20100616Response to Rocky Mountain Power.pdf

Benjamin J. Otto
ISB No. 8292
710 N 6th Street
POBox 844
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservation.org
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IDAHO PU2L;",;
UTILITIES COMMISSION
Attorney for Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUNAIN POWER FOR AN
INCREASE TO TH CUSTOMER
EFFICIENCY SERVICES RATE
)
)
)
)
)
CASE NO. PAC -E-I0-03
IDAHO CONSERVATION LEAGUE'S RESPONSE TO ROCKY MOUNTAI POWER
COMES NOW Idaho Conservation League with the following REPONCE to Rocky
Mountain Power's Reply fied June 14, 2010. While outside of the normal order of events, ICL
is compelled to correct Rocky Mountain's misrepresentations of our comments.
1. Rocky Mountain asserts that, because ICL is concerned about the accumulated back balance,
we believe the Company "should not be allowed to recover, the costs associated with the
programs." Rocky Mountain Reply at 2. This is simply not tre.
ICL repeatedly supported the tariff rider concept as critical to providing timely cost
recovery, commended the Company for its DSM efforts, and acknowledged that program
paricipation exceeding forecasts was drving much of the increase. In regards to the
accumulated back balance, we argued the Commission should review whether the growing
balance and associated caring charge is a prudent use of ratepayer fuds. ICL argued the
RESPONSE OF ICL 1 June 16, 2010
Company had failed to justify recovering the back balance because their Application did not
explain why it had accumuiàted so quickly nor why carg a back balance was a prudent use of
fuds. Nor did their Application explain why the previous rate increase, intended in part to
reduce the back balance, did not do so. See Order No. 30543 at 1. Instead of imputing a false
contradiction onto ICL, if Rocky Mountain requires more money to captue all cost effective
energy efficiency opportities they should ask for, and justify, a larger increase.
2. Rocky Mountain claims ICL "erroneously argues that the costs associated with the irrgation
energy services progr are not 'legitimate'." Rocky Mountain Reply at 3. The Company then
refers to the Utilty Cost Test as proof the progr is cost effective. ¡d. However, the
Company's reply omits that the progr fails the Total Resource Cost test. See 2009 DSM
Report at 24.
ICL pointed to the results of the TRC test because it, unlike the UTC, includes both the
costs incured by the company and those incurred by progrm participants. See California
Stadard Practice Manual at 23. ICL believes the TRC results are importt because the
Company explained some of the rider fuds paid for "customer specific costs associated with
equipment investments that delivered operational effciencies in addition to energy effciency
benefits." Application at 1 0-11. As we explained in our Comments, the only costs ICL believes
may not be a proper use ofDSM rider fuds are those that deliver operational effciencies to
specific customers beyond energy effciency benefits. It is not erroneous to argue that energy
effciency fuds should only pay for energy effciency benefits.
3. ICL is bafted that Rocky Mountain "is unable to find any statement that would lead it to
RESPONSE OF ICL 2 June 16,2010
believe that 'the Commission has previously explained that before granting any adjustment to
the DSM tariff,' they will determine the prudence of progrm spending." Rocky Mountain
Reply at 3. Contrar to the Company's claim, ICL did not "misrepresent the intent of the
Commission Order" No. 29976. ¡d. In fact, ICL directly quoted this Order, which states
The Commission wil examine the distrbution ofDSM program dollars both within and
among customer classes, the cost effectiveness of the programs and the reasonableness
and prudence of the Company's program management and administrtive costs durng
general rate cases and in all proceedings proposing an adjustment to the DSM taff rider.
Order No 29976, at 7 (emphasis added).
In closing, ICL wholehearedly supports the DSM taff rider as an importt tool to
provide timely cost recovery of program expenses. ICL merely urges the Commission to utilze
the review procedure it anounced when originally approving the DSM rider. In our prior
comments we highlighted some of the issues we believe the Commission should consider when
conducting this review. While unortodox, ICL submits these reply comments because we feel
compelled to correct Rocky Mountains distortions of our position.
Respetfuly submittd t1s 16'" day ofJune 2010. ~.
~S6-Benjailo
Idaho Conservation League
RESPONSE OF ICL 3 June 16,2010
CERTIFICATE OF SERVICE
I hereby certify that on this 16th day of June, 2010, tre and correct copies of the
foregoing IDAHO CONSERVATION LEAGUE'S RESPONCE were delivered to the following
persons via the method of service noted:
Hand delivery:
Jean Jewell
Commission Secreta (Orginal and seven copies provided)
Idaho Public Utilties Commission
427 W. Washington St.
Boise, ID 83702-5983
ELECTRONIC MAL ONLY:
Daniel Solander
Senior Counsel
201 South Main, Suite 2300
Salt Lake City, UT 84111
Telephone: [phone]
Facsimile: [phone]
E-mail: Daniei.Solander~PacifiCorp.com
Ted Weston
Idao Regulatory Affairs Manager
201 South Main, Suite 2300
Salt Lake City, UT 84111
Telephone: (801) 220~2963
Facsimile: [phone]
E-mail: ted.weston~PacifiCorp.com
Eric L Olsen
Racine Olson Nye Budge & BailyP.O. Box 13691 .
Pocatello, il 83204-1391
elo~racinelaw .net
Anthony Yankel
29814 Lake Road
Bay Vilage, OH 44140
tony~yankei.net
!Aáb
Benjamin J. Oto
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RESPONSE OF ICL 4 June 16, 2010