
Idaho Power Company
Q. Please state your name and business address. 1
A. My name is Theresa Drake. My business address 2
is 1221 West Idaho Street, Boise, Idaho. 3
Q. By whom are you employed and in what capacity? 4
A. I am employed by Idaho Power Company (“Idaho 5
Power” or “Company”) as Senior Manager of Customer 6
Relations and Energy Efficiency. 7
Q. Please describe your educational background. 8
A. In May of 1990, I received a Bachelor of 9
Science Degree in Marketing with emphasis in Finance from 10
Jacksonville State University in Jacksonville, Alabama. I 11
have attended numerous seminars and conferences on pricing 12
issues, regulatory issues, marketing research, and energy 13
efficiency. 14
Q. Please describe your business experience with 15
Idaho Power. 16
A. I joined Idaho Power in January 1997 as a 17
Pricing Analyst. In July 2001, my position evolved into a 18
Senior Pricing Analyst and included preparing cost-of-19
service studies, development of the Company’s tariffs, and 20
performance of duties as a regulatory liaison for customer-21
related issues. In February 2004, I became Manager of 22
Customer Relations and Research (now referenced as Customer 23
Relations and Energy Efficiency) and in March 2005 I became 24
Senior Manager. In that capacity, I manage staff members 25
DRAKE, DI 2
Idaho Power Company
and activities associated with customer relations, energy 1
efficiency, demand response, renewable energy programs, and 2
customer generation. 3
Q. What is the purpose of the Company’s 4
Supplemental filing in this case? 5
A. In its initial filing, the Company requested 6
the Idaho Public Utilities Commission’s (“Commission”) 7
issue an order designating Idaho Power’s 2022 Demand-side 8
Management (“DSM”) expenses of $39,896,437 as prudently 9
incurred. As part of its application, the Company also 10
indicted it expected to file a supplemental application no 11
later than the end of June 2023, whereby it would file the 12
independent evaluation, measurement, and verification 13
(“EM&V”) study for Northwest Energy Efficiency Alliance 14
(“NEEA”) claimed energy savings, as required by Order No. 15
35270. The Company also committed to identifying its near-16
term plan associated with any findings issued in the 17
report. 18
Accordingly, the Company submits this supplemental 19
application and requests the Commission acknowledge (1) the 20
Company complied with the directives outlined in Order No. 21
35270, and (2) continued participation in NEEA through the 22
current funding cycle is likely to result in cost-effective 23
energy savings for Idaho Power’s customers. 24
DRAKE, DI 3
Idaho Power Company
Q. What is the scope of your testimony in support 1
of these additional requests? 2
A. The scope of my testimony includes a 3
description of Idaho Power’s involvement with NEEA, 4
describes how the Company has complied with Order No. 5
35270, details some of the key findings in the EM&V study 6
report, and presents the Company’s next steps in addressing 7
findings and recommendations with NEEA. 8
Q. Are you sponsoring an y exhibits? 9
A. Yes. I am sponsoring the following exhibits: 10
• Exhibit No. 4 – NEEA EM&V Report 11
• Exhibit No. 5 – Idaho Power’s Net Market Effect 12
NEEA Savings 1997 - 2022 13
• Exhibit No. 6 – NEEA EM&V Report Addendum 14
I. IDAHO POWER’S INVOLVEMENT WITH NEEA 15
Q. What is NEEA? 16
A. NEEA is a non-profit organization whose stated 17
purpose is: “The Northwest Energy Efficiency Alliance is an 18
alliance of utilities and energy efficiency organizations 19
that pools resources and shares risks to transform the 20
market for energy efficiency to the benefit of consumers in 21
the Northwest.”1 NEEA's definition of market transformation 22
is identifying and removing market barriers to energy 23

1 Northwest Energy Efficiency Alliance (NEEA) | About - https://neea.org/about-neea
DRAKE, DI 4
Idaho Power Company
efficiency to drive permanent change throughout the supply 1
chain. NEEA is currently funded by 14 Northwest utilities 2
and/or energy efficiency organizations including, Idaho 3
Power, Avista Corporation (“Avista”), the Energy Trust of 4
Oregon, Northwestern Energy, and the Bonneville Power 5
Administration, among others. This strategic alliance is 6
built around recognition that greater market transformation 7
can be achieved across the Northwest by working in concert 8
rather than by working as individual states or 9
organizations. Established in 1997, Idaho Power has funded 10
NEEA since the organization’s inception. 11
Q. Other than providing funding, how has the 12
Company supported NEEA’s regional efforts? 13
A. Idaho Power participates in all of NEEA’s 14
committees and workgroups, including representation on the 15
Board of Directors. Over the years, Idaho Power 16
representatives have spent a great deal of time on numerous 17
NEEA committees and workgroups giving input and support on 18
NEEA activities and initiatives. 19
I also currently serve on the NEEA Board of 20
Directors, and the Company has been a member of the NEEA 21
Board of Directors since NEEA’s inception in 1997. 22
Q. What do Idaho Power’s customers receive from 23
the Company’s participation in NEEA? 24
DRAKE, DI 5
Idaho Power Company
A. Historically, NEEA has provided pooled 1
resources, market research, and program design in the 2
participating states, providing a greater likelihood that 3
market change within Idaho Power’s service area will be 4
rooted in a regional market, at a scale to which 5
manufacturers are more likely to respond and sustain 6
efforts. 7
From 1997-2022, NEEA and the Northwest utilities 8
have delivered 919 average-megawatts ("aMW") of co-created 9
electric energy savings2 to the region as shown in Chart 1 10
below.3 11
Chart 1. Additive* Co-Created Savings (aMW): 1997–2022 12
13 *Additive Energy Savings are defined as the sum of new first year 14
savings occurring each year across multiple years. 15
2 Co-Created - or shared - energy savings include all savings above the baseline that occur in the market due to the combined efforts of NEEA and its partners. 3 Chart reproduced from NEEA 2022 Annual Report. Available at: https://neea.org/annual-report/2022.
DRAKE, DI 6
Idaho Power Company
NEEA estimates that the alliance and local utilities 1
delivered almost 40 average megawatts of co-created energy 2
savings in 2022. Most of those savings are the result of 3
investments made during previous business cycles. 4
Since Idaho Power first began participating in NEEA, 5
Idaho Power’s allocated portion of cumulative NEEA energy 6
savings from 1997 through 2022 has been 449,236 megawatt-7
hours or 51.28 aMW. See Exhibit 5 to my testimony for the 8
savings allocation by year. 9
II. INDEPENDENT EM&V 10
Q. Please summarize the Commission’s directive 11
issued in Order No. 35270. 12
A. In Case No. IPC-E-21-04, Staff stated in its 13
comments that it was “concerned that NEEA claims savings it 14
is not directly responsible for producing.” Therefore 15
“Staff believes that to support the continued funding of 16
NEEA, an independent Evaluation, Measurement, and 17
Verification should be conducted to (l) clarify the savings 18
NEEA claims; (2) the allocation of those savings to its 19
member utilities: and (3) the cost-effectiveness of those 20
savings to the member utilities based on the utilities' DSM 21
avoided cost.”4 22
In Order No. 35270, the Commission noted Staff’s 23

4 In the Matter of Idaho Power Company’s Application for a Determination of 2020 Demand-Side Management Expenses as Prudently Incurred, Case No. IPC-E-21-04, Staff Comments, p. 10 (Aug. 2, 2021).
DRAKE, DI 7
Idaho Power Company
concerns and directed the Company to conduct an independent 1
EM&V to clarify the NEEA claimed savings and address the 2
items raised by Staff noting that “if NEEA is no longer 3
cost-effective after and independent EM&V is conducted, the 4
Company should reexamine its continued participation.”5 5
Q. Please describe how Idaho Power complied with 6
the Commission order. 7
A. The Commission also stated in Order No. 35270 8
“to the extent possible, the Company may work with other 9
Idaho regulated electric utilities that are conducting a 10
similar EM&V to examine NEEA claimed energy savings.” A few 11
months prior, Idaho Power was aware of Order No. 35129 the 12
Commission issued in Avista’s prudence case (AVU-E-20-13) 13
directing them to conduct an EM&V for NEEA as well.6 14
Therefore, Idaho Power and Avista ultimately decided to 15
collaborate and hire a single evaluator to complete a 16
single EM&V for efficiency purposes. The companies’ hired 17
ADM Associates Inc. (“Evaluator”) to complete the 18
independent EM&V on behalf of both utilities. The report is 19
provided as Exhibit 4 to my testimony. 20
Q. Did the Evaluator’s report determine if NEEA 21
participation is cost effective? 22

5 In the Matter of Idaho Power Company’s Application for a Determination of 2020 Demand-Side Management Expenses as Prudently Incurred, Case No. IPC-E-21-04, Order No. 35270, p. 9 (Dec. 27, 2021).
