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December 11 , 2006
Brad M. Purdy
Attorney for Community Action Partnership Association of Idaho (CAP AI)
2019 N. 1 ih Street
Boise, ill 83702
RE:Idaho PAC-06-
CAP AI Data Requests 1-
Please find enclosed Rocky Mountain Power s Response to CAP AI's Data Request
Numbers 1 through 10.
If you have any questions, please callme at (801) 220-4975,
Sincerely,
D~ / 1/(/)/
Brian Dickman
Manager, Regulation
Enclosure
cc:Jean Jewell/IPUC
Donald L. Howel1/IPUC (e-mail only)
Dean Brockbank/Rocky Mountain Power
PAC-06-10/Rocky Mountain Power
December 11 2006
CAP AI Data Request I
CAPAI Data Request 1
Please list all United States Department of Energy ("DOE") measures that are
eligible under the PacifiCorp low-income weatherization program for
reimbursement and list those not eligible.
Response to CAP AI Data Request 1
The measures eligible are listed in Section C of Schedule 21. Please see
Attachment CAP All. Rocky Mountain Power is unable to locate a separate list
of approved United States Department of Energy measures and is not aware of
specific electrical efficiency measures that would be ineligible for reimbursement.
PREP ARER: Becky M. Eberle, Product Manager
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs
IDAHO
P AC-O6-
SCHEDULE 21 FUNDING STRUCTURE
ROCKY MOUNTAIN POWER
COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO (CAPAI)
DATA REQUEST
TT ACHMENT
CAP AI 1
~ ~~\~o
~OUNT AIN
C. No.Original Sheet No. 21.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 21
STATE OF IDAHO
Low Income Weatherization Services
Optional For Income Qualifying Customers
PURPOSE: Service under this schedule is intended to maximize the efficient utilization of the
electricity requirements of existing residential dwellings inhabited by customers that meet income
guidelines through the installation of energy efficient materials. The decision to extend service under this
schedule shall be based upon the eligibility requirements contained herein.
AVAILABILITY: This tariff is applicable to residential customers in all territory served by the
Company in the state of Idaho.
ENERGY CONSERV A nON SERVICE TO LOW INCOME CUSTOMERS:
This program is available to existing single family and multi-family residential units. It
intended to reduce the electricity requirements and increase the penetration of weatherization and
efficiency measures in residential dwellings inhabited by low income households through the
installation of permanent energy efficiency materials. The decision to extend service under this
schedule shall be based on eligibility requirements contained herein.
Definitions:
Dwelling" is real or personal property within the state inhabited as the principal
residence of a dwelling owner or a tenant. "Dwelling" includes a manufactured
home, a single-family home, duplex or multi-unit residential housing. "Dwelling
does not include a recreational vehicle.
Duplexes and fourplexes are eligible if at least one half of the dwelling is
occupied by low income tenants.
(Continued)
Submitted Under Advice Letter No. 06-
ISSUED: August 15, 2006 EFFECTIVE: September IS, 2006
~ ~~~o
~OUNT AIN
C. No.Original Sheet No. 21.2
ELECTRIC SERVICE SCHEDULE NO. 21 - (Continued)
Definitions (Continued):b. Triplexes and multi-family dwellings are eligible if at least 66% of the units
are occupied by low income tenants.
Agency" means a non-profit group, Municipality or County authorized to receive
funds for installation of energy efficiency materials in low income properties.
Low Income" means households qualifying under the federal low income
guidelines and certified for eligibility according to agency procedure. Income
eligibility is based on 150% of federal poverty guidelines.
Major Measure" means ceiling insulation, wall insulation, floor insulation and
window replacements applicable in dwellings with permanently installed electric
space heating systems. When cost-effective (Savings to Investment Ratio of 1.0 or
greater), all major measures must be installed or in place or financial assistance
under this schedule will not be offered. If physical barriers exist that prohibit the
installation of a measure, then the measure is not required as a condition for
financial assistance under this schedule.
Supplemental Measures and Additional Measures" are not required measures
under this schedule, but may qualify for a Company reimbursement.
Financial Assistance:
The Company will reimburse Agency 50% of the installed cost of all eligible
Energy Conservation Measures listed in Section C of this Tariff. If participating
Agencies exhaust weatherization funds they are provided through federal sources
Company will reimburse 100% of costs associated with the installation of eligible
Energy Conservation Measures. Reimbursements on weatherized homes will be
provided one time only on any individual measure, and up to two times per
dwelling. An incentive will be provided a second time only on dwellings originally
treated before October I , 1993.
Agencies will not delay serving Company customers in order to obtain funding at
the 100% level. Agencies must notify Company when other funds are depleted, no
less than 30 days prior to billing at the 100% reimbursement level.
(Continued)
Submitted Under Advice No. 06-
ISSUED: August 14 2006 EFFECTIVE: September 15 2006
~ ~
~~~o
~OUNTAIN
C. No.Original Sheet No. 21.
ELECTRIC SERVICE SCHEDULE NO. 21 - Continued
Financial Assistance (Continued):
The Company will reimburse Agency for administrative costs based on 15% of
Utah Power s rebate on installed measures, not to exceed the following total
administrative payment per building:
Dwelling Units in Building
1 to 4
5 to 10
11 to 15
16 to 20
21 to 25
26 to 30
31+
Maximum UP&L Administrative Payment
$350
$800
$1200
$1400
$1600
$1800
$2100
The minimum reimbursement will be $1 SO on homes with one or more Major Measure
installed and $50 on homes without the installation of a Major Measure.
Agencies must invoice Company within 120 days of job completion.
A maximum of $150 000 in Company reimbursements will be available annually
(April 1 through March 31).
Energy Conservation Measures:
Financial assistance will be provided based on the results of a cost effective analysis
through a Department of Energy approved energy audit. The energy efficient measures
eligible for funding (Savings to Investment Ratio is 1.0 or greater) must be installed in
dwellings with permanently installed operable electric space heat except where noted. The
energy efficient measures that may be eligible for funding are listed as follows:
Major Measures - Electric Heating System Required:
Ceiling insulation up to R-48 for ceilings with less than R-30 in place. R-
30 or better attics will not be further insulated.
(Continued)
Submitted Under Advice No. 06-
ISSUED: August 14 2006 EFFECTIVE: September IS , 2006
~2~\;~OUNTAIN
C. No.Original Sheet No. 21.
ELECTRIC SERVICE SCHEDULE NO. 21 - Continued
Energy Conservation Measures:(Continued)
Floor insulation over unheated spaced up to R-30.
Wall insulation up to R-26 for walls with no insulation installed (financing will not
be available for the installation of urea-formaldehyde wall insulation).
Replacement windows with a U-value of 0.35 or less.
Nothing shall preclude the Company from providing a reimbursement for the
installation of a greater R value on insulation for the above items that are determined to be
cost effective (Savings to Investment Ratio is 1.0 or greater) through the audit process.
Supplemental Measures - Electric Heating System Required:
Attic ventilation, excluding power ventilators, when installed with ceiling
insulation (required if needed at the time ceiling insulation is installed). Whole
house mechanical ventilation and spot ventilation for kitchen and baths at time
ceiling insulation is installed.
Ground cover and water pipe wrap when installed with floor insulation; other vapor
barrier materials as required when installed with floor or ceiling insulation.
Forced air electric space heatingduct insulation and sealing in unheated spaces.
Weather stripping and/or caulking, including blower door assisted air sealing and
duct sealing.
Thermal doors.
(Continued)
Submitted Under Advice Letter No. 06-
EFFECTIVE: September 15 2006ISSUED: August 14 2006
~~~~OUNT A
C. No.Original Sheet No. 21.
ELECTRIC SERVICE SCHEDULE NO. 21 - Continued
Energy Conservation Measures : (Continued)
Supplemental Measures - Electric Heating System Required (continued)
Timed thermostats on centrally controlled multi-room heating/cooling systems
except when used with heat pumps. Heat anticipating type thermostats for zonal
electric resistance heating systems.
Additional Measures - No Electric Heating System Requirement:
Pipe insulation, energy efficient showerheads and aerators where electric water
heaters are present.
Compact fluorescent light bulbs applicable in all homes - limit 8 Energy Star
certified bulbs per home placed in fixtures that are on 2 hours or more per day.
Existing Refrigerator models with annual usage listed in the Weatherization
Assistance Program Technical Assistance center database as 900 kWh or greater
may be replaced with an Energy Star model with estimated annual consumption of
500 kWh or less. Replaced refrigerators must be removed and recycled in
accordance with EP A guidelines.
Provisions of Service for Energy Conservation Service to Low Income Customers
An Energy Audit must be completed by the Agency prior to installation of the
Major Measures by the Agency.
Agency must qualify residential customers for assistance using the Federal Low
Income guidelines.
Installation shall meet Federal, State and local building codes.
Measures installed under this schedule shall not receive financial incentives from
other Company programs.
