20110513IPC to Staff 1-15.pdf

HIDA~POR~
LISA D. NORDSTROM
Lead Counsel
Inordstromtâidahopower.com
An IDACORP Company
May 12,2011
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-11-05
IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY
FOR A PRUDENCY DETERMINATION OF 2010 ENERGY EFFICIENCY
RIDER EXPENDITURES
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of Idaho Power
Company's Response to the First Production Request of the Commission Staff to Idaho
Power Company in the above matter. Also enclosed are four (4) copies of a non-
confidential disk containing documents being produced in response to Staff's First
Production Request.
Very truly yours,
XiÄ £/vr ~
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise. ID 83707
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
InordstromCâidahopower.com
dwalker~idahopower.com
REeEIVED
ioii HAY f 2 PM a: S2
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
PRUDENCY DETERMINATION OF 2010
ENERGY EFFICIENCY RIDER
EXPENDITURES.
)
) CASE NO. IPC-E-11-05
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE FIRST
) PRODUCTION REQUEST OF THE
) COMMISSION STAFF TO IDAHO
) POWER COMPANY
)
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated April 21, 2011, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO.1: Please provide a complete listing of all expenses charged to
the DSM tariff rider during 2010. Please include date, vender, amount, a brief
description of the expense, and the account to which the charges were booked. Please
separate all expenses by program type so that the expenditures provided reconcile with
the amounts reported in the 2010 DSM Annual Report. If any amounts are allocated
among different programs, please ilustrate the allocation method. Please also identify if
each expense is an incentive payment, purchased service, labor/administration
expense, or materials and other expense. Please provide the requested information in
Excel format.
RESPONSE TO REQUEST NO.1: Idaho Power considers the requested
information, which contains customer, vendor, and employee data, proprietary and
confidentiaL. This information is available for Idaho Public Utilties Commission Staff
("Staff') to audit in accordance with Rule of Procedure 227 and Idaho Code § 61-610 at
Idaho Power headquarters upon signing a Protective agreement. Please contact Doug
Jones at 388-2615 or Camila Victoria at 388-5821 to arrange an on-site audit.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO.2: Please provide the total amount of wages for Idaho Power
Company employees included in the DSM tariff rider for 2010.
RESPONSE TO REQUEST NO.2: In 2010, the total wages included in the
Idaho Energy Efficiency Rider ("Ridet') charges were $2,577,080.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO.3: Did Idaho Power Company award any wage increases to
DSM employees during 2010? If so, please provide the date and percentage of the
increase along with the total amount of 2010 wage increases included in the DSM tariff
rider balance.
RESPONSE TO REQUEST NO.3: Idaho Power assumes that a "DSM
employee" is an employee funded by the Energy Effciency Riders. Demand-side
management ("DSM") employees received a 2.5 percent general wage adjustment on
January 9, 2010. Additionally, employees who were not at the top step of their pay
grade were eligible to receive merit step increases ("MSI") within their job grade
classification throughout the year. As per Idaho Powets compensation methodology,
employees have the opportunity once they rise to the top of their grade to be paid at the
median wage for comparable positions outside the Company. Included on the enclosed
CD is a spreadsheet showing the wage increases for employees funded under the
Idaho and Oregon Energy Efficiency Riders.
The total amount of 2010 wage increases included in the Rider balance is difficult
to determine. These calculations would have to be done on each individual employee
and because of the variabilty from employee to employee, these calculations are very
complex. The variability among employees includes allocation to the Idaho and Oregon
Riders (95 percent/5 percent), the length of service in a particular position, when in the
year an employee was hired, when in the year an MSI was awarded, percent of hours
charged to the Rider, percent of benefit loadings, exempt and non-exempt employees,
etc. Since the average wage increase for all Rider-funded employees, as shown in the
table included on the enclosed CD, was approximately 4.7 percent, an estimate of the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
amount of wage increases included in the Idaho Rider could be calculated by
multiplying the amount provided by the Company in Response to Staff's Production
Request NO.2 by .047. This calculation results in an estimate of $120,070 or 0.3
percent of Idaho Rider expenses.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO.4: Please explain the use of the Weighted Average Cost of
Capital as the discount rate when determining the Net Present Value of costs and
benefits.
