20121023Report.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S )
INQUIRY INTO THE COST-EFFECTIVENESS ) CASE NO. GNR-E-12-01
AND FUNDING OF LOW INCOME )
WEATHERIZATION AND ENERGY ) STAFF REPORT
CONSERVATION PROGRAMS FOR )
ELECTRIC UTILITIES )
The Staff of the Idaho Public Utilities Commission submits this report on the low-
income weatherization and energy conservation education programs offered by electric utilities.
PROCEDURAL BACKGROUND
Idaho Power Company, Avista Utilities, and Rocky Mountain Power Company offer
low-income weatherization programs and energy conservation education programs. In recent
rate cases, questions surfaced about how to best determine each utility's appropriate level of
program funding. In particular, concerns arose about how such programs are to be accurately
assessed for cost-effectiveness and overall customer need. The Commission issued an Order in
each case instructing the companies to participate in public workshops to resolve these issues.
See Order No. 32371, Case No. AVU-E/G-1 1-01; Order No. 32426, Case No. IPC-E-1 1-08;
Order No. 32432, Case No. PAC-E-1 1-12; and Order No. 32440, Case No, PAC-E-1 1-13.
On February 15, 2012, the Commission issued a notice that initiated this generic case
and scheduled a March 19-20, 2012 public workshop at which the utilities, interested persons,
and Commission Staff were to "explore in greater detail issues related to the funding,
STAFF REPORT 1 OCTOBER 23, 2012
implementation, and evaluation of utility low-income weatherization and energy conservation
education programs." After the workshop occurred, Commission Staff was to prepare and
submit a report discussing Staff's findings and recommendations. The Commission said it would
then schedule further proceedings and hearings as needed. See Notice of Public Workshop.
The workshop occurred as scheduled. Staff now submits its Report discussing its
findings and recommendations.
STAFF REPORT
A. Procedural Recommendations.
Staff recommends that the Commission process this case under modified procedure.
After the workshop, Staff provided participants with a draft of Staff's report and asked them to
provide feedback before Staff finalized and filed it. Now that Staff has obtained that feedback
and filed the final report, Staff recommends that the Commission set deadlines for interested
parties to file written comments on the report, that the Staff's reply comments be due fourteen
days later, and that any intervenor-funding requests be filed fourteen days after Staff's reply.'
B. Substantive Findings and Recommendations.
Staff's substantive findings and recommendations are attached as Attachment A.
Respectfully submitted this 28 day of October 2012.
ja :/ A,
KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
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'In Order 32440, Case No. PAC-E-1 1-13, the Commission stated: "The Commission notes that it will entertain a
timely petition for intervenor funding filed by CAPAI following the conclusion of the public workshops ordered in
this case. Because the Commission views this case as a precursor to the generic investigation and public workshops
ordered in this case, PAC-E-1 1-13, and the Company's last general rate case, PAC-E-ll-l2, CAPAI may submit a
request that includes any fees and/or costs incurred by the organization associated with this case."
STAFF REPORT 2 OCTOBER 23, 2012
Idaho Public Utilities Commission Staff
Report on Low Income Weatherization and
Energy Conservation Education Programs
Case No. GNR-E-12-01
Executive Summary
The last year was challenging for Idaho's low income weatherization programs. The
Community Action Partnership Association of Idaho (CAPAI) asked the Commission to approve
funding increases for low income weatherization programs in Idaho Power Company's and
Rocky Mountain Power's general rate cases. See IPC-E-11-08 and PAC-E-11-12. In addition,
Rocky Mountain Power asked the Commission to let it stop evaluating its low income program.
See PAC-E- 11-13. Commission Staff opposed all three requests due to cost-effectiveness and
funding-methodology concerns, and recommended that the Commission schedule public
workshops to resolve these issues. In AVU-E-11-01/AVU-G-11-01, the Commission approved a
funding increase for Avista Utilities' Low Income Energy Conservation Education Program.'
The Commission ultimately directed interested stakeholders to meet at a workshop to
discuss the cost-effectiveness and funding-methodology issues. On March 19-20, 2012, Staff,
utilities, CAPAI, and Community Action Partnership (CAP) agencies participated in the
workshop. This report attaches the workshop agenda as Appendix 1; program-comparison
matrices updated from the workshop as Appendix 2; a list of possible non-energy benefits as
Appendix 3; and a workshop-participant list as Appendix 4. It also presents Staff's findings and
recommendations arising from the workshop and subsequent discussions with stakeholders.
Staff is primarily concerned about the cost-effectiveness of utility-funded low income
weatherization programs in Idaho. Two of the three utilities' programs are not cost-effective
without non-energy benefits, and the third program's cost-effectiveness is in doubt. Despite
these concerns, Staff is reluctant to recommend cuffing established programs that help low
income customers control their energy bills. This is especially true because the Low Income
Home Energy Assistance Program (LIHEAP) recipient list shows that the need for these
programs far outpaces their funding.2
Of the three weatherization programs, only Idaho Power's program claims to be cost-
effective without non-energy benefits. But Staff doubts Idaho Power's program is as cost-
effective as it appears; Idaho Power's 1.96 cost-effectiveness ratio for the Total Resource Cost
(TRC) test in 2011 relies on what Staff believes are overstated energy savings estimates from a
U.S. Department of Energy (DOE)-approved modeling software, the EA4 and its recent update,
the EA5.
Impact evaluations of Rocky Mountain Power and Avista's programs found that the EA4
and EA5 software significantly over-estimated energy savings. Rocky Mountain Power's impact
evaluation found that only 65% of the EA4's expected savings were actually achieved. Avista's
evaluation found that only 27% of the expected savings were achieved. Idaho Power is in the
'The Commission approved an increase from $40,000 to $50,000 effective October 1, 2011.
2 LIHEAP is a federally-funded bill payment assistance program for low-income households.
process of conducting its first low income weatherization impact evaluation and expects to
publish the results in spring 2013.
Rocky Mountain Power's reported cost-effectiveness for 2007-2009 (TRC is 0.79) is
likely the most accurate valuation of a reasonably well-run low income program among the three
utilities. Staff agrees, however, with some of CAPAI expert, Roger Colton's, analysis showing
that the energy savings produced by Rocky Mountain's program are probably understated due to
inadequate billing analysis controls between the participant and non-participant (control) group
during the impact evaluation. A more accurate assessment of energy savings would improve the
cost-effectiveness of Rocky Mountain Power's program, and might demonstrate that it is cost-
effective.
Avista's electric low income program is the most troubling of the three low income
weatherization programs. Cost-effectiveness for the electric low income program fell from 0.66
TRC in 2010 to 0.43 in 201 1.3 This is problematic for many reasons, but primarily because the
0.66 TRC was based on energy savings previously verified through an impact evaluation .4 It is
unclear how the cost-effectiveness could have dropped so precipitously when verified energy
savings were used in both years. Based on the Cadmus process report of Avista's low income
weatherization program, Staff believes that improving the CAP agency and Avista's program
implementation could significantly increase program cost-effectiveness. This report specifies
several improvements, including the prioritization of utility funding constraints over more
generous federal guidelines and reducing the percentage of each project funded by Avista from
100% to 85%, that could increase cost-effectiveness and justify continued Staff support for
Avista's electric low income program.
Avista's natural gas low income program's TRC increased from 0.18 to 0.63 between
2010 and 2011, but the program still struggled with cost-effectiveness. In late May 2012, Avista
received an update to its natural gas Integrated Resource Plan (IRP) in which the supply side
costs avoided by demand-side management (DSM) programs fell by 50% due to low natural gas
prices. The extremely large decrease in avoided costs proved insurmountable to building a cost-
effective gas portfolio. Staff's analysis found that applying the new avoided cost rate to 2011
cost-effectiveness calculations resulted in a TRC of 0.43 and a Utility Cost Test (UCT) of 0.29
for Avista's low income weatherization program. Even with improved implementation and the
cost-effectiveness calculation recommendations included in this report, it is extremely unlikely
that the low income gas program would pass the TRC or UCT. In Order No. 32650, the
Commission approved Avista's request to suspend its entire gas DSM portfolio, including its gas
low income program.5
'Savings estimates from the 2010 Cadmus impact evaluation were applied to 2011 program activities.
"Large drops in cost-effectiveness can occur after a program's first impact evaluation.
Order No. 32650 was issued in Case No. AVU-G-12-03/AVU-G-12-06 on September 25, 2012. The Company will
discontinue its natural gas low income weatherization program on December 31, 2012, when its current
weatherization contract with CAP expires.
2
IPUC Staff Low Income Report
Attachment A
Besides improving implementation, Staff believes all three utilities could modify their
low income cost-effectiveness calculations to improve accuracy and more completely assess
program cost-effectiveness. Staffs recommended modifications will decrease some programs'
reported cost-effectiveness and likely increase other programs' reported cost-effectiveness. A
complete list of Staffs recommendations is included below.
One of the main issues discussed during the recent rate cases and the workshop was
determining a funding methodology to assess the level of low income weatherization funding.
Staff recommends that a combination of factors be considered for funding decisions. Most
importantly, Staff believes that in order for a utility's funding to be increased, it must be shown
that the program is cost-effective. No program should receive a funding increase if it is not cost-
effective according to the criteria outlined in this report. After a program is determined to be
cost-effective, at least five factors should be examined to determine if a funding increase is
appropriate.
1.Funding could be increased if the list of not-previously weatherized homes waiting
for weatherization (as indicated by the LIHEAP data) has increased significantly
since the last review.
2.Funding could be increased if a utility's program provides significantly less funding
on a per-capita basis than the cost-effective program of another utility operating
within the state of Idaho with comparable poverty levels in its service territory.
3.Funding could be increased if the utility is awarded a significant base rate increase.
Rate increases impact low income customers more adversely than other customers,
therefore it could be appropriate to provide increased funding for low income
weatherization when rates increase.
4.Funding could be increased if the utility does not have sufficient funds to acquire the
annually achievable low income energy savings potential as indicated by the utility's
most recent Conservation Potential Assessment (CPA).6 This criterion is similar to
how utilities fund other DSM programs.
5.Funding should not be increased if a utility's CAP agencies have been unable to
spend all of the available utility funding in the previous year.
While these criteria are not a rigid funding mechanism, they do respond to the
Commission's order to incorporate multiple factors into a funding methodology, provide parties
with a more clear understanding of how Staff will analyze funding levels, and provide discretion
to establish funding levels that are specific to each utility. This methodology will also limit the
possibility of unintended consequences that a strict metric might impose, such as reduced
funding amounts if the LIHEAP list of not-previously weatherized homes were to decline.
Incorporating the findings of each utility's CPA will also more closely align low income
6 Conservation Potential Assessments determine the amount of technical, economical, and achievable DSM
resources available in a utility's service territory.
3
IPUC Staff Low Income Report
Attachment A
weatherization funding levels with the method used to determine funding levels for other DSM
programs.
Staff believes that all three electric low income weatherization programs will be either
cost-effective or nearly cost-effective after the implementation and cost-effectiveness calculation
adjustments recommended in this report are adopted. Consequently, Staff recommends that
funding levels for these programs remain at current levels until the uncertainties surrounding
cost-effectiveness are resolved.
Staff recommends that a possible funding increase for Idaho Power be reviewed after the
results of its impact evaluation are published in spring 2013. This will allow parties to review
the cost-effectiveness of Idaho Power's program when those ratios include verified energy
savings, rather than the estimates generated by the EA5 software.
Staff recommends that a possible funding increase for Rocky Mountain Power be
reviewed after its new data collection system is fully implemented and after the 2012 program
data has been analyzed for cost-effectiveness under the recommendations in this report. Staff
anticipates that both of these requirements will be met when Rocky Mountain Power publishes
its annual DSM report in spring 2013.
