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Home My WebLink About20241022IPC to Staff 1-5.pdf 0IQAW POWER@ RECEIVED Tuesday, October 22,2024 MEGAN GOICOECHEA ALLEN IDAHO PUBLIC Corporate Counsel UTILITIES COMMISSION mgoicoecheaallenC�idahopower.com October 22, 2024 Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-24-35 Application of Idaho Power Company for Authority to Fund its Continued Participation in the Northwest Energy Efficiency Alliance in 2025-2029 through the Energy Efficiency Rider Dear Commission Secretary: Attached for electronic filing is Idaho Power Company's Response to the First Production Request of the Commission Staff in the above-referenced matter. If you have any questions about the attached documents, please do not hesitate to contact me. Sincerely, Megan Goicoechea Allen MGA:sg Enclosures P.O.Box 70(83707) 1221 W.Idaho St. Boise,ID 83702 MEGAN GOICOECHEA ALLEN (ISB No. 7623) LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2664 Facsimile: (208) 388-6936 mgoicoecheaallenCaD.idahopower.com Inordstrom(aMdahopower.com Attorneys for Idaho Power Company 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 ) IDAHO POWER COMPANY'S ENERGY EFFICIENCY ALLIANCE IN 2025- ) RESPONSE TO THE FIRST 2029 THROUGH THE ENERGY ) PRODUCTION REQUEST OF EFFICIENCY RIDER ) THE COMMISSION STAFF TO IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Request of the Commission Staff ("Commission" or "Staff") to Idaho Power Company dated October 2, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 1 REQUEST FOR PRODUCTION NO. 1: Please provide all workpapers and supporting documentation used to develop Table 3 of Nesbitt Direct. If not already included, please specify measure life, costs, savings, benefits, and cost-effectiveness for each NEEA initiative (i.e., measures, codes, standards). RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the attachment to Staff's Request for Production No. 1 for the workpapers supporting Table 3 of Nesbitt Direct. The attachment also includes each initiative's underlying measure lives, energy savings, and overall calculated benefits. The cost-effectiveness calculations include the overall portfolio cost of Cycle 7 participation. However, because Northwest Energy Efficiency Alliance ("NEEA") did not provide a forecast of costs on a per-initiative basis, it is not currently possible to provide benefit-cost ratios at the initiative level. Additionally, NEEA was not able to provide a forecast of energy savings resulting from federal product standards, so those savings are not included in the provided measure list nor in the portfolio cost effectiveness calculations. The response to this Request is sponsored by Billie McWinn, Energy Efficiency Program and Customer Analysis Leader, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 2 REQUEST FOR PRODUCTION NO. 2: Please provide the Company's justification for using a 15-year portfolio look for its cost-effectiveness assessment. RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The Company used a 15-year forward look at the NEEA portfolio in part because the savings forecast that NEEA provided to the Company included data on measures up to 2039; as NEEA noted that within the portfolio forecast, many initiatives have a known end date before 2039, and others do not have sufficient data necessary to confidently forecast beyond then. Moreover, the Company believes that a 15-year forecast is reasonable and sufficient to capture the utility cost test benefits stemming from participation in Cycle 7. A shorter span would risk missing the effects of initiatives that have a longer ramp up time, while a longer span would require the Company to extend the forecast provided by NEEA with its own estimates. Such a forecast might be too reliant on tenuous assumptions, such as the uptake and availability of distant emerging technology. The Company also notes that state building codes generally update in 10-year cycles, so a 15-year forward look is enough to capture these changes that would stem from the 5-year duration of Cycle 7. The Company further clarifies that the 15-year look is based on the installation date of measures; measures within the portfolio have useful lives ranging from 7 to 45 years. This means that in the Company's provided cost effectiveness calculations, it is considering the benefits of savings that occur after 2039, but only of measures installed within the 15-year forecast period. The response to this Request is sponsored by Billie McWinn, Energy Efficiency Program and Customer Analysis Leader, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 3 REQUEST FOR PRODUCTION NO. 3: On Page 22 of Nesbit Direct, he describes a third-party source used to inform the average measure life of an energy efficient technology or system. Please answer the following questions: a. Please identify the third-party source; b. Please explain how the average measure life is determined; c. Please explain how this value reflects the measure life of participation in NEEA's 5-year market transformation effort; and d. Please describe any other values or