RESPONSE TO REQUEST NO.4: The after tax Weighted Average Cost of
Capital (UWACC") that is used for DSM analysis is consistent with treatment within the
Integrated Resource Plan ("I RP"). Idaho Powets current WACC discount rate of 6.98
percent was published as part of the 2009 IRP in December of 2009 and represents the
blended cost of capital at the end of 2008.
The after-tax WACC is the preferred discount rate to adequately reflect the time
value of money of both DSM costs and benefit estimates to create a present value
equivalent for cost-effective analyses. In demand-side analyses, Idaho Power strives to
create analytical parity with supply-side resources. The WACC, which represents the
blended cost of capital from both equity and debt resources, is used for all cost
estimates of supply-side resources.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST NO.5: For energy efficiency measures where the Participant Cost
Test has been provided, was the Weighted Average Cost of Capital used as the
discount rate? If not, please identify the discount rate used and explain why it was
used.
RESPONSE TO REQUEST NO.5: Yes, the Weighted Average Cost of Capital
is used as the discount rate for Participant Cost Test analysis.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST NO.6: Please provide the explanation for the 10.9% for loss
assumption and the 13.00% summer peak line loss assumption.
RESPONSE TO REQUEST NO.6: Idaho Power uses a 10.9 percent line losses
factor for energy savings at the distribution level and 13 percent peak line loss factor for
peak savings, which is consistent with its IRP analysis. These line losses are specified
in Idaho Powets 2009 Integrated Resource Plan, Appendix C - Technical Appendix,
page 98. Line losses are added to meter level energy or demand savings data in order
to give them a generation equivalency and compare them to supply-side resources.
Using these line losses helps create parity between demand-side and supply-side
resources.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
REQUEST NO.7: Please provide a current organization chart by title and name
showing Major Customer Representatives, Legal staff, Regulatory staff, Corporate
Publishing, Printers, Regional Managers, Customer Service Representatives, Regional
Customer Relation Managers, and any other Idaho Power employees who charges
times to the Energy Efficiency Tariff Rider. Please provide the contact information for
an Idaho Power employee with whom we may arrange an on-site audit in the event that
employee names are confidentiaL.
a. Please provide complete job descriptions, required qualifications,
salary ranges, bonus opportunities, and total compensation ranges, including benefits,
for all employees identified above.
RESPONSE TO REQUEST NO.7: Idaho Power considers the requested
employee information proprietary and confidentiaL. This information is available for Staff
to audit at Idaho Power headquarters upon signing a Protective agreement. Please
contact Doug Jones at 388-2615 or Camila Victoria at 388-5821 to arrange an on-site
audit.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST NO.8: Please provide a spreadsheet containing the following
information for each customer and each measure incented under the Custom Efficiency
2010 program year. If the entirety of this program data is not available in this format,
please supply the contact information for an Idaho Power employee with whom we can
arrange an on-site audit of the remaining materials:
. Cu~omer Name
. Contact name
. Customer address and phone number
. Measure( s) implemented
. Energy savings
. Demand reduction
. Method of energy savings and demand reduction calculation
. Incentive amount
. Customer investment
. Measure Implementation date
. Incentive date
. Installation verification date
RESPONSE TO REQUEST NO.8: Included on the enclosed CD is a
spreadsheet with a list of the projects for which incentives were paid from the Idaho
Rider through the Custom Efficiency program during 2010. The Company has matched
the fields requested as closely as possible in the attached spreadsheet. However,
contained in the spreadsheet are the following fields:
. Project Number
. Customer (redacted)
. Contact Name (redacted)
. Contact Phone Number (redacted)
. Customer Street (redacted)
. Customer City (redacted)
. Customer State
. Customer Zip (redacted)
. Project Description (customer information redacted)
. Measure Type
. Actual Annual Savings kWh
. Demand Reduction akW
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10
. Demand reduction On-Peak kW
. Demand reduction Off-peak kW
. Actual Incentive
. Project Cost
. I ncentive date
. Installation Verification Date
The requested fields not included in the spreadsheet are:
. Method of energy savings and demand reduction calculation
. Measure Implementation date
Energy and demand savings are estimated by a third-party engineering firm or
the customer and are reviewed by Idaho Power engineers. For all Variable Frequency
Drive projects, no demand reductions are reported. For a sample of large projects,
savings are verified by end-use metering and/or bil analysis. For all large projects,
Idaho Power engineers make on-site visits to confirm that the measure( s) were
implemented as planned. The average demand reduction is calculated by dividing the
annual energy savings by 8,760 hours.