Based on the lower cost-effectiveness ratios and more extensive implementation
recommendations, Staff recommends that a funding review for Avista's low income
weatherization program be delayed until at least 2014. Staff believes that the extra time will
allow Avista and its CAP agency to implement and review program changes for impacts on cost-
effectiveness, and make sure that those improvements persist.
Staff believes that Low Income Energy Conservation Education (Con-Ed) Programs are
separate, stand-alone programs from weatherization. Although the Con-Ed and weatherization
programs are complementary, the cost of and energy savings produced by the Con-Ed Programs
should not be included in cost-effectiveness calculations for low income weatherization
programs. Moreover, since Con-Ed programs are similar to other energy education programs in
that they frequently do not create measurable energy savings, Staff believes that standard cost-
effectiveness tests are not meaningful and therefore should not be applied when evaluating Con-
Ed programs.
The Con-Ed programs are still developing, so Staff will carefully review the findings of
CAPAI's evaluation of the Con-Ed program funded by Rocky Mountain Power, which will be
published in June 2013. Staff recommends continuing the current funding levels for Idaho
Power and Avista's Con-Ed programs. The two CAPs receiving funding from Rocky Mountain
Power have found it difficult to spend the $50,000 currently authorized, so Staff recommends
that funding should be reduced to $25,000. Lastly, Staff believes that the Commission intended
that each utility, including Rocky Mountain Power, fund its Con-Ed program annually.
4
IPUC Staff Low Income Report
Attachment A
Staff Recommendations
Recommendation 1: Staff recommends that Idaho Power use its third-party impact
evaluation results to inform the savings estimates from the EA5 modeling software. After this
adjustment, all three companies will be using verified energy savings estimates in their cost-
effectiveness calculations. Many, but not all, impact evaluations find that actual savings are
lower than the previous estimates. If this is the case for the energy saving produced by Idaho
Power's program, this adjustment will decrease the cost-effectiveness of Idaho Power's program.
Recommendation 2: Staff agrees that customers who qualify for LIHEAP bill assistance
and who are then added to the CAP agency weatherization lists are extremely unlikely to have
sufficient funds to weatherize their homes. Staff further agrees that landlords have little
incentive to pay for energy efficiency measures when they are not responsible for paying the
energy bill. Therefore, Staff recommends that utilities claim 100% Net-To-Gross for this
program. This adjustment will benefit the cost-effectiveness of Idaho Power's program.
Recommendation 3: Staff recommends that utilities claim 100% of the energy savings
produced by each low income weatherization project for which they provide funding. This
adjustment will increase the cost-effectiveness of Idaho Power's program.
Recommendation 4: Staff recommends that Idaho Power develop a method to include
indirect administrative overhead costs in its low income program cost-effectiveness in a manner
that approximates how these expenses are assigned to supply-side resources. This adjustment
may decrease the cost-effectiveness of Idaho Power's program.
Recommendation 5: Requiring low income programs, which often have smaller budgets
and energy savings relative to other DSM programs, to incorporate the full cost of an evaluation
in a single year could lead to extremely lean evaluation budgets, and possibly lower quality
evaluations. Staff recommends that utilities have the option to incorporate program evaluation
costs at the jurisdictional portfolio level rather than the program level. Alternatively, Staff
recommends that utilities have the option to amortize evaluation costs over the two to three years
between evaluations for program level cost-effectiveness calculations.
Recommendation 6: Staff does not oppose Rocky Mountain Power and Avista's use of a
10% conservation preference adder in their low income DSM cost-effectiveness calculations.
Use of the adder is widely accepted by state utility regulatory commissions on a regional basis
and its use is included in the Northwest Power Act. Staff would not oppose Idaho Power's use
of this adder in its low income cost-effectiveness calculations. Including a 10% conservation
preference adder would increase the cost-effectiveness of Idaho Power's low income
weatherization program.
5
IPUC Staff Low Income Report
Attachment A
Recommendation 7: Staff recommends that payment-related non-energy benefits, such as
reductions in utilities' arrearages and bad debt, as well as collection, disconnection, and
reconnection expenses that may accrue when low income customers' bills are reduced through
weatherization, be quantified and included in cost-effectiveness analyses when possible.
Staff recommends excluding economic non-energy benefits and non-energy benefits that
accrue to program participants because they have not yet been rigorously quantified. These
include increased property values, extended lives of weatherized dwellings, health impacts,
takeback, and increased comfort.
Including quantifiable payment-related non-energy benefits will increase the cost-
effectiveness of low income programs over what they otherwise would have been. However,
excluding the economic non-energy benefits already included in Rocky Mountain Power's
Cadmus evaluation will decrease that program's cost-effectiveness.
Recommendation 8: Staff recommends that Avista continue quantifying utility-funded
health, safety, and repair measures as a dollar of non-energy benefits for each dollar of cost.
Staff recommends that Idaho Power and Rocky Mountain Power apply this methodology to their
cost-effectiveness calculations. This adjustment will increase Idaho Power and Rocky Mountain
Power's cost-effectiveness.
Recommendation 9: Staff recommends that the utilities have the option to claim one
dollar of non-energy benefits for each dollar of federal funds invested in health, safety, and
repair measures. Staff recommends that this adjustment remain optional since utilities may have
difficulty collecting accurate data on federally funded measures and because cost-effectiveness
manuals provide discretion on whether federal funds should be included as a cost in the TRC.
Staff's recommendation is consistent with the attribution of federal funds in other DSM
programs, TRC methodology, and treatment of energy savings. If adopted, this adjustment is
likely to increase all three programs' cost-effectiveness, although the exact impact is unknown
because the utilities have not previously tracked the amount of federal funds spent on health,
safety, and repair measures in utility-funded low income weatherized homes.
Recommendation 10: Staff supports Avista' s proposal to use and Idaho Power's current
use of a modified discount rate for participant benefits. However, the only type of participant
benefits Staff has supported for low income weatherization programs are health, safety, and
repair measures that, using Staff's recommended method, are already valued on a NPV basis.
Therefore, applying a modified discount rate to these benefits would have no effect on cost-
effectiveness.
Recommendation 11: Staff does not recommend constructing a specific cost-
effectiveness test for low income programs.
6
IPUC Staff Low Income Report
Attachment A
Recommendation 12: Staff recommends that the utilities incorporate additional
evaluation methods to inform or complement billing analyses for low income programs
whenever possible. If non-participants are used as the control group in a billing analysis, Staff
recommends rigorous controls between the two groups, which may include but not necessarily be
limited to, previously weatherized homes, service disconnections, economic decline and rate
increases, and households prioritized for weatherization, including emergencies. Incorporating
these controls and/or other evaluation and billing analysis methods may increase all three
programs' cost-effectiveness. Staff also recommends that utilities vary the independent
contractors hired to evaluate these programs.
Recommendation 13: Staff believes that Idaho Power should continue to comply with
Order No. 29505 which directs the Company to carry over unspent low income weatherization
funding from base rates into the following year.7 Staff also recommends that Avista and Rocky
Mountain Power continue to use any unspent low income funds for other DSM programs,
consistent with current practice for all programs funded through DSM tariff riders.
Recommendation 14: Staff recommends that Rocky Mountain Power continue the
pending and future upgrades to its low income weatherization data management system. Staff
also recommends that Avista and Rocky Mountain Power consider adopting Idaho Power's
scalable approach to paying for measures to allow for more strategic and cost-effective
investments, if Idaho Power's impact evaluation demonstrates that this technique was effective.
Recommendation 15: Staff recommends that Avista pay no more than 85% of the cost
per project and up to 100% of the cost per measure. This adjustment will increase the cost-
effectiveness of Avista's program and facilitate cost-effectiveness comparisons between the three
utilities.
Recommendation 16: Staff recommends that no program should receive a funding
increase if it is not cost-effective according to the criteria outlined in this report. After a program
is determined to be cost-effective, at least five factors should be analyzed to determine if a
funding increase is appropriate.
1.Funding could be increased if the list of not-previously weatherized homes waiting
for weatherization (as indicated by the LIHEAP data) has increased significantly
since the last review.
2.Funding could be increased if a utility's program provides significantly less funding
on a per-capita basis than the cost-effective program of another utility operating
within the state of Idaho with comparable poverty levels in its service territory.
Page 32 of Order No. 29505, Case No. IPC-E-03-13, states "Any unpaid funds shall carry over and be available in
the next year."
7
IPUC Staff Low Income Report
Attachment A
3.Funding could be increased if the utility is awarded a significant base rate increase.
Rate increases impact low income customers more adversely than other customers,
therefore it could be appropriate to provide increased funding for low income
weatherization when rates increase.
4.Funding could be increased if the utility does not have sufficient funds to acquire the
annually achievable low income energy savings potential as indicated by the utility's
most recent Conservation Potential Assessment (CPA). This criterion is similar to
how utilities fund other DSM programs.
5.Funding should not be increased if a utility's CAP agencies have been unable to
spend all of the available utility funding in the previous year.
Recommendation 17: Staff recommends continued funding for Idaho Power, Avista, and
Rocky Mountain Power's low income weatherization programs at current levels. Staff believes
that funding increases requests for Idaho Power and Rocky Mountain Power could be considered
after both companies publish their annual DSM reports in spring 2013. Staff recommends that a
funding increase request for Avista be delayed until at least spring 2014 to allow time to
implement the more extensive program modifications and determine if those modifications
succeed and persist in improving cost-effectiveness.
Recommendation 18: Staff recommends that utilities' annual DSM reports separately
address their Low Income Energy Conservation Education Programs. At a minimum, Staff
expects each report to describe program design, identify target audience(s), gauge the program's
success in meeting its goals, indicate how utility funding was used, and describe how the
program benefits the utility's customers. As with other education programs in which energy
savings are often very difficult to determine, the Con-Ed programs should not be subjected to
standard cost-effectiveness tests like the TRC and UCT. Staff recommends maintaining the
current annual Con-Ed program funding level for Avista and Idaho Power. Staff recommends
adjusting Rocky Mountain Power's funding to $25,000 with the clear understanding that this
amount should be funded annually.
Low Income Weatherization Pro2rams Background and Pro2ram Summary
The Commission has long-supported utility-funded low income weatherization programs.
These programs, however, have characteristics that make program cost-effectiveness, oversight,
and evaluation more difficult than with other utility-funded energy efficiency programs.
Determining program cost-effectiveness is particularly challenging.
Low income weatherization programs primarily differ from other utility DSM programs
in that utilities contract with CAPs to deliver weatherization services to low income customers at
no direct cost to participants. The CAPs also deliver weatherization services through the
8
IPUC Staff Low Income Report
Attachment A
federally-funded Weatherization Assistance Program (WAP) under a contract administered by
the Idaho Department of Health and Welfare. With one exception,8 the CAPs also manage
LIHEAP. Low income applicants automatically qualify for WAP if they own or rent single
family, multi-family, or manufactured homes that qualify for LIHEAP. Experience in running
multiple energy-related benefit programs, the ability to determine income eligibility, and the
capacity to deliver services to low income clients makes the community action agencies uniquely
qualified to administer utility-funded programs targeting low income customers.
This arrangement has worked well for program delivery, but changing circumstances
have raised some concerns. In December 2009, a "Memorandum of Understanding for Prudency
Determination of DSM Expenditures" (MOU) was signed by the Commission Staff and Rocky
Mountain, Avista, and Idaho Power. The MOU at page 6 addresses utility annual DSM reporting
requirements and prudency determination requests:
By performing within these guidelines, assuming there is no evidence
of imprudent actions or expenses, the utility can reasonably expect that
in the ordinary course of business Staff will support full cost recovery of
DSM program expenses.
Page 9 of MOU Attachment No. 1 states Staffs expectations for Cost-Effectiveness
Tests, Methods, and Evaluations as follows:
.... Staff believes that prudent DSM management requires that cost-effectiveness
be analyzed from a wide variety of perspectives, including the ratepayer
impact perspective, and that all programs and individual measures should
have the goal of cost-effectiveness from the total resource, utility, and
participant perspectives. ...If a particular measure or program is pursued
in spite of the expectation that it will not, itself, be cost-effective from
each of those three perspectives, then the annual DSM report should
explain why that measure or program was implemented or continued.
