20141217IPC to Staff 1-11.pdf

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LISA D. NORDSTROM
Lead Counsel
I nordstrom@idahopower. com
Decembet 17,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-38
NEEAAgreement tor2015-2019 - ldaho Power Company's Response to the
First Production Request of the Commission Staff
Dear Ms. Jewell:
Enclosed forfiling in the above matter please find 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.
AIso enclosed are four (4) copies of a non-confidential disk containing the
attachments.
Very truly yours,
Xr-Q4q^JJ*N
Lisa D. Nordstrom "
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom @ida hopower. co m
Attorney for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO FUND ITS CONTINUED
PARTICIPATION IN THE NORTHWEST
ENERGY EFFICIENCY ALLIANCE
THROUGH THE ENERGY EFFICIENCY
RIDER.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. |PC-E-14-38
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compa[y"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated December 3,2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 1: Please provide the number of lndustrial Technical Training
classes NEEA offered in Idaho for each year from 2010-2014. Please provide the topic,
the number of participants, and the cost to deliver the trainings and webinars in ldaho
Poweds service territory.
RESPONSE TO REQUEST NO. 1: Please see the Excel file provided on the CD
containing a spreadsheet provided by the Northwest Energy Efficiency Alliance
('NEEA'). Please note that NEEA does not have historic labor costs by program, so the
NEEA loaded costs are estimated using an allocation factor. Ecova is NEEA's
contractor that delivers the NW Regional lndustrial Training Program. The $841,648
includes the Cost Share amount that ldaho Power paid directly to Ecova but does not
include the $145,010 attendee subsidy that Idaho Power paid directly to Ecova. The
total cost to deliver the trainings with the attendee fee subsidy was $986,658. The
attachment provides the training topics, the number of participants, and the cost to
deliver the trainings and webinars in ldaho Power's service territory for each year from
2010-2014. Please note that the last training for 2014 is an estimate pending receipt of
materials.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 2: Please provide the Company's forecasted number of
lndustrial Technical Trainings that it will offer in ldaho for each year from 2015-2019.
Please provide the topic, the estimated number of participants, and the estimated cost
to deliver the trainings and/or webinars.
RESPONSE TO REQUEST NO. 2: The Company's lndustrial Training for 2015
and beyond is under development. Idaho Power anticipates providing approximately
the same number of in-class trainings per year as have been provided in the past. The
topics will vary from year-to-year and will include key industrial energy efficiency best
practice concepts to support industrial energy efficiency programs. The Company will
not limit the number of seats per training as was done in the past (NEEAs trainings were
limited to 25 seats). ldaho Power also has links to the supporting documents and the
recorded versions of the webinars that it funded in the past on the ldaho Power web site
for customers to view at their convenience.
The cost estimate for ldaho Power to deliver the trainings can be found on pages
3-4 of Attachment 3 to the Company's Response to Staffs Request No. 9, NEEA Tech
Training Options.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, 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: Why does the Company believe that "it remains unclear if
ldaho customers will utilize the deep energy retrofit tool that is under development as a
direct result of NEEA's prior EBR initiative"? (Kline Direct Testimony, p. 9).
RESPONSE TO REQUEST NO. 3: During NEEA's development of the deep
retrofit tool there was only one ldaho Power participant. The participant's main driver
was not energy efficiency but rather a complex situation dependant on many factors
(budget, tenant leasing dates, equipment !ife, code upgrades). NEEA's desire was to
develop a "canned" approach for existing building renovations. !t has become apparent
through the development that each tenanUowner will have their own challenges and will
need a customized approach to achieve energy savings. ldaho Power is not aware of a
completed tool and there is no evidence that a tool will bring value to this market sector.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO. 4: Does the Company plan to replicate NEEA's Kilowatt
Crackdown event? If not, please explain why not.
RESPONSE TO REQUEST NO. 4: ldaho Power is sti!! waiting for the results
from the Kilowatt Crackdown event. NEEA estimated that five percent savings would be
realized in the first year of the Kilowatt Crackdown, but the Company has not seen
those results. If the Company were to consider another Kilowatt Crackdown
competition or a similar event, it would want to (1) analyze the final savings results from
the previous competition and (2) determine how to appea! to smaller office spaces that
better fit the Boise market.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, 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 is not funding the
"Associated Administrative Expenses" (Attachment 3, p. 13).
RESPONSE TO REQUEST NO. 5: The Company is not funding the referenced
expenses because they pertain to administrative support for the optional programs that
Idaho Power is not funding. ln NEEA's 2015-2019 Business Plan, the "Associated
Administrative Expenses" associated with optional programs are not included in the
funding amount for each program, but rather are combined with other miscellaneous
expenses and identified as "othe/' in the Business Plan Appendix 3.4 (please see
Attachmenl2 of the Application). However, NEEA's 2015-2019 Business Plan states on
page 35, .NEEA will allocate a proportionate share of business administrative overhead
for those programs funded by the participating subset of NEEA funders" of which ldaho
Power is a member.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, 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: For the 2015-2019 Business Plan time period, please provide
the Company's total estimated marketing expenditures as a result of opting out of
NEEA's Marketing and Stakeholder Support option. Please also break out expenses by
category (including but not limited to internal labor and external labor) and include a
brief description of the marketing materials.
RESPONSE TO REQUEST NO. 6: Currently, the only three NEEA
initiatives/programs with optional marketing components are Heat Pump Water Heaters,
Ductless Heat Pumps, and Residential New Construction/Next Step Homes (currently
ENERGY STAR@ Homes).
The Ductless Heat Pump Pilot and ENERGY STAR@ Homes programs are
included in ldaho Powe/s energy efficiency program portfolio. The Heat Pump Water
Heaters ('HPWH') initiative is not included in Idaho Powe/s programs; as a result, the
Company will not be marketing this initiative in the near-term. ldaho Power is
continuing to monitor the HPWH technology for cost-effectiveness and applicability in its
service area.
Marketing plans for ldaho Powe/s Ductless Heat Pump Pilot and ENERGY
STAR@ Homes programs are provided in Attachments 1 and 2 of the Company's
response to Staff Request No. 7. These plans include a description of marketing
materials and an estimation of labor expenses. The total 2015 marketing budget for the
Ductless Heat Pump Pilot program and the ENERGY STAR@ Homes program is
$56,000 and $37,000, respectively. The marketing expenditures for these programs
were not impacted by opting out of NEEA's specific market transformation activities.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
The marketing plans beyond 2015 have not yet been developed. ldaho Powe/s
marketing plans are developed on a cunent year basis. Success metrics of previous
marketing activities are always considered when planning for future marketing plan
tactics.
ldaho Power has requested NEEA's 2015 marketing plans for the Ductless Heat
Pumps and Residentia! New Construction; however, they have not yet been completed.
Typically NEEA's marketing plans are completed in February or March.
The response to this Request is sponsored by Bill Shawver, Corporate
Communication Director, 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 Company's marketing plans which include
NEEA-funded programs. Please distinguish the NEEA marketing efforts from the
Company's local programs.
RESPONSE TO REQUEST NO. 7: Please see Attachments 1 and 2 for ldaho
Poweds marketing plans for the Ductless Heat Pump program and ENERGY STAR@
Homes. ldaho Power requested NEEA's marketing plans on December 8, 2014, and
was informed that they were not yet completed; consequently, ldaho Power cannot
distinguish NEEA's marketing efforts for these programs from those of ldaho Power.
The response to this Request is sponsored by Bill Shawver, Corporate
Communication Director, 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: Page 12 of Mr. Kline's Direct Testimony states that "ldaho
Powe/s media purchase rates are often lower than the nonprofit rates that NEEA can
obtain." Under what circumstances are the Company's media purchase rates lower
than nonprofit rates?
RESPONSE TO REQUEST NO. 8: Idaho Power has contracts with daily papers
across its service area. Contract rates are based on historic annual spend or the
number of ads placed per year. Because the Company contracts for all advertising
including energy efficiency, rates are typically lower than rates offered to organizations
with less advertising volume. ldaho Powe/s 2013 advertising contract with the ldaho
Statesman provided for rates lower than those available to nonprofit organizations.
ldaho Poweds media buyer/contractor, Media Partners, has informed the
Company that radio stations do not typically offer special nonprofit rates and special
rates may only apply to spots offered during undesirable times when the number of
listeners is much lower. They also informed the Company that television stations also
do not typically offer a lower rate to nonprofits.
The response to this Request is sponsored by Bill Shawver, Corporate
Communication Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1O
REQUEST NO. 9: PIease provide the PowerPoint presentation used for the Apri!
24,2014 EEAG conference call.
RESPONSE TO REQUEST NO. 9: Please see Attachments 1-3 for the three
presentations from the April 24,2014, webinar.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST NO. 10: During the 2010-2014 Business Plan, what percentage of
NEEA's total regional savings was allocated to Idaho Power?
RESPONSE TO REQUEST NO. 10: According to the NEEA 2010-2014
Business Plan, 7.3 percent of the total regional savings will be allocated to Idaho Power.
This is a weighted average that includes savings from before 2010, as well as 2010-
2013.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
REQUEST NO. 11: Please provide the 201 5-2019 forecasted energy savings for
ldaho Power. Please indicate which initiatives are likely to generate the majority of
energy savings.
RESPONSE TO REQUEST NO. 11: According to NEEA, ldaho Power will
receive 8.11 average megawatts of energy savings during 2015-2019. NEEA forecasts
that the largest energy savings will be contributed from Efficient Homes, Reduced
Wattage Lamp Replacement, Heat Pump Water Heaters, Commercial Codes, Ductless
Heat Pumps, and Televisions.
The top initiatives with percentages expected of total savings forecast:
(1) Efficient Homes (23 percent, i.e., residential codes)
(2) Ductless Heat Pumps (11 percent)
(3) Televisions (10 percent, mostly in 2015)
(4\ Heat Pump Water Heaters (9 percent)
(5) Commercial Codes (9 percent)
(6) Reduced Wattage Lamp Replacement (7 percent)
It should be noted that the savings forecasts are based on information as of the
third quarter of 2014 and include initiatives in pilot phase. NEEA updates its forecasts
as new information becomes available.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, Idaho Power Company.
DATED at Boise, ldaho, this 17th day of December 2014.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. 13
D. NORDS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of December 2014 ! 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:
Commission Staff
Daphne Huang
Deputy Attomey General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
X Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14