20240910Direct Testimony of Nesbitt.pdf

RECEIVED
Tuesday, September 10, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-24-35
AUTHORITY TO FUND ITS CONTINUED )
PARTICIPATION IN THE NORTHWEST )
ENERGY EFFICIENCY ALLIANCE IN )
2025-2029 THROUGH THE ENERGY )
EFFICIENCY RIDER. )
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
QUENTIN NESBITT

1 Q. Please state your name, business address, and
2 present position with Idaho Power Company ("Idaho Power" or
3 "Company") .
4 A. My name is Quentin Nesbitt. My business
5 address is 1221 West Idaho Street, Boise, Idaho 83702 . I am
6 employed by Idaho Power as the Customer Relations and
7 Program Manager in the Customer Operations Department.
8 Q. Please describe your educational background.
9 A. I earned a Bachelor of Science degree in
10 Agricultural Engineering from the University of Idaho in
11 1989 and received my Professional Engineering license in
12 1992 .
13 Q. Please describe your work experience with
14 Idaho Power.
15 A. I began my employment with Idaho Power in
16 1991 as an Agricultural Representative in the Company' s
17 Energy Management Department where I was responsible for
18 providing customer service to irrigation and agricultural
19 customers . Later in 1991, I was promoted to an engineering
20 position where I provided technical support for Idaho Power
21 Agricultural Representatives . This involved Demand Side
22 Management ("DSM") program design and operation, pump
23 testing, new service requests, investigation of high bills,
24 and irrigation system evaluation and consultation. In 2002,
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1 the Department was reorganized as the Customer Relations
2 Department, and I took on additional duties as the
3 Agricultural Customer Segment Advocate/Expert where I
4 coordinated Company activities that affected agricultural
5 customers . In October of 2014, I was promoted to Energy
6 Efficiency Program Leader and was responsible for
7 overseeing the Company' s Commercial and Industrial and
8 Irrigation DSM programs . In June of 2020, I became the
9 Customer Research and Analysis Leader and was responsible
10 for overseeing the Company' s analysis and reporting of all
11 DSM programs . In December of 2023, I was promoted to my
12 current position as Customer Relations and Program Manager.
13 Q. What is the purpose of your testimony in
14 this matter?
15 A. The purpose of my testimony is to describe:
16 (1) Idaho Power' s involvement with the Northwest Energy
17 Efficiency Alliance ("NEEA") , (2) how the Company evaluated
18 the cost effectiveness of participating in NEEA, (3) the
19 2025-2029 NEEA business cycle ("Cycle 7") , and (4) the
20 Company' s stakeholder engagement leading up to its decision
21 to contract to participate in Cycle 7 .
22 Q. Are you sponsoring any exhibits?
23 A. Yes . I am sponsoring the following exhibits :
24 • Exhibit No . 1 - NEEA EM&V Report
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Idaho Power Company

1 • Exhibit No . 2 - NEEA EM&V Report Addendum
2 • Exhibit No . 3 - NEEA 2023 Annual Savings Report
3 - Idaho Power
4 • Exhibit No . 4 - NEEA Operational Guidelines for
5 Estimating Cost Effectiveness
6 • Exhibit No . 5 - 2024-04 Idaho Power NEEA
7 Presentation to Idaho PUC Staff
8 • Exhibit No . 6 - 2024-05 Idaho Power NEEA
9 Presentation with Avista to Idaho PUC Staff
10 Q. What is Idaho Power' s request in this case?
11 A. Idaho Power requests authority to use the
12 Idaho Energy Efficiency Rider ("Rider") to fund the
13 Company' s continued participation in NEEA.
14 I . IDAHO POWER' S INVOLVEMENT WITH NEEA
15 Q. What is NEEA?
16 A. NEEA is a non-profit organization whose
17 purpose is to maximize energy efficiency in the Northwest
18 via the acceleration and adoption of energy efficient
19 products, services, and practices through market
20 transformation. NEEA is funded by several Northwest
21 utilities, l the Energy Trust of Oregon ("ETO") , and the
1 Funding utilities include Avista, Cascade Natural Gas, Chelan County
Public Utility District ("PUD") , Clark Public Utilities, Idaho Power,
Northwestern Energy, Northwest Natural, Pacific Power, Portland General
Electric, Puget Sound Energy, Seattle City Light, Snohomish PUD, and
Tacoma Power. Additional funders can be found at:
https://neea.org/about-neea under "With Further Support From".
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1 Bonneville Power Administration ("BPA") . This strategic
2 alliance is built around recognition that greater market
3 transformation can be achieved across Washington, Oregon,
4 Montana, and Idaho by working together rather than by
5 working as individual organizations . NEEA was established
6 in 1997, and Idaho Power has funded NEEA since the
7 organization' s inception.
8 Q. Besides providing financial support, how
9 else has the Company supported NEEA' s efforts?
10 A. The Company participates in NEEA' s
11 initiatives and coalitions, including the Commercial
12 Building Stock Assessment ("CBSA") Residential Building
13 Stock Assessment ("RBSA") and the Advanced Heat Pump
14 Coalition (`Coalition") . For both the CBSA and RBSA, Idaho
15 Power has participated in monthly work group meetings to
16 discuss and provide feedback on each studies' objectives,
17 frameworks, sampling designs, billing analysis plans, and
18 communication plans . For the Coalition, Idaho Power attends
19 regular meetings and provides input and guidance.
20 Idaho Power representatives have also provided input
21 and support by participating in the Regional Portfolio
22 Advisory Committee, Cost-Effectiveness and Evaluation
23 Advisory Committee ("CEAC") , Regional Emerging Technology
24 Advisory Committee, the Idaho Energy Code Collaborative,
25 Integrated Systems Coordinating Committee, Products
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1 Coordinating Committee, and numerous working groups . I
2 currently serve on the NEEA Board of Directors and the
3 Company has had representation on the NEEA Board of
4 Directors since 1997 when NEEA began.
5 Q. What benefits do the Company' s customers
6 receive from its participation in NEEA?
7 A. NEEA provides pooled resources, market
8 research, and market engagement in participating states,
9 creating a greater likelihood that market change will be
10 regional, on a scale that manufacturers are more likely to
11 respond to, but which Idaho Power could not achieve on its
12 own. Further, the Company' s participation creates the
13 potential to allow it to influence the direction of NEEA' s
14 activities in a way that brings benefits to its customers .
15 Since Idaho Power began participating in NEEA in
16 1997 through 2023, NEEA and the Northwest utilities have
17 delivered 959 average megawatts ("aMW") of co-created
18 electric savings2 to the region as shown in Chart 1 below. 3
19 In 2023 alone, NEEA estimates that the alliance and local
20 utilities delivered almost 39 aMW of co-created energy
21 savings, approximately 78 percent of which are the result
22 of investments made during previous business cycles .
2 Co-Created (or shared) energy savings include all savings above the
baseline that occur in the market due to the combined efforts of NEEA
and its partners.
3 Chart reproduced from NEEA 2023 Annual Report. Available at:
https://neea.org/annual-report/2023
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1 Chart 1 . Additive* Co-Created Savings (aMW) : 1997-2023
959 aMW
Cycle 1&2(1997-2004,
. Cycle 3(2005-2009)
Cycle 4(2010-2014)
Cycle 5
Cycle 6(2020-2023)
— _ M
M7 1996 1999 2000 2001 2002 2003 20W 2005 2006 2007 2009 2009 2010 2011 2012 2013 2014 2015 2016 2017 2016 2019 2020 2021 2022 M3
2 * Additive energy savings are defined as the sum of new
3 first year savings occurring each year across multiple
4 years.
5 Idaho Power' s allocated portion of cumulative NEEA
6 Net Market Effects energy savings over this same time
7 period (1997 through 2023) was 471, 777 megawatt hours
8 ("MWh") or 53 . 86 aMW. Net Market Effects are savings
9 associated with market change and not counted as locally
10 incented savings or baseline savings . See Attachment 1 to
11 the Application for savings allocation by year.
12 II . INDEPENDENT EVALUATIONS, MEASUREMENTS & VERIFICATION
13 ("EM&V") REPORT
14 Q. Please explain why the Company pursued the
15 completion of an EM&V Report of NEEA.
16 A. In Case No. IPC-E-21-04 Idaho Public
17 Utilities Commission ("Commission") Staff ("Staff") raised
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1 concerns that NEEA claims savings it is not directly
2 responsible for producing. To address its concerns and
3 support the continued funding of NEEA, Staff recommended an
4 independent EM&V be conducted to: " (1) clarify the savings
5 NEEA claims; (2) the allocation of those savings to its
6 member utilities : and (3) the cost-effectiveness of those
7 savings to the member utilities based on the utilities' DSM
8 avoided cost . "4
9 In Order No . 35270, the Commission noted Staff' s
10 concerns and directed the Company to address the items
11 raised by Staff and verify the accuracy of NEEA' s claimed
12 savings through an independent EM&V. The Commission further
13 directed the Company, to the extent possible, to work with
14 other Idaho electric utilities that are conducting similar
15 EM&V reports .5 Similarly, in Order No. 35129 in Avista' s6
16 prudence case, AVU-E-20-13, the Commission directed it to
17 conduct an EM&V for NEEA.?
18 Based on the Commission' s directive, Idaho Power and
19 Avista collaborated to examine NEEA claimed savings, hiring
20 a single evaluator, ADM Associates Inc. ("ADM" or
21 "Evaluator") , to complete a single EM&V on behalf of both
4 In the Matter of Idaho Power Company's Application for a Determination
of 2020 Demand-Side Management Expenses as Prudently Incurred, Case No.
IPC-E-21-04, Staff Comments at 10 (Aug. 2, 2021) .
5 Id. , Order No. 35270 at 9 (Dec. 27, 2021) .
6 Avista Corporation dba Avista Utilities.
' In the Matter of Avista's Applications for a Prudency Determination
for its 2018-2019 Electric and Gas Energy Efficiency Expenditures, AVU-
E-20-13, Order No. 35129 at 9 (Aug. 13, 2021) .
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1 utilities and prepare a report with its findings . The
2 resulting EM&V Report was completed in April 2023 and is
3 provided as Exhibit No . 1 to my testimony.
4 Q. What did the Evaluator determine regarding
5 Idaho Power' s participation in NEEA?
6 A. The Evaluator found that Idaho Power' s
7 participation in NEEA is cost effective. More specifically,
8 it found that during the 2017-2021 program years the
9 Company' s Idaho customers received $73 . 2 million in
10 benefits from NEEA activity at a cost of $12 . 9 million.
11 This yielded an overall cost effectiveness of 5 . 68 from a
12 Utility Cost Test ("UCT") perspective. However, the
13 Evaluator also found that the savings are heavily reliant
14 on code efforts, and it is likely that code savings are
15 overestimated. This is because NEEA claims 100 percent
16 influence on all construction within a 10-year period after
17 any code changes go into effect within the region, without
18 consideration of a naturally occurring baseline .
19 Q. Did the Evaluator make any recommendations
20 based on its findings?
21 A. Yes . Please refer to the table on pages 12-
22 16 of Exhibit No . 2 to my testimony for a comprehensive
23 list of the Evaluator' s 18 findings and nine
24 recommendations . The recommendations included changing to a
25 service territory savings allocation methodology,
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1 completing influence evaluations to verify savings
2 associated with federal standards, completing evaluations
3 for code updates to quantify NEEA' s influence, updating how
4 annual savings and costs are reported, and other updates to
5 how savings are accounted for and reported. Each of the
6 Evaluator' s recommendations ultimately influence the
7 quantification of NEEA' s cost-effectiveness .
8 Q. How has NEEA responded to the
9 recommendations from the Evaluator?
10 A. NEEA has expressed a general willingness to
11 make several of the recommended changes . In summary, NEEA
12 has indicated that it can implement the changes in
13 Recommendation Nos . 1, 2, and 4 but expects additional
14 labor costs to do so. Regarding Recommendation No. 3, Idaho
15 Power requested that going forward, NEEA rely on the
16 service territory allocation approach to report energy
17 savings for state building codes and NEEA has complied. For
18 Recommendations Nos . 5, 6, and 8, NEEA stated that there
19 are no changes necessary as these match current practices .
20 Regarding Recommendation No. 7, the Company will use net
21 market effects whenever performing cost effectiveness
22 tests .
23 Finally, for Recommendation No. 9, NEEA states that
24 it is willing to consider the recommendation but has
25 emphasized that any changes to its current approach on
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1 reporting code energy savings would have to be aligned on
2 by its CEAC because the current approach of claiming one-
3 third of code savings by assuming a code life cycle of 10
4 years rather than 30 years was originally decided on by the
5 CEAC.
6 Table 1 below summarizes NEEA' s responses to each of
7 the Evaluator' s Recommendations :
8 Table 1 : Evaluator' s Recommendations and NEEA' s Response
Recommendation No. Evaluator Recommendation Response
Report annual savings via NEEA agreed to implement
Recommendation No. 1 the service territory
methodology for each
measure claimed by NEEA
Request annual savings NEEA agreed to implement
reports to include
estimates of
Recommendation No. 2 administrative costs,
incentive costs, and non-
incentive costs by
service territory
NEEA work with utilities NEEA agreed to implement -
to accurately produce has transitioned to report
service territory-level energy savings for state
Recommendation No. 3 savings and to best serve building codes using a
each state's current state allocation approach
regulatory environment and
utility's localized
concerns
Track progress for each NEEA agreed to implement
code change relative to
administrative dollars
Recommendation No. 4 spent towards state-level
codes and associated
energy savings accrued by
each state-level code
Only include measure-level No action needed; matches
values in annual reports current practices
for measures in which
savings are claimed;
continue to document each
value as accurately as
Recommendation No. 5 possible, and that each
field is completed in the
workbook to allow for
year-over-year tracking of
regional units, baseline
units, retirement units,
and unit energy savings
values over time
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Distribute naturally No action needed; matches
occurring baseline units current practices
Recommendation No. 6 more equitably between
local program units and
total regional units
In the case that cost Idaho Power agrees to use
effectiveness tests are net market effects
completed using NEEA- whenever performing cost
Recommendation No. 7 reported savings, effectiveness tests
calculate cost-
effectiveness using net
market effects rather than
total regional savings
Complete third-party No action needed; matches
influence evaluations for current practices
the federal standards in
which energy savings are
Recommendation No. 8 claimed by NEEA, as well
as any federal standards
in which NEEA hopes to
claim savings for in the
future
Complete an evaluation for Willing to consider but
each code update to any changes to its current
estimate NEEA's approach on reporting code
qualitative and energy savings would have
quantitative influence to be discussed by its
towards the code update, CEAC
Recommendation No. 9 or, alternatively,
incorporating a
quantitative method for
isolating incremental
savings due to NEEA-
specific efforts approved
by a third-party evaluator
1
2 Q. Has the CEAC had the opportunity to discuss
3 Recommendation No. 9 from the EM&V Report?
4 A. Yes . At CEAC' s November 30, 2023, meeting,
5 NEEA presented the results and recommendations from the
6 EM&V Report . NEEA explained that several of the
7 recommendations could be accommodated with minimal impacts,
8 but the recommendation regarding evaluating NEEA' s
9 influence on codes required further evaluation and
10 alignment from the CEAC due to its impact on other
11 utilities in the region.
12
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1 Q. Does NEEA have a plan for addressing
2 Recommendation No . 9?
3 A. Yes . NEEA presented its proposed process and
4 timeline to follow up on this recommendation at the
5 November 2023 meeting. Figure 1 shows its proposed process
6 and timeline .
7 Figure 1 : CEAC Process & Timeline
CEAC Process & Timeline
042023 Provide background and process.
Nov. 30.
01 2024 Provide an overview of the work NEEA does to influence state energy codes, including how it
Feb 28 compares to its work in influencing federal standards.
Provide current stale of evaluation approaches used to evaluate state energy codes,federal
appliance standards work, and other federal standards work.
022024 Review approach and key assumptions used In eslimatIng and reporting energy savings from state
April 30 energy codes work
Present draft approaches with an opportunity for discussion and feedback, including early
assessment from the 3rd party evaluator.
032024 Present refined draft approaches with 3rd party evaluator assessment.
Aug 28
Staff provides initial recommendation
042024 Staff provides final recommendation with Implications.
Nov 4
Staff will also address if this recommendation would need to be tested before full implementation
8 The staff from NEEA has been actively working with
9 Idaho Power, CEAC, and a third-party evaluator, NMR Group,
10 Inc. , $ ("NMR") to assess influence evaluation approaches and
11 the incorporation of a quantitative method of estimating
12 influence . The Impact Evaluation method ADM referenced in
13 its EM&V report is one of the methods being assessed; this
8 NMR was hired by NEEA to perform the third-party assessment pursuant
to the CEAC process and timeline set forth in Figure 1.
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1 method analyzes NEEA' s market savings impacts and
2 attributes those to Idaho Power' s and Avista' s Idaho
3 service areas . More information on this method can be found
4 in section 2, Impact Evaluation Approach, in Exhibit No. 1 .
5 Q. Has the NMR offered any initial findings?
6 A. Yes . NMR presented its preliminary
7 assessment to CEAC at a July 31, 2024, meeting, where it
8 identified a number of opportunities for improving the
9 qualitative approach NEEA has historically conducted.
10 Notably, NMR recommended that NEEA stop incorporating a
11 quantitative influence score as part of its evaluations,
12 due to concerns over cost and reliability.
13 Q. Does the Company agree with NMR' s
14 recommendations?
15 A. Yes . The Company believes the changes
16 recommended by NMR in its initial assessment will increase
17 the rigor and defensibility of NEEA' s influence on code
18 advancement for each state.
19 Q. What other actions is NEEA taking to address
20 concerns related to code savings?
21 A. Notwithstanding NMR' s recommendation for
22 NEEA to exclude a quantitative influence score from its
23 influence evaluations, the staff at NEEA has committed to a
24 separate third-party review of its approach for
25 establishing and estimating baselines for its state energy
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1 codes work. The role of baselines is to quantitatively
2 estimate influence from market transformation, which is
3 then used in reporting energy savings .
4 For its market transformation work, including state
5 energy codes influence, NEEA has developed two baselines :
6 (1) a pre-intervention baseline condition, and (2) an
7 estimate of what would happen in the market over time
8 without any intervention or influence. Actual market uptake
9 of a product, practice, or code changes is then compared to
10 the baselines, and savings are reported above the
11 baselines . That is, NEEA only reports energy savings above
12 the pre-intervention point and annual estimated baseline.
13 NEEA adopted this approach in recognition that markets
14 would transform eventually on their own without NEEA and
15 its partners' influence, so that NEEA can quantify the
16 savings due to that influence. Baselines are reviewed by
17 third parties for each NEEA initiative.
18 NEEA reports energy savings for code-to-code
19 advancements it has sought to influence per its logic model
20 and planned activities, in new construction only. No above-
21 code savings or savings from major renovations are
22 reported. Reported savings are 100 percent minus code
23 compliance minus the baseline (for the first 10 years of
24 the code' s implementation after a permit/start completion
25 assumption) .
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1 Assumptions NEEA plans to review include but are not
2 limited to :
3 • The assumption that NEEA' s intervention in the
4 regional and national codes process accelerates
5 adoption of more efficient energy code measures by
6 10 years (approximately two code cycles) . After 10
7 years, the assumption is the energy code would have
8 advanced to the same level on its own. This means
9 that the baseline assumption goes from 0 percent to
10 100 percent over the 10-year period.
11 • The assumption that it takes approximately one year
12 from the construction start date for a commercial
13 building to be complete .
14 • The schema NEEA has developed for mapping
15 inconsistent commercial building categories across
16 relevant datasets (e.g. , Dodge Construction Network,
17 Department of Energy) .
18 • The assumption that NEEA should not track above-code
19 savings as resulting from its influence on the
20 market .
21 Q. Have other activities occurred since the
22 July 2024 CEAC meeting?
23 A. Yes . On August 28, 2024, NEEA staff
24 presented to CEAC its initial responses to the
25 recommendations based on the feedback received at the July
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1 CEAC meeting. NMR' s recommendations and NEEA' s initial
2 responses are contained within Table 2 :
3 Table 2 : NEEA' s Initial Responses to NRM' s Recommendations
Recommendation NMR Recommendation NEEA Response
No.
In Market Progress Accepts Recommendation-
Evaluations ("MPERs") , proposes incorporating
conduct deeper, state evaluation methodologies
Overall specific qualitative that support deeper
research, and collaborate qualitative assessment of
with partners to improve NEEA's collaborative
code outcomes influence on energy code
outcomes
Does not have evidence Accepts Recommendation-
that NEEA should develop NEEA will continue to
and apply a downward incorporate estimated
adjustment factor to the code compliance rates as
Supporting No. 1 co-created savings, a decrementing factor
though future evaluations when calculating energy
could suggest an code savings and conduct
adjustment regular third-party
reviews of its market
baseline assumptions
Create a strategy plan Accepts Recommendation-
for each state and code NEEA codes team has begun
cycle and integrate the the development of state
plan' s development and and cycle specific
Supporting No. 2 execution in Codes strategy plans to align
Program Theory and Logic market intervention
Model ("PTLM") activities and intended
outcomes as articulated
in the PTLM
Use MPERs to document and Accepts Recommendation-
highlight the story of NEEA intends to leverage
NEEA's code work, include future code MPERs as a
historical context, platform for increasingly
collaborative approaches rich qualitative
with co-created savings, documentation of its
Supporting No. 3 and the rationales for collaborative efforts,
NEEA' s chosen code NEEA Staff intends to
activities, in public- include interviews or
facing documents other qualitative data
collection as a necessary
component of future codes
MPERs
4 CEAC members were generally supportive of NEEA' s
5 initial response to NMR' s recommendations .
6 Q. Is Idaho Power generally supportive of
7 NEEA' s initial responses to the NMR' s recommendations?
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1 A. Yes . While Idaho Power had hoped the NMR
2 recommendation would identify how code savings would be
3 calculated, it is encouraged by NEEA' s proposed next steps .
4 Q. When does Idaho Power expect final
5 resolution on how NEEA will address Recommendation No. 9?
6 A. NEEA staff is expected to provide final
7 recommendations to the CEAC during its November 4, 2024,
8 meeting. Following that meeting, I expect the third-party
9 assessment of NEEA' s state energy codes baseline
10 methodology and key assumptions used to quantitatively
11 estimate influence will kick off in the fourth quarter of
12 2024 . The results of the third-party assessment will be
13 discussed with CEAC in the first quarter of 2025 .
14 III . IDAHO POWER' S ANALYSIS OF NEEA' S COST EFFECTIVENESS
15 Q. How does NEEA calculate savings?
16 A. In the spring of each year, NEEA sends Idaho
17 Power an annual savings report for the prior year. NEEA
18 reports savings in five ways :
19 • Total Regional Savings - estimated savings
20 associated with all market changes in the
21 Northwest .
22 • Baseline Savings - estimated savings from
23 naturally occurring market changes without
24 utility, NEEA, BPA, and ETO intervention .
25 • Local Program Savings - savings reported from
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1 participating utilities, BPA, and ETO.
2 • Net Market Effects - calculated by subtracting
3 Baseline Savings and Local Program Savings from
4 Total Regional Savings .
5 • Co-Created Savings - sum of Net Market Effect
6 Savings and Local Program Savings .
7 The relationship between the type of savings is
8 reflected in Figure 2 .
9 Figure 2 : Market Transformation Approach
Wr
MARKET TRANSFORMATION APPROACH
ACTUAL
MARKET
SHARE
Net Market a-Co-Created
Effects Savings
W �
Q MARKET Total
= SHARE
(!) BASELINE Regional
f— Savings
W
Y
Q
.S years •10 years •15 years 20•years
TIME
10 Q. How does NEEA calculate Idaho Power' s
11 savings?
12 A. As noted above, for the Cycle 7, NEEA will
13 determine Idaho Power' s Net Market Effect savings using the
14 service territory savings methodology. For codes, NEEA
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1 models code savings rates by state and then applies savings
2 rates to Idaho Power' s share of the state residential
3 customers from the Energy Information Administration. For
4 non-codes, NEEA collects data at the state and zip code
5 level and determines the number of Net Market Effect units
6 and applies a savings rate to determine Idaho Power' s share
7 of Net Market Effect energy savings . NEEA' s data source
8 and allocation methodology are provided for each measure in
9 the final savings report, which is provided as Exhibit No.
10 3 to my testimony.
11 Q. What is NEEA' s approach to cost-
12 effectiveness?
13 A. NEEA evaluates cost effectiveness at the
14 portfolio level over a 20-year horizon. This allows for the
15 analysis to capture the full scope of the market
16 transformation investment and return on investment. Because
17 NEEA looks at the total societal impacts of transforming a
18 market, NEEA considers all incremental costs and benefits
19 of the Total Regional Savings . Finally, NEEA' s benefit
20 value in its cost-effectiveness analysis aligns with the
21 Northwest Power and Conservation Council' s current Power
22 Plan. NEEA' s cost-effectiveness guidelines can be found in
23 Exhibit No. 4 to my testimony.
24 Q. Is NEEA cost effective under this approach?
25 A. Yes . Based on the savings assumptions, the
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1 levelized cost of the Cycle 7 is $0 . 014 - $0 . 019 per
2 kilowatt-hour ("kWh") as reported by NEEA compared to the
3 levelized cost estimate for a gas combined-cycle combustion
4 turbine plant of $0 . 089 per kWh9.
5 Q. How does Idaho Power' s method of assessing
6 cost-effectiveness differ from NEEA' s approach?
7 A. Under Idaho Power' s traditional cost-
8 effectiveness methodology, the Company calculates the cost-
9 effectiveness of a program or measure annually using the
10 first-year costs compared to the present value of the
11 benefits over the average measure life, obtained from a
12 third-party source, of an energy efficient technology or
13 system. Market transformation uses a longer-term look
14 because it requires high up-front investment with the
15 benefits of those investments appearing years later.
16 Q. Did the Company perform an analysis to
17 determine whether the Cycle 7 would be cost effective under
18 Idaho Power' s traditional cost-effectiveness approach?
19 A. Yes . As part of its due diligence leading up
20 to Idaho Power' s entering into the agreement to fund Cycle
21 7, the Company requested NEEA provide a 20-year, service
22 area Net Market Effects savings forecast based on NEEA' s
23 2025-2029 business plan that Idaho Power could use to
24 perform its own cost effectiveness analysis .
9 Idaho Power' s 2023 Integrated Resource Plan at 116.
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1 In response, NEEA provided a high-range savings
2 forecast, which accounts for both quicker market adoption
3 of energy efficiency measures and increased economic
4 activity, and a low range savings forecast, which is NEEA' s
5 base-case forecast. Due to the uncertainty in later years,
6 the forecast provided by NEEA was for 15-years, and it did
7 not include savings from new product standards because NEEA
8 estimates these savings after the Department of Energy
9 approves the standards and a third-party evaluation of
10 influence can be completed. The result of NEEA' s cumulative
11 first-year savings for the 15-year time period is 28 . 46 aMW
12 (249, 304 MWh) under the high range forecast and 19 . 82 aMW
13 (173, 609 MWh) under the low range forecast.
14 As previously stated, under Idaho Power' s
15 traditional cost-effectiveness methodology, the Company
16 calculates the cost-effectiveness of a program or measure
17 annually using the first-year costs compared to the present
18 value of the benefits over the average measure life,
19 obtained from a third-party source, of an energy efficient
20 technology or system. Market transformation uses a long-
21 term look because it requires high up-front investment with
22 the benefits of those investments appearing years later. To
23 assess cost-effectiveness, Idaho Power used a 15-year
24 portfolio look using: 1) Idaho Power' s Cycle 7 funding
25 share for the years 2025-2029, 2) NEEA' s Cycle 7 Net Market
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Idaho Power Company

1 Effects energy savings forecasts for the years 2025-2039,
2 and 3) Idaho Power' s DSM avoided costs from the 2023
3 Integrated Resource Plan ("IRP") .
4 Q. Did the Company modify any assumptions based
5 on the feedback received from the Evaluator?
6 A. Yes . To address the concerns raised by the
7 Evaluator regarding the overstating of code savings, the
8 Company looked at four different scenarios as it evaluated
9 NEEA' s cost-effectiveness : (1) the low range of code and
10 voluntary savings as reported by NEEA; (2) no code savings;
11 (3) code and voluntary savings reduced by 50 percent; and
12 (4) no code savings and voluntary savings reduced by 50
13 percent .
14 Q. What were the results of Idaho Power' s cost-
15 effectiveness analysis?
16 A. Table 3 shows the cost-effectiveness results
17 for the four scenarios that were analyzed. All scenarios
18 were cost-effective with UCTs greater than 1 . 0 .
19 Table 3 : Cost-Effectiveness Analysis Results
. .
Avoided Costs
2025-2039
Lifetime NPV DSM
Scenarios Total First Year UCT
Savings (MWh) Avoided Costs
Savings (MWh)
Cycle 7 as reported: Low
173,609 3,079,042 $53,945,867 3.43
Range
No codes 128,050 1,681,079 $36,210,755 2.30
Savings reduced by 50% 86,804 1,539,521 $26,972,934 1.71
No codes,voluntary savings
64,025 840,539 $18,105,378 1.15
reduced by 50%
20
Nesbitt, DI 23
Idaho Power Company

1 Q. Do you believe participation in NEEA' s 2025-
2 2029 business cycle will bring cost-effective energy
3 efficiency to Idaho Power' s customers .
4 A. Yes . Based on the Company' s assessment, I
5 believe NEEA will provide benefits to customers residing in
6 Idaho Power' s service area.
7 IV. 2025-2029 BUSINESS CYCLE
8 Q. How did NEEA determine the Company' s funding
9 share?
10 A. Each NEEA member' s funding percentage is
11 based upon four components : (1) a regional share of total
12 customers, (2) a regional share of energy sales, 10 (3) load
13 growth forecast for 2025-2029, and (4) a 40 percent cap on
14 increases as compared to the prior funding cycle. This
15 funding percentage calculation places a 12 . 5 percent
16 weighting on the customer component and an 87 . 5 percent
17 weighting on the energy sales component. Load growth is
18 assumed to increase at a rate of 1 percent annually.
19 Q. What is Idaho Power' s funding share for
20 Cycle 7?
21 A. Idaho Power' s funding share is 9 . 56 percent.
22 This equates to $20, 256, 217 over the five-year funding
23 cycle or approximately $4 . 1 million annually.
io Based on 2021 EIA Form 861 data for retail customer and energy sales
and Final Contract High Water Mark (CHWM) Contract amounts for BPA
public power customers.
Nesbitt, DI 24
Idaho Power Company

1 Q. What was Idaho Power' s funding share in the
2 previous 2020-2024 business cycle ("Cycle 6") ?
3 A. Idaho Power' s funding share in Cycle 6 was
4 9 .23 percent . This equated to $14, 710, 808 over the five-
5 year funding cycle or approximately $2 . 9 million annually.
6 Q. Why did Idaho Power' s level of funding
7 increase in the new cycle?
8 A. Idaho Power' s funding share increased for
9 two primary reasons : (1) its portion of the total regional
10 customers and kWh sales were higher than in previous
11 cycles, and (2) NEEA' s overall budget increased for Cycle
12 7 .
13 Q. What drove the increase to the overall
14 budget?
15 A. The overall budget increase is due to new
16 and expanded work planned in Cycle 7 including: (1)
17 increased engagement across all product groups; (2) a new
18 focus on finding opportunities in faster-moving, higher-
19 volume markets; (3) greater emphasis on efficient
20 technologies that save energy during peak load times; (4)
21 more duel-fuel opportunities; (5) research to identify
22 customer segments that are not directly benefiting from
23 market transformation activities; (6) increased investments
24 in regional stock assessments; (7) base funding for the
Nesbitt, DI 25
Idaho Power Company

1 Efficiency Exchange" to ensure the event continues to be
2 held each year and remains accessible; and (8)
3 opportunities for the region to support special projects
4 outside of core business plan funding. 12 Additionally,
5 inflationary pressures have caused a need for NEEA to
6 increase funding amounts . NEEA notes that between 2018 and
7 the start of Cycle 7 in 2025, the Consumer Price Index is
8 forecasted to increase by 28 percent. To recover some of
9 the lost purchasing power, NEEA has factored estimates for
10 inflation into the Cycle 7 budget. If inflation continues
11 during Cycle 7, NEEA is committed to making additional cost
12 reductions and operational adjustments to remain within the
13 five-year fixed budget.13
14 Q. What are NEEA' s goals for Cycle 7?
15 A. NEEA' s efforts will be guided by four
16 strategic goals : (1) transform markets for energy
17 efficiency; (2) accelerate the adoption of grid-enabled
18 end-use technologies through market transformation; (3)
19 advance strategies to reduce greenhouse gas emissions
20 through market transformation; and (4) advance the
21 equitable delivery of energy efficiency benefits to
11 Efficiency Exchange is an annual conference that provides a forum for
knowledge-sharing and networking to help regional energy efficiency
professionals achieve their goals.
12 See NEEA Cycle 7 (2025-2029) Strategic & Business Plans, Exhibit A to
the Agreement provided as Attachment 2 to the Application at 6.
13 Id. at 20.
Nesbitt, DI 26
Idaho Power Company

1 Northwest consumers through market transformation. 14
2 Q. Have you executed an agreement with NEEA to
3 participate in Cycle 7?
4 A. Yes . The Cycle 7 Core Funding Agreement
5 ("Cycle 7 Agreement") was fully executed by Idaho Power and
6 NEEA on August 30, 2024 . The Cycle 7 Agreement can be found
7 as Attachment 2 to the Application.
8 Q. Please generally explain how the contract
9 language in the Cycle 7 Agreement compares to the agreement
10 for Cycle 6 .
11 A. The Cycle 7 Agreement is similar to the
12 agreement for Cycle 6 and includes the same general terms .
13 In addition to incorporating basic contract updates, the
14 Cycle 7 Agreement also includes other changes to improve
15 clarity, consistency, and efficiency to maximize the
16 collective work of the alliance as well as revisions to
17 better mitigate risks and strengthen protections for the
18 Company. Notably, the Cycle 7 Agreement adds robust
19 confidentiality, data security, and insurance provisions
20 with more consistency, clarity, better processes, stronger
21 protections, and more stringent requirements while
22 maintaining the negotiated safeguards from the Cycle 6
23 contract to help ensure the Company can terminate funding
24 if the Company or the Commission find that participation is
i4 Id. at 5.
Nesbitt, DI 27
Idaho Power Company

1 no longer advisable .
2 Q. What terms in the agreement are intended to
3 safeguard Idaho Power' s customers?
4 A. The Cycle 7 Agreement, like the Cycle 6
5 Agreement, includes provisions intended to provide
6 protections for Idaho Power' s customers that allow the
7 Company to terminate the Agreement for a variety of reasons
8 including: lack of regulatory approval, a material change
9 to NEEA' s Bylaws that the Company does not approve, or if
10 the NEEA Board of Directors finds that NEEA has made
11 insufficient progress in achieving its objectives or that
12 NEEA does not have sufficient funds to meet its objectives .
13 The agreement also has a provision that allows for the
14 Company to terminate at any time without cause with 365
15 days' notice .
16 V. STAKEHOLDER ENGAGEMENT
17 Q. Did Idaho Power discuss the findings of the
18 EM&V Report and its plan participation in Cycle 7 with its
19 Energy Efficiency Advisory Group ("EEAG") ?
20 A. Yes, the Evaluator presented the results of
21 the EM&V Report to EEAG at the May 10, 2023, meeting and
22 the Company shared NEEA' s 2025-2029 business plan and the
23 approval process timeline at the August 17, 2023, meeting.
24 Throughout those discussions, EEAG members provided general
25 support for the Company' s continued involvement in NEEA.
Nesbitt, DI 28
Idaho Power Company

1 Q. Did Idaho Power meet with Staff to discuss
2 the Company' s participation in the Cycle 7?
3 A. Yes . The Company held an initial meeting on
4 April 2, 2024, where it provided an overview of market
5 transformation and the states that participate in it, which
6 includes the states that fund NEEA (Washington, Oregon,
7 Idaho, and Montana) as well as California, Minnesota,
8 Wisconsin, Illinois, New York, and Hawaii . It then provided
9 an explanation of how market transformation differs from
10 traditional utility managed programs (resource acquisition)
11 including a comparison between how savings are quantified
12 under each model .
13 Next, the Company discussed how its energy
14 efficiency efforts differ from NEEA' s . Idaho Power focuses
15 on midstream and downstream efforts with proven savings
16 over a one-year cost effectiveness perspective. NEEA
17 focuses on upstream and midstream efforts in emerging or
18 new technologies, practices, and influences the development
19 of new codes or standards over its 20-year portfolio.
20 Additionally, the Company discussed how NEEA
21 calculates savings from its efforts and how much of those
22 savings get attributed to Idaho Power' s service area. The
23 Company reviewed the results of a cost-effectiveness
24 analysis it conducted on the 2010-2014 business cycle.
25 Finally, the Company discussed the EM&V Report and how
Nesbitt, DI 29
Idaho Power Company

1 Idaho Power was addressing the recommendations provided
2 therein.
3 Throughout the meeting, Staff asked questions and
4 requested specific follow-up on several topics .
5 Q. Did the Company hold an additional meeting
6 with Staff?
7 A. Yes . The Company held a follow up meeting to
8 address and respond to Staff' s questions and requests for
9 analyses from the initial meeting. This second meeting was
10 held jointly with Avista and took place on May 30, 2024 .
11 Q. Were there outstanding issues the Company
12 committed to address?
13 A. No . Outside of the prior discussion around
14 how code savings will be calculated and claimed, there were
15 no additional items outstanding. The presentations from the
16 meetings are included as Exhibits Nos . 5 and 6 to my
17 testimony.
18 VI . CONCLUSION
19 Q. Does Idaho Power believe it is in the best
20 interest of its customers to continue to fund NEEA through
21 the next business cycle, 2025-2029?
22 A. Yes, the Company is committed to the pursuit
23 of all cost-effective energy efficiency, and it believes
24 that the energy savings occurring for its customers based
25 on NEEA' s efforts are cost effective. Further, the Company
Nesbitt, DI 30
Idaho Power Company

1 believes continuing to use Rider funds for the Cycle 7 is
2 prudent . The Company will continue to document NEEA funding
3 amounts and annual savings from participation in its annual
4 DSM Report that is filed with the Commission on or before
5 March 15th of each year. Safeguards negotiated in the
6 contract with NEEA would allow the Company to terminate
7 funding for the remainder of the business cycle if the
8 Company or the Commission finds that participation is no
9 longer advisable . The Company respectfully asks that the
10 Commission approve its request for authority to use the
11 Rider to fund its continued participation in NEEA.
12 Q. Does this conclude your direct testimony in
13 this case?
14 A. Yes, it does .
15
16
17
18
Nesbitt, DI 31
Idaho Power Company

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a a a a a a a a a a a a G a a

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-35
IDAHO POWER COMPANY
NESBITT, DI
TESTIMONY
EXHIBIT NO. 1

Evaluation of NEEA
Impacts Allocated to
Idaho Power Company
and Avista Utilities
Within the State of
I d a h o
SUBMITTED TO: IDAHO POWER COMPANY &
AVISTA UTILITIES
SUBMITTED ON : APRIL 6, 2023
SUBMITTED BY: ADM ASSOCIATES, INC.
ADM Associates, Inc Idaho Power Company Avista Utilities
3239 Ramos Circle 1221 W Idaho St 1411 E Mission Ave
Sacramento, CA 95827 Boise, ID 83702 Spokane, WA 99202
916-363-8383
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 1 of 122

Prepared by:
Melissa Kosla
Heather Polonsky
Hannah Lopez
Adam Thomas
II Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 2 of 122

Acknowledgements
We would like to thank the staff at NEEA for their time and effort in contributing to the evaluation of the
Idaho-specific NEEA impacts.This evaluation was conducted with regular coordination with staff at
NEEA, Idaho Power Company, and Avista,who each provided quick feedback and turnaround to the
requests of the evaluation team as well as open and forthright insights into the operations of their
initiatives and efforts.
III Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 3 of 122

Table of Contents
1 Executive Summary...........................................................................................................................12
1.1 Evaluation Objectives..................................................................................................14
1.2 NEEA Background ........................................................................................................15
1.3 Data Provided..............................................................................................................16
1.4 Findings and Recommendations .................................................................................16
2 Impact Evaluation Approach.............................................................................................................20
2.1 Activity-Specific M&V..................................................................................................23
2.2 Step 1: Database Review.............................................................................................25
2.3 Step 2: Document-Based Verification .........................................................................25
2.4 Step 3: UES Review......................................................................................................25
2.5 Step 4: Market Transformation Baseline Review........................................................26
2.6 Step 5: Staff Interviews................................................................................................26
2.7 Step 6: Cost-Effectiveness Testing...............................................................................27
3 Evaluation Results.............................................................................................................................29
3.1 Ex Ante Savings............................................................................................................31
3.2 Verified Ex Post Savings...............................................................................................39
3.3 Allocation Methodology Review..................................................................................50
3.4 Cost Effectiveness Methodology Review.....................................................................56
3.5 Utility Staff Interview Results......................................................................................58
3.6 Impact Evaluation Results ...........................................................................................65
4 Appendix A: Verified Ex Post Savings by Initiative............................................................................96
4.1 Efficiency Measures.....................................................................................................96
4.2 Standards...................................................................................................................101
4.3 Codes.........................................................................................................................104
5 Appendix B: Cost Effectiveness Results...........................................................................................107
5.1 Efficiency Measures...................................................................................................107
5.2 Standards...................................................................................................................114
5.3 Codes.........................................................................................................................116
6 Appendix C: NEEA-Allocated Costs..................................................................................................119
7 Appendix D: Summary of Missing Values........................................................................................121
iv Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 4 of 122

List of Figures
Figure 3-1: Net Market Effects....................................................................................................................29
Figure 3-2: Illustration of Naturally Occurring Market Adoption Approach...............................................29
Figure 3-3: Contributions to Ex-Ante Avista Idaho Electric Savings by Measures, Standards, and Codes.33
Figure 3-4: Contributions to Ex-Ante Idaho Power Idaho Electric Savings by Measures, Standards, and
Codes...........................................................................................................................................................34
Figure 3-5: Efficiency Measure Avista Idaho Electric Savings—WA/OR/MT Contribution to Ex-Ante
(Funder Share)vs Ex-Post(Service Territory).............................................................................................35
Figure 3-6: Code Avista Idaho Electric Savings—WA/OR/MT Contribution to Ex-Ante (Funder Share)vs
Ex-Post (Service Territory) ..........................................................................................................................35
Figure 3-7: Standards Avista Idaho Electric Savings—WA/OR/MT Contribution to Ex-Ante (Funder Share)
vs Ex-Post (Service Territory)......................................................................................................................36
Figure 3-8: Efficiency Measure Idaho Power Idaho Electric Savings—WA/OR/MT Contribution to Ex-Ante
(Funder Share)vs Ex-Post(Service Territory).............................................................................................36
Figure 3-9: Code Idaho Power Idaho Electric Savings—WA/OR/MT Contribution to Ex-Ante (Funder
Share)vs Ex-Post (Service Territory)...........................................................................................................37
Figure 3-10: Standards Idaho Power Idaho Electric Savings—WA/OR/MT Contribution to Ex-Ante (Funder
Share)vs Ex-Post (Service Territory)...........................................................................................................37
Figure 3-11: Efficiency Measure Avista Idaho Gas Savings—WA/OR/MT Contribution to Ex-Ante (Funder
Share)vs Ex-Post (Service Territory)...........................................................................................................38
Figure 3-12: Code Avista Idaho Gas Savings—WA/OR/MT Contribution to Ex-Ante (Funder Share)vs Ex-
Post(Service Territory) ...............................................................................................................................39
Figure 3-13: Current NEEA Electric Funding Share by Organization...........................................................52
Figure 3-14: Example of Single-Family Code Savings Claimed by NEEA.....................................................90
v Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 5 of 122

List of Tables
Table 1-1 Summary of Idaho Power ID Verified Electric Savings................................................................12
Table 1-2 Summary of Avista ID Verified Electric Savings...........................................................................12
Table 1-3 Summary of Avista ID Verified Gas Savings ................................................................................12
Table 1-4: Idaho Power Electric Idaho Overall Cost Effectiveness by Program Year..................................13
Table 1-5: Avista Electric Idaho Overall Cost Effectiveness by Program Year ............................................14
Table 1-6:Avista Gas Idaho Overall Cost Effectiveness by Program Year..................................................14
Table 2-1: Impact Evaluation Tasks by NEEA Activity.................................................................................21
Table 2-2: Summary of NEEA Initiatives......................................................................................................22
Table 2-3: Summary of NEEA Efficiency Measures by Sector.....................................................................24
Table 2-4: Summary of NEEA Codes&Standards Measures......................................................................25
Table 2-5: Summary of Staff Interviews......................................................................................................27
Table 2-6: Data Sources to Answer Research Questions............................................................................27
Table 3-1: Summary of Idaho Power Electric Idaho Ex Ante Savings..........................................................32
Table 3-2: Summary of Avista Electric Idaho Ex Ante Savings....................................................................32
Table 3-3: Summary of Avista Gas Idaho Ex Ante Savings..........................................................................32
Table 3-4: Summary of Idaho Power Idaho Electric Verified Ex Post Savings by Program Year.................40
Table 3-5: PY2017 Summary of Idaho Power Electric Idaho Verified Ex Post Savings by Initiative............40
Table 3-6: PY2018 Summary of Idaho Power Idaho Electric Verified Ex Post Savings by Initiative............41
Table 3-7: PY2019 Summary of Idaho Power Idaho Electric Verified Ex Post Savings by Initiative............42
Table 3-8: PY2020 Summary of Idaho Power Idaho Electric Verified Ex Post Savings by Initiative............43
Table 3-9: PY2021 Summary of Idaho Power Idaho Electric Verified Ex Post Savings by Initiative............44
Table 3-10: Summary of Avista Idaho Electric Verified Ex Post Savings by Program Year .........................44
Table 3-11: PY2017 Summary of Avista Idaho Electric Verified Ex Post Savings by Initiative ....................45
Table 3-12: PY2018 Summary of Avista Idaho Electric Verified Ex Post Savings by Initiative ....................46
Table 3-13: PY2019 Summary of Avista Idaho Electric Verified Ex Post Savings by Initiative ....................47
Table 3-14: PY2020 Summary of Avista Idaho Electric Verified Ex Post Savings by Initiative....................48
Table 3-15: PY2021 Summary of Avista Idaho Electric Verified Ex Post Savings by Initiative....................49
Table 3-16: Summary of Avista Idaho Gas Verified Ex Post Savings by Program Year...............................49
Table 3-17: PY2019 Summary of Avista Gas Verified Ex Post Savings by Initiative ....................................50
Table 3-18: PY2020 Summary of Avista Gas Verified Ex Post Savings by Initiative ....................................50
Table 3-19: PY2021 Summary of Avista Gas Verified Ex Post Savings by Initiative ....................................50
vi Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 6 of 122

Table 3-20: Avista Electric Funder Share ....................................................................................................53
Table 3-21: Avista Gas Funder Share..........................................................................................................53
Table 3-22: Idaho Power Electric Funder Share..........................................................................................54
Table 3-23: Summary of Allocation Share Findings and Recommendations..............................................55
Table 3-24: NEEA and IPC/Avista Cost Effectiveness Methodology Comparison.......................................57
Table 3-25: Summary of Allocation Share Findings and Recommendations..............................................63
Table 3-26:NEEA Code Initiatives...............................................................................................................65
Table 3-27: Summary of Idaho Power Idaho Electric Verified Ex Post Efficiency Measure Savings by
ProgramYear..............................................................................................................................................69
Table 3-28: Summary of Avista Idaho Electric Verified Ex Post Efficiency Measure Savings by Program
Year.............................................................................................................................................................69
Table 3-29: Summary of Avista Idaho Gas Verified Ex Post Efficiency Measure Savings by Program Year
....................................................................................................................................................................70
Table 3-30: Idaho Power Electric Idaho Efficiency Measures Cost Effectiveness by Program Year...........71
Table 3-31:Avista Electric Idaho Efficiency Measures Cost Effectiveness by Program Year......................71
Table 3-32:Avista Gas Idaho Efficiency Measures Cost Effectiveness by Program Year............................71
Table 3-33: Summary of Efficiency Measure Findings and Recommendations..........................................72
Table 3-34: NEEA Standards Initiatives.......................................................................................................74
Table 3-35: Summary of NEEA Standards Influence Evaluations................................................................76
Table 3-36: NEEA Measure-Level Standards...............................................................................................79
Table 3-37: Idaho Power Electric Standards Ex-Ante Savings by Influence Evaluation Completion ..........79
Table 3-38: Idaho Power Electric Standards Ex-Post Savings by Influence Evaluation Completion...........80
Table 3-39:Avista Electric Standards Ex-Ante Savings by Influence Evaluation Completion.....................80
Table 3-40:Avista Electric Standards Ex-Post Savings by Influence Evaluation Completion......................80
Table 3-41: Summary of Idaho Power Idaho Electric Verified Ex Post Standards Savings by Program Year
....................................................................................................................................................................82
Table 3-42: Summary of Avista Idaho Electric Verified Ex Post Standards Savings by Program Year.......82
Table 3-43: Summary of Avista Idaho Gas Verified Ex Post Standards Savings by Program Year.............82
Table 3-44: Idaho Power Electric Idaho Standard Cost Effectiveness by Program Year.............................83
Table 3-45:Avista Electric Idaho Standard Cost Effectiveness by Program Year.......................................83
Table 3-46: Summary of Federal Standards Findings and Recommendations...........................................84
Table 3-47: NEEA Code Initiatives Claimed in 2017-2021...........................................................................85
Table 3-48: Summary of Idaho Power Idaho Electric Verified Ex Post Code Savings by Program Year.....91
Table 3-49: Summary of Avista Idaho Electric Verified Ex Post Code Savings by Program Year...............92
vli Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 7 of 122

Table 3-50: Summary of Avista Idaho Gas Verified Ex Post Code Savings by Program Year.....................92
Table 3-51: Idaho Power Electric Idaho Code Cost Effectiveness by Program Year...................................93
Table 3-52:Avista Electric Idaho Code Cost Effectiveness by Program Year..............................................93
Table 3-53: Avista Gas Idaho Code Cost Effectiveness by Program Year....................................................93
Table 3-54: Summary of Code Findings and Recommendations................................................................94
Table 4-1: PY2017 Summary of Idaho Power Idaho Electric Verified Ex Post Efficiency Measure Savings
byInitiative .................................................................................................................................................96
Table 4-2: PY2018 Summary of Idaho Power Idaho Electric Verified Ex Post Efficiency Measure Savings
byInitiative .................................................................................................................................................97
Table 4-3: PY2019 Summary of Idaho Power Idaho Electric Verified Ex Post Efficiency Measure Savings
byInitiative .................................................................................................................................................97
Table 4-4: PY2020 Summary of Idaho Power Idaho Electric Verified Ex Post Efficiency Measure Savings
byInitiative .................................................................................................................................................98
Table 4-5: PY2021 Summary of Idaho Power Idaho Electric Verified Ex Post Efficiency Measure Savings
byInitiative .................................................................................................................................................98
Table 4-6: PY2017 Summary of Avista Idaho Electric Verified Ex Post Efficiency Measure Savings by
Initiative......................................................................................................................................................98
Table 4-7: PY2018 Summary of Avista Idaho Electric Verified Ex Post Efficiency Measure Savings by
Initiative......................................................................................................................................................99
Table 4-8: PY2019 Summary of Avista Idaho Electric Verified Ex Post Efficiency Measure Savings by
Initiative......................................................................................................................................................99
Table 4-9: PY2020 Summary of Avista Idaho Electric Verified Ex Post Efficiency Measure Savings by
Initiative....................................................................................................................................................100
Table 4-10: PY2021 Summary of Avista Idaho Electric Verified Ex Post Efficiency Measure Savings by
Initiative....................................................................................................................................................100
Table 4-11: PY2019 Summary of Avista Idaho Gas Verified Ex Post Efficiency Measure Savings by
Initiative....................................................................................................................................................101
Table 4-12: PY2020 Summary of Avista Idaho Gas Verified Ex Post Efficiency Measure Savings by
Initiative....................................................................................................................................................101
Table 4-13: PY2021 Summary of Avista Idaho Gas Verified Ex Post Efficiency Measure Savings by
Initiative....................................................................................................................................................101
Table 4-14: PY2017 Summary of Idaho Power Idaho Electric Verified Ex Post Standards Savings by
Initiative....................................................................................................................................................101
Table 4-15: PY2018 Summary of Idaho Power Idaho Electric Verified Ex Post Standards Savings by
Initiative....................................................................................................................................................102
Table 4-16: PY2019 Summary of Idaho Power Idaho Electric Verified Ex Post Standards Savings by
Initiative....................................................................................................................................................102
vili Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 8 of 122

Table 4-17: PY2020 Summary of Idaho Power Idaho Electric Verified Ex Post Standards Savings by
Initiative....................................................................................................................................................102
Table 4-18: PY2020 Summary of Idaho Power Idaho Electric Verified Ex Post Standards Savings by
Initiative....................................................................................................................................................102
Table 4-19: PY2017 Summary of Avista Idaho Electric Verified Ex Post Standards Savings by Initiative 103
Table 4-20: PY2018 Summary of Avista Idaho Electric Verified Ex Post Standards Savings by Initiative 103
Table 4-21: PY2019 Summary of Avista Idaho Electric Verified Ex Post Standards Savings by Initiative 103
Table 4-22: PY2020 Summary of Avista Idaho Electric Verified Ex Post Standards Savings by Initiative 103
Table 4-23: PY2021 Summary of Avista Idaho Electric Verified Ex Post Standards Savings by Initiative 104
Table 4-24: PY2017 Summary of Idaho Power Idaho Electric Verified Ex Post Code Savings by Initiative
..................................................................................................................................................................104
Table 4-25: PY2018 Summary of Idaho Power Idaho Electric Verified Ex Post Code Savings by Initiative
..................................................................................................................................................................104
Table 4-26: PY2019 Summary of Idaho Power Idaho Electric Verified Ex Post Code Savings by Initiative
..................................................................................................................................................................105
Table 4-27: PY2020 Summary of Idaho Power Idaho Electric Verified Ex Post Code Savings by Initiative
..................................................................................................................................................................105
Table 4-28: PY2021 Summary of Idaho Power Idaho Electric Verified Ex Post Code Savings by Initiative
..................................................................................................................................................................105
Table 4-29: PY2017 Summary of Avista Idaho Electric Verified Ex Post Code Savings by Initiative........106
Table 4-30: PY2018 Summary of Avista Idaho Electric Verified Ex Post Code Savings by Initiative........106
Table 4-31: PY2019 Summary of Avista Idaho Electric Verified Ex Post Code Savings by Initiative........106
Table 4-32: PY2020 Summary of Avista Idaho Electric Verified Ex Post Code Savings by Initiative........106
Table 4-33: PY2021 Summary of Avista Idaho Electric Verified Ex Post Code Savings by Initiative........107
Table 4-34: PY2019 Summary of Avista Idaho Gas Verified Ex Post Code Savings by Initiative..............107
Table 4-35: PY2020 Summary of Avista Idaho Gas Verified Ex Post Code Savings by Initiative..............107
Table 4-36: PY2021 Summary of Avista Idaho Gas Verified Ex Post Code Savings by Initiative..............107
Table 5-1: PY2017 Idaho Power Electric Idaho Efficiency Measure Cost Effectiveness by Initiative .......108
Table 5-2: PY2018 Idaho Power Electric Idaho Efficiency Measure Cost Effectiveness by Initiative .......108
Table 5-3: PY2019 Idaho Power Electric Idaho Efficiency Measure Cost Effectiveness by Initiative .......109
Table 5-4: PY2020 Idaho Power Electric Idaho Efficiency Measure Cost Effectiveness by Initiative .......109
Table 5-5: PY2021 Idaho Power Electric Idaho Efficiency Measure Cost Effectiveness by Initiative .......110
Table 5-6: PY2017 Avista Electric Idaho Efficiency Measure Cost Effectiveness by Initiative..................110
Table 5-7: PY2018 Avista Electric Idaho Efficiency Measure Cost Effectiveness by Initiative..................111
Table 5-8: PY2019 Avista Electric Idaho Efficiency Measure Cost Effectiveness by Initiative..................111
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Table 5-9: PY2020 Avista Electric Idaho Efficiency Measure Cost Effectiveness by Initiative..................112
Table 5-10: PY2021 Avista Electric Idaho Efficiency Measure Cost Effectiveness by Initiative................113
Table 5-11: PY2019 Avista Gas Idaho Efficiency Measure Cost Effectiveness by Initiative......................113
Table 5-12: PY2020 Avista Gas Idaho Efficiency Measure Cost Effectiveness by Initiative......................113
Table 5-13: PY2021 Avista Gas Idaho Efficiency Measure Cost Effectiveness by Initiative......................113
Table 5-14: PY2017 Idaho Power Electric Idaho Standards Cost Effectiveness by Initiative....................114
Table 5-15: PY2018 Idaho Power Electric Idaho Standards Cost Effectiveness by Initiative....................114
Table 5-16: PY2019 Idaho Power Electric Idaho Standards Cost Effectiveness by Initiative....................114
Table 5-17: PY2020 Idaho Power Electric Idaho Standards Cost Effectiveness by Initiative....................114
Table 5-18: PY2021 Idaho Power Electric Idaho Standards Cost Effectiveness by Initiative....................115
Table 5-19: PY2017 Avista Electric Idaho Standards Cost Effectiveness by Initiative...............................115
Table 5-20: PY2018 Avista Electric Idaho Standards Cost Effectiveness by Initiative...............................115
Table 5-21: PY2019 Avista Electric Idaho Standards Cost Effectiveness by Initiative...............................115
Table 5-22: PY2020 Avista Electric Idaho Standards Cost Effectiveness by Initiative...............................116
Table 5-23: PY2021 Avista Electric Idaho Standards Cost Effectiveness by Initiative...............................116
Table 5-24: PY2017 Idaho Power Electric Idaho Codes Cost Effectiveness by Initiative..........................117
Table 5-25: PY2018 Idaho Power Electric Idaho Codes Cost Effectiveness by Initiative..........................117
Table 5-26: PY2019 Idaho Power Electric Idaho Codes Cost Effectiveness by Initiative..........................117
Table 5-27: PY2020 Idaho Power Electric Idaho Codes Cost Effectiveness by Initiative..........................117
Table 5-28: PY2021 Idaho Power Electric Idaho Codes Cost Effectiveness by Initiative..........................117
Table 5-29: PY2017 Avista Electric Idaho Codes Cost Effectiveness by Initiative.....................................118
Table 5-30: PY2018 Avista Electric Idaho Codes Cost Effectiveness by Initiative.....................................118
Table 5-31: PY2019 Avista Electric Idaho Codes Cost Effectiveness by Initiative.....................................118
Table 5-32: PY2020 Avista Electric Idaho Codes Cost Effectiveness by Initiative.....................................118
Table 5-33: PY2021 Avista Electric Idaho Codes Cost Effectiveness by Initiative.....................................119
Table 5-34: PY2019 Avista Gas Idaho Codes Cost Effectiveness by Initiative...........................................119
Table 5-35: PY2020 Avista Gas Idaho Codes Cost Effectiveness by Initiative...........................................119
Table 5-36: PY2020 Avista Gas Idaho Codes Cost Effectiveness by Initiative...........................................119
Table 6-1: 2014—2019 5-Year Actual NEEA Costs....................................................................................120
Table 6-2: 2020-2022 Actual NEEA Costs..................................................................................................120
Table 7-1: Avista Electric Summary of Missing Values..............................................................................121
Table 7-2:Avista Gas Summary of Missing Values ...................................................................................121
Table 7-3: Idaho Power Electric Summary of Missing Values...................................................................122
X Exhibit No. 1
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XI Exhibit No. 1
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NEEA Impacts on IPC and Avista Within the State of Idaho
1 Executive Summary
This report is a summary of the evaluation, measurement, and verification (EM&V) effort of the
Northwest Energy Efficiency Alliance (NEEA) activities and energy impact estimates as it relates to
savings allocated to Idaho Power Company (IPC) and Avista Utilities (Avista)within the state of Idaho for
the program years 2017-2021.The evaluation was administered by ADM Associates, Inc(herein referred
to as the "Evaluators").
The Evaluators collected data for the evaluation through review of NEEA codes and standards
methodology documents, NEEA cost-effectiveness methodology documents, previously completed NEEA
measure evaluations, application of prescriptive unit energy savings (UES), annual savings reports, and
collection of historical funding invoices.The Evaluators estimated the energy impacts of the energy
efficiency measures and codes and standards updates through application of Regional Technical Forum
(RTF) prescriptive savings, International Energy Conservation Code (IECC) simulation models, and data
documented from field studies.Table 1-1 through Table 1-3 summarizes NEEA's ex-ante electric savings
(aMW)for the past 5 years (2017 through 2021) for Idaho Power Company electric savings in the state
of Idaho,Avista electric savings in the state of Idaho, Avista gas savings in the state of Idaho,
respectively.
Table 1-1 Summary of Idaho Power ID Verified Electric Savings
Ex Ante Ex Post Realizatio
Year aMW aMW Rate
Savings Savings
2017 2.65 1.72 64.75%
2018 2.77 1.04 37.65%
2019 1.99 2.43 122.00%
2020 1.91 2.72 142.28%
2021 1.82 1.71 93.51%
Total 11.15 9.61 86.23%
Table 1-2 Summary of Avista ID Verified Electric Savings
Ex Ante Ex Post Realization
Year aMW aMW Rate
Savings Savings
2017 0.60 0.31 51.19%
2018 0.57 0.36 63.33%
2019 0.43 0.50 115.22%
2020 0.41 0.48 118.44%
2021 0.39 0.40 103.32%
Total 2.41 2.06 85.41%
Table 1-3 Summary of Avista ID Verified Gas Savings
Ex Ante Ex Post Realization
Year Therms Therms Rate
Savings Savings
2019 43,745 22,808 52.14%
2020 5,678 385 6.79%
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Ex Ante Ex Post Realization
Year Therms Therms Rate
Savings Savings
2021 1 152,881 1 152,881 100.00
Total 1 202,304 1 176,074 1 87.03%
During this evaluation work,the Evaluators compared service territory share to funder share allocation.
The Evaluators ultimately used service territory allocation methodology to estimate total verified
savings and cost-effectiveness of efforts benefitting Idaho customers within Avista's and Idaho Power's
service territories, as seen in the tables above.The tables present the average megawatt hours (aMW)
and Therms verified to claim within the state of Idaho for each utility.The Evaluators estimated verified
savings by multiplying verified net market units,verified UES, and verified savings allocation share.
The Evaluators concluded that the savings estimates for the 2017 through 2021 program years verified
to be allocated to Idaho Power electric is 9.61 aMW at 86.23% realization rate.The verified Idaho
electric savings for Avista during this period is 2.06 aMW at 85.41% realization rate. The verified Idaho
gas savings for Avista during this period is 176,074 Therms at 87.03% realization rate.
The Evaluators also conducted cost-effectiveness testing for each measure, initiative, and program year.
The Evaluators summarize the overall cost-effectiveness by program year. The Evaluators found that
codes and standards efforts were cost effective for all program years,with cost-benefit ratios ranging
between 8 to 49.The Evaluators believe that the cost effectiveness and the savings of the code efforts
are currently overestimated, due to lack of estimation of NEEA influence over code updates.The
Evaluators describe this caveat in detail under the Codes section of the report.
The Evaluators found that all efficiency measure efforts were not cost effective for all program years,
with cost-benefit ratios ranging between 0 and 0.7.Therefore,Avista and Idaho Power funding towards
NEEA remains cost effective due to codes and standards efforts. Further cost-effectiveness testing for
each efficiency measure, standard, and code effort is further detailed in the results section below.
Table 1-4:Idaho Power Electric Idaho Overall Cost Effectiveness by Program Year
Program Year UCT Costs' UCT Benefits
2017 $2,532,792.41 $13,374,742.01 5.28
2018 $2,492,098.69 $9,900,643.72 3.97
2019 $2,491,376.81 $18,155,345.04 7.29
2020 $2,612,183.81 $20,639,160.48 7.90
2021 $2,762,562.35 $11,091,961.06 4.02
Total $12,891,014.08 $73,161,852.31 5.68
Due to carry over dollars between quarters and program years,the total annual funding amounts may not match with Idaho
Power reported spend towards NEEA efforts.
Executive Summary 13
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Table 1-5:Avista Electric Idaho Overall Cost Effectiveness by Program Year
Program Year __J
2017 $576,173 $3,040,522 5.28
2018 $566,915 $4,279,882 7.55
2019 $510,076 $5,984,066 11.73
2020 $432,580 $5,237,060 12.11
2021 $480,617 $3,408,526 7.09
Total $2,566,361 $21,950,055 8.55
Table 1-6:Avista Gas Idaho Overall Cost Effectiveness by Program Year
2019 $154,261 $315,142 2.04
2020 $139,208 $6,048 0.04
2021 $157,375 $2,491,877 15.83
Total $450,844 $2,813,068 6.24
As seen in the tables above, NEEA efforts by program year remained cost-effective using the Idaho
Power and Avista avoided costs and updated verified Ex Post savings to demonstrate savings and cost-
effectiveness in their respective Idaho service territories.
1.1 Evaluation Objectives
The Evaluators identified the following research objectives for the energy efficiency and codes and
standards impact evaluations as it pertains to IPC and Avista within the state of Idaho:
1. Verify and validate the energy and demand (kWh, Therms) impacts attributable to NEEA
activities taking the following into account:
a. The savings calculation methodologies NEEA employs for claiming savings
b. The allocation method of those savings to IPC And Avista
c. The cost-effectiveness of those savings for IPC and Avista;
2. Interview NEEA, IPC, and Avista staff to understand the NEEA savings methodology, NEEA
baseline creation for market transformation and energy saving impacts of NEEA efforts;
2 Due to carry over dollars between quarters and program years,the total annual funding amounts may not match with
Avista reported spend towards NEEA efforts.
3 Due to carry over dollars between quarters and program years,the total annual funding amounts may not match with
Avista reported spend towards NEEA efforts.
Executive Summary 14
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3. Report findings and observations. Make recommendations as applicable;
4. Review and comment on NEEA assumptions and methods for determining and calculating
savings;
5. Review and verify the methodologies and claimed energy impacts that are attributable to IPC
and Avista; and,
6. Complete reviews and verify calculations with 90/10 confidence and precision, where applicable
7. If applicable, propose alternate methods that would result in more accurately quantified and
allocated savings.
This evaluation was requested from Idaho Power and Avista staff due to the Idaho Public Utilities
Commission (IPUC or Commission) Order Number 35270 in case IPC-E-21-04 and Order Number 35129
in AVU-E-20-13/AVU-G-20-08.The Evaluators cite language from Order Number 35270 for which similar
language was used in Order Number 35129:
"The Commission notes Staffs concern with NEEA claimed energy savings and directs the
Company to conduct an independent EM&V to clarify the NEEA claimed savings. We agree it is
concerning for NEEA to claim savings from electrical codes in jurisdictions outside of Idaho. We
direct the Company to verify the accuracy of these claimed savings through an independent
EM&V. If the savings from interjurisdictional codes and standards cannot be verified, then the
method for claiming NEEA savings should be adjusted to remove non-Idaho electrical code
savings. If NEEA is no longer cost-effective after an independent EM&V is conducted, the
Company should reexamine its continued participation. (IPUC Order Nos. 35129 and 35270)
To the extent possible, the Company may work with other Idaho regulated electric utilities that
are conducting a similar EM&V to examine NEEA claimed savings."(IPUC Order No. 35270)
1.2 NEEA Background
NEEA was established in 1997 by the energy efficiency community in Idaho, Oregon, Washington, and
Montana. NEEA operates on the philosophy that the region can accomplish more energy savings than
that of the sum of its individual organizations.The alliance works at a regional and national level to
influence the supply chain and increase the market's ability to deliver energy efficiency at a larger scale.
NEEA claims savings for three types of programs:
1. Efficiency measures
2. Federal standards
3. Building codes
The methodology for calculating net market effects differs between each of the above program types.
NEEA completes efforts for each of the above program types throughout the Northwest region to garner
regional savings that benefit all utilities and customers throughout.This involves training and education
for contractors, outreach, collaboration with large manufacturers and market actors, and maintaining an
overall involvement in standards and codes updates to ensure maximum energy efficiency potential is
reached.
Executive Summary 15
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NEEA plays a large and significant role in energy efficiency within the Northwest. Its contributions have
amounted to large energy efficiency savings across the region. The goal of this evaluation work is to
determine the energy efficiency benefits are benefitting Idaho customers directly. Although NEEA's
work contributes to the entire region, how much of those savings are accrued within Idaho and how
much of those savings affect the local Idaho grid?
The Evaluators' approached this project with those questions in mind as they verified energy efficiency
savings attributable within the state of Idaho to each Avista and Idaho Power.
1.3 Data Provided
The Evaluators requested and received the following documentation from NEEA to facilitate this
evaluation work:
■ Allocation methodology documentation
■ Cost effectiveness documentation
■ 2017-2021 invoices for Avista electric,Avista gas, and Idaho Power electric
■ 2017-2021 annual savings reports for Avista electric,Avista gas, and Idaho Power electric
■ Idaho codes documentation, codes contracts completed, market progress evaluation reports,
and logic models
■ Consumer products, HVAC,water heating, next step homes, and federal standards UES
methodology documentation
■ Federal standards influence evaluation reports
1.4 Findings and Recommendations
The Evaluators offer the following findings and recommendations for the evaluation of NEEA efforts in
Idaho.
1.4.1 Findings
■ Overall,the Evaluators found that contribution to NEEA efforts for standards, and codes
remained cost-effective across program years 2017 through 2021, with cost-benefit ratios
ranging between 11.92 to 167.66, with the exception of one codes program in Avista Gas.
However,the Evaluators found that all efficiency measure efforts were not cost effective for all
program years,with cost-benefit ratios ranging between 0.0 and 0.7. Using the service territory
methodology, measures and codes had overestimated savings accrued out-of-state and had
underestimated savings accrued within Idaho. The Evaluators estimated savings using service
territory allocation methodology, which led to realization rates for individual measures under
100%and over 100%; however,the overall effect of this change revealed NEEA efforts remained
cost-effective for each Idaho Power electric,Avista electric, and Avista gas due to codes and
standards savings.
General Findings
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■ Finding#1: Utilities that fund NEEA can choose whether savings are reported by allocation share
methodology or service territory methodology. The allocation share methodology
overrepresents out-of-state and out-of-service territory savings across measures, codes, and
standards while simultaneously underrepresenting in-state and in-service-territory savings
across measures, codes, and standards. However,the service territory methodology accurately
represents benefits directed to Avista and Idaho Power customers within the state of Idaho.
■ Finding#2:The data NEEA utilizes to estimate net market savings is available at resolutions that
allow NEEA to estimate precise savings for each utility service territory.
■ Finding#3:The Evaluators found that the methodology in which savings were estimated across
measures were inconsistent. For some measures, service territory methodology was used, and
for others,funder share allocation methodology was used.
■ Finding#4: NEEA prioritizes cost-effective savings in terms of regional benefit.Therefore,
savings and cost-effectiveness are distributed across the region evenly, despite observed
distribution of savings across states.Although this philosophy has merit, more precise estimates
of utility-level and program-level savings help NEEA's stakeholders relay relevant savings and
cost-effectiveness results to their respective regulatory commissions.This remains critical, due
to some state-level commission orders to pursue all cost-effective energy efficiency efforts.
■ Finding#5:The interviews revealed that although the three parties fundamentally want to
improve energy efficiency and increase market adoption of emerging technologies, their
preferred approaches to this shared goal vary. Unlike the utilities, who strive to demonstrate the
cost-effectiveness of their initiatives and investments on an annual or bi-annual cycle, NEEA
operates on a five-year funding cycle, which is different than the typical annual or biannual
utility planning cycle.
■ Finding#6: NEEA's programs are designed with a broader constituency in mind than that of its
member utilities. While the Idaho utilities' programs are targeted to produce benefits for their
ratepayers,—NEEA is tasked with developing programs that need to consider what is best for
the entire four-state region. At its core, NEEA's ethos assumes that changes made in one state
will eventually spillover into another state and that in the long run, regional change will be
realized.
■ Finding#7: NEEA currently allocates code savings via funder share methodology,which
estimates a proportion of total NEEA funding to each utility based on number of electric retail
customers and overall load.Therefore,savings from code adoption in other states are in-part
assigned to Idaho.The Evaluators found that out-of-state code building savings are currently
being attributed to Idaho utilities. The Evaluators are skeptical that spillover from out-of-state
code changes result in energy savings within the state of Idaho.Although the barriers to code
adoption from one state to the next may be similar,there is no evidence to suggest that these
learnings transfer to observable and measurable savings. NEEA has stated that starting in 2022,
code savings will be allocated via service territory allocation.
■ Finding#8:The NEEA Cost Effectiveness Advisory Committee (CEAC) meets quarterly with the
NEEA objectives to provide space for discussion around results of recently completed
Executive Summary 17
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evaluation, progress of field studies, relevant updates to programs, and acceptance or
questioning of NEEA methodology towards calculation of savings.
Efficiency Measure Findings
■ Finding#9:The Evaluators estimated verified Ex Post aMW for the efficiency measures to
display 39%, 52%, and 0% realization rates for Idaho Power electric,Avista electric, and Avista
gas savings within the state of Idaho, respectively.The difference in claimed savings and verified
savings is due to the change to using service territory allocation rather than funder share
allocation.The efficiency measures category Ex Ante savings included savings for measures
completed in Washington, Oregon, and Montana—therefore,for some measures,the funder
share allocation methodology underestimated Idaho-specific savings while others
overestimated out-of-state savings.The overall effect of this change resulted in a lower than
100% realization rate.
■ Finding#10:The database review revealed that a variety of fields (measure life, UES)were
empty across measure types due to lack of savings claimed for the measure, which made
verification of values difficult and complicates tracking of a measure progress over time.
■ Finding#11:The database review revealed that NEEA's current method for distribution of
modeled naturally occurring baseline units between local program and NEEA efforts is not
reasonable.A portion of energy efficient technology sales are due to naturally occurring
baseline. NEEA nets out modeled naturally occurring baseline in order to avoid claiming savings
for units that would have been sold had no program or NEEA-effort been provided within the
market. However,the method in which these baseline units are netted out is not distributed
equitably. For some measures, NEEA estimates that a large proportion of local program units are
baseline, and therefore a larger proportion of the remaining net market effects is assigned to
NEEA efforts.The Evaluators raise concern for this assumption, as it is unlikely locally
incentivized, rebated measures display the same free ridership as non-incentivized measures in
the region.
■ Finding#12:The Evaluators reviewed the utilized UES via the Regional Technical Forum (RTF)
workbooks,field study data, and simulation analysis findings and note no large concerns with
NEEA UES methodology or market baseline assumptions.
■ Finding#13:The Evaluators found that NEEA calculates cost-effectiveness of its portfolio using
the total regional savings rather than the net market effects.The Evaluators determined that
this methodology raises concern, and the NEEA cost-effectiveness tests currently account for all
measure, standard, and code completions across the entire region, effectively double counting
local program savings and simultaneously claiming naturally occurring baseline savings. Because
Avista and Idaho Power calculate their own internal cost effectiveness tests,this finding does
not impact Idaho Power or Avista reporting. However,the Evaluators highlight this finding, as
NEEA savings allocation and cost allocation methods are not currently consistent with regulatory
requirements.
Standards Findings
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■ Finding#14:The Evaluators estimated verified Ex Post aMW for the standards efforts to display
34% and 50% realization rates for Idaho Power electric and Avista electric within the state of
Idaho, respectively.Avista gas did not claim any savings for standards.The difference between
claimed savings and verified savings is due to the change to using service territory allocation
rather than funder share allocation. A minor cause of discrepancy is due to corrected baseline
units using influence evaluation values.
■ Finding#15: NEEA contracts third-party evaluators to conduct "influence evaluations"for each
standard,which summarizes NEEA's overall qualitative and quantitative influence towards
federal standards updates. NEEA uses the quantitative assessment as an estimate of federal
standards naturally occurring baseline.The Evaluators found that some of these influence scores
were not integrated properly to estimate baseline units.The Evaluators also found more than
half(13 of 25)federal standard measures lack influence evaluations.
Code Findings
■ Finding#16:The Evaluators estimated verified Ex Post aMW for the code efforts to display
137%, 125%, and 87% realization rates for Idaho Power electric,Avista electric, and Avista gas
savings within the state of Idaho, respectively. The difference between claimed savings and
verified savings is due to the change to using service territory allocation rather than funder
share allocation. Overall,the funder share allocation underestimated Idaho-specific code savings
using the current NEEA policy of claiming 100%code after code is implemented.
■ Finding#17: Currently, NEEA does not complete third-party evaluations of NEEA"influence"
towards codes updates as is currently done for federal standards updates.Therefore, NEEA
currently claims 100%savings for code-built homes. As summarized in the standards influence
evaluations summarized in Table 3-35, NEEA influence towards standards ranges between 2.6%
and 61%. If codes are evaluated similarly, and portray a similar range of influence, NEEA code
savings could be significantly overrepresenting savings. NEEA's current policy is to report 100%
of code-built residential and commercial building savings (while integrating compliance rates)
for 10 years after the effective code update date. Currently, NEEA does not maintain a model to
estimate naturally occurring baseline over time, as it does for its energy efficiency measures.
Essentially,the current NEEA methodology assumes that there would be a 10-year lag in current
residential and commercial building code if NEEA did not participate in code update efforts.
■ Finding#18:The Evaluators reviewed simulation model methodology used by NEEA to estimate
code savings and found that UES methodology for code savings do not present any concerns.
1.4.2 Recommendations
■ Recommendation#1:The Evaluators recommend Avista and Idaho Power request NEEA to
report annual savings via the service territory methodology for each measure claimed by NEEA
for each Idaho Power electric,Avista electric, and Avista gas. (Based on Finding#1, #2,#3)
Executive Summary 19
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■ Recommendation#2:The Evaluators recommend that Avista and Idaho Power request annual
savings reports to include estimates of administrative costs, incentive costs, and non-incentive
costs by service territory.This will allow each utility to calculate more accurate cost-
effectiveness tests for each initiative to determine whether extension of funding is a viable
option within each utility's regulatory environment. (Based on Finding#4)
■ Recommendation#3:The Evaluators recommend that NEEA work with utilities to accurately
produce service territory-level savings and to best serve each state's current regulatory
environment and utility's localized concerns. (Based on Finding#5)
■ Recommendation#4:The Evaluators recommend that NEEA track progress for each code
change relative to administrative dollars spent towards state-level codes and associated energy
savings accrued by each state-level code. With the 20-year market transformation in mind,the
service-territory-level savings will still accrue over the 20-year horizon, however, using this
methodology, actual market transformation effects of co-created savings will be more
accurately tracked. (Based on Finding#6,#7)
■ Recommendation#5:The Evaluators recommend that measure-level values are detailed as
accurately as possible, and that each field is completed in the workbook to allow for year-over-
year tracking of regional units, baseline units, retirement units, and unit energy savings values
over time. (Based on Finding#10)
■ Recommendation#6 The Evaluators recommend that NEEA distribute naturally occurring
baseline units more equitable between local program units and total regional units. (Based on
Finding#11)
■ Recommendation#7: In the case that cost effectiveness tests are completed using NEEA-
reported savings, the Evaluators recommend that Avista and Idaho Power calculate cost-
effectiveness using net market effects rather than total regional savings, as is consistent with
current regulatory requirements to report gross savings that would not have occurred without
program intervention. (Based on Finding#13)
■ Recommendation#8:The Evaluators recommend that third-party evaluations are completed for
the federal standards claimed by NEEA, as well as any federal standards in which NEEA hopes to
claim savings for in the future. Using the quantitative estimate of NEEA influence,the Evaluators
recommend that NEEA calculate a naturally occurring baseline for each standard. (Based on
Finding#15)
■ Recommendation#9:The Evaluators recommend an evaluation is completed for each code
update to estimate NEEA's qualitative and quantitative influence towards the code update.
(Based on Finding#17)
2 Impact Evaluation Approach
The primary objective of the impact evaluation was to determine ex-post verified net energy savings.
This section describes the impact evaluation activities that performed for the evaluation of NEEA's net
market savings impacts attributed to Idaho service territory as well as the partition of those Idaho
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savings to IPC and Avista, respectively.The Evaluators summarize the general approach to validate the
energy and demand impacts attributable to NEEA activities in relation to savings calculation
methodologies for claiming energy savings, allocation of those savings to IPC and Avista, and cost-
effectiveness of those savings for IPC and Avista.
The Evaluators used the following approaches to review and validate NEEA's energy savings assumptions
associated with the efficiency measures, market transformation, and codes and standards efforts
employed by NEEA. Each of these approaches are in accordance with the protocols defined by the
International Performance Measurement and Verification Protocols (IPMVP) and the Uniform Methods
Project(UMP).Table 2-1 summarizes the impact evaluation activities by initiative.
Table 2-1:Impact Evaluation Tasks by NEEA Activity
Initiative Database Document Electric/Gas Impact
Review Verif. Methodology
Efficiency measures ✓ ✓ Deemed Savings/
Codes and standards ✓ ✓ Engineering Algorithms
The M&V methodologies are activity-specific and determined by ex-ante methodology as well as relative
contribution of a given activity to NEEA's overall energy efficiency impacts.The Evaluators reviewed
relevant information on infrastructure,framework, and guidelines set out for EM&V work in several
guidebook documents that have been published over the past several years.These included the
following:
■ Northwest Power& Conservation Council Regional Technical Forum (RTF)
■ Workpapers of previous NEEA measure savings estimate evaluations
■ National Renewable Energy Laboratory(NREL), United States Department of Energy (DOE)The
Uniform Methods Project(UMP): Methods for Determining Energy Efficiency Savings for Specific
Measures, April 20134
■ International Performance Measurement and Verification Protocol (IPMVP) maintained by the
Efficiency Valuation Organization (EVO)with sponsorship by the U.S. Department of Energy
(DOE)s
All components of the data collection and analysis are available to stakeholders and will remain
available through prudence review and investigation as required by the Idaho Public Utilities
4 Notably,The Uniform Methods Project(UMP)includes the following chapters authored by ADM.Chapter 9(Metering Cross-
Cutting Protocols)was authored by Dan Mort and Chapter 15(Commercial New Construction Protocol)was Authored by
Steven Keates.
s Core Concepts: International Measurement and Verification Protocol.EVO 100000—1:2016,October 2016.
Impact Evaluation Approach 21
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Commission subsequent to the evaluation period. Table 2-2 summarizes the measures, codes, and
standards implemented by and claimed by NEEA between the 5-year period of 2017 through 2021.
Table 2-2:Summary of NEEA Initiatives
1 F measure, Electric or
Sector InitiatiZ Standard, Gas
orCode
Agriculture Other Non-Residential Standards Standard Electric
Building Operator Certification Expansion Measure Electric
Commercial Code Enhancement Code Electric
Commissioning Buildings Measure Electric
Condensing Rooftop Units Measure Electric
Desktop Power Supplies Measure Electric
Efficient Rooftop Units Measure Gas
Extended Motor Products Measure Electric
Commercial
Luminaire Level Lighting Controls Measure Electric
Other Codes(Commercial) Code Electric/Gas
Other Non-Residential Standards Standard Electric
Other Strategic Energy Management Measure Electric
Reduced Wattage Lamp Replacement Measure Electric
Window Attachments Measure Electric
XMP Pumps Measure Electric
Certified Refrigeration Energy Specialist(CRES) Measure Electric
Commissioning Buildings Measure Electric
Industrial Drive Power Measure Electric
Other Non-Residential Standards Standard Electric
Other Strategic Energy Management Measure Electric
Reduced Wattage Lamp Replacement Measure Electric
Ductless Heat Pumps Measure Electric
Efficient Gas Water Heater Measure Gas
Efficient Homes Code Electric
Extended Motor Products Measure Electric
Heat Pump Water Heaters Measure Electric
Manufactured Homes Measure Electric
Next Step Homes Measure Electric/Gas
Residential Other Codes(Multifamily) Code Electric
Other Residential Standards Standard Electric
Residential Lighting Measure Electric
Residential New Construction Code Electric
Residential New Construction/Next Step Homes Measure Electric/Gas
Retail Product Portfolio Measure Electric
Super-Efficient Dryers Measure Electric
Televisions Measure Electric
XMP Pumps Measure Electric
Impact Evaluation Approach 22
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
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The Evaluators estimated savings for each of the initiatives listed in the table above by verifying total
regional units,total local program units,total baseline units, and total retirement units are incorporated
correctly, in addition to measure LIES values. Once the net market units and LIES values were verified,
the Evaluators then verified that the most reasonable methods for allocating savings to the Idaho and
utility service territory are incorporated to estimate savings for each Avista and IPC service territories.
2.1 Activity-Specific M&V
In this section,the Evaluators detail our evaluation activities to evaluate the following activities that
result in energy impact savings from NEEA in Idaho:
■ Efficiency Measures
■ Standards
■ Codes
2.1.1 Efficiency Measures
NEEA offers a variety of energy efficiency measures to residential and nonresidential customers in the
Northwest region by working with manufacturers and retailers to lower barriers for customers to
purchase and install energy efficiency measures.This effort allows NEEA the ability to identify
opportunities to increase the overall efficiency of entire product categories, such as air conditioners,
furnaces, and clothes washers and dryers. For the purpose of this report,we refer to the energy
efficiency measures and the energy savings claimed through each of these measures in the ESRPP and
measure initiatives as: "Efficiency Measures".
One of the main objectives of this evaluation is to review and verify NEEA's methodology for claiming
energy and demand savings through the efficiency measures offered through various NEEA efforts.The
Evaluators presents the following measure list for this activity in the table below.
Impact Evaluation Approach 23
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 23 of 122

Table 2-3:Summary of NEEA Efficiency Measures by Sector
Sector
Building Operator Certification Expansion
Commissioning Buildings
Condensing Rooftop Units
Desktop Power Supplies
Efficient Rooftop Units
Commercial Extended Motor Products
Luminaire Level Lighting Controls
Other Strategic Energy Management
Reduced Wattage Lamp Replacement
Window Attachments
XMP Pumps
Certified Refrigeration Energy Specialist(CRES)
Commissioning Buildings
Industrial Drive Power
Other Strategic Energy Management
Reduced Wattage Lamp Replacement
Ductless Heat Pumps
Efficient Gas Water Heater
Extended Motor Products
Heat Pump Water Heaters
Manufactured Homes
Residential
Next Step Homes
Residential Lighting
Residential New Construction/Next Step Homes
Retail Product Portfolio
Super-Efficient Dryers
Televisions
XMP Pumps
The Evaluators summarize the initiative-specific and measure-specific impact analysis activities and
requirements for the Efficiency Measures in the section below.
2.1.2 Codes and Standards
NEEA has supported code activities in the Northwest states since its founding in 1997, principally by
funding staff positions or organizations responsible for code adoption and education. NEEA's goals with
these efforts are to encourage the adoption of more stringent residential and nonresidential energy
codes and to improve energy code program adherence and effectiveness.
Energy codes function to lock into place energy efficiency measures that are commonly used within the
building construction industry.This occurs by eliminating the option of having an efficiency less than
that mandated by code for newly constructed buildings.This can effectively produce significant energy
savings even when the code minimum is set at the market average efficiency by eliminating the option
to install less-than-average efficient products still in the marketplace today.
Impact Evaluation Approach 24
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 24 of 122

One of the main objectives of this evaluation is to review NEEA's impact on adopted code and the
associated claimed energy savings allocated by NEEA towards NEEA's energy codes and standards
efforts, and furthermore,to verify the allocation of those estimated savings to each IPC and Avista.
Table 2-4:Summary of NEEA Codes&Standards Measures
Initiative
Commercial Code Enhancement
Other Codes(Commercial)
Code Efficient Homes
Other Codes(Multifamily)
Residential New Construction
Other Non-Residential Standards—Commercial
Standard Other Non-Residential Standards—Industrial
Other Non-Residential Standards—Agricultural
Other Residential Standards
The following sections detail the impact methods used for each of the codes and standards NEEA has
implemented and in which NEEA claims energy efficiency savings.
2.2 Step 1: Database Review
Before conducting each impact analysis, the Evaluators conducted a database review for each of the
measures.The Evaluators requested all available program tracking data from NEEA that pertains to the
2017 through 2021 program years and consolidated these datasets into one consistently formatted
summary of NEEA's efforts and initiative impacts. This exists as a unified dataset with indicator variables
for calendar year and for applicability to Avista, IPC, or both utilities.
This dataset was then reviewed thoroughly to identify and address any inconsistencies in formatting,
data entry,formula entry, and functionality.
2.3 Step 2: Document-Based Verification
This section describes the Evaluator's general methodology for conducting document-based verification
for NEEA's initiatives in which energy efficiency savings are achieved and quantified.
Documentation for this task will include documented measure specifications, UES workbooks,
whitepapers,testing procedures, previous evaluations, logic models, and presentations that
communicate details used to estimate Idaho-level savings for each measure. In the case that the
Evaluators found any deviations between the sales data, model qualifications, UES values, engineering
algorithms, or assumed input values,the Evaluators noted and summarize these differences in the
aggregated workbooks.
2.4 Step 3: UES Review
To facilitate our review of savings calculations,the Evaluators reviewed and documented whether(1)
NEEA's methodology used for the calculation was appropriate, (2) NEEA's assumptions used were
reasonable and appropriate, and (3) NEEA's savings calculations were completed correctly. With these
Impact Evaluation Approach 25
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 25 of 122

findings,the Evaluators report observations as well as make recommendations to revise such
methodologies.
The Evaluators employed the following approaches to complete impact evaluation activities for
reviewing and evaluating NEEA estimated energy savings:
■ Deemed Savings
■ Engineering Algorithms
The Evaluators did not explore simulation model analysis or billing analysis, as reliable deemed savings
estimates, field data, and technical reference manuals were readily available to verify savings estimates
used in NEEA's analysis. In the following sections,we summarize the general guidelines and activities the
Evaluators followed while conducting each of the above analyses.
2.5 Step 4: Market Transformation Baseline Review
One of the main objectives of this evaluation is to review and verify NEEA's methodology for baseline
creation for NEEA's market transformation and energy savings impact efforts.The Evaluators
interviewed NEEA staff to gain further context on the documentation, procedures, and assumptions
used during baseline creation, and second, review such documentation and the application of the
assumed values to each measure in which a market transformation baseline is created.
The Evaluators also reviewed, in detail, documentation, previous evaluations, and whitepapers,for each
to gather more understanding of how NEEA calculates naturally occurring baseline for each of its
measures, codes, and standards.
NEEA's product baselines represent the market share of qualified products that would exist at a given
time in absence of NEEA's intervention in the market. NEEA develops baseline curves or forecasts to
anticipate the proportions each qualified product market share will naturally occur long-term by
employing available market data and assumptions.
2.6 Step 5: Staff Interviews
The Evaluators conducted thorough interviews with NEEA, IPC, and Avista staff to further understand
the NEEA savings methodology for estimating measure and codes impact savings and the methodology
and assumptions in creating the NEEA baseline for market transformation. As detailed below,the staff
interviews addressed all the objectives identified in the RFP.
The following subsections present overviews of our approach to staff interviews,followed by
information on how we identified and answered important research questions, how we approached
data collection, and how we implemented these interviews.
Table 2-5 summarizes our data collection approaches for each initiative.
Impact Evaluation Approach 26
Exhibit No. 1
Case No. IPC-E-24-35
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Table 2-5:Summary of Staff Interviews
Initiative Staff/Implementers j Measures ■ 4 NEEA staff
■ 2 IPC staff
Codes and Standards ■ 2 Avista staff
The Evaluators used the various information sources—program documentation review and staff
interviews to provide convergent information to address the identified research questions. We made
effective use of each source by identifying which sources will provide the most applicable information to
each question, as shown in Table 2-6.
Table 2-6: Data Sources to Answer Research Questions
Process Evaluation Research Question
Are initiatives run per design and efficiently/effectively? ✓ ✓
Is staffing/organization sufficient and appropriate? ✓ ✓
What is the methodology for allocating co-created energy savings to Idaho ✓ ✓
Power Company,Avista,and other utilities in Idaho?
Are the methodologies employed for calculating and allocating savings ✓ ✓
documented and followed consistently across measures and initiatives?
What is the basis of the assumptions used in each the calculating and ✓ ✓
allocation of savings across measures and initiatives?
What is the methodology for NEEA's baseline creation for market ✓ ✓
transformation and energy savings impacts of NEEA's efforts?
Are the baseline creation methodologies followed consistently across ✓ ✓
initiatives and measures?
How has cost-effectiveness changed over the past years and why? ✓ ✓
Are quality assurance procedures appropriate and effective? ✓ ✓
Are management and implementation tools appropriate and effective? ✓ ✓
Are program materials effective and complete? ✓ ✓
2.7 Step 6: Cost-Effectiveness Testing
Finally, the Evaluators calculated each utility's cost-effectiveness, avoided energy costs, and
implementation costs. We used our in-house-developed cost-effectiveness tool to provide cost-
effectiveness assessments for the IPC and Avista Portfolios by NEEA energy savings activity. NEEA
calculated cost effectiveness for the NEEA portfolio using avoided costs from the 71h Power Plan, a least-
cost power plan for the Pacific Northwest created by the Northwest Power and Conservation Council
and updated approximately every 6 to 7 years.
Impact Evaluation Approach 27
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 27 of 122