Subsequently, the Commission has stressed the need to evaluate, measure, and verify
DSM programs, which has sharpened utilities' focus on cost-effectiveness. In turn, this has
increased the perceived risk to utilities of potentially not recovering program expenditures that
were not cost-effective using standard cost-effectiveness tests. In 2010, the Commission
increased low income weatherization funding for Rocky Mountain Power and Avista, which
increased the sums that utilities may consider to be at risk. In 2011, CAPAI, acting for the CAP
In Canyon County, the Western Idaho CAP manages LIHEAP and the Canyon County Organization on Aging
(CCOA) administers WAP.
9
IPUC Staff Low Income Report
Attachment A
agencies it represents, renewed efforts to increase program funding, in part due to expected large
decreases in federal funding.
Rocky Mountain Power, Avista, and Idaho Power have tried to reduce administrative
complexity by structuring their low income weatherization programs to dovetail with the DOE's
WAP requirements. Using the DOE framework, each state receiving WAP funding must
establish eligibility criteria, an approved process for determining energy savings and cost-benefit
ratios, and audit procedures to verify compliance with laws, rules, and standards. Although
WAP and utility-funded programs share a goal of saving energy, they use different standards to
justify expenditures on energy-savings measures. Unfortunately, no consensus exists among
utilities, regulatory commissions, or other stakeholders on what factors should be considered,
how factors selected should be measured and verified, or how to value factors that are not more
easily quantified.
Utility Cost-Effectiveness Tests
When Idaho utilities fund DSM programs, they are buying a resource to meet customer
load. The amount of energy saved through a DSM program is equivalent to a generation
resource that does not have to be built or energy that does not need to be bought to meet the load
requirement for all customers. Utilities fund DSM programs when funding them is cheaper, or
more cost-effective, than buying or building the energy resource.
Utilities measure cost-effectiveness using several widely accepted cost-effectiveness
tests: the Total Resource Cost Test (TRC), the Utility Cost Test (UCT), the Participant Cost Test
(PCT), and the Ratepayer Impact Measure (RIM). A cost-effectiveness ratio of 1.0 or greater
means that the program is cost-effective from that perspective.
The TRC and the UCT are the two most important cost-effectiveness tests for a utility-
funded DSM program. The TRC compares a DSM program's "benefits and costs from the
perspective of all utility customers, participants and non-participants, in the utility service
territory."9 The UCT analyzes the program from the "perspective of the utility implementing the
program."°
It is important to understand that the TRC and the UCT compare the benefits of a DSM
program to the utility's avoided cost, not to the retail rate of energy that customers pay.
Therefore, it is possible for a program to be cost-effective from a participating customer's
perspective, but not from the perspective of the pool of ratepayers who fund the program as
measured by the TRC, or from the utility's perspective as measured by the UCT.
Avoided costs are the costs of resources that the utility did not have to build or buy to
meet load because the DSM program produced energy savings. Utilities calculate avoided cost
based on a combination of base-load and/or peaking generation costs as well as the
California Standard Practice Manuel: Economic Analysis of Demand-Side Management Programs and Projects. '° California Standard Practice Manuel: Economic Analysis of Demand-Side Management Programs and Projects.
10
IPUC Staff Low Income Report
Attachment A
purchase/sales price for energy.' Each DSM program has a unique avoided cost depending on
its measures, the savings characteristics throughout the year, and the lifespan of its measures.
Table 1 and Table 2 below outline the benefits and costs included in the TRC and UCT.
Table 1: Total Resource Cost Test'2
TRC Benefits TRC Costs
Energy-related costs avoided by the
utility
Program overhead costs
Capacity-related costs avoided by
the utility
Program installation costs
Additional resource savings (e.g.,
gas and water if utility is electric)
Incremental measure costs (paid by
customer or utility)
Monetized non-energy benefits
Applicable tax credits
Table 2: Utility Cost Test 13
UCT Benefits UCT Costs
Energy-related costs avoided by the
utility
Program overhead costs
Capacity related costs avoided by
the utility
Utility incentive costs
Utility installation costs
Much of the confusion surrounding low income program cost-effectiveness comes from
the differences between how the CAP agencies calculate cost-effectiveness and how the utilities
calculate cost-effectiveness. CAP agencies use an energy modeling software, EA4,14 to
determine the Savings to Investment Ratio (SIR) for the suite of measures considered for
installation in a home. The combination of measures must result in a SIR greater than 1.0 for
those measures to be installed according to CAP agency requirements. A SIR ratio of 1.0 means
that for every dollar invested in measures, a dollar was saved.
But the SIR is based on the customer's retail energy rate and not on a utility's avoided
cost. This means that the SIR measures cost-effectiveness from the program participant's
perspective, not from the perspective of all ratepayers or the utility. As previously described,
"Avoided costs rates for DSM programs are not the same as the avoided costs rate for Public Utility Regulatory
Policies Act (PURPA) projects.
12 California Standard Practice Manuel: Economic Analysis of Demand-Side Management Programs and Projects. 13 California Standard Practice Manuel: Economic Analysis of Demand-Side Management Programs and Projects. 14 The EA4 model was developed for Idaho and has been approved for use by CAP agencies in these programs by
the U.S. Department of Energy. An updated version of this model, the EA5, includes the interactive effects between
measures (such as lighting and heating) and was adopted for use by the CAP agencies in mid-2012.
11
IPUC Staff Low Income Report
Attachment A
using the SIR creates instances where the program appears cost-effective from a participating
customer's perspective,'5 but not from the perspective of all ratepayers as measured by the TRC,
or from the utility's perspective as measured by the UCT.
In addition, third-party independent evaluations of Avista and Rocky Mountain Power's
low income weatherization programs in Idaho have concluded that the EA4 model, which
generates the SIR, appears to significantly overstate energy savings. Avista' s 2011 billing
analysis 16 evaluation found that the energy savings provided to it by its Idaho CAP agency using
the EA4 overestimated program savings by 73% during 2010 and 2011.17 Rocky Mountain
Power's billing analysis of its low income weatherization program found 35% less energy
savings than the EA4 predicted.
As shown in Tables 3 and 4 below, two of the three utility-funded low income
weatherization programs were not cost-effective in 2010 and 2011 under the TRC or UCT.
Idaho Power has the only program that appears to be cost-effective. Of the three programs, only
Idaho Power's energy savings rely entirely on the results of the EA4 or EA5 audit tool and have
not been verified by a third party, independent evaluation. Idaho Power plans to conduct a third-
party impact evaluation of its low income program in 2012 and publish the results in its 2012
DSM Annual Report. Staff expects that Idaho Power's pending impact evaluation may
substantially reduce this program's reported savings and decrease its cost-effectiveness.
Table 3: 2010 Low Income Weatherization_Cost-Effectiveness
Test'8 Idaho
Power
Avista
Electric
Avista
Gas
Rocky
Mountain
TRC 1.66 0.66 0.18 0.70
UCT 1 3.27 0.66 0.18 0.70
Table 4: 2011 Low Income Weatherization_Cost-Effectiveness
Test Idaho
Power
Avista
Electric
Avista
Gas
Rocky
Mountain
TRC 1.96 0.43 0.63 07419
UCT 2.67 0.38 0.54 0.74
The Participant Cost Test (PCT) examines the cost-effectiveness of a program from the participant's perspective.
Since participants in low income weatherization programs receive measures for free, the participant cost-
effectiveness test is meaningless. Thus, all three Idaho utilities report "N/A" for the results of their low income
PCT.
16 A billing analysis uses utility meter data to determine the reduction in energy consumption of a project after the
installation of energy efficiency measures.
Avista 2010-2011 Multi-Sector Electric Impact Evaluation Report, May 25, 2012, conducted by Cadmus.
A TRC or UCT ratio over 1.0 means that the program is cost-effective from that perspective.
19 RMP's TRC of 0.74 does not include the costs of responding to CAPAI's production requests in either Case No.
PAC-E-12-1 I 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 those cases. Evaluation costs are also excluded from the 0.74 because
they are captured at the portfolio level.
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IPUC Staff Low Income Report
Attachment A
The cost-effectiveness of Avista's low income electric program concerns Staff. The
program's TRC declined from 0.66 to 0.43 between 2010 and 2011. Avista's independent
evaluator, Cadmus, published a low income process evaluation 20 of this program in 2010 and an
impact evaluation in 201221 that describes several opportunities for improvement that could
significantly increase cost-effectiveness.
First, Cadmus found that "about 12 percent of participants [use] non-electric or gas
sources as their primary means of heating, [so] Avista' s savings estimates may not be accurate if
assuming electric or gas heating systems in its savings calculations. This especially applies to
shell measure savings calculations." Funding measures that will generate neither natural gas nor
electric savings is clearly detrimental to cost-effectiveness. Since 99%22 of Avista's 2011 low
income energy savings in Idaho came from shell measures, correcting this could substantially
improve cost-effectiveness.
Second, Cadmus found that "28 percent of participants reported changing how they heat
their homes following weatherization work, [therefore] estimated savings for these participants
may not be accurate, given Avista's deemed savings estimates." Cost-effectiveness is hindered
when the program does not account for heating sources that change significantly after
weatherization.
In addition, Staff noticed several differences between measures installed in Idaho and
those installed in Washington where Avista has a much more cost-effective program. Forty-
seven Energy Star products were installed in Washington, but none were installed in Idaho.
Since refrigerators are an Energy Star product and are often a very cost-effective way to produce
energy savings in low income households, their absence in Idaho is noteworthy.
Further, as a dual fuel utility, Avista can fund electric to natural gas furnace conversions
as part of its low income program. Since these conversions reduce electrical consumption, they
are funded by the electric DSM tariff rider. Despite their propensity for cost-effectiveness,
Avista reports that no fuel conversions were installed in Idaho in 2011. Installing fuel
conversions and Energy Star products in Idaho households may help improve the cost-
effectiveness of Avista' s low income weatherization program in Idaho.
Lastly, Staff believes it is necessary to reduce the percentage of funding that Avista
contributes towards each home it weatherizes. Avista currently funds up to 100% per measure
installed in a home, and often 100% of the cost to weatherize a home. In most cases, any cost to
weatherize the home that exceeds available utility funding is federally funded. Under the TRC,
Avista considers federal investments an importation of funds from outside the ratepayer
population. 23 Federal expenditures in an Avista-weatherized home are therefore not captured as
a cost. If Avista funded 85% of the measure cost, and claimed 100% of the savings, cost-
effectiveness would be easier to achieve than under the current arrangement where Avista pays
20 Avista DSM 2011 Annual Report, page 272. 21 Avista 2010-2011 Multi-Sector Electric Impact Evaluation Report, May 25, 2012, conducted by Cadmus. 22 Avista DSM 2011 Annual Report, page 19. 23 Rocky Mountain Power also excludes federal costs from the TRC calculation.
13
IPUC Staff Low Income Report
Attachment A
100% of the measure cost. Neither Rocky Mountain Power nor Idaho Power fund more than
85% of each home they weatherize, so this change would make Avista's program more similar to
the other two utility-funded low income weatherization programs. While this adjustment will
remove some spending flexibility from the CAP, Staff believes that preserving the program,
which depends on cost-effectiveness, warrants the restrictions.
Utility Cost-effectiveness Calculations
Energy Savings
While preparing for the three low income weatherization cases last year, Staff discovered
many differences in the way each company calculates cost-effectiveness. The largest and most
important difference is how each company measures energy savings. As described earlier, Idaho
Power uses the results of the EA4 or EA5 modeling software to estimate energy savings. During
the workshop, Rocky Mountain Power and Avista confirmed that while they also use the EA415,
they both use billing analysis results generated during their impact evaluations to adjust the
EA4/5 results from estimates to actual energy savings.
