20130627IPC to Staff 1-29.pdf

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';...JULIAA. HILTON
Corporate Gounsel
[e-mail]
June 27,2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 W est Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-08
2012 Demand-Side Management Expenditures - ldaho Power Company's
Response to the First Production Request of the Commission Staff to ldaho
Power Company.
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's response to the First Production Request of the Commission Staff to
ldaho Power Company.
Also enclosed are four (4) copies of the non-confidential disk and four (4) copies of
a confidentia! disk containing data responsive to Staff's Request. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
j-c^
Julia A. Hilton
JAH:evp
Enclosures
1221 W ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
:-::1 .'. '
JULIA A. HILTON (lSB No. 7740) i '"-"j - '
ldaho Power Company rn11 !:rr: ?1 Fii ?: lB1221West ldaho Street (83702) "G i ': u
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
ih i lton@ ida hopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
lN THE MATTER OF THE APPLICATION )
oF TDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-13-08
DETERMTNATTON OF 2012 DEMAND- )
SIDE MANAGEMENT EXPENDITURES AS ) IDAHO POWER COMPANY'S
PRUDENTLY INCURRED ) RESPONSE TO THE FIRST
) PRODUCTTON REQUEST OF THE) coMMrssroN STAFF To rDAHO
) POWER COMPANY
)
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compory"), and in
response to the First Production Request of the Commission Staff ("Staff') to ldaho
Power Company dated June 6,2013, 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 list all expenses charged to the demand-side
management ("DSM") tariff rider during 2012. Please include date, vendor, amount, a
brief description of the expense, and the account to which the charges were booked.
Please separate all expenses by program so that the expenditures provided reconcile
with the amounts reported in the 2012 DSM annual report. lf any amounts are allocated
among different programs or jurisdictions, please illustrate the allocation method.
Please also identify if each expense is an incentive payment, purchased service,
labor/administrative, or materials and other expense. Please provide the requested
information in Excel format.
RESPONSE TO REQUEST NO. 1: The requested information is voluminous,
proprietary, and confidential. lt will be made available for Staff to audit pursuant to
ldaho Code 61-610 and Rule of Procedure 227 (IDAPA 31.01 .01.227) at Idaho Power's
corporate headquarters. Please contact Doug Jones at 208-388-2615 or Camilla
Victoria at 208-388-5821to arrange a time to review the requested material.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE GOMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 2: Please provide the calculation of the interest accrued to the
DSM tariff rider account.
RESPONSE TO REQUEST NO. 2: Please see the Excel file provided on the
non-confidential CD.
The response to this Request was prepared by Douglas Jones, Finance Team
Leader, ldaho Power Company, in consultation with Julia A. Hilton, Corporate Counsel,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO. 3: Please provide the revenue received (excluding interest) from
the DSM tariff rider.
RESPONSE TO REQUEST NO. 3: Total funding received from the Idaho DSM
Tariff Rider (excluding lnterest) in 2012 was $35,108,151.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, Customer Operations ldaho Power Company, in
consultation with Julia A. Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO. 4: Please provide all DSM research and evaluation expenses for
2012, including date, vendor, amount, and program to which the expense applied.
RESPONSE TO REQUEST NO. 4: Please see the confidential Excel file
provided on the confidential CD. This attachment contains information that is
confidential, proprietary, and/or has commercial value. The confidential CD will be
provided to those parties that have executed the Protective Agreement in this
proceeding. ldaho Power requests that references to the confidential information
provided in this response be excluded or redacted from any reports and/or analyses.
The confidential attachment contains all program evaluation and research costs
charged to the ldaho Tariff Rider in 2012, as well as program evaluation costs for the
ldaho Weatherization Assistance for Qualifying Customer ("WAQC") program, which are
recovered through base rates.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.5
REQUEST NO. 5: Please explain why the Company does not provide
incentives or have a program for electric to gas fuel conversions.
RESPONSE TO REQUEST NO. 5: ldaho Power objects to this request as it
seeks information not reasonably calculated to lead to the discovery of admissible
evidence and/or information that is not relevant to the subject matter of this action.
Notwithstanding this objection, fuel switching from electricity to natural gas is currently
occurring due to natural market forces. The current economic choice for customers in
choosing space heating and water heating fuel is to select natural gas, where available.
ldaho Power's energy efficiency programs promote the wise and efficient use of its
product, electricity.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST NO. 6: ldaho Power is requesting a prudency finding for $3.2 million
invested in the Northwest Energy Efficiency Alliance's ("NEEA") market transformation
activities in 2012. lf that investment was cost-effective and the funds prudently spent,
please explain how ldaho Power's decision to stop funding NEEA after 2014 meets the
Commission's Order to pursue all cost-effective DSM.
RESPONSE TO REQUEST NO. 6: As an original funding partner of NEEA since
its inception in 1997, ldaho Power and its customers have historically found value in a
relationship with NEEA. NEEA was created at a time when ldaho Power began to
rebuild its DSM portfolio offerings and has made a contribution towards elevating
awareness and adoption of DSM in the region. Overthe past 15 years, ldaho Power
has continued to build extensive programs and acquired significant energy efficient
savings through customer education and program participation. ldaho Power has
gained expertise with program design, delivery, and evaluation and a good
understanding of its customers' energy needs. ldaho Power has a good understanding
of the marketplace and works directly with its customers, as well as the Energy
Efficiency Advisory Group to identify and implement cost-effective solutions that support
the best value for customers.
During 2009, the year leading up to the current funding cycle, ldaho Power
expressed its desire for NEEA to alter how NEEA designed its services and
corresponding funding in the 2O1O to 2014 business plan in orderto allow ldaho Power
to direct its funding toward those activities it believes bring the most value to its
customers. There were some aspects in this funding cycle that ldaho Power supported,
such as regional research especially with emerging technologies, regional training, and
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
their "upstream" work with manufacturers. ldaho Power communicated to NEEA its
preference for an alternative funding model that would allow ldaho Powe/s funds to be
directed toward the costs of these supported activities. ldaho Power continues to seek a
funding model that maximizes the investment of customer funds for DSM. ln the
meantime, ldaho Power provided advance notice of its intention to not pursue a
commitment with NEEA for the next funding cycle of 2015-2019. ldaho Power wi!!
continue to participate in the current 2010-2014 funding cycle and actively participate
as currently committed.