Agency shall inspect the installation to insure that the weatherization meets or
exceeds required specifications.
(Continued)
Submitted Under Advice Letter No. 06-
ISSUED: August 14 2006 EFFECTIVE: September IS, 2006
~ ~\;oo
~ aUNT AIN
I.P.C. No.Original Sheet No. 21.
ELECTRIC SERVICE SCHEDULE NO. 21 - (Continued)
Provisions of Service for Energy Conservation Service to Low Income Customers
(Continued)
Company may audit Agency weatherization and financial records and inspect the
installations in dwellings of customers receiving weatherization under this program.
Company shall pay the Agency the amount established under the terms of their
contract when provisions of this schedule have been met.
ELECTRIC SERVICE REGULATIONS: Service under this schedule is subject to the
Electric Service Regulations of the Company on file with and approved by the Idaho Public Utilities
Commission, including future applicable amendments and additional regulations prescribed by regulatory
authorities.
Submitted Under Advice Letter No. 06-
ISSUED: August 14 2006 EFFECTIVE: September 15 2006
PAC-06-10/Rocky Mountain Power
December 11 , 2006
CAP AI Data Request 2
CAP AI Data Request 2
What is the source document that PacifiCorp relies upon to determine which
weatherization measures are eligible for Company funding under the low-income
weatherization program?
Response to CAP AI Data Request 2
Rocky Mountain Power relies on documentation from agency and CAPAI staff to
ensure that all United States Department of Energy approved electric efficiency
measures are included in the Company s low income weatherization program
tariff. The program filing made in September 2005 was based on information
received from Chris Hecht, formerly of CAP AI, and included all United States
Department of Energy approved electric efficiency measures that PacifiCorp was
aware of, based on information provided by CAP AI.
PREP ARER: Becky M. Eberle, Product Manager
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs
PAC-06-10/Rocky Mountain Power
December 11 2006
CAP AI Data Request 3
CAPAI Data Request 3
Please produce a copy of any source document identified in response to the
preceding Production Request.
Response to CAP AI Data Request 3
Included as Attachment CAPAI 3 is a table provided by CAPAI in May 2005
which illustrates measures allowed by the United States Department of Energy
and the Rocky Mountain Power program at that time.
PREPARER: Becky M. Eberle, Product Manager
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs
PAC-06-10/Rocky Mountain Power
December 11 2006
CAP AI Data Request 3
CAPAI Data Request 3
Please produce a copy of any source document identified in response to the
preceding Production Request.
Response to CAP AI Data Request 3
Included as Attachment CAPAI 3 is a table provided by CAPAI in May 2005
which illustrates measures allowed by the United States Department of Energy
and the Rocky Mountain Power program at that time.
PREP ARER: Becky M. Eberle, Product Manager
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs
IDAHO
P AC-O6-
SCHEDULE 21 FUNDING STRUCTURE
ROCKY MOUNTAIN POWER
CO MMUNITY A CTI 0 N P AR TNERSHIP
ASSOCIA TION OF IDAHO (CAP AI)
DATA REQUEST
TT A CHMENT
CAP AI 3
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PAC-06-10/Rocky Mountain Power
December 11 2006
CAP AI Data Request 4
completed. Some building codes may require ground cover when
floor insulation is installed.
6. Water heater repair or replacement
Replacing an electric water heater with another electric water heater is
load retention and so Rocky Mountain Power has not included this in
any list of funded programs.
7. Furnace repair or replacement
Replacing an electric furnace with another electric furnace is load
retention and so Rocky Mountain Power has not included this in any
list of funded programs.
8. Health & safety measures
Prior to any commitment to fund such measures with weatherization
funds, clarification as to health and safety measures that relate to
electric usage and efficiencies is needed in order for Rocky Mountain
Power to respond adequately.
PREP ARER: Becky M. Eberle, Product Manager
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs
PAC-06-10/Rocky Mountain Power
December 11 2006
CAPAI Data Request 5
CAPAI Data Request 5
For each of the past ten years, please identify every year, if any, that the two
eastern Idaho Community Action agencies involved in the Company s low-
income weatherization program fully exhausted the total annual amount of
funding appropriated for that program?
Response to CAPAI Data Request 5
Rocky Mountain Power is only able to access data from 1998 through 2005. The
annual funding was not exhausted during this time period.