However,the Evaluators calculate cost-effectiveness assessments for this evaluation work using Idaho
Power's and Avista's specific avoided cost relevant to each program year.
As Idaho utilizes the Utility Cost Test (UCT)to evaluate a program,the Evaluators determined the
economic performance with UCT. This test assists with identifying avenues to improve cost-
effectiveness, such as adjustments to measure incentive levels, administration spending, or adjustment
to program offerings. Cost-effectiveness workbooks were built "ground-up", at the highest granularity
level supported by the program data.The Evaluators calculated cost effectiveness at the measure-level,
which was then aggregated to initiative-and portfolio-level values.This allows IPC and Avista to address
individual NEEA offerings and potentially select lower-performing initiatives to consider for funding
reductions or reallocations.
Impact Evaluation Approach 28
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 28 of 122

NEEA Impacts on IPC and Avista Within the State of Idaho
3 Evaluation Results
This section provides the results of the overall impact evaluation, as well as the results between
efficiency measures and codes and standards measures.The Evaluators calculated the verified electric
and natural gas savings estimated to reasonably claim as NEEA net market effects within the state of
Idaho for each Avista and Idaho Power.
Net market effects are summarized by NEEA in the following figure:
Figure 3-1:Net Market Effects'
ProgramNet Market Effects Total Regional Local Occurring
Savings Savings Baseline Savings
Market transformation is achieved through removing barriers from consumers, manufacturers, and the
market so that consumers adopt these technologies at a faster pace than without these efforts.The
following figure displays the philosophy behind NEEA's market transformation progress.
Figure 3-2:Illustration of Naturally Occurring Market Adoption Approach'
100%
90%
Market
so% Transformation
70% -
1c0 60%
C 1
N 50%
O
- 40%
O
�0 30%
20% - - -
10%
0%
2020 2025 2030 2035 2040 2045
—Total Market —Naturally Occumng Baseline
The Evaluators outline NEEA's general Ex Ante savings methodology steps as the following:
6 NEEA Operational Guidelines for Estimating Electric Energy Savings, 2022.
7 NEEA Operational Guidelines for Estimating Electric Energy Savings, 2022.
Exhibit No. 1
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1. Total regional units are quantified using regional program and sales data
2. Local program units are quantified using local program data
3. Baseline units are quantified using market transformation baseline models
4. Retired units are quantified using market transformation baseline models
5. Net market units for the Pacific Northwest region are calculated using the above inputs
6. Net market units for the funding utility are allocated using service territory or funder share
allocation methodology
7. Claimable net savings allocated to funding utilities are calculated by multiplying net market units
by the measure-level LIES
The Evaluators outline the above steps in each of the equations detailed below. Each equation input
listed below were reviewed by the Evaluators to confirm that the estimates are reasonable for current
use.The Evaluators also identify opportunities to improve estimates using currently available data.
NEEA calculates net market units to represent energy efficiency upgrades that would not have occurred
without NEEA intervention in the Northwest. Net market units are calculated in a way that nets out
upgrades completed due to local program intervention, upgrades completed due to naturally occurring
baseline, and units estimated to retire.The net market units are calculated for each individual measure
as follows:
Equation 3-1:Regional Net Market Units
Net Market UnitsNorthwest Region
= Total Regional UnitsNorthwestRegion — Local Program UnitsNorthwest Region
— Baseline UnitsNorthwest Region — Retirement UnitsNorthwest Region
Where,
Total Regional Units =The total number of measures installed within the northwest region
(Idaho, Montana, Oregon, and Washington)
Local Program Units =The total number of measures rebated by local programs, estimated
using Energy Trust of Oregon, Bonneville Power Administration, and local utility program data
Baseline Units =The estimated baseline units using the measure-level NEEA market
transformation baseline models
Retirement Units =The estimated retired units, also calculated using NEEA market
transformation baseline models
In order to convert the net market units for the northwest region into net market units for the Idaho-
specific region, an allocation method is utilized to allocate a portion of those savings to the Avista and
Idaho Power utilities within the state of Idaho.The utilities are provided a choice as to whether savings
are reported with one of the following two options:
■ Funder Share Allocation: This methodology was developed by NEEA and allocates a percent
share of total funding amounts to each utility.These values include inputs such as: total load
growth forecasts, weighted retail customers by utility,weighted retail energy sales by utility,
Evaluation Results 30
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 30 of 122

and caps on funding share increases. Further details of this methodology are provided in Section
3.3.2.
■ Service Territory Allocation:This methodology produces a percent share of total measure
completes or new construction completes estimated to occur within the utility shareholder's
utility.This value is aggregated using utility-provided data within the Northwest region, which
provides resolution that allows NEEA to assign each project to a specific utility service territory.
Further details of this methodology are provided in Section 3.3.1.
Further details of each allocation method are presented in Section 3.3.The following equation details
how the service territory allocation value chosen above is incorporated to calculate the utility-specific
net market units.
Equation 3-2:Service Territory Allocation of Savings
Net Market Unitsutility service Territory
= Net Market UnitsNorthwest Region *Service Territory Allocationutility Territory
The following equation details how the funder share territory allocation value chosen above is
incorporated to calculate the utility-specific net market units.
Equation 3-3: Funder Share Allocation of Savings
Net Market Unitsutility service Territory
= Net Market UnitsNorthwest Region
* Funder Share Allo cation Utility service Territory
As depicted above,the Idaho-specific share of total Avista service territory net market units is estimated
by multiplying against the estimated proportion of Idaho service territory within the Avista Utilities
service territory. Further details are presented in Section 3.3.
Finally,the initiative-level savings are calculated by multiplying the net market units by the verified UES,
by program year. NEEA references the Regional Technical Forum (RTF) UES for the majority of measures
offered.The resulting equation is as follows:
Equation 3-4: Verified Ex-Post Idaho-Specific Savings
Verif ied Ex Post Savings = Net Market Unitsutility idaho service Territory * Veri f tied UES
The verified Ex-Post savings are then divided by the NEEA Ex-Ante savings to calculate the resulting
realization rate.The verified Ex-Post Idaho-specific savings and realization rate is calculated by initiative
and sector for each individual year and 5-year period evaluated.
3.1 Ex Ante Savings
In this section,the Evaluators summarize the Ex-Ante savings estimated by NEEA and reported on an
annual basis to Avista and Idaho Power.
Evaluation Results 31
Exhibit No. 1
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Table 3-1:Summary of Idaho Power Electric Idaho Ex Ante Savings
Ex-Ante Savings: Ex-Ante Savings:
Program Year Measures Ex-Ante Savings: Standards
2017 0.31 0.89 1.45 2.65
2018 0.40 1.23 1.15 2.77
2019 0.28 1.32 0.40 1.99
2020 0.39 1.12 0.41 1.91
2021 0.42 1.00 0.41 1.82
Total 1.78 5.56 3.81 11.15
Table 3-2:Summary of Avista Electric Idaho Ex Ante Savings
CodesEx-Ante Savings: 4V Ex-Ante Savings:
Program Year Measures Ex-Ante Savings: Standards Ex-Ante Savings:
2017 0.06 0.18 0.37 0.60
2018 0.06 0.22 0.30 0.57
2019 0.06 0.28 0.09 0.43
2020 0.08 0.24 0.09 0.41
2021 0.08 0.21 0.09 0.39
Total 0.34 1.13 0.94 2.41
Table 3-3:Summary of Avista Gas Idaho Ex Ante Savings
Ex-Ante Savings: Ex-Ante Savings: Ex-Ante Savings:
Program Year Measures Ex-Ante Savings: Standards
(Therms) Codes(Therms) (Therms) Total(Therms)
2019 636 43,109 0 43,745
2020 0 5,678 0 5,678
2021 0 152,881 0 152,881
Total 636 201,667 0 202,304
One of the objectives of this evaluation was to review the proportional savings of measures, codes, and
standards savings attributed to Avista and Idaho Power. During in-depth interviews,Avista and Idaho
Power staff noted that they had noticed savings from codes and standards have increased in proportion
to total savings over the years,whereas the proportion of savings from measures have decreased over
time.The following figures summarize the proportional contributions of each the measures, codes, and
standards Ex-Ante savings determined by NEEA between 2017 and 2021 for each utility.As seen below,
the proportion of savings developed through code and standards efforts has slowly decreased across the
5-year time period, starting from 92%and ending at 77%for Avista and starting at 89%and ending at
77%for Idaho Power.
Evaluation Results 32
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 32 of 122

Figure 3-3: Contributions to Ex-Ante Avista Idaho Electric Savings by Measures,Standards, and Codes
0.50
0.37 0.30
sn° 0.40 (61%) (5^) 0.09
2 (21. 0.09
(23%) 0.09
(23%)
0.30
c
Q
x
w
0.20 0.24 0.21
0.22 (58%) (58%)
0.18 (37%)
(29%)
0.10
2017 2018 2019 021
■Measure Code ■Standard
Evaluation Results 33
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 33 of 122

Figure 3-4: Contributions to Ex-Ante Idaho Power Idaho Electric Savings by Measures, Standards, and
Codes
2.50
1.15
(41%)
2.00
oa
0.40
m (20 6) 0.41
`� (21%) 0.41
150 (224�)
M
a
M+
C
Q -
x 1.23
1.00 (44%) 1.32 1.12 1.00
0.89 (66%) (58%) (55%)
(34%)
0.50
0.00
■ ■
2017 2018 2019 2020 2Ci21
■Measure Code ■Standard
Although codes and standards contributions to savings are slowly decreasing over this 5-year evaluation
period,the Evaluators note that a significant proportion of codes and standards savings originate from
regional measure, standards, and code projects completed out-of-state.The Evaluators summarize the
Ex-Ante savings categorized by state-level source of savings.The figures below depicts the total Ex-Ante
savings attributed to Avista and IPC that had been accrued outside the state of Idaho under the funder
share methodology versus the Ex-Post savings based on the service territory methodology.
Evaluation Results 34
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 34 of 122

Figure 3-5:Efficiency Measure Avista Idaho Electric Savings— WA/OR/MT Contribution to Ex-Ante
(Funder Share) vs Ex-Post(Service Territory)
0.50
0.45
0.40
c�
0.35
v, 0.30
to
0.25
c�
0.20
0.15 0.02 0.03
Q 0.10 (30%) (39%)
0.05
0.00
Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post
2017 2018 2019 2020 2021
■ID ■WA/OR/MT
Figure 3-6: Code Avista Idaho Electric Savings— WA/OR/MT Contribution to Ex-Ante(Funder Share) vs Ex-
Post(Service Territory)
0.50
0.45
0.40
0.35 0.23
0.30 (80%) 0.19
(79%) 0.18
0.25 (82%)
�^ 0.20
0.15 -
0.10
0.05
0.00
Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post
2017 2018 2019 2020 2021
■ID u WA/OR/MT
Evaluation Results 35
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 35 of 122

Figure 3-7:Standards Avista Idaho Electric Savings—WA/OR/MT Contribution to Ex-Ante(Funder Share)
vs Ex-Post(Service Territory)
0.50
0.45
0.40
2 0.35
c�
0.30 0.19
.5; 0.25 4796)
ti
0.20 0.06
0.15 (51%) 0.01 0.01
Q 0.10 (12%) (15%)
0.05 ■ ■
0.00
Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post
2017 2018 2019 2020 2021
■ID L.WA/OR/MT
Figure 3-8:Efficiency Measure Idaho Power Idaho Electric Savings— WA/OR/MT Contribution to Ex-Ante
(Funder Share) vs Ex-Post(Service Territory)
7.00
6.00
5.00
ti
ao 4,00
c
n 300
c 2.00 0.00 0.00 0.00 0.00
Q (0%) (0%) (0%) (0%)
1.00
0.31 0.12 m 0.12
0.00 �
Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post
2017 2018 2019 2020 2021
■ID F WA/OR/MT
Evaluation Results 36
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 36 of 122

Figure 3-9: Code Idaho Power Idaho Electric Savings—WA/OR/MT Contribution to Ex-Ante(Funder
Share) vs Ex-Post(Service Territory)
7.00
6.00
2 5.00 4.69
ti
4.00 (SONS)
c
3.00 1.14 1.06
(92%) (80%) 0.87 0.87
0.76
c 2.00 (5%) (78%) (86%)
Q
1.00 . = 6■ ■��
0.26 oxi 0.249
0,00 Am
Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post
2017 2018 2019 2020 2021
■ID ■WA/OR/MT
Figure 3-10:Standards Idaho Power Idaho Electric Savings— WA/OR/MT Contribution to Ex-Ante(Funder
Share) vs Ex-Post(Service Territory)
.ou
6.00
5.00
�U
4.00 2.34
I 3.00 (85%)
c 2.00 1.16 0.86 0.03
Q 90% (90%) (50,6) (11%) 0.03
1.o0 (18%)
= 0.04jAiglo 0.09 4
0.00
vJ
Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post
2017 2018 2019 2020 2021
■ID s WA/OR/MT
Figure 3-6 confirms that service territory allocation was utilized for 2017 and 2018 for Avista,which is
portrayed by the lack of Washington, Oregon, or Montana-contributed savings towards Avista annual
savings.
In addition,the proportion of code savings from out-of-state efforts are significantly higher than the
proportion of measure or standards savings from out-of-state efforts.Therefore, code savings reported
to Avista and IPC currently claim the majority of savings, (nearly 80%of savings) due to Washington,
Evaluation Results 37
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 37 of 122

Oregon, or Montana code change efforts and benefits by utilizing the funder share allocation
methodology.
The trends seen in each of the figures above for each Avista and Idaho Power are similar, as expected,
due to identical total regional units,total local program units,total baseline units, and total retirement
units.The differences among the two utilities are determined solely through allocation methodology
and values of each allocation methodology.Therefore, proportions of savings between the two should
be similar,while magnitudes differ.
For Avista gas service territory in Idaho, NEEA-assigned Ex Ante savings consisted of almost entirely code
savings, as seen in the figure below.
Figure 3-11:Efficiency Measure Avista Idaho Gas Savings— WA/OR/MT Contribution to Ex-Ante(Funder
Share) vs Ex-Post(Service Territory)
180,OCJO
160,00)
E 140,000
v
120,000
100,000
c
80,000
Ln
60,000
40,000
Q
20,000
636 0 0 0 0 0
0
Ex Ante Ex Post Ex Ante Ex Post Ex Ante Ex Post
2019 2020 2021
■ID n WA/OR/MT
Evaluation Results 38
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 38 of 122

Figure 3-12: Code Avista Idaho Gas Savings— WA/OR/MT Contribution to Ex-Ante(Funder Share) vs Ex-
Post(Service Territory)
180,000
160,000
E 140,000
120,000
r' 100,000
c
80,000 23,655
Ln
60,000 (55%)
5,603
c 40,000 (99%�
d
20,000
0
Ex Ante Ex Post Ex Ante Ex Post Ex Ante E. P , t
2019 2020 202i
■ID u WA/OR/MT
The Avista gas measure savings reported by NEEA in 2019 consisted of no projects completed within the
state of Idaho. Additionally, 55%and 99%of the code savings claimed consisted of projects originating
outside the state of Idaho in 2019 and 2020, respectively. However, NEEA reported the 2021 annual
savings via service territory methodology and therefore no savings were accrued outside the state of
Idaho in 2021.
It is important to note the significant impact to savings that each the funder share methodology and
service territory methodology contribute to overall savings for each of the measure, standards, and
codes programs. In addition, the Evaluators note that inconsistencies among allocation methodology are
seen within these two Idaho utilities,within service territories, within fuel types, and within initiatives.
3.2 Verified Ex Post Savings
In this section,the Evaluators summarize verified Ex Ante and Ex Post electric and gas savings for Avista
and Idaho Power, along with realization rates across program years and NEEA initiatives.
3.2.1.1 Idaho Power Idaho Electric Verified Ex Post Savings
The Evaluators summarize the verified electric savings and realization rates for Idaho Power within the
state of Idaho by program year in the table below.
Evaluation Results 39
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 39 of 122

Table 3-4:Summary of Idaho Power Idaho Electric Verified Ex Post Savings by Program Year
Ex Ante Ex Post Realization
Year aMW aMW Rate
Savings Savings
2017 2.65 1 1.72 64.75%
2018 2.77 1.04 37.65%
2019 1.99 2.43 122.00%
2020 1.91 2.72 142.28%
2021 1.82 1.71 93.51%
Total 11.15 9.61 86.23%
Table 3-5 through Table 3-9 summarizes the Idaho Power Idaho verified electric savings and realization
rates by initiative for each of the program years between 2017 and 2021.The Evaluators note that for
the entirety of the report, the realization rates are based off more than two significant figures.
Table 3-5:PY2017 Summary of Idaho Power Electric Idaho Verified Ex Post Savings by Initiative
Measure, Ex Ante Ex Post Realization
Standard,
Code Savings Savings
Measure Industrial Certified Refrigeration Energy 0.00 0.00 0.00%
Specialist(CRES)
Measure Commercial Commissioning Buildings 0.03 0.00 0.00%
Standard Industrial Drive Power 0.03 0.06 216.45%
Measure Residential Ductless Heat Pumps 0.06 0.00 6.72%
Code Residential Efficient Homes 0.35 0.60 172.50%
Measure Residential Heat Pump Water Heaters 0.10 0.01 5.68%
Measure Commercial Luminaire Level Lighting Controls 0.00 0.00 0.00%
Code Commercial Other Codes(Commercial) 0.38 0.34 90.56%
Code Residential Other Codes(Multifamily) 0.05 0.02 46.03%
Standard Commercial Other Non-Residential Standards 0.27 0.29 108.52%
Standard Residential Other Residential Standards 1.15 0.00 0.12%
Measure Commercial Reduced Wattage Lamp 0.03 0.06 198.85%
Replacement
Code Residential Residential New Construction/Next 0.11 0.26 245.22%
Step Homes
Measure Residential Retail Product Portfolio 0.02 0.02 75.23%
Measure Residential Super-Efficient Dryers 0.05 0.02 32.89%
Measure Residential Televisions 0.02 0.02 103.12%
Total 2.65 1.72 64.75%
Evaluation Results 40
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 40 of 122

Table 3-6:PY2018 Summary of Idaho Power Idaho Electric Verified Ex Post Savings by Initiative
Measure, Ex Ante Ex Post Realization
Standard, Sector Initiative aMW aMW Rate
Code Savings Savings
Measure Commercial Building Operator Certification 0.00 0.00 0.00%
Expansion
Measure Industrial Certified Refrigeration Energy 0.03 0.00 0.00%
Specialist(CRES)
Measure Commercial Commissioning Buildings 0.02 0.00 0.00%
Measure Industrial Commissioning Buildings 0.00 0.00 0.00%
Measure Commercial Desktop Power Supplies 0.15 0.11 73.13%
Standard Industrial Drive Power 0.02 0.00 0.00%
Measure Residential Ductless Heat Pumps 0.03 0.00 0.00%
Code Residential Efficient Homes 0.38 0.81 215.05%
Measure Residential Heat Pump Water Heaters 0.04 0.00 0.00%
Measure Residential Manufactured Homes 0.00 0.00 0.00%
Code Commercial Other Codes(Commercial) 0.62 0.00 0.00%
Code Residential Other Codes(Multifamily) 0.05 0.04 73.04%
Standard Commercial Other Non-Residential Standards 0.08 0.02 29.61%
Standard Industrial Other Non-Residential Standards 0.22 0.02 8.49%
Standard Residential Other Residential Standards 0.82 0.00 0.16%
Measure Industrial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Reduced Wattage Lamp 0.05 0.00 0.00%
Replacement
Measure Industrial Reduced Wattage Lamp 0.01 0.00 0.00%
Replacement
Code Residential Residential New Construction/Next 0.18 0.00 0.00%
Step Homes
Measure Residential Retail Product Portfolio 0.02 0.01 57.04%
Measure Residential Super-Efficient Dryers 0.05 0.03 65.20%
Measur I Residential Televisions 0.00 0.00 104.70%
Total 2.77 1.04 37.65%
Evaluation Results 41
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 41 of 122

Table 3-7.PY2O19 Summary of Idaho Power Idaho Electric Verified Ex Post Savings by Initiative
Standard,Measure, Ex Ante Ex Post Realization
.
Code Savings Savings
Measure Commercial Commissioning Buildings 0.03 0.00 1 0.00%
Measure Industrial Commissioning Buildings 0.00 0.00 0.00%
Measure Commercial Desktop Power Supplies 0.01 0.01 79.15%
Standard Industrial Drive Power 0.01 0.00 11.90%
Measure Residential Ductless Heat Pumps 0.05 0.00 1.02%
Code Residential Efficient Homes 0.37 0.81 217.23%
Measure Residential Heat Pump Water Heaters 0.04 0.00 3.74%
Measure Commercial Luminaire Level Lighting Controls 0.00 0.00 0.00%
Measure Residential Manufactured Homes 0.00 0.00 0.00%
Code Residential Next Step Homes 0.21 0.47 225.25%
Code Commercial Other Codes(Commercial) 0.69 0.92 132.61%
Code Residential Other Codes(Multifamily) 0.04 0.02 38.13%
Standard Commercial Other Non-Residential Standards 0.08 0.03 40.51%
Standard Industrial Other Non-Residential Standards 0.23 0.00 0.00%
Standard Residential Other Residential Standards 0.07 0.06 81.29%
Measure Industrial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Reduced Wattage Lamp 0.04 0.04 85.46%
Replacement
Measure Industrial Reduced Wattage Lamp 0.01 0.01 85.46%
Replacement
Measure Residential Retail Product Portfolio 0.01 0.00 6.92%
Measure Residential Super-Efficient Dryers 0.08 0.06 81.85%
Measure Residential Televisions 0.00 0.00 0.00%
Total 1.99 2.43 122.00%
Evaluation Results 42
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 42 of 122

Table 3-8:PY2O2O Summary of Idaho Power Idaho Electric Verified Ex Post Savings by Initiative
Measure, Ex Ante Ex Post Realization
Standard, Sector Initiative aMW aMW Rate
Code Savings Savings
Measure Industrial Certified Refrigeration Energy 0.00 0.00 0.00%
Specialist(CRES)
Measure Commercial Commissioning Buildings 0.03 0.00 0.00%
Measure Industrial Commissioning Buildings 0.00 0.00 18.80%
Measure Commercial Desktop Power Supplies 0.01 0.00 0.00%
Standard Industrial Drive Power 0.00 0.00 0.00%
Measure Residential Ductless Heat Pumps 0.06 0.00 5.17%
Code Residential Efficient Homes 0.32 0.89 281.70%
Measure Residential Extended Motor Products 0.01 0.00 5.00%
Measure Commercial Extended Motor Products 0.01 0.00 28.78%
Measure Residential Heat Pump Water Heaters 0.08 0.00 4.17%
Measure Commercial Luminaire Level Lighting Controls 0.01 0.01 56.71%
Measure Residential Manufactured Homes 0.01 0.00 0.00%
Code Residential Next Step Homes 0.22 0.50 222.51%
Code Commercial Other Codes(Commercial) 0.54 0.77 142.92%
Code Residential Other Codes(Multifamily) 0.04 0.02 41.94%
Standard Commercial Other Non-Residential Standards 0.09 0.04 43.64%
Standard Industrial Other Non-Residential Standards 0.23 0.30 128.37%
Standard Agriculture Other Non-Residential Standards 0.00 0.00 257.68%
Standard Residential Other Residential Standards 0.08 0.06 75.37%
Measure Industrial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Reduced Wattage Lamp 0.04 0.04 105.76%
Replacement
Measure Industrial Reduced Wattage Lamp 0.01 0.01 105.09%
Replacement
Measure Residential Retail Product Portfolio 0.12 0.08 65.79%
Total 1.91 2.72 142.28%
Evaluation Results 43
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 43 of 122

Table 3-9:PY2021 Summary of Idaho Power Idaho Electric Verified Ex Post Savings by Initiative
Measure, Ex Ante Ex Post Realization
Standard, Sector Initiative aMW aMW Rate
Code Savings Savings
Measure Commercial Desktop Power Supplies 0.01 0.00 1 0.00%
Measure Residential Ductless Heat Pumps 0.05 0.00 2.96%
Code Residential Efficient Homes 0.27 0.60 223.90%
Measure Residential Heat Pump Water Heaters 0.10 0.00 4.18%
Measure Commercial Luminaire Level Lighting Controls 0.01 0.00 51.59%
Measure Residential Manufactured Homes 0.01 0.00 0.00%
Code Commercial Other Codes(Commercial) 0.40 0.46 113.98%
Standard Commercial Other Non-Residential Standards 0.10 0.04 43.48%
Standard Industrial Other Non-Residential Standards 0.24 0.30 128.37%
Standard Agriculture Other Non-Residential Standards 0.00 0.00 257.68%
Standard Residential Other Residential Standards 0.07 0.06 74.00%
Measure Commercial Reduced Wattage Lamp 0.02 0.02 105.99%
Replacement
Measure Industrial Reduced Wattage Lamp 0.00 0.00 105.99%
Replacement
Code Residential Residential New Construction 0.33 0.09 27.15%
Measure Residential Retail Product Portfolio 0.17 0.11 67.14%
Measure Commercial Window Attachments 0.00 0.00 0.00%
Measure Residential XMP Pumps 0.03 0.00 4.19%
Measure Commercial XMP Pumps 0.02 0.01 26.24%
Total 1.82 1.71 93.51%
3.2.1.2 Avista Idaho Electric Verified Ex Post Savings
The Evaluators summarize the verified electric savings and realization rates for Avista within the state of
Idaho by program year in the table below.
Table 3-10:Summary of Avista Idaho Electric Verified Ex Post Savings by Program Year
I Ex Ante Ex Post 7---
Savings Savings f7Rate
2017 0.60 0.31 51.19%
2018 0.57 0.36 63.33%
2019 0.43 0.50 115.22%
2020 0.41 0.48 118.93%
2021 0.39 0.40 103.32%
Total 2.41 2.06 85.41%
Table 3-11 through Table 3-15 summarizes the Avista Idaho verified electric savings and realization rates
by initiative for each of the program years between 2017 and 2021.
Evaluation Results 44
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 44 of 122

Table 3-11:PY2017 Summary of Avista Idaho Electric Verified Ex Post Savings by Initiative
Standard,Measure, Ex Ante Ex Post Realization
.
Code Savings Savings
Measure Commercial Commissioning Buildings 0.00 0.00 1 0.00%
Standard Industrial Drive Power 0.01 0.02 111.91%
Measure Residential Ductless Heat Pumps 0.01 0.00 10.20%
Code Residential Efficient Homes 0.09 0.09 100.00%
Measure Residential Heat Pump Water Heaters 0.03 0.02 68.73%
Measure Commercial Luminaire Level Lighting Controls 0.00 0.00 0.00%
Code Commercial Other Codes(Commercial) 0.07 0.07 100.00%
Code Residential Other Codes(Multifamily) 0.01 0.01 100.00%
Standard Commercial Other Non-Residential Standards 0.09 0.08 91.43%
Standard Residential Other Residential Standards 0.26 0.00 0.16%
Measure Commercial Reduced Wattage Lamp 0.00 0.00 98.27%
Replacement
Code Residential Residential New Construction/Next 0.01 0.01 96.99%
Step Homes
Measure Residential Retail Product Portfolio 0.00 0.00 42.21%
Measure Residential Super-Efficient Dryers 0.01 0.01 94.03%
Measure Residential Televisions 0.01 0.01 100.00%
Total 0.60 0.31 51.19%
Evaluation Results 45
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 45 of 122

Table 3-12:PY2O18 Summary of Avista Idaho Electric Verified Ex Post Savings by Initiative
Standard,Measure, Ex Ante Ex Post Realization
.
Code Savings Savings
Measure Commercial Commissioning Buildings 0.00 0.00 1 0.00%
Measure Industrial Commissioning Buildings 0.00 0.00 0.00%
Measure Commercial Desktop Power Supplies 0.02 0.02 100.00%
Standard Industrial Drive Power 0.01 0.01 100.00%
Measure Residential Ductless Heat Pumps 0.01 0.00 6.02%
Code Residential Efficient Homes 0.11 0.11 100.00%
Measure Residential Heat Pump Water Heaters 0.01 0.00 57.22%
Measure Commercial Luminaire Level Lighting Controls 0.00 0.00 N/A
Measure Residential Manufactured Homes 0.00 0.00 0.00%
Code Commercial Other Codes(Commercial) 0.08 0.08 100.00%
Code Residential Other Codes(Multifamily) 0.01 0.01 100.00%
Standard Commercial Other Non-Residential Standards 0.02 0.01 63.92%
Standard Industrial Other Non-Residential Standards 0.08 0.08 100.00%
Standard Residential Other Residential Standards 0.19 0.00 0.22%
Measure Commercial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Reduced Wattage Lamp 0.00 0.00 98.89%
Replacement
Measure Industrial Reduced Wattage Lamp 0.00 0.00 98.89%
Replacement
Code Residential Residential New Construction/Next 0.01 0.01 100.00%
Step Homes
Measure Residential Retail Product Portfolio 0.00 0.00 54.86%
Measure Residential Super-Efficient Dryers 0.01 0.01 93.09%
Measure Residential Televisions 0.00 0.00 99.98%
Total 0.57 0.36 63.33%
Evaluation Results 46
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 46 of 122

Table 3-13:PY2O19 Summary of Avista Idaho Electric Verified Ex Post Savings by Initiative
Standard,Measure, Ex Ante Ex Post Realization
.
Code Savings Savings
Measure Commercial Commissioning Buildings 0.01 0.00 1 0.00%
Measure Industrial Commissioning Buildings 0.00 0.00 0.00%
Measure Commercial Desktop Power Supplies 0.00 0.00 79.14%
Standard Industrial Drive Power 0.00 0.01 293.18%
Measure Residential Ductless Heat Pumps 0.01 0.00 4.01%
Code Residential Efficient Homes 0.08 0.12 154.66%
Measure Residential Heat Pump Water Heaters 0.01 0.00 43.16%
Measure Commercial Luminaire Level Lighting Controls 0.00 0.00 0.00%
Measure Residential Manufactured Homes 0.00 0.00 0.00%
Code Residential Next Step Homes 0.05 0.11 236.51%
Code Commercial Other Codes(Commercial) 0.15 0.20 133.91%
Code Residential Other Codes(Multifamily) 0.01 0.00 42.77%
Standard Commercial Other Non-Residential Standards 0.02 0.01 69.19%
Standard Industrial Other Non-Residential Standards 0.05 0.00 0.00%
Standard Residential Other Residential Standards 0.02 0.02 99.67%
Measure Industrial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Reduced Wattage Lamp 0.01 0.00 30.55%
Replacement
Measure Industrial Reduced Wattage Lamp 0.00 0.00 31.71%
Replacement
Measure Residential Retail Product Portfolio 0.00 0.00 11.15%
Measure Residential Super-Efficient Dryers 0.02 0.02 109.48%
Total 0.43 0.50 115.22%
Evaluation Results 47
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 47 of 122

Table 3-14:PY2O2O Summary of Avista Idaho Electric Verified Ex Post Savings by Initiative
Standard,Measure, Ex Ante Ex Post Realization
.
Code _JML Savings Savings
Measure Industrial Certified Refrigeration Energy 0.00 0.00 0.00%
Specialist(CRES)
Measure Commercial Commissioning Buildings 0.01 0.00 0.00%
Measure Industrial Commissioning Buildings 0.00 0.00 41.60%
Measure Commercial Desktop Power Supplies 0.00 0.00 0.00%
Standard Industrial Drive Power 0.00 0.00 0.00%
Measure Residential Ductless Heat Pumps 0.01 0.00 9.35%
Code Residential Efficient Homes 0.06 0.10 161.42%
Measure Residential Extended Motor Products 0.00 0.00 0.00%
Measure Commercial Extended Motor Products 0.00 0.00 0.00%
Measure Residential Heat Pump Water Heaters 0.01 0.00 0.00%
Measure Commercial Luminaire Level Lighting Controls 0.00 0.00 0.00%
Measure Residential Manufactured Homes 0.00 0.00 0.00%
Code Residential Next Step Homes 0.05 0.06 134.25%
Code Commercial Other Codes(Commercial) 0.12 0.17 142.74%
Code Residential Other Codes(Multifamily) 0.01 0.00 52.83%
Standard Commercial Other Non-Residential Standards 0.02 0.01 63.24%
Standard Industrial Other Non-Residential Standards 0.05 0.08 157.01%
Standard Agriculture Other Non-Residential Standards 0.00 0.00 258.22%
Standard Residential Other Residential Standards 0.02 0.02 92.40%
Measure Industrial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Other Strategic Energy Management 0.00 0.00 0.00%
Measure Commercial Reduced Wattage Lamp 0.01 0.00 27.67%
Replacement
Measure Industrial Reduced Wattage Lamp 0.00 0.00 27.49%
Replacement
Measure Residential Retail Product Portfolio 0.02 0.03 114.44%
Measure Residential Televisions 0.00 0.00 0.00%
Total 0.41 0.48 118.4%
Evaluation Results 48
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 48 of 122

Table 3-15:PY2O21 Summary of Avista Idaho Electric Verified Ex Post Savings by Initiative
Standard,Measure, Ex Ante Ex Post Realization
.
Code Savings Savings
Measure Commercial Commissioning Buildings 0.00 0.00 1 0.00%
Measure Commercial Desktop Power Supplies 0.00 0.00 0.00%
Measure Residential Ductless Heat Pumps 0.01 0.00 20.19%
Code Residential Efficient Homes 0.06 0.07 123.85%
Measure Residential Heat Pump Water Heaters 0.02 0.00 0.00%
Measure Commercial Luminaire Level Lighting Controls 0.00 0.00 0.00%
Measure Residential Manufactured Homes 0.00 0.00 0.00%
Code Commercial Other Codes(Commercial) 0.09 0.10 111.55%
Standard Commercial Other Non-Residential Standards 0.02 0.01 62.90%
Standard Industrial Other Non-Residential Standards 0.05 0.08 157.01%
Standard Agriculture Other Non-Residential Standards 0.00 0.00 258.22%
Standard Residential Other Residential Standards 0.02 0.02 102.71%
Reduced Wattage Lamp o
Measure Commercial 0.00 0.00 27.73/
Replacement
Measure Industrial Reduced Wattage Lamp 0.00 0.00 27.73%
Replacement
Code Residential Residential New Construction 0.07 0.08 112.68%
Measure Residential Retail Product Portfolio 0.03 0.04 112.24%
Measure Commercial Window Attachments 0.00 0.00 0.00%
Measure Residential XMP Pumps 0.01 0.00 0.00%
Measure Commercial XMP Pumps 0.00 0.00 0.00%
Total 0.39 0.40 103.20%
3.2.1.3 Avista Idaho Gas Verified Ex Post Savings
The Evaluators summarize the verified natural gas savings and realization rates for Avista within the
state of Idaho by program year in the table below.
Table 3-16:Summary of Avista Idaho Gas Verified Ex Post Savings by Program Year
Ex Ante Ex Post Realization
Year Therms Therms Rate
Savings Savings
2019 43,745 22,808 52.14%
2020 5,678 385 6.79%
2021 15 2,881 152,881 100.00%
Total 202,304 176,074 87.03%
Table 3-17 through Table 3-19 summarizes the Avista Idaho verified natural gas savings and realization
rates by initiative for each of the program years between 2019 and 2021.
Evaluation Results 49
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 49 of 122

Table 3-17.PY2019 Summary of Avista Gas Verified Ex Post Savings by Initiative
Measure, Ex Ante Ex Post Realization
Standard, .
Code Savings Savings
Measure Commercial Condensing Rooftop Units 636 0 0.00%
Code Residential Next Step Homes 43,109 22,808 52.91%
Total 43,745 22,808 52.14%
Table 3-18:PY2020 Summary of Avista Gas Verified Ex Post Savings by Initiative
Measure, Ex Ante Ex Post Realization
Standard, Sector Initiative Therms Therms Rate
Code Savings Savings
Code Residential I Next Step Homes 5,678 385 6.79%
Total 5,678 385 6.79%
Table 3-19:PY2021 Summary of Avista Gas Verified Ex Post Savings by Initiative
Measure, Ex Ante Ex Pos
Standarld, Sector Initiative Therms Therms Rate
Code Savings Savings
Code Residential Residential New Construction 152,881 152,881 100.00%
Total 152,881 152,881 100.00%
3.3 Allocation Methodology Review
Allocation methodology review was a key component of this evaluation in this section. It is the method
by which NEEA splits total regional net market transformation savings between each NEEA funding
utility. The allocation methodology is applicable for each efficiency measure as well as for codes and
standards. As described in the equations above, the allocation of savings is currently calculated using
one of the following two methodologies:
■ Service Territory Methodology
■ Funder Share Methodology
Currently, NEEA allows the utility to choose which of the two methodologies is employed to calculate
utility-level savings in the end-of-year annual reporting of savings.
Idaho Power had elected to report NEEA savings using funder share methodology, as indicated by NEEA
annual reports between 2017 and 2021. Avista had elected to report NEEA savings using service
territory methodology in 2017 and 2018. In 2019,Avista changed their preferred reporting to funder
share methodology. However, NEEA continues to provide estimates of service territory share for each
measure, despite allocation methodology chosen.
Evaluation Results 50
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 50 of 122

NEEA reports both the service territory allocation and the funder share allocation for each measure in
each of NEEA's annual report of savings to each funder utility. During this evaluation work,the
Evaluators compared service territory share to funder share allocation and ultimately used service
territory allocation methodology to estimate total verified savings and cost effectiveness of efforts
benefitting Idaho customers within Avista's and Idaho Power's service territories.
The Evaluators further summarize each methodology in the section below.
3.3.1 Service Territory Allocation
The service territory allocation methodology estimates the proportion of projects completed within a
measure that can reasonably be allocated to a specific funding utility.This is completed by reviewing
and aggregating the source data in a way that preserves the originating location of the projects,which
can include zip code information, city information, county information, or state information.
The Evaluators were unable to review total regional and local program unit values reported by NEEA, as
this data is provided to NEEA under individual non-disclosure agreements with local utilities, Energy
Trust of Oregon, BPA, manufacturers, and market actors. However,the calculations reviewed confirm
that the data NEEA aggregates for use in the annual savings reports contains fields that grant NEEA the
ability to calculate service territory allocation based on either zip-code level data, county-level data, or
state-level data. Therefore, it is possible to estimate net market units for smaller segments of the
Northwest region,which can then be aggregated to the utility service territory for each utility that
currently funds NEEA initiative efforts.
The benefit of this service territory method is that NEEA stakeholders can identify states or regions that
are performing well and are cost-effective, and states or regions that are underperforming and are not
cost-effective. This level of transparency assists NEEA staff and stakeholders by identifying real, unique
barriers to energy efficiency in local regions. Once these areas and barriers are identified,work
performed to remove these barriers benefits the entire region, while creating equitable benefits within
the NEEA service territory.
In order to report transparency of program benefits, it is necessary to estimate savings at a higher
resolution than northwest regional savings. For example, it is recommended to report savings at the
state-level, utility-level, or county-level, if source data permits.As the Evaluators have verified that such
source data exists,the Evaluators recommend that NEEA utilize this resolution of data to more
accurately estimate,track, and report savings to its stakeholders.
3.3.2 Funder Share Allocation
One of the main objectives for this evaluation was to review and validate NEEA's methodology for
allocating co-created savings to Idaho Power Company and Avista Utilities. Currently, NEEA employs a
"funder share" allocation method to allocate claimable savings to each Avista and IPC. NEEA staff
describe the funder share allocation as a "core tenet" of how NEEA allocates savings.This funding
mechanism was built 20 years ago.The following figure displays the current NEEA electric funding share
by organization. It is worth noting that a large portion of the current NEEA funding share is owned by
Evaluation Results 51
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 51 of 122

Bonneville Power Administration, an organization that is not a utility, and therefore serves no electric
customers directly. Despite lack of electric customers,this organization receives claimable energy
efficiency savings through contribution to NEEA.
Figure 3-13: Current NEEA Electric Funding Share by Organization'
Chelan PUD(1.0%) Tacoma Power(.95%)
Clark PUD (1.3%) Snohomish PUD(0.7%)
PacifiCorp(2.6%)
Seattle City Light(3.5%)
Northwestern Energy(4.0%)—
Avista Utilities(5.7%) ,
b'
Bonneville Power
Administration (37%)
Idaho
Power(9.2%)
Energy Trust(20.2%)
The calculation NEEA built to estimate the allocation share of funding to each utility is built on the
following components and assumptions:
1. A forecast of load growth: Estimated load growth during funding cycle, determined by Pacific
Northwest Utilities Conference Committee (PNUCC) and Northwest Power and Conservation
Council.
2. Number of retail customers: Estimated by Energy Information Administration (EIA) Form 861 at
the time of establishing funding shares for a funding period. A 12.5%weighting is applied to this
value.
3. Retail energy sales: Native electricity sales to "bundled" retail customers as reported in the EIA
Form 861. All wholesale "energy only" or"transmission only" sales are excluded.An 87.5%
weighting is applied to this value.
8 https://neea.org/resources/neea-current-funder-share-by-organization
Evaluation Results 52
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 52 of 122

4. Cap on funding share increases:To minimize the impacts to any one direct funder, a maximum
40%funder share growth cap is applied for each investor.
The funder share methodology above is founded on the following NEEA principles:
■ Keep the alliance and collaboration between the funding utilities and regional market actors
intact;
■ Be fair and equitable to funders;
• Equitably distribute burden of cost and allocation of benefits;
■ Incorporate number of utility customers and loads to address utilities dominated by few large
industrial customers; and,
■ Provide funding diversification.
These allocation shares are determined at the beginning of NEEA's 5-year program cycle and are
invoiced to each utility on a quarterly basis. In the event that a funder is lost, the total funding amount is
recalculated such that other funders' dollar amounts are unchanged and total funding is reduced. In the
event that a funder is gained,the total funding amount is recalculated such that other funder's dollar
amounts are unchanged and total funding is increased. The NEEA Board reviews the funder allocation
methodology policy during the first year of each funding cycle.
The savings due to NEEA regional market transformation is allocated to utility stakeholders using each
utility's current funding share (Washington, Oregon, Montana, and Idaho, combined). Therefore, since
Avista contributed 5.7%of NEEA's funding to the total NEEA-region,Avista is allocated 5.7%of savings
achieved through NEEA. To estimate Avista savings within the Avista's service territory in Idaho, NEEA
allocates 30%of total Avista regional savings to Avista Idaho territory.To estimate Idaho Power savings
within the Idaho Power service territory in Idaho, Idaho Power internally allocates 95%of savings to
Idaho and 5%of savings to Oregon.The Evaluators followed these breakouts when allocating savings to
the state of Idaho.
The following tables summarize the funder allocation share values between 2017 and 2021 assigned to
Avista and Idaho to estimate savings within the state of Idaho.
Table 3-20:Avista Electric Funder Share
Business Plan Avista Total Avista Idaho
Funding Share Funding Share*
2020-2024 5.65% 1.69%
2015-2019 5.77% 1.73%
2010-2014 5.56% 1.67%
Prior 3.95% 1.19%
*NEEA allocates 30%of overall Avista funder share to Avista service territory in Idaho
Table 3-21:Avista Gas Funder Share
Business Plan Avista Total Avista Idaho
Funding Share Funding Share*
2019 15.63% 3.37%
2020-2021 12.04% 3.55%
Evaluation Results 53
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 53 of 122

