20140826Staff to IPC 1-6.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2013 DEMAND.SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
RECffiI!J:iiti
20lq AUG 25 Pl'l 2: 58
CASE NO. IPC-E-I4.04
COMMISSION STAFF'S
RESPONSE TO THE FIRST
PRODUCTTON REQUEST OF
IDAHO POWER
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, responds as follows to Idaho Power's First Production
Request to Commission Staff.
REQUEST NO. 1: On pages 8-9 of Staffs Comments, Staff states, "Instead of relying
on customer-preference based marketing techniques that are losing effectiveness, Idaho Power
should independently or with the help of external experts, determine and fully fund effective
marketing techniques to drive demand for programs."
a. Please provide any and all work papers, data, or other information used to determine
whether or not customer-preference based marketing techniques are losing effectiveness.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO
POWER AUGUST 26,2014
b. Please provide any and all work papers, data, or other information used to define and
evaluate "effective marketing techniques."
STAFF RESPONSE NO. 1:
a. Staff used the results of the J.D. Power and Associates Customer Satisfaction Study,
the HANSA GCR Non-Participant survey, the Opinion Dynamics Easy Upgrades Program
Process Evaluation, the TRC Energy Services Residential Programs Process evaluation, and the
2013 DSM Annual Report to determine that customer-based marketing techniques are losing
effectiveness.
b. Merriam-Webster defines "effective" as "producing a decided, decisive, or desired
effect." In the case of energy efficiency, this means that "effective marketing techniques" are
those which provide stable or increasing energy savings.
Staff evaluated the effectiveness of Idaho Power's marketing techniques using the results
of the J.D. Power and Associates Customer Satisfaction Study, the HANSA GCR Non-
Participant survey, the Opinion Dynamics Easy Upgrades Program Process Evaluation, the TRC
Energy Services Residential Programs Process evaluation, and the 2013 DSM Annual Report.
REQUEST NO 2: On page 9 of Staffs Comments, Staff "determined that the Company
is not investing sufficiently in its marketing effort when compared to national averages." Please
provide any and all work papers, data, or other information used to:
a. Establish national averages of marketing being 4 to 8 percent of demand-side
management ('DSM") budgets; and
b. Determine the sufficiency of Idaho Power's investment in marketing
STAFF RESPONSE NO. 2:
a. Please see the 2013 DSM Residential Marcom Plan in the Company's response to Staff
production request 15. "Meanwhile, the majority of marketing budgets typically account for 4 to
8 percent of overall portfolio costs." (page 3.)
b. Please see page 8 - 9 of Staff comments that address the HANSA GCR Non-Participant
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO
POWER 2 AUGUST 26,20T4
Survey results, and the marketing and outreach analysis completed by TRC Energy Services and
Opinion Dynamics.
REQUEST NO 3: On page 7 of Staffs Comments, Staff includes a graph entitled
"Annual Percentage Change in Energy Efficiency Savings."
a. Please provide any and all work papers, data, and other information, including Excel
spreadsheets with formulas intact, used to create the graph.
b. For each year illustrated on the graph, please provide the DSM annual reports from
Avista Corporation and Rocky Mountain Power.
c. Not including custom programs and measures, please provide the savings assumptions,
sources, and source dates used to determine each utility's annual energy savings as required by
the Memorandum of Understanding entered into by Idaho utilities and Staff.
d. If the savings assumptions in subsection c are not sourced from public documents (i.e.,
Regional Technical Forum measure workbooks), please provide the savings source
documentation.
STAFF RESPONSE NO.3:
a. Please see the Excel spreadsheet included on the enclosed CD.
b. Please see attachments for the Avista and Rocky Mountain Power DSM Annual
Reports for 2009, 2010,2011,2012 and 2013 included on the enclosed CD.
c. In addition to the annual reports provided, please see Case No. AVU-E-13-09 for
Avista's supporting documents for 2010, 2011 and 2012. Due to the large nature of Avista's
filing, hardcopies are available at the IPUC offrce.
Please see Case No. PAC-E-14-07 for RMP's DSM savings for 2010-2013. Due to the
large nature of Rocky Mountain Power's filing, paper copies are available at the IPUC office.
d. Please see Staff response to 3C.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO
POWER AUGUST 26,2014
REOUEST NO 4: On page l0 of Staffs Comments, Staff states that "many utilities
have found that customers in aggregate reduce their energy consumption between I to 3 percent."
Please provide any and all research, work papers, data, or other information supporting this
statement.
STAFF RESPONSE NO. 4: Please see the following reports provided on the enclosed
CD:
Rocky Mountain Power, Utah Home Energy Reporting Program: l8 Month
Evaluation Report (8lll20l2 - ll3ll20l4). Navigant Consulting, June 18,2014.
Seattle City Light Home Electricity Report Program (January 20120 -2013),
2013 Impact Evaluation. DNV-GL, July 2014.
o Puget Sound Energy Home Energy Report Program, 2013lmpact Evaluation.
DNV-GL, April2}l4.
Impact and Persistence Evaluation Report, Sacramento Municipal Utility Report,
Home Energy Report Program 2008-2011. Integral Analytics, November 2012.
Program Year 2 (2012-2013) EM&V Report for the Residential Energy
Efficiency Benchmarking Program. Presented to Duke Energy Process by
Navigant, January 27, 2014.
o Evaluation of Pacific Gas and Electric Company's Home Energy Report Initiative
for the 2010-2012 Program. Freeman, Sullivan, & Co., April25, 2013.
REQUEST NO 5: On page 11 of Staffs Comments, Staff states that "Depending on the
characteristics of the measures acquired, customers could have saved approximately $474,000 to
$2,164,000 in 2013 if Idaho Power had met its IRP targets." Please provide any and all work
papers, data, and other information, including Excel spreadsheets with formulas intact,
supporting this calculation.
STAFF RESPONSE NO. 5: Please see Staff s workpapers provided on the enclosed
CD.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO
POWER AUGUST 26,2014
REQUEST NO 6: On page l2 of Staffs Comments, Staff states that "the opportunity
cost of the Company not achieving the full economic potential identified in the CPA could have
saved customers anywhere from $2,235,156 to $10,212,708 in 2073.' Please provide any and all
work papers, data, and other information, including Excel spreadsheets with formulas intact,
supporting this calculation.
STAFF RESPONSE NO. 6: Please see Staff s workpapers provided on the enclosed
CD.
DATED at Boise, Idaho, thk lby day of August 2014.
Neil Price
Deputy Attomey General
Technical Staff: Stacey Donohue
Nikki Karpavich
Matt Elam
i:umisc/ipcel4.4 Staff l*' Response to Idaho Power.doc
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO
POWER AUGUST 26,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29th DAY OF ruLY 2014, SERVED
THE FOREGOING COMMISSION STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO POWER, N CASE NO. rpC-E-14-04, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH ST
BOISE ID 83702
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
DARLENE NEMNICH
TAMI WHITE
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
twhite @.idahopower. com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE