20221123Avista to Staff 23-31.pdf

AYISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
RECEIVED
2u22 NOV 23 PN4 3:51
IDAHO PUBLIC
UTI L ITIES COIVIUISSION
JURISDICTION: IDAHO
CASE NO: AYU-E-22-13/AW-G-22-05
REQUESTER: IPUC StAffTYPE: Production Request
REQUEST NO.: Staff- 23
DATE PREPARED: llllT 12022WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: [phone]
REQUEST:
The 2020 in-house cost-effectiveness workpapers reports benefit values of $ I 27,59 I , $2,535,203 ,
and $168,525, respectively, for the low-income, residential, and non-residential natural gas
programs. The third-party cost-effectiveness workpapers show benefit values of $68,285,
$3,502,394, and $181,083 for those same programs despite claiming the same number of therm
savings as the in-house cost-effectiveness workpapers. Please reconcile the difference in benefit
values from the Company's in-house workpapers and the third-party cost-effectiveness
workpapers for the residential, low-income, and non-residential programs. Please provide in Excel
format with all formulas intact. (See Attachments A through G in Response to Production Request
No I for workpapers referenced above).
RESPONSE:
Residential and Low lncome:
Please see Staff-PR-23 - Attachment A. Several factors caused differences in the approach, inputs
and other factors. Please see the list below:
l. ADM model started in second year which was identified as 2020. Avista started with the
fust year in the model which was 2019.
2. ADM model inadvertently included the 10% conservation adder applicable to both the
TRC and UCT avoided cost tables. Avista adjusted its model so that the l0% conservation
adder only applies to the TRC.
3. ADM used discount rate of 2.10o/o intheir model while Avista wed,4.7l%;o.
4. Avista's methodology uses a half-year factor on its discount rate; ADM does not use this
methodology.
5. ADM did not include health and safety in the calculation of the low-income benefit
whereas Avista did include that value.
6. Avista's model does not correctly include avoided costs out past 38 years due to an error in
the model's calculation. The impact of this is that avoided cost values stop at 38 years
instead of continuing to escalate into the future.
Non-Residential:
Please see Staff-PR-23 - Attachment B. Several factors caused differences in the approach to
calculating the benefit value for natural gas. Please see the list below regarding the differences in
approaches, inputs and other factors:
l. For 2020, Cadmus used the avoided cost values from the prior CPA, which contained
slightly higher commodity and pipeline values. The avoided costs used by Cadmus were
from the 2016 CPA study whereas the values used in the Avista model were sourced from
the 2018 CPA study. Note that Cadmus advanced the avoided cost table to use values for
2020 which was the 3d year of the study. This differs from Avista's approach, which used
the first year of the avoided cost table as their starting point.
2. Cadmus had included in their avoided cost values the 10% conservation adder. This value
was not included in Avista's avoided cost but added later in its modeling so that it only is
applied to the TRC cost-effectiveness test and not the UCT.
3. Cadmus made a mathematical error in adjusting the avoided cost tables to account for the
Washington Carbon Adder. This value was subtracted from the avoided cost table,
however, it was not previously included in the calculation. The result of this is that the
avoided cost for Idaho was inadvertently lowered by the value of the Washington Carbon
Adder. This has been included in Attachment B to further illustrate the adjustment made by
Cadmus. Note that Avista did not include this in its modeling.
4. Cadmus made a mathematical error counting the pipeline T&D value by including it within
the commodity avoided cost and also individually; this resulted in double counting.
5. Avista's methodology uses a half-year factor on its discount rate, while Cadmus does not
use this methodology.
6. [n calculating the avoided cost for heating equipment, Cadmus did not use the winter
avoided cost set. These values vary slightly as they assume a different avoided cost price
pertaining to individual measures installed. Avista included a winter and annual value in
calculating its avoided cost.