*NEEA allocates 30%of overall Avista funder share to Avista service territory in Idaho
Table 3-22:Idaho Power Electric Funder Share
Idaho Power Idaho Power
Business Plan Total Funding Idaho Funding
Share Share*
2020-2024 9.23% 8.77%
2015-2019 8.01% 7.61%
2010-2014 8.67% 8.24%
Prior 6.42% 6.10%
*Idaho Power allocates 95%of overall Idaho Power funder share to the Idaho Power service territory in Idaho
The values presented in the tables above were cross verified by reviewing total annual dollars invoiced
by NEEA to Avista and to IPC, as well as reviewing each NEEA annual savings report and associated
funder share value attributed to each measure.
3.3.3 Allocation Methodology Findings and Recommendations
During this evaluation work,the Evaluators reviewed whether the high-level allocation strategy is
reasonable for Idaho stakeholders and whether the funding share is accurately represented for each
organization through documentation and invoices. Although the Evaluators were unable to cross-
reference NEEA-aggregated sales and utility data due to non-disclosure agreements between NEEA and
utility stakeholders in the Northwest region, we reviewed whether the funder share allocation method
is reasonably estimates actual energy efficiency product uptake documented in sales data.
It is critical to understand that the funder share allocation methodology allocate a proportion of the
costs of NEEA's efforts to be invoiced to the utility, despite initiative focus, initiative service, or
customer/regional targeting.This means that savings from Washington are allocated to Montana, Idaho,
and Oregon based on each utility's funder share. For Idaho,this methodology underestimates observed
local service territory savings while simultaneously overestimating out-of-state energy savings.
In order to report transparency of initiative benefits, it is necessary to estimate savings at a higher
resolution than northwest regional savings. For example, it is recommended to report savings at the
state-level, utility-level, or county-level, if source data permits.
The Evaluators were unable to review total regional and local program unit values reported by NEEA, as
this data is provided to NEEA under individual contract with local utilities, Energy Trust of Oregon, BPA,
manufacturers, and market actors with NDA's. However, NEEA confirms that the data provided from
each of these stakeholders includes data at the zip code-level resolution. Therefore, it is possible to
estimate net market units by zip code, which can then be aggregated to the utility service territory for
each utility that currently funds NEEA initiative efforts.
The Evaluators also estimated Idaho local program units using the service territory allocation share.This
assumption assumes that the aggregated local program units from all utilities funding NEEA displays
similar distribution to the total regional units distributed across the Pacific Northwest region. In the case
that NEEA has utility-specific local program unit estimates,those values should be used instead.
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The funder share methodology and the service territory methodology do not rely on the same inputs.
For example, the funder share methodology attempts to estimate utility regional growth in demand
requirements, number of customers, and retail energy sales.This is then applied to program savings,
regardless of the actual observed geographic distribution of measure completes. However,the service
territory methodology does not attempt to forecast future growth. Instead, it estimates the proportion
of total project completions that actually occurred during the evaluation period in question by
summarizing,to the highest detail possible with the data provided,the total aMW most likely to have
been saved within the Idaho Power or Avista service territory for the specific program and measure in
question.
Therefore,the funder share methodology and the service territory methodology do not share any
relationship or interaction.The Evaluators are unable to estimate how selection of service territory
allocation rather than funder share allocation would change the magnitude of savings for a program
without additional information, such as the type of program being claimed,the regional distribution of
measure completes in which savings are being claimed, and the utility service territory in which savings
are being claimed. Each of these considerations have the ability to cause an increase or decrease in
savings.
Based on the findings detailed above,the Evaluators present the following findings and
recommendations based on our review of NEEA's allocation methodology:
Table 3-23:Summary of Allocation Share Findings and Recommendations
Findings Recommendations
Finding#1: Utilities that fund NEEA can choose
whether savings are reported by allocation share
methodology or service territory methodology.The
allocation share methodology overrepresents out-
of-state and out-of-service territory savings across
measures,codes,and standards while
simultaneously underrepresenting in-state and in-
service-territory savings across measures, codes,
and standards. However,the service territory
methodology accurately represents benefits Recommendation#1:The Evaluators recommend
directed to Avista and Idaho Power customers Avista and Idaho request NEEA to report annual
within the state of Idaho. savings via the service territory methodology for
Finding#2:The data NEEA utilizes to estimate net each measure claimed by NEEA for Idaho Power
market savings is available at resolutions that allow electric,Avista electric,and Avista gas.
NEEA to estimate precise savings for each utility
service territory.
Finding#3:The Evaluators found that the
methodology in which savings were estimated
across measures were inconsistent. For some
measures,service territory methodology was used,
and for others,funder share allocation methodology
was used.
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Findings Recommendations
Finding#4: NEEA prioritizes cost-effective savings in
terms of regional benefit.Therefore,savings and Recommendation#2:The Evaluators recommend
cost-effectiveness are distributed across the region that Avista and Idaho Power request annual
evenly,despite observed distribution of savings savings reports to include estimates of
across states.Although this philosophy has merit, administrative costs,incentive costs,and non-
more precise estimates of utility-level and program- incentive costs by service territory.This will allow
level savings help NEEA's stakeholders relay relevant each utility to calculate more accurate cost-
savings and cost-effectiveness results to their effectiveness tests for each initiative to determine
respective regulatory commissions.This remains whether extension of funding is a viable option
critical, due to some state-level commission orders within each utility's regulatory environment.
to pursue all cost-effective energy efficiency efforts.
Based on the findings and recommendations of allocation methodology above,the remainder of the
report estimates Ex Post electric and natural gas savings for NEEA efforts using the service territory
methodology.The service territory allocation values are estimated by NEEA using confidential program
and sales data from various organizations within the Pacific Northwest.Although the Evaluators are
unable to review or replicate these values,the Evaluators have reviewed NEEA's service territory
allocation methodology and find the steps to be reasonable.
3.4 Cost Effectiveness Methodology Review
Although the Evaluators calculated cost effectiveness for this evaluation work independently from
NEEA's cost effectiveness procedures and assumptions, the Evaluators provide in this section a
comparison of cost effectiveness methodology between NEEA and Idaho Power and Avista.
In response to a request for cost effectiveness methodology documentation, NEEA delivered the
following information:
■ NEEA's 2021 portfolio cost effectiveness analysis
■ NEEA's Electric Cost Effectiveness Operational Guidelines
■ 2022 Q1 and Q2 Cost Effectiveness Advisory Committee PowerPoints summarizing NEEA
introduction to savings and cost effectiveness procedures
Within NEEA's Electric Cost Effectiveness Operational Guidelines document, NEEA states:
"NEEA's purpose is to look at the total societal impact of transforming a market to ensure that
the regional investment is an appropriate use of funds for the long term.Working under this
perspective NEEA considers all incremental quantifiable costs and benefits of the total regional
savings achieved through transformation, regardless of who accrues them. Ultimately, NEEA, as
a regional organization, is attempting to answer the question: "will costs to society be reduced
relative to an alternate resource?"
The Evaluators note that NEEA's procedures to include total regional savings in NEEA's cost effectiveness
calculations is in direct opposition to the RTF's Guidelines in which "costs and benefits should reflect the
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differences between the efficient and baseline cases."9 This methodology does not accurately represent
the cost effectiveness of NEEA activities, rather,the cost effectiveness of NEEA activities in combination
with naturally occurring baseline as well as locally incented measures through local utilities. NEEA's
current cost effectiveness methodology essentially estimates the cost effectiveness of total current
gross, non-incremental energy savings for the entire Northwest region, effectively double counting the
benefits and costs already attributed to utilities.The Evaluators conclude that NEEA's current
methodology for calculating cost effectiveness does not accurately reflect NEEA contributions.
In addition to the difference in methodology summarized above,the Evaluators compare and contrast
NEEA's and Idaho Power and Avista cost effectiveness methodology in the table below.The NEEA Cost
Effectiveness Methodology column indicates the methodology NEEA employs to calculate portfolio cost
effectiveness for each planning period. The Idaho Power/Avista Cost Effectiveness Methodology column
indicates the methodology the Evaluators employed to estimate cost effectiveness for NEEA-related
activities in the Idaho Power and Avista service territories for this work.
Table 3-24: NEEA and IPC/Avista Cost Effectiveness Methodology Comparison
Input NEEA Cost Effectiveness Methodology Idaho Power/Avista Cost Effectiveness
Cost Test TRC UCT
■ Energy-related costs avoided
by the utility ■ Energy-related costs avoided
■ Capacity-related costs by the utility
avoided by the utility, ■ Capacity-related costs
Benefits Included including generation, avoided by the utility,
transmission,and distribution including generation,
■ Additional resource savings transmission,and distribution
(non-energy benefits)
■ 10%conservation adder
■ Program overhead costs ■ Program overhead costs
Costs Included ■ Program installation costs ■ Utility/program administrator
■ Incremental measure costs incentive costs
Source of Avoided Costs 6t"or 7t" Power Plan Avoided costs from each utility IRP
Total Regional: includes gross costs
Net Market: includes net costs and
and benefits within the total region, benefits accrued by the utility's
Scope of Costs/Benefits regardless of who accrues it,or how it tracked.This includes only local
is accrued.This includes units program units with naturally occurring
categorized as naturally occurring
baseline removed.
baseline units and local program units.
s https://rtf.nwcouncil.org/rtf-operative-guidelines/
10 Idaho Power and Avista methodology in regards to this evaluation.
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Input NEEA Cost Effectiveness Methodology Idaho Power/Avista Cost Effectiveness
Formally analyzed for each market
transformation initiative in the Market
Development phase, listed below
(codes and standards are not included
in NEEA cost effectiveness portfolio
testing) Analyzed for each measure,standard,
1. Efficiency Measures: or code in which net market effect
Programs Included in savings are claimed, listed below:
a. Manufactured
Portfolio 1. Efficiency Measures
Homes
b. Luminaire Level 2. Standards
Lighting Controls 3. Codes
c. Heat Pump Water
Heaters
d. Retail Product
Portfolio
Calculated based on estimated Calculated based on unit/savings
Period of Analysis portfolio savings during the 20-year achieved for each calendar year
planning horizon. evaluated,separately.
As seen in the table above,the methodology employed by NEEA significantly differs from the
methodology the Evaluators employed for both Idaho Power and Avista.The Evaluators aligned cost
effectiveness methodology for Idaho and Avista to the procedures the utilities employ to report cost
effectiveness of the utility portfolio to Idaho Commission each year.These methodologies portray large
differences in inputs, scope of costs and benefit, definition of'portfolio', and period of analysis. Because
these large differences exist,the Evaluators recommend that Idaho Power and Avista continue to
evaluate cost effectiveness of NEEA impacts internally, and separate from NEEA cost effectiveness
results.
3.5 Utility Staff Interview Results
As part of this work,the Evaluators met with representatives from Idaho Power, Avista, and NEEA to
discuss NEEA's market transformation work.The Evaluators also spoke with each of the Idaho utilities to
gather additional information for the motivations for the evaluation of NEEA's initiatives.The
conversations with the utility staff largely focused on:
■ Utility staffs' concerns towards NEEA's services and methodology;
■ Utility staffs' understanding of NEEA's current savings allocation and cost effectiveness models;
and,
■ Utility staffs' perceived benefits of NEEA's regional market transformation efforts.
The conversations with NEEA sought to better understand NEEA's operations;their baseline savings,
savings allocation, and cost effectiveness models; as well as their opinions of the current market climate.
This section summarizes the key findings from these interviews, highlighting areas of gaps in agreement
or understanding across the three parties.
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3.5.1 Cost Effectiveness Advisory Committee
Before summarizing the results of the staff interviews,the Evaluators find it necessary to outline the
Cost-Effectiveness Advisory Committee (CEAC).The CEAC is a committee consisting of NEEA funding
stakeholders with the objective of reviewing and advising NEEA staff on methods, data sources, and
inputs for use in NEEA's cost-effectiveness analysis and savings reporting. The Committee, composed of
NEEA funders and additional regional stakeholders, meets quarterly to track and review components of
planned and completed market research and evaluation work. CEAC's responsibilities include:
1. Review and advise regarding NEEA cost-effectiveness and savings information to inform annual
reporting
2. Review and advise regarding market transformation cost and savings measurement and
estimation methods
3. Review evaluation findings that affect cost and savings information to inform annual regional
tracking and reporting purposes
4. Work with your organization to provide NEEA staff with relevant incentive data for regional
tracking and reporting purposes
5. Review and advise regarding new market research and evaluation methodologies
Avista staff and Idaho Power staff participate in the quarterly CEAC meetings.
NEEA provided the following documentation regarding the purpose of the CEAC and content of the CEAC
meetings:
■ Cost Effectiveness Advisory Committee Charter: Describes CEAC's purpose, responsibilities,
membership, meeting schedule, and charter review schedule
■ Q1 and Q2 2022 CEAC meeting slides
In addition,the Evaluators asked NEEA Staff,Avista staff, and Idaho Power staff to describe the purpose
of CEAC,the content of CEAC meetings,the frequency of CEAC meetings, and thoughts as to how CEAC
meetings can be improved.
The Cost Effectiveness Advisory Committee Charter document provided by NEEA supports NEEA's
perspective regarding the purpose of CEAC meetings to be focused on reviewing and advising NEEA cost
effectiveness and savings information towards annual reporting. In addition,the first slides in each of
the 2022 CEAC meeting slides reiterate the direct responsibilities of the CEAC to review and advise NEEA
on cost effectiveness and savings information used towards annual reporting. However,the slides
following summarize year-over-year program market progress,forecasted number of units vs. actual
number of units, and overall market growth for each measure, and co-created savings rather than the
specific inputs and assumptions included in those values.The Evaluators reviewed each document for
reference to codes and standards assumptions, however, mention of these topics were not included at
detail greater than forecasted savings.
Although the Evaluators did not review all CEAC meeting slides from 2017 through 2022,the Evaluators
asked NEEA and utility staff to describe CEAC's purpose and the content of CEAC meetings to build a
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more complete narrative of CEAC understanding. Through these in-depth interviews, NEEA staff
indicated that the meetings are provided to allow utilities to question and provide recommendations for
assumptions, inputs, and results. However,the Evaluator found that utility staff described the CEAC
meetings as informative.
3.5.2 Evaluation Motivation
Idaho Power and Avista launched an evaluation to test the cost-effectiveness of NEEA's market
transformation services. Idaho Commission staff have noticed that an increasing portion of the shared
savings the Idaho utilities receive from NEEA's efforts stem from Washington and Oregon based codes
and standard changes. As a result, commission staff"is concerned that NEEA claims savings it is not
directly responsible for"and that "to support the continued funding of NEEA, an independent EM&V
should be conducted to clarify the savings NEEA claimed plus the allocation and cost effectiveness of
those savings to its member utilities based on the utilities'DSM avoided cost" (IPUC Order Nos. 35129
and 35270). Utility staff noted that a large portion of their energy efficiency-related budget is devoted to
NEEA—one that is continually increased year after year--and "if NEEA is no longer cost-effective after an
independent EM&V is conducted, the[companies]should reexamine its continued participation" (IPUC
Order Nos. 35129 and 35270).
Both sets of utility staff stated that they recognize the value and importance of NEEA's regionally-
focused philosophy and acknowledge that NEEA's model depends on collaboration from as many
utilities as possible within the region to succeed.The utility staff noted that NEEA began as a regional
effort that sought to increase the market power of the four states through an alliance; it was founded
on the notion that "if it's good for one area, it's good for all the areas and therefore the savings, the
benefit of the program should be recognized regionally rather than to a specific jurisdiction or state"
(utility staff). According to NEEA staff,when combined into a four-state region,the Pacific Northwest
represents 5%of the national US market;they emphasize that although 5% may seem low, "with a
consolidated, aggregated voice in that marketplace, it's pretty amazing what we've been able to ask
from the national market actors"(NEEA staff). Utility staff cited the residential and commercial building
stock assessments and other regional research efforts NEEA manages are useful in their initiatives and
analyses. However, utility staff indicated they are skeptical of NEEA's customer-focused initiatives,
noting that these initiatives overlap with their own programs. Utility staff explained they would prefer
NEEA to focus more on upstream programs and the manufacturer and distributor levels of the supply
chain. In general, utility staff recognize NEEA's value and the importance of regional collaboration, and
see to ensure Idaho residents are directly benefitting from NEEA's efforts.
3.5.3 NEEA's Market Transformation Model
NEEA staff explained that NEEA stemmed from the recognition that"utility programs are seeking to
influence consumer behavior, ultimately, which includes the whole supply chain that deliver those
products and services to consumers. And if we're going to do that, we need to understand better what
are the mechanisms that bring those products and services to market. What are the things that
consumers think about when they're deciding to buy those things and what are the sort of other
dimensions to the problem?"(NEEA staff).
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At its inception, NEEA achieved funding from various utilities from four states in the Pacific Northwest—
Washington, Oregon, Idaho, and Montana—as well as support from those states' regulatory
commissions, consumer groups, and trade associations. Since NEEA's original three-year pilot phase in
the late 1990s, it has received approval and funding on a five-year cycle. NEEA depends on this longer
funder circle, as market transformation work takes time (typically viewed on a 20-year cycle),therefore
the benefits are not seen immediately.
When explaining their model, NEEA staff use a traditional S-curve to demonstrate the "diffusion of
innovation theory" in which a new technology enters the market at the bottom end of the spectrum, is
first adopted by a specific set of people known as "innovators,"followed by"early adopters," and
eventually hits the mainstream market and becomes standardized via code and standards changes.
NEEA staff explain that their role is to accelerate market adoption and get new technologies into the
mainstream market stage of the S-curve quicker. When NEEA conducts market transformation work,
they focus in on what it will take "to make market adopt[this product]at a high rate?...[we're]doing
market characterization work, [we're]doing market test studies to see what kind of things[we]can do to
help overcome barriers to market adoption"(NEEA staff).
When forecasting their baseline market transformation calculations, NEEA works with third-party
evaluators to collect data on current adoption rates and market trends. NEEA staff noted that they
develop a baseline picture for every initiative in their portfolio and use this data to determine which
initiative to move forward with. NEEA staff explained that throughout each five-year funding cycle they
focus on a variety of technologies in all stages of the market transformation S-curve, noting that
different technologies move through the curve, and ultimately the market adoption process, at varying
speeds. Once NEEA decides which "energy savings opportunities"to focus on,they "spend a lot of time
and effort often getting the[measure]ready for market adoption in the mainstream market adoption,
sort of the middle of the S-curve. But once the market takes off, [their]basic theory is that the market
itself will drive that adoption because[they]have readied the market to do that"(NEEA).
3.5.4 Defining Savings
Utility staff explained that NEEA uses a funder share savings model to allocate savings. Under this
model,the utilities receive a proportion of savings equal to their share of NEEA's overall budget. Funder
share amounts are determined by each utility's electric load, with higher load utilities contributing more
money than lower load utilities. Funder share amounts are reviewed and approved each funding cycle
by NEEA's CEAC.
Under NEEA's funder share and savings allocation model, it does not matter where the savings were
garnered, and thus Idaho may receive savings that resulted from codes and standard changes that
occurred in Washington or Oregon and not Idaho. Although the Idaho utilities staff understand why
NEEA has structured their savings model in this way,they expressed concern that Idaho residents are
not directly benefitting as much from NEEA's work, and simultaneously are funding efforts that are
benefitting customers out-of-state rather than within Idaho, and as a result, NEEA may not be cost
effective for Idaho. In IPUC Order No. 35270, Idaho Power"stated it believed customers benefited from
its participation in NEEA but expressed that it had mentioned similar concerns to Staffs concerns in a
past case, including its concerns about savings attributed to codes and standards, the allocation method
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of savings to customers, and cost effectiveness impacts from declining avoided cost in the current NEEA
cycle;"this sentiment was echoed by Avista in IPUC Order No. 35129. Staff from both utilities noted that
NEEA provides detailed data about where all their savings are coming from. Utility staff indicated that
NEEA are very organized, and that each year,the utilities are provided an annual spreadsheet with
detailed megawatt hour calculations and rolled up savings for each category. However, utility staff
noted that there is a less transparency regarding how NEEA operationalizes their efforts and
subsequently calculates those efforts into savings. Moreover, utility staff do not always agree with some
of the assumptions NEEA includes in their cost-effectiveness models. For example, NEEA relies on winter
capacity benefits for heat pumps, even though Idaho Power is a summer peaking utility. Additionally,
NEEA uses total regional savings that includes baseline numbers, rather than net market effects.
Lastly, although Idaho Power and Avista staff are members of NEEA's CEAC, neither utility's staff feel
empowered to question NEEA's cost effectiveness calculations during those meetings. Utility staff
described the committee's quarterly meetings as a basic report out of their activities over the past few
months, rather than an opportunity to discuss the models and assumptions.This sentiment contradicts
NEEA's perception of the Cost Effectiveness Advisory Committee meetings. NEEA staff indicated that
CEAC meetings are an opportunity for member utilities, regulators, and other stakeholders to review
and question NEEA's saving assumptions:
"Every year every single input assumption to every savings claim that's reported to the utilities is
reviewed by CEAC. That's a lot of work so I won't represent that everybody on the CEAC looks at
every single assumption, but in theory, everything is open and available for comment and
adjustment as needed."(NEEA staff)
3.5.5 Emphasis on Codes &Standards
Referencing the Idaho Public Utilities Commission Order Nos. 35129 and 35270,one of the main
impetuses of this evaluation has been the perceived shift away from measures and equipment upgrade
programs towards codes and standards changes. When asked about this perceived shift, NEEA staff
explained that their budget has remained consistent across their efforts and that codes and standards
are one of the minority investments when comparing against all other NEEA efforts. One theory that
could explain the disconnect between Idaho utilities' perception that there has been increased focus on
codes and standards, rather than efficiency measures and emerging technologies, is the notion that
much of the time and effort invested into the early stages of market transformation work does not
result is substantial savings. It is feasible, that NEEA continues to invest the bulk of budget on the earlier
stages of the market transformation S-curve, but that these savings are not realized until the codes and
standards stage. When asked how they prioritize projects, NEEA staff noted that they consider the
potential market transformation pathway for all proposed "energy savings opportunities" and prioritize
those opportunities with clear paths.They explained that codes and standards changes are the clearest
indicator of market transformation success, as codes and standards make the energy savings
opportunities standard practice.Thus, NEEA tends to focus their work on energy savings opportunities
that can ultimately result in codes and standards changes.
In addition to concerns that NEEA's work has shifted more towards codes and standards changes,the
Idaho utilities expressed the most trepidation over the fact that much of NEEA's codes and standards
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work is located outside of Idaho. As stated in the IPUC Order No. 35270, commission staff is "concerned
that NEEA claim[s]savings it was not directly responsible for producing"and stated "if savings from
codes and standards are removed, NEEA would not be cost-effective." NEEA staff indicated "[they]pay
attention to what[they]call "regional equity", how do[they]have a balanced portfolio that has a
chance of really delivering the allocation of savings back to the states, not down to the service territory"
(NEEA staff).They went on to explain that they focus on state and regional efforts, rather than service
territory efforts, because markets are not that different between the states and there's a lot"self-
referencing between[their]states" (NEEA staff).
Although NEEA's regional lens makes sense to the Idaho utility staff in theory, utility staff noted that this
theory often falls short in practice. Idaho utility staff emphasized the contrasting political climate of their
state versus that of Washington, Oregon, and Montana, noting that what works in one state may not
work in another state.
When asked about the political differences across the state, NEEA recognized the varying political
climates across their four member states and acknowledged the hesitancy towards codes and regulation
environment currently present in Idaho. However, NEEA staff went on to explain that current political
climate does not worry them, as politics constantly change and evolve: "those political winds blow
irrespective of kind of the code environment and the building construction industry"(NEEA staff).
Because of their future forward visioning and five-year cycle planning, NEEA focuses more on long-term
engagement and relationship building among the construction and manufacturing industries, assuming
that politics will eventually catch up with market demands. NEEA staff indicated that much of this long-
term engagement and relationship building with construction and manufacturing industries involves
training and education, meeting with builders, manufacturers, and enforcement personnel.
NEEA admitted that tracking and quantifying their code-based activities—like training, education, and
outreach—is challenging. They noted "it's an evolving piece" and they have engaged third party
evaluators to help them develop better and more effective metrics for these activities that focus more
on actual behavioral changes that resulted from their activities, rather than just raw attendance and
participation numbers.
3.5.6 Interview Findings and Recommendations
It is evident from these interviews that there is a disconnect between the Idaho utilities and NEEA's
understanding of the purpose and expectations of NEEA's market transformation work.
"This disconnect between when NEEA's budget is being applied to the market and when we're
seeing the benefits and being unable to report those benefits is one really key distinction
between a traditional efficiency acquisition program and what we do in market transformation."
(NEEA staff)
The Evaluators present the following findings and recommendations based on our review of NEEA's
allocation methodology:
Table 3-25:Summary of Allocation Share Findings and Recommendations
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Findings Recommendations
Finding#5:The interviews revealed that although
the three parties fundamentally want to improve
energy efficiency and increase market adoption of
emerging technologies,their preferred approaches Recommendation#3:The Evaluators recommend
to this shared goal vary. Unlike the utilities,who that NEEA work with utilities to best serve each
strive to demonstrate the cost-effectiveness of their state's current regulatory environment and utility's
initiatives and investments on an annual or bi- localized concerns.
annual cycle, NEEA operates on a five-year funding
cycle,which is different than the typical annual or
biannual utility planning cycle.
Finding#6: NEEA's programs are designed with a
broader constituency in mind than that of its
member utilities.While the Idaho utilities' programs
are targeted to produce benefits for their
ratepayers,—NEEA is tasked with developing
programs that need to consider what is best for the
entire four-state region.At its core, NEEA's ethos
assumes that changes made in one state will
eventually spillover into another state and that in
the long run, regional change will be realized. Recommendation#4:The Evaluators recommend
Finding#7: NEEA currently allocates code savings via that NEEA track progress for each code change
funder share methodology,which estimates a relative to administrative dollars spent towards
proportion of total NEEA funding to each utility state-level codes and associated energy savings
based on number of electric retail customers and accrued by each state-level code.With the 20-year
overall load.Therefore,savings from code adoption market transformation in mind,the service-
in Washington State are in-part assigned to Idaho. territory-level savings will still accrue over the 20-
The Evaluators found that out-of-state code building year horizon, however, using this methodology,
savings are currently being attributed to Idaho actual market transformation effects of co-created
utilities.The Evaluators are skeptical that spillover savings will be more accurately tracked.
from out-of-state code changes result in energy
savings within the state of Idaho.Although the
barriers to code adoption from one state to the next
may be similar,there is no evidence to suggest that
these learnings transfer to observable and
measurable savings. NEEA has stated that starting in
2022,code savings will be allocated via service
territory allocation.
Finding#8:The NEEA Cost Effectiveness Advisory
Committee(CEAC) meets quarterly with the NEEA
objectives to provide space for discussion around
results of recently completed evaluation, progress of
field studies, relevant updates to programs,and
acceptance or questioning of NEEA methodology
towards calculation of savings.
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The remainder of this report delivers the quantitative analysis of NEEA's claimable savings within the
state of Idaho along with the associated cost effectiveness tests.The Evaluators balanced
acknowledgments that NEEA's regional efforts provide intangible, and often difficult to quantify benefits
to its member states, along with the recognition that the Idaho utilities want to invest their efforts into
activities that are best for their customers within their service territories.
3.6 Impact Evaluation Results
In this section,the Evaluators summarize the verified savings for each Idaho Power and Avista for each
program year between 2017 and 2021, summarized by:
■ Efficiency measures
■ Standards
• Codes
3.6.1 Efficiency Measures
The Evaluators reviewed savings attributed to the efficiency measures in each of the 2017 through 2021
annual NEEA reports to each Idaho Power and Avista. In the table below, the Evaluators summarize the
energy efficiency measure initiatives NEEA has claimed savings for between 2017 and 2021.
Table 3-26: NEEA Code Initiatives
Initiative I
Ductless Heat Pumps Ductless heat pumps
Heat Pump Water
Heat pump water heaters
Heaters
Air purifiers
Clothes washers
Retail Product Portfolio Freezers
Soundbars
Televisions
Residential Window AC
Super-Efficient Dryers Clothes dryers
Televisions Televisions
Manufactured Homes HUD code/NEEM 2
Residential Lighting CFL bulb in existing
LED bulb in existing
Extended Motor Residential hydronic heating circulation w/EE ECM
Products Residential circulator pumps with EE ECM/motor
XMP Pumps DHW ECM circulator
Commercial Commissioning Nonresidential new construction commissioning
Buildings Retro commissioning commercial existing
Evaluation Results 6S
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Initiative
Luminaire Level
Lighting Controls Luminaire level lighting controls
Reduced Wattage Lamp 25W 4ft T8s
7 Replacement 28W 4ft T8s
Building Operator Building operator certification
Certification Expansion
Desktop Power ENERGY STAR desktop
Supplies
Other Strategic Energy
Strategic energy management
Management
Extended Motor Commercial hydronic heating circulation w/EE ECM
Products Commercial circulator pumps with EE ECM/motor
Commercial variable speed clean water pump
Window Attachments Commercial secondary windows
XMP Pumps DHW ECM circulator
Certified Refrigeration Savings from projects submitted by Certified Refrigeration
Energy Specialist(CRES) Energy Specialists
Commissioning Nonresidential new construction commissioning
Industrial
Buildings Retro commissioning industrial existing
Other Strategic Energy
Strategic energy management
Management
Reduced Wattage Lamp 25W 4ft T8s
Replacement 28W 4ft T8s
NEEA claimed efficiency measure savings for measures completed in Washington, Oregon, Montana,
and Idaho. Instead of claiming 100% savings for all efficiency measures completed in the region, NEEA
nets out the number of measures completed through local utilities and naturally occurring baseline.
To calculate verified savings, the Evaluators verified local program units and baseline units were netted
out correctly. Where discrepancies were identified, the Evaluators updated the Ex-Post formulas to
correctly account for NEEA influence values.
The Evaluators also removed non-Idaho federal measure savings from all standards initiatives to
estimate savings that benefit Idaho customers directly.Therefore, this section reports verified efficiency
measure savings accrued within the state of Idaho only. The Evaluators summarize verified savings and
cost effectiveness results in the tables below using service territory allocation methodology.
The sections below detail the reviews completed to estimate verified savings through NEEA code efforts:
Impact methodology review
Cost effectiveness results
Findings and recommendations
3.6.1.1 Impact Methodology Review
In this section,the Evaluators summarize findings and recommendations for each of the following
components towards verified impact results of NEEA's energy efficiency measures:
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■ Database and document review(Section 3.6.1.1.1)
■ UES review(Section 3.6.1.1.2)
■ Market transformation baseline review (Section 3.6.1.1.3)
■ Funder share methodology review(Section 3.6.1.1.4)
3.6.1.1.1 Database and Document Review
The Evaluators reviewed the 2017-2021 annual savings reports for Avista electric,Avista gas, and Idaho
Power electric to identify and address any inconsistencies with data tracking methods and opportunities
to improve year-over-year tracking of NEEA efforts.
The Evaluators found during database review that a variety of fields are empty across measure types (for
example, service territory share, UES, or comment, due to lack of savings claimed for the measure).This
makes verification of values difficult and complicates tracking of a measure progress over time.The
Evaluators summarize the missing values further in Appendix D. The Evaluators recommend that
measure-level values are detailed as accurately as possible, and that each field is completed in the
workbook, whether or not regional net units exist.This allows for year-over-year tracking of regional
units, baseline units, retirement units, and unit energy savings values over time.
Additionally,the Evaluators found that for some measures, the net regional unit calculations were
completed incorrectly.Therefore, the local program units, baseline units, and retirement units were
incorrectly netted out of total regional net savings. For some measures,this change resulted in lower
savings, and for others,this change resulted in higher savings.
The Evaluators also note that the distribution of baseline and retirement units differ across total
regional units and local program units.That is,for some measures, NEEA estimates that a large
proportion of local program units are baseline.The Evaluators raise concern for this assumption, as local
program units are incentivized, and free ridership of programs is also tracked by local utilities. It is
unreasonable to assume that locally incentivized, rebated measures display the same free ridership as
non-incentivized measures in the region.Therefore,the Evaluators calculated verified net energy
savings assuming that distribution of baseline units is equal, proportionally to each total regional units
and local units.The Evaluators recommend, however,that NEEA integrate more accurate assumptions
regarding free ridership to estimate baseline units within locally incentivized units.
3.6.1.1.2 UES Review
The Evaluators reviewed the following documents and spreadsheets for this evaluation work:
■ 2017-2021 annual savings reports for Avista electric,Avista gas, and Idaho Power electric
■ Regional Technical Forum (RTF) UES workbooks
■ Consumer products UES methodology documentation
■ Field studies completed
■ Engineering algorithms utilized by NEEA
The Evaluators reviewed each document listed above in order to identify and address any
inconsistencies in UES value application and engineering algorithms employed by NEEA to estimate total
regional savings.
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The Evaluators found that for the efficiency measures,the majority of measure UES are referenced from
the RTF workbooks,weighted to regional climate zones, average household heating type, and average
square footage.The majority of measure savings are also reviewed by third-party evaluators in order to
verify correct per-unit savings allocation. Due to the high-level of third-party evaluator reviews
conducted for each of the claimed efficiency measures,the Evaluators focused on the application of the
UES values within the annual workbook rather than the validity of the UES themselves.
3.6.1.1.3 Market Transformation Baseline Review
Calculates a naturally occurring baseline for each initiative in order to track the market transformation
of each product in order to follow the market transformation S-curve displayed in Figure 3-2. NEEA
models the counterfactual scenario of market potential that demonstrates how the market would have
progressed without NEEA and utility intervention. NEEA accomplishes this by conducting market
characterization studies early in program design, conducting large customer survey efforts, and
collecting data which identifies trends of current level of practice.
In the case that an event has occurred which has changed the market transformation of a product, for
instance, a federal standard is implemented which updates the product's minimum efficiency, NEEA
reconfigures the model which forecasts naturally occurring baseline.
The Evaluators found that third-party evaluations are completed for the majority of modeled measure
market transformation baselines. The Evaluators reviewed the evaluation reports and concluded that
the market transformation baseline is thoroughly reviewed and defended.Therefore,the Evaluators
focused on how the market transformation baselines are integrated to the annual savings workbook
rather than investigating the assumptions involved in the creation of the baseline itself.
3.6.1.1.4 Funder Share Methodology Review
As described in Section 3.3,the Evaluators calculated verified savings using the service territory
allocation methodology.The service territory values were calculated by NEEA using confidential datasets
from NEEA stakeholders.The Evaluators were unable to review the data or replicate the service territory
values because the originating data is delivered to NEEA with non-disclosure agreements.The Evaluators
used the service territory values as displayed in the NEEA annual workbooks.
The Evaluators note that NEEA calculated Ex Ante savings for energy efficiency measures using a mix of
service territory share and funder share allocation for the measures it claims savings for.The rationality
behind using one methodology over the other is unclear.
As described previously,the Evaluators conclude that the funder share methodology does not accurately
reflect benefits claimed by Idaho utility customers.Therefore,the results displayed in this report reflect
service territory savings.Additionally,the Evaluators recommend that Avista and Idaho Power request
NEEA utilize service territory methodology for future NEEA annual savings reports in order to calculate
energy savings and cost-effectiveness testing for the Commission.
3.6.1.2 Verified Ex Post Savings
The Evaluators summarize verified Ex Post efficiency measure savings results by utility,fuel type, and
program year in the tables below.The Evaluators provide initiative-level savings in Appendix A.
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Table 3-27:Summary of Idaho Power Idaho Electric Verified Ex Post
Efficiency Measure Savings by Program Year
Ex Ante Ex Post Realization
Year aMW aMW Rate
Savings Savings
2017 0.31 0.12 39.20%
2018 0.40 0.15 38.34%
2019 0.28 0.12 43.78%
2020 0.39 0.14 37.32%
2021 0.42 0.15 36.93%
Total 1.78 0.69 38.78%
The overall verified realization rate for Idaho Power measure efforts due to NEEA was 39%. The
discrepancy between Ex Ante and Ex Post savings are largely due to the difference between funder
share allocation and service territory share among measures. Funder share allocation for Idaho Power
ranged between 6.42% and 9.23%, as displayed in Table 3-22. In contrast,the service territory allocation
share ranged between 0%and 16%for individual measures.The overall impact of this change resulted in
a low realization rate, indicating that the majority of claimed measure savings accrue outside the state
of Idaho.
Table 3-28:Summary of Avista Idaho Electric Verified Ex Post
Efficiency Measure Savings by Program Year
Ex Ante Ex Post Realization
Year aMW aMW Rate
Savings Savings
2017 0.06 0.03 57.68%
2018 0.06 0.04 73.37%
2019 0.06 0.03 46.97%
2020 0.08 0.03 39.76%
2021 0.08 0.04 48.21%
Total 0.34 0.18 52.11%
The overall verified realization rate for Avista electric measure efforts due to NEEA was 52%. Similarly,
the discrepancy between Ex Ante and Ex Post savings are also due to the difference between funder
share allocation and service territory share among measures. Funder share allocation for Idaho Power
ranged between 1.19% and 1.73%, as displayed in Table 3-22. In contrast,the service territory allocation
share ranged between 0%and 19%for individual measures.The overall impact of this change resulted in
a low realization rate, indicating that the majority of claimed measure savings accrue outside the state
of Idaho.
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Table 3-29:Summary of Avista Idaho Gas Verified Ex Post
Efficiency Measure Savings by Program Year
Ex Ante Ex Post Realization
Year Therms Therms Rate
Savings Savings
2019 636 0 0.00%
2020 0 0 N/A
2021 0 0 N/A
Total 636 0 0.00%
NEEA allocated natural gas savings to Avista within the Idaho region for the program year 2019. Program
years 2020 and 2021 did not claim savings for any measure initiatives for Avista Idaho gas measures. In
2019,the only initiative NEEA claimed energy savings for was the condensing rooftop unit initiative.The
condensing rooftop units initiative estimated 636 Therms allocated to Avista Idaho via the funder share
methodology. However,the associated service territory allocation for these measure completes was
zero, and therefore, 0 Therms savings are verified to have benefitted Idaho customers for this initiative.
3.6.1.3 Cost Effectiveness Results
The Evaluators found that NEEA calculates cost-effectiveness of its portfolio using the total regional
savings rather than the net market effects. NEEA's rationality for this is the following:
"We use the Total Resource Cost test(TRC) to assess the cost effectiveness of a product.
As mentioned in the guidelines, NEEA's purpose is to look at the total societal impact in a
market to ensure that the regional investment is an appropriate use of funds for the long
term. Working under this perspective, NEEA considers all incremental quantifiable costs
and benefits of the total regional savings achieved through transformation, regardless of
where or how they are accrued. This is achieved through a total, regional framework.As
a result, we include data from naturally occurring baseline in order to capture the full
spectrum of costs and benefits for society. Note that the savings rates and costs we use
do account for pre-market intervention baseline estimates, similar to the approach the
Regional Technical Forum uses."(NEEA staff)
The Evaluators determined that this methodology raises concern, and the NEEA cost-effectiveness tests
currently account for all measure, standard, and code completions across the entire region, effectively
double counting local program savings and simultaneously claiming naturally occurring baseline savings.
The Evaluators recommend that Avista and Idaho Power do not implement this methodology, and
instead calculate cost effectiveness using the reported net market effects (which nets out local program
savings and naturally occurring baseline savings).
Additionally, NEEA calculates cost-effectiveness using the current Power Plan, as stated in Section 2.7.
The Evaluators calculated cost-effectiveness using Avista and Idaho Power avoided costs, rather than the
avoided costs presented in the Power Plan
The Evaluators summarize verified cost effectiveness results in the tables below. Further detail of
measure-level cost-effectiveness is provided in Appendix B.
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Table 3-30:Idaho Power Electric Idaho Efficiency Measures Cost Effectiveness by Program Year
Program Year UCT Costs UCT Benefits UCT
2017 $2,186,140.38 $466,619.15 0.21
2018 $2,151,016.22 $463,122.26 0.22
2019 $2,150,393.15 $448,341.19 0.21
2020 $2,215,102.95 $610,854.65 0.28
2021 $2,342,622.29 $602,148.92 0.26
Total $11,045,275.00 $2,591,086.18 0.23
Table 3-31:Avista Electric Idaho Efficiency Measures Cost Effectiveness by Program Year
Program Year UCT Costs UCT Benefits UCT
2017 $497,315 $166,784 0.37
2018 $489,324 $145,951 0.30
2019 $440,264 $140,466 0.32
2020 $366,823 $152,948 0.42
2021 $407,558 $166,540 0.41
Total $2,201,284 $772,688 0.35
Table 3-32:Avista Gas Idaho Efficiency Measures Cost Effectiveness by Program Year
Program Year UCT Costs UCT Benefits UCT
2019 $152,294 $0 0.00
2020 $126,061 $0 0.00
2021 $142,512 $0 0.00
Total $420,867 $0 0.00
Although NEEA provided gas efficiency measure efforts in the form of condensing rooftop units and
efficient gas water heaters,the Evaluators found that none of the savings were allocated within the
Idaho service territory. Therefore, the costs for each program year were distributed entirely towards
code savings, and efficiency measure cost effectiveness for Avista gas Idaho NEEA efforts is not
applicable.
As seen in the tables above, all efficiency measure efforts were found to be not cost effective using
Idaho Power's and Avista's avoided costs and updated verified Ex Post savings within the state of Idaho,
as displayed by the annual measure UCT values ranging between 0.00 and 0.41.
3.6.1.4 Findings and Recommendations
Overall, the efficiency measures Ex Ante savings claimed savings for measures completed in
Washington, Oregon, and Montana—therefore, some measures underestimated Idaho-specific savings,
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while others overestimated out-of-state savings. The overall effect of this change resulted in a lower
than 100% realization rate.
Based on the findings detailed above,the Evaluators present the following findings and
recommendations based on our review of NEEA's efficiency measures:
Table 3-33:Summary of Efficiency Measure Findings and Recommendations
Findings Recommendations
Finding#9:The Evaluators estimated verified Ex Post
aMW for the efficiency measures to display 39%,52%,
and 0%realization rates for Idaho Power electric,Avista
electric, and Avista gas savings within the state of Idaho, The Evaluators reference Recommendation
respectively.The difference in claimed savings and #1:The Evaluators recommend Avista and
verified savings is due to the change to using service
territory allocation rather than funder share allocation. Idaho request NEEA to report annual savings
The efficiency measures category Ex Ante savings via the service territory methodology for each
included savings for measures completed in Washington, measure claimed by NEEA for each Idaho
Power electric,Avista electric, and Avista gas.
Oregon,and Montana—therefore,some measures
underestimated Idaho-specific savings,while others
overestimated out-of-state savings.The overall effect of
this change resulted in a lower than 100%realization rate.
Recommendation#5:The Evaluators
Finding#10:The database review revealed that a variety recommend that measure-level values are
of fields(measure life, UES)were empty across measure detailed as accurately as possible,and that
types due to lack of savings claimed for the measure, each field is completed in the workbook to
which made verification of values difficult and allow for year-over-year tracking of regional
complicates tracking of a measure progress over time. units, baseline units, retirement units,and
unit energy savings values over time.
Finding#11:The database review revealed that NEEA's
current method for distribution of modeled naturally
occurring baseline units between local program and NEEA
efforts is not reasonable.A portion of energy efficient
technology sales are due to naturally occurring baseline.
NEEA nets out modeled naturally occurring baseline in
order to avoid claiming savings for units that would have Recommendation#6:The Evaluators
been sold had no program or NEEA-effort been provided recommend,that NEEA distribute naturally
within the market. However,the method in which these occurring baseline units more equitable
baseline units are netted out is not distributed equitably. between local program units and total
For some measures, NEEA estimates that a large regional units.
proportion of local program units are baseline,and
therefore a larger proportion of the remaining net market
effects is assigned to NEEA efforts.The Evaluators raise
concern for this assumption,as it is unlikely locally
incentivized, rebated measures display the same free
ridership as non-incentivized measures in the region.
Finding#12:The Evaluators reviewed the utilized LIES via
the Regional Technical Forum (RTF)workbooks,field
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study data, and simulation analysis findings and note no
large concerns with NEEA LIES methodology or market
baseline assumptions.
Finding#13:The Evaluators found that NEEA calculates
cost-effectiveness of its portfolio using the total regional
savings rather than the net market effects.The Evaluators
determined that this methodology raises concern,and Recommendation#7: In the case that cost
the NEEA cost-effectiveness tests currently account for all effectiveness tests are completed using
measure,standard,and code completions across the NEEA-reported savings,the Evaluators
entire region,effectively double counting local program recommend that Avista and Idaho Power
savings and simultaneously claiming naturally occurring calculate cost-effectiveness using net market
baseline savings. Because Avista and Idaho Power effects rather than total regional savings, as is
calculate their own internal cost effectiveness tests,this consistent with current regulatory
finding does not impact Idaho Power or Avista reporting. requirements.
However,the Evaluators highlight this finding,as NEEA
savings allocation and cost allocation methods are not
currently consistent with regulatory requirements.
3.6.2 Standards
In the table below,the Evaluators summarize the federal standards NEEA has claimed savings for within
Avista Idaho and Idaho Power Idaho annual reports between 2017 and 2021.
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Table 3-34:NEEA Standards Initiatives
Sector Initiative Measure
Battery chargers
Clothes dryers
Residential Other Residential Standards Central AC
Furnace fans
Heat pumps
Fluorescent lamp ballasts
Air compressors
Beverage vending machines
Ceiling fan light kits
Ceiling fans
Commercial fryers
Commercial PRSVs
Commercial refrigeration equipment
Commercial Other Non-Residential Standards Commercial unitary ACs
Electric motors
External power supply
Rooftop units
Small electric motors
Steam cookers
Walk-in coolers/freezers
Pumps
Fluorescent lamp ballasts
Industrial Drive Power Motors
Industrial Other Non-Residential Standards Air compressors
Pumps
Agriculture Other Non-Residential Standards Pumps
NEEA claimed federal standard savings for measures completed in Washington, Oregon, Montana, and
Idaho. Instead of claiming 100%savings for all federal standard equipment measures completed in the
region, NEEA completes an influence evaluation in which a third-party evaluator estimates the
qualitative and quantitative influence NEEA contributed towards these federal standard updates.The
quantitative value represents the percent of savings from the federal standard update that was
influenced by NEEA.This value is incorporated in NEEA Ex-Ante calculations to estimate the baseline
units.Therefore, if the influence evaluation concludes that NEEA contributed 3%of the code update
energy savings, NEEA estimates that 97% of the total regional units for that measure is equivalent to the
baseline regional units for the measure.The Evaluators reviewed and verified that these values were
integrated correctly in NEEA workbooks. Where discrepancies were identified, the Evaluators updated
the Ex-Post formulas to correctly account for NEEA influence values.
The Evaluators also removed non-Idaho federal standards savings from all standards initiatives to
estimate savings that benefit Idaho customers directly.Therefore,this section reports verified federal
standards savings accrued within the state of Idaho only.
The sections below summarize the reviews completed to estimate verified savings through NEEA code
efforts:
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■ Impact methodology review
■ Staff interview conclusions
■ Cost effectiveness results
• Findings and recommendations
3.6.2.1 Impact Methodology Review
In this section,the Evaluators summarize findings and recommendations for each of the following
components towards verified impact results of NEEA's federal standards:
■ Database and document review(Section 3.6.2.1.1)
■ UES review(Section 3.6.2.1.2)
■ Market transformation baseline review (Section 3.6.2.1.3)
■ Funder share methodology review(Section 3.6.2.1.4)
3.6.2.1.1 Database and Document Review
The Evaluators reviewed each of the supplemental documents provided by NEEA, which included the
following:
■ 2017-2021 annual savings reports for Avista electric,Avista gas, and Idaho Power electric
■ Completed influence evaluations
The Evaluators reviewed each of the documents above to identify and address any inconsistencies with
data tracking methods and opportunities to improve year-over-year tracking of NEEA efforts.
The Evaluators found during database review that a variety of fields are empty across code tracking
data, similar to our finding for efficiency measure database review.The Evaluators summarize the
missing values further in Appendix D. The Evaluators recommend that measure-level values are detailed
as completely as possible.
The Evaluators found that naturally occurring baseline is calculated through "influence evaluations"
completed by third-party evaluations (summarized in the following sections).The Evaluators found that
the influence evaluation findings were not properly integrated into each standard savings estimate,
thereby underestimating baseline units and overestimating overall net market effects.
3.6.2.1.2 UES Review
The Evaluators reviewed each of the unit energy savings (UES)values assigned to each federal standard
in which savings are claimed by NEEA. NEEA utilizes UES values determined by third-party evaluators for
each of the measures claimed. Each measure unit-level savings is weighted by heating and cooling zone
across three housing types (single family, multifamily, and manufactured home), if applicable.These
values are then multiplied by the net market units for each measure after netting out baseline units for
each measure, described in further detail in 3.6.2.1.3.1.The Evaluators summarize the measure-level
standards and UES methodologies employed by NEEA between 2017 and 2021 in the table below.
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Due to the thorough third-party evaluations and estimates of UES verified for use by NEEA,the
Evaluators do not note any concern for discrepancies with the standards UES values applied to estimate
NEEA savings. Instead,the Evaluators focused on the rationality of NEEA's high-level application of
regional units, baseline methodology, allocation methodology, and overall calculations for each Avista
and Idaho Power.
3.6.2.1.3 Market Transformation Baseline Review
This section summarizes NEEA's methodology for estimating naturally occurring baseline for federal
standards in which NEEA contributed.
NEEA does employ baseline models for federal standards updates.Alternatively, an "influence
evaluation" is completed by a third-party evaluator, which summarizes NEEA's overall qualitative and
quantitative influence towards federal standards updates,which result in energy savings. NEEA uses the
quantitative assessment from each of these evaluations to estimate the proportion of total regional
units to categorize towards naturally occurring baseline.Therefore, NEEA nets out any units that would
have occurred in the absence of NEEA efforts towards increasing the energy efficiency of measures
through standard updates.
In the section below,the Evaluators provide further detail of the integration of influence evaluations
towards estimation of federal standards baseline units.
3.6.2.1.3.1 Influence Evaluation Review
The Evaluators reviewed third party independent evaluations of NEEA's "influence"towards updates in
measure standards.The table below summarizes the third-party standards "influence evaluations"
provided by NEEA.
Table 3-35:Summary of NEEA Standards Influence Evaluations
QuantitativeEvaluation Qualitative Assessment
Completed Assessment
NEEA achieved most of the activities
Beverage Vending identified in NEEA's Codes&Standards logic
mode. NEEA submitted comments in the
Machines Standard TRC 2019 20%
Evaluation public review process, including written
comments and participation in public
meetings.
TRC found that NEEA engaged in most of the
Ceiling Fan activities identified in NEEA's Codes and
Standard TRC 2019 Standards. NEEA focused particularly on 9%
Evaluation Report submitting comments in the public review
process and participating in public meetings.
TRC found that NEEA engaged in most of the
Commercial and activities identified in NEEA's Codes&
Industrial Pumps Standards logic model. NEEA participated in
Standard TRC 2021 the Working Group,comments submitted in 24%
Evaluation Report the public review process, including written
comments and participation in public
meetings.
Commercial Pre- TRC 2021 TRC found that NEEA engaged in most of the 4%
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QuantitativeStandard T Third Evaluation Qualitative Assessment
Party Completed Assessment
Rinse Spray Valves activities identified in NEEA's Codes&
Standard Standards logic model. NEEA submitted
Evaluation comments in the public review process,
including written comments and
participation in public meetings.
TRC found that NEEA played a moderate role
Commercial in the development and adoption of this
Refrigeration standard. In the early stages of the standard
Equipment TRC 2018 development process, NEEA submitted 15°%
Evaluation independent comments on the test
procedure.
Commercial TRC found that NEEA engaged in several
Unitary Air activities prescribed in the codes and o
Conditioners
TRC 2018 standards logic model, particularly through 19%
Evaluation the NEEA staff member's participation in the
ASRAC Working Group.
The Motor Coalition,of which NEEA was a
key member, heavily influenced the
rulemaking, recommending expansion of the
scope of the standard to cover all motors First year:
Electric Motors 100%
Cadmus 2016 except specifically defined exceptions. NEEA
Evaluation was found to provide technical expertise to After first
year: 61%
the Motor Coalition and served as a trusted
voice in a negotiation process that has been
contentious historically.
Overall,TRC found that NEEA played a small
role in the development and adoption of this
standard.This is because there were a few
barriers to this standard once the DOE
External Power removed battery chargers for separate
Supply Evaluation TRC 2017 regulation, manufacturer opposition to the 2.60%
EPS standard was minimal. In addition,
NEEA's contribution to the federal process is
generally to provide technical comments or
analysis, but there were few technical needs
for this standard.
TRC believes that efficiency stakeholders
had a "moderate to low" effect on this
Fluorescent Lamp TRC 2016 23%
standard,and TRC translates this influence o
Ballasts Evaluation of all efficiency stakeholder efforts into a
range between 12%and 24%of all energy
savings from the standard.
TRC found that NEEA played a moderate role
Residential in the development and adoption of this
Furnace Fans TRC 2018 standard. However, in the development of 15%
Evaluation the test procedure, NEEA played a
significant role.
Small Electric Cadmus 2016 The majority of the responding 33%
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QuantitativeStandard Third Evaluation Qualitative Assessment
Party Completed Assessment
Motors Evaluation manufacturer interviewees(5 of 6)said
NEEA was"somewhat effective" or"very
effective" in supporting the small motors
standard adoption.
For the 2014 standard,TRC found that NEEA
engaged in several activities prescribed in
the codes and standards logic model,
Walk In Coolers particularly through comments submitted in
Freezers TRC 2019 the public review process. 2014: 12%
Evaluation For the 2017 standard,TRC found that NEEA 2017: 20%
engaged in several activities prescribed in
the codes and standards logic model,
particularly through comments submitted in
the public review process.
As described above, NEEA makes use of the quantitative assessments from each of these evaluations as
follows:
Equation 3-5:Standards Baseline Units Estimation
Baseline Unitsstandard = Total Regional Unitsstandard * Quantitative Assessmentstandard
First, NEEA uses the quantitative assessment percentage to estimate regional baseline units.Then, NEEA
calculates net market units for the standard by netting out baseline units from the total regional units
for the standard.
Equation 3-6: Net Market Units Estimation
Net Market Unitsstandard = Total Regional Unitsstandard — Baseline Unitsstandard
This methodology ensures that NEEA only claims electric or gas savings towards a standard update
resulted due to their participation and efforts in standard update meetings, proposals, and comments.
The Evaluators carefully reviewed each of the third-party evaluation reports above in order to identify
whether these evaluations result in independent and reasonable quantitative assessments for
estimating claimed savings. We considered the following key topics in our analysis:
■ Evaluation indicated that NEEA staff attended standards update meetings
■ Evaluation conducted interviews with NEEA Staff
■ Evaluation conducted interviews with other parties participating in standards update meetings
■ Evaluation reviewed NEEA-specific proposed changes to standards
■ Evaluation reviewed and estimated NEEA-specific energy-savings changes dependent on NEEA-
specific proposed changes only
■ Evaluation qualitative assessment concluded that NEEA contributed a decent amount of effort
towards standards updates
■ Evaluation quantitative assessment estimated the percentage of savings contributed by each
individual NEEA-specific change, supported by documentation that NEEA submitted as proposed
changes to the standard
■ Each evaluation is conducted consistently and thoroughly
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Through careful review,the Evaluators determined that each of the influence evaluations were
adequately conducted and that the resulting quantitative assessment for each standard is a sufficient
way to estimate NEEA contributions and therefore claimable savings towards each measure.The
Evaluators recommend that NEEA continue to complete independent third-party evaluations of NEEA
influence towards standards.
The Evaluators note that 13 of the 25 federal standard measures lacked influence evaluations.The
Evaluators summarize the federal standard measures in which a third-party evaluation has not been
completed to estimate NEEA's quantitative influence towards updates in the table below.
Table 3-36: NEEA Measure-Level Standards
StandardInitiative Federal
Ceiling Fan Kits
Residential Central AC
Other Residential Residential Heat Pumps
Residential Standards Residential Heat Pump Water Heaters
New Construction Heat Pump Water Heaters
Battery Chargers
Clothes Dryers
Ceiling Fans
Other Non-Residential Ceiling Fan Light Kits
Commercial Standards Commercial Air Compressors
Steam Cookers
Commercial Fryers
Industrial Other Non-Residential Industrial Air Compressors
Standards
The Evaluators provide a summary of the contributions to standards and overall portfolio Ex-Ante and
Ex-Post savings for the standards in which an influence evaluation was conducted vs. standards in which
an influence evaluation was not conducted.
Table 3-37:Idaho Power Electric Standards Ex-Ante Savings by Influence Evaluation Completion
Ex-Ante 1 Ex-Ante Ex-Ante Ex-Ante Ex-Ante Ex-Ante
Standard Standard Standard Standard Standard Standard
Ex-Ante Ex-Ante Savings of Savings of Savings of Savings of Savings of Savings of
Program Standard Portfolio Standards Standards Standards Standards Standards Standards
Year Savings Savings with without with without with without
(aMW) (aMW) Influence Influence Influence Influence Influence Influence
Evaluation Evaluation Evaluation Evaluation Evaluation Evaluation
Standards) Standards) Total) Tota 1)
2017 1.45 2.65 0.31 1.14 21% 79% 12% 43%
2018 1.15 2.77 0.35 0.80 30% 70% 13% 29%
2019 0.40 1.99 0.40 0.00 100% 0% 20% 0%
2020 0.41 1.91 0.41 0.00 100% 0% 21% 0%
2021 0.41 1.82 0.41 0.00 100% 0% 22% 0%
Total 3.81 11.15 1.87 1.94 49% 51% 17% 17%
Evaluation Results 79
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I/ I/ I •/ / I I I •/1 p I I 0 /dd I I
Ex-Post Ex-Post Ex-Post Ex-Post
Standard Standard Ex-Post a Standard Standard Standard Standard
Ex-Post Ex-Post Savings of Savings of Savings of Savings of Savings of Savings of
Program Standard Portfolio Standards Standards Standards Standards Standards Standards
Year Savings Savings with without with without with without
Influence Influence Influence Influence
(aMW) (aMW) Influence Influence Evaluation Evaluation Evaluation Evaluation
Evaluation Evaluation
(aMW) (aMW) (as%of (as%of (as%of (as%of
Standards) Standards) Total) Total)
Ex-Ante -Ante -Ante Ex-Ante
Ex-Ant x-Ante Standard Standard tandard Standard
Standard Standard Savings of Savings of Savings of Savings of
Ex Ante Ex-Ante Savings of Savings of Standards Standards Standards Standards
Program Standard Portfolio Standards Standards with without with without
Year Savings Savings with without
Influence Influence Influence Influence
(aMW) (aMW) Influence Influence Evaluation Evaluation Evaluation Evaluation
Evaluation Evaluation (as%of (as%of (as%of (as%of
(aMW) (aMW) Standards) Standards) Total) Total)
I I I I I I I I •/ I I I I I / / I /
Ex-Post Ex-Post Ex-Post Ex-Post
Standard
Ex-Post Standard
Ex-Post Standard Standard Standard Standard
Standard Standard Savings of Savings of Savings of Savings of
Ex-Post Ex-Post Savings of Savings of Standards Standards Standards Standards
Program Standard Portfolio Standards Standards with without with without
Year Savings Savings with without
(aMW) (aMW) Influence Influence Influence Influence Influence Influence
Evaluation Evaluation Evaluation Evaluation Evaluation Evaluation
(aMW) (aMW) (as%of (as%of (as%of (as%of
Standards) Standards) Total) Total)

