2000316_cc.doc

DECISION MEMORANDUM

TO: COMMISSIONER HANSEN
COMMISSIONER SMITH
COMMISSIONER KJELLANDER
MYRNA WALTERS
RON LAW
BILL EASTLAKE
STEPHANIE MILLER
DON HOWELL
DAVID SCHUNKE
RANDY LOBB
TONYA CLARK
BEV BARKER
TERRI CARLOCK
WORKING FILE

FROM: CHERI C. COPSEY

DATE: MARCH 17, 2000

RE: IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO FUND ITS CONTINUING PARTICIPATION IN THE NORTHWEST ENERGY EFFICIENCY ALLIANCE, INC.;
CASE NO. IPCE9913.

On December 30, 1999, Idaho Power Company filed an Application with the Commission requesting an order authorizing it to continue to participate in the Northwest Energy Efficiency Alliance, Inc. (NEEA) and to recover the costs of participation. NEEA is a nonprofit corporation established in 1996 for the purpose of transforming markets for selected electric conservation products and services on a regional basis. Idaho Power specifically requested that the Commission determine if it is in the public interest for Idaho Power to continue to participate in NEEA for the period 2000-2004. If the Commission decides that continued participation is in the public interest, Idaho Power also requested that the Commission approve a mechanism that allows it to recover its NEEA expenditures. More specifically, it suggested that there are two ways to reimburse it for its continued contributions and participation in NEEA; use of revenue sharing funds or the imposition of a separate charge specifically dedicated to funding NEEA.

On February 1, 2000, the Commission issued a Notice of Modified Procedure setting the deadline for comments as March 9, 2000. Order No. 28273. Consumer Division Staff and Utilities Division Staff filed separate comments. FMC Corporation, the Industrial Customers of Idaho Power, Micron Technology, Inc., the Idaho Department of Water Resources, the NW Energy Coalition (NWEC), Natural Resources Defense Fund (NRDC), the Idaho Rural Council, the Idaho Rivers-United and the Department of Health and Welfare, Bureau of Policy, Grants Units filed comments. The Department of Health and Welfare filed a request to withdraw its comments on March 9, 2000.
Utilities Division Staff recommends the Commission approve the Application and allow Idaho Power to use revenue sharing funds to pay its share of the NEEA participation.
Consumer Division Staff suggests that consumers have not been given an adequate opportunity to respond to the Application and alleges that the Commission has not determined whether NEEA programs are the most efficient or economical energy conservation programs. Therefore, Consumer Division Staff recommends that the Commission “initiate a case to seek public input on these issues and conduct a more comprehensive evaluation of NEEA programs and an economic comparison to other programs.”
Although it is skeptical about the value of participating in NEEA, FMC Corporation does not oppose participation as a general matter but requests the Commission approve excluding the four (4) special contract customers from the NEEA funding charge, allowing those customers to use their allocated portion of the NEEA funds to underwrite self-directed conservation efforts in lieu of funding NEEA’s “market transformation” activities. FMC requests a hearing on Idaho Power's Application to determine whether Idaho Power's large industrial customers should be eliminated from the NEEA funding requirements or allowed to conduct directly funded DSM programs with their allocated share of the conservation contributions.
The Industrial Customers and Micron oppose approving continued participation in NEEA. The Industrial Customers and Micron request a hearing on Idaho Power's Application to determine whether continued participation in NEEA is in the public interest. Industrial Customers and Micron also suggest that the Commission allow Schedule 19 and Special Contract customers to use their allocated portion of the NEEA funds to underwrite self-directed conservation programs and that the details for such a program should be explored in workshops without the need for an evidentiary hearing.
The Idaho Department of Water Resources supports the continued participation in NEEA and supports using revenue sharing funds.
The NW Energy Coalition, NRDC, the Idaho Rural Council, and the Idaho Rivers-United filed joint comments supporting continued participation in NEEA and supports using revenue sharing funds.
BACKGROUND
The issue of whether Idaho Power should be authorized to participate in NEEA and recover the costs of participation has been considered by the Commission three (3) times. Case Nos. IPC-E-96-26 and IPC-E-99-7. After considering direct-filed testimony and evidence, the Commission approved Idaho Power’s participation in NEEA for the years 1997-1999. Order Nos. 27045, 27124, 27200 issued in Case No. IPC-E-96-26. At the time of its initial approval of Idaho Power’s participation in NEEA, the Commission found it desirable to require that Idaho Power defer its annual NEEA expenditures for recovery at a later date once their prudence had been demonstrated. In subsequent orders, the Commission authorized Idaho Power to establish a reserve (consisting of Idaho Power’s accumulated revenue sharing balances) for reimbursement of Idaho Power’s deferred NEEA expenditures for the years 1997-1999. Reimbursement of Idaho Power’s NEEA expenditures was authorized on a year-to-year basis as their prudence was shown.
According to the Commission, “[h]istorically, conservation efforts have occurred throughout the Northwest on an ad hoc basis. . . . NEEA is based on the belief that by transforming markets, it is possible to achieve improvements in the efficiency of electricity use without the need for long-term utility incentives.” Order No. 20475 at 5.
THE APPLICATION
The purpose of the present Application is to determine:
1. Whether it is in the public interest to authorize Idaho Power to commit to participation in NEEA for the years 2000-2004, and