6 In the Matter of Avista’s Application for a Prudency Determination for its 2018-2019 Electric and Gas Energy Efficiency Expenditures, Case Nos. AVU-E-20-13 & AVU-G-20-08, Order No. 35129, p. 9 (Aug. 13, 2021).
DRAKE, DI 8
Idaho Power Company
A. Yes. The Evaluator’s report determined that 1
Idaho Power’s participation in NEEA is cost effective. The 2
evaluation reported that during the 2017 – 2021 program 3
years, the Company’s Idaho customers received a cumulative 4
total of $73.2 million in energy saving benefits from NEEA 5
activity. These benefits came at a utility cost of $12.9 6
million, for an overall Utility Cost Test (“UCT”) ratio of 7
5.68. The Evaluator also determined NEEA cost effectiveness 8
in Idaho is heavily reliant on savings due to code efforts 9
and that it is likely that code savings are currently being 10
significantly over estimated. 11
Q. How does NEEA typically report the energy 12
savings of its activities? 13
A. NEEA’s approach to reporting energy savings 14
differs for each of its main reporting categories 15
(voluntary measure activities, federal or state energy-16
saving product standards, and building codes). For 17
voluntary measure activities, such as the upstream Heat 18
Pump Water Heater initiative, NEEA tracks the total 19
regional sales of the measure to calculate overall energy 20
savings. It then subtracts the baseline estimate of sales 21
that would have occurred in absence of the initiative, 22
resulting in co-created savings. Any applicable energy 23
savings generated by local utility-run programs are removed 24
to avoid double counting savings resulting in the regional 25
DRAKE, DI 9
Idaho Power Company
net market effects as shown in Chart 2 below.7 Finally, NEEA 1
allocates the regional net market effect energy savings to 2
Idaho Power based on the funder share allocation 3
methodology. 4
Chart 2. NEEA Energy Savings 5
6
When a federal or state energy-saving product 7
standard goes into effect, NEEA typically engages a third 8
party evaluator to calculate energy savings. The evaluators 9
assess the overall impact of the standard as well as NEEA’s 10
role in its enactment. Similar to voluntary measures, NEEA 11
then allocates the net market effects energy savings to 12
Idaho Power using the funder share methodology. 13

7 Chart reproduced from NEEA 2020-2024 Strategic Business Plan pg 133. Available at: https://neea.org/img/documents/NEEA-2020-2024-Strategic-and-Business-Plans.pdf
DRAKE, DI 10
Idaho Power Company
Each time a building code is implemented within the 1
region, NEEA conducts a third-party review to quantify the 2
energy impacts compared to the previous code. For example, 3
an evaluation of Idaho’s 2021 residential code update found 4
the new code to be 11.6 percent more efficient than the 5
prior code. NEEA claims these energy savings on all new 6
construction for a 10-year period after the code goes into 7
effect. NEEA also assumes a 100 percent influence on the 8
code change and, unlike its practice for product standards, 9
does not conduct a formal influence evaluation. The funder 10
share methodology was used in the past to report energy 11
savings from building codes and was reviewed as part of the 12
evaluation. However, as of program year 2022, NEEA no 13
longer applies the funder share allocation to energy 14
savings related to code changes. Instead, it assigns saving 15
based on an estimate of the code impact within each 16
funder’s respective region, a methodology known as service 17
territory allocation. 18
Q. Did the Evaluator’s report raise any concerns 19
over how NEEA accounts for energy savings generated by 20
certain activities such as interjurisdictional codes and 21
standards? 22
A. Yes. While the evaluation found NEEA savings 23
to be overall cost effective, it identified several 24
concerns regarding NEEA’s reported energy savings. The 25
DRAKE, DI 11
Idaho Power Company
Evaluator found that the funder share methodology used for 1
voluntary measures, codes, and standards calculations led 2
to misrepresentation of the impacts that NEEA activities 3
had on Idaho Power’s Idaho customers. This practice both 4
overrepresented the effects of out-of-state energy savings 5
and underrepresented savings within the service area. While 6
NEEA has since updated the reporting of building code 7
savings to be based on the service territory methodology, 8
energy savings from voluntary measure and standards are 9
still being reported by the funder share methodology. 10
The evaluation found that NEEA distributes its costs 11
for all its expenses using the same ratio as energy savings 12
across the Northwest region and does not estimate 13
administrative, incentive, and other expenses by service 14
territory. This practice makes it difficult to 15
