20210318Avista to Staff 30-40.pdf

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO: AW-E-20-13/AVU-G-20-08
REQUESTER: IPUC StAffTYPE: Production Request
REQUEST NO.: Staff - 30
031011202L r.i",r i.] DH r+. nftN/A ;. r..i.. lu riirL.ur
Ryan Finesilver , , , *, .;, q, 1.,.1Energy Efficienby ,, ':, .r*:=:,;l$i#;11
(s0e) 4es-4873
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
REQUEST:
In the 2019 Idaho Annual Conservation Report, Table 39 reports a UCT cost of $3,294,904 for
residential electric programs and Table 40 reports a UCT cost of $671,310 for residential gas
programs. In Appendix F, the table displays total Utility Costs of $2,698,269 for residential
electric and $675,070 for residential gas. Please provide a reconciliation of the Utility Cost for
Table 39 and Table 40 and the residential utility cost for gas and electric in20l9 as displayed in
Appendix F. Please provide this information in Excel format with formulas enabled.
RESPONSE
Please see StaflPR_30 Attachment A for details on the variances identified by Staff with further
description of these variances below.
Electric: The variance between the $3,294,904 in Table 39 and the $2,698,269 is a total of
$596,635. Of this amount, $592,829 is attributed to a cost element included in the Program
Administrator Cost (PAC) costs for Avista's Residential Fuel Efficiency Program. In the CE
Analysis provided by Cadmus, the costs associated with "Increased Fuel LJse Gas" was included in
the total costs; this amount was $592,829.48. For purposes of developing Appendix F, those costs
were excluded from the overall total. The other material variance was for $3,760 related to a
dual-fuel Energy Star Homes project. This amount was categorized as a natural gas item in
Appendix F but categoized as electric item in Table 39. There were also two immaterial variances,
one related to Simple Steps for $3 and for Misc. Measures for $49.
Natural Gas: The variance between the $671,310 in Table 40 and the $675,070 in Appendix F is
accounted for by the $3,760 value identified above, which is related to the Energy Star Homes
project.
AVISTA CORPORATION
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REQUESTER:
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REQUEST NO.:
IDAHO
AVU-E-20- 1 3/AVU-G-20-08
IPUC Staff
Production Request
Staff- 31
DATE PREPARED: 0310112021WITNESS: N/A
RESPONDER: Renee Coelho
DEPARTMENT: Energy Efficiency
TELEPHONE: (s09) 49s-8607
REQUEST:
In Order No. 34067, the Commission increased Low-Income funding by $125,000 annually to
weatherize more homes and decrease the Community Action Partnership Association of Idaho
waiting list, which was at 303 customers as of October 2017. Please provide the number of
customers' homes served and the number of homes on the waiting list in Avista Idaho's service
territory by year for the years 2018 through 2020.
RESPONSE:
Currently there are 271 customers on the Community Action Partnership Association of Idaho
(CAPAD waiting list, of which 178 are Avista customers. The 303 customers referenced above is
likely the entire waiting list of customers served by the Community Action Partnership (CAP)
agencies, which includes both Avista and non-Avista customers (e.g. Kootenai Electric,
Clearwater and other providers).
Avista does not keep a record of the number of customers that are on the waiting list since that
information is sourced directly from the CAP agency. The waiting list referenced is a "rolling list"
and is generated from the total number of Energy Assistance (EA) applications received. The
CAP agency inquires with the customer to see if they are interested in weatherization and if the
response is yes, then they are added to the waiting list.
Some nuances applicable to this list are that the applications are only good for a year and the
majority of people will need EA every year. Because of this, their name is always on the list of
potential candidates. Once the CAP agency's weatherization team pulls the client file and
determines ifthe customer's home needs services and/or if service is completed at their home, then
the home is removed from the list.
AVISTA CORPORATION
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REQUEST NO.:
IDAHO
AW-E-20- I 3/AVU-G-20-08
IPUC Staff
Production Request
Staff - 32
DATE PREPARED: 0310112021WITNESS: N/A
RESPONDER: Renee Coelho
DEPARTMENT: Energy Efficiency
TELEPHONE: [phone]
REQUEST:
On page 28 of the 2019 Electric Impact Evaluation, Table 24 shows the Company achieved 43o/o of
its participation goals, with 13 participants for Low-Income Fuel Efficiency. Please explain why
the Company did not reach its participation goals of 30 participants. Additionally, please explain
what led to the Company achieving 37o/o of its 101,640 kWh energy savings goal for Low-lncome
Fuel Efficiency.
