20190207ICL Comments.pdf

Benjamin J. Otto (lSB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
PAC-E-18-12
ICL COMMENTS
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Attomey for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUTAIN POWER FOR
AUTHORITY TO DECREASE
SCHEDULE 191 _ CUSTOMER
EFFICIENCY SERVICES RATE
CASE NO. PAC-E-18.12
IDAHO CONSERVATION LEAGUE
COMMENTS
The Idaho Conservation League (ICL) recommends the Commission defer Rocky
Mountain Power's request to decrease the Schedule 191 Customer Efficiency Services Rate by
0.45%.Instead, ICL recommends the Commission reassess the appropriate funding level after
the conclusion of the 2019lntegrated Resourced Plan process. We support establishing multiyear
plans for Demand Side Management (DSM) targets, programs, and funding levels based on the
results of the most recent IRP analysis. ICL acknowledges the Schedule 191 balancing account
shows revenues slightly exceed expenses. However, as explained below, Rocky Mountain's
analysis shows increasing DSM targets going forward, while the PUC Staff and Commission
recommend Rocky Mountain increase efforts to expand participation in cost effective programs.
Instead of adjusting the Schedule 191 rider now, ICL recommends deferring any until the results
of the IRP provide an updated basis to establish a multiyear plan for programs and expenses.
Increasing Future DSM Targets
ICL supports Rocky Mountains goal "to better align revenue collections with demand-
side management ("DSM") expenditures while gradually reducing the current over-collected
balance associated with acquiring and administering DSM programs in Idaho." Application at I
ICL generally supports using a multiyear timeframe to align DSM expenditures and revenues.
Our concern is that Rocky Mountain's forecast calls for increasing levels of DSM achievement
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I February 7,2079
while forecasted DSM budgets remain flat. In 2077, Rocky Mountain acquired 17,514 mwh of
savings and spent $4.0 million. Order No 34224 a/ 5. Rocky Mountain's targets for 2018 and
2019 are22,950 MWh and 23,060 Mwh respectively. 2017 IRP Appendix D, Table D.4, pg 67.
This level of savings is more akin to 2016 where Rocky Mountain acquired 21,551 Mwh and
spent $4.5 million. Order No 34224 at 5.ICL recommends the Commission maintain current the
current Schedule 191 level in order to ensure adequate funding to acquire these company-
identified targets for achievable, cost effective DSM.
Increasing Customer Participation
While reviewing the prudency of Rocky Mountain's 2016-2017 DSM programs the Idaho
PUC Staff and Commission recommended additional actions to increase customer participation.
Order No 34224.ICL recommends the Commission maintain the current Schedule 191 level to
show support for these recommendations. The Idaho PUC Staff lauded Rocky Mountain's
increased marketing efforts "aimed at reaching different populations on a variety of platforms".
Staff Comments at 7, PAC-E-L8-07. The Commission encouraged Rocky Mountain's efforts to
serve small businesses in Idaho's rural communities. Order No 34224 at 5. As a portfolio, the
DSM programs delivered more than 2 times the utility benefits over the costs. Id at 5. Rocky
Mountain's annual DSM reports show each program was cost effective for the utility and all
customers, including the low-income weatherization program. Id at 6.
Based on this success, the Commission directed Rocky Mountain to consider the
recommendations of the low-income program evaluator in order to increase the participation
levels and further improve this cost effective program. Id at 6.In particular, the evaluator
recommended Rocky Mountain invest in assisting the local CAP agencies to better identifu and
target electric only homes in order to decrease costs and increase savings.l And the evaluator
reported while the program does not offer formal energy education energy education,
participants found the information provided extremely helpful. ICL recommends the
Commission encourage Rocky Mountain to increase the energy education funding above the
' Opinion Dynamics, PacifiCorp ldaho Low Income Weatherization Program Evaluationfor
Program Years 213-2015 at page 5 - 6, September 11,2017. Available at:
http://www.pacificorp.com/contentldamlpacificorp/doc/Energy_Sources/Demand_Side_Manage
mentl 20 I 7 lPacifi Corp_I daho LI WP Evaluation_Report_FlNAl.pdf
PAC-E-18-12
ICL COMMENTS 2 February 1,2019
current $25,000 annual amount.
ICL strongly supports these additional investments to expand participation across all
program areas. We recommend the Commission maintain the current Schedule 191 level to
ensure adequate funding for these directives.
Conclusion
ICL shares the goal of aligning DSM expenses and revenues over multiple years. Here
Rocky Mountain Power proposes a minor change to the Schedule 191 rate that amounts to about
$5 per residential customer per year. Application at 4. Meanwhile the Company, PUC Staff, and
Commission have identified increased DSM activities and expenses in the future years. We
continue to agree with the Commission:
"Effective DSM programs delay the need for higher cost generation resources. It is
precisely for this reason that we strongly support the use of demand-side management
programs. Authorizing Rocky Mountain to recover the costs of its DSM programs
through the Schedule l9l tariff offers a necessary incentive that merely reimburses the
Company for the actual costs. In doing so, the Commission reiterates our previous
finding that DSM cost-recovery is fair, just and reasonable because it creates an
environment wherein "all customers benefit from deferring the cost of having to acquire
new supply-side resources." Order No 33491 at 5-6.
After reviewing the forecasts of future needs, ICL recommends the Commission maintain
the current Schedule 191 level and establish a multiyear plan for DSM program needs after the
conclusion of the 20l9IRP process.
Respectfully submitted this 7th day of February 2019,
Benjamin J. Otto
Idaho Conservation League
PAC-E-18-12
ICL COMMENTS aJ February 7,2019
CERTIFICATE OF SERVICE
I certify that on the 7th day of February 2019, I delivered true and correct copies of the
foregoing COMMENTS to the following persons via the method noted:,4+-
Benjamin J. Otto
Idaho Conservation League
Hand delivery:
Diane Hanian
Commission Secretary (Original and 7 copies)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail
Idaho Public Utilities Commission
Edward Jewell
Deputy Attorney General
Edward j [e-mail]. gov
PacifiCorp
Ted Weston
Michael S. Snow
Daniel E. Solander
ted.weston@pacifi corp.com
micheal. snow@pacifi corp.com
daniel. solander@pacific orp. com
datarequest@pacifcorp. com
PAC-E-18-12
CERTIFICATE OF SERVICE 4 February 7,2019