transparently assess the cost effectiveness of NEEA’s 16
individual efforts. 17
The Evaluator found several inconsistencies with the 18
way NEEA calculates energy savings for changes in state and 19
federal standards. The evaluation found multiple instances 20
where the influence studies intended to quantify NEEA’s 21
impact on the standard did not contain sufficient detail to 22
quantify NEEA’s influence. Therefore, the energy savings 23
attributable to NEEA’s effort is not always conclusive. 24
DRAKE, DI 12
Idaho Power Company
The report also raised a concern with the way NEEA 1
claims savings for code changes. While NEEA typically 2
performs an influence evaluation for standard changes, it 3
does not have a similar practice for code changes. Instead, 4
NEEA claims 100 percent influence for all construction 5
within a 10-year period after any code change goes into 6
effect within the region, without consideration of a 7
naturally occurring baseline. This assumption was decided 8
over twenty years ago. Considering that code savings 9
constitute a significant portion of the overall savings 10
portfolio, the Evaluator believes that NEEA energy savings 11
could be significantly overstated. 12
The evaluation also identified several areas in the 13
workbooks provided by NEEA that did not follow the best 14
practices of data reporting. These instances did not 15
materially affect the overall saving amount, but components 16
of the reports seemed to be misleading or appear 17
incomplete. 18
Q. Did the Evaluator make any specific 19
recommendations? 20
A. Yes. Please refer to Exhibit 6 pages 12-16 for 21
the final table listing all of the Evaluator’s findings and 22
recommendations. There were a total of 18 findings reported 23
by the Evaluator resulting in 9 recommendations. The 24
recommendations ranged from changing to a service territory 25
DRAKE, DI 13
Idaho Power Company
savings allocation methodology, completing influence 1
evaluations to verify savings associated with federal 2
standards, completing evaluations for code updates to 3
quantify NEEA’s influence, updating how annual savings and 4
costs are reported, and other updates to how savings are 5
accounted for and reported. All of the Evaluator’s 6
recommendations play into updating how NEEA’s cost-7
effectiveness is ultimately calculated. 8
Q. How is the Company planning on addressing the 9
recommendations provided in the Evaluator’s report? 10
A. Idaho Power agrees with the recommendations in 11
the evaluation and has initiated plans to address each 12
item. For example, the Company has asked NEEA to begin 13
reporting energy savings going forward using the service 14
territory methodology rather than the funder share 15
allocation method and for NEEA to start reporting costs 16
with the increased level of detail specified in the 17
evaluation recommendations. The Company has also asked NEEA 18
for additional data to support its claim that individual 19
measure offerings, which by themselves tend to be not cost-20
effective, help pave the way for future codes and standards 21
changes. 22
Q. How is the Company planning to address the 23
other recommendations? 24
DRAKE, DI 14
Idaho Power Company
A. Addressing the remaining recommendations may 1
require NEEA to coordinate with other NEEA members. The 2
Company sees these topics playing a role within business 3
planning for the 2025-2029 funding cycle, and the Company 4
will explore methods or alternatives in calculating code 5
savings to address the Evaluator’s recommendations in the 6
near term. The Company will also endeavor to improve 7
reporting as an outcome of the EM&V. The Company recognizes 8
that satisfying these requests would require a change in 9
NEEA’s current practices. 10
Q. Has NEEA reviewed the report and responded to 11
the findings and recommendations in the report? 12
A. Yes. Idaho Power sent a copy of the final 13
report to NEEA in April 2023. NEEA sent a letter addressed 14
to Idaho Power and Avista in May 2023. In the letter, NEEA 15
raised several questions regarding the findings in the 16
report. Idaho Power, Avista, NEEA, and the Evaluator met in 17
mid-May to discuss the report findings and NEEA’s 18
questions. As a result of the meeting, the Evaluator 19
compiled a list of items requiring further follow up with 20
NEEA. NEEA provided additional information to the Evaluator 21
in late May and early June 2023. 22
Q. Did the Evaluator incorporate any revisions to 23
the report? 24
DRAKE, DI 15
Idaho Power Company
A. The Evaluator reviewed the additional 1
information and wrote an addendum to the report with the 2
revised findings and recommendations in June 2023. The 3
addendum is included as Exhibit 6 to my testimony. 4
Q. Has NEEA responded to the Company’s requested 5