The Evaluators conclude that standards in which no influence evaluation was completed for contributed
1.94 aMW (51%) of total evaluation period Ex-Ante savings towards standards Idaho Power electric,
which is equivalent to 17%of total Ex-Ante measure, code, and standards savings combined.The
Evaluators conclude that standards in which no influence evaluation was completed for contributed 0.49
aMW (47%) of total evaluation period Ex-Ante savings towards standards for Avista electric, which is
equivalent to 18%of total Ex-Post measure, code, and standards savings combined. No savings from
standards were claimed for Avista gas measures.
However, after removing savings accrued in Oregon, Montana, and Washington by using the service
territory allocation methodology, standards savings in which no influence evaluation was completed
contributed less than 0.02 aMW(less than 1%)towards total Ex-Post savings for Idaho Power Electric,
and 0.0 aMW (0%)towards Ex-Post savings for Avista electric.
This demonstrates that the standards that lack influence evaluations contributes the majority(over 50%)
of standards Ex-Ante savings and that the integration of influence evaluations for the standards which
lack them could drastically reduce savings for standards overall.
In order to ensure that only energy savings above market baseline is claimed by NEEA,the Evaluators
recommend that third-party evaluations are completed for the federal standards claimed by NEEA in the
table above, as well as any federal standards that NEEA claims savings for in the future. It is
unreasonable to claim 100%of savings due to a federal standard update. Unless an evaluation is
completed to quantify and validate NEEA influence towards federal standards updates, the savings
should be categorized as naturally occurring baseline.
3.6.2.1.4 Funder Share Methodology Review
As described in Section 3.3,the Evaluators calculated verified savings using the service territory
allocation methodology.The service territory values were calculated by NEEA using confidential datasets
from NEEA stakeholders.The Evaluators were unable to review the data or replicate the service territory
values because the originating data is delivered to NEEA with non-disclosure agreements.The Evaluators
used the service territory values as-displayed in the NEEA annual workbooks.
The Evaluators note that NEEA calculated Ex-Ante savings for federal standards using funder share
allocation. As described previously,the Evaluators conclude that the funder share methodology does
not accurately reflect benefits claimed by Idaho utility customers.Therefore,the results displayed in this
report reflect service territory savings.Additionally,the Evaluators recommend that Avista and Idaho
Power request NEEA utilize service territory methodology for future NEEA annual savings reports in
order to calculate energy savings and cost-effectiveness testing for the Commission.
3.6.2.2 Verified Ex Post Savings
The Evaluators summarize verified Ex Post federal standards savings results by utility,fuel type, and
program year in the tables below.The Evaluators provide initiative-level savings in Appendix A.
Evaluation Results 81
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Table 3-41:Summary of Idaho Power Idaho Electric Verified Ex Post
Standards Savings by Program Year
Ex Ante Ex Post RealizationM
Year aMW aMW Rate
Savings Savings
2017 1.45 0.36 24.70%
2018 1.15 0.04 3.88%
2019 0.40 0.09 23.49%
2020 0.41 0.40 97.88%
2021 0.41 0.40 98.46%
Total 3.81 1.29 34.01%
The overall verified realization rate for Idaho Power standards efforts due to NEEA was 34%.The
Evaluators conclude this realization rate is due to two reasons:first, the Evaluators used the service
territory allocation share to estimate Idaho savings. Second,the Evaluators identified and corrected any
standards that lacked integration of influence evaluation quantitative estimates towards baseline units.
Table 3-42:Summary of Avista Idaho Electric Verified Ex Post
Standards Savings by Program Year
Ex Ante Ex Post Realization
Savings Savings Rate
2017 0.37 0.10 26.87%
2018 0.30 0.10 34.85%
2019 0.09 0.04 41.00%
2020 0.09 0.11 124.51%
2021 0.09 0.12 125.13%
Total 0.94 0.47 49.71%
The overall verified realization rate for Avista electric standards efforts due to NEEA was 50%.
Table 3-43:Summary of Avista Idaho Gas Verified Ex Post
Standards Savings by Program Year
Ex Ante Ex Post—FRealization
Year Therms Therms Rate
Savings Savings
2019 0 0 N/A
2020 0 0 N/A
2021 0 0 N/A
Total 0 0 N/A
NEEA did not claim any standards gas initiatives in this timeframe.
3.6.2.3 Cost Effectiveness Results
The Evaluators summarize verified cost effectiveness results in the tables below. The Evaluator allocated
14% of electric costs to codes and standards for 2017-2019 and 15%of electric costs to codes and
standards for 2020-2021.The Evaluator allocated 1%of gas costs to codes and standards for 2019 and
9%of gas costs to codes and standards for 2020-2021.The distribution of costs aligns with NEEA's
Evaluation Results 82
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reported actual spending towards codes and standards. Further detail of measure-level cost-
effectiveness is provided in Appendix B and further detail of NEEA cost breakdown is provided in
Appendix C.
Table 3-44:Idaho Power Electric Idaho Standard Cost Effectiveness by Program Year
Program Year UCT Costs UCT Benefits UCT
2017 $77,800.13 $1,173,841.02 15.09
2018 $17,010.57 $270,271.44 15.89
2019 $13,790.76 $529,252.85 38.38
2020 $61,513.62 $2,433,071.48 39.55
2021 $108,258.31 $2,168,234.69 20.03
Total $278,373.40 $6,574,671.48 23.62
Table 3-45:Avista Electric Idaho Standard Cost Effectiveness by Program Year
Program1
2017 $28,374 $717,397 25.28
2018 $25,286 $708,443 28.02
2019 $5,458 $283,445 51.94
2020 $16,403 $871,386 53.12
2021 $23,256 $623,376 26.81
Total $98,777 $3,204,048 32.44
NEEA does not provide any gas standards efforts in the Northwest region and therefore there is no cost-
effectiveness testing completed for Avista Gas Idaho standards. As seen in the tables above, all
standards efforts remained cost-effective using Idaho Power's and Avista's avoided costs and updated
verified Ex Post savings within the state of Idaho.
3.6.2.4 Findings and Recommendations
Similar to the efficiency measures findings, NEEA claimed savings for measures completed in
Washington, Oregon, and Montana—therefore, some measures underestimated Idaho-specific savings,
while others overestimated out-of-state savings. The overall effect of this change resulted in a lower
than 100% realization rate.
Based on the findings detailed above,the Evaluators present the following findings and
recommendations based on our review of NEEA's federal standards measures:
Evaluation Results 83
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Table 3-46:Summary of Federal Standards Findings and Recommendations
Findings Recommendations
Finding#14:The Evaluators estimated verified Ex
Post aMW for the standards efforts to display 34%
and 50%realization rates for Idaho Power electric The Evaluators reference Recommendation#1:
and Avista electric savings within the state of Idaho, The Evaluators recommend Avista and Idaho
respectively.The difference between claimed request NEEA to report annual savings via the
savings and verified savings is due to the change to service territory methodology for each measure
using service territory allocation rather than funder claimed by NEEA for each Idaho Power electric,
share allocation.A minor cause of discrepancy is due Avista electric,and Avista gas.
to corrected baseline units using influence
evaluation values.
Finding#15: NEEA contracts third-party evaluators
to conduct"influence evaluations"for each
standard,which summarizes NEEA's overall Recommendation#8:The Evaluators recommend
qualitative and quantitative influence towards that third-party evaluations are completed for the
federal standards updates. NEEA uses the federal standards claimed by NEEA,as well as any
quantitative assessment as an estimate of federal federal standards in which NEEA hopes to claim
standards naturally occurring baseline.The savings for in the future. Using the quantitative
Evaluators found that some of these influence estimate of NEEA influence,the Evaluators
scores were not integrated properly to estimate recommend that NEEA calculate a naturally
baseline units.The Evaluators also found more than occurring baseline for each standard.
half(13 of 25)federal standard measures lack
influence evaluations.
3.6.3 Codes
In the table below,the Evaluators summarize the codes and new construction initiatives NEEA has
claimed savings for within Avista Idaho and Idaho Power Idaho annual reports between 2017 and 2021.
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Table 3-47:NEEA Code Initiatives Claimed in 2017-2021
2006 1 ECC
2003 IECC w MT 2009 IECC
2009 WSEC 2009 Specialty amend. 2012 IECC w ID
Residential Efficient 2012 WSEC 2011 Specialty 2009 IECC w MT amend.
Homes 2015 WSEC 2012 Specialty amend. 2006 WSEC
2012 IECC w MT 2009 WSEC
amend. 2012 WSEC
Above code SF/MF Above code SF Above code SF/MF Above code SF
Next Step building building building building
Residential ENERGY STAR MF ENERGY STAR ENERGY STAR SF ENERGY STAR
Homes Next Step Homes SF SF/MF 2018 IECC SF/MF
Next Step Homes SF
2018 IECC SF
ID HERS
Residential WSEC 2015 MF 2011 Specialty SF 2018 IECC SF ID National ENERGY
Residential New WSEC 2018 MF 2011 Specialty MF 2012 IECC w MT STAR Homes
Construction WSEC 2018 SF 2017 Specialty MF amend. MF 2009 IECC MF
2018 IECC MF 2012 IECC w Idaho
amend. MF
2018 IECC MF
2008 Or. Res
Specialty
2011 Or. Res
Other Codes 2006 WSEC Specialty 2009 IECC 2002009 IECC
Residential 9 IECC
(Multifamily) 2015 WSEC 2012 Or. Res 2012 IECC
2012 IECC
Specialty
2017 Or. Res
Specialty
Commercial
Commercial Code 2018 WSEC N/A N/A N/A
Enhancement
2012 WSEC 2006 IECC
Other Codes 2019 OZERCC 2012 IECC 2009 IECC
Commercial (Commercial) 2015 WSEC 2021 OZERCC 2018 IECC 2012 IECC
2018 WSEC 2015 IECC
As displayed in the table above, NEEA claimed codes and new construction savings for new construction
single family and multifamily homes constructed in Washington, Oregon, Montana, and Idaho.The
Evaluators are unable to reasonably assign out-of-state savings to Idaho without an evaluation verifying
that out-of-state code updates lead to market transformation effects in Idaho.
Additionally,the Evaluators recommend that influence evaluations are completed for each code update
in order to estimate the proportion of savings NEEA may claim for its efforts towards building code
updates, similarly to the NEEA influence evaluations completed for federal standards. It is likely that
savings attributed to NEEA is currently being significantly overestimated, assuming that it is likely that
Evaluation Results 85
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similar code updates would have naturally occurred without NEEA participation in code update
meetings.
However, without NEEA influence evaluations completed for these code updates,the Evaluators
assumed 100% code savings due to NEEA influence.The Evaluators did, however, remove non-Idaho
code savings from all code initiatives to estimate savings that benefit Idaho customers directly.
Therefore,this section reports verified code savings accrued within the state of Idaho only.
The sections below summarize the reviews completed to estimate verified savings through NEEA code
efforts:
■ Impact methodology review
■ Cost effectiveness results
• Findings and recommendations
3.6.3.1 Impact Methodology Review
In this section,the Evaluators summarize findings and recommendations for each of the following
components towards verified impact results of NEEA's code updates:
■ Database and document review(Section 3.6.3.1.1)
■ UES review(Section 3.6.3.1.2)
■ Market transformation baseline review (Section 3.6.3.1.3)
■ Funder share methodology review(Section 3.6.3.1.4)
3.6.3.1.1 Database and Document Review
The Evaluators reviewed each of the supplemental documents provided by NEEA, which included the
following:
■ 2017-2021 annual savings reports for Avista electric,Avista gas, and Idaho Power electric
■ 2015 Idaho IECC UEC residential calculation approach
■ 2018 Idaho IECC UEC commercial calculation approach
■ Codes program logic model evaluations
■ Codes and standards contracts, including NEEA employee roles and responsibilities towards the
codes program
■ Idaho energy code collaborative 5-year strategic plan
■ 2018 Idaho field study
■ Residential commercial codes logic models
■ Codes program market progress evaluation reports
The Evaluators reviewed each of the documents above to identify and address any inconsistencies with
data tracking methods and opportunities to improve year-over-year tracking of NEEA efforts.
The Evaluators found during database review that a variety of fields are empty across code tracking
data, similar to our finding for efficiency measure database review. The Evaluators summarize the
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missing values further in Appendix D. The Evaluators recommend that measure-level values are detailed
as completely as possible.
Most importantly,the Evaluators found that NEEA claims 100%of code-built home and facility savings
10 years after the code is implemented.Although NEEA integrates a compliance rate referenced from
recent field studies,the Evaluators conclude that it is unreasonable to claim that 100%of code-built
homes occur due to NEEA and stakeholder efforts. Code development and progress also displays a
naturally occurring baseline. However, NEEA does not estimate a market baseline for code initiatives.
In response to a data request for documents supporting code savings, NEEA delivered the following
documentation:
■ Codes contracts:A workbook summarizing each of the contracts in progress and completed in
relation to code education and training, code proposals, code analysis, code sponsorship, and
code reporting for the 2017 through 2021 years.
■ Market progress evaluation reports (MPER): Reports summarizing the effectiveness of training
and education activities and its associated outcomes
■ Savings methodology: Documentation regarding IECC unit energy calculations approach for
newly updates codes
■ Code development:The history of Idaho's code adoptions of IECC over the last twenty years, an
overview of code proposals NEEA funded or coordinated to have submitted, documentation of
the process NEEA followed to prepare code proposals for 2018 IECC, including details of how
NEEA commonly works with contractors to analyze and prepare code proposals that will benefit
the Northwest, and documentation for how NEEA used the results of 2018 code proposals to
prepare for the 2021 IECC code.
■ Field studies:The 2015 Idaho residential field study report
The delivered documentation adequately summarizes NEEA's approach to collecting and submitting
proposed changes to IECC codes, NEEA's scope for training and education within the region, estimation
of total code-to-code savings, and compliance rates in the region.
The above documents support NEEA claimed savings for Idaho code changes by estimating gross energy
savings differences between previously implemented IECC code and newly implemented IECC code, as
well as estimating regional compliance rates for new construction. However,the documentation
provided does not provide details or support NEEA's policy for claiming 100%of code savings as NEEA-
generated savings, nor does it provide any evaluation requests or estimation of NEEA-specific
quantitative contributions to code savings.
The Evaluators requested information, supporting documents, and/or evaluations of NEEA's
contributions to support NEEA's policy to claim 100%of code savings. NEEA staff responded by stating
the following:
"[We claim] 100%of the amount of savings that we can measure through our code compliance
studies. We have an ongoing building practices measurement where we go out into the field and
find out how much of the code is being complied with. We don't assume 100%compliance.The
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agreement for NEEA to be 100%attributable was a settlement between the 4 states about 10
years ago.This was decided upon by the Cost Effectiveness Advisory Committee.Where we are
today is a direct result of the settlement. NEEA has played such a large role in the code making
process that CEAC decided this was a reasonable way to address NEEA's part in the code making
process.This was a stipulated agreement between NEEA and state regulators." (NEEA Staff)
The Evaluators asked NEEA staff how frequently this agreement is revisited and/or voted on. NEEA staff
indicated that"every year, every single input assumption to every single savings claim is reviewed by
CEAC. In theory, everything is open for comment and adjustment as needed. Which includes this 100%
code savings factor."
The Evaluators conclude that although compliance rate is integrated into claimed savings, it is likely that
code savings are significantly overestimated due to this lack of baseline value, assuming that it is likely
that similar code updates would not have been made without NEEA participation in code update
meetings.The Evaluators highlight this lack of support as a large concern moving forward for claiming
code savings. However,without proper evaluation work completed, and without prior similar work to
reference for literature review,the Evaluators assume 100%savings for this evaluation work, with the
expectation and recommendation for NEEA to integrate a baseline for code savings through evaluation
of NEEA contributions in future program years.
The Evaluators therefore recommend that an evaluation is completed for each code update to estimate
NEEA's qualitative and quantitative influence towards the code update,which is currently completed for
federal standard updates.This evaluation work will enable NEEA to estimate a baseline of homes that
would have occurred without NEEA intervention in code meetings and updates. However, without NEEA
influence evaluations completed for these code updates, the Evaluators assumed 100%code savings
due to NEEA influence.
Finally, as previously stated,the Evaluators conclude that out-of-state code buildings are currently being
attributed to Idaho utilities.The Evaluators are skeptical that spillover from out-of-state code changes
result in energy savings within the state of Idaho.The Evaluators recommend that if NEEA continue to
allocate out-of-state code savings to Idaho utilities, an evaluation is completed that defends such
assumptions.
3.6.3.1.2 UES Review
The Evaluators reviewed each of the supplemental documents provided by NEEA, which included the
following:
■ 2017-2021 annual savings reports for Avista electric,Avista gas, and Idaho Power electric
■ 2015 Idaho IECC UEC residential calculation approach
■ 2018 Idaho IECC UEC commercial calculation approach
■ 2018 Idaho field study
■ Codes program market progress evaluation reports
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The Evaluators reviewed each of the unit energy savings (UES)values assigned to each code update in
which savings are claimed by NEEA. NEEA utilizes UES values determined by third-party evaluators for
each of the code updates claimed. Each measure unit-level savings is weighted by heating and cooling
zone across three housing types (single family, multifamily, and manufactured home), and across facility
types for nonresidential code updates.These values are then multiplied by the net market units for each
measure after netting out baseline units for each measure, described in further detail in 3.6.2.1.3.1.
NEEA gathers the electric use, natural gas use, and total building area values developed by third-party
evaluators to calculate the difference in energy use per square foot of building between code changes in
IECC-code-built buildings.
Due to the thorough third-party evaluations and estimates of UES verified for use by NEEA,the
Evaluators do not note any concern or discrepancies with the code's energy per square-foot values
applied to estimate NEEA savings for code-built buildings. Instead,the Evaluators focused on the
rationality of NEEA's high-level application of regional units, baseline methodology, allocation
methodology, and overall allocation of savings for each Avista and Idaho Power.
3.6.3.1.3 Market Transformation Baseline Review
As described previously, NEEA claims savings for each IECC standard in Washington, Montana, Idaho,
and Oregon.The current baseline for each of the IECC codes is the previously implemented IECC code.
Therefore,to claim savings for residential buildings completed to meet IECC 2009 in Idaho, NEEA
estimates the regional baseline as the total number of households built to prior code (IECC 2006).
Similarly,to claim savings for residential buildings completed to meet IECC 2012 in Idaho with Idaho
amendments, NEEA estimates the baseline regional units as the total number of households built to
IECC 2009 code.The Evaluators provide the following figure to summarize NEEA's general methodology
for claiming savings for code-built households in the Northwest region.
Evaluation Results 89
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Figure 3-14: Example of Single-Family Code Savings Claimed by NEEA
s
7
6
5
4
3
2
1
0
IECC 2006 IECC 2009 IECC 2012 with Idaho Amendments
■NEEA-claimed savings for IECC 2012 with Idaho amendments
■NEEA-claimed savings for IECC 2009
■NEEA-claimed savings for IECC 2006
*Proportions in figure above are not indicative of actual incremental savings
The Evaluators note that NEEA does not assume 100%compliance rate. NEEA savings calculations
integrate observed code compliance rates for each state based on code compliance studies,which are
completed every one or two years.Therefore, each of the IECC code update savings are weighted by
actual compliance within each state using the most recent, third party-evaluated, state-level field study.
Currently, NEEA currently assumes a compliance rate of 75%for Idaho.The Evaluators agree with this
approach and recommend continuing to include compliance rates in order to prevent claiming savings
from homes that are not 100%compliant.
The Evaluators note concern about specific code savings methodologies and policies currently
implemented by NEEA:
■ Currently, NEEA does not complete third-party evaluations of NEEA"influence"towards codes
updates as is currently done for federal standards updates.Therefore, NEEA currently claims
100%savings for code-built homes. As summarized in the standards influence evaluations
summarized in Table 3-35, NEEA influence towards standards ranges between 2.6%and 61%. If
codes are evaluated similarly, and portray a similar range of influence, NEEA code savings could
be significantly overrepresenting savings.
■ NEEA's current policy is to report 100%of code-built residential and commercial building savings
(while integrating compliance rates)for 10 years after the effective code update date. Currently,
NEEA does not maintain a model to estimate naturally occurring baseline over time, as it does
for its energy efficiency measures. Essentially,the current NEEA methodology assumes that
there would be a 10-year lag in current residential and commercial building code if NEEA did not
participate in code update efforts.
■ NEEA currently allocates out-of-state code compliance savings to Idaho utilities. Similarly, NEEA
currently allocates Idaho code compliance savings to out-of-state utilities. However, NEEA has
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stated that starting in 2022, code savings will be allocated via service territory allocation. If this
NEEA converts all code savings calculations to utilize service territory methodology, state-level
code savings will be claimed only by utilities within the state. However, if NEEA continues to
utilize funder share methodology for code savings,the Evaluators recommend that NEEA
complete an evaluation which can demonstrate energy savings from out-of-state code updates
can be realized across states, and specifically,within Idaho.
3.6.3.1.4 Funder Share Methodology Review
As described in Section 3.3,the Evaluators calculated verified savings using the service territory
allocation methodology.The service territory values were calculated by NEEA using confidential datasets
from NEEA stakeholders.The Evaluators were unable to review the data or replicate the service territory
values because the originating data is delivered to NEEA with non-disclosure agreements.The Evaluators
used the service territory values as displayed in the NEEA annual workbooks.
The Evaluators note that NEEA calculated Ex-Ante savings for code measures using a mix of service
territory share and funder share allocation for the measures it claims savings for.The rationale behind
using one methodology over the other is unclear.
As described previously,the Evaluators conclude that the funder share methodology does not accurately
reflect benefits claimed by Idaho utility customers.Therefore,the results displayed in this report reflect
service territory savings.Additionally,the Evaluators recommend that Avista and Idaho Power request
NEEA utilize service territory methodology for future NEEA annual savings reports in order to calculate
energy savings and cost-effectiveness testing for the Commission.
3.6.3.2 Verified Ex Post Savings
The Evaluators summarize verified Ex Post code savings results by utility, fuel type, and program year in
the tables below.The Evaluators provide initiative-level savings in Appendix A.
Table 3-48:Summary of Idaho Power Idaho Electric Verified Ex Post
Code Savings by Program Year
Ex Ante Ex Post Realization
Year aMW aMW Rate
Savings Savings
2017 0.89 1.24 138.75%
2018 1.23 0.85 68.91%
2019 1.32 2.22 168.03%
2020 1.12 2.17 194.85%
2021 1.00 1.15 115.07%
Total 5.56 7.63 137.25%
The Evaluators emphasize that the savings from codes are likely overestimated due to lack of influence
evaluations. The Evaluators pose that it is unreasonable to claim 100%of code savings due to NEEA
participation in code update meetings.As stated previously,the Evaluators recommend that influence
evaluations are completed for all code updates NEEA claims savings for.The resulting influence score
will then be used to allocate a portion of total code savings towards NEEA efforts.
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The overall verified realization rate for Idaho Power code efforts due to NEEA was 137%. Although the
Evaluators zeroed out non-Idaho code savings,the Idaho service territory allocation share for Idaho
code new construction completes outweighed the deficit created by out-of-state new construction
completes.The funder share methodology overestimated out-of-state code savings while
underestimating Idaho code savings.
The overall effect of this was a larger savings effect than estimated using the funder share allocation
methodology. However,the Evaluators note again that these code savings are likely still overestimated
due to lack of influence evaluation towards a naturally occurring baseline for code updates.
Table 3-49:Summary of Avista Idaho Electric Verified Ex Post
Code Savings by Program Year
Ex Post Realization i
Ex Ante
Savings Savings
2017 0.18 0.18 99.88%
F2018 0.22 0.22 100.00%
2019 0.28 0.43 153.74%
2020 0.24 0.34 143.02%
2021 0.21 0.25 115.20%
Total 1.13 1.41 125.40%
The overall verified realization rate for Avista electric code efforts due to NEEA was 125%, also for the
reasons listed above.
Table 3-50:Summary of Avista Idaho Gas Verified Ex Post
Code Savings by Program Year
Ex Ante Ex Post Realizationn
Year Therms Therms Rate
Savings Savings
2019 43,109 22,808 52.91%
2020 5,678 385 6.79%
2021 15 2,881 152,881 100.00
Total 201,667 176,074 87.31%
The overall verified realization rate for Avista gas code efforts due to NEEA was 87%, also for the reasons
listed above.A large portion of Ex Ante code savings accrued in 2019 and the large majority of Ex Ante
code savings accrued 2020 due to Washington, Oregon, and Montana new construction projects. In
2021, NEEA claimed savings only for Idaho code updates.The overall realization rate across these
program years for code gas saving is less than 100%.
3.6.3.3 Cost Effectiveness Results
The Evaluators summarize verified cost effectiveness results in the tables below. The Evaluator allocated
14% of electric costs to codes and standards for 2017-2019 and 15%of electric costs to codes and
standards for 2020-2021.The Evaluator allocated 1%of gas costs to codes and standards for 2019 and
Evaluation Results 92
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 92 of 122

9%of gas costs to codes and standards for 2020-2021.The distribution of costs aligns with NEEA's
reported actual spending towards codes and standards. Further detail of measure-level cost-
effectiveness is provided in Appendix B and further detail of NEEA cost breakdown is provided in
Appendix C.
Table 3-51:Idaho Power Electric Idaho Code Cost Effectiveness by Program Year
Program Year UCT Costs UCT Benefits UCT
2017 $268,851.90 $11,734,281.85 43.65
2018 $324,071.89 $9,167,250.01 28.29
2019 $327,192.90 $17,177,751.00 52.50
2020 $335,567.24 $17,595,234.34 52.43
2021 $311,681.75 $8,321,577.44 26.70
Total $1,567,365.68 $63,996,094.65 40.83
Table 3-52:Avista Electric Idaho Code Cost Effectiveness by Program Year
Program Year UCT Costs UCT Benefits UCT
2017 $50,484 $2,156,341 42.71
2018 $52,305 $3,425,488 65.49
2019 $79,600 $7,331,020 92.10
2020 $49,354 $4,212,726 85.36
2021 $49,803 $2,618,611 52.58
Total $281,545 $19,744,185 70.13
Table 3-53:Avista Gas Idaho Code Cost Effectiveness by Program Year
2019 $1,967 $315,142 160.23
2020 $13,147 $6,048 0.46
2021 $14,863 $2,491,877 167.66
Total $29,977 $2,813,068 93.84
As seen in the tables above, all code efforts remained cost-effective using the Idaho Power and Avista
avoided costs and updated verified Ex Post savings within the state of Idaho.
3.6.3.4 Findings and Recommendations
Similar to the efficiency measures findings, NEEA claimed savings for measures completed in
Washington, Oregon, and Montana—therefore, some measures underestimated Idaho-specific savings,
while others overestimated out-of-state savings. The overall effect of this change resulted in a higher
than 100% realization rate.
Evaluation Results 93
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 93 of 122

Based on the findings detailed above,the Evaluators present the following findings and
recommendations based on our review of NEEA's code initiatives:
Table 3-54:Summary of Code Findings and Recommendations
Findings Recommendations
Finding#16:The Evaluators estimated verified Ex
Post aMW for the code efforts to display 137%,
125%,and 87%realization rates for Idaho Power
electric,Avista electric,and Avista gas savings within The Evaluators reference Recommendation#1:
the state of Idaho, respectively.The difference The Evaluators recommend Avista and Idaho
between claimed savings and verified savings is due request NEEA to report annual savings via the
to the change to using service territory allocation service territory methodology for each measure
rather than funder share allocation. Overall,the claimed by NEEA for each Idaho Power electric,
funder share allocation underestimated Idaho- Avista electric,and Avista gas.
specific code savings using the current NEEA practice
of claiming 100%code savings for 10 years after
code is implemented.
The Evaluators reference Finding#10 also applies The Evaluators reference Recommendation#6:
for the codes review:The database review revealed The Evaluators recommend that measure-level
that a variety of fields(measure life, UES)were values are detailed accurately and that each field is
empty across measure types due to lack of savings completed in the workbook to allow for year-over-
claimed for the measure,which made verification of year tracking of regional units, baseline units,
values difficult and complicates tracking of a retirement units, and unit energy savings values
measure progress overtime over time.
Finding#17:Currently, NEEA does not complete
third-party evaluations of NEEA"influence"towards
codes updates as is currently done for federal
standards updates.Therefore, NEEA currently claims
100%savings for code-built homes.As summarized
in the standards influence evaluations summarized
in Table 3-35, NEEA influence towards standards
ranges between 2.6%and 61%. If codes are
evaluated similarly,and portray a similar range of
influence, NEEA code savings could be significantly Recommendation#9:The Evaluators recommend
overrepresenting savings. NEEA's current policy is to an evaluation is completed for each code update
report 100%of code-built residential and to estimate NEEA's qualitative and quantitative
commercial building savings(while integrating influence towards the code update.
compliance rates)for 10 years after the effective
code update date.Currently, NEEA does not
maintain a model to estimate naturally occurring
baseline over time, as it does for its energy
efficiency measures. Essentially,the current NEEA
methodology assumes that there would be a 10-year
lag in current residential and commercial building
code if NEEA did not participate in code update
efforts.
Finding#18:The Evaluators reviewed simulation
Evaluation Results 94
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 94 of 122

Findings Recommendations
model methodology used by NEEA to estimate code
savings and found that UES methodology for code
savings do not present any concerns.
Evaluation Results 95
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 95 of 122

NEEA Impacts on IPC and Avista Within the State of Idaho
4 Appendix A: Verified Ex Post Savings by Initiative
This section summarizes the Evaluator's verified Ex Post savings for each Avista electric,Avista gas, and
Idaho Power electric, parsed by program year, and initiative.
4.1 Efficiency Measures
This section summarizes the realization rates for efficiency measure savings.
4.1.1 Idaho Power Electric
This section summarizes the realization rates for Idaho Power electric measure verified savings.
Table 4-1:PY2017 Summary of Idaho Power Idaho Electric Verified Ex Post
Efficiency Measure Savings by Initiative
Savings Savings
Certified Refrigeration Energy Specialist(CRES) 0.00 0.00 0.00%
Commissioning Buildings 0.03 0.00 0.00%
Ductless Heat Pumps 0.06 0.00 6.72%
Heat Pump Water Heaters 0.10 0.01 5.68%
Luminaire Level Lighting Controls 0.00 0.00 0.00%
Reduced Wattage Lamp Replacement 0.03 0.06 198.85%
Retail Products Portfolio 0.02 0.02 75.23
Super-Efficient Dryers 0.05 0.02 32.89%
Televisions 0.02 0.02 103.12%
Total 0.31 0.12 39.20%
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 96 of 122

Table 4-2: PY2018 Summary of Idaho Power Idaho Electric Verified Ex Post
Efficiency Measure Savings by Initiative
Ex Ante Ex Post IrRealization
Savings Savings Rate
Building Operator Certification Expansion 0.00 0.00 0.00%
Certified Refrigeration Energy Specialist(CRES) 0.03 0.00 0.00%
Commissioning Buildings-Commercial 0.02 0.00 0.00%
Commissioning Buildings-Industrial 0.00 0.00 0.00%
Desktop Power Supplies 0.15 0.11 73.13%
Ductless Heat Pumps 0.03 0.00 0.00%
Heat Pump Water Heaters 0.04 0.00 0.00%
Other Strategic Energy Management-Industrial 0.00 0.00 0.00%
Other Strategic Energy Management- 0.00%
Commercial 0.00 0.00
Reduced Wattage Lamp Replacement-
Commercial 0.05 0.00 0.00%
Reduced Wattage Lamp Replacement-Industrial 0.01 0.00 0.00%
Retail Product Portfolio 0.02 0.01 57.04%
Super-Efficient Dryers 0.05 0.03 65.20%
Televisions 0.00 0.00 104.70%
Total 0.40 0.15 38.34%
Table 4-3: PY2019 Summary of Idaho Power Idaho Electric Verified Ex Post
Efficiency Measure Savings by Initiative
X Ante M�wx Post Realization
Initiative MRNVF aMW aMW Rate
Savings Savings
Commissioning Buildings-Commercial 0.03 0.00 0.00%
Commissioning Buildings-Industrial 0.00 0.00 0.00%
Desktop Power Supplies 0.01 0.01 79.15%
Ductless Heat Pumps 0.05 0.00 1.02%
Heat Pump Water Heaters 0.04 0.00 3.74%
Luminaire Level Lighting Controls 0.00 0.00 0.00%
Manufactured Homes 0.00 0.00 0.00%
Other Strategic Energy Management-Industrial 0.00 0.00 0.00%
Other Strategic Energy Management- 0.00%
Commercial 0.00 0.00
Reduced Wattage Lamp Replacement-
Commercial 0.04 0.04 85.46%
Reduced Wattage Lamp Replacement-Industrial 0.01 0.01 85.46%
Retail Product Portfolio 0.01 0.00 6.92%
Super-Efficient Dryers 0.08 0.06 81.85%
Televisions 0.00 0.00 0.00%
Total 0.28 0.12 43.78%
Appendix A:Verified Ex Post Savings by Initiative 97
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 97 of 122

Table 4-4: PY2020 Summary of Idaho Power Idaho Electric Verified Ex Post
Efficiency Measure Savings by Initiative
Ex Ante Ex Post IrRealization
Savings Savings Rate
Certified Refrigeration Energy Specialist(CRES) 0.00 0.00 0.00%
Commissioning Buildings-Commercial 0.03 0.00 0.00%
Commissioning Buildings-Industrial 0.01 0.00 18.80%
Desktop Power Supplies 0.01 0.00 0.00%
Ductless Heat Pumps 0.06 0.00 5.17%
Extended Motor Products-Residential 0.01 0.00 5.00%
Extended Motor Products-Commercial 0.01 0.00 28.78%
Heat Pump Water Heaters 0.08 0.00 4.17%
Luminaire Level Lighting Controls 0.01 0.01 56.71%
Manufactured Homes 0.01 0.00 0.00%
Other Strategic Energy Management-
Commercial 0.00 0.00 0.00%
Other Strategic Energy Management-Industrial 0.00 0.00 0.00%
Reduced Wattage Lamp Replacement-
Commercial 0.04 0.04 105.76%
Reduced Wattage Lamp Replacement-Industrial 0.01 0.01 105.09%
Retail Product Portfolio 0.12 0.08 65.79%
Total 0.39 0.14 37.32%
Table 4-5: PY2021 Summary of Idaho Power Idaho Electric Verified Ex Post
Efficiency Measure Savings by Initiative
--inow- Ex Ante Ex Post Realization
Initiative aMW aMW Rate
Savings Savings
Commissioning Buildings 0.00 0.00 0.00%
Desktop Power Supplies 0.01 0.00 0.00%
Ductless Heat Pumps 0.05 0.00 2.96%
Heat Pump Water Heaters 0.10 0.00 4.18%
Luminaire Level Lighting Controls 0.01 0.00 51.59%
Manufactured Homes 0.01 0.00 0.00%
Reduced Wattage Lamp Replacement- a
Commercial 0.02 0.02 105.99/0
Reduced Wattage Lamp Replacement-Industrial 0.00 0.00 105.99%
Retail Product Portfolio 0.17 0.11 67.14%
Window Attachments 0.00 0.00 0.00%
XMP Pumps-Residential 0.03 0.00 4.19%
XMP Pumps-Industrial 0.02 0.01 26.24%
Total 0.42 0.15 36.93%
4.1.2 Avista Electric
This section summarizes the realization rates for Avista electric measure verified savings.
Table 4-6:PY2017 Summary of Avista Idaho Electric Verified Ex Post
Efficiency Measure Savings by Initiative
Appendix A:Verified Ex Post Savings by Initiative 98
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 98 of 122