methods the Company considered to quantify the measure life of NEEA participation and why they were ultimately not used to conduct cost-effectiveness test. RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The Company clarifies that the referenced comments on Page 22 of Nesbitt Direct lines 14 — 20 were intended as added context to highlight a subtle difference between the cost-effectiveness assessment of market transformation savings compared to that of a typical Energy Efficiency ("EE") program. Measure lives used for evaluating NEEA cost effectiveness are provided by NEEA itself. The "third-party source" for measure lives was in reference to the rest of the Company's EE portfolio. a. The Company references multiple third-party sources to provide assumptions across its various EE programs. Primarily, the Company uses assumptions published by the Regional Technical Forum. For some programs the Company also references assumptions calculated within a technical reference manual, most recently prepared by ADM Associates. In other cases, such as Custom projects, savings and measure lives may be calculated on a per-project basis. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER -4 b. For a typical EE program or measure, the Company uses average measure life assumptions from various third-party sources depending on the program and application. Each source may calculate measure lives using a range of industry standard methods, including market research surveys, analysis of vendor data, or engineering calculations. c. The Company used measure life assumptions provided by NEEA in its cost effectiveness analysis of the Cycle 7 portfolio. The Company believes this is the best available information with which to assess the value of the measures resulting from the 5-year funding cycle. d. The Company believes it is most reasonable to use the measure lives provided by NEEA itself and thus did not consider alternative approaches to measure lives. The response to this Request is sponsored by Billie McWinn, Energy Efficiency Program and Customer Analysis Leader, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 5 REQUEST FOR PRODUCTION NO. 4: Please provide NEEA's cycle 7 net market effects energy savings forecast for 2025-2039 for each NEEA initiative. RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see the attachment to Staff's Request for Production No. 4 for NEEA's Cycle 7 net market effects energy savings forecast for 2025-2039. The file contains both a base case savings forecast and a high case savings forecast. In its cost-effectiveness analysis, the Company only considered the base case forecast. NEEA also split out savings in the provided file to distinguish savings that will occur in the 2025-2039 range as a result of other funding cycles, namely Cycle 6 and Cycle 8. The Company did not consider either of those cycle's savings in its analysis of Cycle 7. The response to this Request is sponsored by Billie McWinn, Energy Efficiency Program and Customer Analysis Leader, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 6 REQUEST FOR PRODUCTION NO. 5: On Page 12 of Exhibit No. 6, the Company describes a potential overlap of midstream and downstream activities offered by NEEA and by the Company. Please answer the following questions: a. Please provide a comparison of NEEA's cycle 7 midstream and downstream activities in the Company's service territory relative to the Company's existing midstream and downstream DSM programs; and b. Please explain if there are any NEEA activities that the Company has opted out of due to overlapping offerings. RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Both NEEA and Idaho Power are involved in a range of energy efficiency activities, which are largely distinct from one another and driven by different perspectives, though the efforts can often add complementary value. In general, NEEA is primarily focused on upstream and midstream activities, to accelerate the market adoption of energy-efficient technologies and to influence the development of new codes or standards over its 20-year portfolio. Conversely, the Company is largely focused on midstream and downstream efforts, including direct-to-consumer incentives. NEEA's downstream engagement is limited and focused on regionwide marketing activities to increase product awareness among consumers and generally complement, rather than overlap with, the Company's Demand- Side Management ("DSM") programs. Similarly, NEEA pursues midstream activities in ways that complement the Company's efforts without duplicating efforts or causing customer confusion as more fully described in (a) below. Moreover, in order to avoid double counting, the Company provides NEEA with its claimed savings for the various DSM program measures annually, which NEEA then subtracts from net market effects IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 7 for any overlapping initiative activities as appropriate. a. In preparation for responding to these discovery requests, NEEA provided the Company with a summary of its primary initiatives for Cycle 7 along with