20240709IPC to Staff 43-48.pdf

0IQAHO Ro
MEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaallen(a)_idahopower.com RECEIVED
2024 July 9, 1:43PM
IDAHO PUBLIC
July 9, 2024 UTILITIES COMMISSION
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-24-11
In the Matter of the Application of Idaho Power Company for a Determination
of 2023 Demand-Side Management Expenses as Prudently Incurred
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Response to the Fourth
Production Request of the Commission Staff in the above-entitled matter.
Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the attachments
to these requests to the secure FTP site to allow parties to view the requested information
remotely unless otherwise noted in the response. Because certain attachments contain
confidential information, the FTP site is divided between confidential and non-confidential
information.
The login information for the non-confidential portion of the FTP site has been provided to
all parties that have intervened to date. The login information for the confidential portion of
the FTP site has been provided the parties that have executed the Protective Agreement in
this matter.
If you have any questions about the attached filing, please do not hesitate to contact
me.
Sincerely,
Megan Goicoechea Allen
MGA:cd
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Application of Idaho Power Company for Determination of 2023 Demand-Side
Management Expenses as Prudently Incurred
Case No. IPC-E-24-11
The undersigned attorney, in accordance with Commission Rule of Procedure 67,
believes that the attachments provided in Attachments to Production Request No. 45 in
Idaho Power Company's Response to the Fourth Production Request of the Commission
Staff dated July 9, 2024, may contain information that Idaho Power Company and a third
party claims constitutes trade secrets and/or confidential business records of a private
enterprise required by law to be submitted to or inspected by a public agency as described
in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected from
public disclosure and exempt from public inspection, examination, or copying.
DATED this 9t" day of July, 2024.
?I fA�CI UyJUU�L
Megan Goicoechea Allen
Counsel for Idaho Power Company
CERTIFICATE OF ATTORNEY- 1

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
mgoicoecheaallenCa�,idahopower.com
InordstromCa)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-24-11
DETERMINATION OF 2023 DEMAND-SIDE )
MANAGEMENT EXPENSES AS ) IDAHO POWER COMPANY'S
PRUDENTLY INCURRED. ) RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Fourth Production Request of the Commission Staff ("Commission" or
"Staff") to Idaho Power Company dated June 25, 2024, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1

STAFF REQUEST FOR PRODUCTION NO. 43: In response to Production
Request No. 17, the Company describes that the new Small Business Direct Install
("SBDI") program will be marketed in stages. Please describe these stages and how they
are expected to reach customers that the original round of SBDI may have also marketed
to.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 43:
The SBDI program is being replaced by the Small Business Lighting Program
("SBL"). The SBL will be marketed to customers by sending direct mail letters in batches,
as the workloads of participating contractors allow. In addition, the company will stage the
mailings to match the level of customer interest. For example, if a mailing results in a lot
of customer interest, the timing of the next mailing may be modified to enable participating
contractors to service the interested customers in a timely manner. The Company will not
market SBL to past participants of the SBDI program, but it does intend to market SBL to
customers who received a previous letter inviting them to participate in the SBDI program,
but who chose not to participate at that time.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2

STAFF REQUEST FOR PRODUCTION NO. 44: In its 2022 Demand-Side
Management Annual Report on page 66, the Company stated that it will determine
modifications to the smart thermostat measure in 2023. Please describe any changes
that the Company has considered and/or implemented for this measure in 2023 or 2024
program years.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 44:
Idaho Power has considered and implemented several modifications to the
Heating & Cooling Efficiency ("HCE") Program's smart thermostat offering since 2022.
Idaho Power relies on workpapers compiled by the Regional Technical Forum ("RTF") to
calculate energy savings for a number of its measures, including the smart thermostat
measure. At the August 11, 2022, Energy Efficiency Advisory Group ("EEAG") meeting,
the Company shared that the RTF had updated their savings assumptions for smart
thermostats based on recent research and evaluations completed within the region.
Compared to RTF's previous smart thermostat workbook, the new savings assumptions
showed an annual decrease in savings per unit of over 60 percent on average.
Additionally, the newest RTF workbook included a new combination: smart thermostats
installed on air-source heat pumps with resistance heat optimization. This new
combination provides the highest potential savings. Because most new air-source heat
pumps include a smart thermostat and are installed with resistance heat optimization, the
savings associated with these installations offset the overall decrease in smart thermostat
savings.
Idaho Power considered several potential modifications to keep the measure cost
effective given the updated savings assumptions. The first option considered, and
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3