Ex Ante Ex Post I
Initiative aMW aMW Realization
Savings Savings Rate
Commissioning Buildings 0.00 0.00 0.00%
Ductless Heat Pumps 0.01 0.00 10.20%
Heat Pump Water Heaters 0.03 0.02 68.73%
Luminaire Level Lighting Controls 0.00 0.00 0.00%
Reduced Wattage Lamp Replacement 0.00 0.00 98.27%
Retail Product Portfolio 0.00 0.00 42.21%
Super-Efficient Dryers 0.01 0.01 94.03%
Televisions 0.01 0.01 100.00%
Total 0.06 0.03 57.68%
Table 4-7:PY2018 Summary of Avista Idaho Electric Verified Ex Post
Efficiency Measure Savings by Initiative
Ex Ante Ex Post Realization
7witiative aMW aMW Rate
Savings Savings
Commissioning Buildings-Commercial 0.00 0.00 0.00%
Commissioning Buildings-Industrial 0.00 0.00 0.00%
Desktop Power Supplies 0.02 0.02 100.00%
Ductless Heat Pumps 0.01 0.00 6.02%
Heat Pump Water Heaters 0.01 0.00 57.22%
Manufactured Homes 0.00 0.00 0.00%
Other Strategic Energy Management-
Commercial 0.00 0.00 0.00%
Reduced Wattage Lamp Replacement-
Commercial 0.00 0.00 98.89%
Reduced Wattage Lamp Replacement-Industrial 0.00 0.00 98.89%
Retail Product Portfolio 0.00 0.00 54.86%
Super-Efficient Dryers 0.01 0.01 93.09%
Televisions 0.00 0.00 99.98%
Total 0.06 0.04 73.37%
Table 4-8:PY2019 Summary of Avista Idaho Electric Verified Ex Post
Efficiency Measure Savings by Initiative
Ex Ante T Realization
Initiative aMW aMW Rate
Savings Savings
Commissioning Buildings-Commercial 0.01 0.00 0.00%
Commissioning Buildings-Industrial 0.00 0.00 0.00%
Desktop Power Supplies 0.00 0.00 79.14%
Ductless Heat Pumps 0.01 0.00 4.01%
Heat Pump Water Heaters 0.01 0.00 43.16%
Luminaire Level Lighting Controls 0.00 0.00 0.00%
Manufactured Homes 0.00 0.00 0.00%
Other Strategic Energy Management-Industrial 0.00 0.00 0.00%
Other Strategic Energy Management-Commercial 0.00 0.00 0.00%
Reduced Wattage Lamp Replacement-Commercial 0.01 0.00 30.55%
Reduced Wattage Lamp Replacement-Industrial 0.00 0.00 31.71%
Appendix A:Verified Ex Post Savings by Initiative 99
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 99 of 122

Ex Ante Ex Post Realization
Initiative aMW aMW Rate
Savings Savings
Retail Product Portfolio 0.00 0.00 11.15%
Super-Efficient Dryers 0.02 0.02 109.48%
Total 0.06 0.03 46.97%
Table 4-9:PY2O20 Summary of Avista Idaho Electric Verified Ex Post
Efficiency Measure Savings by Initiative
x Ante Ex Post Realization
Initiative aMW aMW Rate
'Savings Savings
Certified Refrigeration Energy Specialist(CRES) 0.00 0.00 0.00%
Commissioning Buildings-Commercial 0.01 0.00 0.00%
Commissioning Buildings-Industrial 0.00 0.00 41.60%
Desktop Power Supplies 0.00 0.00 0.00%
Ductless Heat Pumps 0.01 0.00 9.35%
Extended Motor Products-Residential 0.00 0.00 0.00%
Extended Motor Products-Commercial 0.00 0.00 0.00%
Heat Pump Water Heaters 0.01 0.00 0.00%
Luminaire Level Lighting Controls 0.00 0.00 0.00%
Manufactured Homes 0.00 0.00 0.00%
Other Strategic Energy Management-Industrial 0.00 0.00 0.00%
Other Strategic Energy Management-Commercial 0.00 0.00 0.00%
Reduced Wattage Lamp Replacement-Commercial 0.01 0.00 27.67%
Reduced Wattage Lamp Replacement-Industrial 0.00 0.00 27.49%
Retail Product Portfolio 0.02 0.03 114.44%
Televisions 0.00 0.00 0.00%
Total 0.08 0.03 39.76%
Table 4-10: PY2021 Summary of Avista Idaho Electric Verified Ex Post
Efficiency Measure Savings by Initiative
Ex Ante Ex Post!_rRea I ization
_IUMInitiative aMW aMW
Savings Savings Rate
Commissioning Buildings-Commercial 0.00 0.00 0.00%
Desktop Power Supplies 0.00 0.00 0.00%
Ductless Heat Pumps 0.01 0.00 20.19%
Heat Pump Water Heaters 0.02 0.00 0.00%
Luminaire Level Lighting Controls 0.00 0.00 0.00%
Manufactured Homes 0.00 0.00 0.00%
Reduced Wattage Lamp Replacement-
Commercial 0.00 0.00 27.73%
Reduced Wattage Lamp Replacement-Industrial 0.00 0.00 27.73%
Retail Product Portfolio 0.03 0.04 112.24%
Window Attachments 0.00 0.00 0.00%
XMP Pumps-Residential 0.01 0.00 0.00%
XMP Pumps-Commercial 0.00 0.00 0.00%
Total 0.08 0.04 48.21%
Appendix A:Verified Ex Post Savings by Initiative 100
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 100 of 122

4.1.3 Avista Gas
This section summarizes the realization rates for Avista gas measure verified savings.
Table 4-11: PY2019 Summary of Avista Idaho Gas Verified Ex Post
Efficiency Measure Savings by Initiative
Ex Ante Ex Post _� Realization
Initiative Therm Therm Rate
Savings Savings
Condensing Rooftop Units 1 636 0 0.00%77
Total 636 0 0.00%
Table 4-12: PY202O Summary of Avista Idaho Gas Verified Ex Post
Efficiency Measure Savings by Initiative
Ex Ante Ex Post Realization
Initiative Therm Therm Rate
Savings Savings
Condensing Rooftop Units 0 0 N/A
Efficient Gas Water Heaters 0 0 N/A
Total 0 0 N/A
Table 4-13: PY2021 Summary of Avista Idaho Gas Verified Ex Post
Efficiency Measure Savings by Initiative
Ex Ante Ex Post Realization
Initiative Therm Therm Rate
Savings Savings
Efficient Gas Water Heaters 0 0 N/A
Efficient Rooftop Units 0 0 N/A
Total 0 0 N/A
4.2 Standards
This section summarizes the realization rates for standards savings.
4.2.1 Idaho Power Electric
This section summarizes the realization rates for Idaho Power electric standards verified savings.
Table 4-14: PY2O17 Summary of Idaho Power Idaho Electric Verified Ex Post
Standards Savings by Initiative
Ex Ante Ex Post Realization
Initiative aMW aMW Rate
Savings Savings
Drive Power 0.03 0.06 216.45%
Other Non-Residential Standards 0.27 0.29 108.52%
Other Residential Standards 1.15 0.00 0.12
Total 1.45 0.36 24.70%
Appendix A:Verified Ex Post Savings by Initiative 101
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 101 of 122

Table 4-15: PY2018 Summary of Idaho Power Idaho Electric Verified Ex Post
Standards Savings by Initiative
Ex Ante 40�MFE_x Post
IrRealization
Savings Savings Rate
Drive Power 0.02 0.00 0.00%
Other Non-Residential Standards-Commercial 0.08 0.02 29.61%
Other Non-Residential Standards-Industrial 0.22 0.02 8.49%
Other Residential Standards 0.82 0.00 0.16%
Total 1.15 0.04 3.88%
Table 4-16: PY2019 Summary of Idaho Power Idaho Electric Verified Ex Post
Standards Savings by Initiative
Ex AnteTEa Post
Realizatio
�W W Ini lativU aM aMW Rate
Savings Savings
Drive Power 0.01 0.00 11.90%
Other Non-Residential Standards-Commercial 0.08 0.03 40.51%
Other Non-Residential Standards-Industrial 0.23 0.00 0.00%
Other Residential Standards 0.07 0.06 81.29%
Total 0.40 0.09 23.49%
Table 4-17: PY2020 Summary of Idaho Power Idaho Electric Verified Ex Post
Standards Savings by Initiative
M JEW ExA Ex Post
Rate
Savings Savings
Drive Power 0.00 0.00 0.00%
Other Non-Residential Standards-Commercial 0.09 0.04 43.64%
Other Non-Residential Standards-Industrial 0.23 0.30 128.37%
Other Non-Residential Standards-Agricultural 0.00 0.00 257.68%
Other Residential Standards 0.08 0.06 75.37%
Total 0.41 0.40 97.88%
Table 4-18: PY2020 Summary of Idaho Power Idaho Electric Verified Ex Post
Standards Savings by Initiative
Ex Ante Ex Post
Initiative aMW aMW Realization
Savings Savings Rate
Other Non-Residential Standards-Commercial 0.10 0.04 43.48%
Other Non-Residential Standards-Industrial 0.24 0.30 128.37%
Other Non-Residential Standards-Agricultural 0.00 0.00 257.68%
Other Residential Standards 0.07 0.06 74.00%
Total 0.41 0.40 98.46%
Appendix A:Verified Ex Post Savings by Initiative 102
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 102 of 122

4.2.2 Avista Electric
This section summarizes the realization rates for Avista electric standards verified savings.
Table 4-19: PY2017 Summary of Avista Idaho Electric Verified Ex Post
Standards Savings by Initiative
Ex Ante�G�Ex Post OF—
IrRealization
Savings Savings Rate
Drive Power 0.01 0.02 111.91%
Other Non-Residential Standards 0.09 0.08 91.43%
Other Residential Standards 0.26 0.00 0.16%
Total 0.37 0.10 26.87%
Table 4-20:PY2O18 Summary of Avista Idaho Electric Verified Ex Post
Standards Savings by Initiative
Ex Ante x CIS I Realization
-WinitWiative aMW aMW Rate
Savings Savings
Drive Power 0.01 0.01 100.00%
Other Non-Residential Standards-Commercial 0.02 0.01 63.92%
Other Non-Residential Standards-Industrial 0.08 0.08 100.00%
Other Residential Standards 0.19 0.00 0.22%
Total 0.29 0.10 34.85%
Table 4-21: PY2019 Summary of Avista Idaho Electric Verified Ex Post
Standards Savings by Initiative
Ex Ante I Ex Post Realization
Initiative aMW aMW Rate
Savings Savings
Drive Power 0.00 0.01 293.18%
Other Non-Residential Standards-Commercial 0.02 0.01 69.19%
Other Non-Residential Standards-Industrial 0.05 0.00 0.00%
Other Residential Standards 0.02 0.02 99.67%
Total 0.09 0.04 41.00%
Table 4-22: PY2020 Summary of Avista Idaho Electric Verified Ex Post
Standards Savings by Initiative
Ex Ante Ex Post Realization
Initiative aMW aMW Rate
Savings Savings
Drive Power 0.00 0.00 0.00%
Other Non-Residential Standards-Commercial 0.02 0.01 63.24%
Other Non-Residential Standards-Industrial 0.05 0.08 157.01%
Other Non-Residential Standards-Agricultural 0.00 0.00 258.22%
Other Residential Standards 0.02 0.02 92.40%
Total 0.09 0.11 122.33%
Appendix A:Verified Ex Post Savings by Initiative 103
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 103 of 122

Table 4-23: PY2021 Summary of Avista Idaho Electric Verified Ex Post
Standards Savings by Initiative
Ex Ante 90�MrEx Post Realization
Savings Savings
Drive Power 0.00 0.00 N/A
Other Non-Residential Standards—Commercial 0.02 0.01 62.90%
Other Non-Residential Standards—Industrial 0.05 0.08 157.01%
Other Non-Residential Standards—Agricultural 0.00 0.00 258.22%
Other Residential Standards 0.02 0.02 102.71%
Total 0.09 0.12 125.13%
4.2.3 Avista Gas
NEEA did not claim any standards update savings for gas measures.
4.3 Codes
This section summarizes the realization rates for code savings. As stated in Section 3.6.3, the following
results are presented with a caveat: currently, NEEA does not conduct influence evaluations for code
updates. It is likely that these code savings are overestimated since a naturally occurring baseline is not
integrated. However, without NEEA influence evaluations completed for these code updates, and with
no literature to reference on similar code-based evaluations, the Evaluators assumed 100%code savings
due to NEEA influence.
4.3.1 Idaho Power Electric
This section summarizes the realization rates for Idaho Power electric code verified savings.
Table 4-24: PY2017 Summary of Idaho Power Idaho Electric Verified Ex Post
Code Savings by Initiative
— Ex Ante Ex Postq 97 Realization
Savings Savings
Efficient Homes 0.35 0.60 172.50%
Other Codes(Commercial) 0.38 0.34 90.56%
Other Codes(Multifamily) 0.05 0.02 46.03%
Residential New Construction/Next Step Homes 0.11 0.26 245.22%
Total 0.89 1.24 138.75
Table 4-25: PY2018 Summary of Idaho Power Idaho Electric Verified Ex Post
Code Savings by Initiative
Ex Ante Ex Post '077-alization I
_mMF"'Inn7tiative� aMW aMW Re Rate
Savings Savings
Efficient Homes 0.38 0.81 215.05%
Other Codes(Commercial) 0.62 0.00 0.00%
Other Codes(Multifamily) 0.05 0.04 73.04%
Appendix A:Verified Ex Post Savings by Initiative 104
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 104 of 122

Ex Ante Ex Post I Realization
Initiative aMW aMW Rate
Savings Savings
Residential New Construction/Next Step Homes 1 0.18 0.00 0.00%
Total 1.23 0.85 68.91%
Table 4-26: PY2019 Summary of Idaho Power Idaho Electric Verified Ex Post
Code Savings by Initiative
Ex Ante Ex Post 7 Realization
Initiative aMW aMW Rate
Savings Savings
Efficient Homes 0.37 0.81 217.23%
Next Step Homes 0.21 0.47 225.25%
Other Codes(Commercial) 0.69 0.92 132.61%
Other Codes(Multifamily) 0.04 0.02 38.13%
Total 1.32 2.22 168.03%
Table 4-27: PY2020 Summary of Idaho Power Idaho Electric Verified Ex Post
Code Savings by Initiative
Ex Ante Ex Post Realization
Initiative aMW aMW Rate
Savings Savings
Efficient Homes 0.32 0.89 281.70%
Next Step Homes 0.22 0.50 222.51%
Other Codes(Commercial) 0.54 0.77 142.92%
Other Codes(Multifamily) 0.04 0.02 41.94%
Total 1.12 2.17 194.85%
Table 4-28: PY2021 Summary of Idaho Power Idaho Electric Verified Ex Post
Code Savings by Initiative
Ex Ante ., Rea a ion
-TMW Rate
Savings Savings A
Efficient Homes 0.27 0.60 223.90%
Other Codes(Commercial) 0.40 0.46 113.98%
Residential New Construction 0.33 0.09 27.15%
Total 1.00 1.15 115.07%
4.3.2 Avista Electric
This section summarizes the realization rates for Avista electric code verified savings.
Appendix A:Verified Ex Post Savings by Initiative 105
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 105 of 122

Table 4-29: PY2017 Summary of Avista Idaho Electric Verified Ex Post
Code Savings by Initiative
Ex Ante 'WrEx Post
0 Savings Savings Rate
Efficient Homes 0.09 0.09 100.00%
Other Codes(Commercial) 0.07 0.07 100.00%
Other Codes(Multifamily) 0.01 0.01 100.00%
Residential New Construction/Next Step Homes 0.01 0.01 96.99%
Total 0.18 0.18 99.88%
Table 4-30:PY2O18 Summary of Avista Idaho Electric Verified Ex Post
Code Savings by Initiative
11111111111111VInitiativf-"d Ex Ante Ex Post Realization
Savings Savings
Efficient Homes 0.11 0.11 100.00%
Other Codes(Commercial) 0.08 0.08 100.00%
Other Codes(Multifamily) 0.01 0.01 100.00%
Residential New Construction/Next Step Homes 0.01 0.01 100.00%
Total 0.22 0.22 100.00%
Table 4-31:PY2O19 Summary of Avista Idaho Electric Verified Ex Post
Code Savings by Initiative
Ex Ante Ex Post Realization
Initiative aMW aMW Rate
Savings Savings
Efficient Homes 0.08 0.12 154.66%
Next Step Homes 0.05 0.11 236.51%
Other Codes(Commercial) 0.15 0.20 133.91%
Other Codes(Multifamily) 0.01 0.00 42.77%
Total 0.28 0.43 153.74%
Table 4-32:PY2020 Summary of Avista Idaho Electric Verified Ex Post
Code Savings by Initiative
Ex Ante I Ex Post Realization
Initiative aMW aMW Rate
Savings Savings
Efficient Homes 0.06 1 0.10 161.42%
Next Step Homes 0.05 0.06 134.25%
Other Codes(Commercial) 0.12 0.17 142.74%
Other Codes(Multifamily) 0.01 0.00 52.83%
Total 0.24 0.34 143.02%
Appendix A:Verified Ex Post Savings by Initiative 106
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 106 of 122

Table 4-33: PY2021 Summary of Avista Idaho Electric Verified Ex Post
Code Savings by Initiative
Ex Ante 'WrEx Post
Savings Savings Rate
Efficient Homes 0.06 0.07 123.85%
Other Codes(Commercial) 0.09 0.10 111.55%
Residential New Construction 0.07 0.08 112.68%
Total 0.21 0.25 115.20%
4.3.3 Avista Gas
This section summarizes the realization rates for Avista electric code verified savings.
Table 4-34: PY2019 Summary of Avista Idaho Gas Verified Ex Post
Code Savings by Initiative
Ex Ante Ex Post
Therm Therm I FRWe a r lization
LM Savings Savings Rate
"Next Homes 43,109 1 22,808 1 52.91%
Total 43,109_1 22,808 1 52.91%
Table 4-35: PY2020 Summary of Avista Idaho Gas Verified Ex Post
Code Savings by Initiative
Ex Ante I Ex Post I Realization
Initiative Therm Therm Rate
Savings Savings
Next Step Homes 5,678 385 6.79%
Total 5,6781 385 6.79%
Table 4-36: PY2021 Summary of Avista Idaho Gas Verified Ex Post
Code Savings by Initiative
Ex Ante Ex Post Realization
Initiative Therm Therm Rate
Savings Savings
Residential New Construction 152,881 152,881 100.00%
Other Codes(Commercial) 0.00 0.00 N/A
Total 152,881 152,881 100.00%
5 Appendix B: Cost Effectiveness Results
5.1 Efficiency Measures
This section summarizes the cost effectiveness tests for efficiency measure savings.
Appendix B: Cost Effectiveness Results 107
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 107 of 122

5.1.1 Idaho Power Electric
This section summarizes the cost effectiveness results for Idaho Power electric measures.
Table 5-1:PY2017 Idaho Power Electric Idaho Efficiency Measure Cost Effectiveness by Initiative
Building Operator Certification Expansion -Commercial- $0 $0 0.00
Large
Certified Refrigeration Energy Specialist(CRES)-industrial $0 $0 0.00
Commissioning Buildings-Commercial-Large $0 $0 0.00
Ductless Heat Pumps-Residential $76,441 $17,513 0.23
Heat Pump Water Heaters-Residential $101,261 $28,386 0.28
Luminaire Level Lighting Controls-Commercial-Large $0 $0 0.00
Reduced Wattage Lamp Replacement-Commercial-Large $1,155,809 $235,198 0.20
Residential Lighting-Residential $0 $0 0.00
Retail Product Portfolio-Residential $273,673 $61,990 0.23
Super-Efficient Dryers-Residential $275,738 $72,602 0.26
Televisions-Residential $303,217 $50,931 0.17
Total $2,186,140 $466,619 0.21
Table 5-2:PY2018 Idaho Power Electric Idaho Efficiency Measure Cost Effectiveness by Initiative
Building Operator Certification Expansion-Commercial- $0 $0 0.00
Large
Certified Refrigeration Energy Specialist(CRES)-Industrial $0 $0 0.00
Commissioning Buildings-Commercial-Large $0 $0 0.00
Commissioning Buildings- Industrial $0 $0 0.00
Desktop Power Supplies-Commercial-Large $1,537,781 $241,160 0.16
Ductless Heat Pumps-Residential $0 $0 0.00
Heat Pump Water Heaters-Residential $0 $0 0.00
Manufactured Homes-Residential $0 $0 0.00
Other Strategic Energy Management-Industrial $0 $0 0.00
Other Strategic Energy Management-Commercial-Large $0 $0 0.00
Reduced Wattage Lamp Replacement-Commercial-Large $0 $0 0.00
Reduced Wattage Lamp Replacement-Industrial $0 $0 0.00
Retail Product Portfolio- Residential $121,903 $58,449 0.48
Super-Efficient Dryers-Residential $453,479 $155,218 0.34
Televisions-Residential $37,852 $8,294 0.22
Appendix B: Cost Effectiveness Results 108
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 108 of 122

Total $2,151,016 $463,122 0.22
Table 5-3: PY2019 Idaho Power Electric Idaho Efficiency Measure Cost Effectiveness by Initiative
Building Operator Certification Expansion-Commercial- $0 $0 0.00
Large
Certified Refrigeration Energy Specialist(CRES) -Industrial $0 $0 0.00
Commercial Code Enhancement-Commercial-Large $0 $0 0.00
Commissioning Buildings-Commercial-Large $0 $0 0.00
Commissioning Buildings-Industrial $0 $0 0.00
Desktop Power Supplies-Commercial-Large $159,989 $17,355 0.11
Ductless Heat Pumps-Residential $9,673 $1,973 0.20
Heat Pump Water Heaters-Residential $23,768 $6,127 0.26
Luminaire Level Lighting Controls-Commercial-Large $0 $0 0.00
Manufactured Homes-Residential $0 $0 0.00
Other Strategic Energy Management-Industrial $0 $0 0.00
Other Strategic Energy Management-Commercial-Large $0 $0 0.00
Reduced Wattage Lamp Replacement-Commercial-Large $675,913 $123,236 0.18
Reduced Wattage Lamp Replacement-Industrial $167,547 $30,548 0.18
Residential Lighting-Residential $0 $0 0.00
Retail Product Portfolio-Residential $8,693 $2,510 0.29
Super-Efficient Dryers-Residential $1,104,808 $266,593 0.24
Televisions-Residential $0 $0 0.00
Total $2,150,393 $448,341 0.21
Table 5-4:PY202O Idaho Power Electric Idaho Efficiency Measure Cost Effectiveness by Initiative
Building Operator Certification Expansion-Commercial- $0 $0 0.00
Large
Certified Refrigeration Energy Specialist(CRES)-Industrial $0 $0 0.00
Commercial Code Enhancement-Commercial-Large $0 $0 0.00
Commissioning Buildings-Commercial-Large $0 $0 0.00
Commissioning Buildings-Industrial $13,915 $1,780 0.13
Desktop Power Supplies-Commercial-Large $0 $0 0.00
Ductless Heat Pumps-Residential $48,160 $11,844 0.25
Extended Motor Products-Residential $8,254 $2,381 0.29
Extended Motor Products-Commercial-Large $61,653 $23,976 0.39
Appendix B: Cost Effectiveness Results 109
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 109 of 122

Heat Pump Water Heaters-Residential $48,619 $14,973 0.31
Luminaire Level Lighting Controls-Commercial-Large $82,678 $25,433 0.31
Manufactured Homes-Residential $0 $0 0.00
Other Strategic Energy Management-Industrial $0 $0 0.00
Other Strategic Energy Management-Commercial-Large $0 $0 0.00
Reduced Wattage Lamp Replacement-Commercial-Large $584,542 $126,571 0.22
Reduced Wattage Lamp Replacement-Industrial $143,053 $30,975 0.22
Residential Lighting-Residential $0 $0 0.00
Retail Product Portfolio-Residential $1,224,230 $372,922 0.30
Super-Efficient Dryers-Residential $0 $0 0.00
Televisions-Residential $0 $0 0.00
Total $2,215,103 $610,855 0.28
Table 5-5:PY2021 Idaho Power Electric Idaho Efficiency Measure Cost Effectiveness by Initiative
Initiative UCT Benefits LICT
Commissioning Buildings-Commercial-Large $0 $0 0.00
Desktop Power Supplies-Commercial-Large $0 $0 0.00
Ductless Heat Pumps-Residential $23,906 $6,085 0.25
Heat Pump Water Heaters-Residential $61,897 $16,483 0.27
Luminaire Level Lighting Controls-Commercial -Large $65,807 $16,850 0.26
Manufactured Homes-Residential $0 $0 0.00
Reduced Wattage Lamp Replacement-Commercial-Large $309,492 $51,618 0.17
Reduced Wattage Lamp Replacement-Industrial $61,851 $10,316 0.17
Retail Product Portfolio-Residential $1,713,122 $465,264 0.27
Window Attachments-Commercial-Large $0 $0 0.00
XMP Pumps-Residential $17,362 $4,294 0.25
XMP Pumps-Commercial-Large $89,185 $31,239 0.35
Total $2,342,622 $602,149 0.26
5.1.2 Avista Electric
This section summarizes the cost effectiveness results for Avista electric measures.
Table 5-6:PY2017 Avista Electric Idaho Efficiency Measure Cost Effectiveness by Initiative
Commissioning Buildings-Commercial-Large $0 $0
Ductless Heat Pumps-Residential $18,720 $10,772 0.58
Appendix B: Cost Effectiveness Results 110
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 110 of 122

Heat Pump Water Heaters-Residential $257,390 $99,636 0.39
Luminaire Level Lighting Controls-Commercial-Large $0 $0
Reduced Wattage Lamp Replacement-Commercial-Large $22,674 $4,869 0.21
Retail Product Portfolio-Residential $25,272 $5,313 0.21
Total $324,057 $120,589 0.37
Table 5-7:PY2018 Avista Electric Idaho Efficiency Measure Cost Effectiveness by Initiative
Building Operator Certification Expansion -Commercial- $0 $0
Large
Certified Refrigeration Energy Specialist(CRES)-Industrial $0 $0
Commissioning Buildings-Commercial-Large $0 $0
Commissioning Buildings-Industrial $0 $0
Desktop Power Supplies-Commercial-Large $270,624 $39,975 0.15
Ductless Heat Pumps-Residential $5,821 $3,998 0.69
Heat Pump Water Heaters-Residential $54,146 $26,752 0.49
Luminaire Level Lighting Controls-Commercial-Large $0 $0
Manufactured Homes-Residential $0 $0
Other Strategic Energy Management-Industrial $0 $0
Other Strategic Energy Management-Commercial-Large $0 $0
Reduced Wattage Lamp Replacement-Commercial-Large $24,912 $6,871 0.28
Reduced Wattage Lamp Replacement-Industrial $6,532 $1,801 0.28
Residential Lighting-Residential $0 $13,096
Retail Product Portfolio-Residential $21,719 $7,552 0.35
Super-Efficient Dryers-Residential $96,709 $43,964 0.45
Televisions-Residential $8,861 $1,943 0.22
Total $489,324 $145,951 0.30
Table 5-8:PY2019 Avista Electric Idaho Efficiency Measure Cost Effectiveness by Initiative
Building Operator Certification Expansion -Commercial- $0 $0
Large
Certified Refrigeration Energy Specialist(CRES)-Industrial $0 $0
Commissioning Buildings-Commercial-Large $0 $0
Commissioning Buildings-Industrial $0 $0
Desktop Power Supplies-Commercial-Large $31,059 $3,631 0.12
Ductless Heat Pumps-Residential $7,380 $3,902 0.53
Appendix B: Cost Effectiveness Results 111
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 111 of 122

Heat Pump Water Heaters-Residential $53,241 $20,220 0.38
Luminaire Level Lighting Controls-Commercial-Large $0 $0
Manufactured Homes-Residential $0 $0
Other Strategic Energy Management-Industrial $0 $0
Other Strategic Energy Management-Commercial-Large $0 $0
Reduced Wattage Lamp Replacement-Commercial-Large $46,915 $9,968 0.21
Reduced Wattage Lamp Replacement-Industrial $12,068 $2,564 0.21
Residential Lighting-Residential $0 $0
Retail Product Portfolio-Residential $2,721 $1,029 0.38
Super-Efficient Dryers-Residential $286,880 $99,151 0.35
Televisions-Residential $0 $0
Total $440,264 $140,466 0.32
Table 5-9:PY2O20 Avista Electric Idaho Efficiency Measure Cost Effectiveness by Initiative
Initiative LICT Benefits LICT
Building Operator Certification Expansion -Commercial- $0 $0
Large
Certified Refrigeration Energy Specialist(CRES)-Industrial $0 $0
Commissioning Buildings-Commercial-Large $4,566 $588 0.13
Commissioning Buildings-Industrial $0 $0
Desktop Power Supplies-Commercial-Large $0 $0
Ductless Heat Pumps-Residential $15,135 $9,700 0.64
Extended Motor Products-Residential $0 $0
Extended Motor Products-Commercial-Large $0 $0
Heat Pump Water Heaters-Residential $0 $0
Luminaire Level Lighting Controls-Commercial-Large $0 $0
Manufactured Homes-Residential $0 $0
Other Strategic Energy Management-Industrial $0 $0
Other Strategic Energy Management-Commercial-Large $0 $0
Reduced Wattage Lamp Replacement-Commercial-Large $33,048 $8,262 0.25
Reduced Wattage Lamp Replacement-Industrial $0 $0
Residential Lighting-Residential $0 $0
Retail Product Portfolio- Residential $314,074 $134,398 0.43
Super-Efficient Dryers- Residential $0 $0
Televisions-Residential $0 $0
Total $366,823 $152,948 0.42
Appendix B: Cost Effectiveness Results 112
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 112 of 122

Table 5-10:PY2O21 Avista Electric Idaho Efficiency Measure Cost Effectiveness by Initiative
Certified Refrigeration Energy Specialist(CRES)-Industrial $0 $0
Commissioning Buildings-Commercial-Large $0 $0
Commissioning Buildings- Industrial $0 $0
Desktop Power Supplies-Commercial-Large $0 $0
Ductless Heat Pumps-Residential $24,660 $15,454 0.63
Heat Pump Water Heaters-Residential $0 $0
Luminaire Level Lighting Controls-Commercial-Large $0 $0
Manufactured Homes-Residential $0 $0
Other Strategic Energy Management-Industrial $0 $0
Other Strategic Energy Management-Commercial-Large $0 $0
Reduced Wattage Lamp Replacement-Commercial-Large $12,254 $2,801 0.23
Reduced Wattage Lamp Replacement-Industrial $2,449 $560 0.23
Retail Product Portfolio-Residential $368,195 $147,725 0.40
Window Attachments-Commercial-Large $0 $0
XMP Pumps-Residential $0 $0
XMP Pumps-Commercial-Large $0 $0
Total $407,558 $166,540 0.41
5.1.3 Avista Gas
This section summarizes the cost effectiveness results for Avista gas measures.
Table 5-11:PY2019 Avista Gas Idaho Efficiency Measure Cost Effectiveness by Initiative
Conde7Gas
ooftop Units 17,.
$0 0.00
EfficieWater Heaters $0 N/A
Total 52,294 $0 0.00
Table 5-12:PY2O2O Avista Gas Idaho Efficiency Measure Cost Effectiveness by Initiative
Condensing Rooftop Units $126,061 $0 0.00
Efficient Gas Water Heaters $0 $0 N/A
Total $126,061 $0 0.00
Table 5-13:PY2O21 Avista Gas Idaho Efficiency Measure Cost Effectiveness by Initiative
Condensing Rooftop Units $21,077 $0 0.00
Appendix B: Cost Effectiveness Results 113
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 113 of 122

Efficient Gas Water Heaters $121,435 $0 0.00
Total $142,512 $0 0.00
5.2 Standards
This section summarizes the cost effectiveness tests for standards savings.
5.2.1 Idaho Power Electric
This section summarizes the cost effectiveness results for Idaho Power standards.
Table 5-14:PY2017 Idaho Power Electric Idaho Standards Cost Effectiveness by Initiative
Drive Power- Industrial $14,017 $238,156 16.99
Other Non-Residential Standards-Commercial-Large $63,494 $929,391 14.64
Other Residential Standards-Residential $289 $6,294 21.76
Total $77,800 $1,173,841 15.09
Table 5-15:PY2018 Idaho Power Electric Idaho Standards Cost Effectiveness by Initiative
Drive Power- Industrial $0 $0 0.00
Other Non-Residential Standards-Commercial-Large $9,238 $129,369 14.00
Other Non-Residential Standards-Industrial $7,263 $134,391 18.50
Other Residential Standards-Residential $510 $6,512 12.76
Total $17,011 $270,271 15.89
Table 5-16:PY2019 Idaho Power Electric Idaho Standards Cost Effectiveness by Initiative
Drive Power- Industrial $238 $5,290 22.21
Other Non-Residential Standards-Commercial-Large $5,014 $155,648 31.04
Other Non-Residential Standards-Industrial $0 $0 0.00
Other Residential Standards-Residential $8,538 $368,315 43.14
Total $13,791 $529,253 38.38
Table 5-17:PY2020 Idaho Power Electric Idaho Standards Cost Effectiveness by Initiative
Drive Power-Industrial $0 $0 0.00
Appendix B: Cost Effectiveness Results 114
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 114 of 122

Other Non-Residential Standards-Commercial-Large $6,395 $194,435 30.40
Other Non-Residential Standards-Industrial $46,092 $1,859,240 40.34
Other Non-Residential Standards-Commercial-Small $50 $1,567 31.37
Other Residential Standards-Residential $8,977 $377,830 42.09
Total $61,514 $2,433,071 39.55
Table 5-18:PY2021 Idaho Power Electric Idaho Standards Cost Effectiveness by Initiative
Other Non-Residential Standards-Commercial-Large $11,346 $168,080 14.81
Other Non-Residential Standards-Industrial $81,969 $1,682,475 20.53
Other Non-Residential Standards-Commercial-Small $0 $0 0.00
Other Residential Standards-Residential $14,943 $317,680 21.26
Total $108,258 $2,168,235 20.03
5.2.2 Avista Electric
This section summarizes the cost effectiveness results for Avista standards.
Table 5-19:PY2017 Avista Electric Idaho Standards Cost Effectiveness by Initiative
Initiative LICT Costs LICT Benefits UCT
Drive Power-Industrial $4,526 $53,952 11.92
Other Non-Residential Standards-Commercial - Large $23,730 $661,032 27.86
Other Residential Standards-Residential $118 $2,413 20.46
Total $28,374 $717,397 25.28
Table 5-20:PY2018 Avista Electric Idaho Standards Cost Effectiveness by Initiative
Drive Power-Industrial $2,878 $37,923 13.18
Other Non-Residential Standards-Commercial-Large $2,859 $64,760 22.65
Other Non-Residential Standards-Industrial $19,449 $603,853 31.05
Other Residential Standards-Residential $101 $1,907 18.97
Total $25,286 $708,443 28.02
Table 5-21:PY2019 Avista Electric Idaho Standards Cost Effectiveness by Initiative
Drive Power-Industrial $1,149 $26,591 23.15
Other Non-Residential Standards-Commercial - Large $1,913 $70,589 36.90
Appendix B: Cost Effectiveness Results 115
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 115 of 122

Other Non-Residential Standards-Industrial $0 $0
Other Residential Standards-Residential $2,396 $186,265 77.75
Total $5,458 $283,445 51.94
Table 5-22:PY2020 Avista Electric Idaho Standards Cost Effectiveness by Initiative
Drive Power-Industrial $0 $0
Other Non-Residential Standards-Commercial-Large $14,047 $695,980 49.55
Other Non-Residential Standards-Industrial $0 $0
Other Non-Residential Standards-Commercial-Small $0 $0
Other Residential Standards- Residential $2,356 $175,406 74.45
Total $16,403 $871,386 53.12
Table 5-23:PY2021 Avista Electric Idaho Standards Cost Effectiveness by Initiative
Drive Power-Industrial $0 $0
Other Non-Residential Standards-Commercial-Large $2,722 $47,891 17.59
Other Non-Residential Standards-Industrial $17,002 $489,978 28.82
Other Non-Residential Standards-Commercial-Small $16 $338 20.60
Other Residential Standards-Residential $3,515 $85,169 24.23
Total $23,256 $623,376 26.81
5.2.3 Avista Gas
There were no gas standards efforts completed by NEEA between 2017 and 2021.
5.3 Codes
This section summarizes the cost effectiveness tests for code savings.
As stated in Section 3.6.3, the following results are presented with a caveat: currently, NEEA does not
conduct influence evaluations for code updates. It is likely that these code savings are overestimated
since a naturally occurring baseline is not integrated. However, without NEEA influence evaluations
completed for these code updates, and with no literature to reference on similar code-based
evaluations, the Evaluators assumed 100% code savings due to NEEA influence.
5.3.1 Idaho Power Electric
This section summarizes the cost effectiveness results for Idaho Power codes.
Appendix B: Cost Effectiveness Results 116
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 116 of 122

Table 5-24:PY2017 Idaho Power Electric Idaho Codes Cost Effectiveness by Initiative
Efficient Homes-Residential $131,145 $6,357,207 48.47
Other Codes(Commercial)-Commercial-Large $74,954 $2,335,114 31.15
Other Codes (Multifamily) - Residential $5,311 $257,465 48.47
Residential New Construction/Next Step Homes- $57,442 $2,784,496 48.47
Residential
Total $268,852 $11,734,282 43.65
Table 5-25: PY2018 Idaho Power Electric Idaho Codes Cost Effectiveness by Initiative
Efficient Homes-Residential $309,663 $8,759,652 28.29
Other Codes(Commercial)-Commercial-Large $0 $0 0.00
Other Codes(Multifamily)-Residential $14,409 $407,598 28.29
Residential New Construction/Next Step Homes- $0 $0 0.00
Residential
Total $324,072 $9,167,250 28.29
Table 5-26:PY2019 Idaho Power Electric Idaho Codes Cost Effectiveness by Initiative
Efficient Homes-Residential $119,241 $7,245,659 60.76
Next Step Homes-Residential $69,869 $4,245,586 60.76
Other Codes(Commercial)-Commercial-Large $135,576 $5,534,205 40.82
Other Codes(Multifamily)-Residential $2,506 $152,301 60.76
Total $327,193 $17,177,751 52.50
Table 5-27:PY2020 Idaho Power Electric Idaho Codes Cost Effectiveness by Initiative
Efficient Homes-Residential $137,603 $8,160,111 59.30
Next Step Homes-Residential $76,718 $4,549,508 59.30
Other Codes (Commercial)-Commercial-Large $118,840 $4,742,908 39.91
Other Codes(Multifamily)-Residential $2,406 $142,707 59.30
Total $335,567 $17,595,234 52.43
Table 5-28:PY2021 Idaho Power Electric Idaho Codes Cost Effectiveness by Initiative
Efficient Homes-Residential $163,529 $5,047,965 30.87
Other Codes(Commercial)-Commercial-Large $123,982 $2,527,467 20.39
Residential New Construction-Residential $24,171 $746,146 30.87
Total $311,682 $8,321,577 26.70
Appendix B: Cost Effectiveness Results 117
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 117 of 122

5.3.2 Avista Electric
This section summarizes the cost effectiveness results for Avista codes.
Table 5-29:PY2017 Avista Electric Idaho Codes Cost Effectiveness by Initiative
7Efficientes-Residential $24,720 $1,300,997 52.63
Commercial)-Commercial-Large $21,355 $623,326 29.19
Other Codes(Multifamily)-Residential $2,490 $131,049 52.63
Residential New Construction/Next Step Homes-Residential $1,919 $100,969 52.63
Total $50,484 $2,156,341 42.71
Table 5-30: PY2018 Avista Electric Idaho Codes Cost Effectiveness by Initiative
7Efficientes-Residential $26,671 $2,295,012 86.05
Commercial)-Commercial-Large $19,900 $637,087 32.01
Other Codes(Multifamily)-Residential $2,902 $249,716 86.05
Residential New Construction/Next Step Homes-Residential $2,832 $243,673 86.05
Total $52,305 $3,425,488 65.49
Table 5-31: PY2019 Avista Electric Idaho Codes Cost Effectiveness by Initiative
Commercial Code Enhancement-Commercial-Large $0 $0
Efficient Homes-Residential $17,357 $1,956,279 112.71
Next Step Homes-Residential $16,810 $1,895,989 112.79
Other Codes(Commercial)-Commercial-Large $29,567 $1,638,091 55.40
Other Codes(Multifamily)-Residential $619 $69,796 112.71
Total $64,354 $5,560,155 86.40
Table 5-32:PY2020 Avista Electric Idaho Codes Cost Effectiveness by Initiative
Commercial Code Enhancement-Commercial-Large $0 $0
Efficient Homes-Residential $15,245 $1,770,866 116.16
Next Step Homes-Residential $9,239 $1,073,163 116.16
Other Codes(Commercial)-Commercial-Large $24,233 $1,294,717 53.43
Other Codes(Multifamily)-Residential $637 $73,981 116.16
Total $49,354 $4,212,726 85.36
Appendix B: Cost Effectiveness Results 118
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 118 of 122

Table 5-33:PY2021 Avista Electric Idaho Codes Cost Effectiveness by Initiative
Efficient Homes-Residential —r—$14,341 $772,522 53.87
Other Codes(Commercial)-Commercial-Large $20,011 $1,013,693 50.66
Residential New Construction-Residential $15,452 $832,395 53.87
Total $49,807 $2,618,614 52.57
5.3.3 Avista Gas
This section summarizes the cost effectiveness results for Avista gas codes.
Table 5-34:PY2019 Avista Gas Idaho Codes Cost Effectiveness by Initiative
Next Step Homes $1,967 $315,142 160.23
Total $1,967 $315,142 160.23
Table 5-35:PY2020 Avista Gas Idaho Codes Cost Effectiveness by Initiative
Next Step Homes $13,147 $6,048 0.46
Total $13,147 $6,048 0.46
Table 5-36:PY2020 Avista Gas Idaho Codes Cost Effectiveness by Initiative
Residential New Construction-Residential $14,863 $2,491,877 167.66
Other Codes(Commercial)-Commercial-Large $0 $0 N/A
Total $14,863 $2,491,877 167.66
6 Appendix C: NEEA-Allocated Costs
This section summarizes the total NEEA budget for the 5-year 2015-2019 and the 2020 to 2024 business
plans. The proportion of NEEA-allocated funds is used to distribute Avista-and Idaho Power-provided
NEEA funding between the efficiency measures, codes, and standards.
6.1.1 2014-2019 Business Plan
This section summarizes the actual costs reported by NEEA for the 2014 to 2019 5-year business plan.
Appendix C: NEEA-Allocated Costs 119
Exhibit No. 1
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 119 of 122

Table 6-1:2014—2019 5-Year Actual NEEA Costs
I Primary Strategies 5-Year Electric 5-Year Natural
Actual Costs Gas Actual Costs
Emerging technology $10,534,740.00 $2,364,765.00
Effective Portfolio Execution $25,762,239.00 $3,619,888.00
Building Envelope $698,671.00
Consumer Products $12,785,010.00 $394,407.00
HVAC $6,702,005.00 $1,777,354.00
Lighting $3,188,446.00
Motor-Driven Systems $1,525,470.00
New Construction $8,772,362.00 $400,000.00
Water Heating $19,665,505.00 $1,777,800.00
Enabling Infrastructure $10,819,593.00
LTMT $10,725,919.00
Codes&Standards $15,959,117.00 $102,923.00
Market Intelligence $9,518,708.00 $606,019.00
Convene and Collaborate $9,149,857.00 $0.00
Administration $21,276,009.00 $0.00
Allocate Shared Services ($3,012,494.00) $2,533,527.00
Total $164,071,157.00 $13,576,683.00
Highlighted in orange in the table above represents the total costs allocated to efficiency measures.
Highlighted in light blue in the table above represents the total costs allocated to codes &standards.
Based on the table provide above, the Evaluators distributed costs using the following methodology:
Electric costs:
o Efficiency measures capture 86%of shared category
o Codes & Standards capture 14% of shared category
Natural gas costs:
o Efficiency measures capture 99%of shared category
o Codes & Standards capture 1%of shared category
NEEA codes and standards contribute a minority of total funding from NEEA, however, based on the
impact evaluation, codes and standards provides the majority of claimable savings by NEEA.
6.1.2 2020-2024 Business Plan
This section summarizes the actual costs reported by NEEA between 2020 and 2022 for the 2020 to
2024 5-year business plan.
Table 6-2:2020-2022 Actual NEEA Costs
Primary Strategies Actual Costs Natural Gas
Actual Cost
Emerging Technology $9,566.00 $1,958.00
Effective Portfolio Execution $74,149.00 $8,361.00
Appendix C: NEEA-Allocated Costs 120
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Codes&Standards $13,292.00 $872.00
Market Intelligence $5,122.00 $488.00
Convene and Collaborate $7,700.00 $0.00
Administration $21,858.00 $0.00
Allocate Shared Services -$4,715.00 $3,136.00
Total Core Activities $126,972.00 $14,815.00
Highlighted in orange in the table above represents the total costs allocated to efficiency measures.
Highlighted in light blue in the table above represents the total costs allocated to codes & standards.
Based on the table provide above, the Evaluators distributed costs using the following methodology:
Electric costs:
o Efficiency measures capture 85%of shared category
o Codes & Standards capture 15% of shared category
Natural gas costs:
o Efficiency measures capture 91%of shared category
o Codes & Standards capture 9% of shared category
7 Appendix D: Summary of Missing Values
In this section,the Evaluators summarize the elements missing from the tracking data delivered by NEEA
to estimate total regional and utility savings for each Idaho Power Electric, Avista Electric, and Avista Gas
savings reports.
Table 7-1:Avista Electric Summary of Missing Values
020 2021
Load shape 6(11%) 23(12%) 23(12%) 25(11%) 101(100%)
Measure Life 7(13%) 12(6%) 0(0%) 17(8%) 0(0%)
kWh/unit energy savings 2(4%) 56(30%) 61(32%) 64(29%) 43(43%)
Total Regional Units 0(0%) 0(0%) 0(0%) 0(0%) 0(0%)
Local Program Units 0(0%) 0(0%) 0(0%) 0(0%) 0(0%)
NEEA Baseline 0(0%) 0(0%) 0(0%) 0(0%) 0(0%)
Retirements 6(11%) 8(4%) 13(7%) 12(5%) 14(14%)
Retirements allocated to local 3(5%) 9(5%) 11(6%) 10(5%) 15(15%)
programs
Retirements allocated to baseline 9(16%) 17(9%) 23(12%) 22(10%) 29(29%)
Initiative Start Year 55(100%) 0(0%) 0(0%) 0(0%) 101(100%)
Table 7-2:Avista Gas Summary of Missing Values
Initiative 2019 020 2021
Load shape N/A N/A N/A
Appendix D:Summary of Missing Values 121
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Measure Life 24(100%) 25(100%) 43(100%)
Therm/unit energy savings 3(13%) 0(0%) 8(19%)
Total Regional Units 0(0%) 0(0%) 0(0%)
Local Program Units 0(0%) 0(0%) 0(0%)
NEEA Baseline 0(0%) 0(0%) 0(0%)
Retirements 24(100%) 25(100%) 43(100%)
Retirements allocated to local 24(100%) 25(100%) 43 (100%)
programs
Retirements allocated to baseline 24(100%) 25(100%) 43(100%)
Initiative Start Year 24(100%) 25(100%) 43(100%)
Table 7-3:Idaho Power Electric Summary of Missing Values
020 2021
Load shape 14(9%) 12(11%) 23(12%) 24(11%) 101(100%)
Measure Life 7(4%) 8(7%) 1(1%) 17(8%) 0(0%)
kWh/unit energy savings 49(31%) 0(0%) 61(32%) 64(29%) 0(0%)
Total Regional Units 0(0%) 0(0%) 0(0%) 0(0%) 0(0%)
Local Program Units 0(0%) 0(0%) 0(0%) 0(0%) 0(0%)
NEEA Baseline 0(0%) 0(0%) 0(0%) 0(0%) 0(0%)
Retirements 11(7%) 3(3%) 13(7%) 12(5%) 11(11%)
Retirements allocated to local
8(5%) 5(5%) 11(6%) 11(5%) 3(3%)
programs
Retirements allocated to baseline 18(11%) 7(7%) 23(12%) 22(10%) 14(14%)
Initiative Start Year 0(0%) 0(0%) 0(0%) 0(0%) 101(100%)
The Evaluators imputed a likely load shape and appropriate measure life in cases in which the load
shape or measure life was not defined by NEEA. For the line items missing kWh/unit or Therm/unit
energy savings values,the Evaluators note that the number of units in which savings apply are zero do
not affect savings, as the number of units claimed for those examples was zero. Although the total net
market units for these measures are zero, and total net market effects are effectively zero, the
Evaluators recommend that appropriate kWh/unit and Therm/unit energy savings values are still
defined appropriately.
NEEA includes in the tracking data estimates of total retired units in the region.The Evaluators note that
in some instances, total regional retirement units are defined in aggregate, whereas in other instances,
local program retirement and baseline retirement units are defined. The Evaluators recommend that in
any instances where local program, baseline, or total regional retirement units is above 0, that those
retirement units are then categorized under the local program or baseline retirement units.This will
help with tracking how retirement units are partitioned between each category,for each measure, over
time.
Appendix D:Summary of Missing Values 122
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-35
IDAHO POWER COMPANY
NESBITT, DI
TESTIMONY
EXHIBIT NO. 2