The response to this Request was prepared under the direction of Theresa
Drake, Manager of Customer Relations and Energy Efficiency, ldaho Power Company,
in consultation with Julia A. Hilton, Corporate Counsel, ldaho 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 the cost-effectiveness workpapers and
calculations for each DSM program in 2012 in Excel format with all formulas intact.
RESPONSE TO REQUEST NO. 7: Please see the confidential Excel file
(Attachment 1) provided on the confidential CD, which contains EnerNOC information
that is confidential, proprietary, and/or has commercial value. The confidential CD will
be provided to those parties that have executed the Protective Agreement in this
proceeding. ldaho Power requests that references to the confidential information
provided in this response be excluded or redacted from any reports and/or analyses.
Please see the non-confidential Excel files (Attachment 2, 3, and 4) used to
create the program cost-effectiveness pages for ldaho Power's 2012 Demand-Side
Management Annual Report: Supplement 1 ("Supplement").
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counse!, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST NO. 8: How does ldaho Power or its contractor determine the
participant costs for its Flex Peak and lrrigation Peak Rewards programs?
RESPONSE TO REQUEST NO. 8: ldaho Power did not determine any
participant costs for Flex Peak Management or lrrigation Peak Rewards tn 2012. The
Company does not estimate any participant costs for the FlexPeak Management
program. While there may be a small amount of participant labor costs, they are not
considered in the FlexPeak Management program because it is assumed that, through
the third party aggregator model, the offset of these costs is built into the negotiated
customer compensation package.
Because the lrrigation Peak Rewards cost-effectiveness model is based on a 20-
year program life, there are program costs associated with the program's historical
performance and forecasted future use. For 2012, because the program was not
dispatched, there were no participant costs included in the analysis. When the program
is dispatched, it's assumed that there is a small cost to the participants. Similar to the
FlexPeak Management, the labor costs for the Inigation Peak Rewards program is
difficult to estimate, but the Company has placed a monetary value to the irrigators'time
to participate. Under one dispatch option, an irrigator can choose to manually shut off
and turn on their pumps for each event. Under another option, the irrigator can choose
to have their pumps automatically shut off. The pumps can sometimes be restarted
automatically; however, it's assumed that regardless of which restart option the irrigator
chooses, they will still want to check each pump after the event to ensure that it is
working properly. Because of the likelihood that it will be the owner or manager that wil!
check these pumps after hours, the Company believed it was reasonable to assume
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1O
that the participant cost would be $15 per hour for 2 hours per event per site. Note that
if the participant costs are not included, both the Total Resource Cost ("TRC") ratio and
Utility Cost ("UC") ratio for the program would be 1.79. lncluding the participant costs in
lrrigation Peak Rewards analysis makes the UC ratio 1.79 and the TRC ratio 1.72
demonstrating that the impact on the TRC is small with the inclusion of the participant
costs.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST NO. 9: Please provide access to the ldaho Power
database.
RESPONSE TO REQUEST NO. 9: The requested information is voluminous,
proprietary, and confidential. lt wil! be made available for Staff to audit pursuant to
ldaho Code 61-610 and Rule of Procedure 227 (IOAPA 31.01 .01.227\ at ldaho Poweds
corporate headquarters. Please contact Doug Jones at 208-388-2615 or Camilla
Victoria at 208-388-5821to arrange a time to review the requested material.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate 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. 10: Please explain how ldaho Power determined the incentive
amounts for A/C Cool Credit and the fixed and variable incentive amounts for the
lrrigation Peak Rewards program in 2012. Please provide all relevant workpapers and
calculations in Excel format with allformulas intact.
RESPONSE TO REQUEST NO. 10: After communication with Commission Staff
it was clarified that they are requesting how ldaho Power determined the incentive
structure and individua! incentives paid to participants in 2012.
The Company's objective in setting incentive levels for the lrrigation Peak
Rewards program is somewhat different than for the A/C Cool Credit program. While
each program must be shown to be cost-effective, the goal for A/C Cool Credit is to be
cost-effective from the long-term perspective while for lrrigation Peak Rewards the goal
is to have it cost-effective on an annual basis. For the lrrigation Peak Rewards program
the decision to participate is typically an annual decision which is based on what crops
are grown or if a particular pump is utilized on a year to year basis. The customer
agreement to participate can be canceled by either party on an annual basis.
The cost-effectiveness work papers and calculations for the A/C Cool Credit and
the lrrigation Peak Rewards programs are included in Idaho Power's response to Staff's
Production Request No. 7.
The monthly incentive amounts for the A/C Cool Credit pilot program were
initially established in Case No. IPC-E-02-13 under Commission Order No. 29207. ln
the Company's application to begin a residentia! air conditioner cycling pilot program the
Company proposed: "ln exchange for an intelligent programmable thermostat installed
in their homes and a $5 monthly monetary incentive, participating customers would
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
voluntarily permit the Company to cycle their central air conditioners." Commission
Order No. 29207 stated: "the monetary incentive for residential customer who
participates in the Residential Air Conditioner Cycling Pilot Program shall be increased
from $5 to $10 per month of successful participation."
ln Case No. IPC-E-04-27, ldaho Power proposed to discontinue using
programmable thermostats, use switches on or near the customer's A/C units, and
reduce the incentive to $7 per month for June, July, and August. The Company based
this proposal on a third-party evaluation and a cost-effectiveness analysis. The
Application stated:
The Company conducted an analysis of the cost-
effectiveness of the Program based on the Pilot Program
findings. The analysis yielded a benefit-cost ratio of 1.07 by
the 1Oth year of operation and a ratio of 1 .42 over a 3O-year
operation period. These ratios were calculated using the
Utility Cost Test perspective. According to these ratios, the
Program benefits are expected to exceed program costs in
by the tenth year of operation. (Page 6, application)
ln this case, Staff recommended that the Commission approve the program as
filed and the Commission granted the Company permission to implement its revised
residential A/C Program as filed (Order No. 29702, page 4).
ln order to measure participant satisfaction with the incentive level for A/C Cool
Credit, in 2011, ldaho Power partnered with ADM Associates, lnc. ('ADM') to conduct a
customer survey regarding the Company's demand response programs. The reports
which are included in the Demand-Side Management 2011 Annual Report Supplement
2: Evaluations ('Supplement 2") contain the results of the phone surveys for A/C Cool
Credit and lrrigation Peak Rewards participants. For A/C Cool Credit, ADM surveyed
520 randomly selected program participants. When asked how likely they would be to
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
continue to participate in the program if the bill credit level and structure stayed the
same, 88 percent of respondents indicated they would be "very likely" to participate and
10 percent indicated they would be "somewhat likely."
