20190607IPC to Staff 1-27.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
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RECEIVED
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iDfiHO PUBLICITI!-ITIES COMMISSION
June 7, 2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Case No. IPC-E-19-11
2018 Demand-Side Management Expenses - ldaho Power Company's
Response to the First Production Request of the Commission Staff
Dear Ms. Hanian
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.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing information responsive to Staffs production requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
Very tru ly yours,
Lisa D. Nordstrom
LDN:kkt
Enclosures
P.O. Box 70 (83707)
1221 W. ldaho St.
Boise, lD 83702
Re
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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 @ id ahopowe r. com
REC EIVED
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}TILITIES COM*{ISSION
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERM!NATION OF 2018 DEMAND-
SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED
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CASE NO. IPC-E-19-11
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated May 17,2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 1: Please provide the cost-effectiveness workpapers and
calculations for each demand-side management DSM program in 2018 in Excel format,
with all formulas intact.
RESPONSE TO REQUEST NO. 1: Please see the attachment on the enclosed
non-confidential CD.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 2: Please provide a!! electronic workpapers, with links intact and
formulae enabled, supporting the tables on pages 14 through 57 of the Company's DSM
2018 Annual Report, Supplement 1.
RESPONSE TO REQUEST NO. 2:For the program cost-effectiveness tables,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
please see the attachment to the Company's response to Staff's Request No. 1 on the
enclosed non-confidential CD. For the measure cost-effectiveness tables, please see
the attachment to this response on the non-confidential CD.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
REQUEST NO. 3: Please provide the revenue received (excluding interest) by
class and tariff schedule for the DSM tariff rider in 2018.
RESPONSE TO REQUEST NO. 3: The table below contains the 2018 ldaho
Power Energy Efficiency Rider funding by rate class
2018
Rate Class Tariff Schedule Rider Fundins
Residential
Commercial
lndustrial
lrrigation
Liqhtinq
01,03,05,06
07, 08, 09
19,26,29,30
24
15,40, 41,42
17,080,537
10,149,641
5,807,468
5,266,566
171,651
$
$
$
$
$
Total $ 38,475,863
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 - 4
REQUEST NO. 4:Please provide the calculation of the interest accrued to the
DSM tariff rider account.
RESPONSE TO REQUEST NO. 4: Please see the attachment on the enclosed
non-confidential CD. The Company calculates interest based on the average of the
beginning and ending balances for the month. lnterest is recorded on a one-month lag.
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 - 5
REQUEST NO. 5: Please explain why the Company's estimated kWh savings
decreased between 2017 and2018 (2018 DSM Annual Report, page 10).
RESPONSE TO REQUEST NO. 5: Please see the attachment on the enclosed
non-confidential CD for a side-by-side comparison of participants and kilowatt-hour
("kwh") savings by program, which references Appendix 3 of both the 2017 and 2018
DSM Annual Reports. The difference in reported savings between 2017 and 2018,
which includes the 2018 preliminary savings from the Northwest Energy Efficiency
Alliance, is 8,093,561 kwh which represents an overall 4.2 percent decrease. The
residential Energy Efficient Lighting program (one of two areas of the "Simple Steps,
Smart SavingsrM" program) had the largest reduction in savings between 2017 and
2018 with a decrease of 18,908,257 kwh. This reduction in savings is somewhat offset
by the increase in savings in the Commercial and Industrial ("C&1")sector at 10,334,022
kwh.
The decline in savings for the Energy Efficient Lighting program is described in
ldaho Power's Demand-Side Management 2018 Annual Report, pages 53-54, noting
that between 2017 and 2018, bulb sales declined nearly 24 percent while savings
declined nearly 50 percent.
In January 2017, the Regional Technical Forum ("RTF') updated and revisited
the assumptions for light-emitting diodes ("LED") to account for market changes due to
the federal standards compliance. Because LEDs are becoming a larger share of the
market, the RTF updated the current market baseline for lightbulbs to incorporate this
change. Due to the timing of the RTF's update, Bonneville Power Administration and
CLEAResult Consulting, lnc. implemented the new savings in 2018 in the Simple Steps,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
Smart SavingsrM promotion. The RTF LED workbook version 5.2 was the source of
most Iighting savings assumptions throughout ldaho Power's residential program
offerings.
The annual savings for the most popular bulb type, the general-purpose lightbulb
in the 250-1049 lumen range, decreased from 13 kwh to 10 kwh. This bulb type made
up 53 percent of the total bulbs sold in the program and nearly 40 percent of the total
savings. With the change in per-bulb savings and sales declining just over 15 percent,
the total savings for this bulb type declined by nearly 3 million kWh between 2017 and
2018.
