20111115Staff to ICL,NWEC,SNA 1-3 with Attachment.pdf

DONALD L. HOWELL, II
KARL T. KLEIN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NOS. 3366/5156
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
CE 1'""
t,)
lOl1NOV \5 Pr,I:02
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE IN IDAHO. )
)
)
)
)
)
)
CASE NO. IPC-E-1l-8
COMMISSION STAFF'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE IDAHO CONSERVATION
LEAGUE, N.W. ENERGY
COALITION, AND SNAKE
RIVER ALLIANCE
The Staff of the Idaho Public Utilties Commission, by and through its attorneys of record,
Donald L. Howell, II and Karl T. Klein, Deputy Attorneys General, responds as follows to the Idaho
Conservation League, N.W. Energy Coalition and Snake River Allance's First Production Request to
Commission Staff.
REQUEST NO.1: Please refer to the Direct Testimony of Donn English, pages 5 - 6, where Mr.
English describes the Idaho Power's plans to increase energy efficiency activities over 2010 levels.
Please quantify the cost of these increased energy efficiency activities.
RESPONSE NO.1: Staff objects to the extent this request asks Staff to speculate. Staff does
not know which specific programs Idaho Power intends to implement, or which existing programs
Idaho Power intends to expand. Consequently, Staff canot quantify the cost of increased
STAFF'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF ICL, NWEC AND SNA 1 NOVEMBER 15,2011
energy effciency activities. Subject to this objection, Staff notes that financial information
provided to those present at the October 14, 2011 meeting of the Idaho Power Energy Efficiency
Advisory Group indicates that Idaho Power has curently expensed $31,010,999 through
September 30, 2011 on DSM compared to $35,370,048 for the same period in 2010. Furher,
approximately $5.1 milion of incentive payments made through the Company's Custom
Effciency program have been capitalized as a regulatory asset. Combining the expenses through
September 30,2011 with the amount capitalized indicates that Idaho Power has spent $36,110,999 on
DSM through September 30, 2011, which is $740,951 (2.1 %) greater than the same period in 2010.
REQUEST NO.2: Please refer to Idaho Power's 2009 Demand Side Management Potential
Study.
a. Does the Idaho PUC staff expect Idaho Power to acquire the economic potential for
energy efficiency identified in this study?
b. If the answer is yes, please describe how setting the Energy Effciency Rider level at 4%
supports this expectation.
c. If the answer is no, please explain how the Idaho PUC Staff determines if the Company
is fulfillng the Commission's directive to acquire all cost effective energy efficiency.
RESPONSE NO.2: Staff objects to the extent this request seeks previously unwritten and
unpublished opinion or policy statements. See RP 225.01.a. Subject to this objection, Staff answers
this request's subpars as follows:
a. Staff has formed no such expectation. Rather, Staff expects the Company to abide by
Commission Order No. 32245, which states that "Idaho Power should continue to
pursue all cost-effective DSM." See Order No. 32245 at 5.
b. Staff believes that setting the Energy Effciency Rider level at 4% provides the
Company with sufficient revenue to abide by Commission Order No. 32245.
Furhermore, per that Order, should Idaho Power identify additional cost effective
DSM programs, it should "continue to pursue all cost-effective DSM - even in excess
of Energy Effciency Rider revenues." ¡d. Thus, the Company may exceed the 4%
Rider fud revenue.
STAFF'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF ICL, NWEC AND SNA 2 NOVEMBER 15,2011
c. The Commission did not direct the Company "to acquire all cost effective energy
efficiency." Rather, the Commission has directed that Idaho Power "should continue
to pursue all cost-effective DSM." Staff believes the Company is making a good-faith
effort at following the Commission's directive.
REQUEST NO.3: Please refer to Idaho's evaluation plan for 2010 - 2012 found on pages
4 - 6 of Supplement 2 of Idaho Power's 2010 Demand Side Management Annual Report.
a. Does the Idaho PUC Staff believe this evaluation plan is sufficient both in timing and in
the depth of each evaluation?
b. Does the Idaho PUC staff believe the Company should increase the use of third party
evaluators?
c. Please quantify the Idaho PUC Staffs understanding of the cost of retaining a third
pary evaluator?
RESPONSE NO.3: Staff objects to the extent this request seeks previously unwritten and
unpublished opinion or policy statements. See RP 225.0L.a. Subject to this objection, Staff answers
this request's subpars as follows:
a. Yes. Staff believes the Company's evaluation plan is suffcient because the plan is
generally consistent with the 2009 Memorandum of Understanding ("MOU") signed
by representatives from Idaho's three Investor Owned Utilties and Commission Staff.
b. Please see Attachment NO.1 of the MOU referenced in the response to Request No.