Since Commission Order No. 29702, the Company had not filed to modify the
customer incentive amounts prior to the 2012 season for the A/C Cool Credit Program.
The Company believes that the incentive level paid in 2012 creates a balance between
program participation, customer retention, and long term cost-effectiveness.
The original incentive amounts and program design of the dispatchable lrrigation
Peak Rewards program were stipulated to in Case No. IPC-E-08-23 and approved in
Commission Order No. 30717. The Company stated in its petition:
This Petition is the result of workshops that were held as an
outgrov,rth from the settlement Stipulation in the Company's
last general rate proceeding, Case No. IPC-E-07-08. The
Company hosted a workshop to review the current Program
and explore possible modifications to it. Attendees of the
workshop included representatives of the ldaho lrrigation
Pumpers Association, lnc. ("llPA'), ldaho Power agricultural
inigation customers, Commission Staff, and Company
representatives. Two follow-up phone conference
workshops were held where the terms of the present
Stipulation were discussed and agreed upon by llPA,
Commission Staff, and the Company (the "Parties"). The
Parties have agreed to support this Petition to modify the
Program in accordance with the provisions of the settlement
Stipulation, which is enclosed as Attachment No.1 to this
Petition.
ln a subsequent filing, Case No. IPC-E-10-46, the Company proposed several
modifications to the lrrigation Peak Reward program including a change to the incentive
structure which would include a fixed and variable portion. The Company filed for an
incentive structure that would pay participants forty percent of their incentive as the
fixed portion and sixty percent as the variable portion, based on the hours the program
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15
is used. Overall, the proposed changes would result in a larger incentive payment, as
compared to the previous incentive structure, if the program was dispatch at the
maximum number of hours per season.
!n its application the Company stated:
Overall, the proposed Program modifications are reflective of
a collaborative process in which ldaho Power received
feedback from numerous stakeholder groups, including the
ldaho lrrigation Pumpers Association, the Commission Staff,
the Energy Efficiency Advisory Group; and the lntegrated
Resource Plan Advisory Council. The revised Program, as
proposed, will more closely align Program incentives with the
Company's need for demand response. (Application, page 6)
The actual fixed and variable incentive levels were determined in Commission
Order No. 32200 in Case No. IPC-E-10-46 which states:
The Commission finds that changing the incentive payment
amount to include a 25o/o variable portion is fair and
reasonable. The lrrigators recommended this allocation as
adequate to customers in the Program and ldaho Power
reply comments agree an allocation of 75% fixed and 25o/o
variable is justifiable. (Order No. 32200 page 4)
ln order to measure participant satisfaction with and the opportunities to make
incentive modifications in the incentive structure and levels for the lrrigation Peak
Rewards program, in 2011,2O5 randomly selected lrrigation Peak Rewards participants
were surveyed by ADM. When asked how likely they would be to continue to participate
in the program if the incentive level and structure stayed the same, 87 percent of
respondents indicated they would be "very likely" to participate and 12 percent indicated
they would be "somewhat Iikely." However, the respondents were open to potential
changes to the incentives. When asked how likely they would participate if the incentive
level were reduced with a corresponding increase in variable incentives, 18 percent of
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
respondents said they would "very likely" with 69 percent being "somewhat likely."
When asked how likely they would participate if the incentives are variable based solely
on the number of events called, 16 percent of respondents said they would be "very
likely" with 72 percent would be "somewhat likely."
There were no variable payments made in 2012 and the Company has not filed
to change the incentives paid to participant in the lrrigation Peak Rewards program
since the issuance of Commission Order No. 32200 and prior to the 2012 irrigation
season.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17
REQUEST NO. 11: Please explain how ldaho Power determined the incentive
amounts for its energy efficiency programs in 2012. Please provide all relevant
workpapers and calculations in Excel format with all formulas intact.
RESPONSE TO REQUEST NO. 11: After personal communication with
Commission Staff it was clarified that they are requesting ldaho Power's general
philosophy in determining the incentive structures and individual incentives for its
energy efficiency programs paid in 2012.
ln setting customers incentive amounts, ldaho Power balances the goal of
maximizing customer participation and minimizing costs. This involves several
considerations. The first and most important consideration is that the programs and
measures pass all of the cost-effectiveness tests as outlined in the memorandum of
understanding with Commission Staff dated January 2010. The incentive levels have
the most impact on the Utility Cost Test and the Participant Cost Test and need to be
set to allow these test ratios to be greater than one.
The second consideration is that the participant should share in the efficiency
investment and the Company should use Energy Efficiency Rider funds as wisely as
possible, so the incentive generally should not cover the entire incremental cost of the
efficiency upgrade. For example, in the Custom Efficiency Program, the Company pays
participants twelve cents per kilowatt-hour saved in the first year or seventy percent of
the project costs, whichever is less. The goal of this program is to decrease payback
time for the efficient investment. For prescriptive programs it is more difficult to
determine the incremental cost. The Company relies of the Regional Technical Forum
("RTF") and other third party sources to determine the incremental cost of measures.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 18
The third consideration for setting incentive amount is the ability to set the
incentive level such that a customer would opt for the efficient option over the inefficient
investment. This is often difficult based on the first two constraints.
The Company tries to balance these three considerations as well as set
incentives which allow customers and trade allies to participate in programs as easily as
possible and to reduce barriers for participation. ldaho Power reviews its incentives for
each program on a regular basis and adjusts these incentives based on cost-
effectiveness, customer participation, changes in data from the RTF or other third-party
research.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho 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 explain what is required in the pre-approval process
for Easy Upgrades projects with expected incentive payments of more than $1,000, or
that contain variable-frequency drives or non-standard lighting measures.
