20231201Reply Comments.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

November 30, 2023

Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-23-10
In the Matter of the Application of Idaho Power Company for a Determination
of 2022 Demand-Side Management Expenses as Prudently Incurred

Dear Commission Secretary:

Attached for electronic filing in the above-entitled matter is Idaho Power Company’s
Reply Comments in the above matter.

If you have any questions about the attached documents, please do not hesitate to
contact me.

Sincerely,

Megan Goicoechea Allen
MGA:cd
Enclosures
RECEIVED
2023 NOVEMBER 30, 2023 4:33PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S REPLY COMMENTS - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
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’S
REPLY COMMENTS

Idaho Power Company (“Idaho Power” or “Company”) respectfully submits the
following Reply Comments in response to Comments filed by the Idaho Public Utilities
Commission (“Commission”) Staff (“Staff”) on November 16, 2023.
I. REPLY COMMENTS
In its Comments, Staff concludes the Company’s programs are generally well
managed and recommends the Commission approve $39,886,970 in DSM-related
expenditures including $31,575,643 in Idaho Energy Efficiency Tariff Rider (“Rider”)
expenses (which includes an adjustment of $9,467 to reflect the exclusion of advertising
expenses) and $8,311,328 in Demand Response (“DR”) program incentives. In these
IDAHO POWER COMPANY’S REPLY COMMENTS - 2
Reply Comments, the Company briefly responds to issues and recommendations raised
by Staff.
A. Advertising Expense Disallowance
Idaho Power notes Staff’s recommendation to remove $9,467 from the prudence
request associated with brand-enhancement focused advertisements at the Boise Airport,
and the Company does not oppose the recommendation. While the Energy Efficiency
Rider did not directly pay for the “Clean Energy” ad (it was a bonus ad provided by the
advertiser for purchasing the "Powering Business" ad), the “Powering Business” ad was
paid for by the Rider because of the mention of energy efficiency incentives. However,
the Company acknowledges the ad did not include an energy efficiency specific “call to
action” (e.g., an EE-specific website URL) and accordingly, is not opposed to Staff’s
recommendation to remove the $9,467 from the prudence request. Going forward, the
Company will work to ensure all future Rider-funded ads are energy efficiency focused.

B. DSM Program Management

The Company appreciates Staff’s positive comments related to the Welcome Kits,
Commercial & Industrial Custom Projects, and DR programs. The Company is committed
to providing valuable educational opportunities, documenting projects to ensure prudent
spending, and offering cost-effective incentives to customers that provide load reduction
during high-risk time periods.
Specifically, the Company agrees with Staff’s recommendation to allocate future
Welcome Kit expenses to the Residential Energy Efficiency Education Initiative (“REEEI”)
and is committed to continuing to evaluate ways to reduce the overall cost of the kits.
While the expenses will be allocated to the REEEI, the Company highlights that it does
not currently track savings for other educational-type efforts undertaken as part of the
IDAHO POWER COMPANY’S REPLY COMMENTS - 3
REEEI, and therefore will not allocate savings to that initiative. Rather, the Company
intends to continue to allocate the savings associated with the Welcome Kits to the
Educational Distributions program, which will ensure total portfolio savings are reflective
of all quantifiable savings.
In its comments, Staff also recommended the Company continue to monitor the
Heating & Cooling Efficiency program cost-effectiveness and to make changes as
necessary to maintain a cost-effective program. The Company agrees with the
recommendation and also notes that it has recently made changes to the program that,
along with relying on the new avoided costs from the 2023 Integrated Resource Plan, are
expected to result in the program being cost-effective in 2023 and going forward.
In all aspects of DSM program management, the Company particularly appreciates
the involvement and input from Staff, as well as the broader Energy Efficiency Advisory
Group (“EEAG”) and will continue to bring items related to program management and
opportunities for improvement to the EEAG for their perspective.
C. Home Energy Reports

For the Home Energy Reports program, “Staff believes the Company should not
use a life-cycle perspective to evaluate the cost-effectiveness of the program and should
use the measure life instead.”1 The Company agrees with Staff’s comments and will
continue to report cost-effectiveness of the program from the measure life perspective as
it is currently. It is the goal of Idaho Power for all programs to be cost-effective each year
based on the measure life and program life.
For historical context, the program was cost-effective from a one-year measure life
perspective in 2018 and 2019, though in 2020, the offering was not cost-effective largely

1 Staff Comments at 7.
IDAHO POWER COMPANY’S REPLY COMMENTS - 4
due to the additional costs associated with the program’s expansion from a pilot to a full
program. At that time, it was expected to be cost-effective from an annual basis going
forward; however, updated avoided cost assumptions and the removal of capacity
benefits in 2021 impacted the program’s cost-effectiveness in 2021 and 2022. As a result
of the Company’s near-term capacity deficiency, the program is anticipated to once again
be cost-effective from a one-year measure life perspective, and the Company is currently
reviewing the potential to continue the offering beyond 2023. All future program options
are anticipated to be cost-effective from a one-year measure life perspective.
D. Northwest Energy Efficiency Alliance (“NEEA”)
The Company appreciates Staff’s recommendation for the Commission to provide
input on the matter of Idaho Power’s NEEA participation. In their comments, Staff raised
concerns stating:
 “Staff is concerned that NEEA is no longer focused on the needs of its
participants east of the Cascades and in states without Renewable Portfolio
Standards (“RPS”).”2
 “Staff believes NEEA activities need to provide benefit to Idaho; if NEEA
activities do not benefit Idaho, participation should be reevaluated.”3
 “NEEA claims 100% of code savings and standards savings are based on
a template that NEEA created for evaluating their influence. Staff is
uncertain about the amount of influence that NEEA provides for these
changes.”4

2 Staff Comments at 15
3 Staff Comments at 16
4 Staff Comments at 17
IDAHO POWER COMPANY’S REPLY COMMENTS - 5
Idaho Power shares Staff's concerns, and after the Evaluation Measurement &
Verification (“EM&V”) was finalized, met with NEEA on several occasions to assess how
NEEA intends to respond to findings from the report. To date, NEEA has committed to
addressing all the recommendations from the EM&V including providing service area level
reporting for Idaho Power. Of particular interest to the Company is the issue of state code
savings and how those will be attributed to NEEA in the future. The need to estimate
NEEA’s qualitative and quantitative influence, developed with a third-party, for estimating
future state code savings was included as Recommendation #9 from the EM&V, and in
discussions between Idaho Power and NEEA, NEEA has committed to address this
recommendation.5 NEEA has maintained that its Cost Effectiveness Advisory Committee
(“CEAC”) ultimately informs how code savings are quantified and allocated among
jurisdictions. As noted by Staff, on November 30, 2023, NEEA’s CEAC met to discuss a
process and timeline to determine a framework for future state code evaluations. The
Company intends to engage directly with NEEA on a process to address
Recommendation #9 for Idaho, separate from the CEAC process.
While the Company believes that NEEA understands the concerns related to the
quantification and allocation of code savings, the Company is uncertain whether NEEA
will be able to appropriately address Recommendation #9 in a timely and satisfactory
manner before the Idaho Power contract with NEEA for the 2025-2029 funding cycle
needs to be finalized. To provide adequate time for the Commission to review, and
ultimately decide on Idaho Power’s involvement in the next funding cycle, Idaho Power
believes having resolution on this matter in advance of August 2024 is necessary. If Idaho
Power ultimately signs a contract with NEEA for the 2025-2029 business cycle, Idaho

5 Direct Testimony of Theresa Drake, Exhibit 4, Page 20
IDAHO POWER COMPANY’S REPLY COMMENTS - 6
Power will seek Commission approval of that decision and anticipates filing that request
by September 1, 2024, to allow for a Commission order by the end of 2024 – prior to
Idaho Power investing customer funds in the next business cycle. In the meantime, with
the Commission’s support, Idaho Power is committed to its continued collaboration with
NEEA and anticipates beginning contract negotiations as early as January 2024. The
Company will undertake negotiations in good faith subject to the assumption that the code
issue will be able to be satisfactorily resolved to appropriately account for energy savings
associated with NEEA code activities in Idaho. To date, NEEA has been responsive to
Idaho Power’s inquiries and requests for discussion on these matters and the Company
is appreciative of NEEA’s desire to resolve all outstanding issues in a manner that is
satisfactory to Idaho Power and the Commission.
While the Company believes timely resolution is possible, it is not yet clear whether
the ultimate outcome will appropriately ensure Idaho customers are benefiting from the
activities and savings associated with the claimed savings from codes. Considering the
magnitude of the overall business cycle cost to be paid for by Idaho Power’s customers
– approximately $20 million6 – satisfactory resolution of this matter is imperative. Guided
by the findings and recommendations of the EM&V and NEEA’s potential implementation
of the same, as well as any Commission guidance received through orders issued in this
matter, the Company will evaluate whether it believes entering into a contract for the
2025-2029 business cycle will provide sufficient direct benefits to Idaho residents moving
forward such that the cost of participation will be a wise use of customer funds.

6 Direct Testimony of Theresa Drake, Table 1, page 18.
IDAHO POWER COMPANY’S REPLY COMMENTS - 7
II. CONCLUSION
Idaho Power is committed to pursuing cost-effective energy efficiency measures
on behalf of its customers and supports market transformation activities as part of those
efforts. Idaho Power appreciates the ongoing collaboration with Staff and the EEAG to
continually improve its energy efficiency offerings. Additionally, the Company intends to
continue discussions with NEEA in order to evaluate whether continued participation
provides sufficient value to Idaho Power’s customers to justify investing funds in the
upcoming NEEA business cycle. To this end, the Company would welcome input from
the Commission, as recommended by Staff, on the matter of Idaho Power’s ongoing
NEEA participation.
The Company respectfully requests that the Commission issue an Order: (1)
designating Idaho Power’s expenditures of $31,575,643 in Rider funds and $8,311,328
of DR program incentives, for a total of $39,886,970, as prudently incurred DSM
expenses; (2) finding the Company complied with the directives outlined in Order No.
35270 related to conducting an EM&V of NEEA savings and cost-effectiveness; and (3)
acknowledging that continued participation in NEEA through the current funding cycle is
likely to result in cost-effective energy savings for Idaho Power’s customers.
DATED at Boise, Idaho, this 30th day of November 2023.
________________________________
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S REPLY COMMENTS - 8
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 30th day of November 2023, I served a true and
correct copy of Idaho Power Company’s Reply Comments upon the following named
parties by the method indicated below, and addressed to the following:

Commission Staff
Michael Duval
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-500
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Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-500
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Christy Davenport
Legal Administrative Assistant