2. If NEEA participation is in the public interest, then how should the Company’s expenditures be funded.

Idaho Power suggests that a regional approach to Demand Side Management (DSM) is preferable. Idaho Power advocates continued participation in NEEA identifying what it believes are that organization’s successes to date.
For the years 1997-1999, NEEA was funded through the contributions of Idaho Power, Avista Utilities, Bonneville Power Administration, Montana Power Company, PacifiCorp, Portland General Electric Company, and Puget Sound Energy (formerly Puget Sound Power & Light Company). According to Idaho Power’s Application, the NEEA Board of Directors has determined that NEEA is accomplishing its purpose and has requested that Idaho Power, along with the other original founders, renew their commitment to NEEA for the period 2000-2004. For that period, Idaho Power’s contribution would be reduced to $1.3 million annually on a system basis. Idaho Power characterizes it support for continued participation in NEEA as follows:
. . .in its first three years of existence NEEA is fulfilling that public purpose. In light of the uncertainties surrounding the electric industry, Idaho Power also believes that to the extent it is in the public interest for Idaho Power to engage in DSM (conservation) programs, participation in NEEA is the best way to accomplish that goal.

Application at 16.
NEEA now requires its participating members to sign five-year commitments. The allocated share to the Idaho jurisdiction is $1,241,500 annually, or a total of $6,207,500 for the five-year period. Idaho Power has already signed a Memorandum of Agreement in support of NEEA and has signed its funding agreement. The funding agreement, however, provides that Idaho Power shall not have any obligation to provide funding to NEEA if it does not receive cost recovery approval from this Commission.
In its Application, Idaho Power alleges that to the extent it is an enterprise engaged in selling a commodity (electricity) and to the extent it is engaged in DSM activities, it should be reimbursed for the expenditures that it makes. Idaho Power relies on Order No. 27045 issued by the Commission in Case No. IPC-E-96-26 in which the Commission held that Idaho Power's ratepayers, not its shareholders should fund its participation in NEEA because of the financial benefits they reap through their reduced use of electricity and through the avoidance of new resources. Order No. 27045 at 5.
In Order No. 28041, Case No. IPC-E-98-16, the Commission specified that all revenues previously attributable to DSM activities be used to fund the amortization of Idaho Power’s deferred DSM expenditures or its existing Low Income Weatherization Program. Consequently, there are no revenues currently being collected to fund any ongoing Idaho Power NEEA participation for the period 2000-2004. Idaho Power suggested in its Application that there are two methods by which it could be reimbursed for its NEEA contributions for the 2000-2004 period: (1) the continued utilization of revenue sharing funds, or (2) a separate charge specifically dedicated to funding DSM activities.
For the years 1997-1999, the Commission authorized utilizing revenue sharing funds. Idaho Power contends that this is a simple, straightforward approach and causes no changes to its retail rates. In its Application, Idaho Power points out that, to date, it has accrued revenue sharing funds for the year 1999 in an amount that appears to be sufficient to fund Idaho Power’s commitment to NEEA for the next five years. Idaho Power suggests that a reserve could be established which would accrue interest at the rates set for customer deposits established annually by the Commission. Assuming a rate of 5%, this would require $5,462,388 to be placed in the reserve. Idaho Power suggests that as its payments are made to NEEA, that money could be transferred from the reserve to reimburse Idaho Power for the period 2000-2004.
As an alternative, Idaho Power suggests that the Commission could authorize a specific charge dedicated to DSM activities. The Commission has already approved a similar charge for Avista. Idaho Power agrees that this would be an acceptable method, as well. In developing the charge, Idaho Power suggests the Commission could also exclude a customer class from the requirement to pay a NEEA charge (i.e., Idaho Power’s four special contract customers). That class could then be determined to be ineligible for participation in NEEA programs if it were the desire of NEEA and/or the Commission. Idaho Power also suggested that the Commission could also make adjustments to the rate design of the NEEA charge such as using a different allocation method or placing a per customer cap on the distribution charge. Ultimately, Idaho Power notes, the NEEA charge could be implemented as a uniform rate per kWh, a flat fee or some other pricing structure.
Idaho Power also suggested that if such a NEEA charge is ordered, then customer input should be solicited in order to best determine how to structure the charge. However, Idaho Power proposed the reserve fund methodology as the most appropriate method for recovering the costs of continued participation in NEEA.
COMMENTS
1. Consumer Division Staff Comments
Consumer Division Staff opposes continued participation in NEEA based on the current record and without further proceedings. More particularly, Consumer Division Staff recommends:
Consumers have not been given an adequate opportunity to respond to the question of whether or not they support energy efficiency programs and, if so, what types would they find to be most beneficial.

The Commission has not determined whether or not NEEA programs are the most efficient and economic approach to energy conservation or whether or not it is duplicative of other programs.

The Consumer Division Staff therefore recommends that the Commission initiate a case to seek public input on these issues and conduct a more comprehensive evaluation of NEEA programs and an economic comparison to other programs.

Consumer Division Staff further suggested that “[i]f conservation of kilowatt-hours is the Commission’s goal it should look at the supply side (utility side) as well; while NEEA claims to have saved 14 average megawatts in 3 years, Idaho Power reported 1.2 million-megawatt hour losses in its 1998 Annual Report to the Federal Energy Regulatory Commission.”
a. Customer Notice Concerns. Consumer Division Staff suggested that “[t]he Commission’s decision to take up both questions under modified procedure may have limited customer notice on the possibility of a rate increase.” Furthermore, “it is the opinion of the Consumer Division Staff that customers should also be given the opportunity to comment on a five-year commitment to NEEA.” According to Consumer Division Staff, should the Commission decide to order a specific charge for cost recovery, Consumer Division Staff recommended that “it should also consider whether or not proper notice has been given to the ratepayers.”
b. Consumer Input. Based on its review of the records in the earlier Commission cases, Case Nos. IPC-E-96-26 and IPC-E-98-12, Consumer Division Staff concluded that
Consumers in general prefer to manage their own conservation efforts and resent and distrust government interference. The real motivator to conserve energy is money and saving money on utility bills. Others are just flat tired of conservation programs; they feel the effort has run its course. Consumers are clearly educated on the issue and see no individual benefit to them. Low-income consumers in particular do not see “market transformation” as a solution to their problems.

Consumer Division Staff noted that Idaho Power had conducted no customer surveys. However, based on its review of various surveys conducted by others, it concluded that
While it was clear in various surveys that consumers thought energy conservation was important, especially in lieu of new energy resources and especially resources that were not environmentally friendly, it was not so clear how much people were willing to pay for energy conservation policies and programs such as NEEA. Since most of the surveys were asking whether or not consumers were willing to pay more for “green power” a favorable response to that question does not equate to a favorable response for a market transformation energy conservation program.

c. NEEA Contribution Recovery. With respect to NEEA cost recovery, Consumer Division Staff suggested:
While the Consumer Division Staff understands why the Commission would want to utilize revenue sharing funds to cover the cost of participating in NEEA in order to avoid a rate increase, those consumers who view this as a tax believe it is in the public interest to reflect on the customer’s bill what the cost to them is for this policy. If this is a “public purpose charge” perhaps it is no different than a “universal service fee” or a “911 surcharge.”

Moreover, “[t]he Consumer Division Staff and most of the commentors in IPC-E-96-26 also believe that the rate design for recovery of this cost should be based on a percent of the total bill because it is inherently more fair and has some built in conservation incentive.” Finally, Consumer Division Staff suggested that it would “also be unfair for some customer classes to be allowed to opt out, leaving the cost to be redistributed on the backs of the remaining customers.”
d. Weatherization Programs. Consumer Division Staff reviewed the Idaho Department of Health and Welfare provided results of the Department of Energy’s (DOE) Low-Income Weatherization Program. Based on that review, Consumer Division Staff recommended that “[a] well-defined weatherization program would appear to have a more direct and significant impact on energy bills.” As a result, it recommended that “[t]he Commission should consider how many Idaho homes could be weatherized for $1.3 million per year.”
2. Utilities Division Staff Comments.
The Utilities Division Staff continues to support the concept of market transformation and recommended that Idaho Power be authorized to continue to participate in NEEA for the next five years as proposed in its Application. The Utilities Division Staff further recommended that the costs for participation be recovered through revenue sharing funds as previously approved by the Commission.
According to the Utilities Division Staff while, since NEEA’s inception in 1996, Staff has supported the regional market transformation concept and the financial participation of Idaho Power, that support has not been without some concern. However, in analyzing the most recent information the Utilities Division Staff found that many of the potential problems identified in prior Staff comments have either not materialized or have been addressed. For example, earlier Staff identified the potential for conflicts of interest, more identifiable return on customer funds, customer participation and cost effectiveness.
a. Potential for Conflict of Interest. While the potential for conflict of interest still exists, the Utilities Division Staff suggested that NEEA’s existing conflict of interest rules and its process for evaluating programs have effectively limited the opportunity for inappropriate profit or programs. According to the Utilities Division Staff, financial and operational audits have not identified any major deficiencies.
NEEA also added a customer representative to the Board to obtain input from the group that will ultimately pay for the programs. NEEA also expanded its programs within Idaho to provide a better return on funds contributed by Idaho customers. Idaho Power improved its participation in NEEA both at the Board of Directors level and within Idaho through increased contact with its Idaho customers and improved promotion of available NEEA programs. In 1999, Idaho Power conducted seven workshops, designed to educate customers about NEEA programs, with as many as 60 customers attending each workshop. It plans to continue to hold such workshops.