RESPONSE TO REQUEST NO. 12: The requested information is available on
the Company's website. ldaho Power's website states:
Preapproval Requ i rements
The following projects require pre-approval from
ldaho Power prior to equipment purchase or installation:
. Projects with an estimated incentive of $1,000
or more. Non-standard lighting measures. Variable-frequency drives
The Terms & Conditions for Non-Lighting projects
states:
Pre-Approval Application-ldaho Power customers
("Customed') shall submit an Easy Upgrades Non-Lighting
Pre-Approval Application ("Pre- Approval Application") and
accompanying Project information for all variable
speed/frequency drive ("VSD') Projects and Projects with an
estimated incentive payout of $1,000 or more prior to the
purchase or installation of any qualified equipment. ldaho
Power will review the Pre- Approval Application and, if
approved, will notify Customer to proceed with equipment
purchase and installation. All VSD projects must be installed
in accordance with the /nsfifute for Electrical and Electronics
Engineers (IEEE) Standard 519. A site inspection of
Customer's facility may be required prior to giving
preapproval and will be at the sole discretion of ldaho
Power. No warranty is expressed or implied by this
inspection or the preapproved incentive. Submitting the Pre-
Approval Application with incomplete or missing information
will delay ldaho Powe/s review and may cause return of the
Pre-Approval Application to Customer. False information
may lead to rejection of this and future incentive Pre-
Approval Applications. lncentive payments will be made after
the Project is completed and the Easy Upgrades Non-
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.20
Lighting Payment Application ("Payment Application") and
accompanying Project information has been submitted,
reviewed, and approved by ldaho Power.
The standard practice for the pre-approval process for Easy Upgrades is for
customers or trade allies to submit their pre-approva! application and associated
documentation to ldaho Power (email for lighting projects and emaillfax for non-lighting
projects). These forms and tools are located on ldaho Power's website at
http://www.idahopower.com/EnerqvEfficiencv/Business/Proqrams/EasvUpqrades/defaul
t.cfm. Customers may use the electronic fillable PDF pre-approval form or printed
version of the pre-approval form for non-lighting projects or the electronic lighting tool
for lighting projects. Please see the PDF files provided on the non-confidential CD.
Attachment 1 is a copy of the Non-Lighting Pre-Approval Application and Attachment 2
is a copy of the Commercia!-lndustria! Lighting Retrofit Pre-Approval Application.
When an application is received, Easy Upgrades staff logs the project and enters
it into a database. The project is forwarded to the program specialist to either route for
pre-inspection or to be reviewed. lf a project is not selected for pre-inspection it is sent
directly to a reviewer. The reviewer may be in contact with the applicant during the
review process if there appears to be issues with compliance. The reviewer notifies the
program specialist once their review is complete.
lf a project is selected for pre-inspection, the project is pre-inspected and is then
sent to a reviewer. The reviewer checks over the project information to ensure it
complies with program criteria. The reviewer may be in contact with the applicant
during the review process if there appears to be issues with compliance. The reviewer
notifies the program specialist once their review is complete.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21
Once a project has been reviewed and pre-approved by the program specialist,
an email is sent to the applicant notifying them to proceed with the retrofit project and
submit the payment application when the project is completed. lf the project has been
reviewed and does not meet program criteria, the program specialist notifies the
applicant that their application has been rejected, but that they may re-submit if the
project scope changes in a way that brings it into compliance with program criteria.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Julia A.
Hilton, Corporate 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. 13: Please provide the list of projects, incentive payments, and
locations for all Office of Energy Resources ("OER") projects that the Company incented
in 2012.
RESPONSE TO REQUEST NO. 13: Please see the confidential PDF file
provided on the confidential CD. The confidential CD will be provided to those parties
that have executed the Protective Agreement in this proceeding
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 23
REQUEST NO. 14: Please provide the Request For Proposals ("RFPs") and all
responses to the RFPs, including bid amounts, for the WAQC and Weatherization
Solutions for Eligible Customers ("WSEC") impact evaluation, the lrrigation Efficiency
Research, and the Conservation Potential Assessment. Please include the scope of
work for each RFP if it is not already included in Supplement 2.
RESPONSE TO REQUEST NO. 14: The RFP responses and Scopes of Work
("SOW') requested are confidential, proprietary, and/or have commercial value. Access
to the responses to ldaho Power's RFPs and SOWs will be provided on site at ldaho
Power's corporate headquarters to those parties that have executed the Protective
Agreement in this proceeding. Please contact Doug Jones at 208-388-2615 or Camilla
Victoria at 208-388-5821to arrange access to the information requested.
Please see the non-confidential PDF files. Attachment 1 is the WAQC and
WSEC lmpact Evaluation RFP and Attachment 2 is ldaho Power's Energy Efficiency
Potential Study RFP.
The RFP process was not used for the lrrigation Efficiency Research for several
reasons. The University of ldaho Extension Agency was hired to conduct this research
because they had access to Idaho Power's irrigation customers, had conducted similar
research in the past, and had the facilities, skills, and equipment to conduct this
research. Additionally, the Company thought it was essential to complete this research
during the 2012 growing season to provide for the RTF an opportunity to review the
research to bring these savings into compliance. The Company did not see any benefit
to using the RFP process for this research. lf it had done so, the research would not
have been completed in 2012.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24
As stated on page 105 of the Demand-Side Management 2012 Annual Report:
All cost-effective analyses [for the Menu lncentive Option]
were based on the savings approved by the RTF in January
2010. The measures were reviewed for compliance with the
new RTF savings guidelines in 2011 and were determined to
be out of compliance. ln 2012, the RTF approved of a planto bring the measure back into compliance with the
guidelines. ldaho Power will meet with the RTF in early
2013 to evaluate the research done by the University of
ldaho to study the savings impacts of the measures provided
in the Menu lncentive Option.
The RTF approved updates to the agriculture irrigation hardware savings under
the "Small Savef' category at its Apri! 16, 2013, meeting.The unit energy savings for
be found atthe irrigation measures can
http://rtf. nwcou ncil.oro/measures/measure.asp?id=84.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 25
REQUEST NO. 15: Please explain how the "Evaluation of Sprinkler lrrigation
System Components in Southern ldaho" findings were used to estimate unit energy
savings and non-electric benefits for the Company's irrigation efficiency measures.
Please provide the resulting energy savings and non-electric benefits for each measure.
RESPONSE TO REQUEST NO. 15: ldaho Power received the results of the
"Evaluation of Sprinkler lrrigation System Components in Southern Idaho" early in 2013.
Consequentially, the report's findings were not used to estimate unit energy savings and
non-electric benefits for lrrigation Peak Reward's menu option measures in the
Company's Demand-Side Management 2012 Annual Report ('DSM Report")
Su pplement 1 : Cost-Effectivene ss.
