20140219AVU to Staff 68-70.pdf

Avista Corp.
1411 East Mission P.O.Box3727
Spokane. Washington 99220-0500
Telephone [phone]
TollFree 8OO-727-917O
kustt
Corp.
February 18,2014
Idaho Public Utilities Commission
472W. Washington St.
Boise,lD 83720-0074
Attn: Karl T. Klein
Deputy Attorney General
Re: Production Request of the Commission Staffin Case No. AVU-E-I3 -091G-13-02
Dear Mr. Klein,
Enclosed are an original and three copies of Avista's responses to IPUC Staffs production
requests in the above referenced docket. Included in this mailing are Avista's responses to
production requests 68, 69, and 70. The electronic versions of the responses were emailed on
02ll8ll4 and are also being provided in electronic format on the CD included in this mailing.
If there are any questions regarding the enclosed information, please contact Paul Kimball at
[phone] or via e-mail at [e-mail]
Regulatory Analyst
Enclosures
CC (Email):IPUC (Klein, English, Donohue, Karpavich)
AVISTA CORPORATION
RESPONSE TO REQUEST F'OR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02114/2014
CASE NO: AVU-E-13-09/AVU-G-13-02 WITNESS: Chris Drake
REQUESTER: IPUC Staff RESPONDER: Chris DrakeTYPE: Production Request DEPARTMENT: DSM
REQUEST NO.: Staff-68 TELEPHONE: (s09) 49s-8624
REQUEST NO.:
Staff Production Request No. 55 asked the Company to list the measures that did not comply with
DSM tariff rules. The Company responded, in summary, that the'oCompany followed processes
and procedures as set forth in DSM tariff Schedule 90," but "Schedule 90 previously did not ...
mention ... prescriptive ... programs." The Company thus "proposed and received approval of
additional language [to clarify] how these programs are offered and designed in compliance with
tariff rules." See Response to Staff Production Request No. 55. With regard to the Company's
response, does the Company contend that all the measures in its prescriptive programs complied
with DSM tariff rules?
a. If so, please explain why the Company disagrees with the Cadmus 2012 Process
Evaluation conclusion thal74%;o of nonresidential prescriptive projects did not comply with tariff
rules to cap project incentives at 50oh of the incremental cost of the project. See Cadmus memo,
August 2,2013,p.7.
b. If not, please list each measure in the Company's prescriptive programs that did not
comply with DSM tariff rules and, for each listed measure, please provide: (i) the simple payback
period, (ii) the incented amount, (iii) whether or not the measure exceeded the 50%o cap; and (iv)
the specific cost-effectiveness calculations that demonstrate the measure was still cost-effective.
RESPONSE:
a. Yes. The Company contends that all the measures in its prescriptive programs complied
with DSM tariff rules. It should be noted that this does not disagree with the Cadmus
memo. On p.5 of the August 2,2013 Cadmus memo, the evaluator states "Cadmus does
not believe the tariff language was clear enough on the topic of compliance to conclude
whether individualprescriptive projects should be subject to the simple payback period
and incentive cap restrictions at the time of rebate application approval." The evaluator
adds on p.5 of the memo, "It should be clear that by presenting the prescriptive findings
below, Cadmus is simply suggesting that better clarity is needed and not necessarily that
these projects were out of compliance."
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO: AVU-E-13-09/AVU-G-13-02
REQUESTER: IPUC StaffTYPE: Production Request
REQUEST NO.: Staff-69
DATE PREPARED: 0211412014
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
Jon Powell
DSM
(s0e) 49s-4047
REQUEST:
In response to Staff Production Request No. 56, the Company lists two programs as being subject
to the tariff rules under o'market transformation." Please explain the Company's definition of
"market transformation" and how "market transformation" programs contrast with other energy
efficiency programs.
RESPONSE:
Market transformation programs are different from local DSM acquisition programs in that they
intervene in a market for a defined period of time and are then terminated with the impact of the
transformed market continuing on past that termination. Local DSM acquisition programs touch
are permanent (the qualiffing technologies may change, but there isn't a built-in termination of the
program. The Company's working definition of market transformation can be generally described
as follows:
Market transformation is a specifically defined intervention intended to shift the
adoption of a cost-effective efficiency measure towards a higher long-term trajectory
for a defined period of time, after which point the intervention ends, however the
impact of the intervention continues.
The contrasts that exist with the remainder of Avista's energy-efficiency programs include:
o Market transformation programs have an exit strategy. Generally available
incentive-granting programs are usually offered with the expectation of continuing
availability.o The intent of market transformation programs is to create a sustainable change in the
market rather than to acquire individual resources from individual customers.
Frequently, market transformation programs are performed on a regional basis, because individual
utilities don't have the critical mass necessary to impact most markets. Typically these regionally
cooperative programs are performed as part of the Northwest Energy Efficiency Alliance's
(NEEA) portfolio; however other ad hoc regional cooperative programs may also form around
specif,rc measures.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO: AVU-E-13-09/AVU-G-13-02
REQUESTER: IPUC StaffTYPE: Production Request
REQUEST NO.: Staff-7O
DATE PREPARED: 0211412014
WTTNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
Lori Hermanson
DSM
(s09) 4es-46s8
REQUEST:
In response to Staff Production Response No. 54, the Company indicates that none of its l1
renewable projects were cost-effective. See Response to Staff Production Request No. 54
(disclosing that each renewable project had a TRC and UCT of less than one). Why did the
Company incent renewable projects that were not cost-effective? How many customers who
participated in a renewable project participated in additional DSM programs (spillover)?
RESPONSE:
Earlier in the 2010-2012 time periods, Schedules 90 and 190 allowed for projects to be
incentivized regardless of the length of simple payback. The tariffs were modified during this
period to incentivize energy efficiency projects that did not exceed a simple payback of 8 years for
lighting or 13 years for non-lighting measures. While this improved the cost-effectiveness on a
going forward basis by limiting these types of longer payback, non-cost-effective projects, there
were still several projects that had been contracted under the previous tariff and therefore eligible
for incentive. Those that were completed according to the contract terms were paid, reported and
included in the overall portfolio cost-effectiveness. None of the customers who participated in a
renewable project participated in additional DSM programs.