changes based on the Evaluator’s recommendations? 6
A. Yes. NEEA has responded to the Company’s 7
requests and expressed a general willingness to make the 8
recommended changes. NEEA confirmed that a switch to 9
service-territory allocated energy savings will be 10
implementable starting in the 2023 reporting year of the 11
current funding cycle. NEEA also responded that providing 12
more detailed estimates of expenditures, as recommended in 13
the evaluation, will be developed in 2024 with 14
implementation in 2025. 15
NEEA stated that it is willing to look at the 16
concerns relating to code savings. However, it stressed 17
that any change must also be agreed to by the Cost-18
Effectiveness Advisory Committee, and potentially brought 19
before the NEEA board. Idaho Power understands that the 20
Cost-Effectiveness Advisory Committee made the initial 21
decision to use a stipulated assumption in lieu of 22
influence evaluations. 23
Q. Based on the EM&V report findings and NEEA’s 24
response to those findings, do you believe Idaho Power’s 25
DRAKE, DI 16
Idaho Power Company
participation in NEEA through the remaining funding cycle 1
will yield cost-effective energy savings for Idaho Power’s 2
customers? 3
A. Yes. Based on the Evaluator’s calculated UCT 4
cost-effectiveness ratio of 5.68, Idaho Power’s 5
participation in the current NEEA funding cycle is cost-6
effective. However, if NEEA changes its method of 7
estimating code savings, only reports standard savings with 8
conclusive quantifiable NEEA influence, and reports Idaho 9
Power Service area savings, the cost-effectiveness ratio 10
will likely decrease. 11
Q. How will the concerns revealed by the 12
evaluation impact Idaho Power’s decision to participate in 13
the 2025-2029 NEEA funding cycle? 14
A. In any decision, the Company is committed to 15
the pursuit of tangible, transparent, and cost-effective 16
energy savings for its customers. Based on NEEA’s initial 17
response to the EM&V findings, Idaho Power will continue 18
discussions to address each concern before the next funding 19
cycle. At this time, Idaho Power is undecided on 20
participating in the next funding cycle. Using the findings 21
and recommendations of the EM&V, NEEA’s potential 22
implementation of any of the EM&V recommendations, and any 23
Commission guidance received, the Company will evaluate 24
whether it believes NEEA is a wise use of customer funds 25
DRAKE, DI 17
Idaho Power Company
and provides sufficient direct benefits to Idaho residents 1
moving forward in order to determine whether it will 2
participate in the 2025-2029 funding cycle. 3
Q. Are there regional issues that impact NEEA’s 4
work? 5
A. Yes. While the Northwest states share many 6
common attributes that make the region well suited for 7
coordinated market transformation, the Company recognizes 8
the continually widening differences in jurisdictional 9
regulatory goals, market trends, and customer needs across 10
each state. For instance, in the state of Washington, 11
utilities are mandated by law to participate in market 12
transformation activities, effectively requiring 13
cooperation with NEEA given that they are the most 14
prominent regional actor. Many jurisdictions in the region 15
have adopted vastly different policy directions surrounding 16
issues such as decarbonization and electrification. As a 17
longstanding supporter of NEEA since its inception in 1997, 18
Idaho Power is concerned that these conflicting pressures 19
could push the alliance to lose sight of its initial vision 20
of regional energy efficiency market transformation, which 21
does not align with the direction the Company has been 22
given by the Commission on spending Idaho Energy Efficiency 23
Rider dollars to pursue cost-effective energy efficiency. 24
DRAKE, DI 18
Idaho Power Company
Currently NEEA offers select opportunities for 1
funders to opt into special-funding initiatives, which 2
enable utilities to seize opportunities that benefit them 3
at a more localized level. However, these opportunities 4
make up less than 10 percent of overall NEEA funding, with 5
the remainder falling under the core funding contributions 6
made by each member utility. 7
Q. What are the estimated costs for the 2025-2029 8
NEEA funding cycle? 9
A. See Table 1 below detailing NEEA funding cycle 10
costs over the past two funding cycles as well as the 11
current proposed costs for the upcoming 2025 – 2029 12
business cycle. The 2025 – 2029 budget and Idaho Power’s 13
funding share are both estimates at this point in time, but 14
the potential rising costs of NEEA participation concerns 15
Idaho Power. At this expense level it is imperative to be 16
confident that Idaho Power customers are realizing a 17
relative benefit. 18
Table 1 – NEEA Funding Cycle Comparison 19
