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Home My WebLink About20190207CAPAI Comments.pdfBrad M. Purdy Attomey at Law 2019 N. 17m St. Boise, ID 83702 Land: 208-384-1299 Cell: 208-484-9980 bmpurdy@hotmail.com ISB#:3472 Attomey for Community Action Partnership Association of Idaho IN THE MATTER OF THE ) APPLTCATTON OF ROCKY ) MOUNTAIN POWER FOR ) AUTHORITY TO DECREASE ) SCHEDULE 191 - CUSTOMER ) EFFICIENCY SERVICES RATE ) HICEIVED iui! f[B -7 P]l lr: Str ssrci{ BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. PAC-E.18.12 COMMENTS OF THE COMMUNITY ACTION PARTNERSIIIP ASSOCIATION OF IDAHO COMES NOW, the Community Action Partnership Association of Idaho ("CAPAI") and, in response to Order No. 34230 and Notice of Modified Procedure, issued by the Commission on January 17,2019, submits the following comments in response to Rocky Mountain Power's application seeking authorization to decrease the collection rate, under Schedule 191, applied to customer bills for energy effrciency measures, including Low Income Weatherization Assistance ("LIWA"). CAPAI recommends that the Commission deny Rocky Mountain's request to reduce, by 0.45o/o,the Company's Schedule 191 Customer Efficiency Services Rate. While CAPAI understands and generally supports the concept of avoiding an excessive amount of conservation funds collected in relation to expenditures incurred or expected to be incurred in the relatively near future, the Company's Application causes CAPAI concern, particularly with respect to the Low Income Weatherization Progranr, in terms of adequate funding should expenditures for 1COMMENTS OF CAPAI LIWA rise in the near future. CAPAI notes that in Order No.34224, Case No. PAC-E-I8-07, the Commission recommended additional actions to increase customer participation in all DSM programs, including LIWA. Id. at p. 6. l.rry such increased participation will, of course, require additional funding. CAPAI notes that it has had the opportunity to review the comments to be filed this day by the Idaho Conservation League ("ICL") and agrees with the entirety of those comments. As noted by ICL, Rocky Mountain is proposing a reduction in the rider amount while simultaneously agreeing to pursue more energy savings. In fact, 2017 expenditures were significantly less than expenditures estimated for the years 2018 and 2019. See, Order 34224, Case No. PAC-E-18-07. Thus, the Company proposes reducing funding at the same time it anticipates increasing expenditures. Furthermore, the 2019 IRP will be informative in an on-going perspective and that document will likely shed valuable light on the rate of collections over expenditures that better reflects future DSM investments and activities. Should circumstances and data at that time justiff a reduction in the Schedule 191 rider, then such a reduction could be made then without running the risk, in the interim, of lacking sufficient funding for low income DSM. In short, CAPAI recommends a multi-year time frame for truing-up expenditures and collections under Schedule 191. Conclusion CAPAI respectfully submits that Rocky Mountain's application should be denied and that the matter be resolved after the Company's 2019 Integrated Resource Planning process has been completed. CAPAI believes that the Commission's recommendations set forth in Order 34224 to enhance conservation efforts by, inter alia, increasing customer participation would best be 2COMMENTS OF CAPAI served by maintaining the current Schedule 191 charge until after the 2019 IRP process has been completed. DATED, this 7s day of February,2079 + Brad M. Purdy Attorney for CAPAI JCOMMENTS OF CAPAI CERTIFICATE OF SERVICE I certiff that on the 7m day of February, 2Ol9,I delivered a true and correct copy of the foregoing COMMENTS to the following persons via electronic mail (unless otherwise noted). Hand Delivery Diane Hanian Commission Secretary Idaho Public Utilities Commission 472W. Washington St. Boise, ID 83702 Electronic Mail Ted Weston Michael S. Snow Daniel E. Solander Ted.weston@pacifi corp. com Michael. snow@pacifi corp. com D aniel. so lander@pacifico rp. co m datarequest@,pacifi corp. com Idaho Public Utilities Commission Edward Jewell Deputy Attorney General Edward jewell@puc. idaho. gov P**e ?-"nfu Brad M. Purdy 4COMMENTS OF CAPAI