Staff noted that Idaho Power has yet to conduct an impact evaluation of its program, and
the Company confirmed that the program will receive a third-party impact evaluation this year.
The impact evaluation will likely include a billing analysis, and if feasible, another evaluation
method. If a billing analysis is conducted, Idaho Power points out that the analysis can be done
using a household as its own control group in which the energy consumption of a particular
home is measured before and after weatherization. This is similar to the method used by
Cadmus in Avista' s 2010-2011 low income impact evaluation.
Idaho Power emphasized that even after the impact evaluation, it will continue to use the
EA5 because the Company's scalable method of determining funding amounts per measure
based on the EA5's energy savings estimates has worked well. Staff can support continued use
of the EA5 modeling software as long as the Company adjusts the energy savings used in cost-
effectiveness calculations and acquisition reports to account for the impact evaluation results.
Recommendation 1: Staff recommends that Idaho Power use its third-party impact
evaluation results to inform the savings estimates from the EA5 modeling software. After this
adjustment, all three companies will be using verified energy savings estimates in their cost-
effectiveness calculations. Many, but not all, impact evaluations find that actual savings are
lower than the previous estimates. If this is the case for the energy saving produced by Idaho
Power's program, this adjustment will decrease the cost-effectiveness of Idaho Power's program.
Net-to-Gross Ratio
The net-to-gross (NTG) ratio is applied to the energy savings generated by a program so
that the program results only include savings that occurred because of the energy efficiency
program rather than external factors. The National Action Plan for Energy Efficiency (NAPEE)
states that "...the NTG deducts energy savings that would have been achieved without the
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IPUC Staff Low Income Report
Attachment A
efficiency program (e.g., "free-riders") and increases savings for any "spillover" effect that
occurs as an indirect result of the program."24 Accurate NTG ratios can help determine the
effectiveness of an energy efficiency program.
Since the centerpiece of many energy efficiency programs is incentive money from a
utility in order to install energy efficiency measures, "free-riders" are frequently characterized as
program participants who would have installed the energy efficiency measure without the
incentive. Likewise, "spillover" is understood as people who installed the energy efficiency
measure because of the program's influence, but without receiving an incentive.
The Database for Energy Efficiency Resources (DEER),25 a generally recognized source
for NTG values, recommends claiming an 80% NTG ratio for many standard residential
programs. An 80% NTG ratio means that 20% of the program participants would have installed
the energy efficiency measure without the incentive.
Idaho Power claims 80% NTG for its low income weatherization program, which is the
same figure it claims for its other residential DSM programs. The Company says it uses the
standard residential NTG value for its low income program because Commission Staff has
recommended its use in the past. In contrast, Avista and Rocky Mountain Power claim 100%
NTG for their programs, a figure that CAPAI supports.
At the workshop, Avista, Rocky Mountain Power, and CAPAI expressed confidence that
low income weatherization programs have extremely low, if any, free-ridership. Idaho Power
also agrees that most low income program participants are very unlikely to weatherize their
homes without help. CAP agencies report that free-ridership is zero because the weatherization
candidates, by virtue of their income qualification for the program, cannot afford the retrofits.
The CAP agencies pointed out that landlords have little incentive to pay for weatherization
because utility bills are either paid directly by the tenants or added to the rental amount. ICL and
NW Energy Coalition also agree with this conclusion.
Recommendation 2: Staff agrees that customers who qualify for LIHEAP heating bill
assistance and who are then added to the CAP agency weatherization lists are extremely unlikely
to have sufficient funds to weatherize their homes. Staff further agrees that landlords have little
incentive to pay for energy efficiency measures when they are not responsible for paying the
energy bill. Therefore, Staff recommends that utilities claim 100% Net-To-Gross for this
program. This adjustment will increase the cost-effectiveness of Idaho Power's program.
Percentage of Energy Savings Claimed per Residence
Another prominent difference between the three utilities is the percentage of energy
savings per weatherization project that each claims. Rocky Mountain Power funds 85% of the
cost of each measure installed in a home, up to 85% of a home's weatherization cost. Avista
24National Action Plan for Energy Efficiency, "Understanding Cost-Effectiveness of Energy Efficiency Programs,"
2008, page ES-3.
25 DEER provides energy savings estimates for residential and non-residential technologies.
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IPUC Staff Low Income Report
Attachment A
pays 100% of the measures it funds in a home, which is usually about 100% of the project cost.
Both Rocky Mountain Power and Avista claim 100% of the energy savings produced by a home
that is weatherized through their low income programs.
Depending on the cost-effectiveness of the measure, Idaho Power funds up to 100% of
the cost per measure, not to exceed 85% of the project cost per home. Idaho Power claims only
the percentage of the energy savings that it funds per measure, rather than 100%. For example, if
Idaho Power funds 85% of the cost in a home, it will claim 85% of the energy savings generated
by that project.
During the workshop, Staff pointed out that all other DSM programs pay a partial
incentive (for example, $50 for a high efficiency clothes washer) but claim 100% of the savings
from the high efficiency unit. Staff sees no reason why a different standard should apply to low
income weatherization programs. Idaho Power states that it only claims the proportion of energy
savings it funds to avoid double-counting savings that were also attained with federal funding.
Staff appreciates this conservative approach, but has no evidence that the DOE is concerned with
double counting energy savings. The DOE has not objected to Avista's and Rocky Mountain
Power's long-standing practice of claiming 100% of the energy savings.
Also, leveraging federal weatherization funds is a primary reason that utilities operate
and fund low income weatherization programs through CAP agencies, rather than create separate
programs to be managed and funded entirely by each utility. Excluding the energy savings
associated with the federal investments detracts from the benefit of leveraging external funding
sources. The NW Energy Coalition and ICL agree that utilities should claim 100% of the
savings produced by low income projects. Idaho Power says it is comfortable with this
adjustment.
Recommendation 3: Staff recommends that utilities claim 100% of the energy savings
produced by each low income weatherizatiori project for which they provide funding. This
adjustment will increase the cost-effectiveness of Idaho Power's program.
Indirect Administration Costs
Utility DSM program implementation requires two types of internal administrative costs:
direct and indirect administrative costs. Direct administrative costs can be directly assigned to
each particular program. For example, the salary of a program manager is charged to the
program s/he operates and is considered a direct administrative cost.
Besides direct administrative expenses, each program also requires regulatory,
managerial, and financial oversight services, which are indirect administrative expenses. The
exact amount of these indirect administrative expenses incurred by each program is difficult to
assign precisely, even though each program requires the various services.
Each Idaho utility has a different method of assigning indirect overhead costs among its
DSM programs. Avista assigns each program a dollar amount of indirect overhead that
corresponds to the relative percentage of avoided cost that program achieves. Rocky Mountain
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IPUC Staff Low Income Report
Attachment A
Power assigns indirect overhead costs based on the relative percentage of energy savings
generated by the program as compared to the total jurisdictional DSM portfolio, which in this
case is its Idaho service territory.
Idaho Power assigns no indirect administrative costs to its programs, including its low
income program. Because Idaho Power does not include indirect administrative costs in its cost-
effectiveness tests, Idaho Power's TRC and UCT are higher than they would be if these relevant
costs were included. Cost-effectiveness calculations that do not include all overhead costs
associated with program administration do not accurately reflect cost-effectiveness.
Idaho Power believes this recommendation would be very difficult to implement because
most departments in the Company do not track their labor expenses by department served when
it occurs in the normal course of business. Idaho Power also claims that Staff's suggested
method does not align with how supply-side resources are valued by Idaho Power.
Staff maintains that supply-side resources include similar indirect overhead expenses,
such as regulatory, managerial, and financial oversight costs, although it may be on a
functionalized basis rather than assigned to individual projects. Staff believes that Idaho Power's
departments would not need to track their expenses incurred in the normal course of business;
these types of costs could be assigned on a proportional basis to DSM programs.
Recommendation 4: Staff recommends that Idaho Power develop a method to include
indirect administrative overhead costs in its low income weatherization program cost-
effectiveness in a manner than approximates how these expenses are assigned to supply-side
resources. This adjustment may decrease the cost-effectiveness of Idaho Power's program.
Evaluation Costs
The Memorandum of Understanding for Prudency Determination of DSM Expenditures
signed in December 2009 by the Commission Staff, Idaho Power, Rocky Mountain Power, and
Avista required those utilities to evaluate all substantive DSM programs every two or three
years. As a result, the cost of these evaluations can cause the cost-effectiveness of DSM
programs to decline. This can be particularly true for programs with smaller budgets. In April
2011, Rocky Mountain Power filed case PAC-E- 11-13 requesting permission to suspend future
evaluations of its low income portfolio. The Company claimed that the large cost of evaluations
on a program with a small budget and energy savings damaged the program's cost-effectiveness.
This is another area where each utility has calculated cost-effectiveness differently.
Before 2011, Rocky Mountain Power included the full cost of the evaluation in the program level
cost-effectiveness calculation during the year in which the cost was incurred. Beginning in 2011,
Rocky Mountain Power began including the evaluation costs for all DSM programs, including its
low income weatherization program, at the portfolio level. Avista includes the low income
evaluation cost in the cost-effectiveness calculation at the Idaho electric portfolio level, rather
than the individual program level. This approach frees programs with smaller relative energy
savings from bearing the costs of an evaluation in a cost-effectiveness calculation, but still
17
IPUC Staff Low Income Report
Attachment A
ensures that the evaluation cost is captured in a broader cost-effectiveness analysis. ICL
supports this method of capturing evaluation costs in cost-effectiveness calculations.
Idaho Power has not yet evaluated its low income program, but it expects to include the
total cost of the evaluation in one year's program level cost-effectiveness calculation. Staff
understands that Idaho Power's relatively large low income program budget and energy savings
makes it easier to absorb the cost of an evaluation in a single year.
Recommendation 5: Requiring low income programs, which often have smaller budgets
and energy savings relative to other DSM programs, to incorporate the full cost of an evaluation
in a single year could lead to extremely lean evaluation budgets, and possibly lower quality
evaluations. Staff recommends that utilities have the option to incorporate program evaluation
costs at the jurisdictional portfolio level rather than the program level. Alternatively, Staff
recommends that utilities have the option to amortize evaluation costs over the two to three years
between evaluations for program level cost-effectiveness calculations.
Energy Conservation Adders
Consistent with the Northwest Power and Conversation Act, Avista and Rocky Mountain
Power include a 10% energy conservation preference adder to their cost-effectiveness
calculations for all of their DSM programs, including their low income weatherization programs.
The 10% adder was adopted to show a preference for energy efficiency over supply side
resources, not to capture any specific unquantified non-energy benefits. Avista adds 10% to its
avoided cost and Rocky Mountain Power adds 10% to its TRC benefits, which it refers to as the
PacifiCorp TRC (PTRC). Idaho Power does not include a conservation preference adder on any
DSM program, including its low income program.
The workshop included extensive discussion about energy conservation adders used by
several other state commissions. In particular, the Northwest Energy Coalition presented a
February 7, 2012 order from the State of Vermont Public Service Board that ordered that energy
efficiency providers apply a 15% non-energy benefits adder to energy benefits, as well as a 15%
adder to the energy benefits for low income energy efficiency investments. Staff hesitates to
recommend any adder when the underlying derivation of the adder or other justification for the
percentage has not been specifically provided.
Importantly, while Rocky Mountain Power reports the PTRC in its annual DSM report, it
does not make resource-acquisition decisions based on the PTRC. Idaho Power does not oppose
including a 10% adder in its annual DSM report, but similar to Rocky Mountain Power, it "does
not believe that the use of a conservation adder is appropriate in cost-effectiveness calculations
while conducting supply-side resource planning." Only Avista uses a 10% adder when deciding
what resources to acquire. Staff believes that additional evaluation would be required if acquired
resources were not cost-effective without the adder.