descriptions of the proposed intervention methods; NEEA's plans for each midstream and downstream measure are summarized below, as well as how the Company's DSM programs are involved, if applicable: • Retail Product Portfolio — NEEA's retail product portfolio program consists of a range of energy saving measures, namely Energy Star appliances. NEEA will work midstream directly with national and local retailers to preferentially stock and promote efficient retail products. The Company is not involved in midstream activities on retail product measures. The Company provides downstream direct- to-consumer incentives for some of these same measures through its Heating & Cooling Efficiency Program and Retrofits Lighting Program. An example retail measure is the Connected (Smart) Thermostat incentive in the Heating & Cooling Efficiency Program. • Extended Motor Products (Pumps) — NEEA will work midstream to encourage retailers to stock and be informed of the products, as well as downstream to promote the products to consumers via educational outreach and hands-on demonstrations. The Company offers downstream direct-to-consumer incentives for pumps, including XMP, but does not separately promote or incent on this type of pump prescriptively. • Heat Pump Water Heater — NEEA will work with midstream distributors to ensure training opportunities are accessible to installers throughout the region. NEEA IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 8 intends to work with its funders in Cycle 7 to plan a downstream collaborative marketing effort. For example, NEEA worked downstream region-wide for three months in 2024 with their consumer facing heat pump water heater marketing campaign. The Company's Heating & Cooling Efficiency Program offers a downstream direct-to-consumer incentive for heat pump water heaters. • High Performance HVAC — NEEA will provide midstream incentives to manufacturers to promote product availability. The Company offers downstream direct-to-consumer incentives for this technology through its Custom Projects program. • Luminaire Level Lighting Controls — NEEA will promote the program midstream with distributors and trade associations. The Company offers downstream direct- to-consumer incentives through its Commercial and Industrial ("C&I") Retrofits program for this measure. • Advanced Heat Pumps — NEEA will provide downstream interventions via performing field tests as part of an outreach to end customers. The Company's Heating & Cooling Efficiency program and some if its C&I DSM programs offer downstream direct-to-consumer incentives for the same technology covered by this measure. The Company believes that NEEA's Advanced Heat Pump efforts align synergistically with the Company's heat pump offerings. b. Previously, in the 2015-2019 Business Cycle, the Company opted out of specific market transformation activities related to marketing and stakeholder support as a result of concerns about potential duplication of efforts that could lead to customer confusion. Since that time, however, NEEA has incorporated feedback and IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 9 addressed the Company's concerns, and the Company has not currently opted out of any NEEA activities due to overlapping offerings and does not at this time intend to opt out of any NEEA activities in Cycle 7. While some NEEA initiatives involve some of the same technologies incented by the Company's DSM programs, the Company will continue to work with NEEA to avoid duplication of effort and look for opportunities to leverage resources and to coordinate on a complimentary approach to minimize potential overlap and optimize effectiveness. NEEA regularly solicits advice from its funders on how to implement its initiatives and programs in the different regions and understands that some midstream and downstream activities, in particular, require close coordination with funders. In the event the Company does have concerns that a new NEEA initiative or program will negatively interfere with one of its own programs, it will ask NEEA to revise its approach to better suit Idaho Power's region, ideally to avoid the need to opt out entirely. The response to this Request is sponsored by Billie McWinn, Energy Efficiency Program and Customer Analysis Leader, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 10 Respectfully submitted this 22nd day of October 2024. MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 11 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 22nd day of October 2024, 1 served a true and correct copy of Idaho Power Company's Response to the First Production Request of the Commission Staff to Idaho Power upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Chris Burdin U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email Chris.Burdin(c�puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 12 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-35 IDAHO POWER COMPANY REQUEST NO. 1 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-35 IDAHO POWER COMPANY REQUEST NO. 4 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET