20080425NWEC Comments.pdf

NW Energy Coaliti
for a dean and affordable ønørgy future
April 24, 2008
Jean Jewell
Commission Secretar
Idaho Public Utilties Commission
472 West Washington
Boise, ID 83702
m
Docket No. PAC-E-08-01
Ms. Jewell:
Please accept the following comments of the NW Energy Coalition on the
application of Rocky Mountain Power (RMP) for an increase to the customer
efficiency services rate adjustment and proposed changes to the Company's energy
effciency programs.
The NW Energy Coalition supports the RMP fiing and urges the Commission to
approve the tariff increase and programatic enhancements with some
recommendations.
Tariff Increase
The 2.2 percent proposed increase in the rider may seem dramatic yet in our view it
reflects the latent opportunity to acquire energy savings. RMP has been under
fuding and under achieving energy savings and the time is ripe for a signficant
expansion of effort. Last year PacifiCorp released a comprehensive Demand Side
Management assessment for its entire service terrtory. This assessment estimated
achievable efficiency potential at 440 aMW of effciency potential in three RMP
states over 20 years. RMP states in its fiing that it "hopes to achieve 13,140
MWh/year in energy savings", this modest level of savings is not possible without
an increase in funding. That said, according to the Southwest Energy Efficiency
Projectl, the DSM assessment significantly under estimates the cost-effective
effciency opportunties available throughout all PacifiCorp's service territories.
i Comments on PacifiCorp's DSM Potential Study, Howard Geller, SWEEP,
August 24, 2007
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Salem: (503) 851-454. (53)390287
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Now is a vital time for RMP to ramp up its efficiency services and enhance program offerings.
Rising energy prices and power plant constrction costs make DSM programs even more cost
effective and increase consumer interest in adopting these measures. The tarff increase is
necessar to faciltate more extensive delivery of a broader aray of efficiency programs that will
help Rocky Mountain Power customers reduce their electricity bils. Previous fuding levels were
insufficient. There is nothing more frstrating to customers than seeing a promotion for a program
and then being told that there is no longer adequate fuding or there is a waiting list contingent
upon future funding. This program delivery history can make ramping up and instiling customer
confidence a challenge. The State of Idaho clearly recognzed the opportnity for efficiency in
meeting Idahoan's energy needs in the 2007 State Energy Plan and with the elevation of energy
policy within state governent with the establishment of the Office of Energy Resources. Inaddition, growing concern about global waring, energy stabilty and new power plant proposals
have raised public awareness of and interest in cost saving energy effciency.
While the fuding increase is waranted it is a concern to see 50% of the two year fuding goingto purchase and maintain load control equipment for irrigation customers and no programatic
increase in a number of programs. Capacity savings are importt and should be pursued and
should be acquired in addition to captung all cost-effective efficiency savings. Given the
comments of SWEEP and the low level of historic DSM activity in the RMP Idaho service
terrtory, the opportunty for higher energy savings levels is great.
The Coalition is concerned that there is no proposed increase in support for the low-income
weatherization program. Given rising energy costs in general and even the modest increase in
bils due to this tarff increase, it is good policy, at a minimum, to include a proportional increase
in low-income weatherization fuding.
In Attchment 3 of the Company's application the 2009 budget is shown as $4,529,244 and the
2008 budget is shown as 4,825,061. It is not clear why there is a $295,817 decrease in the budget
for 2009 if the rider remains unchanged unless the Company projects a decline in customers.
Program Enhancements
As par of its approval of these new and expanded programs and increased funding, the
Commission should make it clear that it will judge utilty performance not on the expenditue of
fuds but on the savings acquired. The Coalition is pleased to see program evaluation built into the
program budget. The Commission should ensure that the evaluation and verification of program
savings and effectiveness are done by 3rd pary evaluators and reported to the Commission.
To tap into customer wilingness to undertake cost-effective energy effciency measures and
actions, RMP must market and promote its programs in a simple and compellng maner.
Coalition alles in Utah support RMP's FinAswer program but urged more aggressive marketing
of this program as it is rolled out in Idaho..
While RMP provided information on programatic changes to Schedule 118, Home Energy
Savings, as an informational service to the Commission, I believe that RMP should expand this
offering to include more incentives and education around a growing element of residential and
commercial usage - plug loads. RMP should educate its residential and commercial customers to
make them aware of plug load draw, to purchase lower power devices and how to use power
management features. RMP should paricipate in national marketing and incentive programs such
as the 80+ power supply program, ENERGY STAR PCs, monitors, TVs, TV signal converter
boxes, battery chargers, and other ENERGY STAR electronic products. Electronic devices are
evolving quickly and consumers make changes and upgrades on a similar pace. As a result, there
will be many opportities for cost-effective energy savings in the future and many ways for RMP
to help customers capture these savings.
Than you for your consideration of these comments. I am happy to paricipate fuher with the
Commission in the ongoing review of implementation of these programs.
Sincerely,
Nancy Hirsh
Policy Director
nancy~nwenergy.org
206-621-0094