Funding Cycle 2015-2019 2020-2024 2025-2029*
NEEA Electric Budget $168,241,447 $159,350,000 $211,800,000
Idaho Power Electric Funding Share 8.0% 9.23% 9.58% **
Idaho Power Funding (Contract) $13,450,835 $14,710,808 $20,290,440
*Proposed by NEEA
** Assuming same participating funders as in current cycle

DRAKE, DI 19
Idaho Power Company
III. STAKEHOLDER ENGAGEMENT 1
Q. Did Idaho Power consult the Energy Efficiency 2
Advisory Group (“EEAG”) regarding the Evaluator’s EM&V 3
report? 4
A. Yes, on May 10, 2023, the Company presented 5
the findings from the Evaluator’s EM&V to EEAG. Several 6
EEAG members asked clarifying questions regarding 7
differences in methodology between NEEA and the Evaluator’s 8
cost-effectiveness calculations, how NEEA allocates energy 9
savings to Idaho Power, and how influence on codes and 10
standards is quantified. There were also comments made by 11
EEAG members supporting NEEA’s intent for market 12
transformation to move from the larger population centers 13
to smaller ones over time. 14
Q. Did Idaho Power consult with Staff during the 15
EM&V process? 16
A. Yes, the Company has had several meetings with 17
Staff, the Evaluator, and Avista to create the evaluation 18
plan and to report progress and findings. These check-in 19
meetings have benefitted the process by ensuring that the 20
evaluation met the expectations of the Commission set forth 21
in Order No. 35270. After an initial kick off meeting with 22
Avista and the Evaluator in September 2022, the Evaluator 23
developed a workplan outlining the evaluation objectives, 24
activities, and overall approach. The Company and Avista 25
DRAKE, DI 20
Idaho Power Company
met with Staff in October 2022 to share the workplan and 1
answered questions regarding the Evaluator’s proposed 2
evaluation approach as well as cost-effectiveness 3
calculation methodology. Once Staff’s questions were 4
addressed, the Company and Avista finalized the workplan 5
and the Evaluator commenced the EM&V. 6
The Company and Avista received an initial copy of 7
the report in January 2023. In February 2023, the Evaluator 8
presented the initial findings and recommendations to the 9
Company, Avista, and Staff. As a result of the meeting, the 10
Evaluator updated the report to provide additional context 11
and clarity around specific findings and recommendations. 12
Due to the timing of the Annual Report and prudence filing 13
and the need for additional research and follow up, Idaho 14
Power met with Staff in March and June to discuss timing of 15
this supplemental filing. 16
IV. CONCLUSION 17
Q. Please summarize Idaho Power’s next steps in 18
evaluating the 2025-2029 funding cycle. 19
A. While Idaho Power and NEEA share the same 20
fundamental objective of improving energy efficiency, as 21
the EM&V demonstrates, their preferred approaches and 22
priorities to pursuing this shared goal may not always 23
align. Guided by the findings and recommendations of the 24
EM&V, NEEA’s potential implementation of any of the EM&V 25
DRAKE, DI 21
Idaho Power Company
recommendations, and any Commission guidance received 1
through orders issued in this matter or other relevant 2
proceedings, the Company will evaluate whether it believes 3
NEEA is a wise use of customer funds and provides 4
sufficient direct benefits to Idaho residents moving 5
forward in order to determine whether it will participate 6
in the next funding cycle. 7
Q. Please summarize the Company’s request in this 8
case. 9
A. The Company respectfully requests the 10
Commission issue an order: (1) designating Idaho Power’s 11
2022 DSM expenses of $39,896,437 as prudently incurred, (2) 12
finding the Company complied with the directives outlined 13
in Order No. 35270, and (3) acknowledging continued 14
participation in NEEA through the current funding cycle is 15
likely to result in cost-effective energy savings for Idaho 16
Power’s customers. 17
Q. Does this conclude your testimony? 18
A. Yes, it does. 19
DRAKE, DI 22
Idaho Power Company
ATTESTATION OF TESTIMONY 1
2
STATE OF IDAHO ) 3 ) ss. 4
County of Ada ) 5
I, Theresa Drake, having been duly sworn to testify 6
truthfully, and based upon my personal knowledge, state the 7
following: 8
I am employed by Idaho Power Company as Customer 9
Relations & Energy Efficiency Senior Manager and am 10
competent to be a witness in this proceeding. 11
I declare under penalty of perjury of the laws of 12
the state of Idaho that the foregoing pre-filed testimony 13
and exhibits are true and correct to the best of my 14
information and belief. 15
DATED this 30th day of June 2023. 16
17 18 Theresa Drake 19
20 SUBSCRIBED AND SWORN to before me this 30th day of 21
June 2023. 22
23
24 Notary Public for Idaho 25 Residing at Boise, Idaho 26
My commission expires:09/10/2026 27 28 29 30