20230915IPC to Staff 20-25.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

September 15, 2023

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-23-10
In the Matter of the Application of Idaho Power Company for a Determination
of 2022 Demand-Side Management Expenses as Prudently Incurred

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the Third
Production Request of the Commission Staff in the above matter.

Due to the voluminous nature of non-confidential information provided in response to
data requests in this case, the Company is posting the attachments to these requests to
the secure FTP site to allow parties to view the requested information remotely. The login
information for the FTP site was previously provided to all parties through email.

If you have any questions about the attached documents, please do not hesitate to
contact me.

Sincerely,

Megan Goicoechea Allen
MGA:cd
Enclosures
RECEIVED
Friday, September 15, 2023 12:56:13 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2022 DEMAND-SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
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CASE NO. IPC-E-23-10

IDAHO POWER COMPANY’S
RESPONSE TO THE THIRD
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Third Production Request of the Commission Staff (“Commission” or
“Staff”) to Idaho Power Company dated August 25, 2023, herewith submits the following
information:

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 20: In response to Production
Request No. 18, the Company provided copies of advertisements it paid for during 2022.
For the advertisements labeled "2022CIAirportAd" and "2022CIAirportAd2", please
provide total costs, including production costs and placement costs, and the accounts to
which they were booked. Please provide the basis for any allocation between accounts
and service jurisdictions.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 20:
The total placement cost in 2022 for the ads labeled "2022CIAirportAd" and
"2022CIAirportAd2" was $9,467. Because the ads were produced in the previous year,
no additional production costs were associated with these placements for 2022. The
account the ads were booked to was one single account, Commercial Overhead, and
allocated 95 percent to the Idaho Rider and 5 percent to the Oregon Rider.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
STAFF REQUEST FOR PRODUCTION NO. 21: For each recommendation
provided by the NEEA evaluation" Evaluation") please describe the Company's requested
action, NEEA's corresponding response (i.e., accepted, contingent, etc), and if the action
will be implemented in the 2025-2029 funding cycle.
a. For any recommendations not accepted by NEEA, please explain why it was not
accepted.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 21:
On April 7, 2023 Idaho Power requested NEEA provide a response on each
recommendation that applied to NEEA in the original evaluation report by ADM. These
items included Recommendation numbers 1, 2, 4, 5, 6, 8, and 9. The table below shows
each recommendation and NEEA’s initial May 4, 2023 response. NEEA has committed
to implementing each recommendation in the 2025-2029 funding cycle with a caveat on
Recommendation #9.
Recommendation NEEA Response
1. Request NEEA to report
annual savings for Idaho via
service territory methodology
for each measure claimed by
NEEA.
Yes, NEEA can implement recommendation. Additional
analytical labor costs associated with service territory
reporting. NEEA’s current service territory approach will
be used. Full implementation to start with reporting 2025
energy savings.
2. Request that annual
savings reports include
estimates of administrative
costs, incentive costs, and
non- incentive costs by
service territory.
Yes, NEEA can implement recommendation. Additional
labor costs associated with Idaho-specific reporting. This
report will use the same service territory allocation used
in reporting of savings. The report will provide an
allocation of program administrative, incentive, and non-
incentive costs. Develop report format in 2024 with
implementation in 2025.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
4. Track progress for each
code change relative to
administrative dollars spent
towards state level codes and
associated energy savings
accrued by each state-level
code.
Yes, NEEA can implement recommendation. Additional
labor costs associated with Idaho-specific reporting.
Develop report format in 2024 with implementation in
2025.
5. Detail measure-level values
as accurately as possible, and
that each field is completed in
the workbook to allow for
year-over-year tracking of
regional units, baseline units,
retirement units and unit
energy savings over time.
No change, matches current practice. In the savings
workbook provided annually to each funder, NEEA
already enters all data fields for active programs and
measures within each program for which we are reporting
savings. NEEA references all the data sources in the
workbook.
6. NEEA to distribute naturally
occurring baseline units more
equitably between local
program units and total
regional units.
No change, this matches current practice, NEEA
distributes naturally occurring baseline units equitably
between local programs and total regional units today,
and no further adjustment is recommended. NEEA staff
would be happy to have a discussion to further clarify and
understand the concern.
8. Complete third-party
influence evaluations for all
federal standards claimed by
NEEA, as well as any future
standards in which NEEA
hopes to claim savings for the
future. Using quantitative
estimate of influence calculate
a naturally occurring baseline
for each standard.
No change, this is part of NEEA's current practice today.
9. Complete influence
evaluations for each code
update to estimate NEEA’s
qualitative and quantitative
influence towards the code
update.
NEEA can possibly implement, pending further
discussion with the Cost Effectiveness and Evaluation
Advisory Committee (CEAC). NEEA already conducts
third-party evaluation of its energy codes work. Since the
current influence approach’s application to reported
energy savings was recommended by CEAC, any
changes would need to be discussed by that committee.
Possible implementation in 2025 with cost implications to
be determined.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
For Recommendation #9, Idaho Power has continued to work with NEEA on an
alternate method of quantifying code savings. NEEA has agreed to reviewing the current
method. Please see the response to Production Request No. 22 and 23 for additional
detail.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
STAFF REQUEST FOR PRODUCTION NO. 22: Please explain if there are any
incremental costs associated with implementation of the NEEA Evaluation
recommendations.
a. If yes, please provide the cost associated with each recommendation and explain
how those costs will be passed on to NEEA participants or the Company.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 22:
Idaho Power received the following cost estimates from NEEA associated with
implementing the recommendations from the NEEA Evaluation. These costs will be part
of the 2025-2029 NEEA Business Cycle and will be paid for by all NEEA funders.
 Recommendation #1 and #5 - $30,000 will be applied to the analytics, research
and evaluation category
 Recommendation #2 - $10,000 will be applied to administration expense category
 Recommendation #4 - $10,000 will be applied to codes and standards expense
category
 Recommendation #9 - Up to $500,000 for additional evaluations would go in the
analytics, research, and evaluation expense category.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
STAFF REQUEST FOR PRODUCTION NO. 23: Please describe any changes
made to the NEEA business plan in response to the Evaluation recommendations.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 23:
Idaho Power received the following from NEEA in an email dated September 7,
2023.
In response to a request from Avista Utilities and Idaho
Power, NEEA staff will conduct an assessment in 2024 of its
current evaluation methods for state energy code work with a
third-party evaluator review. This assessment will be reviewed
by NEEA’s Cost Effectiveness Advisory Committee (CEAC) –
the regional body responsible for advising NEEA’s Executive
Director on methods, data sources and inputs used in NEEA’s
energy savings reporting as well as evaluation
methodologies, as is NEEA’s standard operating practice.
NEEA’s Executive Director will review the recommendations
and decide how to proceed. Any changes will start
implementation as part of NEEA’s core operations and budget
during the 2025-2029 business cycle. NEEA has allocated
budget over the 2025-2029 Business Cycle within its core
budget to address any potential changes to its evaluation
practices. This regional approach is responsive to the needs
conveyed by IOU funders in Idaho and honors NEEA’s
longstanding regional collaborative process.

The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
STAFF REQUEST FOR PRODUCTION NO. 24: Please provide any
communication between the Company and NEEA related to the Evaluation or
implementation of Evaluation recommendations.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 24:
Prior to initiating the evaluation, Idaho Power had a few phone/virtual
conversations to inform NEEA that the Company and Avista were conducting a joint
evaluation, however Idaho Power does not have a comprehensive list of dates of those
discussions.
Please see the email Attachments provided for this response related to the
evaluation and its recommendations.
In addition to the email communications, Idaho Power met with NEEA several
times to discuss the Evaluation and the Evaluation recommendations. The following is a
summary of the meetings and topics discussed.
 April 6, 2023: Meeting with Idaho Power, Avista, and NEEA to discuss the
Evaluation report to be sent to NEEA on April 7 with an expectation a
response would be received from NEEA within 30 days of receipt of the
letter.
 May 17, 2023: Meeting with Idaho Power, Avista, NEEA, and ADM to
discuss report findings. The purpose of the meeting was to provide further
clarification from both ADM and NEEA’s perspectives.
 May 30, 2023: Meeting with Idaho Power, Avista, and NEEA to discuss
evaluation follow up communication process. The purpose of the meeting
was to clarify roles and set expectations for interacting with ADM.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
 July 13, 2023: Meeting with Idaho Power, Avista, and NEEA to discuss
request for additional information. The purpose of the meeting was to
address NEEA’s 20-year cost-benefit analysis.
 August 3, 2023: Meeting with Idaho Power, Avista, and NEEA to discuss
Recommendation #9 – code influence evaluation.
 August 29, 2023: Meeting with Idaho Power, Avista, and NEEA to discuss
evaluation recommendation potential action by NEEA. The purpose of the
meeting was to seek alignment on NEEA’s proposal for Recommendation
#9 and preparation to discuss Recommendation #9 at the September 11th
and 12th NEEA Board meetings.
 September 6, 2023: Meeting with Idaho Power and NEEA to discuss
implementation of Recommendation #1 – savings by service territory to
report 2023 savings.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
STAFF REQUEST FOR PRODUCTION NO. 25: For NEEA's 2025-2029 Business
Cycle, please provide the expected cost for the Company and how that funding amount
was determined. Additionally, please identify any cost associated with ad hoc requests
(i.e., cost to implement recommendations or measures for Idaho Power specifically) and
provide a breakdown of costs associated with the Business Plan to the greatest extent
possible (i.e., administration, codes, standard changes, measure support, etc.).
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 25:
Idaho Power’s cost for the NEEA 2025-2029 Business Cycle is estimated to be
$20,290,440. For a detailed description of how funder shares are calculated, please see
Attachment 1 provided for this response for NEEA’s Direct Electric Funding Mechanism
Policy and see Attachment 2 which shows each existing NEEA funder and their
preliminary funding levels for the 2025-2029 business cycle. Also, the table listed below
is a breakdown of NEEAs overall budget (NEEA’s Cycle 7 (2025-2029) Business Plan
Draft pg 48). Please see the response to Production Request No. 22 for the estimated
costs associated with implementing the recommendations from the NEEA Evaluation.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11

The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

Respectfully submitted this 15th day of September 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 15th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Third Production Request of
the Commission Staff upon the following named parties by the method indicated below,
and addressed to the following:

Commission Staff
Claire Sharp
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-500
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Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-500
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Christy Davenport
Legal Administrative Assistant