19990902Notice of Modified Procedure.doc

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY TO OFFSET 1998 AND 1999 NORTHWEST EFFICIENCY
ALLIANCE PAYMENTS AGAINST RESERVED FUNDS

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CASE NO. IPC-E-99-7

NOTICE OF APPLICATION

NOTICE OF MODIFIED
PROCEDURE

YOU ARE HEREBY NOTIFIED that on August 10, 1999, the Idaho Power Company (Idaho Power; Company) filed an Application for authority to offset the Company’s 1998 and 1999 Northwest Energy Efficiency Alliance (NEEA) payments against the Company’s reserved funds. In Order No. 27877 issued in January of this year in Case No. IPC-E-98-12, the Commission authorized the creation of a reserve to provide for the funding of the Company’s 1998 and 1999 payments to NEEA. In that Order, the Commission provided that when the Company believed that it had sufficient evidence of prudence, it should file an Application for Authority to offset the Company’s 1998 and 1999 NEEA expenditures against the reserved funds.
Attached to the Company’s Application is a copy of the 1998 operational audit conducted by Pricewaterhouse Coopers and an executive summary letter to Idaho Power from Margaret Gardner, Executive Director of NEEA. Idaho Power contends that, overall, the audit evaluation found that NEEA’s actions and plans are aligned with the organizations’ purposes and objectives and that there are many strengths and effectiveness and efficiency of the organization’s overall performance.
Also attached to the Company’s Application is the independent audit report of Moss-Adams, LLP, on NEEA’s financial statements for the years 1997 and 1998. Idaho Power contends that report indicates NEEA’s financial statements fairly present the position of NEEA as of year end 1998 and 1997.
According to Idaho Power, NEEA has adopted a process to monitor program results to ensure that its programs are cost effective. That process has five major purposes:

1. To provide timely feedback on program design and performance.

2. To assess the impact of the program on target markets, market structure and market players.
3. To assess the process of NEEA toward the exit strategy adopted by the Board.

4. To estimate total program effects for the region and to document changes in basic program assumptions.

5. To provide a record of venture accomplishments, contained primarily in the evaluation publications generated by NEEA.

In addition, the NEEA evaluation process provides value added service to the ventures and developers by augmenting or independently developing market intelligence or market characterization data. Idaho Power’s Application describes in greater detail the evaluation process for NEEA programs.
Idaho Power states that NEEA has developed an evaluation process for ensuring that its programs are cost effective for customers. When a proposal is being prepared by Staff to present to the NEEA Board, a preliminary cost effectiveness and potential savings analysis is conducted. Data from the initial analysis is present to the Board during the project adoption phase. If the project is approved, a more thorough search is made to improve the data.
Annually, a committee of the Board meets to review the analysis of savings and the costs per kWh from the projects. This information is contained in the NEEA annual report and other corporate communications. In addition, NEEA has requested that its evaluation contractors review the data used in the original Staff analysis for some of the older projects and make recommendations for particular changes.
Included with Idaho Power’s Application are letters of support from the Idaho Department of Water Resources, the International Conference of Building Officials (Idaho Chapter), the Northwest Building Operator’s Association and the Association of Idaho Cities. Moreover, Idaho Power states that it has been proactive in its role as a participating member of NEEA. The Company argues that it has actively encouraged workshops and training sessions for its customers for various energy savings measures. Idaho Power states that it has also located personnel for NEEA with needed expertise. The Company offers its conference rooms and facilities across its service territory to NEEA for training sessions and meetings.
The Company has also utilized its employees, bill stuffers, company newsletters and trade relationships to disseminate information to its customers concerning opportunities to save energy through NEEA programs. Last year, Idaho Power formed a NEEA advisory group consisting of Company employees who review NEEA’s programs and determine how best Idaho Power can promote those programs to its customers and to determine opportunities or barriers specific to the Company’s service territory.
The Company’s delivery service representatives help provide the link between NEEA programs and Idaho Power’s industrial and larger commercial customers. The Company uses its own customer and employee publications to provide information about NEEA programs.
Idaho Power notes that Darlene Nemnich, the Company’s NEEA Board of Directors representative, participates in all regular meetings and is active on several NEEA committees. Idaho Power provides other specific examples of how the Company is promoting particular NEEA programs to its customers.
The Company’s Application states that because Commission Order No. 27877 was actually issued in 1999, the Company knew the exact amount attributable to the Idaho jurisdiction that had been paid to NEEA for the year 1998 which was $1,615,831.93. Idaho Power argues that it should be permitted to offset that amount against the reserve that has been established for that purpose.
Because the Company’s NEEA assessment for 1999 will be approximately the same as 1998, the Company, pursuant to Order No. 27877, reserved $1,615,832 as the allocable share for the Idaho jurisdiction for the year 1999. Idaho Power states that it has already paid 1999 NEEA assessments in the amount of $792,586.72. Idaho Power contends that it should be permitted to offset these payments against the Company’s 1999 reserve and, as the Company makes the balance of the 1999 payments, it should be permitted to offset those payments from the 1999 reserve amounts.
Idaho Power reminds that the Company has only deferred the cash payments actually paid to NEEA. It has not deferred any indirect costs of participation in NEEA. Idaho Power requests that its Application be processed under Modified Procedure.
YOU ARE FURTHER NOTIFIED that the Application together with supporting workpapers, testimonies and exhibits, have been filed with the Commission and are available for public inspection during regular business hours at the Commission offices.
YOU ARE FURTHER NOTIFIED that all proceedings in this case will be held pursuant to the Commission's jurisdiction under the Title 61 of the Idaho Code and that the Commission may enter any final Order consistent with its authority under Title 61.
YOU ARE FURTHER NOTIFIED that all proceedings in this matter will be conducted pursuant to the Commission's Rules of Procedure, IDAPA 31.01.01.000 et seq.
YOU ARE FURTHER NOTIFIED that the Commission has determined that the public interest may not require a formal hearing in this matter and will proceed under Modified Procedure pursuant to Rules 201 through 204 of the Idaho Public Utilities Commission's Rules of Procedure, IDAPA 31.01.01.201 through .204.
YOU ARE FURTHER NOTIFIED that any person desiring to state a position on this Application may file a written comment in support or opposition with the Commission within twenty-one (21) days from the date of this Notice. The comment must contain a statement of reasons supporting the comment. Persons desiring a hearing must specifically request a hearing in their written comments. Written comments concerning this application shall be mailed to the Commission and the Applicant at the addresses reflected below:
COMMISSION SECRETARY LARRY D. RIPLEY
IDAHO PUBLIC UTILITIES COMMISSION GREGORY SAID
PO BOX 83720 IDAHO POWER COMPANY
BOISE, IDAHO 83720-0074 PO BOX 70
BOISE, IDAHO 83707-0070
STREET ADDRESS FOR EXPRESS MAIL:

472 W. WASHINGTON STREET
BOISE, IDAHO 83702-5983

These comments should contain the case caption and case number shown on the first page of this document.
YOU ARE FURTHER NOTIFIED that if no written comments are received within the time limit set, the Commission will consider this matter on its merits and enter its Order without a formal hearing. If written comments are received within the time limit set, the Commission will consider them and, in its discretion, may set the same for formal hearing.

DATED at Boise, Idaho this day of August 1999.

Myrna J. Walters
Commission Secretary

bls/N:ipce997_bp
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE 1

Office of the Secretary
Service Date
September 2, 1999