20231020IPC to Staff 26-29.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

October 19, 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 a redacted version of Idaho Power Company’s
Response to the Fourth Production Request of the Commission Staff in the above matter.
The confidential version will be sent in an encrypted email to the parties who have signed
the Protective Agreement. Please treat the confidential documents in accordance with the
Protective Agreement.

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

Sincerely,

Megan Goicoechea Allen
MGA:cd
Enclosures
RECEIVED
Thursday, October 19, 2023 4:23:30 PM
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION

Application of Idaho Power Company for Determination of 2022 Demand-Side
Management Expenses as Prudently Incurred

Case No. IPC-E-23-10

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that Response to Request for Production No. 26 to Idaho Power Company’s
Response to the Fourth Production Request of the Commission Staff dated October 19,
2023, may contain information that Idaho Power Company and a third party claims is a
confidential trade secret and/or business records of a private enterprise required by law
to be submitted to or inspected by a public agency as described in Idaho Code § 74-101,
et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and exempt
from public inspection, examination, or copying.

DATED this Thursday, October 19, 2023,

Megan Goicoechea Allen
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH 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.
)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-10

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Fourth Production Request of the Commission Staff (“Commission” or
“Staff”) to Idaho Power Company dated September 28, 2023, herewith submits the
following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 26: In its May 2022 Energy Efficiency
Advisory Group meeting, the Company provided an overview of a planned Online
Marketplace. Please provide an update on the status of any associated expenses and
provide an estimated timeline of the marketplace model. Please also provide any
associated expenses from 2022 for this project.
CONFIDENTIAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO.
26:

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3

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

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
STAFF REQUEST FOR PRODUCTION NO. 27: In its Response to Production
Request No. 21, the Company indicated that it has requested responses to
recommendation Nos. 1, 2, 4, 5, 6, 8, and 9. Please explain why recommendation Nos. 3
and 7 were not included in the Company's request.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 27:
From the ADM evaluation report of the Northwest Energy Efficiency Alliance
(“NEEA”) (Exhibit 4 page 20 of the Direct Testimony of Theresa Drake), recommendations
Nos. 3 and 7 were not included in the Company's request back to NEEA because the
recommendations applied to Idaho Power and Avista; they are not activities that NEEA
would undertake. Specifically, for No. 3, ADM’s recommendation directed at NEEA is not
NEEA’s responsibility. Idaho Power is better positioned to address matters related to the
“current regulatory environment and utility’s localized concerns.”
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
STAFF REQUEST FOR PRODUCTION NO. 28: In its Response to Production
Request No. 21, the Company states that it has worked with Northwest Energy Efficiency
Alliance "(NEEA")" on an alternate method for quantifying code savings. Please describe
the alternate method.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 28:
The alternate method has not been determined yet, but NEEA has agreed to
conduct an assessment in 2024 of its current evaluation methods for state energy code
work with a third-party evaluator. It is Idaho Power’s understanding that this evaluator will
come up with an alternate method that would then be presented for review. NEEA has
committed up to $500,000 for additional evaluations as part of the 2025-2029 NEEA
Business Cycle which will be paid for by all NEEA funders (as highlighted in the
Company’s Response to Staff’s Request for Production No. 22).
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
STAFF REQUEST FOR PRODUCTION NO. 29: In its Response to Production
Request No. 23, NEEA describes an assessment of its state energy code evaluation
methods to be conducted in 2024. Please provide a scope of work, a timeline, and
completion date for the assessment.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 29:
In preparing this response, Idaho Power requested NEEA provide a scope of
work and timeline for its state energy code evaluation methods. Please see the
Attachment to this response which contains NEEA’s approach.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

Respectfully submitted this 19th day of October 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 19th day of October 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Fourth 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

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-500
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]
[e-mail]

Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-500
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Christy Davenport
Legal Administrative Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-10

IDAHO POWER COMPANY

ATTACHMENT TO RESPONSE NO. 29

October 12, 2023

NEEA State Energy Code Evaluation Assessment Process and Estimated Timing

At the NEEA Board of Directors meeting in September 2023, the Board discussed how to address
recommendation #9 of the Evaluation of NEEA Impacts Allocated to Idaho Power Company and Avista
Utilities Within the State of Idaho, dated April 6, 2023, and submitted by: ADM ASSOCIATES, INC.:

“Complete influence evaluations for each code update to estimate NEEA’s qualitative and
quantitative influence towards the code update. Or, alternatively, incorporating a quantitative
method for isolating incremental savings due to NEEA-specific efforts approved by a third-party
evaluator.”

The Board aligned on the following steps to address this recommendation:
• NEEA will conduct a review of evaluation methods with support from a third-party contractor.
• Results and recommendations will be reviewed by the regional Cost Effectiveness Advisory
Committee (CEAC). This committee is responsible for overseeing the evaluation and energy
saving calculation methodologies of NEEA’s work and is a public forum that includes funders,
stakeholders and members of state regulatory staff.
• Recommendations resulting from this CEAC process will be approved by NEEA’s Executive
Director.
• NEEA’s Executive Director will keep NEEA’s Board updated throughout the process and informed
of the outcome.
• Any additional evaluation costs that may be an output of this work with CEAC will be embedded
within NEEA’s Cycle 7 (2025-2029) existing Business Plan budget. Any additional costs will be
capped at $500K above already budgeted evaluation costs for the 5-year 2025-2029 business
cycle.

Process, Timeline and Scope of Work to Address Recommendation #9 with CEAC
To address recommendation #9, the outcomes of this work is to develop a recommendation for a
framework for evaluating state energy codes that are most applicable to Market Transformation and
NEEA’s current framework for reporting energy savings.

The objectives of this work are to:

1. Assess the current evaluation approach to state energy codes.
2. Explore alternative frameworks for evaluating and reporting energy savings associated with
state energy codes.

Below is the process and estimated timeline to approach achieving the objectives and desired outcome.
This process follows the current operational practices for regional alignment on key alliance activities,
although the timeline is accelerated. This process my also evolve based on conversations with CEAC and
the third-party evaluator. Staff will attempt to accelerate progress further if possible as this process
unfolds.

• Provide background on situation and
process.

Develop and release an RFQ for a third-party
evaluator.

Status report at Board of Directors meeting.
CEAC members individually and
collectively to understand the
situation and background, as well as
time to inform their home
organization.
• Provide an overview of the work that
NEEA does to influence state energy
codes, and compare and contrast to its
work in influencing federal standards.

• Provide current state of evaluation
approaches used to evaluate state energy
codes, federal appliance standards work,
and other federal standards work.

• Review NEEA’s existing evaluation
methodologies, including the rationale,
cadence and estimated costs.

• Discussion.

Select 3rd party evaluator.

Staff to develop alternative evaluation approach
options to be assessed by the 3rd party evaluator.

Status report at Board of Directors meeting.

current state of evaluation approaches
NEEA utilizes for CEAC members
individually and collectively to
understand the situation and
background. This provides the
foundation from which any potential
changes would be made.

• Review approach and key assumptions
used in estimating and reporting energy
savings from state energy codes work.

• Present draft approaches with an
opportunity for discussion and feedback,
including early assessment from the 3rd
party evaluator.

draft evaluation approaches with pros, cons and
implications.

Status report at Board of Directors meeting.
• Refined draft approaches with 3rd party
evaluator assessment are presented with
opportunity for discussion and feedback.

• Staff provides initial recommendation,
with rationale, implications and
estimated costs for discussion and
feedback.

Status report at Board of Directors meeting.
• Staff provides final recommendation with
implications for review and advice.

• Staff will also address whether or not this
recommendation would need to be
tested before full implementation. If the
proposed approach is untested within a
Market Transformation framework, this
may warrant a phased approach to
implementation to permit time for
testing the evaluation method.

Status report at Board of Directors meeting.
NEEA Executive Director provides a
recommendation with cost implications including
the CEAC feedback. This is for Board information