The second most popular bulb type is a reflector lightbulb in the 250-1049 lumen
range which is commonly used in recessed canned light fixtures. The RTF reduced the
per-bulb savings for this bulb type from 37 kWh to 24 kwh. These reflector bulbs made
up just over 19 percent of the total lightbulbs sold in the program and nearly 30 percent
of the total savings. ln 2018, the 250-1049 lumen reflector lightbulb sales declined 50
percent compared to 2017. With the decline in both sales and deemed savings, the
total savings for this bulb type declined over 13 million kWh between 2017 and 2018.
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 - 7
REQUEST NO. 6: Please provide the hourly rate billed and total amount paid to
Thomas Eckman for his testimony in this current case. Provide documentation for any
contracts, payments, and the accounts to which payments were charged.
RESPONSE TO REQUEST NO. 6: Please see confidential Attachments 1 - 3
on the enclosed confidential CD. The confidential CD will only be provided to those
parties that have executed the Protective Agreement in this matter.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. S
REQUEST NO. 7: Please provide a list of market transformation and marketing
activities offered by NEEA that ldaho Power has opted out of for all or part of its service
territory.
a. For these activities, please provide a side-by-side comparison of NEEA
marketing activities and those conducted by the Company.
b. Please provide financial comparisons of these activities. Where
applicable, please identify whether, and how much funding was refunded from NEEA to
the Company to conduct these marketing activities.
RESPONSE TO EOUEST NO. 7:
a. ln 2018, Idaho Power opted out of the following activities and completed
the following marketing activities. For further details, please see ldaho Power's
Demand-Side Management 2018 Annual Report, pages 62-64 and 153-154.
Heat Pum Water Heaters
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
ldaho PowerNorthwest Energy Efficiency Al !iance
("NEEA")
NEEA developed and deployed a paid
media campaign to raise awareness of
HPWHs among our target audience.
Creative will run in YouTube, HGTV, and
DIY Network on cable and via an ad
network. ldaho Power was excluded,
when possible.
When ldaho Power launched the Heat
Pump Water Heater incentive, the
Company launched a new webpage on
the incentive, sent a News Briefs article to
media, did social media posts and a yeal
long search engine marketing campaign,
and developed a pull-up banner
showcasing a full-size HPWH for trade
shows.
Postcards were mailed in February and
August that promoted all Heating &
Cooling measures, including HPWHS. A
letter was sent in June to 267 wholesalers
and plumbers with information on the
incentive. ln July, 100 letters were sent
with tech sheets to retailers.
Developed point-of-purchase materials
that include utility rebate information and
distributed them to regional Lowe's and
Home Depot locations.
I lr ttl I
NEEA ldaho Power
Decals promoting HPWHs were included in
Energy-Saving Kits for customers with
electric water heat, beginning in February.
A bill insert was sent in April and
September with a HPWH call-out.
A testimonialfrom the first HPWH recipient
was the cover story of the April issue of
Connections.
Facebook ads highlighting HPWH and/or
the Heating & Cooling program as a whole
ran in February, March, and July. Digital
ads ran in February, July, and Auqust.
HPWH were mentioned in a television
segment in the first quarter of 2018.
NEEA ldaho Power
NEEA created a marketing toolkit to
support utilities and distributors in
promoting LLLCs that ldaho Power did
not receive access to due to the opt-out.
ldaho Power provided customer training on
advanced lighting controls on February 27
and March 1.
the ldaho Power rolled out a networked
lighting control incentive on August 15,
2018.
Luminaire Level hti Controls ..LLLC"
b. As found in ldaho Power's Application in IPC-E-14-38, page 9,
(http://www.puc.idaho.sovffileroom/cases/elec/lPC/lPCE1438/20141029APPLlCATlON.
PDF) for the contract with NEEA for the 2015-2019 funding cycle, the Company
reduced funding in the amount of $794,388 over the five-year funding cycle associated
with marketing activities and an addition $119,126 in associated administration
expenses for all the optional programs the Company opted out of. ldaho Power has no
knowledge of NEEA's spending on their marketing activities; consequently the
Company does not have financial comparisons for these activities.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 1O
REQUEST NO. 8: Please provide copies of all print, web, television, and radio
ads and/or content used to market the Company's energy efficiency programs in ldaho.
ln addition, please include the Energy Efficiency Winter Guide mentioned on page 160
of the DSM 2018 Annua! Report. Please provide any ads or content created for socia!
media platforms that differ from materials supplied above.
