20130717IPC to ICL 1-3.pdf

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An IDACORP Company
JULIAA HILTON
Corporate Counsel
ihi [e-mail]
July 17,2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West 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 Requestof the ldaho Conservation League
to Idaho Power Company.
Dear Ms. Jewel!:
Enclosed for filing in the above matter are an origina! and three (3) copies of Idaho
Power Company's response to the First Production Request of the ldaho Conservation
League to ldaho Power Company. Please note that per Jean Jewell's approval ldaho
Power has provided four (4) bound copies and one (1) emailed copy of ldaho Power's
attachment to Request No. 2.
JAH:evp
Enclosures
. r .-:- I ali;i .;,..i-l
1221 W. ldaho 5t. (83702)
PO. Box 70
Boise, lD 83707
Very truly yours,
Julia A. Hilton
JULIA A. HILTON (lSB No. 7740)
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
ih i lto n@ ida hopower. com
I nord strom@ idahopower. co m
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
tN THE MATTER OF THE APPLTCATTON )
oF IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-13-08
DETERMTNATTON OF 2012 DEMAND- )
SIDE MANAGEMENT EXPENDITURES AS ) !DAHO POWER COMPANY'S
PRUDENTLY INCURRED ) RESPONSE TO THE FIRST
) PRODUCTTON REQUEST OF THE
) IDAHO CONSERVATTON LEAGUE
) TO IDAHO POWER COMPANY
)
COMES NOW, ldaho Power Company ("ldaho Powed' or "Company"), and in
response to the First Production Request of the ldaho Conservation League ("lCL") to
ldaho Power Company dated June 26,2013, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 1
REQUEST NO. 1: Please provide a copy of all production requests submitted in
this case by other parties, along with any responses by Idaho Power.
RESPONSE TO REQUEST NO. 1: Please see Idaho Power Company's
Response to Staff's First Production Request to ldaho Power Company. The
confidential CD that accompanied the Response will be provided to those parties that
have executed the Protective Agreement in this proceeding. The non-confidential
portions of the response were served on the ldaho Conservation League via electronic
mail on June 27,2013.
The response to this Request was prepared by Elizabeth Paynter, Legal
Administrative Assistant, 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 IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY.2
REQUEST NO. 2: Please provide a hard copy of the 2013 Demand Side
Management Potential Study including any appendices.
RESPONSE TO REQUEST NO. 2: Please see the enclosed hard copies of
ldaho Power's Energy Efficiency Potential Study by EnerNOC Utility Solutions
Consulting, February 15,2013, and the Technical Appendix of ldaho Power's Energy
Efficiency Potential Study.
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 IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 3
REQUEST NO. 3: Please compare, by DSM program, the level of energy
efficiency achieved by ldaho Power in 2012 against the level of cost effective potential
and the achievable potential identified in the 2009 DSM Potential Study. Along with
quantifying the gap, please provide a qualitative description of the factors underlying
any gap.
RESPONSE TO REQUEST NO. 3: ln 2009, ldaho Power conducted an energy
efficiency Potential Study which provided a 2O-year outlook of energy efficiency
potential savings prepared by the third party consultant firm, Nexant lnc ("Nexant"). The
study defined energy efficiency potential in three different categories: technica!
potential, economic potential, and achievable potential. The Nexant Study states:
The DSM resource for EE programs can be characterized by
the technica! potential, economic potential, and achievable
potential. The technical potential describes the savings
available if all baseline equipment stock was replaced with
every applicable measure. The economic potential is a
calculation of savings when all measures that are cost-
effective are installed. Market penetration rates are then
developed from market research and evaluation data
gathered through the implementation of representative DSM
programs, primarily in the Northwest. Applying these market
penetration rates to the economic potential yields the
calculation of achievable potential which represents the
savings that IPC can expect to achieve from EE programs.
Economic or all cost-effective energy efficiency will always be higher in any
potentia! study than achievable potential, and while it is the Company's desire to
minimize the gap between economic and program results through effective marketing,
education, and efficient program design, it is not reasonable in most cases for the gap
to be bridged at 100 percent. A useful example of barriers to achieving all economic
potential would include a high incremental cost measure such as a high-efficiency heat
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 4
pump. lt would be difficult to expect that all forced air furnaces that need replacement
on an annual basis be converted to a high-efficiency heat pump at 100 percent because
each consumer will have a different set of economic choices that may include things
such as willingness to pay, planned tenure in the residence, climate, or any other
unique personal preferences that might impact the purchasing decision.
ln responding to this request, ldaho Power assumes that ICL's reference to "cost-
effective potential" is referring to economic potentia! as defined in the Nexant report. lt
is important to note that by the report's definition the achievable potential is what Idaho
Power can expect to achieve from its energy efficiency programs.