3(a) for Staffs position on a utilty's use of third-pary evaluators. A copy of the
MOU is attched to this response.
c. Staff lacks sufficient information from which to quantify the cost of retaining a third-
pary evaluator.
STAFF'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF ICL, NWEC AND SNA 3 NOVEMBER 15,2011
.-i
DATED at Boise, Idaho, this JIJ day of November.
~u f1L-
Karl T. Klein
Deputy Attorney General
Technical Staff witness: Randy Lobb
i:umisc:prodreqlresponse/ipce 1 l.8dkkri staff response to otto 1_3.doc
STAFF'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF ICL, NWEC AND SNA 4 NOVEMBER 15,2011
, .
. MEMORANDUM OF UNDERSTANDING
FOR PRUDENCY DETERMINATION OF DSM EXPENDITURES. .
This Memoranduni of Un~erstanding (UMOU") is entered into on . this. 21st day ó~
December 2009 between Idaho Power Company '("Idaho Power") , .Avista Utilities,
. PacifCorp '(d/b/a' Rocky Mountain Power) (collectively "the Utilities" and individuålly as .. .'
''the utilty"), and the Staff of the Idaho Public Utilities Commission ("Btaff).. All otthe. " ..
above-n~med e,ntities are hereinafter sometimes referred tl? collectively 'as ~Parties" or
, individually as "Part."
WITNESSETH:
A. The Parties agree that there exist a nee(for th~ Utili.ties' and'.Staff to
develop a common understanding of the basis upon which prude'ncy of demand-side
management ("DSMj expènditures can be determined for purposes of cost recovéry. .
B. The. Parties attended a workshop on October 5, 2009, to discuss the
contents of a more comprehensive utilit annual DSM report that would demonstrate a,
commitm'ent to, and accomplishment of, objective and trasparent evaluation of DSM
efforts. The agreed.:upoq principles ("guidelines") stemming from that w9rkshop are set
. but below.
C. A copy of Staffs expectations for DSM prudency review is ;jncluded as
Attachment NO.1. 'Afthough Utilties wil make .a good faith effort to . address Staffs' .
expectations in f~ffowing these guidelines, staff expectations are informational' and the
Utilties wil not be hound by them in the context of this Memorandum of Understanding.
D. The Parties recognize that implementation of the DSM. pruden~y.,
guidelines and .evaluation framework described below wil not automatically result 'in
MEMORANDUM OF UNDERSTANDING - 1
Attachment NO.1
Staff Response to First Production
Request ofICL, NWEC and SNA
11/15/11 Page 1 of 10
~. ' . .
DSM prudency findings. Instead, even with their implementation, futre DSM prudency
findings wil'require the preparation .of a formal filing with the Commi~sion. .
. NOW1 THEREFORE, in consideration of the foregoing, the parties agree as
follows.;
Utilit DSM Annual Report Requirements
1. Template. Idaho Powets 2008 Demand-Side Management Annual
.Report wil be used as a starting point template for enhanced reports, beginning with
report for 2009 DSM operations and results. Elements like those found in 'Idaho
.... .'
. Pbwets 2008 report Will be included in each Utility's annuál report for Idaho programs
that reporting year, clearly identiing Idaho-specific data and narrtives. Th~ DSM
annual reports may be filed as stand-alone . documents or as à combjnation of
documents (e.g., combined with a DSM business plan) that together fulfll the
agreements in this MOU.
2. Table of Conteilts. Each annLlal DSM report wil contain a ,fable ,of
contents that re:ferences all items sp~cifed below, including the åppendix where the
Cost-Effectiveness and Evalúation Table caii be found.
3. Highlight~ or Introduction Section. Each annual, DSM' Report will includ~
an initi~1 Qverview of:
a. Process evaluations begun or' campleted during the previous year, '
modifications to DSM processes that resulted from those evaluations, and pla~ned :
process eVàluations and modifcations for the coming year.
b. Impact evaluations begun "or completed during, the previous year,
modifcations 'to DSM programs that resulted from those evaluations, and planned
MEMORANDUM OF UNDERSTANDING - 2
Attchment No. 1
Staff Response to First Production
, Request ofICL, NWEC and SNA
11/15/11 Page 2 of 10
. .
impact evah,iations for the coming year. This section wil also highlight updates of
assumptions or- reference report used in assessing cost-effectiveness during the past. , .
year and those expected to be reviewed in the coming year.