RESPONSE TO REQUEST NO. 8: Please see the attachments on the enclosed
non-confidential CD. Because Linkedln only allows individuals or companies to pull
posts and analytics from the previous year, the Company is unable to pull screenshots
from any posts that took place prior to May 24,2018. The Energy Efficiency Winter
Guide is included in the Residential Education subfolder of the Residential Programs
Marketing Materialfolder on the non-confidential CD.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
REQUEST NO. 9: Please provide the amount budgeted and spent for the DSM-
related marketing campaign for 2018. Please provide documentation supporting the
amount spent, including invoice copies and proof of payment.
RESPONSE TO REQUEST NO. 9: Please see the confidential attachments on
the enclosed confidential CD for documentation supporting the amount spent. On a
May 24, 2019, phone conversation between ldaho Power and ldaho Public Utilities
Commission Staff, ldaho Power agreed to provide invoice copies to fulfill the request.
Due to the volume of files being provided in response to this Request, the individual file
names and the actual documents have not been labeled with the word "confidential."
However, the file folders have been labeled confidential; all files provided on the
confidential disk in response to this Request should be treated as confidential and
handled accordingly. The confidential CD will only be provided to those parties that
have executed the Protective Agreement in this matter.
The amount budgeted for the 2018 Residential Energy Efficiency Awareness
Campaign in ldaho was $1,041,883 and the amount spent on the 2018 Residential
Energy Efficiency Awareness Campaign in ldaho was $807,918.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 12
REQUEST NO. 10: Please provide copies of all bill inserts referencing energy
efficiency in ldaho that were sent out with customer bills during 2018.
RESPONSE TO REQUEST NO. 10: Please see the attachments on the
enclosed non-confidential CD.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
REQUEST NO. 11: Please provide 2018 website analytics information for each
DSM program or measure website and include the following information, if available:
a. Number of visitors (page views)
b. Number of unique visitors
c. Session duration
d. Source of incoming traffic
e. lnteractions while on site (For example, on your Heat Pump Water Heater
website, are they downloading the incentive application or looking at the qualified
products list?)
f. Exit pages (Are users exiting to other ldaho Power pages or returning
back to search engines?)
RESPONSE TO REQUEST NO. 11l. Please see the attachments on the
enclosed non-confidential CD. The Company does not currently have tracking
mechanisms in place for item e (interactions on website).
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
REQUEST NO. 12: On page 119 of the DSM 2018 Annual Report, the Company
states that the evaluator recommended changing program design of the Commercial
and lndustrial (C&l) Energy Efficiency Program so that the program intervened at a
different level in the market. The Company explained that an upstream or midstream
model "is an entirely different program approach that would be considered if the current
approach proved inadequate."
a. Please provide the citation for this recommendation.
b. Please explain how the Company defines "inadequate" in this context.
c. Please explain what prevents ldaho Power from developing parallel
programs for C&l with interventions at the upstream (manufacturer) or midstream
(distributor or installer level).
RESPONSE TO REQUEST NO. 12:
a. The recommendation was included in the ldaho Power Commercial and
lndustial Energy Efficiency Program Evaluation, DNV-GL, page 20, provided in Idaho
Power's Demand-Side Management 2017 Annual Report, Supplement 2, on pdf page
317: https://docs.idahopower.com/pdfs/EnerqyEfficiency/Reports/2017Supplement2.pdf.
Consider moving some measures to an upstream or
midstream incentive mode!. As programs mature, they
tend to evolve from custom models to deemed models to
upstream models. Measures with deemed savings are the
best candidates for upstream incentives, and lighting is
typically the first end use that moves upstream. Some
programs implemented by other utilities evaluated by DNV
GL have also recently moved HVAC (rooftop units) and
water heating measures (domestic and instant water
heaters) upstream. A n advantage of upstream programs is
administrative simplicity for the program. A disadvantage is
that upstream programs are less visible to participants,
which means that ldaho Power might not generate as much
customer satisfaction from them. Upstream programs are
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
also more difficult to evaluate. While some measures will
eventually be able to move upstream, some measures and
projects will always require a custom approach.
b. Should the existing C&l Energy Efficiency Program prove unsuccessful in
achieving expected energy savings results, ldaho Power may consider the existing C&l
energy efficiency program results as inadequate. The program has the greatest kWh
savings of any program that ldaho Power operates, with the retrofits option being a
major part of the overall program savings.
c. The Company has found success in offering customers a full suite of
incentives within the Company's traditional downstream program. The Company
implements a thoughtful and regular review of the measures it incents, as evidenced by
the adding, removing, and/or modifying measures as needed to address cost-
effectiveness and market conditions.
ldaho Power has evaluated whether incorporating an upstream or midstream
incentive model would achieve incremental savings and after careful consideration, the
Company has elected not to pursue such a course. The C&l energy efficiency program
implementing an upstream/midstream incentive will result in certain products being
removed from the downstream program to support the upstream/midstream program,
shifting energy savings between the downstream and upstream/midstream programs.