Addendum : Evaluation of NEEA
Impacts Allocated to Idaho Power
Company and Avista Utilities
Within the State of Idaho
SUBMITTED TO: IDAHO POWER COMPANY &
AVISTA UTILITIES
SUBMITTED ON: JUNE 15, 2023
SUBMITTED BY: ADM ASSOCIATES, INC.
M.
ADM Associates, Inc Idaho Power Company Avista Utilities
3239 Ramos Circle 1221 W Idaho St 1411 E Mission Ave
Sacramento, CA 95827 Boise, ID 83702 Spokane, WA 99202
916-363-8383
Exhibit No.2
Case No.IPC-E-24-35
Q.Nesbitt,IPC
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Table of Contents
1. Response to NEEA's Feedback.............................................................................................................4
1.1 Summary.....................................................................................................................................................4
1.2 Recommendation#5 ..................................................................................................................................4
1.3 Recommendation#6..................................................................................................................................6
1.4 Recommendation#8..................................................................................................................................8
1.5 Recommendation#9................................................................................................................................11
1.6 Overall Conclusions..................................................................................................................................12
Addendum ii
Exhibit No.2
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List of Tables
Table 1-1: NEEA Response to Recommendation#5.....................................................................................5
Table 1-2: NEEA Response to Recommendation#5 Examples.....................................................................5
Table 1-3: NEEA Response to Recommendation#6.....................................................................................7
Table 1-4: NEEA Response to Recommendation#6 Examples.....................................................................8
Table 1-5: NEEA Response to Recommendation#8.....................................................................................9
Table 1-6: NEEA Response to Recommendation#8 Examples...................................................................10
Table 1-7: NEEA Response to Recommendation#9...................................................................................11
Table 1-8: Revised Findings and Recommendations ..................................................................................12
admenergy.com 13239 Ramos Circle, Sacramento, CA 95827 1 916.363.8383 iii
Exhibit No.2
Case No.IPC-E-24-35
Q.Nesbitt,IPC
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1. Response to NEEA's Feedback
ADM Associates (herein referred to as the "Evaluators") developed a report summarizing the
evaluation,measurement,and verification(EM&V)of the Northwest Energy Efficiency Alliance(NEEA)
activities and energy impact estimates as it relates to savings allocated to Idaho Power Company(IPC)
and Avista Utilities (Avista)within the state of Idaho for the program years 2017-2021.
NEEA's executive team reviewed the evaluation findings and recommendations and submitted a
response to IPC and Avista. ADM reviewed NEEA's response and is supplying this addendum to
recharacterize language previously provided in the evaluation report and to clarify final conclusions
and recommendations resulting from this evaluation.
1.1 Summary
Upon review of the evaluation report, NEEA provided responses to conclusions and recommendations
from the evaluation work summarized above. In this addendum, the Evaluators elaborate on the
following recommendations:
■ Recommendation#5:The Evaluators recommend that measure-level values are detailed as
accurately as possible, and that each field is completed in the workbook to allow for year-over-
year tracking of regional units, baseline units, retirement units, and unit energy savings values
over time. (Based on Finding#3 and Finding#10)
■ Recommendation#6:The Evaluators recommend that NEEA distribute naturally occurring
baseline units more equitably between local program units and total regional units. (Based on
Finding#11)
■ Recommendation#8:The Evaluators recommend that third-party evaluations are completed for
the federal standards claimed by NEEA, as well as any federal standards in which NEEA hopes to
claim savings for in the future. Using the quantitative estimate of NEEA influence,the Evaluators
recommend that NEEA calculate a naturally occurring baseline for each standard. (Based on
Finding#15)
■ Recommendation#9:The Evaluators recommend an evaluation is completed for each code
update to estimate NEEA's qualitative and quantitative influence towards the code update.
(Based on Finding#17)
The Evaluators outline the revised recommendations in the sections below.
1.2 Recommendation #5
The Evaluators summarize the Evaluators'findings and recommendations, NEEA responses, and the
Evaluator's summarizing response for Recommendation #5.
Addendum 4
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Table 1-1:NEEA Response to Recommendation#5
■ Finding#3:The Evaluators found that the methodology in which savings were
estimated across measures was inconsistent. For some measures,service territory
methodology was used,and for others,funder share allocation methodology was
Finding used.
■ Finding#10:The database review revealed that a variety of fields(measure life,
UES)were empty across measure types due to lack of savings claimed for the
measure,which made verification of values difficult and complicates tracking of a
measure progress over time.
■ Recommendation#5:The Evaluators recommend that measure-level values are
Recommenclatio detailed as accurately as possible,and that each field is completed in the workbook
to allow for year-over-year tracking of regional units, baseline units, retirement
units,and unit energy savings values over time.
■ In the savings workbook provided annually to each funder, NEEA already enters all
NEEA Response data fields for active programs and measures within each program for which we are
reporting savings. NEEA references all the data sources in the workbook.
1.2.1 Evaluator Examples
In response to NEEA feedback, the Evaluators provided examples of incomplete and inconsistent data
provided in NEEA's annual reports delivered Idaho Power Company and Avista Utilities between the 2017
and 2021 program years. The table below summarizes the Evaluator's examples as well as NEEA's
response to said examples.
Table 1-2: NEEA Response to Recommendation#5 Examples
■ The inconsistency in allocation method within a single program year is observed in
the Avista 2017 and 2018 workbooks. In both years, most measures displayed
Evaluator service territory share, but a handful showed funder share allocation.Although we
Examples see that this practice does not continue into more recent years(2019-2021), we
note that this should be an area to consider in quality assurance and quality
control.
■ NEEA allocates the savings using the most disaggregated data available.The data
sources can range from service-territory level to regional. When NEEA only has
regional data,the reports allocate the savings using funding shares.
■ Of the 30 observations provided,only 4 of the measures(13%) had savings.The
NEEA Response savings for these measures amounted to approximately 1%of the Net Market
Effects. In all four cases, NEEA did not have data/analysis available that would have
provided a more accurate estimate of the service territory allocation.
■ NEEA provides all detailed data annually as called out in recommendation#5.The
only missing data,as finding#10 states,were fields intentionally left empty due to
NEEA not reporting savings for that measure.
Addendum 5
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1.2.2 Recommendation #5 Summary
The Evaluators provide the following feedback to NEEA's response summarized above.
■ The Evaluators understand that measure-level values are dependent on resolution of data
available to NEEA. To the fullest extent possible,the Evaluators recommend NEEA weigh
regional savings most aligned with funder-selected methodology.Therefore, although the
approved service territory share methodology is not entirely feasible with the data available,the
results in some way consider the allocation methodology perspective when summarizing results.
■ In addition,the Evaluators recommend that for any measures NEEA currently does not claim
savings,these measure line items are removed from funder annual reports.This will ensure that
funders only receive complete and verified reports.
1.3 Recommendation #6
The Evaluators summarize the Evaluators'findings and recommendations, NEEA responses, and the
Evaluator's summarizing response for Recommendation #6.
Addendum 6
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Table 1-3:NEEA Response to Recommendation#6
■ Finding#11:The database review revealed that NEEA's current method for
distribution of modeled naturally occurring baseline units between local program
and NEEA efforts is not reasonable.A portion of energy-efficient technology sales
are due to naturally occurring baseline. NEEA nets out modeled naturally occurring
baseline to avoid claiming savings for units that would have been sold had no
program or NEEA-effort been provided within the market. However,the method in
which these baseline units are netted out is not distributed equitably. For some
measures, NEEA estimates that a large proportion of local program units are
baseline, and therefore a larger proportion of the remaining net market effects is
assigned to NEEA efforts.The Evaluators raise concern for this assumption,as it is
unlikely locally incentivized, rebated measures display the same free ridership as
non-incentivized measures in the region.
■ Recommendation#6:The Evaluators recommend that NEEA distribute naturally
Recommendation occurring baseline units more equitably between local program units and total
regional units.
■ NEEA disagrees with ADM's assertion that the distribution method of baseline units
NEEA uses is not reasonable or equitable.A foundational principle of NEEA,as an
alliance, is that local programs support market adoption and are therefore a part of
the market transformation taking place. NEEA's baseline market share estimate
represents the adoption that would have occurred without the intervention of
NEEA or its funders' local programs,so NEEA's approach assumes that a portion of
NEEA Response the baseline market share applies to the local incentive units.
■ Regarding the question of equitability, NEEA does not assign savings to NEEA
efforts separately from funder programs; rather, it measures the full market
transformation savings from our collective efforts(Co-created Savings)and reports
that to funders.To help our funders avoid double-counting, in our savings reports
we net out local program savings.The remaining savings,called net market effects
savings are not representative of distinct NEEA efforts, nor do they reflect
attribution.
1.3.1 Evaluator Examples
The distribution of local program baseline units refers to the value characterized in the annual reports as
"retirement units replaced by local programs." In response to NEEA feedback,the Evaluators provided
examples of retirement units in which local programs were over decremented, referring to line items
provided in Idaho Power Company and Avista Utilities annual reports.The table below summarizes the
Evaluator's examples as well as NEEA's response to said examples.
Addendum 7
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Table 1-4: NEEA Response to Recommendation#6 Examples
■ The Evaluators found that the retirement units for some measures were distributed
entirely to local programs, rather than total regional units.Therefore, a large
Evaluator portion of local program units were nullified.Although this does not affect the
Examples aggregate total net market units for the measure, it underestimates the proportion
of total net market units that the local program units account for.We provided
examples referencing the 2021 annual report for Idaho Power for the clothes
washers,clothes dryers,and refrigerators.
■ In the examples provided,the"retirement units replaced by local programs" is the
estimate of local program units allocated to Baseline.
NEEA Response ■ The share of the local program units allocated to baseline looks high because the
report does not show the market shares.
■ NEEA provided to the Evaluators back-end calculations portraying how baseline
units are calculated for each measure.
1.3.2 Recommendation #6 Summary
The Evaluators provide the following feedback to NEEA's response summarized above.
■ In reviewing the example NEEA provided for calculating total regional unit baseline and local
program unit baseline units,the Evaluators rescind our Recommendation#6. NEEA currently
integrates a method for distributing retirement units replaced by local programs proportional to
estimated market baseline.
1.4 Recommendation #8
The Evaluators summarize the Evaluators'findings and recommendations, NEEA responses, and the
Evaluator's summarizing response for Recommendation #8.
Addendum 8
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Table 1-5:NEEA Response to Recommendation#8
■ Finding#15: NEEA contracts third-party evaluators to conduct"influence
evaluations"for each standard,which summarizes NEEA's overall qualitative and
quantitative influence towards federal standards updates. NEEA uses the
quantitative assessment as an estimate of federal standards naturally occurring
baseline.The Evaluators found that some of these influence scores were not
integrated properly to estimate baseline units.The Evaluators also found more
than half(13 of 25)federal standard measures lack influence evaluations.
■ Recommendation#8:The Evaluators recommend that third-party evaluations are
completed for the federal standards claimed by NEEA,as well as any federal
Recommendation standards in which NEEA hopes to claim savings for in the future. Using the
quantitative estimate of NEEA influence,the Evaluators recommend that NEEA
calculate a naturally occurring baseline for each standard.
■ NEEA does not agree with these two assertions:that influence scores were not
integrated properly and that reported energy savings lacked evaluations.The
variance was either due to rounding or a reduction of the percentage based on
NEEA's participation (Fluorescent Lamp Ballasts).
NEEA Response ■ There is one case(Pumps)where the assumptions contained a preliminary value
and is to be updated based on the final evaluation value'.
■ In cases where NEEA reported co-created energy savings and ADM is stating no
evaluation was conducted,they are mistaken. NEEA reviewed all appliance
standards for which we claimed co-created savings and confirmed evaluations are
available in each instance.
1.4.1 Evaluator Examples
In response to NEEA feedback, the Evaluators provided examples of the 13 federal standards update
savings claimed by NEEA in which no influence evaluations were conducted.The table below
summarizes the Evaluator's examples as well as NEEA's response to said examples.
1 NEEA does not request any revisions or comment regarding this statement.
Addendum 9
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Table 1-6: NEEA Response to Recommendation#8 Examples
■ The Evaluators found that the following standards were claiming savings, but
lacked influence evaluation documentation, both in requested information during
the evaluation,and during independent research to locate an influence evaluation:
o Battery standards in Oregon
Evaluator o Commercial HPWH (Existing)
Examples o Commercial HPWH (New construction)
o Residential AC
o Clothes Dryers
o Residential Heat Pumps
o Nonresidential ceiling fans
o Nonresidential ceiling fan kits
■ For the following measures, NEEA provided program-level evaluation reports
completed by third party evaluators:
o Battery standards in Oregon
o Commercial HPWH (Existing)3
o Commercial HPWH (New construction)'
■ For the following measures, no influence evaluation was conducted. NEEA never
reported Net Market Effects from these standards.The measures are listed in the
NEEA Response Table View of the Savings reports because they were part of NEEA's database for
other reporting purposes.The Table View of the report is meant to be a database
view of the savings reported on the individual tabs.
o Residential AC
o Clothes Dryers
o Residential Heat Pumps
o Nonresidential ceiling fans
o Nonresidential ceiling fan kits
o Residential ceiling fan light kits
1.4.2 Recommendation #8 Summary
The Evaluators provide the following feedback to NEEA's response summarized above.
■ In reviewing the document provided for the battery standards in Oregon,the Evaluators found
that the program evaluation documentation does not sufficiently estimate NEEA influence
towards the standard.The influence evaluations completed for other standards provide clear
objectives and conclusions towards NEEA proportional influence towards quantitative savings.
Although the document provided in replacement of a battery standards influence evaluation
provides verification for estimating energy savings in Oregon overall, the report does not
provide a clear quantitative estimate for NEEA influence towards the standard update.
■ NEEA confirmed that the Evaluators used the correct influence percentage (24%)for the Pumps
standard.
■ In reviewing the document provided for the commercial heat pump water heater standard for
existing and new construction facilities,the Evaluators again found that the program evaluation
z https://neea.org/img/uploads/long-term-monitoring-and-tracking-report-on-2011-activities.pdf
3 https://neea.org/img/documents/Heat-Pump-Water-Heater-Benefit-Cost-Model-Review.pdf
4 ibid.
Addendum 10
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documentation does not sufficiently estimate NEEA influence towards the standard.The
influence evaluations completed for other standards provide clear objectives and conclusions
towards NEEA quantitative and proportional influence towards quantitative savings. However,
the documents provided in replacement of an influence evaluation for these standards does not
estimate or conclude a clear influence value towards NEEA efforts.
■ In reviewing the remaining measures (residential AC, clothes dryers, residential heat pumps,
nonresidential ceiling fans, nonresidential ceiling fan kits, and residential ceiling fan kits),the
Evaluators recognize that savings claimed for these standards are negligible (demonstrating
1.9E-17 aMW savings in total).Therefore,the Evaluators rescind our conclusion for completing
influence evaluations for these standards in which no measurable savings are claimed.
1.5 Recommendation #9
The Evaluators summarize the Evaluators' findings and recommendations, NEEA responses, and the
Evaluator's summarizing response for Recommendation #9.
Table 1-7:NEEA Response to Recommendation#9
■ Finding#17:Currently, NEEA does not complete third-party evaluations of NEEA
"influence"towards codes updates as is currently done for federal standards
updates.Therefore, NEEA currently claims 100%savings for code-built homes.As
summarized in the standards influence evaluations summarized in Table 3-35, NEEA
influence towards standards ranges between 2.6%and 61%. If codes are evaluated
similarly,and portray a similar range of influence, NEEA code savings could be
significantly overrepresenting savings. NEEA's current policy is to report 100%of
code-built residential and commercial building savings(while integrating
compliance rates)for 10 years after the effective code update date. Currently,
NEEA does not maintain a model to estimate naturally occurring baseline over time,
as it does for its energy efficiency measures. Essentially,the current NEEA
methodology assumes that there would be a 10-year lag in current residential and
commercial building code if NEEA did not participate in code update efforts.
■ Recommendation#9:The Evaluators recommend an evaluation is completed for
Recommendation each code update to estimate NEEA's qualitative and quantitative influence
towards the code update.
■ NEEA already conducts third-party evaluation of its energy codes work.Since the
current influence approach's application to reported energy savings was
recommended by CEAC,any changes would need to be discussed by that
committee. Possible implementation in 2025 with cost implications to be
NEEA Response determined.
■ As outlined in Finding#17, NEEA's significant influence in the state building energy
code process is distinct from federal appliance standards and therefore we would
like to understand ADM's basis for this recommendation before suggesting any
changes to process or reporting. If there were a change,their most likely would be
cost implications to NEEA.
1.5.1 Evaluator Examples
Additional examples were not provided to NEEA for this recommendation.
Addendum 11
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1.5.2 Recommendation #9 Summary
The Evaluators did not provide to NEEA specific examples towards Recommendation#9. Instead, the
Evaluators provide the following feedback.
■ The Evaluators understand that NEEA's current policy effectively claims savings for 1/3 of the
code life cycle by claiming 10 years of savings rather than 30 years of savings.Therefore,there
does exist some form of baseline integration to the savings claimed for codes. However,the
Evaluators note that NEEA's 100%savings for 10 years policy arose from a decision made by the
Cost Effectiveness Advisory Group (CEAC) nearly 25 years ago. It is unclear whether this
assumption or policy has been reassessed since its original decision over two decades ago. Since
then, a framework for quantitatively estimating NEEA's influence has been solidified for
standards. It is of the Evaluator's view that a similar framework can be developed for
quantitatively estimating NEEA's influence towards code updates.The Evaluators recommend
NEEA's 100%savings claimed for 10 years policy is revisited by CEAC and further methods for
estimating NEEA influence and market baseline is explored when claiming code savings in future
program years.
1.6 Overall Conclusions
The Evaluators took into consideration NEEA's responses and associated documents in order to provide
revised findings and recommendations for the evaluation, measurement, and verification (EM&V) effort
of the Northwest Energy Efficiency Alliance (NEEA) activities and energy impact estimates as it relates to
savings allocated to Idaho Power Company(IPC) and Avista Utilities (Avista) within the state of Idaho for
the program years 2017-2021.The findings and recommendations presented in the section below
provide the most up-to-date conclusions for this evaluation work.
1.6.1 Revised Findings and Recommendations
The Evaluators provide a summary of the revised findings and recommendations to the evaluation
report, based on additional feedback from NEEA.
Table 1-8: Revised Findings and Recommendations
Findings Recommendations
Finding #1: Utilities that fund NEEA can choose whether
savings are reported by allocation share methodology or
service territory methodology. The allocation share
methodology overrepresents out-of-state and out-of- Recommendation #1: The Evaluators recommend
service territory savings across measures, codes, and Avista and Idaho Power request NEEA to report
standards while simultaneously underrepresenting in- annual savings via the service territory methodology
state and in-service-territory savings across measures, for each measure claimed by NEEA for each Idaho
codes, and standards. However, the service territory Power electric,Avista electric,and Avista gas.
methodology accurately represents benefits directed to
Avista and Idaho Power customers within the state of
Idaho.
Addendum 12
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Finding#2:The data NEEA utilizes to estimate net market
savings is available at resolutions that allow NEEA to
estimate precise savings for each utility service territory.
Finding#3:The Evaluators found that the methodology in
which savings were estimated across measures were
inconsistent. For some measures, service territory
methodology was used, and for others, funder share
allocation methodology was used.
Finding#4: NEEA prioritizes cost-effective savings in terms
of regional benefit. Therefore, savings and cost- Recommendation #2: The Evaluators recommend
effectiveness are distributed across the region evenly, that Avista and Idaho Power request annual savings
despite observed distribution of savings across states. reports to include estimates of administrative costs,
Although this philosophy has merit, more precise incentive costs, and non-incentive costs by service
estimates of utility-level and program-level savings help territory. This will allow each utility to calculate
NEEA's stakeholders relay relevant savings and cost- more accurate cost-effectiveness tests for each
effectiveness results to their respective regulatory initiative to determine whether extension of
commissions.This remains critical,due to some state-level funding is a viable option within each utility's
commission orders to pursue all cost-effective energy regulatory environment.
efficiency efforts.
Finding #5: The interviews revealed that although the
three parties fundamentally want to improve energy
efficiency and increase market adoption of emerging Recommendation #3: The Evaluators recommend
technologies, their preferred approaches to this shared that NEEA work with utilities to accurately produce
goal vary. Unlike the utilities, who strive to demonstrate service territory-level savings and to best serve each
the cost-effectiveness of their initiatives and investments state's current regulatory environment and utility's
on an annual or bi-annual cycle, NEEA operates on a five- localized concerns.
year funding cycle, which is different than the typical
annual or biannual utility planning cycle.
Finding#6: NEEA's programs are designed with a broader
Recommendation #4: The Evaluators recommend
constituency in mind than that of its member utilities.
that NEEA track progress for each code change
While the Idaho utilities'programs are targeted to produce
benefits for their ratepayers, — NEEA is tasked with relative to administrative dollars spent towards
state-level codes and associated energy savings
developing programs that need to consider what is best for
the entire four-state region. At its core, NEEA's ethos accrued by each state-level code. With the 20-year
market transformation in mind, the service-
assumes that changes made in one state will eventually
spillover into another state and that in the long run, territory-level savings will still accrue over the 20-
year horizon, however, using this methodology,
regional change will be realized.
Addendum 13
Exhibit No.2
Case No.IPC-E-24-35
Q.Nesbitt,IPC
Page 13 of 16

Finding #7: NEEA currently allocates code savings via actual market transformation effects of co-created
funder share methodology, which estimates a proportion savings will be more accurately tracked.
of total NEEA funding to each utility based on number of
electric retail customers and overall load. Therefore,
savings from code adoption in other states are in-part
assigned to Idaho.The Evaluators found that out-of-state
code building savings are currently being attributed to
Idaho utilities. The Evaluators are skeptical that spillover
from out-of-state code changes result in energy savings
within the state of Idaho. Although the barriers to code
adoption from one state to the next may be similar,there
is no evidence to suggest that these learnings transfer to
observable and measurable savings. NEEA has stated that
starting in 2022, code savings will be allocated via service
territory allocation.
Finding #8: The NEEA Cost Effectiveness Advisory
Committee (CEAC) meets quarterly with the NEEA
objectives to provide space for discussion around results
of recently completed evaluation,progress of field studies,
relevant updates to programs, and acceptance or
questioning of NEEA methodology towards calculation of
savings.
Finding#9:The Evaluators estimated verified Ex Post aMW
for the efficiency measures to display 39%, 52%, and 0%
realization rates for Idaho Power electric, Avista electric,
and Avista gas savings within the state of Idaho,
respectively.The difference in claimed savings and verified The Evaluators reference Recommendation#1:The
savings is due to the change to using service territory Evaluators recommend Avista and Idaho request
allocation rather than funder share allocation. The NEEA to report annual savings via the service
efficiency measures category Ex Ante savings included territory methodology for each measure claimed by
savings for measures completed in Washington, Oregon, NEEA for each Idaho Power electric,Avista electric,
and Montana—therefore, for some measures, the funder and Avista gas.
share allocation methodology underestimated Idaho-
specific savings while others overestimated out-of-state
savings. The overall effect of this change resulted in a
lower than 100%realization rate.
Recommendation #5: The Evaluators recommend
that measure-level values are only included in
annual reports for measures in which savings are
Finding#10: The database review revealed that a variety claimed. In addition, the Evaluators recommend
of fields (measure life, UES) were empty across measure NEEA continue to document each value as
types due to lack of savings claimed for the measure,which accurately as possible, and that each field is
made verification of values difficult and complicates
tracking of ameasure progress over time.
completed in the workbook to allow for year-over-
year tracking of regional units, baseline units,
retirement units, and unit energy savings values
over time.
Addendum 14
Exhibit No.2
Case No.IPC-E-24-35
Q.Nesbitt,IPC
Page 14 of 16

Finding #11: The database review revealed that NEEA's
current method for distribution of modeled naturally Recommendation #6: Rescinded based on
occurring baseline units between local program and NEEA additional information provided by NEEA.
efforts is reasonable.
Finding#12: The Evaluators reviewed the utilized UES via
the Regional Technical Forum (RTF)workbooks,field study
data, and simulation analysis findings and note no large
concerns with NEEA UES methodology or market baseline
assumptions.
Finding #13: The Evaluators found that NEEA calculates
cost-effectiveness of its portfolio using the total regional
savings rather than the net market effects.The Evaluators
determined that this methodology raises concern,and the Recommendation #7: In the case that cost
NEEA cost-effectiveness tests currently account for all effectiveness tests are completed using NEEA-
measure, standard, and code completions across the reported savings, the Evaluators recommend that
entire region, effectively double counting local program Avista and Idaho Power calculate cost-effectiveness
savings and simultaneously claiming naturally occurring using net market effects rather than total regional
baseline savings. Because Avista and Idaho Power savings, as is consistent with current regulatory
calculate their own internal cost effectiveness tests, this requirements to report gross savings that would not
finding does not impact Idaho Power or Avista reporting. have occurred without program intervention.
However, the Evaluators highlight this finding, as NEEA
savings allocation and cost allocation methods are not
currently consistent with regulatory requirements.
Finding #14: The Evaluators estimated verified Ex Post
aMW for the standards efforts to display 34% and 50%
realization rates for Idaho Power electric and Avista The Evaluators reference Recommendation#1:The
electric within the state of Idaho, respectively. Avista gas Evaluators recommend Avista and Idaho Power
did not claim any savings for standards. The difference request NEEA to report annual savings via the
between claimed savings and verified savings is due to the service territory methodology for each measure
change to using service territory allocation rather than claimed by NEEA for each Idaho Power electric,
funder share allocation. A minor cause of discrepancy is Avista electric,and Avista gas.
due to corrected baseline units using influence evaluation
values.
Finding #15: NEEA contracts third-party evaluators to Recommendation #8: The Evaluators recommend
conduct "influence evaluations" for each standard, which that third-party influence evaluations are
summarizes NEEA's overall qualitative and quantitative completed for the federal standards in which
influence towards federal standards updates. NEEA uses energy savings are claimed by NEEA, as well as any
the quantitative assessment as an estimate of federal federal standards in which NEEA hopes to claim
standards naturally occurring baseline. The Evaluators savings for in the future.This third-party evaluation
found that some of these influence scores were not must include the objective to quantitatively
integrated properly to estimate baseline units. The estimate NEEA influence towards the standard
Evaluators also found a small number (3 of 19) federal update as a proportion of incremental savings.This
standard measures in which savings are claimed by NEEA influence evaluation is suitable for removing the
lack influence evaluations. market baseline counterfactual in which NEEA did
not participate in standards update efforts.
Addendum 15
Exhibit No.2
Case No.IPC-E-24-35
Q.Nesbitt,IPC
Page 15 of 16

Finding #16: The Evaluators estimated verified Ex Post
aMW for the code efforts to display 137%, 125%, and 87%
realization rates for Idaho Power electric, Avista electric, The Evaluators reference Recommendation#1:The
and Avista gas savings within the state of Idaho, Evaluators recommend Avista and Idaho Power
respectively.The difference between claimed savings and request NEEA to report annual savings via the
verified savings is due to the change to using service service territory methodology for each measure
territory allocation rather than funder share allocation. claimed by NEEA for each Idaho Power electric,
Overall,the funder share allocation underestimated Idaho- Avista electric,and Avista gas.s
specific code savings using the current NEEA policy of
claiming 100%code after code is implemented.
The Evaluators reference Recommendation#5: The
Evaluators recommend that measure-level values
The Evaluators reference Finding#10 also applies for the are only included in annual reports for measures in
codes review:The database review revealed that a variety which savings are claimed. In addition, the
of fields (measure life, UES) were empty across measure Evaluators recommend NEEA continue to document
types due to lack of savings claimed for the measure,which each value accurately and that each field is
made verification of values difficult and complicates completed in the workbook to allow for year-over-
tracking of a measure progress over time year tracking of regional units, baseline units,
retirement units, and unit energy savings values
over time.
Finding #17: Currently, NEEA does not complete third-
party evaluations of NEEA "influence" towards codes
updates as is currently done for federal standards updates.
Therefore, NEEA currently claims 100% savings for code-
built homes. As summarized in the standards influence
evaluations summarized in Table 3 35, NEEA influence
towards standards ranges between 2.6%and 61%. If codes Recommendation #9: The Evaluators recommend
are evaluated similarly, and portray a similar range of an evaluation is completed for each code update to
influence, NEEA code savings could be significantly estimate NEEA's qualitative and quantitative
overrepresenting savings. NEEA's current policy is to influence towards the code update, or,
report 100% of code-built residential and commercial alternatively, incorporating a quantitative method
building savings(while integrating compliance rates)for 10 for isolating incremental savings due to NEEA-
years after the effective code update date.Currently,NEEA specific efforts approved by a third-party evaluator.
does not maintain a model to estimate naturally occurring
baseline over time, as it does for its energy efficiency
measures. Essentially, the current NEEA methodology
assumes that there would be a 10-year lag in current
residential and commercial building code if NEEA did not
participate in code update efforts.
Finding #18: The Evaluators reviewed simulation model
methodology used by NEEA to estimate code savings and
found that UES methodology for code savings do not
present any concerns.
Addendum 16
Exhibit No.2
Case No.IPC-E-24-35
Q.Nesbitt,IPC
Page 16 of 16

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-35
IDAHO POWER COMPANY
NESBITT, DI
TESTIMONY
EXHIBIT NO. 3

SEE ATTACHED SPREADSHEET

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-35
IDAHO POWER COMPANY
NESBITT, DI
TESTIMONY
EXHIBIT NO. 4

February 15, 2023 >>
neea
NEEA Operational Guidelines for Estimating
Cost-Effectiveness
Title: Evaluating Cost-Effectiveness of Energy Efficiency
Owner: NEEA Data, Planning and Analytics Department, Principal Planning Analyst
Type:Guidelines
Description:These guidelines provide NEEA's methodology to estimate cost-effectiveness of energy efficiency
Last Update Date: February 2023
OF •
1. INTRODUCTION.........................................................................................................................................2
1.1. NEEA'S APPROACH......................................................................................................................................2
1.2. NEEA'S COST-EFFECTIVENESS GOAL..................................................................................................................3
2. CORE PRINCIPLES OF ESTIMATING COST-EFFECTIVENESS..........................................................................4
3. NEEA'S COST-EFFECTIVENESS TEST............................................................................................................5
3.1. COST-EFFECTIVENESS METRICS......................................................................................................................6
3.1.1 Benefit Cost Ratio.....................................................................................................................6
3.1.2 Levelized Cost...........................................................................................................................7
4. INPUTS......................................................................................................................................................8
4.1 AVOIDED COST OF ELECTRIC RESOURCES.............................................................................................................8
4.2 CARBON SAVINGS.........................................................................................................................................9
4.3 REGIONAL ACT CREDIT....................................................................................................................................9
4.4 DEFERRED TRANSMISSION,DISTRIBUTION,AND GENERATION CAPACITY COSTS..............................................................9
4.5 INCREMENTAL CAPITAL COSTS...........................................................................................................................9
4.5.1 Pre-Conditions..........................................................................................................................9
4.5.2 Current practice/initial capital cost.........................................................................................10
4.6 REPLACEMENT COSTS...................................................................................................................................12
4.7 OPERATION AND MAINTENANCE COSTS(O&M)..................................................................................................12
4.8 INITIATIVE ADMINISTRATIVE COSTS..................................................................................................................12
4.9 NEEA INITIATIVE IMPLEMENTATION AND EVALUATION COSTS.................................................................................12
4.10 OTHER QUANTIFIABLE NONELECTRIC BENEFITS OR NEGATIVE COSTS.....................................................................13
4.11 PERIOD OF ANALYSIS..................................................................................................................................13
4.12 DISCOUNT RATE AND DOLLAR VALUE.............................................................................................................13
5. AGGREGATING THE MEASURE-LEVEL RESULTS........................................................................................ 13
6. MANAGING COST-EFFECTIVENESS ACROSS NEEA'S PORTFOLIO.............................................................. 13
7. COST-EFFECTIVENESS REVIEW PROCESS..................................................................................................14
Q2023 Copyright NEEA Page 1 1
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 1 of 14

1. � •D •
Evaluating the cost-effectiveness of energy efficiency is essential to identifying how much of the region's potential
for energy efficiency resources could be captured. Defining cost-effectiveness helps energy efficiency compete
with the broad range of other resource options.
In its simplest form,energy efficiency cost-effectiveness is measured by comparing the benefits of an investment
with the costs. Five key cost-effectiveness tests have been used for over 20 years as the principal approaches for
energy efficiency program evaluation.These five cost-effectiveness tests are the participant cost test(PCT),the
utility/program administrator cost test(PACT),the ratepayer impact measure test(RIM),the total resource cost
test(TRC)and the societal cost test(SCT).
The most common primary measurement of energy efficiency cost-effectiveness is the TRC,followed closely by the
SCT.A positive TRC result indicates that the program will produce a net reduction in energy costs in the utility
service territory over the lifetime of the program.The distributional tests(PCT, PACT,and RIM)can then be used to
indicate how different stakeholders are affected. Historically, reliance on the RIM test has limited energy efficiency
investment, as it is the most restrictive of the five cost-effectiveness tests.
The choice of where to apply each cost-effectiveness test has a significant impact on the ultimate set of measures
offered to customers. In general,there are three places to evaluate the cost-effectiveness test:at the"measure"
level,the"initiative" level,and the"portfolio" level.
A key position in any of the cost-effectiveness tests is understanding the baseline against which the cost and
benefits are measured.What costs and benefits would have been realized absent energy efficiency?
1.1. NEEA'S APPROACH
NEEA's purpose is to look at the total societal impact of transforming a market to ensure that the regional
investment is an appropriate use of funds for the long term.Working under this perspective NEEA considers all
incremental quantifiable costs and benefits of the total regional savings achieved through transformation,
regardless of who accrues them. Ultimately, NEEA, as a regional organization, is attempting to answer the
question:"will costs to society be reduced relative to an alternate resource?"
NEEA considers a 20-year horizon when estimating the cost-effectiveness of a market transformation initiative.
This allows the full effect of the investment and market results of efficiency conditions and resulting adoption to
manifest.
Choosing a narrower time slice for assessing cost-effectiveness would yield misleading results because the analysis
would not capture the full scope of the Market Transformation investment and return on investment horizon.
Examples include the following:
Page 1 2
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 2 of 14

Investment RA 1 RA 2 RA 3
in MTI Codes&Standards
Z Market
0 Share of MTI
' Innovation
> ' D
0 z
Z X
Z '
TRANSFORMATION ;
t..................
,,L Natural
0 Baseline
LU Forecast
Q
x
LA
H
W
Y
cc
CQ
C
Innovators Early Adopters/Majority Late Majority/Laggards
TIME
RA signifies Range of Analysis
RA 1: Investment is high, market has yet to materialize. Benefits will be low, and this paradigm forces incorrect
decision-making to either significantly reduce costs, leading to poor program results, or shut down the program
completely before it can pay dividends.
RA 2: Investment is winding down, market structures are building,and consumers are adopting.This is still an early
slice of consumer potential and may inadvertently signal that the market is too small or that investment must
conclude immediately, sabotaging the likelihood of securing sustainable mechanisms in the market.
RA 3: Investment has concluded, market has shifted, and consumer adoption has reached take-off point.This is a
positive state in the MT initiative and yields positive cost-effectiveness results but doesn't account for the
investment period that enabled the results to materialize and may signal overoptimistic expectations for future
programs.
MT:The construct spans the complete horizon of investment to market saturation to capture the full costs and
benefits of the effort.
1.2. NEEA'S COST-EFFECTIVENESS GOAL
NEEA's goal is to maintain a portfolio of programs that are cost effective. Its 2020-2024 Business Plan defines cost
effective as having a portfolio Benefit-Cost Ratio equal to or greater than one.To maintain a cost-effective
portfolio, NEEA evaluates the Benefit-Cost Ratio of its initiatives prior to adding them its portfolio.As part of its
due diligence, NEEA also reports levelized costs.
Page 1 3
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 3 of 14

2. O. PRINCIPLES
Where possible and sensible, NEEA aligns with the Northwest Power and Conservation Council's(NWPCC)
approach. Key concepts here include valuing efficiency as a resource and alignment with regional policy goals and
objectives. NEEA also applies principles from the National Standard Practice Manual. NEEA makes few adjustments
to these principles to better reflect Market Transformation work.Table 2 lists the Core Principals by source.
Table 1:Core Principles
. - 111. . . ROOM Mil .-
Be incremental to baseline. Costs and benefits should reflect the differences between
the efficient and baseline cases.
Represent costs/benefits throughout measure life.The entire stream of costs and
lir benefits associated with the efficient and baseline cases over the measure life should
be accounted for. For example,for an early retirement measure,the efficient case
capital costs are incurred when the measure is implemented, but baseline
replacement costs(assumed to be the full cost of the current practice equipment)are
incurred at the end of the Remaining Useful Life(RUL). Use the same baseline as for
savings.The same baseline that is used for savings should be used for costs and
benefits and may differ during the RUL and balance of measure life periods.
.. . Be specific to measure application.Where possible, costs and benefits should be
specific to the measure application, defined by identifiers such as delivery mechanism,
geographic region, market sector, building type,and business type.
+ Be discounted to present value. Costs and benefits incurred later than the time of
measure delivery should be discounted to the time of measure delivery.
�. Be in real dollars for the base year of the current Power Plan. When converting costs in
different base years to the base year of the assessment,the national Gross Domestic
Product(GDP)deflators published in the SIW should be used.
- Reflect the average for expected participants. Costs and benefits should reflect the
average incremental cost for expected participants. Where costs are significantly
different across groups of expected participants and data are sufficient to discern this,
measure identifiers can be used to differentiate, even if savings are not different.
. Represent a Northwest regional perspective. Costs and benefits should be expressed
as net values across the region. Program incentives should not be included as a cost or
a benefit because the cost to program is equal to the benefit to the participant(i.e., it
is simply a financial transfer).
All of the costs and benefits of electricity and natural gas savings(or increases)are
computed by ProCost as a function of the measure application's annual savings, load
profiles, and measure life', and other financial parameters approved by the RTF for
use across all measures.
Cost-effectiveness practices should be symmetrical,where both costs and benefits are
included for each relevant type of impact.
.. - Cost-effectiveness practices should be completely transparent, and should fully
document all relevant sources, inputs,assumptions, methodologies,and results.
' NEEA will deviate from the RTF's Measure life assumption if it has newer data.
2 National Standard Practice Manual for Assessing Cost-Effectiveness of Energy Efficiency Resources. May 2017.
https://nationalefficiencyscreening.org/wp-content/uploads/2017/05/NSPM May-2017 final.pdf.
Page 14
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 4 of 14

Cost-effectiveness practices should account for all relevant,substantive impacts,even
those that are difficult to quantify and monetize. Using best-available information,
proxies, alternative thresholds, or qualitative considerations to approximate hard-to-
monetize impacts is preferable to assuming those costs and benefits do not exist or
have no value.These impacts should also be reviewed regularly as some may become
easier to quantify over time.
PrinciplesRelevant .
NEEA assesses cost and benefit streams throughout the process of transformation.
This can include:
• Declining costs as market barriers are removed
• Increasing savings as technology advances
NEEA will include costs and benefits of efficiency that occur anywhere along the supply
chain from production to consumption if they impact the NW region.
NEEA adds the present value of administrative costs to the analysis. NEEA also includes
midstream incentives in the administrative costs.
3.�NEEAS COST-EFFECTIVENESS TEST
NEEA uses a similar perspective as the NWPCC.This perspective originates from the Pacific Northwest Electric
Power Planning and Conservation Act3 passed by Congress on December 5, 1980.While this legislation was written
before the terms from the National Standard Practice Manual (such as Total Resource Cost or Societal Cost tests)
were in the vernacular,specific sections that establish this perspective include:
3(4)(A). "Cost-effective", when applied to any measure or resource referred to in this chapter, means
that such measure or resource must be forecast--
3(4)(A)(i). to be reliable and available within the time it is needed, and
3(4)(A)(ii). to meet or reduce the electric power demand, as determined by the Council or the
Administrator, as appropriate, of the consumers of the customers at an estimated incremental
system cost no greater than that of the least-cost similarly reliable and available alternative measure
or resource, or any combination thereof.
3(4)(B). For purposes of this paragraph, the term "system cost"means an estimate of all direct costs
of a measure or resource over its effective life, including, if applicable, the cost of distribution and
transmission to the consumer and, among other factors, waste disposal costs, end-of-cycle costs,
and fuel costs (including projected increases), and such quantifiable environmental costs and
benefits as the Administrator4 determines, on the basis of a methodology developed by the Council
as part of the plan, or in the absence of the plan by the Administrators, are directly attributable to
such measure or resource.
NEEA considers benefits and costs such as Health, Safety and Comfort currently not considered by the NWPCC if
the values can be quantified and directly tied to the measure. Unlike the Council, NEEA is not comparing the
output with other energy resources for decision making. NEEA is only looking at the cost-effectiveness for the
3 Northwest Power Act Summary Webpage. NWPCC.January 2010.
https://www.nwcouncil.org/reports/northwest-power-act.
'Administrator" means the Administrator of the Bonneville Power Administration
Page 1 5
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 5 of 14

measure in question using the best available data. If NEEA does deviate from the Council for these reasons, NEEA
will clearly document and communicate the deviation.
Given this, NEEA looks at the total societal impact of transforming a market to ensure that the regional investment
is an appropriate use of funds for the long term. Working under this perspective NEEA considers all incremental
costs and benefits of the total regional savings achieved through transformation, regardless of who accrues them.
Ultimately, NEEA, as a regional organization, is attempting to answer the question:"Will the benefits to society be
greater than the costs?"
3.1. COST-EFFECTIVENESS METRICS
NEEA calculates both Benefit-Cost ratios and Levelized Costs.
3.1.1 BENEFIT COST RATIO
The benefit-cost ratio is the summation of the monetized benefits divided by the monetized costs. The Calculation
converts all negative costs to positive benefits and all negative benefits to positive costs before dividing the total
benefits in dollars by the total costs in dollars. The conversion means that the CE Index can never be negative. A
measure is cost-effective if the ratio is greater than or equal to one.All costs and benefits are incremental values
to the non-initiative market alternative products or services. The Benefit-Cost Ratio has the following formula:
" Benefitst,m
_ � (1+r)t
Benefit-Cost Ratio: n, Costst,m
Yt_,=, (l+r)t
Where,
t=year
n=period of analysis
r=discount rate
m=measure within the initiative
The benefits include any monetized benefits associated with the measure.
These include:
• Avoided Cost of Electric Resource
• Carbon Savings
• Deferred Transmission, Distribution, and Generation Capacity Costs
• Other Quantifiable Non-Electric Benefits or Negative Costs
The costs comprise monetized incremental per unit cost associated with measure.
Page 6
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 6 of 14