7. Avista provided an updated discount rate to 4.71 n its calculations while the Cadmus
calculation used 4.27.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMA',TTON
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AYU -E-22- 1 3 /AVU- G -22 -0 5
IPUC Staff
Production Request
Staff -24
DATE PREPARED: llllT /2022WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: (s09) 49s-4873
REQUEST:
T\e 2020 in-house cost-effectiveness workpapers show benefits and costs of $311,999 and
$637,629, respectively, for the low-income electric program. The third-party cost-effectiveness
workpapers show benefits and costs of $272,178 and $546,723, respectively, despite claiming the
same number of saved kWh for the same program. Please reconcile the differences between costs
and benefits between the workpapers. Please provide in Excel format with all formulas intact.
RESPONSE:
Benefits:
Please see Staff PR 24 - Attachment A. The difference in benefit values is primarily due to
different starting points in the avoided cost tables. ADM's cost-effectiveness analysis begins with
the "year 2" value while the Avista workpapers start at "year 1". Because of this difference, a
higher value is used in ADM workpapers as the avoided cost values escalate into the future.
The second difference is that Avista's model uses a half-year convention for the discount rate
whereas ADM does not. This difference in methodology is not expected to create a significant
difference, however, it will result in a variation in each year's avoided cost value.
Because the2020 avoided costs were based offthe 2019 CPA, the starting point used in the Avista
model was'!ear l" but from a labeling perspective, was 2019 avoided cost values. ADM started
their analysis based on the values identified as2020 which is the 3d year ofthe avoided cost within
the model.
StaffPR 24 - Attacfune'nt A provides an illusfration between the two sets.
Tab 1.0 illustrates the avoided cost for each load shape. The intent of this tab is to show that there
is no variation in the avoided costs used, acknowledgrng that the two models used different years
as their starting points. This is before applying the discount rate.
Tab 1.1 illustrates that by modifring the starting point and the discount rate factor, the avoided
costs arrive at the same values.
StaffPR 24 - Attaclwrent B shows the individual measures and the differing inputs that went into
each respective model. Note that for some measures, a difference exists for the load shape used and
the measure life. This attachment illustrates how the $272,178 was calculated by ADM and how
the $311,999 value was calculated by Avista.
Costs:
Please see StaffPR 24 - Attachmoril C fur a rrconciliation of costs associatod with the low-income
program. In review of the total expenses, ADM had inadverterily ercluded $90,906.43 related to
general implerrentation exp€ilses.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION: IDAHO
CASE NO: AYU-E-22-13/AW-G-22-05
REQUESTER: IPUC StAffTYPE: Production Request
REQUEST NO.: Staff - 25
DATE PREPARED: ltllT 12022WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: [phone]
REQUEST:
T\e 2020 in-house cost-effectiveness workpapers and the 2020 Annual Report show 5,282,547
kWh in energy savings for the residential electric program. The third-party cost-effectiveness
workpapers show energy savings of 4,523,393 kwh. Please reconcile the difference in kWh
savings between the work-papers. Please provide in Excel format with all formulas intact.
RESPONSE:
TIte 4,523,393 kwh as provided in ADM workpapers is not inclusive of the savings derived from
the Multifamily Direct Install (MFDD program, which is also considered a residential offering and
included in the reports total for residential programs. This program was evaluated by Cadmus and
provided an additional747,227 kWh of savings. After accounting for the saving from the MFDI
program, the total residential savings was 5,282,547 kWh for the 2020 progrartyear.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU -E-22- l 3 /AW-G -22-0 s
IPUC Staff
Production Request
Staff- 26
DATE PREPARED: llllT 12022WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: (s09) 49s-4873
REQUEST:
Please provide the workpapers for the benefits and costs reported in the 2020 Annual Report at 72
for the residential electric program.
RESPONSE:
Please see the Cost Effectiveness tab contained within Staff-PR-30 - Attachment A. The tables for
residential on page 72 cnntain the combined values from the residential program as evaluated by
ADM and also the Multifamily Direct Install (MFDD Program as evaluated by Cadmus.
See Staff-PR-l - Attachment E for the below program portfolio calculations.
MFDI
See StaflPR-l -Attachment C forthebelow data.
Residential
$551,861 $590,021 0.94Total Resource Cost (TRC)
Utility Cost Test (UCT)$501,692 $445,952 t.t2
Participant Cost Test (PCT)$1,087,671 $422,624 2.57
Ratepayer Impact (RIM)$501,692 91,255,067 0.40
Cost-Ell'ectivcness Tcst Benclits Costs Bcnelit/Cost
Ratio
Total Resource Cost (TRC)$5,579,452 $2,681,641
$1,687,155
2.08
Utility Cost Test (UCT)95,072,229 3.01
Participant Cost Test (PCT)$6,330,037 $1,597,316 3.96
Ratepayer Impact (RIM)$5,072,229 $10,805,160 0.47
Res+MFDI (Combined)
Total Resource Cost (TRC)$6,131,313 s3,271,662 1.87
Utility Cost Test (UCT)$5,573,921 $2,133,107 2.61
Participant Cost Test (PCT)$7,417,708 $2,019,940 3.67
Ratepayer Impact (RIN,I)85,573,921 $12,060,227 0.46
Please see the Cost-Effectiveness workpapers provided in the Company's resporurc to
Staff-PR-Ol. For natural gas, no MFDI was included, therefore, please reference Staff-PR-l -
Attachment D for the below infomration.
Residential
Total Resource Cost (TRC)3.852.633 3.466.M2 1 ll
Utilrty Cost Test (UCT)3,s02"394 1"426.403 2.46
Participant Cost Test (PCT)4,821,706 3,422,171 I .4I
Ratepayer Impact GIlvI)3,502,394 I1,836,441 0.30
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMA'TION
ruRISDICTION: IDAHO
CASE NO: AVU-E-22-13/AW-G-22-05
REQUESTER: IPUC StaffTYPE: Production Request
REQUEST NO.: Staff-27
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
tUt712022
N/A
Ryan Finesilver
Energy Efficiency
(s}e) 4es-4873
REQUEST:
The Company's202D Annual Report at 72 shows the residential electric program had benefits and
costs of $5 ,573,921 and $2,1 13,107, respectively. The third- party cost-effectiveness workpapers
show the residential electrical program had benefits and costs at $5,072,229 and $1,687,155,
respectively. The 2020 in-house workpapers for residential electric programs show benefits and
cost at $4,852,201and $1,870,086, respectively. Please reconcile the differences in benefits and
costs between the in-house workpapers, third-party workpapers, and the 2020 Annual Report.
Please provide in Excel format with all formulas intact.
RESPONSE:
Benefits:
With regard to the 2020 Annual Report's table at 72 versus third-party cost-effectiveness
workpapers, the table at 72 was prepared with the combined values from the residential program
(evaluated by ADM) and the MFDI program (evaluated by Cadmus). After including $501,692 of
benefits from the MFDI program to the $5,072,229 from residential, the sum is $5,573,921.
Note that the tables included at 72 do not reflect the Company's in-house calculations since the
Order to provide in-house cost-effectiveness occurred after the report was finalized.
MFDI
Total Resource Cost (TRC)$551,861 $590,021 0.94
Utility Cost Test (UCT)$501,692 $445,952 1.12
$1,087,671Participant Cost Test (PCT)$422,624 2.57
Ratepayer Impact (RIM)$501,692 $r,255,067 0.40
Cost-Effectiveness Test Benefits Costs Benefit/Cost
Ratio
Residential
Total Resource Cost (IRC)$5,579,452 $2,681,il|2.08
Utility Cost Test (UCT)$5,072229 $1,687,155 3.01
Participant Cost Test (PCT)$6,330,037 $1,597,316 3.96
Ratepayer Impact (RIIrd)$5,072,229 $10,805,160 0.47
Total Resource Cost (TRC)$6,131,313 $3,271,662 1.87
Utility Cost Test (UCT)$5,573,921 $2,133,107 2.61
Participant Cost Test (PCT)$7,417,708 $2,019,940 3.67
Ratepayer Impact (Rnd)$5,573,921 $12,060,227 0.46
Res+MFDI
Regarding third-party cost-effectiveness workpapers versus Avista workpapers, please see the
Company's response to Staff-PR-24.\\e workpapers provided for low-income also support the
residential calculations
Costs
With regard to the 2020 Annual Report's table at 72 versus third-parly cost-effectiveness
workpapers, see the tables above for benefit and cost info.