An additional consideration is that savings determinations from upstream or midstream
models are less certain as the specifics of what equipment is being replaced is
unknown.
Additionally, ldaho Power has inquired of and received feedback from other
utilities that it is difficult to keep the same product in multiple incentive models. Idaho
Power also has direct experience managing customer and trade ally expectations on
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 16
receiving incentives from participation in the regional Simple Steps, Smart SavingsrM
(residential lighting program) buy-down offer. For example, commercial customers have
purchased lighting from retailers under the Simple Steps, Smart SavingsrM buy-down
program, then also expect to receive an incentive from the retrofits program. These
situations have been challenging for ldaho Power and somewhat confusing for
customers. But the Company will remain open to discuss different program delivery
methods with the Energy Efficiency Advisory Group if the existing program does not
achieve expected energy savings results.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 17
REQUEST NO. 13: Were the savings values for the Home Energy Reports
weather-normalized? Please explain.
RESPONSE TO REQUEST NO. 13: No. Because the home energy report pilot
is a randomized control trial ("RCT"), there is no need to weather normalize data
because both control group and program participants were randomly selected from a
similar stratification of customers. The RCT pre-screening and assignment process
ensures that Contro! and Treatment customers experience similar weather. The
stratifications were created after pre-screening customers by home vintage and size,
heating fuel usage and air conditioning usage, geography, and overall energy use
patterns.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 18
REQUEST NO. 14: For the Green Motors lnitiative described on page 145 of the
Company's DSM 2018 Annual Report, please provide the following information:
a. Workpapers and calculations showing how the kWh savings values in
Table 24 were determined.
b. Criteria used to determine whether or not a particular motor qualifies for
an incentive under the Green Motors lnitiative.
c. Workpapers and calculations showing how the Annual Gross Energy
Savings, NPV DSM Avoided Costs, and Gross lncremental Participant costs on page 39
of the Company's DSM 2018 Annual Report, Supplement 1 were determined.
RESPONSE TO REQUEST NO. 14:
a. The savings for Table 24 on page 145 of the Company's Demand-Side
Management 2018 Annual Report may be found on the "Green Motors - lndustrial" and
"Green Motors - lrrigation" worksheets in the attachment provided in the Company's
response to Staff's Request No. 1.
b. The Company's Green Motors lnitiative program webpage includes a
horsepower range for eligible motors: https://www.idahopower com/ways-to-
save/savinqs-for-vour-business/additional-business-resources/qreen-motors-initiative/
The webpage also includes a link to the Green Motors lnitiative website which provides
a listing of participating service centers who verify motor condition for eligibility based on
the RTF standards: http://qreenmotors.orq/. The RTF "Green Motor Rewinds"
information regarding the measure can be found at the following website:
https://rtf. nwcouncil.oro/measure/qreen-motor-rewind.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 19
For the detailed electric motor repair specifications, please see the attachment
on the enclosed non-confidential CD.
c. As noted in Supplement 1: Cost-Effecfiveness at page 39, the RTF
workbook, lndGreenMotorRewind_v2_3.xlsm, was the source of all assumptions for the
industrial motor rewinds including Annual Gross Energy Savings and Gross lncremental
Participant costs. The workbook can be found at
https.//nwco u n ci l. box. com/s/d rd s2c 1 3 xTqtqs3h I 1 0e1 c7 7 agudvla.
As noted in Supp/ement 1: Cost-Effecfiveness at page 57, the RTF workbook,
AgGreenMotorRewind_v2_3.xlsm, was the source of all assumptions for the industrial
motor rewinds including Annual Gross Energy Savings and Gross lncremental
Participant costs. The workbook can be found at
https://nwcouncil. box.com/s/bbq2uqdfxv9slixducpTdutcbvSo3vey.
For the calculations of the NPV DSM Avoided Costs for each motor, please see
the "Summary" worksheet in the attachment provided in the Company's response to
Staff's Request No. 2.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 20
REQUES'I NQ.t!5: For the Ene rgy Savings Kits program, please explain why
the deemed savings per lamp is identical for 9 watt and 6 watt LED Light Bulbs (ldaho
Power Energy-Saving Kit Program Summary Report, Appendix A, page 24).