As stated on page 105 of the DSM Report:
All cost-effective analyses were based on the savings
approved by the RTF in January 2010. The measures were
reviewed for compliance with the new RTF savings
guidelines in 2011 and were determined to be out of
compliance. ln 2012, the RTF approved of a plan to bring
the measure back into compliance with the guidelines.
Idaho Power will meet with the RTF in early 2013 to evaluate
the researched done by the University of ldaho to study the
savings impacts of the measures provided in the Menu
lncentive Option.
The study used actual leak measurements to calculate energy savings with
assumed annual operating hours of 2,000, and the report does discuss non-energy
benefits, but does not quantify them on a per measure basis. The RTF convened a
subcommittee to evaluate the research and approved updates to the agriculture
irrigation hardware unit energy savings ("UES") under the "Small Saved' category at its
April 16, 2013, meeting. The UES for the irrigation measures can be found at
http://rtf. nwcouncil.orq/measures/measure.asp?id=84 .
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 26
The Company plans to use this information to modify the program for the fall of 2013.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.2T
REQUEST NO. 16: Please explain how the sample for the inigation efficiency
research was established. lf the sample was chosen by the researchers, please explain
how selection bias was addressed.
RESPONSE TO REQUEST NO. 16: The nature of the research was to collect
actual field measurements of water losses along with estimates of yield improvement
and energy reduction resulting from component repair and replacement. Because the
research was not intended to create a baseline population measurement, a non-
population based sample was selected primarily based on known accessible systems to
University of ldaho personnel in Southern ldaho. A portion of the research sites were
purposefully selected because they had previously participated in the lrrigation
Efficiency Menu option. The goal of the selection process was to obtain a variety of
leaky systems, with variation in age and equipment condition, to improve engineering
based calculations and savings calculations for lrrigation Efficiency Menu measures.
The research was intended to not only improve ldaho Power's energy savings
estimates, but to be used in the region as a whole.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 28
REQUEST NO. 17: The chart on page 2 of Supplement 2: Evaluations indicates
that lrrigation Efficiency will undergo an impact evaluation in 2013. Please explain how
this impact evaluation will differ from the research conducted on the program in 2012.
RESPONSE TO REQUEST NO. 17: The lnigation Efficiency Rewards program
research done in 2012 was not an impact evaluation conducted to determine overall
gross or net program energy savings. lt was done to quantify the unit energy savings
for measures offered under the lrrigation Efficiency Rewards Menu Option.
The 2013 impact evaluation of the lrrigation Efficiency Rewards program will be
an assessment of energy and demand savings attributable to the program using a
statistically valid sampling methodology incorporating both Custom Option and deemed
Menu Option savings.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.29
REQUEST NO. 18: Please provide the revised version of the impact evaluation
for Building Efficiency referenced on page 80 of the DSM 2012 Annua! Report and
highlight changes from the original version.
RESPONSE TO REQUEST NO. 18: Please see the non-confidential PDF file
provided on the non-confidential CD.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Supervisor, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counse!, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 30
REQUEST NO. 19: When the Regional Technical Forum ("RTF") updates the
deemed savings for a measure in the middle of the program year, when does ldaho
Power start using the new savings estimates for program reporting and cost-
effectiveness calculations?
RESPONSE TO REQUEST NO. 19: Throughout the year, ldaho Power staff
attends RTF meetings and follows the progress of measures as they are reviewed and
updated. ldaho Power updates the energy savings and cost-effectiveness analysis for
each program in preparation of the Demand-Side Management Annual Report
("Report"). Generally, the savings reported and used for cost-effectiveness analysis by
ldaho Power are the most recently updated savings from the RTF or other sources.
The exceptions are if the savings are tied to a code change that occurs on a specific
date or if the updates were made late in the year. For instance, new RTF savings for
measures that are updated late in the year are not used since the final RTF
spreadsheets are sometimes not immediately available and/or work on the Report has
progressed to a point where changes to savings cannot be incorporated into the text,
tables, analysis, appendices, and Supplemenfs necessary to complete and file the
Report.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counse!, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 31
REQUEST NO. 20: Did ldaho Power include indirect administrative expenses
(overhead expenses such as regulatory, managerial, and financial oversight) in the
cost-effectiveness calculations for its DSM programs in 2012? lf so, please explain
what categories and amounts of costs were included. Please also describe the method
of overhead cost allocation among the programs.
RESPONSE TO REQUEST NO. 20l. ln 2012, the only programs for which ldaho
Power allocated indirect program expenses were the WAQC and WSEC programs.
These did not include overhead expenses such as regulatory or lega! expenses;
however, expenses related to financial oversight and energy efficiency leadership were
included in the allocation.
As stated in ldaho Powe/s Demand-Side Management 2012 Annual Report
("Annual Report"), Supplement 1: Cost-Effectiveness, page 5:
ldaho Power has adopted the following commission staff's
recommendations from Case No. GNR-E-12-01 for
calculating [the WAQC and WSEC programs].
o lncluded indirect administrative overhead costs. The
overhead costs of 2.71 percent was calculated from the
$1,335,509 of indirect program expenses divided by the total
DSM expenses of $49,326,859 as shown in Appendix 3 of
the Demand-Side Management 2012 Annual Report.
ln Idaho Powers accounting system direct program expenses are tracked by
work order and task. Program Specialists charge their labor and other administrative
expenses directly to the programs. Additionally, work performed on specific programs
by field staff and corporate communications are charged directly to the programs.
The energy efficiency leaders, analysts (including the financial analyst), and
marketing specialists charge their labor and administrative expenses to the work orders
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 32
identified under lndirect Program Expenses in Appendix2 of the Annual Report. These
work orders are also used to track general marketing expenses, services, memberships,
and research that touch all programs such as the energy efficiency potential study.
These work orders do not include the labor expenses from other departments such as
regulatory and legal.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 33
REQUEST NO. 21: Please list the measures and dollar values for each measure
included as a health, safety, and repair measure in the 2012 WAQC and WSEC cost-
effectiveness calcu lations.
RESPONSE TO REQUEST NO. 21: Dollar values for health and safety
measures along with repair measures are fully contained in the measure categories
Health and Safety and Repair respectively listed in the Demand-Side Management
2012 Annual Report Supplement 1: Cost-Effectivenesson pages 55 (WAQC) and 57
(WSEC). The Health and Safety dollar contributions for both WAQC and WSEC include
various categories of improvements to the custome/s home that are needed to protect
the safety of the installed measures and/or the customer and may include items such as
carbon monoxide detection, water leaks, small construction modifications, and detection
of lead. These sub-categories of the Health and Safety measures are identified in the
EA4.6 (WSEC) and EAS (WAOC) audit forms as comment and text descriptions and
any associated productions costs are aggregated into the Health and Safety measure
category. The Repair category includes just one sub-category and that is repairs done
to furnaces.
ln 2012, the total Health and Safety measure cost for WAQC was $1 19,061 with
$7,279.64 billed as Idaho Power measure costs. For WSEC the total Health and Safety
measure cost was $35,320.22. ln 2012, WAQC repair measures which consisted of
furnace repairs totaled $18,280.61 with $3,898.88 billed as ldaho Power production
costs. For WSEC in 2012, $7,779.54 in repair measures (furnace repairs) expenses
were incurred as part of home weatherization.
The response to this Request was prepared by Pete Pengilly, Customer
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 34
Research and Analysis Supervisor, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 35
REQUEST NO. 22: Does the WAQC program include refrigerator replacements
as a qualifying measure? lf so, please explain why none were funded in ldaho in 2012.
RESPONSE TO REQUEST NO. 22: Refrigerator replacements under the
WAQC program are not common for several reasons. ln ldaho Powe/s opinion,
these reasons are:
1. The Weatherization managers that work for the CAP agencies report that
with ldaho Power's low rates it is difficult to calculate a savings to investment ratio
(SlR) greater than one for refrigerator replacement which is one of the criteria for
ldaho Power to fund a measure. When they do replace refrigerators they generally
use non-ldaho Power funds.
2. Many times the requirements in the ldaho State Weatherization
Assistance Program manual and the customer agreement required for refrigerator
replacement are barriers to customers' acceptance of the measure.
Please see the PDF files provided on the non-confidential CD for the
Weatherization customer agreement (Attachment 1) and the ldaho State
Weatherization Assistance manual requirements (Attachment 2).
3. Many weatherization customers prefer not to replace their current models
with the allowed styles of refrigerators which are specified in the ldaho State
Weatherization Assistance Manual and customer agreement.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 36
REQUEST NO. 23: Does Idaho Power plan to alter the list of qualifying
measures or other aspects of its WAQC and WSEC programs to improve cost-
effectiveness? lf so, please describe what potential changes are being considered.
RESPONSE TO REQUEST NO. 23: ldaho Power has not identified any specific
potential program changes and continues to direct WAQC agencies and WSEC
contractors to follow the guidelines for the ldaho State Weatherization Assistance
Program provided by Department of Energy. The Company is researching changes that
could improve the cost-effectiveness of the WAQC and WSEC programs for the
company.
ln 2013, ldaho Power issued an RFP for process evaluations for the WAQC and
WSEC programs, selected a contractor, negotiated a contract, and have had the initial
meeting with the contractor.
Additionally, ldaho Power will issue a RFP to conduct research and analyses on
the Energy Audit 5 (EA 5) model to assess the differences between the audit results
and impact evaluations.
The WAQC and WSEC program specialist has discussed the issues surrounding
cost-effectiveness with the weatherization managers and contractors and plans to meet
with them in August.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 37
REQUEST NO. 24: ln Commission Order No. 32667, Case No. !PC-E-12-15,
the Commission encouraged the Company "to take other opportunities [besides the
EEAGI to improve customers' energy LQ. and to educate them about the Company's
energy efficiency programs. For example, the Company might hold workshops or post
videos on its website that explain the energy efficiency programs it offers, why it selects
certain programs and measures over others, and how it perceives cost-effectiveness
and values energy efficiency within its system." What opportunities, if any, has the
Company taken to improve customers' energy l.Q. and to educate them about the
Company's energy efficiency programs, beyond the opportunities that existed in 2011?
RESPONSE TO REQUEST NO. 24: ldaho Power educates its customers, trade
allies, and contractors on the benefits of energy efficiency and the Company's energy
efficiency programs through many avenues. These activities are described in each
yeads Demand-Side Management Annual Report. Descriptions of education and
marketing activities are included in the introduction, each program's section, and the
sections labeled Sector Overviews, Residential Energy Efficiency Education lnitiative,
Commercial Energy Efficiency Education and Continued Commitment. Specifically
these activities are described in lhe Demand-Side Management 2011 Annual Report on
pages 12-13, 109-120, 127-131. ln the Demand-Side Management 2012 Annual
Report the marketing and education activities are described on pages 15-16, 117-127,
133-137.
The Company did enhance its education and outreach activities beyond those
that existed in 2011, however due to the timing of the issuance of the order, these
enhancements were not a direct result of the order. Commission Order No. 32667,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 38
Case No. IPC-E-12-15 was issued on October 22, 2012, leaving only 10 weeks in 2012
to act on this order. Since the issuance of the order, the Company has and will continue
to comply with Commission Order No. 32667.
One of the 2012 activities included working with an external vendor to produce a
customer testimonial video that focuses on ductless heat pumps. The video's objective
is to highlight the benefits of energy efficient ductless heat pumps. This video was
posted in 2012 and as of June 2013 has had more than 8,700 views, higher than any
other Idaho Power video posted on the ldaho Power YouTube channel. To maximize
the usage of this video, it was also posted on ldaho Power's ductless heat pump
program web page:
htto://www.idahopower.com/EnerqyEfficiencv/Residential/Proorams/ductlessHeatPump
s/default.cfm.
!n addition, two movie theater ads were produced using internal resources. One
ad promoted the Home lmprovement program and the other ad promoted the Ductless
Heat Pump pilot and the Heating & Cooling Efficiency programs. These animated ads
were shown at Regal Cinema theaters in Nampa and Boise for eight weeks during June
and July, 2012. The number of individual ads shown totaled 12,544. The number of
total projected impressions was 695,376. Both ads have been posted to YouTube as
well as to the ldaho Power Home Improvement web page:
http://www.idahopower.com/EnerqvEfficiencv/Residential/Proqrams/HomelmprovemenU
default.cfm.
To increase the level of communication with the Company's small/medium
commercial customerc, the Company launched the first bi-annual "Energy at Work"
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 39
commercial newsletter in August 2012. A second edition was sent out in the spring of
2013 with plans to publish another newsletter in September 2013. The goal of the
newsletter is to provide information that is pertinent and useful to a customer segment
that has very limited time. The spring 2013 edition is available for download on ldaho
Power's business energy efficiency web page:
http://www.idahopower.com/EnergvEfficiency/Business/default.cfm?tab=Business.
Planning for an online advertising campaign to increase participation in the Easy
Upgrades program began in the fa!!/winter of 2012. This was the first time the Company
has used online advertising for a commercial energy efficiency program. An animated
ad was developed to target commercial businesses. The ad launched on January 2,
2013, and finished on April 1, 2013. The final campaign summary showed total
impressions (ads) served was 2,853,297 with 3,367 people who clicked on the ad and
were taken to ldaho Power's Easy Upgrades web page. According to Media Partners,
the external vendor who managed the campaign, "The campaign has improved the
visibility and awareness of the Easy Upgrades program, based on the high re-
messaging totals."
ln 2012, ldaho Power published three Energy Efficiency Guides to educate
customers about its energy efficiency programs and provide appropriate suggestions for
both summer and winter conditions. The two winter guides that anived in January and
November, placed particular emphasis on energy efficiency programs and
behaviors/choices to assist customers living in electrically heated homes. Other topics
included no and low-cost savings opportunities, an explanation of why ldaho Power
promotes energy efficiency and how it selects program measures, and suggestions for
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.40
improving comfort and getting the most out of energy upgrade investments. Eleven
local newspapers and the Boise Weekly distributed over 633,000 guides in 2012-up
from 162,500 guides distributed by six newspapers in June of 2011 .
ln 2012, ldaho Power proposed a new Student Energy Efficiency Kit program to
EEAG and upon their overall agreement began the RFP process in order for the
program to be implemented in the first quarter of 2013. These 2012 activities resulted
in 2,773 student kits being distributed to homes via 4th-Oth grade students on or before
April 1 ,2013.
ln 2012, Idaho Power engaged participating contractors in the Home
lmprovement Program, Energy House Calls, H&CE Program, Boise Home Audit
Project, and See ya later, refrigerator@ program to assist in disseminating the
educational booklet "30 Simple Things You Can Do to Save Energy" which is published
in both English and Spanish. Local libraries were also invited to serve as distribution
points for this book as well as to host a table display promoting Energy Efficiency Kits
for checkout. Eight libraries participated. ldaho Power partnered with the ldaho Design
Lab ("lDL") in late autumn to offer two residential training seminars in the Better Bricks
series-up from one seminar in 2011. !n Hailey, seven community workshops were
given to support the Hailey Community Climate Challenge effort-a project that will
continue into 2013. ln addition to these efforts, ldaho Power participated in a tota! of
171 outreach activities and delivered 268 energy efficiency presentations to a broad
spectrum of customers including students and senior citizens-representing an
approximate 35 percent increase in recorded outreach activity over 2011.
The Building Efficiency program held 21 technical training lunches in 2012, up
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 41
from 20 held in 2011. The Building Efficiency program, in conjunction with the Custom
Efficiency program sponsored 12 training sessions for the Building Simulations User
Group through the lDL, up from nine in 20'11. Building Efficiency teamed up with the
Buihing Owners and Managers Association (BOMA) and NEEA to offer a Kilowatt
CrackdownrM competition for large office buildings in the Treasure Valley, with an
emphasis on raising energy use awareness. The Custom Efficiency staff developed the
Refrigeration Operator Coaching for Energy Efficiency (ROCEE) offering which includes
a focus on coaching and educating industrial customers on their refrigeration energy
consumption, to be implemented in 2013. ldaho Power's Major Customer
Representatives (MCR) were directed to each visit 10 new non-participant customers in
2012, with a goal of educating them on ldaho Power energy efficiency programs. Easy
Upgrades offered eight lighting trade ally program information workshops in 2012, which
was up from five in 2011. These trainings were also expanded into McCall for the first
time in 2012. Easy Upgrades led a significant effort to visit trade allies in the ldaho
Power service territory, with a goal of increasing knowledge of the Easy Upgrades
program. Over 75 visits were made in 2012. Also in 2012, six new Success Stories
were created and posted to the company's website. These success stories highlight
customers' energy savings efforts and their participation in the ldaho Power energy
efficiency incentive programs. Idaho Power also expanded on the IDL contract to
increase the general public and design community literacy about how different
classifications of commercial buildings consume energy and the metrics associated with
this data in 2012. This information was used to create five informational graphics
sheets, organized by building type, which were then featured for download on the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 42
University of Idaho-lDL website.
ldaho Power has offered workshops educating irrigation customers on efficient
irrigation methods, equipment, and programs. ln 2012, ldaho Power provided six
workshops for educating irrigation customers and promoting the lrrigation Efficiency
Rewards program throughout its service area. Approximately 260 customers attended
workshops in Blackfoot, Burley, Twin Falls, Grand View, and Nampa. ldaho Power also
accepted invitations to present the program at three workshops sponsored by
agricultural groups in ldaho Falls, Gooding, and Nampa. Exhibitor booths were
displayed at regional agricultural trade shows, including the Eastern and Western ldaho
Agriculture Expos, the Agri-Action Ag show, the Treasure Valley lrrigation Conference,
and the ldaho lrrigation Equipment Association show and conference.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 43
REQUEST NO. 25: How has the Company's marketing department restructured
itself to "utilize better-coordinated marketing campaigns and targeted messaging" with
the A/C Cool Credit team? See Portland Energy Conservation, Inc. (.PECI') A/C Cool
Credit process evaluation, page 5.
RESPONSE TO REQUEST NO. 25: The PECI report was received in November
2Ol2leaving little time in 2012 to incorporate recommendations from the report into the
Company's marketing plan. Additionally, at that time ldaho Powe/s marketing activities
for the A/C Cool Credit program were minimal because the Company filed on December
20, 2012, to temporarily suspend the A/C Cool Credit program for the summer of 2013.