ultimately selected, was lowering the overall smart thermostat incentive. The Company
also considered providing a lower incentive amount for units that were not directly
installed by a contractor, or even removing the incentive's self-install option completely.
Another option considered was limiting the incentive to only smart thermostats installed
on resistance-optimized air source heat pump systems and combining it with the existing
heat pump measure. With most residential programs limited to customers with electric
heat only, Idaho Power was reluctant to add another barrier to participation for residential
customers. The Company weighed cost-effectiveness with maximizing potential savings,
ease of implementation, and customer satisfaction when deciding on the potential change
to the program.
In the 2023 Integrated Resource Plan ("IRP"), the DSM avoided cost values see a
higher value in winter months than in prior IRPs. In the August 17, 2023, and November
8, 2023, EEAG meetings, Idaho Power shared that because smart thermostats provide
the most savings during the winter months, the benefit value would increase with the
application of the 2023 IRP avoided costs when compared to the 2021 IRP avoided costs.
This shift in the winter value changed how the Company planned to adjust the offering
and while a change was still necessary due to the lower savings, the Company
determined that lowering the incentive to $50 would keep the measure cost-effective
under all combinations and would allow for maximum number of customers to participate
in the offering. This change went into effect November 1, 2023.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF -4

STAFF REQUEST FOR PRODUCTION NO. 45: Please provide a sortable list of
the 95 Custom Projects and 17 Green Motors Initiative — Industrial projects assigned to
the Commercial and Industrial Energy Efficiency ("EE") program.
a. For each project, please include the project name, a brief project description, the
project completion date, the incentive amount paid, and the estimated annual
kilowatt-hours ("kWh") saved;
b. Please reconcile the list to ensure that the total annual kWh saved equals the
values provided in Table 21 of the Annual Report. If the totals do not match, please
explain why; and
c. For the five projects with the largest annual kWh savings, please provide the
incentive approval letter and associated reports, analysis, or documentation
supporting the energy-saving actions that contributed to the savings. Include the
kWh saved by each action.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 45:
a. Please see the confidential attachments 1 and 2 provided for this response.
Confidential attachment 1 shows all 95 projects in the first tab and the five largest
in the second tab.
b. The total annual kWh saved, shown in the attachments 1 and 2 provided for this
response, equal the values provided in Table 21 of the Annual Report.
c. Please see confidential attachments 3 through 7 provided for this response.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5

STAFF REQUEST FOR PRODUCTION NO. 46: The Company's response to
Production Request No. 3 shows that each EE program has a distinctive load shape that
affects that program's avoided cost. Please explain how the load shapes are determined
for each EE program measure. Also, please explain the basis for the load shape of the
Custom Project program given the wide diversity of EE actions included in that program.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 46:
Most of the measure load shapes come directly from the Regional Technical
Forum's ("RTF") Load and Savings Shapes file and for non-RTF measures, Idaho Power
will attempt to match the savings to a load shape. The 8,760 hourly data is then converted
into Idaho Power's summer and non-summer hourly buckets (as informed by the
applicable IRP). For the commercial programs, a general load shape is used for each
measure category rather than an industry specific load shape. For instance, a general
commercial lighting load shape is used for all lighting savings versus the lighting load
shape specific to groceries, schools, restaurants, or small and large offices. An exception
to this approach was used in the Commercial Energy-Savings Kits offering in which
industry specific load shapes were used for the items in the kits. For both Retrofits and
New Constructions, the programs' load shapes were weighted based on the various end
uses incented on in 2023.
For Custom Projects, most load and associated savings are relatively flat, so a
general Industrial load shape is used for the whole program. There are a few things to
note. When looking at the 2021 avoided costs, the avoided costs are fairly similar across
all of the time blocks with the exception of the Summer On-Peak, and accordingly,
anything with significantly more or less savings during the Summer On-Peak will have the
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6

greatest impact on cost-effectiveness. When compared to the 2023 program load shapes
for Retrofits and New Construction, which were weighted by measure, the Custom Project
program's load shape is fairly similar with a slightly lower Summer On-Peak percentage.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7

