20201019IPC to ICIP 9-12.pdf

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LISA D. NORDSTROIII
Load Couneel
lnorddnomOldehoo*rr.com
October 19,2020
VIA ELEGTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-20-33
ln the Matter of the Application of ldaho Power Company for Authority to
Revise the Energy Efiiciency Rider, Tarifr Schedule 91
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 34602, is ldaho Power
Company's Responses to the Second Production Request of the Industrial Customers of
ldaho Power, Nos. 9 through 12.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
X;- !.ff"*+.-.-,
Lisa D. Nordstrom
LDN:slb
Attachment(s)
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO PO\A'ER COMPANY FOR
AUTHORITY TO REVISE THE ENERGY
EFFICIENCY RIDER, TARIFF SCHEDULE
91.
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CASE NO. |PC-E-20-33
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF
IDAHO POWER
COMES NOW, Idaho Power Company ("ldaho Powef or.Company"), and in
response to the Second Prduction Request of the lndustrial Customers of ldaho Power
Company dated September29,2020, herewith submits the following information:
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTR]AL CUSTOMERS OF IDAHO POWER - 1
REOUEST FOR PRODUCTION NO.9:
On page 4 of the Application states;
Notably, pafticipation in the Company's Commercial and industrial
Custom Prcject option has incrcased, with the Company achieving
the same kWh savings level in the six months ending June 2020, as
for all of 2019.
For the last three years please provide a list of the dollar amount of payments
to each Commercial and/or lndustrial Custom Project (without customer specific
identifying information, if possible) and the assumed energy saving for each Custom
Project.
Please see the attachment provided with this request for a list of proiects paid an
incentive in the Commercial and lndustrial Efficiency program uCustom" option from
2017 through July 2020.
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 INDUSTRIAL CUSTOMERS OF IDAHO PO\A'ER - 2
FEQUEST FOR PRODUCTTON NO. 10:
What is the assumed level of annual Utility Gosts for the Custom Projects
used in the forecasts of annual for DSM year 2020 and the low and high forecast for
DSM year 2021?
RESPONSE TO REQUEST FOR PRODUCTIOI{ NO. IO:
For the 2020 forecast which included actual expense through July, and forecast
for August through December, the assumed level of utility costs for the Gustom portion
of the Commercial and lndustrial Efficiency program was $ 18,790,011. This number
includes incentives, labor and expenses.
Both the 2021 high- and low-case forecasts are based on energy savings
identified in potential studies, which are provided at the Commercial and lndustrial
sector level, not at the individual program level, such as Custom. As part of the annual
budget process, the potentialstudy sector levelsavings help inform program level
savings budgets.
For 2021, the forecast for the high-case used the achievable economic energy
efficiency potentialfrom the 2020 potential study. The 2020 potentialstudy identified
Commercial and lndustrial sector savings of 98,228,000 kWrs. The2021low-case
forecast used the achievable economic energy efficiency potentialfrom the 2018
potential study. The 2018 potentialstudy identified Commercialand lndustrialsector
savings of 84,065,000 kWhs. Both the high- and low-case forecasts for 2021 used a
portfolio level utility cost of $0.2097 per k\/Vh to develop the associated utility costs.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IOAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POVVER.3
REQUEST FOR PRODUCTION NO. {{:
ln Case IPC-E-20-15 Company witness Goralski states:
Changes to the cost+ffecfiVeness testforenergy efficiency will be
canied out over the 202A program year to synchrcnize with the
Company's annualplanning cycle. The Company is in the process
of implementing the UCT as fhe pimary percpective as if moves
into the 2021 IRP planning cycle. fGoralski, Dircct Testimony, IPC-
E-20-15, at p. 16.]
ln Response #8 to the lndustrial Customers First Production Request to
Company stated;
For the 2O2O DSM progmm year, cost-effectiveness rcpofting will
be based on the DSM avoided cosfs from the 2017 lRP. Because
the 2019 IRP was not acknowledged beforc the Company stafted
preparing the 2021 progrum year in August 2020, ldaho Powerwill
use the 2017 DSM avoided cosfs to calculate 2021 prctgmm year
cost-effecfiveness.
Does this mean Company witness Goralki's statement in his Direct Testimony is
no longer valid? lf so, will it be withdrawn? Does this also mean the avoided costs used
for the UTC cost effeteness tests for the 2020 and 2021 DSM program years will based
on estimates of avoided costs that will be three and four years old?
RESPONSE TO.REQUEST FOR PRODUGTION NO. 1{:
Company witness Goralski's statement in Direct Testimony in Case No. IPC-E-
20-15 remains valid. ln 2020, the Company has transitioned to using the Utility Cost
Test ("UCT") as the primary cost-effectiveness perspective for energy efficiency
resource planning, as well as program planning and implementation. To clariff, the
reliance on a particular cost-effectiveness test for program planning and implementation
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER .4
determines the costs and beneftts to be included in the analysis;the lntegrated
ReEource Plan ("lRP") alternate costs are simply an input used to determine benefits.
To determine cost-effectiveness of its energy efficiency programs, the Company
uses the DSM alternate costs from the most recently acknowledged IRP that were relied
upon for program year budgeting and program planning purposes. The current practice
of relying on the DSM alternate costs from the most recently acknodedged IRP has
been utilized by ldaho Power since 2A14 and has been discussed with and supported
by memberc of the Company's Energy Efficiency Advisory Group ('EEAG"). For the
2O2O and2021 program years, the Company used avoided costs ftom the 2017 IRP to
establish budgets and intends to use the same avoided cosE when measuring cost-
effectiveness.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER. S
REQUEST FOR PRODUCTION NO. {2:
ln response to lClP Request for Prcduction No. 8, the Company states that,
"ldaho Power uses the DSM avoided costs, discount rate, and escalation rate from
the most recently acknowledged IRP at the time the assumptions were fozen to
calculate the cost-effective ratios." On what authority does the company rely for the
use of the most recent acknowledged IRP for calculating cost-effective rations,
please provide copies and citations?
RESPONSE TO REQUEST FOR PRODUGTION NO. 12:
The current practice of relying on the DSM alternate costs from the most recently
acknowledged IRP has been utilized by ldaho Power since 2014 and has been
discussed with and supported by members of the Company's Energy Efficiency
Advisory Group ('EEAG'). ldaho Power believes that its practice of using the best
available information at the time of budgeting and program planning, which occurs in
September-October timefiame prior to the program year, comports with utility
stiandards, is consistent with third-party evaluator recommendations, and has been
disclosed in multiple reports and filings submitted to both the ldaho and Oregon
Commissions.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
DATED at Boise, ldaho, this 19th day of October 2020.
X*!.ffa,+r..,-,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19m day of October 2020,1 served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POI/VER
upon the following named parties by the method indicated below, and addressed to the
following:
Commission Staff
Edward Jewell
Deputy Attomey General
11331 W. Chinden Blvd., Suite 201-A
Boise, ldaho 83714
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
710 N 6th Street
Boise, lD 83702
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Stephanie Buckner, Executive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG-E-20-33
IDAHO POWER COMPANY
ATTACHMENT TO REQUEST NO. 9
(EXCEL SPREADSHEET ATTACHED TO EMAILI
ro
IDAHO POWER COMPANY'S RESPONSE TO THE
SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER