20210701IPC to Staff 18-21.pdf

ADAM LOWNEY (lSB No.10456)
McDowell Rackner Gibson PC
419 SW 11th Avenue, Suite 400
Portland, OR 97205
Telephone: [phone]
Facsimile: [phone]
[e-mail]
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LISA D. NORDSTROM (!SB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ idahopower. com
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2O2O DEMAND-SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. !PC-E-21-04
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODCUTION REQEUST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the Second Production Request of the Commission Staff to ldaho Power
Company dated June 30,2021, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF 1
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REQUEST NO. 18: Please provide the cost-effectiveness workpapers and
calculations for each measure, kit, giveaway, and/or program under the Educational
Distributions Programs in 2020 in Excelformat, with allformulas intact.
RESPONSE TO REQUEST NO. 18: Please see the attachment provided to this
response.
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 2
REQUEST NO. 19: On page 85 of the Annual Report, the Company states that
"$129,391 will be provided to the non-profit pooled fund to weatherize buildings
housing non-profit agencies that primarily serve qualified customers in ldaho." Please
answer the following:
a. What is the origin of this program and who is administering it?
b. What are the qualifications for non-profits to participate in this program?
c. Please provide the current balance of the fund
d. How does the Company determine funding amounts per year?
e. Please provide the list of these agencies expecting to receive service in
2021?
f. Please provide the list of these agencies expecting to receive service in
2021.
g. ls the Savings to lnvestment Ratio tool used to determine the measures
installed in the agency buildings? lf not, how are measures selected to be
installed?
h. How does the Company claim the savings?
i. Has the Company conducted cost-effectiveness tests for only these
buildings? lf so, please provide these results in Excel format, with formulas
enabled.
j. Has the company conducted any evaluations on these buildings? lf yes,
please provide the evaluation.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF 3
a. RESPONSE TO REQUEST NO. 19: The origin of Weatherization
Assistance for Qualified Customers Program ("WAQC") came from a
program previously called Low lncome Weatherization Assistance
("L|WA"). ln Order No.29505 issued in Case No. IPC-E-13-03, the
Commission ordered ldaho Power to increase expensed LIWA payments
to CAP agencies by $t million along with other administrative changes. lt
was also ordered the Company work with Community Action Partnership
of ldaho ('CAPAI') and the Energy Efficiency Advisory Group ("EEAG") to
resolve several issues related to program administration and to report
details and explanations of the LIWA program changes back to the
Commission (at page 32).
Subsequently, the Company filed a report detailing the structural changes
to the program on October 4,2004 in Case No. IPC-E-03-13. The repod
stated:
"ln addition to the funding made available to each agency for
weatherization of low-income homes, a pool of funds will be available for
the weatherization of buildings occupied by non-profit organizations. ln
order to receive funding, these organizations must receive electric service
from ldaho Power, serve primarily low-income clientele and have Section
501(c)(3) tax-exempt status under the lnternal Revenue Code. The total
cost of weatherization measures is eligible for reimbursement using LIWA
funds. Buildings occupied by non-profit organizations do not need to be
heated primarily with electricity in order to receive LIWA funds."
b. The qualifications for non-profits to participate in the WAQC Program are
o The agency must be an ldaho Power customer.
o The building must house a non-profit agency that primarily serves
special needs customers in ldaho.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF 4
o The agency must supply a copy of its IRS 501(C)(3) notification letter.
. The agency must supply an owner/renter agreement if the building is
rented.
o The agency must supply a lease agreement if the building is being
leased.
o Weatherization assistance is only available one time per building.
c. The current balance of the WAQC non-profit fund is $129,391.44.
d. The non-profit pooled account is funded at $50,000 annually plus unused
carryover funds from previous years. The $50,000 annual funding amount
began in 2005 and the carryover was directed by Commission Order No.
29505, which stated "any unpaid funds shall carry over and be available in
the next year." The table below shows the funding and spend of the non-
profit pooled fund over the last five years.
Year Base
Fundinq
Carryover
from
previous vear
Total Fundino Annual
Spend
2017 $50,000 $14,493 $64,493 $38,159
2018 $50.000 $26,334 $76,334 $39,694
2019 $50,000 $36,640 $86,640 $57,249
2420 $50,000 $29,391 $79,391 $0
2021 $50,000 $79,391 $129,391 $0
e. Below is a list of non-profit agencies with weatherization requests pending
for 2021:
a. Garden Valley Senior Center
b. Gooding Senior Center
c. All Saints Community Food Service and Clinic
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF 5
f. Below is the list of non-profit agencies that received weatherization
services under this program between 2018 and 2020:
2018
. American Falls Medical Clinic
Twin Falls Optimists Food Distribution and Meal Kitchen BuiHinga
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF 6
2019
o The Mustard Seed Community Center and Thrift Store
o Richfield Senior Center
o New Plymouth Senior Center
. Melba American Legion Hall
2020
. No non-profit weatherization work was completed due to COVID-19
safety protocols.
g. Yes, the EAS energy audit tool is used by the ldaho State Weatherization
Assistance Program to determine which measures are installed in non-
profit buildings using the savings to investment ratio.
h. The Company uses a per square foot value calculated from the evaluated
savings of other WAQC projects to claim savings on the non-profit
projects.
i. No. The Company has not conducted cost-effectiveness tests for only the
non-profit buildings; however, the Company does include the cost and
savings associated with these projects in the WAQC cost-effectiveness
analysis.
j. No. ldaho Power has not conducted an evaluation specific to the non-
profit buildings. The 2020 ldaho Power Weatherization Programs Analysis
evaluation is included in Supplement 2 of the 2020 Demand-Side
Management Annual Report. The evaluation was completed by Nexant,
and they stated on page 10 "Caution should be exercised in using results
from groups that have small customer counts (n < 15) as they are more
susceptible to the influence of the impact of outliers." Therefore, with 7
non-profit weatherization jobs completed during 2016-2018, the process
for evaluating savings specific to non-profits would be challenging and the
results unreliable.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
!DAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF 7
REQUEST NO. 20: On page 135 of the Annual report, the Company states that
"final NEAA savings for 2020 will be released Iater in the year." Wren is the expected
date for NEAA savings to be finalized? lf the savings are finalized, please provide the
report from NEEA for the finalized savings tor 2020 in Excel format, with all formulas
intact.
RESPONSE TO REQUEST NO. 20: ldaho Power received the Final 2020 Annual
Savings Report from the Northwest Energy Efficiency Alliance ("NEEA"; on Apri! 6,2021.
Please see attachments 1 and 2 provided to this response that contain the final savings
report and the Excelworkbook from NEEA.
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 8
REQUEST NO. 21: For promotional and marketing items in2020 please answer
the following
a. \Mat items does the Company claim energy efficiency savings on?
b. \Mat are the sources of these savings?
RESPONSE TO REQUEST NO. 21:
a. ldaho Power does not claim energy efficiency savings on promotional and
marketing items. Giveaway items for which the Company does claim energy
efficiency savings on fall under the Educational Distributions program. These
giveaway items include LED bulbs, LED night lights, and Energy-savings kits.
b. The savings source for the giveaway items within the Educational Distributions
program are included in the attachment to Response No. 18.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
Respectfully submitted this 30th day of June 2021.
ADAM LOWNEY
LISA D. NORDSTROM
Attorneys for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF 9
CERTIFICATE OF SERVIGE
I HEREBY CERTIFYthat on the 30th day of June 2021,1 served a true and correct
copy 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
Matt Hunter
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A(83714')
PO Box 83720
Boise, lD 83720-0074
lndustrial Customer of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 North 27th Street
P.O. Box 7218
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Gonservation League
Benjamin J. Otto
710 N.6th Street
Boise, ldaho 83702
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CERTIFICATE OF SERVICE - 1
GIty of Boise
Mary Grant
Deputy CityAttorney
Boise Gity Attomey's Office
150 N. Capitol Blvd.
P.O. Box 500
Boioe, Idaho 83701{500
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boisecityatto rney@cityofu o ise. oro
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M,{rqXil!
Alisha Till, Paralegal
CERTIFICATE OF SERMCE -2