b. Cost-Effectiveness of NEEA Programs. With respect to the cost-effectiveness of NEEA, the Utilities Division Staff stated that on a prorated basis Idaho investor-owned utilities contributed approximately $5.3 million or 8.1% of NEEA’s total budget. The energy savings in Idaho according to Idaho Power’s Application is estimated to be 4.2 average megawatts (aMw) during the contract period and 34 aMw over a ten-year period. The Utilities Division Staff found that while these savings represent approximately 7.5% of all estimated NEEA savings, they also include energy use reduction in all electric service areas of Idaho.
In analyzing the cost effectiveness, the Utilities Division Staff compared the overall levelized cost of NEEA’s programs with the overall levelized cost of other intra-company DSM programs, like Low Income Weatherization and Manufactured Home Acquisition. The Utilities Division Staff found that the overall levelized cost of NEEA’s programs is estimated to be 0.15 cents per kWh or 1.5 mills per kWh. In 1996, Idaho Power spent $4.35 million on intra-company DSM programs that produced weighted, real levelized energy savings at a cost of approximately 5.7 mills per kWh. Low Income Weatherization programs produced levelized utility costs of 18.7 mills/kWh and Manufactured Home Acquisition programs produced levelized utility costs of 23.8 mills/kWh.
The Utilities Division Staff suggested that continued participation by Idaho Power through 2004 will cost slightly less on an annual basis than it did for the 1997 through 1999 period and that Idaho Power will contribute slightly less than $2 per year on average for each residential customer. The Utilities Division Staff suggested that determining whether Idaho Power customers are getting their “money’s worth,” it recognized that customers derive the benefits of energy efficiency in several ways. For example, it suggested that Idaho Power customers who actually participate in the energy efficiency programs and reduce their power bills derive direct benefits. The Utilities Division Staff suggested that Idaho Power customers who do not participate in the programs but experience a lower rate from lower overall power supply costs derive a more indirect benefit.
The Utilities Division Staff suggested that comparing the NEEA costs of energy saved within Idaho to the incremental increase in the cost of supply alternatives such as market purchases demonstrates the potential for this benefit. According to the Utilities Division Staff, the weighted cost of energy saved in Idaho is estimated to be about 0.184 cents per kWh or 1.84 mills per kWh. Therefore, the Utilities Division Staff found that the incremental increase in the cost of purchasing energy on the market is significantly larger than the estimated increase resulting from NEEA energy saved in Idaho.
Idaho Power customers can also indirectly experience a lower rate due to reduced regional demand and market prices, benefit from increased energy efficiency, improved environmental conditions from reduced consumption of fossil fuels, reduced environmental impact from fewer generating facilities and the reduced consumption of natural gas and water resources.
The Utilities Division Staff reviewed NEEA’s methodology for estimating program energy savings and stated it was satisfied that it is logically and reasonably based on the most up to date information available.
c. Recommendation. The Utilities Division Staff recommended approving Idaho Power's continued participation in NEEA. The Utilities Division Staff further recommended that annual review of NEEA activities with comments/reports to the Commission continue as part of the Idaho Power expense recovery process to allow continued input on NEEA operations. Finally, the Utilities Division Staff recommended that revenue sharing funds be used to fund Idaho Power’s continued participation in NEEA.
3. FMC Comments.
Although it is skeptical about the value of participating in NEEA, FMC Corporation does not oppose participation as a general matter but requests the Commission approve excluding the four special contract customers from the NEEA funding charge, allowing those customers to use their allocated portion of the NEEA funds to underwrite self-directed conservation efforts in lieu of funding NEEA’s “market transformation” activities. FMC requests a hearing to determine whether Idaho Power's large industrial customers should be excluded from the NEEA funding requirements or allowed to conduct directly funded DSM programs with their allocated share of the conservation contributions.
FMC asserts that large industrial customers generally do not directly benefit from NEEA market transformation activities and that most NEEA programs effectively target mass consumer markets rather than individual conservation opportunities. It argues that this results in those large industrial customers shouldering a significant share of the costs for participating in NEEA without receiving proportional benefits. Therefore, it suggests that allowing such customers to retain their NEEA contributions for direct conservation investments would both redress this alleged imbalance and mitigate the risks associated with pursuing only one limited type of conservation program. Therefore, it urges the Commission to hold an evidentiary hearing to determine whether Idaho Power's large industrial customers should be excluded from the NEEA funding requirements and allowed to conduct directly funded DSM programs with their allocated share of the conservation contributions.
4. Industrial Customers of Idaho Power Comments.
The Industrial Customers oppose further participation in NEEA, arguing that such participation is not in the public interest. It requests the Commission to hold an evidentiary hearing on whether continued participation is in the public interest, and if the Commission decides that it is in the public interest, it requests another evidentiary hearing on the question of funding. Industrial Customers’ Comments at 2-3. Furthermore, if the Commission approves the Application, the Industrial Customers argue that the Schedule 19 customers and the special contract customers should be able to self-direct their contributions for their own individual energy conservation projects.
There are several reasons that the Industrial Customers argue participation in NEEA is not in the public interest. They argue that “market transformation” is a vague term, subject to multiple definitions with little consensus as to its meaning. Moreover, the Industrial Customers assert that the benefits are speculative and require today’s ratepayers to fund conservation efforts that may occur in the future. They suggest this violates the concept of “used and useful” and improperly requires ratepayers to pay for “plant held for future use.” Id. at 6; Building Contractors v. Idaho Public Utilities Commission, 128 Idaho 534, 916 P.2d 1259 (1996). The Industrial Customers also argue that Idaho Power's participation is not in the public interest because prudency cannot be demonstrated. Furthermore, they allege that NEEA has failed to restructure its governing body to account for the lack of customer representation. According to the Industrial Customers, the NEEA Board is controlled by three parties, comprised of public power interests, investor-owned utilities and public interest groups. This makes the customer representative meaningless they allege. They also argue that NEEA participation is inappropriate because the Pacific Northwest is resource deficit.
Finally, the Industrial Customers assert that they are better suited to deliver cost-effective conservation to Idaho’s industry. Id at 10. They allege that NEEA has not been a success. Therefore, they suggest that if the Commission approves continued participation in NEEA, all Industrial Customers should be excluded from participation, permitting those customers to fund conservation programs at their individual facilities targeted to best suit the particular facility. At pages 11-14 of their Comments, the Industrial Customers generally describe a self-direction program which would be under the control of an independent Administrator. This Administrator would be charged with evaluating proposed conservation programs using certain criteria and approving the use of the appropriate funds.
Based on these Comments, the Industrial Customers recommend further evidentiary hearings or denial of the Application.
5. Micron Technology Comments.
Micron adopts the arguments and position proposed by the Industrial Customers.
6. Idaho Department of Water Resources Comments.
The Idaho Department of Water Resources supports approval of the Application and continued participation in NEEA with the costs supported out of revenue sharing funds. It wrote that it operates several NEEA projects and that NEEA Board decisions on the various acquisition programs sponsored by NEEA are based on extensive analyses to assure funds are prudently spent on products having a direct value to consumers. It suggested that participation in NEEA allows member utilities access to conservation and market transformation projects without needing to employ a large number of conservation staff, thus saving money. Therefore, it supports the continued participation in NEEA.
7. The NW Energy Coalition, Natural Resources Defense Fund, the Idaho Rural Council and the Idaho Rivers-United Comments.