. 4., Cost-Effectiveness. Section. Each DSM annual report wil include a Cost-
Effectiveness section and table listing individual programs/measures and the basis. for'
estimates of their cost-effectiveness, i.e., formulas, data, inputs ~nd assumptions, and
source/rationale for each datum and assumption, including. the date of the sour~.
5.. .Evaluation Section. Each DSM annual report wil include an' Evaluation
..section and table showing the schedule for evaluations, including impact assessent, '
'assumptions, source review, the schedule for fieid impact . measurement, and
completion date. If this schedule 'is not included, a reasonable explanation for why such
a schedule, in whole or in part, is not necessary wil be included.
'a. It is anticipated that over a reasonable frequency cycle (e.g., ~ to 3
years): all substantial programs'wil håve undergone process and impact evaluations.
However, Staff.agrees that the initial evaluation cycles may be longer for 2008 ~nd 2009
'programs until these guidelines are fully implemented.
b. A copy of each. DSM evaluation completed since filing the previous
. DSM ,annual report wil be included ~s an appendix to the annual DSM report, ~s well as
any confidential cost information that are not included. .The utilty wil supplement .it~ . .
DSM. report with any confidentiål cost information once the Staff has signed a protecliv.e' .
..: .~. . ,"
agreement with the utility., .
6, Program Specific Section. Program-specifc sections of the annual DSM
Raport wil be reported by. sector or by customer class i with a description of each
MEMORANDUM OF UNDERSTANDING - 3
Attachment No. 1
Staff Response to First Production
Request ofICL, NWEC and SNA
11/15/11 Page 3 of 10
i "t,
individual program offered in t/e sector or customer class, and wil include.a list of
measures wi~in each program.
a. Proces Evaluation. Each program-specifc section wil have' a,
process evaluation description that includes:
i. - Program implementation modifications undertaken during
the course of the year'and the rationale behind the change(s).
ii. Other process issues identifed during tne course of the year.
iii. Any formal process evaluation undertaken duri.ng the yea,r.
iv. . Total process evaluation cost, inclusive' of both utilit- -" ,- '
provided and contra-ct-provided services, and names of primary outside evaluators
conducting process evaluations and tites of internal evaluators. The DSM Report wil
indicate which cost infrmation is considered confidential; each utilty wil supplement-.its
DSM report with any program evaluations containing confidential proprietary information ,-
once the Staff has signed a protective agreement with the utilty.
v. Process changes cómpleted or planned duripg the upeomíng
year, if any.
b. Impact and Cost-effectiveness Evaluation. Each program-s'pecific
section wil include art impact and cost-effectiveness evaluation description inCluding:
i. Primary assumptions and source (with year source was
produced) used in the initial determination of cost-effectivehess.
it Primary assumptions' and source (With. year source was
produced) used to determine post implementation impact ~nd cost-effctiveness.
MEMORÃNDUM OF UNDERSTANDING - 4
Attachment No. 1
Staff Response to First Production
Request of ICL, NWEC and SNA
11/15/11 Page 4 of 10
iii. Any changes from inital determination (or last evaluation)
usèd for current cost-effectiveness evàluation and the reason for the change (such as
updated àssumptions, sources or field measurement). '
iv. Planned cycle for reassessment of cost-effctiveness
'assumptions or measurement.
v. . Total impact evaluation cost, inclusiye of both utilty-provided
ånd contract-provided services, and names of primary outside èvaluators and titles of
,inside evaluators. The DSM Report 'Ri1 indicate which cost information is considered
confidential; each utilit wil supplement its DSM report wih any program ev.aluations
. containing confidential proprietary infoiiation once the Staff has signed a protective' .
agreement wit the utilty.
vi. . Changes in' program due to evaluation results.
c. Market Effects Evaluations., Each proram-specific section wil
-
describe any market effects evaluations that have been planned or completed by or for
the utility, including' those planned or completed by the Northwest, Energy Effëiency, ,
AIIrance that are .pertinent to any programs for which the utilty.is claiming eleccit ,
savings or other impacts.
7. Expenses Without Direct Energv Savings. As discussed in the October,5
workshop, the Utilties have. expenses associated with DSM-related activities for which
they do ,not claim energy savings. Expenses associated with non-quantifiable energy
saving programs and initiatives, including but not limited to, infrastructure, education,
outreach, and research, wil be identifed in the DSM annual- report and may be
considered reasonable and necessary expenses for a broad based DSM portlio.