Regarding third-party cost-effectiveness workpapers versus Avista workpapers, please see
StaffiPR-27 - Attachment A for details and the reconciliation.
The variance is caused by the following:
1. ADM had inadvertently double counted $602,830.19 of incentives in calculating the total
cost value.
2. ADM did not include $77,768 of general implerrentation expenses in the calculation of
costs.
3. Since Cadmus evaluated the MFDI program, ADM's calculation did not include $445,952
relatd to MFDI, creating a reconciliation item.
4. Avista had inadvertently double counted $262,550 of third-parly costs related to Simple
Steps in its calculation. This error was due to the model classiffing the expense as a 3d party
cost and also a non-incentive cost.
5. An immaterial variance of $509 in incentive values between Avista and ADM ince,ntive
calculations.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATTON
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU -E-22- I 3 /AW- G -22 -0 5
IPUC Staff
Production Request
Staff- 28
DATE PREPARED: llllT 12022WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: (509) 49s-4873
REQUEST:
Tt,re2020 in-house cost-effectiveness workpapers show costs of $166,393 for the non-residential
gas program. The third-party cost-effectiveness workpapers show costs of $196,443 for the
non-reside,lrtial gas program despite claiming the same number of saved therms. Please reconcile
the cost differences between the two sets of workpapers. Please provide in Excel format with all
formulas intact.
RESPONSE:
The variance between the two cost numbers is due to an error in Avista's model where the
non-incentive utility costs had not correctly been allocated to all non-residential programs
resulting in understating non-residential costs by $30,049. Please see Staff-PR-28 - Attachment A
for a reconciliation of these costs.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO: AYU-E-22-13/AW-G-22-05
REQUESTER: IPUC StAffTYPE: Production Request
REQUEST NO.: Staff- 29
DATE PREPARED: llllT 12022WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: [phone]
REQUEST:
The2020 in-house cost-effectiveness workpapers show costs of $2,711,045 for the non-residential
electrical program. The third-party cost-effectiveness workpapers show costs of $3,207,038
despite claiming the same number of saved kWh for the same progrilm. Please reconcile the cost
differences between the two sets of workpapers. Please provide in Excel format with all formulas
intact.
RESPONSE:
The variance between the values originates from the incentive values used in Avista's model.
First, the Company had inadvertently understated in its cost-effectiveness model incentive values
related to site-specific programs with a reconciling value of $271,515.33 ($242,717 + $28,799)
between Avista-provided costs and Cadmus-provided costs.
Second, the incentive value related to SS Multifamily was overstated by Cadmus, which caused an
additional reconciling itern. The overall incentive value is $444,000, which agrees to Avista's
records. Please see Staff-PR-29 - Attachment A.
AVISTA CORPORATION
RESPONSE TO REQIIEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU -E-22- I 3 /AW-G -22-0 5
IPUC Staff
Production Request
Staff- 30
DATE PREPARED: llllT 12022WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: [phone]
REQUEST:
Please provide the workpapers for the therm savings reported in the 2020 Annual Report at99.
RESPONSE:
Please see the low-income tab within Staff-PR-3O - Attachment A.
AYISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU -E-22- I 3 /AVU-G -22-05
IPUC Staff
Production Request
Staff- 3l
DATE PREPARED: llllT /2022WITNESS: N/A
RESPONDER: Ryan Finesilver
DEPARTMENT: Energy Efficiency
TELEPHONE: (509) 49s-4873
REQUEST:
T\e 2020 in-house cost-effectiveness workpapers and third-party workpapers show savings of
4,748 therms for the low-income natural gas program.T\e2020 Annual Report at 99 shows therm
savings of 5,495 for the low-income natural gas program. Please reconcile the difference between
the savings value reported in the Annual Report and the two sets of workpapers. Please provide in
Excel format with all formulas intact.
RESPONSE:
Avista had inadvertently included the *adjusted" savings value for G HE Fumaces of 3,049.76
instead of the "vetrified" savings value of 3,796.64 therms in its cost-effectiveness model. This is a
variance of 747 therms. See Table No. 63 of the Annual Conservation Report forthe illustration of
these values.