NW Energy Coalition, Natural Resources Defense Fund, the Idaho Rural Council and the Idaho Rivers-United filed joint comments supporting approval of the Application and recommending continued utilization of revenue sharing funds for the 2000-2004 time period. According to these groups, NEEA has proven effectiveness. NEEA projects that it will have saved more than an average of 400 MW in the region, including Idaho, by 2010 which amounts to a savings of just under three cents ($0.03) per kilowatt-hour. They argue that Idaho Power has saved over 30 aMWs. They also comment on the comments filed by Health and Welfare regarding low-income weatherization which were later withdrawn. They suggest that the Commission should revisit the weatherization program and consider restoring funding to its original level of $320,000.
These groups argue that NEEA programs deliver prudent investments that ultimately result in cost-effective conservation being delivered to electric users in Idaho and throughout the region. Therefore, they urge the Commission to continue using Idaho Power's revenue sharing funds to participate in NEEA.
CONSUMER DIVISION STAFF RECOMMENDATION:
Consumer Division Staff recommends that the Commission initiate another case to seek public input on NEEA and this Application. More specifically, it recommends that the Commission conduct a more comprehensive evaluation of NEEA programs and compare those NEEA programs to other energy conservation programs. In addition, Consumer Division Staff recommends that this include consideration of weatherization programs.
UTILITIES DIVISION STAFF RECOMMENDATION:
Utilities Division Staff recommends the Commission issue an order to allow all parties the opportunity to respond to the comments that have been filed. Such reply comments can be filed simultaneously. Utilities Division Staff believes this would be particularly appropriate because the Industrial Customers have proposed a detailed approach to establishing a self-directed program for Schedule 19 and Special Contract customers that deserves careful consideration. Moreover, the Commission needs to know what impact excluding these customer contributions may have on Idaho Power's NEEA contribution and whether this may affect other customers. Given that this is the first time it has been proposed in such detail, it is important for the other parties to have the opportunity to review the proposal and, at a minimum, file comments.
Utilities Division Staff does not believe that additional evidentiary proceedings are necessary. Utilities Division Staff notes that this is the fourth time that Idaho Power’s participation in NEEA has been evaluated and considered by the Commission. In the past, the Commission provided an opportunity for all interested parties to prefile direct testimony and exhibits setting forth their position in regard to Idaho Power’s NEEA involvement. See Order No. 27124. The Industrial Customers, Staff and Idaho Power all filed testimony regarding the NEEA programs and the Commission considered this testimony in reaching its decision. Order No. 27200.
Utilities Division Staff also notes that to the extent the Commission wants to consider DSM programs outside the parameters of the Application, it must do so in a separate proceeding. Such consideration is outside the scope of the Application.
Commission Decision:
1. Does the Commission want to enter an order allowing all parties to file responses to the initial comments?
2. Does the Commission want to order the filing of direct testimony in anticipation of an evidentiary hearing to consider whether Idaho Power's continued participation in NEEA is appropriate?
3. Does the Commission want to order the filing of direct testimony in anticipation of an evidentiary hearing to consider some self-direction program for Schedule 19 and Special Contract customers?
4. Does the Commission want to open another docket to further evaluate NEEA programs and compare them to other DSM programs?
5. Does the Commission consider this case ready for decision as a fully submitted matter?

Cheri C. Copsey

Consumer Division Staff: Tonya Clark

Utilities Division Staff: Randy Lobb

M:ipce9913_cc2.doc

The Industrial Customers is an unincorporated association of some of Idaho Power's Schedule 19 customers. See Comments in Opposition and Request for Hearing of the Industrial Customers of Idaho Power at p. 1.

The NWEC is a coalition of approximately 90 organizations in Idaho, Washington, Oregon, Montana and British Columbia. In Idaho, its members include the Idaho Citizens Network, Idaho Rural Council, Idaho Conservation League, Idaho Consumer Affairs, Idaho Rivers United, Idaho Wildlife Federation, League of Women Voters, Southeastern Idaho Community Action Agency, South Central Community Action Agency and Golden Eagle Audubon Society. These groups represent over 50,000 consumers in Idaho. It is also on the NEEA Board. See NW Energy Coalition Comments at 1.

The NRDC is a non-profit environmental organization with approximately 2,000 members living in Idaho and purchasing power in Idaho. See NW Energy Coalition Comments at 1.

The Idaho Rural Council in a not-for-profit grassroots, community building organization with over 13 years working in Idaho. It has more than 500 members. See NW Energy Coalition Comments at 1.

Idaho Rivers United is a statewide organization dedicated to preserving and protecting Idaho’s rivers. It has more than 1,700 members and “virtually all of IRU’s members also live and purchase power in Idaho.” See NW Energy Coalition Comments at 2.
These comments were filed February 18, 2000, but Health and Welfare requested by letter dated March 9, 2000, that these comments be withdrawn.

This program provides services for impoverished elderly, disabled and families with young children who are at or below 133% of the Office of Management and Budget (OMB) poverty guidelines. The DOE funds received for weatherization statewide are disbursed locally, based on poverty figures from the 1990 Census. Funds expended through the Weatherization Program come from several sources, DOE ($1.2 million for 2000), Low-Income Home Energy Assistance Program (LIHEAP) automatic transfer of 15% ($965,702 in 2000), Bonneville Power Administration ($525,000 for 2000-2001), Petroleum Violation Escrow funds ($70,000 for 2000) and Utility investments. Idaho Power will contribute approximately $177,000 to Low-Income Weatherization and an additional $30,000 to weatherize non-profit buildings in 2000. This is a reduction of 33.5% from the original funding amount of $320,000. Idaho Power and DSM administrative funds were reduced in 1998 in a decision by the Public Utilities Commission (Order No. 27660); this resulted in the reduction of Idaho Power funds available for the Weatherization Program.

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