STAFF REQUEST FOR PRODUCTION NO. 47: In its response to Production
Request No. 10, the Company confirmed that it will remove transformer core losses from
the line loss adjustment in future analyses. Please provide the approximate percent value
for transformer core losses that should have been removed from the overall line loss
adjustment.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 47:
For program year 2023, the 2021 IRP was the source of all financial assumptions
and accordingly, a 9.6 percent annual loss coefficient and a 9.7 percent peak loss
coefficient were based on the 2012 Line Loss Study (the most recently completed study
at the time the 2021 IRP was prepared). While the 2012 Line Loss Study did not report a
specific number for the transformer core losses, based on information in the study, the
Company estimates that the transformer core loss would have adjusted the annual loss
coefficient by 0.024 and the peak loss coefficient by 0.017, as shown in the table below.
Annual Peak
Loss Coefficient Loss Coefficient
2012 Loss Study 1 .096 1.097
Transformer Core Losses Removed 1 .072 1.080
Difference 0.024 0.017
A copy of the energy efficiency cost-effectiveness workpapers was submitted as
an attachment to Staff Production Request No. 3. An updated attachment has been
provided with this response with the updated line loss percentages. While the cost-
effectiveness ratios for the programs and sectors decreased slightly with the updated line
loss coefficients, all programs that were previously identified as being cost-effective from
the Utility Cost Test perspective would remain cost-effective.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8

Of note the Company completed an updated Line Loss Study in 2023 for use in
the 2023 IRP and in that study, transformer core losses are separately reported. For
program year 2024, the Company will utilize the 2023 Line Loss Study and will remove
transformer core losses from the avoided losses when determining cost-effectiveness.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9

STAFF REQUEST FOR PRODUCTION NO. 48: Please provide copies of all
contracts valid for the 2023 DSM year and all invoices paid with any charges booked to
the DSM Rider during 2023 for ADM Associates and Applied Energy Group.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 48:
Please see the attachment 1 provided for this response for a list of invoices paid
with charges booked to the DSM Rider during 2023 for ADM Associates and Applied
Energy Group. See attachments 2 through 10 for invoices and see attachments 11
through 14 for contracts.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
Respectfully submitted this 9th day of July 2024.
Ay�r T I,W 6
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 9th day of July 2024, 1 served a true and correct
copy of the foregoing Idaho Power Company's Response to the Fourth Production
Request of the Commission Staff upon the following named parties by the method
indicated below, and addressed to the following:
Adam Triplett Hand Delivered
Deputy Attorneys General U.S. Mail
Idaho Public Utilities Commission Overnight Mail
P.O. Box 83720 FAX
Boise, ID 83720-0074 X Email
adam.triplett(a),puc.idaho.gov
Ed Jewell Hand Delivered
City of Boise City U.S. Mail
150 N. Capitol Blvd. Overnight Mail
P.O. Box 500 FAX
Boise, Idaho 83701-0500 X Email
BoiseCityAttorney(a)_cityofboise.org
ejewell cityofboise.org
Steven Hubble Hand Delivered
Boise City Dept. of Public Works U.S. Mail
150 N. Capitol Blvd. Overnight Mail
P.O. Box 500 FAX
Boise, Idaho 83701-0500 X Email
shubble cityofboise.org
Matthew Nykiel Hand Delivered
Attorney for Idaho Conservation League U.S. Mail
710 N. 6t" St. Overnight Mail
Boise, ID 83702 FAX
X Email
matthew.nykielC@.gmail.com
Brad Heusinkveld Hand Delivered
Idaho Conservation League U.S. Mail
710 N. 6th St. Overnight Mail
Boise, Idaho 83702 FAX
X Email
bheusinkveld(a)_idahoconservation.org
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11

F. Diego Rivas Hand Delivered
NW Energy Coalition U.S. Mail
1101 8th Ave Overnight Mail
Helena, MT 59601 FAX
X Email
diego nwenergy.org
Ken Robinette Hand Delivered
South Central Community Action U.S. Mail
Partnership Overnight Mail
550 Washington Street South FAX
Twin Falls, ID 83303 X Email
ken _sccap-id.org
a4lw
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12