RESPONSE:
Avista partners with Community Action Partnership, Lewiston (CAP) to administer its
Low-Income Fuel Efficiency program in nine Idaho counties. The CAP agency evaluates each
home with the intent to provide a holistic retrofit; sometimes the home only needs a couple of
measures, while others need a complete retrofit. While Avista does provide a list of measures that
are available to the CAP agency for servicing customers, it does not direct the CAP agency on how
many measures each home should receive.
As part of the Company's planning process, the Energy Efficiency team estimates the amount of
savings to be obtained from each program. This is typically done by updating the Unit Energy
Savings (UES) values for each measure and multiplying these numbers by the estimated
throughput for the upcoming year(s). For the Idaho Low-Income Fuel Efficiency program, the
overall number of units installed at customers' homes remains small year over year, and a 43%o
participation goal is reflective of this.
Avista achieved 37% of its Low-Income Fuel Efficiency savings goal for 2019, and this is
attributed to the lower throughput per measure. For 2019, the UES values for the program were
reduced as a result of the 2016-2017 Impact Analysis. This adjusfrnent caused the Combo measure
(Furnace & Water Heat) to be set to the 'orebate only" position, which then reduces the overall
funding available to install this measure at customer homes.
AVISTA CORPORATION
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JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-20- 1 3/AVU-G-20-08
IPUC Staff
Production Request
Staff- 33
DATE PREPARED: 0310112021WITNESS: N/A
RESPONDER: Renee Coelho
DEPARTMENT: Energy Efficiency
TELEPHONE: [phone]
REQUEST:
On page 19 of the 2019 Gas Impact Evaluation, Table 19 shows that the Company achieved 2o/o of
its participation goals. Please explain why the Company did not reach its participation goals for
the 2019 Low lncome Gas Program. Additionally, please explain what led to the Company
achieving 15% of its 25,262 therms energy savings goal for the Low-Income Programs.
RESPONSE:
Table 19 does not provide an accurate indicator ofprogram performance for Avista's Low-Income
Gas Program, as having "participation" defined to include both the number of installed units as
well as the square feet of installed insulation or windows provides an opportunity for any lack of
square footage throughput to skew the percentage of goal reached entirely. For example, of the
154,647 units listed for "participation goals", over 154k were intended to capture potential square
feet of insulation to be realized, while the remaining units were for HVAC equipment and other
weatherization measures. So, while the Company did achieve approximately 64% of its HVAC
goals, and 40Yo of its goals in other low-income weatherization measures as part of the 3,303
"participation reported", since the square footage represents such a large number of anticipated
achievements, the actual units achieved are downplayed in the final percentage of goal achieved
(2%).Put simply, these two units of measurement (the number of installed units vs. individual
square feet) are best suited in separate illustrations, as they are not parallel comparisons so basing
a percentage achievement on this mixed data is not an adequate representation of the program's
successes or failures. Please see the table below for the actual low-income participation for 2019,
including the number of units or square footage reported per project.
Cateqory
Unit of
Measurement Estimated Actual
Achievement
Percentage
Weatherization Units 53 2t 40%
Weatherization Sq Ft r54.525 3.221 2%
I{VAC Units 69 44 64%
Health and Safety Units 1 t7 1700%
Total 154.647 3.303 20
As alluded to above, the main contributor to the 15%o achievement of the Company's 25,262
therms energy savings goal was the blatant lack of participation in insulation measures during the
2019 program year. The Company had planned for approximately 17,500 therms from insulation
measures alone, but found virtually no throughput from insulation measures. Between attic and
duct insulation, there were 4 projects with an achievernent less than 100 therms in total.
AYISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO: AVU-E-20-13/AVU-G-20-08
REQUESTER: IPUC StaffTYPE: Production Request
REQUEST NO.: Staff- 34
DATE PREPARED: 0310112021WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHoNE: (s09) 49s-4873
REQUEST:
In the 2019 Idaho Annual Conservation Report, Appendix E shows a total of $91,399 for Health
and Safety for the Low-Income programs. Appendix F shows the Low-Income programs total
Utility Cost of $320,352 for gas and electric Health and Safety programs. Please provide in Excel
format with formulas enabled a reconciliation of the Health and Safety costs in Appendix E and F
for Low-Income Programs for both gas and electric.
RESPONSE:
Appendix E inadvertently included the Health and Safety dollars from2017-2019 where it should
have included only 2019. The table below summarizes how Schedule E arrived at the $320,352.
Note the total includes a rounding adjustment of $1.
Per Schedule F, the Health and Safety totals were shown as $9 1 ,3 99, which agrees to the 2019 total
in the table above.
Please see Staff PR 34 Affachment A for the excel file supporting these calculations.
Year Electric Gas Total
2017 $51,453 $50,248 $101,702
2018 $75,790 $47,255 $123,046
20t9 s42,919 $48,481 $91,399
Total $170,162 $145,985 $316,147
I HPWH Proiect included as H&S s4.204 94,204
Total per Schedule E $174.366 $145.985 $320,351
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2O- 1 3/AW-G-20-08
IPUC Staff
Production Request
Staff- 35
DATE PREPARED: 0310112021WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: (509) 49s-4873
REQUEST:
In the 2019 Idaho Annual Conservation Report, Appendix E shows Health and Safety gas utility
costs of $145,985, which is 42Yo of the Company's Low-Income Utility Cost. Please explain how
the Company monitors Lewiston Community Action Partnership Health and Safety expenditures
to ensure they do not exceed 15% of the overall program allocation. Please provide any
documentation for the Company's procedures. Please explain why 42% of program funds were
allocated to Health and Safety in2019.
RESPONSE:
Please see the Company's response to Staf[_PR_34. The $145,985 stated in Appendix E
inadvertently included 2017-2019 expenses for Health and Safety. The correct amount was
$48,481, as shown in Appendix F.
Regarding the monitoring of the Lewiston Community Action Partnership (CAP) agency's Health
and Safety expenditures, Avista begins the program year by communicating the allocation of
Health and Safety budget to the CAP agency. Health and Safety expenditures are set at the l5o/o of
the overall annual budget. Based on the Health and Safety amount of $48,481, the overall
percentage of CAP funding that was spent on Health and Safety projects was 15.24%
($48,481/$318,101).
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-20- I 3/AW-c-20-08
IPUC Staff
Production Request
Staff- 36
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0310u2021
N/A
Ryan Finesilver
Energy Efficiency
(soe) 49s-4873
REQUEST:
On page 70 of the 2019 Annual Conservation Report, the Company states that for natural gas
Energy Star manufactured homes, the rebate was reduced from $600 to $200 in the beginning of
2019, then mid-year it was increased to $400.
a) Please explain the reasoning for adjusting the rebate.
b) How often are the rebates for measures adjusted?
c) Please provide documents for the Company's formal process for setting and adjusting
rebates/incentives.
d) If no documents are available, please explain the Company's process for setting and
adj usting rebates/incentives.
RESPONSE:
a) For 2019, the estimated first year therm savings from the Energy Star Manufactured
Homes (natural gas) was lower than in the prior year, which had an effect on the overall
cost-effectiveness for the measure, bringrng the TRC to less than 1.0. Avista adjusted the
incentive value down to $200 as a result of this change. Mid-year, Avista reevaluated the
measure and decided that since there was still a positive UCT ratio, we could adjust the
incentive higher to maximize throughput but also maintain a positive cost-effectiveness
ratio. The result of this adjustment was that the measure maintained a TRC that is lower
than 1.0 but still carried a UCT of 1.75.
b) In general, rebates are adjusted during the business planning process or as a result of
impact evaluation information that notifies the energy efficiency team that an incentive can
be or should be adjusted.
c) Avista does not document its formal process for setting and adjusting rebates.