MEMORANDUM OF UNDERSTANDING - 5
Attchment No. 1
Staff Response to First Production
Request of ICL, NWEC and SNA
11/15/11 Page 5 of 10
Reasonable eva'luations of such programs and efforts', commensurate with their 'cost~,
will 'be åCcomplished and reported. The Utilities wil include these expenses 'in the
calculations which determine a cost-effective DSM portolio.
Prudency Determination
8. , A utilit may request a DSM prudency review at any time.
9. The Parties recognize that planning, implementing, and evaluating DSM
programs are not a precise science; they require the application of judgment and
exprience. Utilties are encouraged to continually review these programs and m~kê
. appropriate program improvements. ,
"
10. Within that context, review of utilty demand-side management expen.ses, .'
for prudency shall take into consideration utilty compliance Vrith the planning,
evaluation, and reporting guidelines listed above. A showing by the utiHty that it made a
, good faith effor to reasonably perform within these guidelines wil constitte pnma facie. .
evidence that the utilty's DSM expenses were prudéntly incurred for cost recovery
purposes. By its performing within these 'guidelines, assuming there is no evidence of
imprudent actions or expenses, the' utility can reasonably expec that in the ordinary .
course of business Staff wil support full cQst recoverY of its DSM prògram expenses.
. Treatment of 2008 and 2009 Expenditures
, . 11. Recognizing. that their 2008 DSM report have already .been filed. the
. .Utilties need not amend those reports, but instead wil combine evaluation reporting 'for . .
,2008 with 2009 in their 2009 reports to be filed in 2010. Because it is not possible'.to
comply exactly with the requirements listed above for thè historical expenses of 2008
and 2009, Parties agree to include as many components as possibie in the 201 0 Annu~1
MEMORANDUM OF UNDERSTANDING - 6
Attachment No. 1
Staff Response to First Production
Request of ICL, NWEC and SNA
11/15/11 Page 6 of 10
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Attachment No. 1
Staff Response to First Production
: Request ofICL, NWEC and SNA
11/15/11 Page 7 of 10
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Dated this ;42 day of December 2009. .
MEMORANDUM OF UNDERSTANDING - 8
ROCKY MOUNTAIN POWER
Attchment No. 1
Staff Response to First Production
Request of ICL, NWEC and SNA
11/15/11 Page 8 of 10
ATTACHMENT NO.1
Staff Expectations for Cost-Effectiveness Tests, Methods and Evaluations
1. Cost Effectiveness Measureme'nts. As stted at the October ,5" 2,009,
DSM evaluation workshop, Staff believes that prudent DSM management-equires that
cost-effctiveness be analyzed from a wide variety of perspectives, including the
ratepayer'imp.act perspective, and ~hat aU programs' and individual measure should.
have, the goal of còst-effectiveness from the total resource, utility, and p~rticipant~. ~ .
perspectives. (See IPUC Order No. 22299 issued January 27, 1989, and Order No." .
.28894 issued November 21, 2001.) If a particular measure or program is pursu~~ in,
spite of the expectron that it wil not, itself, be cost-effective from each of those th~e
perspectives, then the'annual DSM report should explain why the measure ~r program'
was implemented or continued.
2. Net-to-Gross Adiustments. The net-to-gross issue was also discusse~ at
the evaluation workshop. Some of the references that the utilties assert that they use, ,'. ,
such as the Califrnia Standard Practice Manual, actually require that all tests be done
on a net savings basis. Staff continues to assert that most programs and measures
have a signifint number of participants who would have installed the ineasure or
changed their benavior in the absence of the 'utilit program. Absent new èvaluation
research to provide a basis for the net-ta-gross adjustments used by each utilit, the
utlity has the burden of explaining the sourc of its net savings adjustments or lack
th~reof. Staff wil contìnue to asSess whether utilit cost-effectiveness estimates
suffciently and prudently include net-to-ross adjustments.
;....
3.' Third-Part Evaluators. Independence of evaluators from program and
portolio management is another important issue that was discussed at the evaluation
workshop. While it was generally agreed .that ,not all evaluations need to be performed
by, third-part evaluators, Staff believes such evaluations tend to be perceivèd as being
rnore objective and transparènt, and thus more credible, than evaluations performed by
utilty st!3ff, all other factors being equal. While Staff wil review all evaluations arid may'
MÈMORANDUM OF UNDERSTANDING - 9 Attchment No. 1
Staff Response to First Production
Request of ICL, NWECand SNA
11/15/11 Page 9 of 10
,. :. 1, .,
review any evaluation in depth, utilties should expect that their self-evaluations may bè
scrutinized more closely than third-part evaluations, as may the programs th~mselves. ,
4. Estimating Non-Energy Benefits. Non-energy benefits .are important and
prudent factors to assess in analyzing cost-effectiveness ànd detennining' incentive-
levels', but Staff cautions against cre~ting'confusion by subtracting the estimated value, .
.of non-energy benefits from program and measure costs when reporting DSM costs on
a cents per kWh basis.
.5. Contctor Costs. After DSM report are filed in 2010, Staff may
reconsider whether to require inclusion of specifc contract amounts paid to contrçtors
in subsequent DSM report.
6. Suggested Resourcs. . In addition to the several evaluation,, ' .
measurement, and cost-effectiveness manuals that were discussed at the workshop, '
Staff .süggests ~t may be useful for utilites to generally follow the guidelines in .the
Nationaf Acton Plan for Energy Effciency'S Model Energy Effciency Progm Impac,t
Evaluation Guide, released November 2007. Another of NAPEE's reports titled
Understanding Cost-Effectiveness of Energ Effciency Prorams: Beat Practices,
Technical Methods, and Emerging Issues for Policy-Makers may also be usefuL.
....
MEMORANDUM OF UNDERSTANDING - 10
Attachment No. 1
Staff Response to First Production
Request ofICL, NWEC and SNA
11/15/11 Page 10 of 10
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF NOVEMBER 2011,
SERVED THE FOREGOING COMMISSION STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF ICL, NWEC AND SNA, IN CASE NO. IPC-E-II-08, BY
E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREP AID, TO THE
FOLLOWING:
LISA D NORDSTROM
DONOV AN E WALKER
JASON B WILLIAMS
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: lnordstrom(ßidahopower.com
dwalker(ßidahopower.com
jwiliams(ßidahopower .com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(ßrichardsonandolear.com
greg(ßrichardsonandolear.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204
E-MAIL: elo(ßracinelaw.net
ARTHUR PERRY BRUDER
ATTORNEY -ADVISOR
US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: Arthur.bruder(ßhg.doe.gov
GREGORY W SAID
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: gsaid(iidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(ßmindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(iyanel.net
DWIGHT ETHERIDGE
EXETER ASSOCIATES
10480 LITTLE PATUZENT PKWY
STE 300
COLUMBIA MD 21044
E-MAIL: detheridge(iexeterassociates.com
CERTIFICATE OF SERVICE
E-MAIL ONLY:
STEVE A PORTER
US DEPT OF ENERGY
E-MAIL: steven.porter(fhq.doe.gov
KURT JBOEHM
BOEHM KURTZ & LOWERY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: kboehm(fbkllawfrm.com
E-MAIL ONLY:
RICHARD E MALMGREN
SR ASST GENERAL COUNSEL
MICRON TECHNOLOGY INC
E-MAIL: remalmgren(fmicron.com
E-MAIL ONLY:
THORVALD A NELSON
MARK A DAVIDSON
FRED SCHMIDT
HOLLAND & HART LLP
E-MAIL: tnelson(fhollandhar.com
madavidson(fhollandhar.com
fschmidt(fhollandhar.com
lnbuchanan(fhollandhar.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710N 6TH ST
BOISE ID 83702
E-MAIL: botto(fidahoconservation.org
E-MAIL ONLY:
JOHN R HAMMOND JR
BATT FISHER PUSCH
& ALDERMAN LLP
E-MAIL: jrh(fbattfisher.com
KEVIN HIGGINS
ENERGY STRATEGIES
215 S. STATE ST SUITE 200
SALT LAKE CITY UT 84111
E-MAIL: khiggins(fenergystrat.com
ELECTRONIC/ CDI PAPER SERVICE
MARY V YORK
HOLLAND & HART LLP
101 S. CAPITAL BLVD., SUITE 1400
BOISE,ID 83702
E-MAIL: myork(fhollandhar.com
BRAD MPURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmail.com
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-MAIL: kmiler(fsnakeriverallance.org
CERTIFICATE OF SERVICE
NANCY HIRSH
POLICY DIRECTOR
NW ENERGY COALITION
811 1 ST AVE., SUITE 305
SEATTLE WA 98104
E-MAIL: nancyaYnwenergy.org
SCOTT PAUL CEO
HOKU MATERIALS INC
ONE HOKU WAY
POCATELLO ID 83204
E-MAIL: spaulaYhokucorp.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joeaYmcdevitt-miler.com
heatheraYmcdevitt-miler.com
~~
SECRETARY
CERTIFICATE OF SERVICE