Recommendation 6: Staff does not oppose Rocky Mountain Power and Avista' s use of a
10% energy conservation preference adder in their low income DSM cost-effectiveness
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IPUC Staff Low Income Report
Attachment A
calculations. Use of the adder is widely accepted by state utility regulatory commissions on a
regional basis and its use is included in the Northwest Power Act. Staff would not oppose Idaho
Power's use of this adder in its low income cost-effectiveness calculations. Including a 10%
conservation preference adder would increase the cost-effectiveness of Idaho Power's low
income weatherization program.
Payment-related, Economic, and Participant Non-Energy Benefits
Cadmus' April 2011 evaluation of Rocky Mountain Power's low income weatherization
program raised the issue of non-energy benefits. Cadmus' analysis maintained that Rocky
Mountain Power's program was cost-effective, but only when non-energy benefits were
included. Although no workshop participant disputed that additional often unquantified—non-
energy benefits occur as a result of these programs, there was spirited discussion about which
non-energy benefits the cost-effectiveness analysis should include.
Staff believes that non-energy benefits are an important aspect of cost-effectiveness
because they, not the energy savings, are often the primary incentive for customer participation.
Further, if a cost-effectiveness analysis captures all costs paid by the customer to install the
measure (which are often much larger than the incentive provided by the utility), the analysis
should also capture all of the benefits that accrue to the customer. Although these benefits are
important, they are often very difficult to quantify and for that reason are often omitted from
cost-effectiveness calculations.
Payment-related Non-Energy Benefits
In a report prepared for CAPAI in Case No. PAC-E-ll-l3, Roger Colton discussed
payment-related benefits and recommended that they be incorporated into evaluations of low
income weatherization programs. 26 Examples of payment-related non-energy benefits are
reductions in arrearages, reductions in bad debt, and reductions in collection, disconnection, and
reconnection expenses that may occur when low income customers' bills are reduced through
weatherization. These non-energy benefits accrue to the utility and the ratepayers, as well as to
the customer whose home is weatherized.
All workshop participants agreed that when payment-related non-energy benefits can be
quantified and associated with the low income weatherization program with reasonable certainty,
it is appropriate to include them in the cost-effectiveness analysis. Rocky Mountain Power
pointed out, however, that assigning a dollar value to payment-related savings can be more
difficult than is often assumed. Idaho Power concurred that calculating these benefits is "very
difficult if not impossible" because it requires the utility to determine that the reductions were
generated by the weatherization measures rather than a host of outside factors, including the
26 Roger Colton (October 2011), "Assessing the Cost-Effectiveness of Low Income Weatherization in Idaho: A
Review of the Rocky Mountain Power Evaluation," Pp. 26-28. Colton references the seminal study on low income
DSM programs done by the Oak Ridge National Laboratory in 1994.
19
IPUC Staff Low Income Report
Attachment A
financial circumstances of the customer. Similar to Idaho Power and Rocky Mountain Power's
claims, the Northwest Power and Conservation Council's Regional Technical Forum (RTF)27
concluded that it is difficult to quantify non-energy benefits flowing to the utility, such as
reduced arrearages, disconnections, reconnections, and cost collection activities.
Staff and other parties also noted that the dollar value associated with payment-related
benefits is relatively small. In its impact evaluation, Cadmus estimated the value of reduced
arrearages for Rocky Mountain Power from 2007 to 2009 was only $8,000.
Avista pointed out that under the TRC, reductions in arrearages, bad debt, collection,
disconnection, and re-connection charges could reasonably be considered a transfer of benefits
within the ratepayer population. Transfers have no net impact on the TRC.
Economic Non-Energy Benefits
Economic non-energy benefits are even more difficult to quantify than payment-related
benefits. These include benefits to the local economy, including jobs that result from equipment
purchases and installation costs. Cadmus tried to measure the economic benefits of Rocky
Mountain Power's low income weatherization program using Idaho-specific data as inputs in an
economic-multiplier model. But the model's assumptions and analysis were not transparent
enough to convince Staff of the model's accuracy.
Participant Non-Energy Benefits
Workshop participants also discussed including non-energy benefits that accrue to the
program participant or property owner, such as increased property values, longer lives for
weatherized dwellings, and the reduced use of other fuels (e.g., wood). The Northwest Energy
Coalition supported monetizing the value of health benefits and the value of improving the
conditioned space, as a government-funded effort in New Zealand has already begun doing.
Another workshop participant suggested counting takeback 28 as a non-energy benefit because
non-functioning appliances repaired through the weatherization program clearly benefit the
participant.
No one at the workshop suggested concrete mechanisms to value non-energy benefits that
accrue to program participants. Similarly, the RTF published a March 2012 study by Navigant
Consulting, which said that "Conclusive estimates of the monetary impact of these [ancillary]
elements do not generally exist... {A]ncillary impact(s) may be included in a measure cost
analysis if it can be sufficiently demonstrated to the RTF that the impact(s) are significant and
monetizable."29
27 The RTF is a technical advisory committee of the Northwest Power and Conservation Council.
28 The increase in electrical consumption some program participants experience when, for example, a non-working
furnace is repaired and begins consuming energy. 29 "Guidelines for the Development and Maintenance of Incremental Measure Costs and Benefits Estimates,"
prepared for the RTF by Navigant Consulting, March 2012, page 19. Underlining in the original.
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IPUC Staff Low Income Report
Attachment A
Staff agrees that conclusive evidence about the value of these participant benefits has not
yet been established. Although Staff opposes including non-energy benefits that accrue to
program participants based on the insufficient quantification and justification provided thus far,
Staff will accept the 10% DSM preference adder and continue to evaluate the merits of these
benefits for possible future inclusion.
Staff does not support including non-energy benefits that cannot be valued and calculated
with adequate transparency and rigor. Occasionally, just enough non-energy benefits are
included in a program evaluation to reach a pre-determined level of cost-effectiveness. Staff
believes this is inappropriate. Staff suggests that in-house and third-party evaluators work to
improve a program's cost-effectiveness through decreased costs and increased energy benefits,
and not try to make a program simply appear more cost-effective through the arbitrary use of
non-energy benefits.
By not devoting resources to quantify non-energy benefits that are by their nature
difficult or impossible to quantify, we can reduce the complexity and perhaps expense of low
income weatherization program evaluations. That would improve cost-effectiveness for utilities
that choose to include evaluation costs at the program level or portfolio if done at that level.
Recommendation 7: Staff recommends that payment-related non-energy benefits, such as
reductions in utilities' arrearages and bad debt, as well as collection, disconnection, and
reconnection expenses that may accrue when low income customers' bills are reduced through
weatherization, be quantified and included in cost-effectiveness analyses when possible.
Staff recommends excluding economic non-energy benefits and non-energy benefits that
accrue to program participants because they have not yet been rigorously quantified. These
include increased property values, extended lives of weatherized dwellings, health impacts,
takeback, and increased comfort.
Including quantifiable payment-related non-energy benefits will increase the cost-
effectiveness of low income programs over what they otherwise would have been. However,
excluding the economic non-energy benefits already included in Rocky Mountain Power's
Cadmus evaluation will decrease that program's cost-effectiveness.
Utility-Funded Health and Safety Measures and Repairs as Non-Energy Benefits
In order to leverage federal money for low income weatherization through the State of
Idaho Weatherization Program, each utility's low income program includes funding for health
and safety measures and repairs. These measures are sometimes required before the energy
efficiency measure can be installed. For example, mechanical ventilation may be required when
a home is weatherized to ensure safe air quality for the resident. But ventilation reduces energy
savings. Although health and safety measures like ventilation, roof repair, carbon monoxide
detectors, and electrical wiring repairs can consume up to 15% of a utility's annual
weatherization budget, they do not produce energy savings. Therefore, health and safety
measures can significantly impede cost-effectiveness.
21
IPUC Staff Low Income Report
Attachment A
Avista explained in the workshop that it quantifies utility-funded health and safety
measure benefits as equal to the dollar amount of the investment in its cost-effectiveness
calculations. 30 For example, if Avista spends $100 on a furnace repair, Avista claims $100 of
non-energy benefits for that repair. Claiming a one-to-one dollar cost/benefit eliminates the
difficulty in quantifying the non-energy benefit associated with health and safety measures. In
cost-effectiveness tests, this treatment neutralizes the negative effect of health, safety, and repair
measures on programs. Workshop participants agreed that the dollar-for-dollar assumption very
likely understates the non-energy benefits associated with health, safety, and repair measures.
Further, this modification only affects the TRC because the health, safety, and repair measure's
benefits accrue to the program participant.
Idaho Power points out that only about 3% of its annual low income budget is used for
health, safety and repair measures. Therefore, the impact of claiming these as a benefit in cost-
effectiveness calculations in its program is anticipated to be relatively small. Idaho Power's
policy is to save the expense of trying to calculate more difficult to quantity non-energy benefits
when a program passes the TRC or UCT on energy savings alone. Since its low income program
has historically passed these tests, Idaho Power has never tried to quantify or monetize any
associated non-energy benefits. While this approach has some advantages, it could be viewed as
backing into cost-effectiveness with non-energy benefits when the need arises.
Rocky Mountain Power paid about $24,000 towards healthy, safety, and repair measures
in 2011. It believes that off-setting this cost with a $24,000 benefit will not significantly impact
the program's cost-effectiveness. However, since utility investments in health, safety, and repair
measures can be up to 15% of a low income program's expenditures, it could have a significant
impact if health, safety, and repair expenditures increase in future years. Rocky Mountain Power
also cautioned that combining a 10% adder with utility and federally-funded non-energy benefits
may overvalue non-energy benefits.
Staff appreciates Rocky Mountain Power's concern. However, Staff notes that the Rocky
Mountain Power already includes a 10% energy conservation adder in its PTRC and included a
significant amount of economic non-energy benefits as estimated by Cadmus in its 2010 cost-
effectiveness analysis. In fact, Rocky Mountain Power's 2007-2009 reported TRC with
economic non-energy benefits and arrearages was 1.23. Rocky Mountain estimates that if a 10%
adder as well as utility and federally-funded non-energy benefits was included per Staff's
recommendations and applied to 2011 program data, the TRC would be 1.07.
Staff recognizes that funding levels and other circumstantial changes could affect the
difference between TRC ratios from 2007-2009 and 2011. However, Staff's recommendations
produce a more conservative cost-effectiveness estimate than Rocky Mountain Power's
methodology. Staff prefers to value non-energy benefits on a more conservative and controlled
basis rather than as part of a much less well-understood economic model.
30 Idaho Power nor Rocky Mountain Power claim a benefit for health, safety, and repair measures. Neither
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IPUC Staff Low Income Report
Attachment A
Staff understands that this particular type of non-energy benefit quantification is not
broadly accepted. It may not currently be used by any other utility besides Avista and it is not
directly recommended in any cost-effectiveness manual. However, the list of non-energy
benefits that are quantified and monetized by utilities across the country is long, diverse, and
undefined. Since the proposed method likely underestimates the value of the health, safety, and
repair measure and provides a transparent one-to-one ratio of benefits to investments, Staff is
comfortable recommending its use even though we have opposed the use of less quantifiable
non-energy benefits that accrue to program participants. ICL also supports including utility-
funded health, safety, and repairs measures as non-energy benefits.
Recommendation 8: Staff recommends that Avista continue quantifying utility-funded
health, safety, and repair measures as a dollar of non-energy benefits for each dollar of cost.
Staff recommends that Idaho Power and Rocky Mountain Power apply this methodology to their
cost-effectiveness calculations. This adjustment will increase Idaho Power and Rocky Mountain
Power's cost-effectiveness. 31
Federally-Funded Health and Safety Measures and Repairs as Non-Energy Benefits
After the workshop discussion about utility investments in health, safety, and repair
measures, Avista suggested treating federally-funded non-energy benefits the same way. 32 That
would mean utilities could claim a dollar of non-energy benefits for each dollar of federal
investment in health, safety, and repair measures.
