20200522IPC to Staff 6-12.pdf

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',,,! r.1 lit tl.4-. , tL! I'irli'r-JLISA D. NORDSTROM
Lead Counsel
[e-mail]
May 22,2O2O
ELECTRONIC FILING
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-20-15
2019 Demand-Side Management Expenses - ldaho Power Company's
Response to the Second Production Request of the Commission Staff
Dear Ms. Hanian:
Attached for electronic filing is ldaho Power Company's Response to the Second
Production Request of the Commission Staff. The attachments that respond to Production
Request 7 are too voluminous for e-mailtransmittal and instead will be made available to
the parties on the Company's discovery FTP site lf you have any questions about the
attached documents, please do not hesitate to contiact me.
Very truly yours,
AnD Oof,Pcompe'ry
X* !.Z(^l-t."*,
Lisa D. Nordstrom
LDN:sdh
Attachment
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom @ ida h opower. co m
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2018 DEMAND-
SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED
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CASE NO. IPC.E.2O.15
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company, and in response to the Second
Production Request of the Commission Staff to ldaho Power Company ("ldaho Powef
or "Company") dated May 1 ,2020, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 6: Please provide a list of market transformation and marketing
activities offered by NEEA that the Company has opted out of for all or part of its service
tenitory.
a. For those activities, please provide a side-by-side comparison of NEEA
marketing activities and those conducted by the Company.
b. Please provide a financial comparison of those activities. !f applicable,
please identify how much the Company was reimbursed from NEEA for those marketing
activities.
RESPONSE TO REQUEST NO. 6:
a. Below please find a side-by-side comparison of those NEEA-sponsored
marketing activities ldaho Power opted out of during 2019 and those activities
completed by ldaho Power. For further details, please see ldaho Power's
Demand-Side Management 2019 Annual Report, pages 135-142.
Luminaire Level htin Controls ,,
Heat Pum Water Heaters
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
ldaho PowerNEEA
ln 2019 there were no customer-facing
marketing activities that fel! under NEEA's
oot-out orovision.
Northwest Energy Efficiency Alliance
(..NEEA")
ldaho Power
A paid media campaign to raise
awareness of HPWHs that ran on
YouTube, HGTV and DIY networks on
cable TV.
ldaho Power promoted HPWHs as part of its
residential Heating and Cooling program.
NEEA deployed HPWH consumer
testimonial videos that were used on
NEEA's Hot Water Solutions site.
Target postcards were mailed in February that
promoted all Heating & Cooling measures,
includino HPWHS.
An email promotion was sent to residential
customers in July promoting all Heating and
Coolino measures. includino HPWHS.
Digitalads ran in February promoting the
Heatino and Coolinq prooram. and included a
HPWH call-out.
Social media posts throughout the year
featured heating/cooling related tips, with some
mentionino HPWHS.
A bill insert was sent to all residential
customers in April and September with a
HPWH call-out.
ln the Fall, content and image updates were
made to all heating and cooling webpages on
idahooower.com.
Ductless Heat Pu Ps
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF.3
Northwest Energy Efficiency Alliance
(..NEEA")
ldaho Power
ldaho Power promoted DHPs as part of its
residential Heatinq and Coolino Drooram.
Produced a buye/s guide and distributed
via owned and eamed channels.
Developed consumer-facing and installer-
facing materials intended to educate both
audiences on NEEA's soon-to-be-released
DHP Cold Climate and Recommended
Practices, including best practices for
sizing, installation, use and maintenance.
Postcards were mailed in February that
promoted all Heating & Cooling measures,
including DHPs.
DHPs were prominently featured in the
company's TV commercial in the Fall and
Spring. Ads ran on network TV and digital
platforms.
An email promotion was sent to residential
customers in July promoting all Heating and
Coolino Drooram measures. includinq DHPs.
Digitalads ran in February promoting the overall
Heating and Cooling program, including a DHP
call-out.
Social media posts throughout the year featured
heating/cooling related tips, with some
mentionino DHPs.
A bill insert was sent in April and September to
all residential customers with a DHP call-out.
An article on DHPs was featured in the Summer
EE quide.
ln the Fall, content and image updates to all
heating and cooling webpages on
idahooower.com.
b. As found in ldaho Power's Application in IPC-E-14-38,1 page 9, for the
contract with NEEA for the 2015-2019 funding cycle the Company reduced funding
over the five-year funding cycle in the amount of $794,388 associated with marketing
activities and an additional $119,126 in associated administration expenses for all the
optional programs for which the Company opted out. ldaho Power has no knowledge of
NEEA's spending on its marketing activities; consequently, the Company does not have
financia! comparisons for these activities.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, ldaho Power Company.
thttos://puc.idaho.eov/Fileroom/PublicFiles/ELEC/IPC/IPCEl438/CaseFiles/20l4l029Application.pdf
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF.4
REQUEST NO. 7: Please provide copies of all print, web, television, and radio
ads, and/or content used to market the Company's DSM programs in ldaho.
RESPONSE TO REQUEST NO. 7: Please see the attachments provided for this
response.
Because Linkedln only allows individuals or companies to pull posts from the
previous year, the Company is unable to pull screenshots from any posts that took
place prior to May 7,2019 but has provided a list of Linkedln posts for the period of
January 1,2019 through May 6, 2019.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
REQUEST NO. 8: Please provide the amounts budgeted and spent on DSM
marketing in 2019. Please identify which program each expenditure was billed to and
provide documentation to support the amount spent, including copies of invoices and
proof of payment.
RESPONSE TO REQUEST NO. 8: As part of discussions on May 6,2020, to
clarify Staffs request, Staff indicated that ldaho Power need not respond to this request.
The response to this Request is sponsored by Pau! Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 6
REQUEST NO. 9: Please provide the 2019 website analytics for each DSM
program or measure website and include the following information-to the extent such
analytics are available to the Company.
a. Number of page views;
b. Number of unique visitors;
c. Session duration;
d. Source of incoming traffic;
e. lnteractions while on the website (For example, are visitors using the
program
f. Exit pages (Are users exiting to other ldaho Power pages or returning
back to search engines or social media.)
RESPONSE TO REQUEST NO. 9: Please see the attachment provided for this
response.
The Company does not currently have tracking mechanisms in place for item e
(interactions on website).
Because ldaho Power updated the Uniform Resource Locator ('URL') for its
webpages during 2019, webpage results in the attachment may be listed under more
than one URL.
For item f (exit pages), if the webpage listed in the "Exit Page" and "Page"
columns match, the user exited ldaho Power's website from the same energy efficiency
webpage. lf "Exit Page" and "Page" do not match, the "Exit Page" column indicates the
last ldaho Power webpage the user visited before exiting idahopower.com.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 7
The response to this Request is sponsored by Quentin Nesbitt, Gustomer
Research and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 8
REQUEST NO. 10: Please provide the number of Advanced Metering
lnfrastructure ("AM!") switches for the A/C Cool Credit and lrrigation Peak Rewards
programs that the company has in inventory. Additionally, has the Company purchased
any AMI switches for these programs since December 31,2018?
RESPONSE TO REQUEST NO. 10: The inventory of Advanced Metering
lnfrastructure ("AMl") switches utilized in both the A/C Cool Credit and lrrigation Peak
Rewards programs was approximately 2,446 as of May 2020.
The Company has not purchased any AM! switches since September 2012.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
REQUEST NO. 11: Please provide a copy of the Technical Resource Manual
that was used for the Company's 2019 DSM report.
RESPONSE TO REQUEST NO. 11: Please see the attiachment provided forthis
response.
A hyperlink to the Company's Technical Reference Manual ('TRM") may be
found on the Company's Energy Efficiency Program Reports website:
https://www.idahopower.com/enerqy-environmenUwavs-to-save/enerqv-efficiencv-
prooram-reports/
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF.lO
REQUEST NO. 12: Please provide the following for the Weatherization
Assistance for Qualified Customers program:
a. The incentives or expenses paid for each measure type;
b. The potential savings for each measure in the energy audit tool, such as
EA5 or EA6, used for cost-effectiveness screenings; and
c. The cost effectiveness analysis, based on @nsumption datia, showing the
Annual Gross Savings by measure type.
RESPONSE TO REQUEST NO. 12:
a. The number of measures installed and the production costs of those
measures may be found in Table 12, WAQC summary of measures installed
in 2019 on pages 84-85 of ldaho Powefs Demand-Side Management 2019
Annual Report.2 Production costs are defined as the direct costs paid by
ldaho Power to fund audits, energy efficiency measures, and health and
safety measures.
b. The Company does not use measure-level potential savings for cost-
effectiveness screenings. The ldaho Department of Health and Welfare uses
the Department of Energy approved energy audit program (EA5) for the ldaho
Weatherization Assistance Program and, therefore, the ldaho Community
Action Partnership ('CAP") agencies use the EAS. ldaho Power receives
output data from the EA5 files for each job ldaho Power helps fund with post-
calculation home-specific savings, but does not have access to the CAP
agency EA5 tool.
2 https://docs.idahopower.com/pdfs/EnereyEfficiency/Reportsi20l9DSM.pdf
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
c. Please see ldaho Powe/s response to Staff Request No. 1 for the Company's
cost-effectiveness workpapers showing the calculation for the WAQC
program. ldaho Power does not use measure level savings data for cost-
effectiveness calculations; in 2019 the Company used average whole house
consumption information from pre and post weatherization billing analysis.
The Company describes the cost-effectiveness methodology for the WAQC
program and shows the results on pages 7 and 32 of ldaho Powefs Demand-
Side Management 2019 Annual Report: Supplement 1, Cost Effectiveness.3
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader ldaho Power Company.
DATED at Boise, Idaho, this 22nd day of May 2020.
X*!.(,,1-t"-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
3 https://docs.idahopower.com/pdfs/EnergyEfficiency/Reports/20l gSupplement l.pdf
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF. 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of May 2020 I served a true and conect
copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Dayn Hardie
Deputy Attomey General
ldaho Public Utilities Commission
1 1331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
ldaho Conseryation League
Benjamin J. Otto
ldaho Conservation League
710 North 6h Street
Boise, ldaho 83702
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Gity of Boise
Abigail R. Germaine
Deputy City Attomey
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701 -0500
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A*)-z/4r"_
Sandra D. Holmes
Legal Adm inistrative Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14