These include:
• Incremental Capital Cost
• Replacement Costs
• Operation and Maintenance Cost
• Local Program Administrative Costs
• NEEA Initiative Implementation and Evaluation Costs
• Other Quantifiable Incremental Costs
3.1.2 LEVELIZED COST
The Levelized Cost is the net present value of all the costs(capital, 0&M, and negative non-energy benefits)
annualized over the initiative life and divided by the annual electricity savings in kWh.The value is often used to
compare the cost of efficiency to other generating resources.
� NetCostsr,m
,
Levelized Cost(Cents/kWh)= L+
t (1+r)r
YEBenefitsr,m
, (1+r)`
Where,
t=year
n=period of analysis
r=discount rate
m=measure within the initiative
The Net Costs comprise monetized incremental per unit cost associated with initiative less the monetized non-
electric benefit.
These include:
• Incremental Capital Cost
• Replacement Costs
• Operation and Maintenance Cost
• Local Program Administrative Costs
• NEEA Initiative Implementation and Evaluation Costs
• Other quantifiable incremental costs such
• Less:
— Deferred transmission,distribution, and generation capacity costs
— Other quantifiable non-electric benefits or negative costs such as gas savings or
a decrease in Operation and Maintenance cost.
Page 1 7
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 7 of 14

The Electricity Benefit is the average incremental per-unit savings(kWh)'at busbar associated the
initiative over the period of analysis.
UES* (1 +Bulk T&D Loss Factor) * (1 +LocalDistributionLossFactor)
Where UES=Unit Energy Savings in kWh per Year
The Bulk System T&D Loss Factor and the Local System Distribution Loss Factor comes from the current
Power Plan.
This section describes how NEEA calculates each of the inputs.
• Avoided Cost of Electric Resource
• Carbon Savings
• Regional Act Credit
• Deferred Transmission, Distribution, and Generation Capacity Costs
• Incremental Capital Cost
• Replacement Costs
• Operation and Maintenance Cost
• Local Program Administrative Costs
• NEEA Initiative Implementation and Evaluation Costs
• Other Quantifiable Non-Electric Benefits or Negative Costs
• Period of Analysis
• Discount Rate and Dollar Value
4.1 AVOIDED COST OF ELECTRIC RESOURCES
The 2021 Power Plan defines avoided cost as:
An investment guideline, describing the value of conservation and generation resource investments in terms of the
cost of more expensive resources that would otherwise have to be acquired.'
Deterred electricity consumption is one of the main components of the benefits portion of the Benefit-Cost Ratio.
The value of the energy conservation by time segment depends upon the energy price by time segment. NEEA's
uses the NWPCC's electric energy price forecasts by time segment to estimate the values of electric savings.These
values are available on the RTF's website htti)s://rtf.nwcouncil.org/work-products/supportinq-
documents/procost.
6 The difference between the amount of energy savings acquired or planned to be acquired as a result of energy
efficiency activities in one year, and the amount of energy savings acquired or planned to be acquired as a result of
the energy efficiency activities in the prior year.
62021 Power Plan Glossary(nwcouncil.org)
Page 18
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 8 of 14

4.2 CARBON SAVINGS
The reduction in energy consumption can also reduce carbon emissions.The Council has a carbon price forecast
($/MWh)that it adds to the avoided cost forecast.
The carbon values are available on the RTF's website.'
4.3 REGIONAL ACT CREDIT
NEEA includes the Council's application of the Regional Act Credit in its calculations. For the 2021 Power Plan,the
credit is:
Used in the act to give economic preference to conservation resources.When estimating incremental cost of an
energy-efficiency measure,this cost is reduced by 10%of the value of the energy system benefits.
4.4 DEFERRED TRANSMISSION, DISTRIBUTION, AND GENERATION CAPACITY COSTS
In addition to the value of electricity conservation, savings occur because of the elimination of line losses. If
utilities produced the equivalent power as opposed to conserved,then that electricity would have moved across
power lines resulting in power line losses.
Measures can also reduce peak demand. NEEA's uses the Council's definition of peak. For the 2021 Power Plan,the
definition is:
Peak-load hours are defined as the four hours beginning at 7pm and ending at 11pm, Monday through Saturday.
Off-peak hours are the remaining 20 hours in the day(M-Sa)and all day Sunday. For Council analysis,the winter
period is roughly defined as the months of October through March.The summer period runs from April through
September. However,the most important winter months with respect to resource planning are December,January
and February. Similarly,the most critical summer months for resource planning are July and August. NEEA also
runs the analysis using winter and summer peak assumptions for additional perspectives. For winter peaking, NEEA
assumes the peak hours are 6 pm weekday, December-February. For summer peaking, NEEA assumes the peak
hours are 6 pm weekday,July-August.
4.5 INCREMENTAL CAPITAL COSTS
Incremental costs are a key assumption that drives cost-effectiveness, and therefore is evaluated by third party
evaluations.The 2021 Power Plan defines the Incremental Costs as:
The difference between the cost of baseline equipment or service and the cost of alternative energy-efficient
equipment or service.
Capital Costs should represent the cost of efficiency gains and not non-energy value.
4.5.1 PRE-CONDITIONS
For retrofits, NEEA uses the full cost of the device plus installation costs.The incremental cost of Ductless heat
Pumps,for example, is the full cost of installation and equipment.The data often comes from NEEA or utility
programs.
'httr)s:Hrtf.nwcouncil.org/work-products/supporting-documents/r)rocost.
Page 9
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 9 of 14

For early replacements,the full costs are adjusted based on the remaining present value of the old device.
4.5.2 CURRENT PRACTICE'/ INITIAL CAPITAL COST
For replacements or new construction/lost opportunity measures,the cost should reflect the incremental cost of
increased efficiency.This approach is not the same a comparing the difference between the cost of an efficient
product and a non-efficient option.The measurement should control for key product attributes that also influence
price.
NEEA uses three approaches for this analysis.
• Component analysis:determine which technology options enable a product to improve EE,then find cost
data for the necessary components.
• Hedonic pricing model:collect online retail products data and fit a regression model to the data.
• External Estimates:use estimates already completed by external parties such as the Department of
Energy(mostly used for initiatives prior to Market Development).
The biggest difference between the component analysis and Hedonic model is that one is measuring the cost to
the manufacturer and the other—Hedonic Model—is measuring the cost to the consumer. NEEA will use either
approach; but the approach should best represent the capital cost to the region.
Component analysis measures the incremental measure cost(IMC) based on the component within the product
that makes it more efficient. Figure 1 shows the steps. NEEA has used this approach with televisions and new
construction measures. For televisions, NEEA identified that the cost of backlighting was a proxy for the IMC. The
Televisions initiative purchased industry data on component costs and linked the components to its efficiency
measures,which were a function of the ENERGY STAR versions and the screen size. Finally, NEEA compared the
lighting options to estimate the IMC.
Figure 1: Method to Estimate Component Costs
STAGE OUTCOME
1. ..uct-specific technical - 1.Attributes that affect efficiency
2.Acquire component-level data 2. Costs and impacts of efficient
components
3.Analyze paths to efficiency 3. Determine cost effectiveness of
component combinations
4. Minimum cost of efficiency
Compare4. product options improvements for diverse set of products
Lim-
Options for acquiring the cost data:
Page 10
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 10 of 14

• Search for available component-level data
• Contact manufacturers
• Perform teardown analysis
• Purchase teardown analysis data
• Contact installers for installation
• Field tests for installation.
• Research (lab and/or field)for operations and maintenance
Hedonic Price modeling uses pricing data and regression analysis to isolate the IMC. NEEA uses this approach for
most consumer products.Steps to estimate IMC include web-harvesting, data cleaning, multiple regression
analysis,and model selection and verification (Figure 2).Some advantages to this approach are:
1. Measures consumer price differences, not manufacturer cost
2. Yields insights about which product features most strongly influence price
3. Less expensive than component analysis
4. Over time, more data leads to more precise IMC estimates
5. New products can be added as needed
Figure 2: Method to Create a Hedonic Price model
STAGE OUTCOME
1. • harvesting 1 . Raw data
data attributes 2. Likely key attributes that
2. Clean influence price
3. Multiple regression ana3. Identify models that
explain price variance
4. Model " " •n & validation 4. Identify the best model
�1 5. Convert EE coefficient
5. EE IMC estimate
to $
Some limitations to consider with Hedonic Price Models are:
1. The price is not tied to the specific technology pathways for efficiency
2. Price to the consumer does not always reflect cost to the manufacturer
3. Online product selection could differ from brick and mortar store selection
4. The regression can only control for product features that are listed online
As a result,cross-checking the results with market data is important.
Page 11
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 11 of 14

External estimates are the most common source in the Department of Energy's Technical Support documents.
Other sources include the Regional Technical Forum,consulting firms, and/or staff's best professional judgment.
This approach is limited because the information is often dated and difficult to align with initiative baselines.
4.6 REPLACEMENT COSTS
Because NEEA looks at cost-effectiveness over a 20-year period, NEEA considers how the capital costs could
decline over time;thus, affecting the cost to replace the measure over the analysis period.
Replacement costs can account for economies of scales.An example of economies of scale would be the declining
average cost of an ENERGY STAR product as manufacturers switch production.
It is important to note that the cost should still be incremental to the initial baseline.As a result,the replacement
cost does not go to zero because the measure becomes a code or standard.
4.7 OPERATION AND MAINTENANCE COSTS (0&M)
The RTF defines the 0&M costs as:
The ongoing and periodic incremental costs required to operate and maintain the measure affected
building components or equipment over the measure life. Operation and Maintenance includes costs for
fuels(except electricity and gas)and water. Other materials or services that may be required for operation
and maintenance should be valued if the incremental cost or benefit is expected to be substantial.
0&M Costs should represent the annualized maintenance for the efficient measure compared with the baseline
option.The value can be either positive or negative. For example,the longer life of CFLs led NEEA to use a negative
0&M estimate based on cost savings from not needing to replace the bulb with an incandescent.
NEEA generally uses third-party research or RTF assumptions for 0&M inputs. Initiative data can also support 0&M
estimates.
4.8 INITIATIVE ADMINISTRATIVE COSTS
The RTF 2018 Operative Guidelines defines Initiative administration costs as:
The administrative costs(such as audits, design services, marketing and overhead)incurred by the
initiative operator...incentives are not included as they are transfer payments and do not impact regional
cost-effectiveness.
NEEA estimates these costs incurred by utilities,the Bonneville Power Administration and the Energy Trust and
governments using the following approach.
• Market Transformation Administrative Cost: Utilities,the BPA and the Energy Trust incur additional costs
to oversee NEEA's initiative. NEEA estimates this cost as 3%-20%of the NEEA's direct costs.The
percentage depends on the level of involvement that the local programs have with the initiative.
Generally, if the utilities do not have a local program for the measure,the cost would be 3%.
• Local Program Administrative Costs: NEEA's partners incur a cost to administer its initiatives. Generally,
NEEA estimates the value is 20%of the incentive cost. NEEA tracks the incentives costs through its
initiative team or its Annual Local Programs survey.The 20%is a standard percentage that NEEA uses to
estimate administrative costs that utilities incur for their incentive programs.
4.9 NEEA INITIATIVE IMPLEMENTATION AND EVALUATION COSTS
Page 1 12
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 12 of 14

NEEA costs comprise the implementation and contracts costs, upstream incentives, evaluation,and overhead
costs.
• Implementation and Contracts:The implementation and contracts costs comprise payments to
contractors, marketing efforts and website enhancements.
• Incentives:The costs should include incentives as part of the TRC if the incentives are upstream and not
included in the consumer's cost.
• Evaluation: NEEA evaluates currently and previously funded initiatives. NEEA includes these and other
evaluation costs in its cost-effectiveness calculation as well as its budget forecasts.
Historical costs come from NEEA's accounting department.The forecasts come from the initiative team.
4.10 OTHER QUANTIFIABLE NON-ELECTRIC BENEFITS OR NEGATIVE COSTS
NEEA attempts to quantify all other non-energy benefits that result from a measure including such items as
environmental costs and benefits directly tied to the measure such as wastewater and water savings.
4.11 PERIOD OF ANALYSIS
From initiative-level analysis, NEEA assesses the benefits and costs over a 20-year period starting from the
inception of the initiative.The length of time aligns with the length of time the Northwest Power and Conservation
Council uses for power planning purposes.
4.12 DISCOUNT RATE AND DOLLAR VALUE
NEEA discounts the costs and savings based on the most recent Power Plan discount rate assumption.This value is
meant to represent a societal discount rate and is expressed in real terms(accounting for inflation).Additionally,
the dollar values are in the Plan Power's base year. For the 2021 Power Plan,the year is 2016.
5.�AGGREGATING THE MEASURE-LEVEL RESULTS
NEEA evaluates cost-effectiveness at both the initiative and portfolio level, however;to do this the values are first
calculated at the individual measure-level.When possible, measures are disaggregated if components of the
measure are subject to different benefits,costs or load shapes. Measures are aggregated to the initiative and then
portfolio level based on the relative 20-year Total Regional Savings.
• • • PORTFOLIO
NEEA uses a management framework called the Initiative Lifecycle(Figure 1)to progress initiatives from concept
development to initiative development and finally full-scale market development.
Page 1 13
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 13 of 14

Figure 3:NEEA's Initiative Lifecycle
---- concept program
SCANT CONCEPT MARKETS MARKET LONG-TERM
OPPORTUNITY PRODUCT ASSESSMENT ASSESSMENT DEVELOPMENT MONITORING
Concept Initiative Start Product Readiness Scale-up Approval Initiative Review Transition
Advancement RPAC Vote Approval RPAC Vote (IR#1&#2) Complete
(CA) (IS) (PRA) (SA) (TC)
The goal is always to have a benefit cost ratio greater than or equal to 1 for both the initiative and the portfolio,
but NEEA manages cost-effectiveness calculations differently for initiatives depending upon the phase they are in.
NEEA-developed cost-effectiveness metrics are only fully generated for initiatives in the Market Development$
phase because it is at this point when the transformation objectives and associated costs and benefits are more
clearly defined.The cost-effectiveness metric should be one criterion considered by the Regional Portfolio Advisory
Committee when voting to advance an initiative through the Scale-Up Approval stage gate.
For initiatives in phases prior to Market Development, NEEA generates a preliminary cost-effectiveness metric and
runs sensitivity analysis on uncertain variables to determine the likelihood that it will be a cost effective. Initiatives
without a viable pathway to cost-effectiveness are unlikely to advance in the initiative lifecycle framework.
NEEA uses the benefits and costs of initiatives in Market Development to assess its portfolio. NEEA also adds the
remaining Business Plan budget to the costs.The goal is to have a portfolio with a Benefit-Cost Ratio greater than
1.
PROCESS[�:ICOST-EFFECTIVENESS REVIEW
NEEA vets and receive advice on cost-effectiveness topics through the Cost-Effectiveness Advisory Committee.
NEEA provides the information to the Committee for review on an annual basis and at any time upon request.
s Market Development is a phase of NEEA's Initiative Lifecycle management framework.This is the phase in which
the products, markets and interventions are clearly defined and NEEA is actively engaged in transforming the
market.
Page 1 14
Exhibit No.4
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 14 of 14

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-35
IDAHO POWER COMPANY
NESBITT, DI
TESTIMONY
EXHIBIT NO. 5

�I 0 POWER,
Idaho ower and
Background and Next Steps
Billie McWinn
Kathy Yi
Quentin Nesbitt
4 Exhibit No.5
Case No. IPC-E-24-35
4Nesbitt, IPC
Page 1 of 22

IQAHO POWER.
• What is Market Transformation
• Background
• Cost-effectiveness framework
• Types of savings
• What has NEEA delivered ?
• 1997-2023 expenses and savings
• Cycle 4 (2010-2014) savings and cost-effectiveness
• ADM Evaluation
• Decision Timeline
• Considerations
Exhibit No.5
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 2 of 22

IQAHO POWER.
Actual Market
Investment Adoption
N i v
Naturally-
_ rt Occurring
Baseline
C Transformation ,
---------------
W
dA
L
C
W
Emerging Early Market
Mainstream Market Adoption
Technologies Adoption
Exhibit No.5
Casg3W. IPC-E-24-35
Q.Nesbitt, IPC
Page 3 of 22

Who is Engaged in • ' •
0
MT?
By State
WA 1
OR MN �
• Not every state does Market NY
Transformation
• NEEA is the only multistate I�
organization ca
• Hawaii is training / education
program
• New York is "beyond EF
program
• Every group does savings / cost-
effectiveness differently
ExhibitHI
.
Nesbitt,Case No. IPC-E-24-35
Q.
..-4 of 22

-w§IQAHO POWER.
MARKET TRANSFORMATION RESOURCE • •
Scale Entire defined market Program level
Target All consumers Participants
Goal Structural changes in market leading to Near-term savings
long-term savings
Approach Save energy through mobilizing the Save energy through incenting customer
market for lasting savings participation
Scope of Effort Results from effects of multiple efforts or Usually from a single program
interventions
Technology focus Emerging or new technologies, practices Established, proven technologies,
or services practices or services with reliable savings
What is tracked, Interim and long-term indicators of Quantifiable results that can be
measured, and market penetration and structural controlled, predicted and measured, such
evaluated changes, attribution to the program and as energy savings and number of
cumulative energy impacts participants
Timeframe for cost Is usually planned over a 5-10 year Usually based on 15t year or cycle savings
effectiveness timeframe or longer
Exhibit No.5
Cash No. IPC-E-24-35
Q.Nesbitt, IPC
Page 5 of 22

What is Market • ' •
Transformation ?
NEEA Efforts vs Idaho
Power Efforts Approach to • Midstream (Distributor,
• Upstream (Manufacturers)
Market contractor)
• Midstream (Distributor, contractor) . Downstream Customers
Transformation (Customers)
Portfolio
Technology • Emerging or new technologies, * Proven Savings
practices, services
Focus
*Theory based evaluations
Portfolio Metrics& Evaluation * Market progress evaluations • Impact and process evaluations
Approach • Influence evaluations • Potential studies
•Stock assessments
Cost . Measured over 20-year portfolio *One year perspective
Effectiveness

IQAHO POWER.
Cost-Effectiveness Market Transformation Resource Acquisition
Calculation Elements
• • • Codes & Standards savings Included for market Excluded
• transformation initiatives that are
proposed to lead to a code or
• - : • • - - • • standard
• • • • • Timeframe of forecasted Cost & Lifetime of the market Program funding period
Benefits transformation initiative
(forecast 20 years forward from
current period and continue
accruing costs and savings from
the date of inception for the
initiative)
Incremental Costs Typically decline over time Typically remain static
Exhibit No.5
Case No. IPC-E-24-35
Q.Nesbitt, IPC
Page 7 of 22

What is Market • ' •
0
Transformation ?
NEEA's Approach to
Savings MARKET TRANSFORMATION APPROACH
• Total Regional Savings ACTUAL
MARKET
Savings associated with ALL market SHARE
change. Used in NEEA's portfolio cost- Net Market o-Cr_ _
effectiveness. Effects Savings
LU
ly
< MARKET
• Co-Created Savings • -
a) BASELINE Regional
All energy savings above baseline that Savings
occur in the market due to the combined LIJ
efforts of utilities, NEEA and other •
actors.
• Net Market Effects
Savings reported to utilities (funder vs 20+years
service territory share) 5 years 0 10 years 15 years
ExhibitTIME
.
Case No. IPC-E-24-35
Q.Nesbitt,
Page : .

What is Market • ' •
0
Transformation ?
NEEA's Approach to
Savings — Total Regional MARKET TRANSFORMATION APPROACH
Savings
"NEEA's purpose is to look at the ACTUAL
total societal impact of MARKET
transforming a market to ensure SHARE
that the regional investment is an .. .d
appropriate use of funds for theSavings
longterm. Working under this , Local
perspective NEEA considers all MARKET
incremental quantifiable costs SHARE Total
and benefits of the total regional Cn BASELINE Regional
savings achieved through
tranSavings
sformation, regardless of who
accrues them. Ultimately, NEEA, :
as a regional organization, is
attempting to answer the
question: will costs to society be
reduced relative to an alternate
resource?" 0 5 years 0 10 years 0 15 years 20+
TIME
NEEA-O erational-Guidelines-for-
Estimatin -E ectric-Cost-
E Fe-c-tiveness.Of ExhibitNo.
Nesbitt,Case No. IPC-E-24-35
Q.
Page • .

IQAHO POWER.
Additive'Co-Created Savings(aMW):1997-2022
• • . . • While NEEA is funded in 5-year increments,market transformation is typically a 15-20-year endeavor.The
following chart depicts how NEEA's early direct intervention investments for each business cycle resulted in
permanent market change that led to continued long-term energy savings.
•
• Working together,the region has achieved more than 919 average megawatts(aMW)of Co-Created electric
energy savings since 1997—equivalent to enough energy to power more than 670,000 Northwest homes
• each year.
•
mdwe�,m•s,.,ms xe eenree ss me�ar M+•n�rrex sa..,ys xo.my exn f�x�n.emNe man_
' • 919 aMW
. • . Cycle 1&2(1997.2004 1
. Cycle 3(2005-2009)
Cycle 4(2010.2014)
S Cycle 5
Cycle 6(2020.2022)
Figure l Co-Created Savings Estimate(2020-2039)
Forecasted Energy Savings based on Proposed Cycle 7 Market Transformation Portfolio
_ 50 Cycle 7 Cycle 8 Cycle 9
•
40
30
20
10
0
2020 20212022 2023 2024 2025 2026 2027 2028 2029 2030 20312032 2033 2034 2035 2036 2037 2038 2039
Prior Investments ■Active Programs,Codes and Standards
Exhibit No.5
, New Programs Developed in Cycle 6 New Emerging Technology for Cycle 7
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 10 of 22

UIQAHO R®
• - - - - - Initiative Lifecycle
- - • • - • • : concept development i program development market transformation --
• • _ • CONCEPT
&TRACKING
Advisory Committee Vote: Advisory Committee Vote:
Concept Advancement Program Advancement
Ben fits
Al I N E EA Costs
Exhibit No.5
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 11 of 22

0IQAHO R®
' - • • - • •
Manufactured
Homes
Current Programs in Portfolio eat Pump Water
OHeaters
Ef6c'ent Gas
' • • • 1 • Water Heaters Retail Products
• Portfolio
Dual-fuel
ResKlential HVAC Ol 10 Luminaire Level
• • Lighting Controls
High-efficiency
DOAS(natural Advanced Commercial O Extended Motor
gas) Gas Water Heating © Products-Pumps
O Power Drive
- O High-Performance Ole High-Performance
Windows
Systems Windows � HYAC
• 50+ Emerging Market 0 Efficient Fans O Roocftop ient Units O Monitonng
• and Technology 3 Previous
+A Opportunities Advanced Heat © Programs
•- •• • Pumps
concept development prograin development inarket transformation
TRACKINGCONCEPT MARKE7T LONG-TERM
.,,,-a caQm<»NEEA �=Pivgrams that advanced in Cycle 9
Exhibit No.5
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 12 of 22

UIDIAHO R.,,
2025-2029
$4.5M Cycle 7
$4.OM 2010-2014
Cycle 4 2020-2024
$3.5M I 2015-2019 Cycle 6
Cycle 5
• $3.OM
1997-
1 $2.5M 1999
Cycle 1
$2.OM 2000-2004P
� Cycle 2
_ •
2005-2009
$1.5M Cycle 3 ,
$1.0m
$0.5M
$0.0M -
°� °� o° o0 oti oti o� o� oh o° o� o� o° do titi titi ti3 ti� tih ti° ti� ti� do ,yo ,yti titi ti� ti� ti� ti° ti� ti� do
ti° ti� ti° ,yo ,yo do ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo do 1�0 ,yo do
Exhibit No.5 Q. Nesbitt, IPC
Case No. IPC-E-24-35 Page 13 of 22

What has NEEA • ' •
0
Delivered ?
Idaho Powers Savings 30,000 $4.OM
and Expenses
• Measure savings 25,000
• 2010— most measure savings from CFLs '
and clothes washers. 1
• 2011 — most measure savings from CFLs 20,000
and efficient TVs
• 2012-2014— most measure savings from
efficient TVs
111 $2.OM
• Standards savings
• 2014—first year of battery charger
standards savings 10,000
• 2016-2018 - electric motor & battery
chargers $1.0m
PF
• Codes savings 5,000
• Funder share included code savings from
other states
• Service territory savings as of 2022 report 1
• Expenses and savings not
synced
Case No. IPC-E-24-35
Q...- . of 22

• IQAHO POWER.
- $4.OM 18,000
$3.5M 16,000
14,000
12,000
• • • . - $2.5M
10,000
$2.OM
8,000
$1.5M
6,000
$1.0M
4,000
$0.5M 2,000
$0.0m 0
do titi titi ti3 ti� ti`' ti° ti� ti� do ,yo ,yti titi ti�
,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo do ,yo
Exhibit No.5
Savings ■ Expenses Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 15 of 22

What has NEEA • ' •
Delivered ?
2010-2014 Cycle 4:
Cost-effectiveness 2009 IRP Avoided 2023 IRP Avoided
Costs Costs
2010-2023
• NEEA's cost-effectiveness is
based on forecast of future Savings Avoided Avoided
savings. Costs
• Based on estimated savings Savings as reported 93,212 0:. . .
associated with Cycle 4, was
cycle 4 cost-effective? r No Codes ; ,
• At the time the Cycle 4 contract
was signed, the 2006 Integrated No Codes .
Standards ' ' '
Resource Plan was the
acknowledge IRP.
• Used assumptions from the filed Savings reduced by 50% • • •• • 2.19 $10,799,923 : •
2009 IRP.
• Ran another scenario with the
currently filed 2023 IRP.
Exhibit .
Nesbitt,Case No. IPC-E-24-35
Q.
Page 16 of 22

0
ADM Evaluation
What are Codes &
Standards?
Codes .
• Codes Codes Buildings • . • Appliances
• Envelope Equipment
• Mechanical systems
• Lighting density --a
• Standards �.. .
• Consumer products
• Lighting products
• System components ` uu
Exhibit •
Case •
Q. Nesbitt,
.•' 17 of

IQAW R®
• . Product Examples
Standards Codes and Standards Codes
Stand alone products . Controls • System performance
• Sizing • Installation Practices
• Installation Practices
LU D
i
Exhibit No.5
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 18 of 22

%6 IQAHO POWER.
Recommendation
9. Complete influence evaluations Possibly, pending further NEEA already conducts third-party
for each code update to estimate discussion with evaluation of its energy codes work. Since
NEEXs qualitative and the Cost Effectiveness the current influence approach's application
quantitative influence towards and Evaluation Advisory to reported energy savings was
the code update. Committee (CEAC). recommended by CEAC, any changes would
need to be discussed by that committee.
Possible implementation in 2025 with cost
implications to be determined.
Exhibit No.5
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 19 of 22

• [
• NEEA provide background and process to the Cost-Effectiveness Advisory Committee (CEAC)
Decision timeline
� -
Filin
i
• Decision Deadline
i
• Provided CEAC an overview of NEEA work to influence codes
•
Provided CEAC current state of evaluation approaches used to evaluate codes and standards
� • 1
Review with CEAC approach and key assumptions used to estimate savings from state energy
codes work
Present to CEAC draft approach with opportunity for discussion and feedback
i
IPC Internal '
• Present CEAC refined draft approach
DeclSlOn _ • NEEA Staff provide initial recommendation
• NEEA Staff provides final recommendation with implications to CEAC Exhibit No.5
Case No. IPC-E-24-35
• NEEA Staff to address if recommendation needs tested before implementation Q. Nesbitt, IPC
Page 20 of 22

Considerations
How is the Market
Transformed?
Alliance Structure: Funder Participation, Staff Expertise, Market Relationship
• Emerging Technology Trusted Reputation, Market Data Collection + Analysis
• Testing on heat pump water heaters
and clothes dryers
• Market Strategy & Execution
• Program implementation, planning
• Codes & Standards Emerging Market Codes Analytics, Convene
• Influencing the adoption of federal Technology Strategy + Standards Research + Collaborate
standards for vending machines, Execution valuation
motors, walk-in coolers, etc.
• AnalY tics Research & Evaluation
• Work on residential and commercial
building stocks, market progress Benefits: Customer Engagement Opportunities, Peak & Cost-Efficient Energy
evaluations (used by RTF and
potential studies) Savings, Lowered Risk, Energy Efficiency Resources, Permanent Market Change
• Convene & Collaborate
• Committees, working groups

0IQAW R®
• • • How do we want to define Market Transformation activities
✓ Acquisition programs also can lead to MT, but has not been an
emphasis
• Cost-Effectiveness is inherently different
✓ Savings timeframe
✓ Net market vs Total market
• NEEA Cycle 7 Business Plan is set
✓ Idaho Power influence limited
✓ Requires trust, but some opportunity for verification
✓ NEEA MT model requires some faith vs all facts
• Code Savings Issue (recommendation #9)
✓ 100 % for 10 years vs ?
✓ Political issues
• Standards
✓ Influence evaluations
✓ DOE vs NEEA vs Other organizations
• Replacement expectation?
✓ Does the "all cost-effective energy efficiency" directive include market
transformation? Exhibit No.5
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 22 of 22

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-35
IDAHO POWER COMPANY
NESBITT, DI
TESTIMONY
EXHIBIT NO. 6

�I 0 POWER,
Idaho ower an EEA
Follow-up and Next Steps
May 1 2024Quentin Nesbitt
; .�
Mary Alice Taylor
ver Exhibit No.6
Kathy Yi - ►- Case No. iPC-E-24-35
Q. Nesbitt, IPC
Page 1 of 28

Agenda `10n"0 POWER.
April Meeting Recap
Follow- up Items
Various Topics
Upstream/Midstream/ Downstream Efforts
Code Activities
Cycle 7 Cost-effectiveness — Idaho Power
Avista Follow- up
General Discussion

0
Meeting Recap
April 2, 2024 Agenda
• What is Market Transformation
• Background
• Cost-effectiveness framework
• Types of savings
• What has NEEA delivered?
• 1997-2023 expenses and savings
• Cycle 4 (2010-2014) savings and
cost-effectiveness
• ADM Evaluation
• Decision Timeline
• Considerations
Exhibit . .
Case No. IPC-E-24-35
Q.
.. of 28

0-10AM R®
Actual Market
' • , Adoption
• Investment
•
Naturally- ' A,
Occurring
Baseline
C Transformation
V -
W \.
Gl
C
I
Emerging Early Market
Technologies Adoption Mainstream Market Adoption .
Time ~
HI
• 1997- expenses and NEEA Idaho Power
• Cycle 4 (2010-2014 sa
Approach to Upstream(Manufacturers) -Midstream(Distributor,
cost-effectiveness Market contractor)
MidstreamTransformation ' Cost-Effectiveness Market Transformation Resource Acquisition
• ADM n /I Evaluation Calculation Elements
!'1 I V IPortfolio Emerging new Codes&Standards savings Included for market Excluded
• Decision Timeline • • • technologies, -Proven transformation initiatives that are
Focusproposed to lead to a code or
standard
• ConsiderationsTimeframe of forecasted Cost& Lifetime of the market Program funding period
-Theory..
•• • • - Benefits transformation initiative
&Evaluation .Market progress evaluationsImpact and process . (forecast 20 years forward from
-Influence evaluations -Potential st . - current period and continue
Approach -Stock assessments accruing costs and savings from
the date of inception for the
initiative)
Cost Incremental Costs Typically decline over time Typically remain static
MeasuredEffectiveness over 1 •• •lio -One year perspective Exhibit
- .-
Exhibit No.6
Case No. IPC-E-24-35 4
Q.Nesbitt,IPC
Page 4 of 28

TRANSFORMATIONMARKET -w DIM POWRO
Am ACTUAL
• • MARKET
_ SHARE
NO 113l1z1 Current Programs in Portfolio
Effects o-Created
Savings �,
irir
• , ' , • • , Q MARKET 0•
•
2 SHARE Total •�
(/7 BASELINE Regional `�; 0 rl.
H Savings
IL O�s
QwE.Nrousw Qs..r.. O mwo N,..9
�
N ran%r ®3 Rwns Ij aa..... •,� amva,.
s r.— ior..R .....rs 3o.y... �.w.�...r�.a..
TIME
$4.0M 18,000
2025-2029
54.sM Cyc( Ae� $3.SM 16,000
54.UM 2010-2014 4
Cya4 2020-2024 14,W0
N
53.SM r--J1 203s-2019 Cyc1a6 —"
12,000
cycles 1, $2.SM
53.UM �
3992- 10,00[I
52— 1999 1 S2.OM
•
Cyc1l B4OW 2000-2004
r 1 Cycle 2 $1.5M
2005-2U09 6,W0
53.SM � Cyrlw 3
• • $1.1M I I I I I I1 I) $1.OM 4,OW
. = Sn.SM $O.SM 1,W0
SO.OM SO.OM O
o"d'r 41 Qs ss -61 .e"s ,a" 41 4a
I I I I , ■Sevin R' t.p-
2009 IRP Avoided 2023
• ADM Eva uation Costs sts
2010-2023
• Decision Timelin First Year NPVDSM NPVDSM
Savings Avoided Avoided
Scenarios (MWh) Costs UCT Costs UCT
• Considerations
Savings as reported 93,212 $55,089,397 4.37 $21,599,847 1.72
No Codes 86,791 $46,417,976 3.68 $19,214,205 1.53
No Codes&Standards 18,850 $12,564,328 1.00 $4,791,642 0.38 Exhibit No.6
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Savings reduced by 50% 46,606 $27,544,699 2.19 $10,799,923 0.86 Page 5 of 28

0IQAM R,
Codes and Standards Product Examples
Codes = Buildings Standards = Appliances / Standards Codes and Standards Codes
Stand alone products Controls System performance
M Sizing Installation Practices
Equipment
Installation Practices
KS."
at has EV d
• 1997. 3 expenses an
savings Recommendation
Cycle 4 (2010-201 1 ' "
and cost-effectiven 9. Complete influence evaluations Possibly, pending further NEEA already conducts third-party
for each code update to estimate discussion with evaluation of its energy codes work. Since
NEEXs qualitative and the Cost Effectiveness the current influence approach's application
quantitative influence towards and Evaluation Advisory to reported energy savings was
the code update. Committee (CEAC). recommended by CEAC, any changes would
• Considerations need to be discussed by that committee.
Possible implementation in 2025 with cost
implications to be determined.
Exhibit No.6
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 6 of 28

0IQAW R®
• How do we want to define Market Transformation activities
• 1 - • ✓ (Acquisition programs also can lead to MT but has not been an emphasis
• Cost-Effectiveness is inherently different
✓ Savings timeframe
✓ Net market vs Total market
• NEEA Cycle 7 Business Plan is set
✓ Idaho Power influence limited
✓ Requires trust, but some opportunity for verification
✓ NEEA MT model requires some faith vs all facts
• Code Savings Issue (recommendation #9)
✓ 100 % for 10 years vs ?
at has� �'E�'A�d
✓ Political issues
• 1997 .E expenses •an Standards
savings ✓ Influence evaluations
Cycle 4 (2010-201 ✓ DOE vs NEEA vs Other organizations
and cost-effectiven
• (Replacement expectation?)
✓ Does the "all cost-effective energy efficiency" directive include market transformation?
• ADM Evaluation Alliance Structure: Funder Participation,Staff Expertise,Market Relationship,
ed 'on Trusted Reputation,Market Data Collection+Analysis
Market Codes+ Analytics,
Emerging Strategy+ Research+
Technology I Execution I standards Evaluation I . _.. .
In E7
Exhibit No.6
Case No. IPC-E-24-35 Lowered� Energy Opportunities,mer Engagement _ncy _Peak� Cost-Efficient Permanent Market Change
Q. Nesbitt, IPC
Page 7 of 28

Agenda 91 of
ML A
April Meetin Recap
0 i,-I f-a_.%W
pstr am/ Midstream / Downstream Efforts
Code Activities
Cycle 7 Cost-effectiveness
Avista Follow- up
General Discussion

N6 •IQAHO POWER,
• What will the impacts to the Company be if we don't participate?
• How will operations look different?
• Will we be able to see benefits elsewhere?
• How is the increase in cost to the Company justified?
• What will we be getting from the increase?
• How does the influence of government IRA affect thoughts on NEEA's role in
market transformation?
• How can NEEA further separate out how much savings they claim vs. the
utilities?
• How much can the Company expand into midstream and what would costs
look like?
• Are there replacement options (NEEA will cost $4,000,000 annually)
• Currently look at all cost-effective measures
• Brio vs NEEA
• Evaluate/claim MT savings from Acquisition programs?
• What Agreement exit provisions are there? Exhibit No.6
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 9 of 28

0
Follow-up Items
Various Topics - • • - • ' " = - • ' • • •
• Agreement Exit Provisions
from Cycle 6
"If the Board of Directors determines at any time that NEEA has made
insufficient progress in achieving objectives set forth in the Business Plan, or
that NEEA does not have sufficient funds to operate or meet all objectives,
I..Funder may choose to terminate or reduce its Cycle 6 Core Funding
obligations."

Agenda
ML A
April 1,Meetain Recap K(e
1 0 pie )
Various Topics
Code Collaborative
Cycle 7 Cost-effectiveness
Avista Follow- up
General Discussion

• ' - IQAHO POWER.
NEEA Activities Idaho Power Activities
• Engaging in National
Partnership
• • Influencing ENERGY STAR
specifications
• Improving DOE and EPA test
procedures
• " • Developing code proposals
• . • I with International Code
.• • • Council
Increasingsupply chain
• - • • pp y awareness Increasing supply chain
• • • Training, education, and awareness
' technical assistance (includes Training, education, and
• technical assistance
codes) Product incentives or sales
• _ 0 Product incentives
incentives
• - Increasing consumer Increasing consumer
awareness awareness
• Marketing Marketing
• Direct customer incentives
Exhibit No.6
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 12 of 28

a Re
Product Group Concept Development Program Market Development Long-term Monitoring
• - Development
• High Performance
Windows(dual fuel)
Consumer Products Retail Products
Portfolio
• - • • HVAC • Next Generation • High Performance
Residential Heat Pumps HVAC
• Rooftop Units with Heat ® .�0 Ductless Heat Pumps
Pumps • Advanced Heat Pumps
• Manufactured Homes
Lighting • Luminaire Level Lighting
Controls
Motor-Driven • Expansion to New Pump Efficient Fans • Extended Motor
Systems and Fan Applications Products(pumps)
• Efficient Motor-Drive
Systems
Water Heating • Commercial/Multifamily Heat Pump Water
Central Heat Pump Water Heaters
Heater ® •VE : IL
• Residential Heat Pump ii Exhibit No.6
Water Heaters for All Case No. IPC-E-24-35
Q.Nesbitt, IPC
Applications Page 13 of 28

Agenda 91
ML A
April 1,Meetin Recap
Various Topics
Upstr m/ Midstream / Downstream Efforts
Cyc e Cos -e fectiveness
Avista Follow- up
General Discussion

IQAHO POWER,
Recommendation
9. Complete influence evaluations Possibly, pending further NEEA already conducts third-party
for each code update to estimate discussion with evaluation of its energy codes work. Since
• • - NEEXs qualitative and the Cost Effectiveness the current influence approach's application
quantitative influence towards and Evaluation Advisory to reported energy savings was
the code update. Committee (CEAC). recommended by CEAC, any changes would
need to be discussed by that committee.
Possible implementation in 2025 with cost
implications to be determined.
Exhibit No.6
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 15 of 28

0IQAM R®
The Four Alternative Evaluation Approaches
. . .plus the current approach.
0 Qualitative Description of NEEA Influence
Aligned wrth NEEA developed,cycle-specific state code support plans.
0 (Modified) Standards Influence Evaluation Approach
Conduct a qualitative assessment to develop a quantitaMe influence"score"similar to NEEA's standards approach.
0 Index of NEEA's Effective Code Proposals
Analysis of share of effectrve Isuccessful)proposals.would require defining and valuating'effecti%*ness"
© Quantitative Measure-level Assessment
Consistent with CA PM impact evaluation approach.
5. Current Evaluation Approach (Codes "MPER")
Assessment of NEEA's influence on each code cycle through standard theory-based MPEP approach,intentionally aligned with
NEEA's cycle-specific Code Support Plans.
13C Z=xayror.FFs
Exhibit No.6
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 16 of 28

0IQAM R®
0 Comparing the Approaches
1
Incremental PrecedentsCos t
Qualitative description of LOW NEEA MT Program Investment to develop data collectionand analysis methods.could scope
influence Market Progress Evals this as part of a future Codes NIP ER.
(MPERs)
Modified standards approach Low Similar to`other Investment to develop data col IeRWn
and analysis methods.Does not
standards"evals (ether account for long-term approach
Standards not part of MT associated with market
programs) transformation.
Effectiveness score for code Low Code proposals are a Does not capture key elements codes market intenpntions buildld
er
proposals logic model outcome; training,call center,continuous
periodically assessed improvement of codes language,etcl
Quantitative measure-level High California Public Utilities Data co!lectwn and analysis
procedures A-ould need to be
assessment Commission established and standardized;budget
.,,oula need to be allocated.
Current approach None MPERs 1, 2, and 3 Data collection and analysis
procedures will be refined and
(upcoming) standardized through NiPEa r3 and
be-pond.
Exhibit No.6
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 17 of 28

IQAHO POWER,
• Active Participation in Code Development
• Adaptive Management
• Training and Education
. • -
• Compliance and Savings Measurement Collaborative
• Market Development / Measure Awareness
Exhibit No.6
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 18 of 28

010AW R®
• Currently run by the Association of Idaho Cities through a NEEA
• • - • . • • - funded grant
• Contract is for $150,000
• Group of Idaho stakeholders that meets quarterly
• AIC, NEEA, code officials (city and county), Office of Energy and
Mineral Resources, utilities (Idaho Power and Avista), energy
• , • • , _ , . code circuit rider, energy code trainers, Integrated Design Lab,
• - - - - - Idaho Conservation League, and other energy code advocates
. . - Recent Activities
• Idaho building codes Zero Based Regulation review
• Discuss trainings
• Review of the 2021 and 2024 International Energy Conservation
Code
• Could Idaho Power manage in NEEA's absence?
Exhibit No.6
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 19 of 28

Agenda 91
ML A
April 1,Meetin Recap
Various Topics
Upstream/ Midstream / Downstream Efforts
Code Activities
Avista Follow- up
General Discussion

RECAP: What is Market
Transformation?
NEEA's Approach to
Savings MARKET TRANSFORMATION APPROACH
• Total Regional Savings ACTUAL
MARKET
Savings associated with ALL market SHARE
change. Used in NEEA's portfolio cost- Net Market o-Cr_ _
effectiveness. Effects 1'z
LLI
ly
< MARKET
• Co-Created Savings SHARE Totala) BASELINE Regional
All energy savings above baseline that Savings
occur in the market due to the combined LIJ
efforts of utilities, NEEA and other •
actors.
• Net Market Effects
Savings reported to utilities (funder vs 20+years
service territory share) 5 years 0 10 years 15 years
TIME
Exhibit . .
Case No. IPC-E-24-35
Q. Nesbitt, IPC
..-

• UIDIAHO R,,,
2025-2029
$4.5M Cycle 7
$4.OM 2010-2014
Cycle 4 2020-2024
$3.5M I 2015-2019 Cycle 6
Cycle 5
$3.OM
1997-
• 1 $2.5M 1999
Cycle 1
$2.OM 2000-2004P
� Cycle 2
� 2005-2009
$1.5M Cycle 3 ,
Follow up: Cycle 7
estimated to cost $1.oM
$3.68 per residential
customer per year $0.5M
$O.OM
o0 oti oti " 1 o" o6 o� o� o" do titi titi ti3 tia 11 ti° ti� ti� ti� do yti titi ti� ti� ti� ti° ti� ti� do
ti° ti� ti° ,yo ,yo do ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo ,yo do 2�0 ,yo do
Exhibit No.6 Q.Nesbitt, IPC
Case No. IPC-E-24-35 Page 22 of 28

IQAHO POWER.
In
First Year Savings - Low Range
' - - 20,000.00
• • 18,000.00
16,000.00
14,000.00
12,000.00
10,000.00
8,000.00
• _ , 6,000.00
4,000.00
• • • 2,000.00
• 0.00
2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039
Year
■Voluntary ■Code
Lifetime Savings — Low Range
• . • • • 180,000.00
160,000.00
••- • • • 140,000.00
120,000.00
100,000.00
• • • ' . • 80,000.00
60,000.00
40,000.00
20,000.00 , 1111111 11yyyyyrtyrill no . —
ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti
Year
■Voluntary ■Code Exhibit No.6
Case No. IPC-E-24-35 23
Q. Nesbitt, IPC
Page 23 of 28

m N6 IQAHO POWER.
In
First Year Savings - Low Range
• 20,000.00
18,000.00
16,000.00
14,000.00
12,000.00
10,000.00
• ' 1 2
8,000.00
•' •• • - • ''• •' 6,000.00
•• • • • 4,000.00
2,000.00
0.00
2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039
Year
$4.5M 20,000.00
$4.OM ■Voluntary ■Code 18,000.00
$3.5 M 16,000.00
$3.OM 14,000.00
LA 12,000.00
$2.5M s
v 10,000.00
Q $2.OM
LU 8,000.00
$1.5M
6,000.00
$1.0m
4,000.00
$0.5 M 2,000.00
$0.0M 0.00
2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039
Exhibit No.6
Expenses First Year Savings Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 24 of 28

• IQAHO POWER.
2023 IRP Avoided Costs
- 2025-2039
• ' • • • • Total First Lifetime NPV DSM
Year Savings Savings Avoided
• - • • - • Scenarios (MWh) (MWh) Costs UCT
• Cycle 7 as reported: Low Range 173,609 3,079,042 $54,404,779 3.46
• - • • - • •
. - No codes 128,050 11-681,079 $37,037,459 2.36
• • • • - Savings reduced by 50% 861804 11-539,521 $27,202,389 1.73
• - • - • • No codes, voluntary savings 64,025 840,539 $18,518,729 1.18
1' • reduced by 50%
Exhibit No.6
Case No. IPC-E-24-35
Q. Nesbitt, IPC
Page 25 of 28

Agenda
ML A
April Meeting Recap
Follow- up Items
Various Topics
Upstream/ Midstream / Downstream Efforts
Code Activities
Cycle 7 Cost-effectiveness
�4& 1 0
111:W
General Discussion

Agenda
ML A
April Meeting Recap
Follow- up Items
Various Topics
Upstream/ Midstream / Downstream Efforts
Code Activities
Cycle 7 Cost-effectiveness
Avista Follow- up

N6 -U IQAHO POWER,
• Do we agree/align with the NEEA market
transformation savings model ?
• If yes, NEEA is cost-effective
• Is NEEA Market Transformation necessary?
• Regardless, benefits from NEEA's activities will
continue to occur in Idaho
• Other implications of exiting NEEA
Exhibit No.6
Case No.IPC-E-24-35 28
Q.Nesbitt, IPC
Page 28 of 28