The most significant difference between utility-funded and federally-funded non-energy
benefits is that federally-funded non-energy benefits do not always appear as a cost in the TRC.
The TRC often only captures costs that are paid by ratepayers in the service territory. Federal
expenditures, including tax credits, are sometimes considered an importation of funds from
outside the ratepayer population and therefore are not captured as a cost.
The TRC, however, captures the benefits of federally-funded measures. In this
application, that means including federally-funded health, safety, and repair measures as non-
energy benefits would increase the benefits included in the TRC, but not the costs, thereby
improving cost-effectiveness. No Idaho utility, including Avista, currently claims federally-
funded health, safety, and repair measures as non-energy benefits.
This treatment of federally-funded non-energy benefits is consistent with Avista's
previous treatment of ARRA-funded efficiency rebates (e.g., stimulus-funded appliance rebate
program), and as previously stated, is consistent with generally accepted TRC methodology. 33 It
31 The increase in cost-effectiveness for Idaho Power is anticipated to be relatively small because Idaho Power only
spends a small percentage of their weatherization funds on health and safety measures. 32 The majority, but not all, of non-utility funds for low income weatherization comes from the federal government.
In Idaho, funds from several sources, including the federal government, are administered by the State of Idaho or
Tribal Governments in Idaho. For ease of discussion, all of this non-utility money will be referred to as federal
funds.
The American Recovery and Reinvestment Act of 2009.
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IPUC Staff Low Income Report
Attachment A
is also consistent with Avista and Rocky Mountain Power's method for capturing federally-
funded energy savings measures. These two utilities claim 100% of the savings produced by
homes weatherized through the program, although the utilities have sometimes funded less than
100% of the measures in a home. 34 Including the entire energy savings produced by a project to
take advantage of leveraged federal funds is one of the primary reasons stated by the
Commission for running utility weatherization programs through CAP agencies. This
modification would not impact any cost-effectiveness test other than the TRC, similar to the
recommended treatment of utility-funded non-energy benefits.
Rocky Mountain Power said it could accept this approach if the criteria determining
health, safety, and repair measures are clear. Weatherization Program Notice 11-6 contains a
comprehensive list of DOE-allowed health, safety, and repair measures. 35 Weatherization
Program Notice 12-09 provides guidance on repairs and could be used to determine if a measure
is an efficiency measure or a health, safety, and repair measure. 36
However, Rocky Mountain Power points out that it does not currently track federal
health, safety, and repair expenditures in homes weatherized through their program. Rocky
Mountain Power expressed concern that tracking these data could be cost-prohibitive. Although
Avista originally developed the idea of incorporating federally-funded health, safety, and repair
measures as non-energy benefits, it is still working with its CAP agency to capture these data.
Idaho Power can likely quantify these data with relatively minor modifications to its
tracking systems because the Company already collects very detailed weatherization invoices
from the CAP agencies. Staff understands that the invoices that populate Idaho Power's
database record the federally-funded measures in a home, but since Idaho Power has not
previously pulled that information from the database it cannot yet confirm that these data can be
tracked without excessive cost.
Idaho Power has expressed reservations about excluding some of the costs associated
with a project in the TRC. The literature on cost-effectiveness is not definitive on this point.
Most manuals say that federal tax credits can and/or should be treated as an importation of funds
into the ratepayer population and therefore should not be counted as a cost. However, since the
federal funds for weatherization are an importation of funds supplied from outside the ratepayer
population, Staff is comfortable excluding them as costs. ICL also supports this methodology.
Recommendation 9: Staff recommends that the utilities have the option to claim one
dollar of non-energy benefits for each dollar of federal funds invested in health, safety, and
repair measures. Staff recommends that this adjustment remain optional since utilities may have
difficulty collecting accurate data on federally-funded measures and because cost-effectiveness
Rocky Mountain previously funded 75% of the measures in a home and Avista funded 85%. Currently Rocky
Mountain funds 85% of the measures in a home and Avista funds 100%.
" DOE, Weatherization Program Notice 11-6, Effective Date: January 12, 2011.
http://wantac.org/datalfiles/websitedocs/government/guidance/20 I I /wpn%20 II -6.pdf 36 U.S. DOE, Weatherization Program Notice 12-09, Effective Date: June 27, 2012.
http://waptac.orgldatalfiles/websitedocs/governmentjguidance/2o 1 2/wpn 1 2-09-incidental-repair-measure.pdf
24
IPUC Staff Low Income Report
Attachment A
manuals provide discretion on whether federal funds should be included as a cost in the TRC.
Staff's recommendation is consistent with the attribution of federal funds in other programs,
TRC methodology, and treatment of energy savings. If adopted, this adjustment is likely to
increase all three programs' cost-effectiveness, although the exact impact is unknown because
the utilities have not previously tracked the amount of federal funds spent on health, safety, and
repair measures in utility-funded low income weatherized homes.
Discount Rate Modification
In energy efficiency cost-effectiveness calculations, the discount rate is applied to the
future value of costs and benefits to allow the benefit-cost ratio to be viewed on a Net Present
Value (NPV) basis. 37 A positive discount rate reduces the value of a program's benefits.
Because benefits accrue over multiple years, decreasing the discount rate increases the value of
the benefits. Costs are unaffected by modifying the discount rate because costs occur almost
exclusively in the first year of a program.
Decreasing the discount rate will increase the NPV of a DSM program, which in turn
increases cost-effectiveness. For example, a 7% discount rate applied to $135 in benefits that
accrue over five years will bring the NPV to about $100. Applying a 4% discount rate to the
same $135 in benefits that accrue over five years will bring the NPV to about $110.
Historically, Idaho utilities have used the Weighted Average Cost of Capital (WACC),
currently around 7%, as the discount rate for all benefits produced by a DSM program. The
WACC estimates the time value of money for the utility based on the utility's borrowing costs
and anticipated return on investments. But DSM programs, including low income
weatherization, include benefits that accrue to participants in addition to the utility.
Recently, there has been much discussion about the accuracy of applying the utility's
discount rate—the WACC—to participant benefits. Many groups agree that participant
investment-value is unrelated to utility investment-value; thus, it is incorrect to apply the utility's
discount rate to participant benefits.
During the workshop, Avista proposed using a different discount rate depending on the
group to which benefits accrue. This would mean applying the WACC as the discount rate for
utility benefits, and an alternate discount rate for participant benefits. In this case, participants'
benefits are the non-energy benefits generated by investments in health, safety, and repair
measures. Alternate discount rates are primarily relevant to the TRC because that test includes
benefits that accrue to the utility and participants. The UCT only includes utility costs and
benefits, so it is reasonable to use only the WACC in the UCT.
It can be difficult, however, to determine the correct discount rate for participants. For
example, the discount rate for participant benefits could be 1%, which reflects the interest rate on
treasury bills, or 4%, which reflects home mortgage interest rates.
It may help to think of the discount rate as an interest rate, applied backward in time to a program's benefits, to
determine the opportunity cost of making a particular investment.
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IPUC Staff Low Income Report
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During workshop discussions, the Northwest Energy Coalition provided an order from
the Vermont Public Service Board ordering "energy efficiency providers regulated by the Board"
to use a 3% discount rate for cost-effectiveness screening of "all efficiency investments."
Regionally, the Sixth Northwest Conservation and Electric Power Plan assumes 5% as the real
discount rate, which is "based on mid-term forecasts for the cost of capital to the entities or
sectors examined ,,38 and incorporates a 3.2% discount rate for residential customers .
39 The Oak
Ridge National Laboratory applied a 3.2% discount rate for all non-energy benefits quantified in
its 2002 report, "Non-Energy Benefits from the Weatherization Assistance Program: A Summary
of Findings from the Recent Literature." ICL also supports the use of a modified discount rate
that is directly aligned with the perspective being measured.
In its DSM 2011 Report, Idaho Power concluded that "since the participant benefit is
based on the anticipated bill savings of the customer, it was determined that the WACC was not
an appropriate discount rate." In that report, the Company began applying a 3.88% discount rate
to participant bill savings and non-energy benefits. 40 This "real discount rate" value was derived
by applying an escalation or inflation rate of 3% to Idaho Power's WAAC (7%).
During the workshop, Staff pointed out that a modified discount rate could be applied to
all DSM programs, not just low income programs. Idaho Power's 2011 DSM Report follows
this logic; the 3.88% discount rate is applied to participant benefits in all programs.
But not all workshop participants agreed that adjusting the discount rate for different
streams of benefits based on recipient is appropriate. At the workshop, Rocky Mountain Power
hesitated to endorse changing the discount rate for its cost-effectiveness tests claiming that
applying the WACC to all benefits lets Rocky Mountain Power compare DSM resources to
supply side resource more readily. Several participants pointed out that changing an assumption
in the benefit-cost ratio does not make comparing the results more difficult, but could make the
results more accurate. Rocky Mountain Power also said it could not support a modification
without first having its power-supply planning team analyze the effect of changing the discount
rate.
Staff supports the use of a modified discount rate for valuing participant benefits.
However, the only non-energy benefits recommended for use in low income weatherization
programs are investments in health, safety, and repair measures. Staff recommends valuing
those participant benefits as an amount equal to the investment. This means that the benefits are
already valued on a NPV basis and therefore applying a modified discount rate would have no
effect.
Recommendation 10: Staff supports Avista's proposal to use and Idaho Power's current
use of a modified discount rate for participant benefits. However, the only type of participant
benefits Staff has supported for low income weatherization programs are health, safety, and
Sixth Northwest Power and Conversation Plan, Appendix N: Financial Assumptions and Discount Rate, N-2.
Sixth Northwest Power and Conservation Plan, Appendix N: Financial Assumptions and Discount Rate, N-8. 40 Idaho Power Demand-Side Management 2011 Annual Report: Cost-Effectiveness Supplement 1, page 3.
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IPUC Staff Low Income Report
Attachment A
repair measures that, using Staff's recommended method, are already valued on a NPV basis.
Therefore, applying a modified discount rate to these benefits would have no effect on cost-
effectiveness.
Creating a Low Income Weatherization Specific TRC
Some groups, both at the workshop and nationally, maintain that traditional cost-
effectiveness tests do not adequately represent the unique benefits produced by low income
weatherization programs. Further, some maintain these tests incorrectly penalize the unique
aspects of low income weatherization programs by including all of the costs of the program, but
not including all of the benefits that accrue to participants, which are often more substantial for
low income program participants than other DSM program participants.
One solution to this problem is to create a low-income specific TRC. California has
moved in this direction by creating a Low Income Public Purpose Test (LIPPT) as the standard
by which to determine prudency, rather than using more narrow cost-effectiveness tests.
Staff review of this approach found that the California public purpose test is a TRC that
includes a generous array of non-energy benefits. The LIPPT "is designed to include a broader
range of non-energy benefits"4' than even the standard public purpose test, which itself includes
an expansion of benefits over the TRC. Among other non-energy benefits, the LIPPT includes
participant savings from fewer moves, fewer lost sick days, improved comfort, reduction in fire
losses, and participant value from fewer calls to the utility, which are valued as time savings. As
previously discussed in this report, while these types of benefits are important, they have not yet
been quantified with adequate rigor or transparency for Staff to recommend their inclusion.
The NW Energy Coalition believes the idea of creating a separate, low-income program
cost-effectiveness test should be more thoroughly studied. It maintains that many of the listed
non-energy benefits help all utility customers, even if the benefits are hard to quantify. Staff
understands that perspective, but cannot support the inclusion of additional energy or non-energy
benefits, beyond the preference adder, which cannot be rigorously and transparently quantified.
Thus far, few non-energy benefit calculations have met this standard, although Staff is open to
the possibility that future calculations may meet this threshold.
Other workshop participants recommended that low income programs not be subjected to
rigorous cost-effectiveness tests, but instead be deemed prudent by the Commission in part from
a public assistance perspective. Avista has suggested a similar approach to its Washington
regulators.
Although these options may be trends in other states, Staff believes that low income
weatherization programs should be viewed as an alternative to supply side resources rather than
as public assistance. Further, the Commission supported this view in Order No. 32426 when it
wrote, "we are concerned about the cost-effectiveness of Idaho Power's low-income
weatherization program. Because ratepayers fund Idaho Power's weatherization programs, we
" The Low Income Public Purpose Test: Final Report, TecMarket Works, May 2001, page 1.
27
IPUC Staff Low Income Report
Attachment A
have a responsibility to ensure that these programs are cost-effective and designed to maximize
benefits for all customers."
Concern has been raised that if the recommendations in this report are only applied to
low income weatherization programs, that Staff will be, in effect, recommending a separate cost-
effectiveness test for low income weatherization programs. Staff disagrees will this assessment.
The recommendations in this report merely clarify how standard cost-effectiveness tests should
be applied to low income programs in Idaho, which are currently being calculated in many
different ways. Several of these recommendations actually make low income cost-effectiveness
calculations more consistent with standard cost-effectiveness guidelines. Further, many of these
recommendations, including a modified discount rate, capturing evaluation costs at the portfolio
level, claiming 100% of savings, applying a 100% NTG value, and including a limited number of
strictly-defined non-energy benefits are already in use by at least one of the three utilities.
Recommendation 11: Staff does not recommend constructing a specific cost-
effectiveness test for low income weatherization programs.
Program Implementation
Evaluation Methodology
Beginning with the Cadmus evaluation report cited in Case No. PAC-E- 11-13 and
continuing through other recently completed Commission cases addressing low income
weatherization, the issues surrounding program cost-effectiveness often centered on evaluation
methodology. Billing analyses are the most common method used to measure the energy savings
produced by whole house weatherization programs because they capture the effects of multiple
measures installed in a single home. But billing analyses in residential settings, particularly with
low income customers, are problematic because the pre and post conditions cannot be as
precisely controlled as they can be in a commercial or industrial setting. Staff recommends that
the utilities examine evaluation methods that may infonn or complement billing analyses for low
income programs.
Low income billing analyses sometimes determine energy savings by comparing the
energy consumption of program participants after weatherization (the treatment group) to non-
participants (the control group). Besides pre and post inconsistencies, the accuracy of billing
analyses can be undermined if relevant differences between the treatment and control groups are
not mitigated.
Roger Colton, commenting in Case No. PAC-E-1 1-13, found several places where the
Cadmus evaluation failed to adequately control for differences between the participant and non-
participant groups. CAPAI maintains that these lapses inaccurately reduced the participant
group's energy savings and incorrectly reduced the non-participants group's energy
consumption. Therefore, the study underestimated the energy consumption difference between
program participants and non-participants.
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IPUC Staff Low Income Report
Attachment A
Staff agrees with some of Mr. Colton's findings and conclusions. To correct many of
these shortcomings, Staff recommends stringent controls between participants and non-
participants in the billing analysis if the utility chooses to use non-participants as the control
group. Previously weatherized homes (funded with either utility or federal money) should be
excluded from the non-participant group. Evaluations should control for energy savings
produced by service disconnections in the non-participant group. Evaluations should also
explore how a declining local economy and utility rate increases could affect non-participants
differently than participants. Lastly, evaluations should not emphasize customer satisfaction
surveys to the detriment of very rigorous billing analysis controls.
CAP agencies prioritize weatherization services for homes with seniors, children, and
disabled customers. These households could be more financially disadvantaged than other low
income customers. Reduced financial resources could reduce consumption in the prioritized
groups as compared to non-participants, so impact evaluations should control for this difference
as much as possible.
In addition, CAP agencies reported at the workshop that between 50% - 80% of all homes
are weatherized in an emergency situation. Emergencies include, for example, mid-winter
furnace failures. Impact evaluations should control for emergency weatherization measures that
might further skew the differences between the participant and non-participant group.
All these factors almost certainly contributed to artificially low energy consumption in
the non-participant group. This list is not exhaustive, and Staff recommends that utilities
explore, quantify, and control for other discrepancies between the treatment and control groups.
Rocky Mountain Power has consistently maintained that Cadmus' methodology was
conceptually and analytically sound, but acknowledges that it did not control for the effects of
previously weatherized homes and service disconnections in the non-participant group.
After the workshop, Rocky Mountain Power and Staff discussed Staff ways to address some of
these concerns in future billing analyses, including controlling for previously weatherized homes
and service disconnections in the non-participant group.
Idaho Power has pointed out that the control group for a billing analysis does not have to
be non-participants. Program participants can be their own control group: the evaluator can
measure the energy consumption of a home before and after weatherization. This could remove
the problem of matching or controlling for the differences between the treatment and control
groups. Avista's 2012 low income impact evaluation, conducted by Cadmus, also used this
method.
Rocky Mountain has expressed concern that barriers to collecting sufficient data to
implement these controls potentially include cost, adequate cooperation from CAPAI and the
CAP agencies, and regulatory filing deadlines. Staff believes that including evaluation costs at
the portfolio level—one of this report's recommendations that Rocky Mountain Power has
already implemented—will mitigate cost-effectiveness concerns. Although Staff has not been
informed of any deficiencies in this area previously, Staff believes that the recent focus on
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IPUC Staff Low Income Report
Attachment A
funding for low income weatherization programs will encourage increased responsiveness from
both CAPAI and the CAP agencies. Staff is unaware of any Idaho regulatory filing deadlines
that impede comprehensive data collection.
Staff also recommends that utilities vary the contractors they hire to evaluate these
programs. Ecotope and Cadmus have each evaluated Avista's low income weatherization
program once. Cadmus has evaluated Rocky Mountain Power's program twice. Future
evaluations will be more informative if a variety of evaluators and methods are used.
Rocky Mountain Power has agreed that varying contractors could be "more informative,"
but also pointed out that consideration must be given to contractor cost and competency. Staff
agrees that the cost of evaluations should be controlled, but points out that there are many well-
qualified evaluators in the region who are well-versed in utility impact and process evaluations.
Rocky Mountain Power can leverage this supply to lower costs. Staff believes that while it may
be less expensive to rehire the same evaluator several years in a row, an implicit bias towards the
utility may develop over time.
Also, if the same evaluator conducts multiple impact evaluations of the same program,
there is an incentive for the evaluator to find the results it published in the previous evaluation
were accurate. The same pattern can hold true for process evaluations. If the utility incorporates
recommendations made by the evaluator in its first report, there is a clear incentive for the
evaluator to find that the utility's program is now very effective. If either of these situations
occur, ratepayers will have paid a premium for an independent, third-party evaluation, but could
receive evaluations that are not much more independent than if the utility had conducted them.
In expressing its reservations, Rocky Mountain Power asked that this item remain a
recommendation and not a requirement. Staff clarifies that all items in this report are Staff
recommendations, not Commission requirements.
Recommendation 12: Staff recommends that the utilities incorporate additional
evaluation methods to inform or complement billing analyses for low income programs
whenever possible. If non-participants are used as the control group in a billing analysis, Staff
recommends rigorous controls between the two groups, which may include but not necessarily be
limited to, previously weatherized homes, service disconnections, economic decline and rate
increases, and households prioritized for weatherization, including emergencies. Incorporating
these controls and/or other evaluation and billing analysis methods may increase all three
programs' cost-effectiveness. Staff also recommends that utilities vary the independent
contractors hired to evaluate these programs.
Fixed Annual Funding versus Roll-over of Unspent Funds
In tandem with the recent cases in which CAPAI asked the Commission to increase low
income weatherization funding, a recent problem has been unspent low income program funds.
For example, in 2010, Rocky Mountain Power funded two CAPs approximately $133,000 of the
program's $150,000 annual available budget, leaving about $17,000 in unspent funds. With the
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IPUC Staff Low Income Report
Attachment A
suspension of its natural gas low income program, Avista may have unspent funds in 2013.
Since utilities do not dispense low income weatherization funding until they receive an invoice
from a CAP agency, unspent weatherization funds suggest that the CAPs, not the utility, had
difficulty spending the funds that year.
Avista and Rocky Mountain Power fund their low income weatherization programs
through their DSM tariff riders. Unspent low income funds are not carried over into the next
year, but they can be used for other programs in the current year.
Idaho Power's Weatherization Assistance for Qualifying Customers (WAQC) program is
funded through base rates. Since utilities are allowed to keep any unspent money allocated in
base rates, the Commission has ordered Idaho Power to carry over unspent low income
weatherization funds into the next year. 42 Idaho Power carried over $50,000 in unspent funds
from 2010 into 2011.
Rocky Mountain Power and the CAP agencies agreed that unspent funds in 2010 were
caused by the large influx of ARRA funding that the CAP agencies needed to spend first. None
of the workshop groups anticipate that spending all of the utility money will be a problem in the
future, although it is important to note that this discussion took place before the Commission
approved Avista's request to suspend its natural gas programs.43 Unspent program funds are
rarely a problem, and when it is, the funds are applied either to low income weatherization
programs in future years or other programs in the current year.
The NW Energy Coalition believes that because of the need for more low income
resources, any unspent funds should be used for low income weatherization and/or education
programs rather than transferred to other DSM programs. The Coalition maintains that since all
low income customers pay into the DSM tariff rider, but low income weatherization/education
programs are the only realistic way for low income customers to participate in DSM programs,
transferring unspent funds to other DSM programs unfairly restricts their ability to participate.
While Staff would prefer that all customers have equal opportunity to participate in DSM
programs, Staff continues to believe that regardless of direct participation, all customers,
including low income customers, benefit from funding cost-effective DSM because it defers
investment in a more costly generation resource.
Recommendation 13: Staff believes that Idaho Power should continue to comply with
Order No. 29505 which directs the Company to carry over unspent low income weatherization
funding from base rates into the following year. 44 Staff also recommends that Avista and Rocky
Mountain Power continue to use any unspent low income funds for other DSM programs,
consistent with current practice for all programs funded through DSM tariff riders.
42 Page 32 of Commission Order No. 29505, Case No. IPC-E-ll-03, states "Any unpaid funds shall carry over and
be available in the next year."
u The suspension was approved by Order No. 32650, Case No. AVU-G-12-03/AVU-G-12-06.
Page 32 of Order No. 29505, Case No. IPC-E-03-13, states "Any unpaid funds shall carry over and be available in
the next year."
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IPUC Staff Low Income Report
Attachment A
Capture Project-Level Data to Enable Evaluation and Program Management
A comprehensive data management system to track expenditures and energy savings on a
measure by measure basis is an important tool with which to make program management
decisions and enable independent, third-party evaluations.
Avista maintains a fully electronic data transfer via web portal from its CAP agency. 45
Data collected by the utility through this system includes date of installation, invoice date, costs
per measure, and verified savings estimates per measure, and amount of each measure funded by
Avista.
Idaho Power has also built a fully electronic data transfer system via web portal through
which the CAP agencies upload data. Data collected through this system includes date of
installation, costs, EA5 savings estimates per measure, and the percent of each measure funded
by Idaho Power. Idaho Power has very effectively used the EA5 model to spend utility money
on the most cost-effective measures in each residence. Since Idaho Power can fund anywhere
from zero to 100% of a measure (not to exceed 85% of the weatherization cost of a house), Idaho
Power instructs its CAP agencies 46 to bill Idaho Power (rather than the federal funding sources)
for the measures with the highest Savings to Investment (SIR) ratio, thus maximizing the cost-
effectiveness of its investments. This method of strategic investments would be impossible
without Idaho Power's detailed data collection and program oversight.
