20250211Reply Comments.pdf

_ ROCKY MOUNTAIN
POWER. 1407 W.North Temple,Suite 330
Salt Lake City,Utah 8Wl&,EIVED
A DIVISION OF PACIFICORP
2025 February 11
IDAHO PUBLIC
February 11, 2025 UTILITIES COMMISSION
VIA ELECTRONIC FILING
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8 Suite 201A
Boise, ID 83714
Attn: Commission Secretary
RE: CASE NO. PAC-E-24-10—REPLY COMMENTS
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
REQUESTING A PRUDENCY DETERMINATION ON DEMAND SIDE
MANAGEMENT EXPENDITURES
Please find enclosed Rocky Mountain Power's Reply Comments in the above referenced matter.
Informal questions related to this matter may be directed to me at(801) 220-4214.
Sincerely,
Michael S. Snow
Manager, Regulatory Affairs
Enclosures

Joseph M. Dallas, (ISB# 10330)
Senior Attorney
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Telephone: [phone]
Email:joseph.dallas&pacificorp.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER ) CASE NO. PAC-E-24-10
REQUESTING A PRUDENCY )
DETERMINATION ON DEMAND SIDE ) REPLY COMMENTS
MANAGEMENT EXPENDITURES. )
Rocky Mountain Power, a division of PacifiCorp (the "Company"), in accordance with
Order No. 32788 and Rule of Procedures 052 and 201, et. seq., and hereby respectfully submits
reply comments to the Idaho Public Utilities Commission (the "Commission") in the above-
referenced matter.
BACKGROUND
I. On October 11, 2024, the Commission issued a Notice of Modified Procedure in
Order No. 36352 for the above referenced matter, allowing parties to file comments by January
28, 2025, and reply comments by February 11, 2025. Comments were filed by Commission Staff
("Staff') on January 28, 2025. The Company provides these reply comments in response to
comments filed by Staff.
REPLY COMMENTS
2. Staff made the following statements/recommendations in their comments:
a) Recommended the Commission issue an order designating $9,043,899 of
the Company's 2022 and 2023 Demand Side Management ("DSM")
expenses as prudently incurred.
b) The Commission should Direct the Company to conduct a follow-up impact
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evaluation of the Whole Home measure category using billing data to
quantify the energy saving impacts to the Company's system.
c) The Schedule 191 Tariff Rider balance was overfunded as of
December 31, 2023, and noted the current rate of 2.5%was meant to return
the balance to zero by December 31, 2024.
d) The Company consider conducting a billing analysis to evaluate the impact
of the Wattsmart Homes Non-AHRI matching dual fuel heat pump tier
when sufficient data is available and as savings from the tier justify the
expense.
e) Staff believes the control group method proposed by the third-party
evaluator for Home Energy Reports balances the need for a control group
to inform evaluations while offering the program to as many customers as
possible.
f) In subsequent reports for the Wattsmart Battery program, the Company
report the benefits of each grid management function and include an
analysis comparing exports of consumption between standalone solar
systems and solar with battery systems.
3. In response to recommendation (a), the Company agrees that the two expenses
discovered by Staff were improperly recorded to the Idaho jurisdiction, reducing the total 2022-
2023 DSM expenses for Idaho by$59,083. The remaining$9,043,899 of the Company's 2022 and
2023 DSM expenses should be designated as prudently incurred.
4. In response to recommendation (b), the Company does not believe it is necessary
or prudent to re-evaluate the Whole Home measure category for 2021-2022 using billing data. For
the 2021-2022 period, the Whole Home measure category accounted for 2% of the total kilowatt
hour (kWh) savings for the Wattsmart Homes program. The Company believes this figure is not
substantial enough to yield statistically significant data that would alter the results of the
evaluation.
5. Additionally, Staff believes the Company's use of the REM/Rate model does not
provide meaningful evaluation of the program's impact on the Company's system. The Company
disagrees with Staff s assessment. The nationally accredited REM/Rate model is widely used by
Home Energy Rating Systems across the United States and adheres to nationally recognized
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standards for home energy efficiency analysis. Deviating from this national standard in favor of
conducting a billing analysis, as Staff recommends, would incur additional cost to the program.
6. In response to statement (c), the Company acknowledges that the Schedule 191
balancing account is currently over-collected. On August 1, 2024, Staff was informed of the
Company's intent to wait to adjust the Schedule 191 rates until the current general rate case in
Case No. PAC-E-24-04 had concluded in order to utilize the most current information for the
Schedule 191 rate analysis. The Company did not receive any objection to this approach. On
February 3,2025,the Company conveyed to Staff that with the approval of the rate case settlement
pursuant to Order No. 36452,the Company plans to conduct a Schedule 191 rate analysis to inform
if a rate adjustment is necessary to balance the account. Once the rate analysis has been conducted,
the Company will discuss with Staff and submit an Application for the Commission's approval if
a rate adjustment is determined to be necessary to balance the account.
7. In response to recommendation(d), if the savings from the Wattsmart Homes Non-
AHRI measure ever justify the expense of conducting a billing analysis, and a billing analysis is
the preferred method and industry standard, the Company will consider this approach.
8. In response to statement (e), the Company intends to continue using a deemed
savings value for the Home Energy Reports ("HER")program. The current deemed savings value
was informed by a white paper completed by a third-parry in 2020. The Company intends to
commission another white paper in 2025-2026 to update the deemed savings value. The Company
believes using a deemed savings value for HER remains the most cost-effective way to manage
the program.Additionally,the savings derived from the HER program are not counted towards the
Company's Integrated Resource Plan("IRP")targets as the program no longer yields incremental
savings and can essentially be categorized as an education and outreach program at this stage of
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the program's life. As such, creating and maintaining a control group would add needless cost to
a program wherein the Company is not claiming energy savings.
9. In response to recommendation(f), as part of the annual DSM report,the Company
will start providing a comparative analysis of exports and consumption usage between solar with
batteries and solar without batteries. The Company also currently reports on grid management
functions for Company-initiated events, such as frequency response. Grid management functions
such as load shifting, backup power, and contingency reserve are naturally occurring and are not
actively tracked or managed by the Company. The Company will continue to report on all initiated
battery demand response events.
REQUEST FOR RELIEF
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission issue a
final order designating Rocky Mountain Power's 2022 and 2023 total DSM expenditures of
$9,043,899 as prudently incurred, as recommended by Staff.
DATED this 1 lth Day of February 2025.
Respectfully submitted,
By
Joseph M. Dallas
Attorney for Rocky Mountain Power
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