PREP ARER: Becky M. Eberle, Product Manager
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs
PAC-06-10/Rocky Mountain Power
December 11 , 2006
CAP AI Data Request 6
CAP AI Data Request 6
For each of the past ten years, please provide the percentage oflow-income
weatherization funds expended as a percentage ofthe total amount appropriated
for that year?
Response to CAP AI Data Request 6
Rocky Mountain Power is able to provide this information for 1998 through 2005
as follows:
1998 = 98%
1999 = 34%
2000 = 90%
2001 = 54%
2002 = 61 %
2003 = 22%
2004 = 40%
2005 = 37%
Additionally, the annual funding available from Rocky Mountain Power increased
by 1/3 in late 2005 , and to date the agencies have billed for 92% of that amount in
calendar year 2006.
PREP ARER: Becky M. Eberle, Product Manager
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs
P AC-06-O/Rocky Mountain Power
December 11 , 2006
CAP AI Data Request 7
CAP AI Data Request 7
Please explain why PacifiCorp s percentage of funding for each low-income
weatherization project should be lower than either Idaho Power Company or
AVISTA?
Response to CAPAI Data Request 7
Rocky Mountain Power does not know how the structure or funding of programs
is determined for other companies.
PREPARER: Brian S. Dickman, Manager, Idaho Regulatory Affairs
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs
PAC-06-10/Rocky Mountain Power
December 11 2006
CAP AI Data Request 8
CAPAI Data Request 8
On page 7 of his direct testimony, Company witness Brian Dickman contends that
an increase in the percentage of funding per project by PacifiCorp will actually
reduce the total number of homes weatherized under the low-income
weatherization program.
Regarding this contention, please respond to each ofthe following questions:
1 )Does the contention rely on the assumption that PacifiCorp is currently
funding 50% of all DOE approved weatherization measures actually
installed on the project?
Does this contention assume that the eastern Idaho community action
agencies exhaust all of the funding provided by PacifiCorp for any given
fiscal year?
Response to CAP AI Data Request 8
No. The contention assumes that Rocky Mountain Power is currently
funding 50% of approved measures as listed in Schedule 21. When
matching Federal funds are exhausted, Rocky Mountain Power funds
100% of approved measure installation.
Yes. Because the Company cannot predict the number of homes that will
receive services in a given year, the Company assumes the program will
be fully utilized for analysis purposes.
An example of the number of homes completed ifthe average total cost
per home is $3 000 using Company rebates of50%, 85% and 100% with
an annual funding allotment from Rocky Mountain Power of $150 000 is
as follows:
50% Reimbursement = 100 homes
85% Reimbursement = 59 homes
100% Reimbursement = 50 homes
PREP ARER: Brian S. Dickman, Manager, Idaho Regulatory Affairs
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs
P AC-06-O/Rocky Mountain Power
December 11 2006
CAP AI Data Request 9
CAPAI Data Request 9
On page 6, lines 19-, of his direct testimony, Company witness Brian Dickman
states that the low-income weatherization program "narrowly passed the Utility
Cost Test under the Integrated Resource Plan ("IRP") Decrement approach for
quantifying the expected benefits.
Regarding this contention, please answer the following questions:
Does this assume that PacifiCorp is actually funding 50% of all project
costs?
Does this assume that actual project costs when the study was conducted
was the $1 500.00 cap that has since been eliminated?
Response to CAP AI Data Request 9
1 )The study assumes that Rocky Mountain Power funds 50% of all costs
eligible for reimbursement under Schedule 21.
The study assumes that the average cost per home is $2 744; therefore
Rocky Mountain Power would fund $1 372 and the $1 500 cap is not
relevant for the study.
PREP ARER: Brian S. Dickman, Manager, Idaho Regulatory Affairs
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs
P AC-06-O/Rocky Mountain Power
December 11 , 2006
CAP AI Data Request 10
CAPAI Data Request
On page 6, line 23 through page 7, line 3, Company witness Brian Dickman
testifies that "(a)n increase in the Company s reimbursement would mean a larger
percentage of program costs would be covered from funds collected through
Schedule 191 and a smaller percentage through federal tax funds.
Please provide all proof, including the production of all documents or other
physical evidence, supporting this contention.
Response to CAPAI Data Request
The statement is based on the reasoning that ifthe Schedule 21 sharing percentage
is increased but the cost of weatherizing homes remains the same, a higher
proportion ofthe cost to weatherize homes served by Rocky Mountain Power
would be reimbursed by the Company.
PREPARER: Brian S. Dickman, Manager, Idaho Regulatory Affairs
SPONSOR:Brian S. Dickman, Manager, Idaho Regulatory Affairs