Pages 15-17 of ldaho Power's Demand-Side Management 2012 Annual Report
describe ldaho Power's general marketing activities for 2012 including the addition of a
second marketing specialist to the energy efficiency team. Also, in ldaho Power's
Demand-Side Management 2012 Annual Report on pages 27-28, the Company
describes its marketing activities specific to A/C Cool Credit throughout2Ol2.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 44
REQUEST NO. 26: Why hasn't the Company renegotiated the terms of the
Honeywel! contract for the A/C Cool Credit program to be more responsive to the
Company's peak? See Portland Energy Conservation, lnc. ("PECI') A/C Cool Credit
process evaluation, page 14.
RESPONSE TO REQUEST NO.26: The PECI process evaluation referred to by
Staff in this request was received in November, 2012, leaving little time in 2012 for
Idaho Power to evaluate and/or act on the recommendations from the report.
The Company filed, on December 20,2012, to temporarily suspend the A/C Cool
Credit program for the summer 2013 which resulted in the Company renegotiating the
contract with Honeywell for 2013. The new contract includes no new installations,
receiving customer service calls during normal business hours, processing of customer
service requests (removals and troubleshooting), processing move in/outs and removal
of equipment when appropriate, and maintaining the existing client server database
which interfaces with the Company's CIS system.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 45
REQUEST NO. 27: Please provide the life cycle cost-effectiveness calculations
for the FlexPeak program assuming a S-year measure life.
RESPONSE TO REQUEST NO. 27: Please see the confidential Excel file
provided on the confidential CD, which contains EnerNOC information that is
confidential, proprietary, and/or has commercial value. The confidential CD will be
provided to those parties that have executed the Protective Agreement in this
proceeding. ldaho Power requests that references to the confidential information
provided in this response be excluded or redacted from any reports and/or analyses.
Under a five-year program !ife, FlexPeak Management is shown to have a TRC
ratio of 1.35 which is higher than the 1 .22 TRC shown in Demand-Srde Management
Annual 2012 Report, Supplement 1: Cost-Effecfiveness. This is due to the higher
annual TRC ratios from the historica! years (2009-2012) and the lower annual TRC ratio
under the assumptions used in the future years (2013-2018).
As described on page 82 of the Demand-Side Management 2009 Annual Report
in regards to the program's higher than expected cost-effectiveness ratio:
Lower expenses and higher demand reduction contributed to
the program's cost-effectiveness in year one....Most notably,
the assumption in the cost-effectiveness analysis was that
EnerNOC would achieve the exact MW demand reduction
they committed to provide ldaho Power. ln actuality,
EnerNOC achieved a much greater reduction than the
committed MW reduction.
The cost-effectiveness analysis for FlexPeak Management was designed to
observe the extreme case scenario in the future years. ln this scenario, the program
would be called for the maximum 60 event hours which would increase the program
costs. Additionally, it is assumed that there is a one-to-one relationship between the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 46
megawatt (.MW') achieved and the MW committed in the future years. ln reality, when
EnerNOC achieves more than the committed MW, ldaho Power pays for a fraction of
that additional MW reduction. Also, when EnerNOC achieves less than the committed
or contracted MW reduction, EnerNOC pays penalties to ldaho Power. Both of these
scenarios have occurred in the past four years, which is why the annual TRCs from
2009 to 2012 are higher than forecasted.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 47
REQUEST NO. 28: Please provide specific examples of how the Company
educated Realtors@ and appraisers to help assist in marketing Energy Star Homes
Northwest.
RESPONSE TO REQUEST NO. 28: ln 2012, ldaho Power recertified with the
ldaho Real Estate Commission to offer the lncreasing Sales with ENERGY STAR@
course. Realtors receive four continuing education credits ("CEC") with the successful
completion of the class. This course instructs realtors and appraisers in the need for,
and technical aspects of, Energy Star homes and demonstrates the whole house
approach to energy efficiency. While appraisers do not receive credit, unless they are a
licensed realtor, they, and all students in the class, are taught how an energy-efficient,
ENERGY STAR@ home differs from a standard home built to code. ldaho Power
submits all class information to the Idaho Real Estate Commission for CEC and sends
class completion certificates to attendees. This course is taught by Northwest ENERGY
STAR@ trainers and local Home Performance Specialists ("HPS"). One HPS offered the
course in 2012. ldaho Power supplied program materials to be distributed to attendees.
ldaho Power ensures ENERGY STAR@ Homes marketing materials are available to
realtors at all times. These materials assist realtors in marketing ENERGY STAR@
Homes to, and educating, consumers on the benefits of purchasing an energy-efficient,
ENERGY STAR@ Home.
ldaho Power Canyon Region staff are also members of their local Realtor
Association and promote ENERGY STAR@ Homes to realtors through that association.
Provided on the non-confidential CD are non-confidential PDF files of the
ENERGY STAR@ Home Realtor packets provided to promote the sale of ENERGY
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 48
STAR@ Homes (Attachments 1-6).
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 49
REQUEST NO. 29: How many training sessions were held in September 2012
for Heating and Cooling Efficiency? Was the eligibility requirement to attend the
sessions specific to new participants or all participants?
RESPONSE TO REQUEST NO. 29: ldaho Power conducted seven heat pump
trainings during 2012 for the Heating and Cooling Efficiency program. One of the seven
was held in September. The trainings are available and offered to both participating
and non-participating contractors across the ldaho Power service territory.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, Idaho Power Company.
DATED at Boise, ldaho, this 27th day of June 2013.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 50
Attorney for Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 27h day of June 2013 I served a true and
conect copy of 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:
Gommission Staff
KarlT. Klein
Deputy Attomey General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
710 N 6th Street
Boise, Idaho 83701
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mai!
FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 51
CERTIFICATE OF ATTORNEY
ASSERTION THAT MATERIALS REQUESTED AND PROVIDED DTRTItrG.iXTTE Pi.i
couRSE oF AN TDAHO PUBLTC UTtLtTtES COMMTSSTON PROCEEpIN.G
ARE PROTECTED FROM PUBLIC INSPECTION , -,"i: ,1-, .-
Case No. IPG-E-13-08
The undersigned attorney, in accordance with RP 233, hereby certifies that the
attachments provided in ldaho Power Company's response to the ldaho Public Utilities
Commission Staffs Production Request Nos. 4, 7, 13, & 27 contain information that is a
trade secret or privileged or confidential as described in ldaho Code S 9-340, ef seg.,
and $ 48-801, ef seq., and as such are exempt from public inspection, examination, or
copying.
DATED this 27th day of June 2013.
2: lB
:._, : : _
Counsel for ldaho Power Company