20121121PAC Reply Comments.pdf

'ROCKY MOUNTAIN
' POWER
A DIVISION OF PACIFICORP 201 South Main, Suite 2300
101LNOV2I AMII: 11 Salt Lake City, Utah 84lll
November 21, 2012
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Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Re: CASE No. GNR-E-12-01
IN THE MATTER OF THE COMMISSION'S INQUIRY INTO THE
COST-EFFECTIVENESS AND FUNDING OF LOW INCOME
WEATHERIZATION AND ENERGY CONSERVATION PROGRAMS
FOR ELECTRIC UTILITIES
Dear Ms. Jewell:
Please find enclosed for filing seven copies of Rocky Mountain Power's reply comments in
the above referenced matter
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
AT.ey K. Larsen
Vice President, Regulation
Enclosures
DANIEL E. SOLANDER
SENIOR ATTORNEY
ROCKY MOUNTAIN POWER
201 SOUTH MAIN, SUITE 2300
SALT LAKE CITY, UT 84111
[phone]
[phone]
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TfliT1ES COMMISSi0
IDAHO BAR NO. 8931
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
INQUIRY INTO THE COST-EFFECTIVENESS
AND FUNDING OF LOW INCOME
WEATHERIZATION AND ENERGY
CONSERVATION PROGRAMS FOR
ELECTRIC UTILITIES
) CASE NO. GNR-E-12-01
)
) REPLY COMMENTS
)
)
)
)
COMES NOW PacifiCorp, dba Rocky Mountain Power ("the Company"), by
and through its attorney, provides reply comments on the Idaho Public Utilities
Commission Staff's low income weatherization and energy conservation education
report.
PROCEDURAL BACKGROUND
Idaho Power Company, Avista Utilities, and Rocky Mountain Power offer low-
income weatherization programs and energy conservation education programs. During
2011 all three utilities had general rate cases pending before the Commission. Questions
were raised in each of these proceedings on how best to determine each utilities
appropriate funding level and how to accurately assess cost-effectiveness and customer
need.
REPLY COMMENTS OF - 1 - November 21, 2012
ROCKY MOUNTAIN POWER
On February 15, 2012, the Commission initiated this generic proceeding and
scheduled a public workshop for March 19-20, 2012, to explore the implementation, and
evaluation of utility low-income weatherization and energy conservation education
programs. The workshop occurred as scheduled. At the workshop Staff stated its
intentions to prepare draft comments which would be circulated to the participating
parties for comments. Staff considered parties' comments and reflected many of those
comments in its report discussing findings and recommendations.
REPLY COMMENTS
The Company would like to express its appreciation and acknowledge the efforts
of all parties in the collaborative effort to develop greater consistency around how Low
Income Weatherization Assistance ("LIWA") program evaluations are conducted and
program performance (cost-effectiveness guidelines and considerations) is measured.
Also for the discussion and consideration on customer need, conservation education, and
appropriate funding levels. The Company supports many of the proposals summarized in
Staffs report. However, in addition to a correction regarding Rocky Mountain Power's
treatment of LIWA in our 2011 annual report, the Company continues to have concerns
with some of the recommendations and wants the Commission to be aware of those
concerns.
The Company would like to note a correction to Staffs report regarding the
treatment of costs associated with CAPAI production requests in the calculation of the
Company's 2011 program cost-effectiveness results. Footnote 19 on page 12 of Staffs
report reads:
"RMP's TRC of 0.74 does not include the costs of responding to CAPAI' s production
requests in either Case No.PAC-E- 12-11 or Case No. PAC-E-12-13, but it does include the
cost of responding to Staff's production requests and all other regulatory costs associated with
REPLY COMMENTS OF -2- November 21, 2012
ROCKY MOUNTAIN POWER
those cases. Evaluation costs are also excluded from the 0.74 because they are captured at the
portfolio level."