The table below illustrates that in total ldaho Power exceeded Nexant's
achievable potential by 24 percent.
All Programs
ldaho Power Program
20t2
Achievable
Potential
(Nexant)
20t2
Program
Savines
2OL2to Actual
Savings to
Achievable Gap
(Portfolio Savings -
Achievable
Potential)
Overall Program Performance 125,586 155,115 29,529
*lncludes line-losses
ldaho Power is constantly improving programs and researching new possible
measures to add to programs and increase energy savings. ln the Company's
Demand-Side Management 2012 Annual Report, ldaho Power includes for each
program a section entitled 2013 Strategies. These sections include new potential
savings opportunities, and forward-looking challenges in achieving savings. ln each
program section the Company includes a description of changes to programs and
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 5
measures that may be included or excluded from programs based on cost-
effectiveness.
For the residential sector, the total savings reported in ldaho Power's Demand-
Side Management 2012 Annual Report for the nine programs that were included in the
Nexant study exceeded the forecasted achievable potential energy savings by 11
percent. Overall, for the residential customer class, the Nexant achievable potential
forecasted savings was 23,605 megawatt-hours ('MWh") in 2O12 while ldaho Poweds
reported savings were 26,169 MWh including line-losses.
The gap between 2012 actual claimed savings and the study's forecasted
economic potential savings was 185,662 MWh. Over 80 percent of the difference
between actual program savings was due to deficits quantified in three programs;
Heating and Cooling Efficiency, Home lmprovement, and Home Products. The table
below lists each residential program with the achievable potential and the economic
potential from the Nexant study, ldaho Power's 2012 program savings, and the gap
between the economic potential and the achieved savings. Ductless heat pumps were
not included in the Nexant study and therefore are listed with an "n/a" in the economic
and achievable potentia! columns. There are six measures in the study that are not
currently measures in ldaho Power's program portfolio which account for 27,061 MWh
of economic potential savings and 1,430 MWh of achievable potential that are listed as
other potential measures in the table. The list of measures includes gravity film heat
exchanger, electronic thermostats, infiltration control, single family home duct sealing,
water heater pipe insulation, and ceiling fans.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 6
Residential Programs
ldaho Power Program
2012
Achievable
Potential
(Nexant)
20L2
Economic
Potential
(Nexantl
2012
Program
Savings
20L2
Economic to
Actual
Savines sao
Totals (MWhl 23,605 2LL,83L 26,!69 -185,662
Ductless Heat Pump Pilot
Energy Efficient Lighting
Energy House Calls
ENERGY STAR@ Homes Northwest
Heating & Cooling Efficiency
Program
Home lmprovement Program
Home Products Program
Rebate Advantage
See ya later refrigeratoro
Low lncome Weatherization
Other Potential Measures
nla
8,069
398
658
3,159
3,44L
3,300
702
264
2,L64
L,430
n/a
L3,OL4
664
3,927
7L,454
68,8L2
13,815
1,533
3,266
8,185
27,06t
493
18,530
L,322
596
764
520
984
208
L,748
L,OO4
nla
493
5,515
658
-3,331
-70,690
-68,292
-L2,832
-L,425
-1,518
-7,t80
-27,O6L
Gravity film heat exchangers extract energy from residential heated waste water
and is a measure not adopted in the region by the Regional Technical Forum (RTF).
Electronic thermostats have been monitored as a potential measure, but with much of
the savings relying on customer behavior and mixed program evaluations from other
utilities the measure has not been implemented. Whole house infiltration control and
single-family home duct sealing are both measures under consideration for
implementation. ldaho Power has been monitoring pilot programs in other regional
utilities for whole house duct sealing and exploring program potential implementation
designs. Water pipe insulation has been considered as a potential bundled measure
with high efficiency water heaters when an Energy Star rating is developed for electric
water heaters. Ceiling fans were offered in the Home Products program, but with
increasing baselines in lighting and the reliance of savings of ceiling fans on lighting
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 7
savings, the measure was removed from the program as non cost-effective prior to
2012.
The largest gap between 2012 actual savings and the economic potential was for
measures that apply to the Company's Heating and Cooling Efficiency program which
incents ducted heat pump systems and also evaporative coolers. The gap between
actual program savings and the economic potential is 70,690 MWh. lncluded in that
gap is an estimate that replacements of central air conditioning units with evaporative
coolers would total 20,750 MWh of savings. Although evaporative coolers are included
in the Heating and Cooling Efficiency program and have been since 2007, there has
been very little interest in evaporative coolers by ldaho Power's customers. The other
significant portion of the gap between economic potential and actual program results
were in air source heat pumps. The primary barrier to the adoption of this measure is
high incremental costs including the costs of the proper installation required by the
program. The second highest gap between the Nexant economic potential was for
measures included in the Home lmprovement program. The 68,000 MW gap is largely
due to window replacements. Window replacements were implemented in 2013 and the
measure is only cost-effective for electrically heated homes, which limits the adoption of
this measure. The third significant gap between program savings and economic
potential is from appliances offered in the Home Products program. The potential
model has efficient clothes washers still ramping up during 2012 but because of the
rapid market transformation of efficient clothes washers and increasing baseline
efficiencies the measure clothes washers are no longer considered cost-effective and
were removed from the program during 2013.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 8
Another contributor to the gap between Nexant economic potential and ldaho
Power's actual energy savings is the potential in multi-family residential weatherization
retrofits and for an increase penetration into the new construction market. The
Company is monitoring regional analysis of savings estimates and discussions
occurring on the challenges of the split incentive problem in multi-family efficiency. !n
many cases building owners do not see an immediate benefit to installing and
maintaining energy efficient equipment and investing in building upgrades when the
tenants are often paying the electricity bills and realizing the savings.
For the Commercial and lndustrial ("C&1") sector, ldaho Powe/s 2012 reported
savings for the three C&l programs that were included in the Nexant study exceeded
the Nexant forecasted achievable potential energy saving by 26 percent. Overall for the
C&l customer classes Nexant's achievable potential forecasted savings of 101,981
MWh for 2012, was exceeded by reported savings of 128,945 MWh including line-
losses.
The gap between 2012 actual claimed savings and the forecasted economic potential
savings was is almost 693,000 MWh. The table below lists each C&l program with the
economic potential, 2012 program savings with line losses, and the gap between the
two.
C&lPrograms
ldaho Power
Program
20!2
Achievable
Potential
(Nexant)
2012 Economic
Potential
(Nexantl
2012 Program
Savings*
2012 Economic
to Actual
Savings gap
Totals (MWhl 101,981 82L,O32 L28,945 -692,O87
Building Efficiency
Easy Upgrades
Custom Efficiency
4,477
31,583
65.92L
27,O42
515,055
277,934
22,679
46,100
60,L67
-4,363
-469,956
-2t7,768
*lncluding Line Losses
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 9
The largest gap between Nexant's economic potential and ldaho Poweds
reported savings is attributable to the program offerings under the Easy Upgrades
program, with a gap of over 450,000 MWh. The savings attributed to the Easy
Upgrades program has steadily increased since its inception with a 7 percent increase
from 201 1 to 2012 contributing 36 percent of the C&l savings in 2012.
ln 2013, ldaho Power anticipates offering incentives for qualifying T-8 lamps to
reduced-wattage T-8 lamps, T-5 High Output (T-SHO) lamps to reduced-wattage T-SHO
lamps, screw-in metal halide lamps, T-8 lamps, and T-8 to LED refrigeration/case
lighting. The Easy Upgrades program continues to offer training to trade allies because
they are a primary source of awareness of the program for the customers.
The Company has several new program offerings in 2013 for larger C&l
customers including the options for customers with smaller targeted custom projects
involving end-uses such as compressed air, pump, and fan Variable Frequency Drives
(VFD). Additional offerings include direct hands-on energy efficiency training to key
individuals whose actions have a direct bearing on the energy performance of energy-
intensive systems. The third program offering will provide training and incentives to
program-offering participants focused on low-cost or no-cost measures that may have
more behavioral or operations and maintenance-related. Other plans for program
growth include doing non-participant research and interviews with customers to learn
about barriers to the next project or why they have not participated previously in custom
efficiency or other programs.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 1O
The response to this Request was prepared by
Research and Analysis Leader, ldaho Power Company, in
Hilton, Corporate Counsel, Idaho Power Company.
DATED at Boise, ldaho, this 17s day of July 2013.
Pete Pengilly, Customer
consultation with Julia A.
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 11
I HEREBY CERTIFY that on this 17th day of July 2013 t served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Karl T. Klein
Deputy Attomey Genera!
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
710 N 6h Street
Boise, ldaho 83701
X Hand Delivered
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Ovemight Mai!
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 12