The measure implementation date, as requested by the Staff, may vary from a
few days to months prior to incentive payment. Because the projects in the Custom
Efficiency program are often large and complex, different aspects of the projects are
implemented at different times. The projects are often phased in over time prior to
incentive payments being made. Thus, one specific implementation date is not
generally available.
The following fields have been redacted from the attached spreadsheet:
. Customer
. Contact Name
. Contact Phone Number
. Customer Street
. Customer City
. Customer Zip
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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Idaho Power customer specific information is proprietary and confidentiaL. The
redacted fields are available for Staff to audit at Idaho Power headquarters upon signing
a Protective agreement. Please contact Doug Jones at 388-2615 or Camila Victoria at
388-5821 to arrange an on-site audit.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
REQUEST NO.9: For the AC Cool Credit program, please provide the complete
criteria used for selecting customers to whom marketing materials, excluding bil
stuffers, are mailed.
RESPONSE TO REQUEST NO.9: Idaho Power uses several filters in its
Customer Information System to select customers for direct mail marketing efforts for
the AlC Cool Credit program. These filters are applied through a softare query that
looks for residential customers who meet the following criteria:
· Are on rates 101, 184, and 001 ;
. Have an active Service Agreement;
· Have not specified they do not want to receive marketing materials;
· Are not currently enrolled in the program;
· Reside in the premise type of "House";
· Reside in specified counties, including Ada, Bannock, Bingham,
Canyon, Elmore, Gem, Gooding, Jerome, Malheur, Payette, Power,
Twin Falls, and Washington; and
· Had usage for the previous summer of at least 500 kilowatts
("kWh").
After the query is pulled, a process is employed to further filter the resulting
accounts to remove:
· Accounts where the customer has said they do not want to receive
Idaho Powets promotional materials.
· Accounts that were previously turned down by the program.
· Accounts associated with a person who is on the program on
another account.
. Accounts that have applied for the program and have not yet been
installed or turned down (backlog).
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
. Accounts in any other areas that were included in a county but are
not a city where the program is offered, such as Cambridge in
Washington County.
. Accounts whose address is out of state/county locations.
. Accounts that have additional records that can be identified to be
removed; examples include but are not limited to barn, shop,
garage, church, well, temp, etc., as well as those where there is a
property ownets association or it is in care of someone else.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
REQUEST NO. 10: Please provide the installation verification rates for the Easy
Upgrades, Building Efficiency, Irrigation Efficiency, and Home Products Program.
RESPONSE TO REQUEST NO. 10: In 2010, Idaho Power conducted process
evaluations on Easy Upgrades, Building Efficiency, and Irrigation Efficiency. As part of
the process evaluation, the programs' quality assurance and verification processes
were reviewed. The final reports had no further recommendations for Irrigation
Effciency's verification process; however, formal verification plans were recommended
for Easy Upgrades and Building Efficiency. As a result, many of the recommendations
are currently being implemented to formalize the verification process and tracking for
these programs. Furthermore, in 2011, Building Efficiency and Easy Upgrades wil be
fully integrated in the new DSM database, which will provide a better tracking
mechanism for these verifications.
Easy Upgrades. Of the 1,535 total projects completed in 2010, the installation
verification was conducted on 87 projects (5.6 percent). In addition to these 87 projects,
approximately 736 incentive checks were sent to Customer Representatives for delivery
to customers. A high percentage of these 736 incentive checks were hand delivered by
Customer Representatives. This allowed the Customer Representatives to discuss
completed projects, as well as visually inspect the projects. The Company is in the
process of improving the quality assurance and verification process for Easy Upgrades.
During the fourth quarter of 2010, a lighting specialist employee was retained to review
the pre- and post- inspections of the lighting projects.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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Building Effciency. Installations were verified on 60 percent of the Building
Efficiency projects based on proof of installation letters from third-party contractors.