RESPONSE TO REQUEST NO. 15: As shown in the footnote in the ldaho
Power Energy-Saving Kit Program Summary Report, Appendix A, page 24, the savings
are based on the RTF's "by request general purpose and three-way bulbs," with the
250-1049 lumen range evaluated as a single group. Because the g-watt LEDs are 800
lumens and the 6-watt LEDs are 480 lumens, they have the same deemed savings per
lamp. Specifically, as shown in Demand-Srde Management 2018 Annual Repoft,
Supplement 1: Cost-Effecfiveness, page 15, these savings are from the
ResLighting v5. 2. xlsm workbook: https.//nwcou nci l. box. com/v/Res Liq htinqv5-2
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 21
REQUEST NO. 16: On page 17 of the ldaho Power Energy-Saving Kit Program
Summary Report, the Company states that 50% of all respondents reported installing all
I LED light bulbs. Please explain how this compares to the installation rate used to
develop the 8.20 kWh Regional Technical Forum (RTF) value shown on Appendix A,
page 24.
RESPONSE TO REQUEST NO. 16: The RTF does not use installation rate for
"by-request LEDs bulb"; rather the RTF assumes an initial 24 percent storage rate for
these types of bulbs; the RTF assumes that bulbs in storage will be installed within four
years. Please reference the "by-request bulbs" as shown in the
Lamps_StorageRemoval tab of the Reslighting_v5.2.xlsm workbook at
https ://nwcou nci L box. com/v/Res Liq hti nqv5-2.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.22
REQUEST NO. {7: On page 1 of its Shade Tree Evaluation Report, DNV GL
reports a mortality rate of 360/o at 3-5 years since planting. What steps is the Company
taking to improve the survival rate of trees planted under the Shade Tree Project?
RESPONSE TO REQUEST NO. 17: ldaho Power has taken several steps to
improve the survival rates of trees planted under the Shade Tree Project, including:
. Creation of a display used at Shade Tree pick-up events to demonstrate proper
staking techniques (implemented in 2015)
o Creation of a newsletter containing tree care tips that is sent to customers
approximately six to nine months after planting (implemented in 2015)
. lnitiation of a pre-event arborist briefing on common issues found during audits to
ensure arborists address these issues during planting demonstrations
(implemented in 2015)
. Creation of a video showing proper tree planting techniques (implemented in
2016)
o Allocation of tree species to specific counties based on predominant soil type.
Although all tree species had been selected by local arborists for all areas, it was
identified that some species may not do as well in the more alkaline soils outside
Ada County (implemented in 2017).
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 23
REQUEST NO. 18: On page 2 of its Shade Tree Evaluation Report, DNV-GL
provides a summary of non-electric impacts (Table 2). Were any of these values used
in the Company's Cost and Benefit calculations? lf so, please provide workpapers, with
links and formulae enabled, showing how these values were used.
RESPONSE TO REQUEST NO. 18: Yes. Please see the attachment on the
enclosed non-confidential CD.
This shade tree calculator model was provided to ldaho Power by DNV GL as
part of the Shade Tree evaluation. The non-electric impacts ('NEl") are calculated
under each of the following tabs: Therms, Air Pollution $, Carbon $, and Stormwater
Runoff $. The original model provided by DNV GL calculated savings and NEls through
2033. The values from 2034 through 2038 were extrapolated using the same formulas
that were used to calculate years 2017 through 2033. All values in green font are
additionalformulas added to the model by ldaho Power.
As noted on page 89 of ldaho Power's Demand-Side Management 2018 Annual
Report, the cost-effectiveness for the Shade Tree Project is based on the model savings
forthe trees distributed in2018 and the costs incurred in 2018. The values shown in
row 15 of each NEI tab are also shown on the Shade Tree Project tab in the attachment
provided in the Company's response to Staff's Request No. 1. As shown in the Shade
Tree Project tab, the net present value of the NEls were used in the cost and benefit
calculations.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 24
REQUEST NO. 19: The Com pany reported a cumulative energy (kwh) savings
of 1,560,005 kwh in its 2018 DSM Annual Report, Supplement 1, page 30. Please
answer the following:
a. Please explain how this value was determined and provide supporting
workpapers with all links and formulae enabled.
b. Was the 36% mortality rate reported by DNV GL used in the Company's
cumulative kWh savings?
RESPONSE TO REQUEST NO. 19:
a. Please see the attachments provided in the Company's response to
Staff's Request Nos. 1 and 18.
The 1,560,005 kWh is the cumulative savings at the generation level. This
number is grossed up from the site savings value of 1,422,065 kwh using the
transmission line loss percentages. ln general, customer site savings are reported
while cost-effectiveness is calculated at the generation level. This can be seen in the
Shade Tree Project tab of the attachment provided in the Company's response to Staff's
Request No. 1.
To determine the site savings of 1 ,422,065 kwh, ldaho Power used the shade
tree model provided by DNV GL. As shown on row 15 of the kWh Savings tab in the
attachment provided in the Company's response to Staff's Request No. 18, the
cumulative savings for the trees distributed in 2018 is 1 ,422,065 kwh.
b. Yes. The mortality rate is adjusted for each year. This can be seen in row
5 of the kWh Savings tab on the attachment provided in the Company's response to
Staff's Request No. 18.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 25
REQUEST NO.20: Table 1-1 (page 1-2) of Tetra Tech's 2017 Custom Projects
lmpact Evaluation Report shows that realization rates for custom pumps and
compressed air measures were 155.2% and 66.8%, respectively. What steps is ldaho
Power taking to improve the methods used to estimate the energy savings realized
through these programs?
RESPONSE TO REQUEST NO. 20:Although the Custom Projects lmpact
Evaluation Report shows variability in the realization rates, the overall realization rate
was 100.4 percent. For the pump measure, the evaluators sample came from two
separate projects. One project had a realization of 100 percent and the other a
realization of 162 percent which resulted in the weighted average of 155.2 percent. The
evaluator determined higher savings than ldaho Power on the one project because
ldaho Power utilized a more conservative estimate of operating hours. ldaho Power
had calculated savings under two operating scenarios: (1) using the same annual
operating hours as before, and (2) assuming the new pump would be used more
frequently than the other well pumps serving the facility due to its higher efficiency.
Given the uncertainty around the operation of the pump in the future, the Company
utilized the more conservative value of same annual operating hours for the savings
estimate. The evaluator had assumed the pump would be used more frequently.
For the compressed air measure, the evaluator's sample also came from two
separate projects. One project had a realization of 100 percent and the other a
realization of 36 percent which resulted in the weighted average of 66.8 percent. On
the second project, the evaluator determined lower savings than ldaho Power after
identifying there was an increase in air flow and resulting compressor load as compared
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 26
to the original measurement and verification ('M&V") completed a yeat earlier. ldaho
Power followed up with the customer to verify that compressor controls and set points
were set up and operating as intended. ldaho Power also followed up with the M&V
contractor to review the evaluation data file and verified the origina! M&V was
completed correctly but just at a lower system air flow level for the compressed air
system. The higher overall air-flow rates were the reason for the higher compressor
load and the reduced savings from when the original M&V was completed a year earlier.
After carefu! review of these projects and the evaluator's findings, ldaho Power
has determined the variance in realization rates was solely attributable to changes in
the customer's business operations from the time of M&V and the evaluation. !n light of
this, ldaho Power believes its current practice of M&V produces reasonable results and
at this time does not believe a change to the current method is warranted.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 27
REQUEST NO. 21: Table 3-13 (page 3-9) of Tetra Tech's 2017 Custom Projects
lmpact Evaluation Report shows that realization rates for projects 1690 and 1699 were
155.3o/o and 36.4%, respectively. What steps is ldaho Power taking to improve the
methods used to estimate energy savings realized through its Custom Streamlined
Process program?
RESPONSE TO REQUEST NO. 21: As noted in the response to Request No
20, while the impact evaluation report shows variability in the realization rates, the
overall realization rate was 100.4 percent. Since results from the evaluation were
received, Idaho Power has discussed these projects with its Custom Projects
streamlined contractor. Project 1690 was a variable frequency drive project on a feed
mixing and grinding process. The evaluator determined a significantly different use
profile for both the mixer and grinder than the original M&V which resulted in higher
savings than ldaho Power had estimated. The Company determined this was due to
changes in production operations at the customer's location.
Project 1699 was a fast-acting door project. The evaluator determined there
were a few installation issues - one that resulted in pass-by traffic tripping the motion
sensor which caused the door to open more than original estimates, reducing the
savings.
After careful review of these projects and the evaluator's findings, ldaho Power
has determined the variance in realization rates was solely attributable to changes in
the customer's business operations from the time of M&V and the evaluation, and one
instance of an inadequate installation. ln light of this, ldaho Power believes its current
practice of M&V produces reasonable results and at this time does not believe a change
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 28
in the current method is warranted. ln regard to the fast-acting doors, ldaho Power will
look for ways to commutate the potential installation issues when promoting fast-acting
doors to customers to better align business logistics with door operation.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 29
REQUEST NO.22: Section 1.3 (pages 1-1 through 1-4) of Tetra Tech's 2017
Custom Projects lmpact Evaluation Report makes a number of impact
recommendations, includ ing :
a. Consider including post-verification customer follow-up for control-based
projects.
b. Continue close communications with Wastewater Cohort contacts.
c. Use RTF method for New Construction Baseline
d. Use rated capacity and wattage for equipment.
e. Consider requiring a pump curve submission for pumping projects.
Please explain what, if any, steps ldaho Power is taking to implement each of the
above listed recommendations. For any of these recommendations that the Company
is not implementing, please explain why the Company is not implementing them.
RESPONSE TO REQUEST NO. 22:
a. Since results from the evaluation were received, ldaho Power has decided
to implement a "key to savings" included as part of the customer issued incentive check
letters and will make sure that the customers have a copy of the final M&V reports.
ldaho Power is also exploring ways these "key to savings" could be brought up in future
meetings with customers by ldaho Power Account Representatives.
b. The evaluators recommendation was to continue close communications
with Wastewater Cohort contacts. ldaho Power agrees with this recommendation and
will continue to emphasize communication with the Wastewater Cohort contacts in the
future.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 30
c. The evaluators recommendation refers to the RTF New Construction
baselines for compressors and may apply to other new construction project types. For
ldaho Power's Custom option on a new construction project, the Company develops a
baseline by consulting the customer and M&V contractor to determine the appropriate
baseline for a specific project. ldaho Power will adopt the evaluators recommendation
in cases where the RTF baselines are appropriate. The Company also considers the
baselines from ldaho Power's Technical Reference Manual ('TRM") and building code
when applicable.
d. After further review of this recommendation from the evaluator, it was
determined this recommendation stemmed from an HVAC and a lighting project. ldaho
Power uses rated capacity for HVAC equipment in savings calculations and the
evaluator determined the ldaho Power savings were overstated by 4 percent. After
review of this instance, ldaho Power determined the variance was due to an oversight in
calculating energy savings that the Company believes was an abnormality, and that a
change in review practices is not warranted.
With regards to lighting, the evaluator recommended using DesignLights
Consortium ("DLC") listed input wattage. ldaho Power has found the DLC database is
difficult and time consuming to use and has developed a more user-friendly approach
for trade allies, customers, and reviewers. The Company relies on input wattage listed
on manufacturer specification sheets, resulting in a more straightforward, consistent
process. While ldaho Power does not use the listed input wattage from the DLC
database, the Company does confirm wattage with the manufacturer if a large
discrepancy between the DLC wattage and the manufacturer specification sheets is
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 31
found during project review. For these reasons, ldaho Power believes its method
produces reasonable results and does not believe a change to its current practice is
warranted. The Company plans to continue with its current practices with respect to
using rated capacity and manufacturer-supplied wattage for equipment, however it will
continue to evaluate the reasonableness of discrepancies between the DLC wattage
and the manufacturer specification sheets.
e. ldaho Power uses pump curves as an input to calculate energy savings on
pumping projects. However, there are cases where the pump curve may be unavailable
due to customers or their vendor's missing records and the pump being inaccessible or
in a well. Since results from the evaluation were received, ldaho Power has instructed
its contractor for the Streamlined Custom projects to specifically provide pump curves
on all pump-related projects where possible. These were being submitted in most
cases prior but ldaho Power now specifically, requests them for all projects involving
pumps.
The response to this Request is sponsored by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 32
REQUEST NO. 23: Does ldaho Power include realization rates reported by its
evaluators when determining benefits of its individual programs? lf so, please explain
how these are applied. If not, please explain why these are not used.
RESPONSE TO REQUEST NO. 23 No. There are several reasons, but it is
primarily a timing issue because impact evaluations are typically conducted on savings
data from a completed year. For example, evaluations conducted in 2018 analyzed
2017 program data and were not complete until late in 2018, while ldaho Power
conducted its annual cost-effectiveness calculations in the first quarter of 2018. For
ldaho Power's Demand-Side Management 2018 Annual Repoft, the Company reported
and conducted cost-effective an analysis using 2018 saving data. For the 2018
evaluations, the realization rates were a result of 2017 program savings, so based on
2017 data.
lf a realization rate is the result of an issue for a program such as using an
incorrect RTF table, the Company corrects the issue as soon as possible and the
correction would apply to future cost-effectiveness calculations.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 33
REQUEST NO. 24: Does ldaho Power use realization rates reported by its
evaluators to identify improvement opportunities in its programs? lf so, please explain
how realization rates are used. lf not, please explain why realization rates are not used
to identify improvement opportunities.
RESPONSE TO REQUEST NO. 24: Yes. While program improvement
opportunities are generally a result of process evaluations, the Company works to
correct or modify the issue when realization rates identify a systemic issue in a
program's ex-ante estimated energy savings. Realization rates are used in impact
evaluations to determine the difference between reported savings and evaluated
savings. lf an impact evaluation indicates variances regarding reported savings, ldaho
Power requires the third-party evaluator to report these variances in terms of measure
realization rates and reasons for the variance, and provide recommendations for
improvement. ldaho Power then determines if the variance has already been adjusted,
and if not, acts to improve or eliminate these variances moving forward. For example,
the 2018 impact evaluation of the Multifamily Energy Savings Program found that Idaho
Power used the incorrect savings values from the 2016 potential study which resulted in
an overall realization rate of 84 percent, rather than the likely 100 percent realization
rate using correct savings values. The error was corrected for the 2018 program year
and is described on page 78 of the Company's Demand-Side Management 2018
Annual Report.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 34
REQUEST NO. 25: For each date during 2018 in which demand response
programs were used, please provide the date, the amount of load reduction (by
program), the system peak, and the daily load curves.
RESPONSE TO REQUEST NO. 25: The demand response load reduction for
each program by day can be found in ldaho Power's Demand-Side Management 2018
Annual Repoft, pages 37 , 132, and 143, and are shown below.
Table 8. A/C Cool Credit demand response event details
Event Details
Monday,
July 16
Wednesday
July 25
Tuesday
July 31
Monday,
August 6
Event time....
Average temperature
4-7 p.m
93'F
4-7 p.m.
98"F
4-7 p.m.
96'F
4-7 p.m.
89"F
Maximum load reduction (MW)29 27.3 zu 16.1 10.4
Table 20. Flex Peak Program demand response event details
Event Details Monday, July 16 Wednesday, July 25 Tuesday, July 31
Event time....
Average temperature
4-8 p.m
93"F
4-8 p.m.
98'F
4-8 p.m
96"F
Maximum load reduction (MW)27.2 21.8 32.9
f able22. lrrigation Peak Rewards demand response event details
Event Details Friday, July 13 Tuesday, July 17 Wednesday, August 1
Event time
Average temperature
2-9 p.m.
95"F
2-9 p.m.
94"F
2-9 p.m.
98'F
Maximum load reduction (MW)296.7 256.6 263.8
ln the process of preparing this response, a typographical error was found in the
A/C Cool Credit chart for Tuesday, July 31. The demand reduction was published as
27.3 megawatts ("MW') and should have been 16.1 MW. Please see the attachment on
the enclosed non-confidential CD for system peaks and daily load shapes.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 35
REQUEST NO. 26: Please provide the number of switches for the A/C Cool
Credit Program that the Company currently has in inventory. Additionally, please
provide the amount that is included in the Company's Energy Efficiency Tariff Rider
balance as of December 31,2018 for the A/C Cool Credit switches.
RESPONSE TO REQUEST NO. 26: The inventory of Advanced Metering
lnfrastructure ("AMl") switches utilized in both the A/C Cool Credit and lrrigation Peak
Rewards programs was approximately 2,295 as of May 2019.
The Company has not purchased any AMI switches since September 2012.
Because they were expensed (through the Energy Efficiency Rider tariff) in the year
they were purchased, there is no amount in the current 2018 DSM prudence request or
in the Energy Efficiency Rider tariff balance as of December 31 ,2018, associated with
the AMI switches.
The response to this Request is sponsored by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.36
REQUEST NO. 27: Please provide a copy of the ldaho Power Technical
Resource Manualthat was used for the Company's DSM 2018 Annual Report.
RESPONSE TO REQUEST NO. 27: PIease see the attachment on the enclosed
non-confidential CD.
A hyperlink to the Company's TRM may be found on page 283 of ldaho Power's
Demand-Side Management 2018 Annual Report, Supplement 2: Evaluation, or on the
Company's Energy Efficiency Program Reports website:
https://www.idahopower.com/wavs-to-save/energy-efficiencv-program-reports/.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 7th day of June 2019.
D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 37
I
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 7th day of June 20191 served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Matt Hunter
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 38
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berly T l, Executive Assistant