d) The Company sets and adjusts its rebates/incentives using the following process
New Pro gram/IVleasure Offerin gs
First, we obtain Unit Energy Savings (UES) values from a well-supported source. This is typically
based on either an analysis performedby Energy Efficiency Engineers, Regional Technical Forum
(RTF) values, or other credible sources. The UES values are entered into Avista's modeling
workbook along with a test value for the incentive to estimate the Total Resource Cost (TRC) and
Utility Cost Test (UCT). The Company uses a $0.20 per kWh for electric and $3 per therm for
natural gas rebate benchmark. The rebate amount is adjusted based on the following criteria:
a. Attaining aClE ratio of 1.0 or higher with the UCT being the primary test.
b. Determine the ratio of rebate to "Customer Incremental Cost". In general, the
guideline is that the rebate is 20o/o of Customer lncremental Cost but incentive
amounts may be higher or lower.
c. Since Avista is a dual fuel utility, we attempt to make sure that one fuel is not
receiving more preferential treatment than the other (e.g. insulation incentives
should be the same between electric and natural gas customers to the degree
possible).
d. Test to see ifthe rebate amount is similar to the offerings of other utilities within the
region.
The overall portfolio is analyzed to determine the program's/measure's impact on the budget,
savings and cost-effectiveness.
Existine Pro erams/Measures
For existing programs and measures, the process is similar, however, we also include impact
evaluation results that may have recommendations on adjusting UES values. When the impact
evaluation proposes a UES value change, Avista makes the determination of whether to include
that feedback which could, in turn, affect the incentive value.
Avista also considers the historic performance of the prograrn/measure and adjusts its incentive to
influence more customer participation. The past throughput of the program is considered along
with the incentive levels during those years to see if an incentive change has resulted in a
throughput change.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2o- 1 3/AVLr-G-2 0-08
IPUC Staff
Production Request
Staff - 37
DATE PREPARED: 0310112021WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: (509) 49s-4873
REQUEST:
In response to Production Request No. 2, what steps has the Company taken to implernent
recoflrmendations related to the Customer Care & Billing system, customer approval of rebates,
and incentive calculations and Top Sheets?
RESPONSE:
Regarding the recommendations related to the Customer Care & Billing Systern (CC&B), when
duplicate residential prescriptive rebates are found, they are immediately addressed in CC&B in
the following ways:
o The rebate claim is reopened and any kWh or therm savings is zeroed out, there is also a
note made on the measure to indicate that it was a duplicate. These fields are both
reportable for review later on.
o In addition, all rebate-related financial adjustments are now made directly in CC&B on the
customer's account, making any rebate adjustments visible to all users of the system as
well as on reports.
Regarding the recommendation related to the customer approval of rebates, for Non-Residential
Prescriptive rebates, signatures are required on Page 1 of the Application. If the Application comes
in through the Site-Specific program without a signature, either a signed Application is requested
from the customer or a written consent (by email) or verbal consent (over the phone) is requested.
If the consent is made verbally, a note is made on the Application by the Program Manager.
Regarding the recommendation related to making rebate calculations and top sheets more visible,
for Non-Residential Prescriptive rebates, a note is made directly on the Application form if
amounts are updated from the original Application request. These notes are typically made on the
measure page of the Application. The rebate calculation showing the qualified and paid amounts is
kept separately in iEnergy and is not currently being attached as an additional page on the
Application.
When prescriptive measures change, the change is noted not only in the Technical Resource
Manual (TRM), but also in the measure calculation set for iEnergy. Top Sheets havebeen replaced
with questions in iEnergy as each successive technical approval is done online and these are now
dated with the name of the approver. The technical approvals now do not advance above the
Engineering manager. Administrative approvals for Site Specific incentives are advanced based
on the projected incentive and are performed through DocuSign at the contract phase of the project
and through iEnergy at the time of incentive payment. As we transition to iEnergy and other
electronic resources, we will continue to explore the program(s) capabilities and resources.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-20- I 3/AW-G-20-08
IPUC Staff
Production Request
Staff- 38
DATE PREPARED: 0310112021WITNESS: N/A
RESPONDER: Randy Gnaedinger
DEPARTMENT: Transmission Services
TELEPHONE: (s09) 49s-2047
REQUEST:
Please answer the following questions regarding the Residential Static Var
Compensator ("RSVC") research listed in the table provided by the Company in Production
Response No. 9:
a. Is the 1olo savings listed on this table an acfual savings value, or does it represent a potential
savings derived from modeling? Please explain.
b. Has the Company installed any of the RSVC devices developed through this research? If so,
please provide any reports on the field ef[ectiveness of these devices.
c. Has the Company or its customers benefited from the patent that was issued for this project? If
so, please describe the benefits.
RESPONSE:
a. The"l%o addition to CVR" referenced in the table represents a conservative benefit based
upon the powerflow analysis work conducted by the Boise State research team during
2015-16. Through this analysis the researchers modeled a Sagle, Idaho disfibution feeder
that has RSVC devices installed at optimal locations. Their powerflow time-series analysis
results captured in Table 7-l (included below and on page70 of Staff PR_38 Attachment
A) dernonstrates a potential annual energy and peak savings of approximately 2.5o/o.
Teble 7-l: Suooery of Resrrle
Encrgp U*d
(kTl h)
PcekPoscr
GIT]
Encrgy
Sertd
(kll'h)
Prak
Rcdnrtion
(kTl)
Potmdal srringr
($/ycar)
Basr Casr 13,?19.071 3,470 NA NA NA
Car I 13.446,160 3.392 272,91I ?8 sr2J81
Carc !13,381,926 3,386 337 145 84 $15,17r
b. To date, no field-ready prototypes of the RSVC have been developed.
c. Benefits to the Company or its customers would likely result from an exclusive license
with an end manufacture. The Company is continuously pursuing other partners for
prototyping and manufacturing the RSVC devices.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION: IDAHO
CASE NO: AVU-E-20-13/AVU-G-20-08
REQUESTER: IPUC StaffTYPE: Production Request
REQUEST NO.: Staff- 39
DATE PREPARED: 0310112021WITNESS: N/A
RESPONDER: Randy Gnaedinger
DEPARTMENT: Transmission Seryices
TELEPHONE: [phone]
REQUEST:
Please answer the following questions regarding the Simulation Based Commissioning of
Energy Management Control System ('EMCS") listed in the table provided by the Company
Production Response No. 9 and further described in Production Response No. 25.
a. Please explain the asterisk (*) next to the l4MWh savings listed for this project?
b. Was EMCS used to control the HVAC system at U of I's COBE building, or was the study
confined to simulations? Please explain in detail.
RESPONSE:
The "*" should have been removed, as it was previously used as a reference to the "Realized
Savings for COBE Building" report provided to the IPUC in a previous round of responses.
The EMCS was never intended to control the HVAC at U of I's COBE building, but instead to
virtually act as a commissioning agent. Please see Sta[PR_39 Attachment A, and the following
sections within it for the reseatcher's own description of how virtual commissioning, energy
modeling, and real data feedback are used to predict energy savings.
2. Executive Summary, and
5. I Virtual Commissioning
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMA'TION
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2O- I 3/AVU-G-20-08
IPUC Staff
Production Request
Staff- 40
DATE PREPARED: 0310112021WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: (s09) 49s-4873
REQUEST:
In the 2018 and 2019 Idatro Annual Conservation Reports, Appendix E reports total Northwest
Energy Efficiency Alliance ('T{EEA") expenditures as $471,953 in 2018 and $824,591 in 2019 for
a cornbined total of $1,296,544. In the Company's Production Response No. 11, the Company
states that Idaho customers incurred $1,255,424 for NEEA in 2018 and 2019. Please provide a
reconciliation.of the difference in NEEA expenditures reported in Appendix E and the Company's
Production Response No. 11. Please provide in Excel format with all formulas intact.
RESPONSE:
Please see Sta[PR_40 Attachment A for a reconciliation between the 51,296,544 included in
Schedule E and the $1,255,424 inchtded in the Company's Production Response No. 11. The
$41,120 difference in expense is athibuted to internal expenses for participating in NEEA
Commiffees.
The following table provides hn overview of the reconciliation.
NEEA Committees (2425731
NEEA Committees (242514)
Total Committees Expense
Total PerApp E $1,@2,57t.s203,973 $L,296,54
s36,168
s1,002
s37,169
S3,882
s70
s3,951
$40,049
5L,07L
s41,120