The Company wishes to point out that the TRC of 0.74 does include the Company's costs
of responding to CAPAI's productions requests in both those cases, as well as the costs of
Staff's production requests. The TRC of 0.74 does exclude program evaluation costs
which are included only at the portfolio level. If the costs of CAPAI's production request
had been excluded, the TRC would improve to 0.87 1 .
The Company also wishes to comment and/or raise concerns regarding
Recommendations 12, 16, 17, and 18.
Recommendation 12 focuses on evaluation methods. This recommendation
states: "Staff recommends that utilities vary the independent contractors hired to evaluate
these programs". The Company recognizes the value of rotating evaluators and has
recently hired a second firm to perform the commercial and industrial evaluations for a
multi-year contract. Procurement of evaluation services is subject to a competitive bid
process. If utilities are required to rotate evaluators, without consideration of cost, the
evaluations may result in higher overall costs and lower benefit to cost ratio for the
portfolio raising risks associated with prudency.
Recommendation 16 identifies a minimum of five factors that should be analyzed
before determining whether an increase in LIWA funding is appropriate, provided a
program is first determined to be cost-effective.
The Company recognizes the need and fully supports funding LIWA program.
However, the Company shares similar concerns about CAPAI's database that Staff
Reference Rocky Mountain Power 2011 Energy Efficiency and Peak Reduction Annual Report - Idaho,
page 25 Table 13.
REPLY COMMENTS OF -3 - November 21, 2012
ROCKY MOUNTAIN POWER
summarized in its report. When the Company requested the report that CAPAI relied
upon to claim significant increases in the participant waiting list in Case No. PAC-E-12-
12 CAPAI was unable to replicate the report nor were they willing to provide any data to
support their claims. The Company believes CAPAI should be required to provide
meaningful reporting information as part of the justification for funding.
Absent reliable data Staff developed five factors that they believe should be
considered to determine funding. The first item on that list is dependent on CAPAI's
database. The Company recognizes the Commission has no jurisdiction over CAPAI,
however if CAPAI is asking the Commission to set funding levels they should be
required to demonstrate some level of need. At a minimum the Company would hope that
CAPAI would commit to improve the accuracy and reliability of its data and be willing to
provide an annual report to share that information with the utilities that are funding
CAPAI's programs as well as Staff.
The Company does not believe the use of factor 3 which is based on rate increases
is relevant to determining weatherization need or in addressing utility funding. Also if the
Commission determines that it is appropriate to increase LIWA funding Rocky Mountain
Power would respectfully request that the Commission order an increase in the
Company's Schedule 191 Customer Efficiency Service Rate at the same time as funding
increase is implemented.
Recommendation 17 is closely related to Recommendation 16. Funding should be
contingent on reasonable assurances that the program is capable of being delivered cost-
effectively.
REPLY COMMENTS OF -4 - November 21, 2012
ROCKY MOUNTAIN POWER
Recommendation 18 would adjust the Company's funding for Low Income
Energy Conservation Education (ConEd) from a total of $50,000 to $25,000 a year.
Rocky Mountain Power supports a meaningful ConEd program and suggests funding
should be adjusted to be up to $25,000 per year pending program results indicating funds
are fully utilized and program effectiveness is proven. If the agency was not able to
utilize the fill amount in one year the next year's contribution would be $25,000 less any
unspent funds from the previous year. Rocky Mountain Power committed to a one-time
amount of $50,000 in 2009, to date the kits from those funds has not been fully utilized.
The Company thanks Staff for its work and the Commission for the opportunity to
comment on the Staff's report and looks forward to further refining the recommendations
and strategies to improve the consistency of approach and financial performance of the
utilities Low Income Weatherization Programs.
Respectfully submitted this 21st day of November 2012.
aniel E. Solande *
Senior Attorney
Rocky Mountain Power
REPLY COMMENTS OF -5 - November 21, 2012
ROCKY MOUNTAIN POWER