These contractors include engineers, architects, and general contractors who write
letters to the Company verifying the purchase and installation of equipment. Installation
of 100 percent of Daylight Photo Control measures were field verified by the Integrated
Design Lab.
Customer Representatives delivered checks after project completion for 66 of 70
Building Efficiency projects. In many case, the Customer Representatives view the
project when delivering the checks to the customer. In 2011, Idaho Power plans to hire
a third-party consultant provide field installation verifications on at least 5 percent of
completed projects in 2011.
Irrigation Effciency. The Irrigation Effciency program is made up of two
options, the Custom option and the Menu option. Each Custom project (100 percent) is
verified by an Agricultural Representative. Because these projects are system
upgrades or retrofits, the Agricultural Representative's expertise is utilzed by the
customer; therefore, the representatives are heavily involved with the design and
verification process of each system.
Under the Menu option, Idaho Power verifies the equipment purchases with
invoices that accompany each project. Under this prescriptive option, the Company
currently does not verify each project, due to the difficulty of counting every new
sprinkler nozzle, gasket, or other items on a project that could span hundreds of acres.
However, in 2010, of the 610 Menu projects completed, 296 were installed by a third-
party contractor as indicated on the invoices. These projects consist of "pivot
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
packages" for which an irrigation equipment dealer supplies and installs the equipment.
The installation labor is a line item on the receipts received as part of the program
documentation. This represents 48.5 percent of the Menu projects.
Home Products. The Home Products program provides incentives for the
purchase of ENERGY STAR(I qualified projects. Incentives are offered for clothes
washers, refrigerators, freezers, light fixtures, and ceilng fans. Incentive applications
are mailed to the Company and upon verification that the appliance is ENERGY STAR(I
compliant and an accurate purchase receipt is included, incentive checks are mailed.
Participants are also required to provide their customer account number on the
application. Idaho Power wil only provide incentives to the customer of record at the
address were the product is installed.
To increase certainty of product utilization and to minimize risk of fraud,
customers are required to submit an itemized receipt of the purchase. In 2010, if a
customer had purchased a second appliance within the past three years, the Program
Specialist called the store of the original purchased unit to verify if an appliance had
been returned. Additionally, if multiple light fixtures were purchased by a customer, the
Program Specialist contacted the participant to verify that all of the fixtures are being
installed at the residence on the application. In 2011, the Company has implemented a
limit of "one appliance per customer for the lifetime of the program." This limit applies to
the purchase of an additional clothes washer, refrigerator, or freezer. This limit was
established to mitigate the possibilty of a customer purchasing an appliance, returning
it, and applying for another incentive on another appliance.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 18
REQUEST NO. 11: Please provide a detailed budget breakdown for the Energy
Efficient Lighting program.
RESPONSE TO REQUEST NO. 11: Idaho Power assumes that the "detailed
budget breakdown for the Energy Effciency Lighting program" refers to the program's
actual 2010 expenses. A high-level break down of the program's expense by major
expense type (incentives, labor/administration, materials, other expenses, and
purchased services) is shown on page 5 of Supplement 1: Cost-Effectiveness of Idaho
Powets Demand-Side Management 2010 Annual Report. In addition, included on the
enclosed CD is a more detailed, itemized description of each expense.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19
REQUEST NO. 12: Please provide the 2011 process evaluation, referenced in
the 2010 Evaluation Plan, for the Flex Peak Management program.
RESPONSE TO REQUEST NO. 12: The Flex Peak Management 2009
Preliminary Report, which provided some process evaluation information for the first
year of operation, was included in the Research section of Supplement 2 of Idaho
Powets Demand-Side Management 2010 Annual Report. The 2010 Evaluation Plan
provided in the Demand-Side Management 2009 Annual Report shows a planned
process evaluation in late 2011 for the Flex Peak Management program. However, the
Company has decided not to complete that evaluation for two reasons. First, the
program had only operated two years, not providing enough time to mature. Second,
the Company determined instead to focus its resources on process evaluations of all
nine of its energy efficiency programs in the commercial, industrial, and irrigation
sectors which had not been evaluated within the last three years. Page 6 of the
Memorandum of Understanding recommends program evaluation on two to three year
cycles. Additionally, the third-party aggregator, EnerNOC, regularly surveys program
participants. These activities are fully described on page 86 of the Demand-Side
Management 2010 Annual Report and copies of these surveys were provided in
Supplement 2: Evaluation.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20
REQUEST NO. 13: Please explain why Idaho Power did not conduct or plan to
conduct a process or impact evaluation for the Energy Efficient Lighting program
between 2010 and 2012.
RESPONSE TO REQUEST NO. 13: Historically, there have been many
evaluation efforts and there are several ongoing evaluation projects for energy efficient
lighting in the region by both the Regional Technical Forum ("RTF") and the Northwest
Energy Efficiency Allance ("NEEA"). Because an Idaho Power evaluation would be
redundant, in combination with the fact that the laws governing energy efficient lighting
have changed and are stil in flux, Idaho Power does not believe that it would be the
most effective use of its resources to conduct a process or impact evaluation at this
time.
Idaho Power has relied on the annual evaluations and market research studies
conducted by KEMA on behalf of NEEA since 2005. A copy of the two most recent
reports can be found in Supplement 2 of Idaho Power's Demand-Side Management
2009 and 2010 Annual Reports.
Idaho Power utilzes RTF analysis and evaluation where appropriate. For
example, in May 2009, the RTF used information received from various regional studies
that took into account installation, storage, removal, and take-back rates. As a result,
the RTF reduced compact fluorescent light ("CFL") annual savings from 33 kWh to 24
kWh and reduced the measure life from 7 years to 5 years. Recognizing that CFL use
varied between spirals and specialty bulbs, the RTF reviewed and approved the savings
for specialty bulbs in April 2010, while taking into account the different hours of use and
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21
storage, removal, and take-back rates. As of February 2011, the RTF has placed spiral
CFLs under review and wil look to update these savings again.
At its May 2011 meeting, the RTF discussed the methodology that wil be used to
update the savings associated with CFLs. In the May 2011 meeting, the RTF discussed
updating the baseline to take into consideration the changes that wil take place in the
market over the next few years due to the Energy Independence and Security Act
("EISA"). The impact of these changes as well as the hours of operation reported in a
recent KEMA evaluation would potentially lower the savings attributed to CFLs based
on their use in the home. The RTF plans to update these savings later in 2011.
Additionally, Idaho Power is monitoring industry trends and federal regulations to
determine impacts to utility lighting programs, such as impacts on market
transformation, cost-effectiveness, and value of utility programs.Specifically,
Idaho Power is monitoring implementation of the EISA and the new lighting
technologies, such as light-emitting diode and new energy efficient EISA-compliant
incandescent bulbs.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 22
REQUEST NO. 14: Regarding the changes between the 2009 Evaluation Plan
and the 2010 Evaluation Plan, please explain the discrepancies in the following
programs:
a. AC Cool Credit: moving the impact evaluation from 2010 to 2011
and delaying the process evaluation by 6 months.
b. Ductless Heat Pump Pilot: delaying the impact evaluation from
2010 to 2011 and shortening it by 7 months, and shortening the process evaluation by 7
months.
c. ENERGY STAR Homes Northwest: eliminating the impact
evaluation and delaying the process evaluation supervised by Idaho Power from 2010
to 2012.
d. Home Products Program: eliminating the process evaluation
scheduled for 2010.
e. Rebate Advantage: eliminating the process evaluation scheduled
for 2010.
f. See ya later, refrigerator: delaying the impact evaluation from mid-
2011 to mid-2012.
g. Residential Energy Efficiency Education Initiative: consolidating
three annual process evaluations into one process evaluation completed in 2011.
h. Easy Upgrades: eliminating the impact evaluation scheduled for
2011.
i. Flex Peak Management: eliminating the 2010 impact evaluation
and shortening the 2011 impact evaluation by half.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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j.Irrigation Peak Rewards:moving the impact and process
evaluations from late 2011 to 2010.
RESPONSE TO REQUEST NO. 14: As stated on page thirteen of Idaho
Power's Demand-Side Management 2010 Annual Report, the Evaluation Plan is
intended to schedule evaluations. The timing of specific program evaluations wil be
based on considerations of program evaluation needs, and other relevant regional
studies. The Evaluation Plan is intended to be a living document that may change
throughout the year as both internal and external conditions change.
a. In 2009, Idaho Power contracted with a third-party consultant to provide a
Measurement and Verification plan to assist the Company with the creation of
appropriate impact evaluation requirements for the AlC Cool Credit program. This plan
was not received until February 2010, which did not provide enough time to issue a
request for proposal ("RFP"), evaluate potential evaluation vendors, complete contract
negotiations, and install monitoring equipment before the curtailment season began in
June of 2010. As stated on page 22 of the Demand-Side Management 2010 Annual
Report, "In early 2010, Idaho Power contracted with Paragon Consulting Services and
received a detailed plan to evaluate the impacts of the 2010 AlC Cool Credit program.
Idaho Power is using this evaluation plan as a basis for conducting a comprehensive
impact evaluation in 2011." Therefore, this impact evaluation was postponed in order to
be able to estimate the program impacts during the next curtailment season. On
January 13, 2011, Idaho Power issued an RFP for this evaluation. A contractor has
been selected and the impact evaluation is currently in progress. The process
evaluation is stil planned for 2012, but was moved back approximately six months to
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24
minimize the effect on participants and to allow the Company time to evaluate results
from the recent impact evaluation.
b. The Ductless Heat Pump program is a pilot program being administered in
partnership with NEEA and other regional utilties. The evaluations of this pilot, both
process and impact, have been on-going throughout 2010 and 2011. These
evaluations are explained in detail on page 26 of Idaho Powets Demand-Side
Management 2010 Annual Report. The Market Progress Report was concluded in
March 2010 and was included on the CD in Supplement 2 of the Demand-Side
Management 2010 Annual Report. Monitoring equipment is currently in place and the
impact evaluation is ongoing in conjunction with the pilot being conducted by NEEA. In
addition, laboratory testing of Ductless Heat pump equipment is being conducted and
the final evaluation report is anticipated mid-year of 2012. The length of impact or
process evaluation time period is an estimate based on recent experience with other
evaluations and does not reflect the quality or effectiveness of the evaluation.
c. As indicated in the 2010 Evaluation Plan, a market progress report was
provided by ECONorthwest and sponsored by NEEA in April 2010. In addition, a
program energy analysis was also sponsored by NEEA and conducted by KEMA in
August 2010. Both of these evaluations were included on the CD in Supplement 2 of
Idaho Power's Demand-Side Management 2010 Annual Report and satisfied the near-
term need for impact and process evaluations. Because these evaluations were done
in 2010, Idaho Power has focused its resources on conducting evaluations on programs
which have not undergone recent external third-party evaluations.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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d. The Home Products program was a relatively new program offering in
2010, and many process changes were recently implemented. These process changes
are fully described on page 48 of Idaho Powets Demand-Side Management 2010
Annual Report. There were also significant changes in the RTF deemed savings
values, as well as, considerable changes in product baselines due to the adoption of the
2009 International Energy Conservation Codes. Also, as stated on page 48 of the
Demand-Side Management 2010 Annual Report, in May of 2010, Idaho Power began
outsourcing the processing of applications for this program through a third-party vender,
which was a significant change to the program processes. As stated on page 50 of the
Demand-Side Management 2010 Annual Report:
The Demand-Side Management 2009 Annual Report
indicated that a process evaluation would be completed for
the Home Products Program in 2010. Home Products
Program was a relatively new program offering in 2010, and
many process changes were implemented; therefore, it was
decided to conduct a process evaluation on other residential
programs in 2010.
e. The Rebate Advantage program provides incentives to customers who
purchase ENERGY STARCI qualified manufactured homes. As can be seen in Appendix
4, page 134 of Idaho Power's Demand-Side Management 2010 Annual Report, the
,
(
number of homes incented under this program has steadily decreased since 2007,
trending with the economic downturn. As stated on page 54 of Idaho Powets Demand-
Side Management 2010 Annual Report
A program impact evaluation of the Rebate Advantage
program is planned in 2011. A process evaluation of the
Rebate Advantage program was scheduled for 2010;
however, due to the economic downturn and decreased
participation in this program, evaluation funds were
reallocated to Energy House Calls.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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f. Idaho Power contracts with JACO to provide most services for the See ya
later, refrigeratorI program. With permission from the utilties, in 2010, the RTF
collected data from JACO for all the utilties in the Northwest using JACO services. The
data collected includes how the participants heard about the program, what they would
have done with the unit without the program, the age of refrigerator, brand, type, size,
model name and/or number, and other pertinent information. The RTF wil use this data
to evaluate the savings and measure life of these programs for the region. Idaho Power
is awaiting the results for the RTF evaluation before expending resources on a
potentially duplicate study.
g. The annual process evaluations indicated on the 2009 Evaluation
Schedule for the Residential Energy Effciency Education Initiative are exit surveys
conducted for the Library Series held each fall in Boise. As noted on page 108 of Idaho
Powets Demand-Side Management 2010 Annual Report:
These surveys centered primarily on reasons for attending
the show. Information from these surveys wil be used to
improve messaging and to establish a baseline to track
trends of the population these attendees represent. The
Company decided to not only continue to perform these
surveys, but to conduct a thorough third-party process
evaluation of the program in 2010.
This process evaluation final report is included in the Demand-Side Management
2010 Annual Report, Supplement 2: Evaluations.
h. The impact evaluation of the Easy Upgrades program originally scheduled
for 2011 is being postponed until 2012 due to significant changes made to the program
in 2011. Many of these changes are a result of energy code changes, internal cost-
effectiveness analysis, and the requirements surrounding the adoption of revised
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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deemed savings from the RTF. The Company believes that conducting this evaluation
in 2012 would be more beneficial after having at least one year of activities under the
new program design and with some of the enhancements made as a result of the
process evaluation conducted on this program in 2010.
i. The annual impact evaluations conducted in 2009 and 2010 on the Flex
Peak Management program are internal analyses conducted as part of the
reconcilation process with the demand response aggregator that Idaho Power contracts
with to administer this program. Idaho Power has all the interval meter data from each
participant. The Company uses this data to calculate the demand savings provided by
each participant, which is aggregated in order to reconcile the load impacts determined
by the aggregator. The length of any evaluation time period is an estimate based on
experience with other evaluations and does not reflect the quality or effectiveness of the
evaluation.
j. Idaho Power assumes in this request the Staff meant that the evaluations
were moved from late 2010 to 2011. Each year, Idaho Power has conducted extensive
analyses into the costs, savings, impacts and realization rates for the Irrigation Peak
Rewards program. These reports were filed with the Commission in 2007 through
2009, in compliance with Final Order No. 30194.
In the fall of 2010, in conjunction with the 2011 IRP, Idaho Power conducted
additional significant analyses on the demand response needs and effectiveness for the
Company. As a result of these analyses, Idaho Power filed Case No. IPC-E-10-46,
which could significantly change the Irrigation Peak Rewards program. Considering the
amount of research and analyses that has been conducted on this program, the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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Company believes that it would be wise to continue the annual analysis and wait until
the conditions ordered by the Commission under this case are fully implemented to
conduct any more extensive impact evaluation in late 2011.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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REQUEST NO. 15: Please provide a breakdown of the DSM evaluation
expenses for 2010, including vendor name, date of payment, amount of payment, and a
brief description of the expense. Please also identify if each expense is an incentive
payment, purchased service, labor/administration expense, other expense, or materials.
Please provide the requested information in Excel format.
RESPONSE TO REQUEST NO. 15: Idaho Power considers this vendor
payment information confidential and proprietary. Therefore, this information wil be
made available for Staff review at Idaho Power headquarters upon receiving a signed
Protective agreement. Please contact Doug Jones at 388-2615 or Camila Victoria at
388-5821 to make arrangements. As stated on page 11 of Idaho Powets Demand-Side
Management 2010 Annual Report, all costs associated with program evaluation are part
of the "other expense" category.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, th.is 12th day of May 2011.
gl)~
LISA D. NORDS ROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1ih day of May 2011 I served a true and correct
copy of the foregoing IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-- Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email Weldon.StutzmanCâpuc.idaho.gov
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 2¡th Street
P.O. Box 7218
Boise, Idaho 83702
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email peterCârichardsonandoleary.com
9 regCârichardsonandoleary .com
Dr. Don Reading
6070 Hil Road
Boise, Idaho 83703
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email dreadingCâmindspring.com
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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