Rocky Mountain Power has dramatically improved relevant data collection from its CAP
agencies 47 from the time of the 2010 Cadmus process review. The Cadmus review reported that
precise analysis was difficult because Rocky Mountain Power did not collect all the necessary
data from the CAP agencies. In January 2011, Rocky Mountain Power replaced its database
system. The new data collection system includes measure level cost and savings estimates, and
installation date rather than just invoice date. The smaller size of Rocky Mountain's low income
program compared to Idaho Power and Avista's programs made investing in comprehensive data
management system a slower process.
Since the workshop, Rocky Mountain has begun using a software tool that creates an
Idaho-specific reference home with data from its local CAP agencies. This tool is intended to
improve the pre-weatherization energy savings estimates and minimize variances between
reported savings and actual savings determined through impact evaluations. Having more
accurate data about the energy characteristics of local homes from the CAP agencies will help
Rocky Mountain maximize the cost-effectiveness of its weatherization investments.
Recommendation 14: Staff recommends that Rocky Mountain Power continue the
pending and future upgrades to its low income weatherization data management system. Staff
' Avista only has one CAP agency in its Idaho service territory.
46 Idaho Power has five CAP agencies in its Idaho service territory, two of which it shares with Rocky Mountain
Power (SEICAA and EICAP). In addition, CCOA provides weatherization services in Canyon County. For
simplicity, references to CAPs in this report include CCOA.
Rocky Mountain has two CAP agencies in its Idaho service territory, both of which it shares with Idaho Power
(SEICAA and EICAP).
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IPUC Staff Low Income Report
Attachment A
also recommends that Avista and Rocky Mountain Power consider adopting Idaho Power's
scalable approach to paying for measures to allow for more strategic and cost-effective
investments if Idaho Power's impact evaluation shows that this technique was effective.
Project-Funding Parity
Avista's low income weatherization program has struggled with cost-effectiveness much
more than the other two utility-funded programs. Staff investigation discovered that the cause
of this problem has been two-fold. First, the 2010 Cadmus process evaluation revealed that
insufficient data collection about heating sources and prioritizing federal funding guidelines over
utility cost-effectiveness concerns contributed to the deficiency. These implementation problems
can be corrected without obtaining the Commission's specific permission. Avista has already
begun working with its CAP to collect more accurate pre and post-weatherization heating source
data and prioritize utility cost-effectiveness.
However, the second problem requires Commission action. Currently, Avista pays 100%
of the project cost for the measures it funds in a home and in addition, pays its CAP agency a
15% administrative fee for each measure funded. Idaho Power and Rocky Mountain Power pay
85% of the project cost per home. Idaho Power pays its CAP agencies a 10% administrative fee
per home, and Rocky Mountain Power pays a 15% administration fee per home. Avista's larger
financial contribution in both categories significantly reduces cost-effectiveness.
Staff recognizes that the 100% funding and higher administrative fee from Avista provide
more spending flexibility for its CAP agency. While Staff supports fees that promote
administrative effectiveness, Staff is concerned that higher fees decrease cost-effectiveness. In
the interest of preserving Avista' s low income program for the long-term, Staff recommends that
Avista pay 85% per project (up to 100% per measure). Cost-effectiveness will be increased by
funding a smaller percentage of each project, but continuing to claim 100% of the energy
savings.
Reducing the percentage per measure that Avista funds will allow Avista to fund a
greater percentage of the more cost-effective measures and a smaller percentage of the less cost-
effective measures. This scalable approach, already used effectively by Idaho Power, will allow
Avista to fund the most cost-effective measures in a home. As previously discussed, the Staff
also recommends that Rocky Mountain Power consider allocating funds on a scalable approach,
depending on the cost-effectiveness of the measure, if Idaho Power's impact evaluation shows
that this approach improves cost-effectiveness.
Recommendation 15: Staff recommends that Avista pay no more than 85% of the cost
per project and up to 100% of the cost per measure. This adjustment will increase the cost-
effectiveness of Avista' s program and facilitate cost-effectiveness comparisons between the three
utilities.
33
IPUC Staff Low Income Report
Attachment A
Funding Levels
Funding Methodology
Staff concedes that the need for low income weatherization exceeds available funding.
According to the CAP agencies, utility funding for these programs is between 20% - 60% of the
CAPs' weatherization funding. This percentage is likely to grow as federal funding shrinks.
How to correctly determine each utility's funding levels was a contentious point in recent
cases addressing low income weatherization. CAPAI has consistently argued for "parity," which
CAPAI defines as each utility funding about an equal dollar amount per residential customer. 48
CAPAI calculates parity by dividing the total low income weatherization program funding by the
number of each utility's Idaho residential customers to arrive at a per capita funding level.
Staff and the Commission have disagreed with CAPAI's definition of "parity," where
dollars per residential customer is the sole factor used to establish equivalent funding levels.
CAPAI's parity methodology provides no logic for the three utilities' current funding levels. It
also does not necessarily correlate to the need for low income weatherization in a utility's service
territory. To address these issues, the Commission ordered that many factors besides similar per
capita funding levels be considered to determine need, including employment rates, poverty
rates, number of electrically heated homes, and CAP agency waiting lists in each utility's service
territory.49
During the workshop, participants identified two broad options by which to create a
funding methodology. The first option was to develop a funding metric by assigning dollar
values to specific data points, used as proxies for need, within each service territory. The second
option was to let CAPAI' s state-wide LIHEAP recipient list serve as a comprehensive
weatherization waiting list. Staff developed a third option during its post-workshop analysis.
The three funding methodology options are discussed below.
Option 1: Funding Based on Need Indicators.
Under the first option, the funding methodology would instruct utilities to provide
funding that directly corresponds to poverty rates, unemployment rates, and/or other indicators of
need as prescribed by the metric. There was some discussion that several of these indicators
could be combined to create a funding formula for the utilities. This methodology would allow
funding to fluctuate as these indicators of need increase or decrease. While this broad approach
has merit with respect to its relationship to need, utility and CAP weatherization program
planning and delivery could be adversely affected by frequently changing funding levels.
' In the recent rate cases, it was determined that Idaho Power and Rocky Mountain Power spend about $3.06 and
$5.32 respectively per residential customer on low income weatherization. As a dual fuel utility, Avista spends
about $4.00 per residential customer on electric low income weatherization measures, or $6.69 per residential
customer on both gas and electric low income weatherization measures.
49 Order No. 32426, Case No. IPC-E-I 1-08, page 15.
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IPUC Staff Low Income Report
Attachment A
After the workshop, Staff further examined the possibility of calculating the need for
weatherization services based on metrics commonly associated with low income customers (e.g.,
poverty rates, unemployment, etc.). Some of these data were available through the U.S. Census
and American Community Surveys, but it was very difficult to tailor these data to specific utility
service territories, and it was impossible to equate the need for weatherization services to any of
these data. Most poverty data are available by county, but utility service territories rarely follow
county lines. For example, Idaho Power and Rocky Mountain Power split Bannock County,
where the large population center of Pocatello is located. Very detailed geographical poverty
data would be needed to identify utility-specific data for Bannock County.
Similarly, many other municipal or cooperative electric companies such as Idaho Falls
Power serve electric customers within specific counties. Low income customers served by these
utilities would need to be removed from the county level poverty data to provide accurate low
income customer data for investor-owned utilities.
It is also difficult to determine how heavily each of the metrics should be weighted. For
example, during the workshop, participants acknowledged that poverty is not necessarily
correlated to unemployment. Further, the broad poverty data available for each of the utility
service territories showed relatively similar levels of poverty for each utility. 50 Another
drawback of using a data-based metric to determine need and subsequent funding levels is that
the most geographically specific data available is only generated once every five years. The
American Community Survey (ACS) uses U.S. Census data collected over a five year period and
weighted to be representative of the population over that period. A one year sample focuses on
areas with populations greater than 65,000. Given Idaho's population density, the five year
sample is the most appropriate one to use when trying to match the data to each utility's service
territory.
Further, poverty statistics are based on a percentage of individuals, whereas
weatherization occurs at the household level. At the household level, ACS data are available for
family households and non-family households. Family households are defined as a householder
living with one or more individuals related to him/her by birth, marriage, or adoption. Non-
family households are defined as householders living alone or with non-relatives only. Further
stratification of the household data by income level is only available for family households.
Excluding non-family households is a large omission in most Idaho counties; on average, it
would exclude more than one-quarter of all households.
The shortcomings of devising a data-driven metric compelled the workshop participants
to return to focus on a waiting list methodology to derive need and funding levels. CAP waiting
lists have previously been cited to show the need for weatherization rather than to establish
funding "parity" among utilities. As determined in the Idaho Power and Rocky Mountain Power
50Although poverty data do not align with utility service territories, it is possible to generate a broad poverty
estimate for each utility by collecting poverty rates for all counties in a utility's service territory, even if the utility
does not serve the entire county. Using this method, the 2009 poverty rate for Avista was 16.1%, 14.9% for Rocky
Mountain Power, and 14.7% for Idaho Power.
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IPUC Staff Low Income Report
Attachment A
rate cases,5 ' the waiting lists maintained by the individual CAP agencies cannot be used as a
funding tool because each CAP manages its list differently.
Option 2: Funding Based on LIHEAP Recipient List.
Under the second option, CAPAI's state-wide LIHEAP recipient list would serve as a
comprehensive weatherization waiting list. The CAP agency enters LIHEAP applicants into the
central database when they apply with the CAP for benefits. Weatherization candidates are
almost exclusively drawn from the LIHEAP recipient list. While the LIHEAP data is not a
"waiting list," it is an accurate list of each program year's LIHEAP recipients. 12 Further, CAPAI
has access to and can combine LIHEAP data with data on homes weatherized under both federal
and utility programs into a single database. For simplicity, we refer to this combined database as
"LIHEAP data" or "LIHEAP lists" in this report.
CAPAI assured the workshop participants that the LIHEAP list can be sorted by utility
and primary heat source, so that the waiting list, or need, for weatherization services would be
accurate by fuel type for each utility's service territory.53 Funding levels providing "parity"
based on this data could require each utility to provide sufficient annual funding to weatherize a
certain percentage of their low income customers' homes not previously weatherized as it
appears on the LIHEAP recipient list.
After the workshop, Staff received and reviewed CAPAI's LIHEAP recipient lists from
the last five years in an effort to construct a funding mechanism. During its review, Staff found
inconsistencies in the LIHEAP data that make them unsuitable as a base for establishing a
funding mechanism.
Staff's primary concern is that the LIHEAP recipient list could not be closely replicated
when data for the same year was downloaded from the central database by CAPAI on two
separate occasions. It was later determined that recent changes by CAPAI's information
technology department skewed the data on the second data download, but this was not
immediately evident. Staff believes it is inappropriate to link a funding mechanism solely to a
data collection system that does not produce consistent data for historic program years.
Staff explored the possibility of corroborating the LIHEAP data with utility data to make
it robust enough to support a funding mechanism. Since each utility tracks LIHEAP recipients
and the homes in its service territory have participated in the low income weatherization
program, Staff reasoned that each utility would have sufficient data to determine the number of
electrically-heated and not-previously weatherized LIHEAP recipients in its service territory.
However, utilities have no method to track homes that have been weatherized solely using
federal funding. Therefore, a "waiting list" of eligible homes generated by utility data would
51 Case numbers IPC-E- 11-08 and PAC-E- 11-12, respectively.
52 The LIHEAP program years runs from October 1 of the first year through September 30 the next year.
This would ensure that only electrically-heated homes populate the waiting list for each utility.
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IPUC Staff Low Income Report
Attachment A
incorrectly include homes previously weatherized with federal money. This would create an
inflated tally of homes eligible for weatherization.
Staff also tried to corroborate CAPAI's LIHEAP data with Idaho Department of Health
and Welfare (DHW) data, since DHW is the state agency that issues LIHEAP payments.54
Unfortunately, DHW's LIHEAP data do not track which LIHEAP recipients have been
weatherized with either utility or federal money, which means that no useful waiting list estimate
can be derived from these data.
CAPAI has created a database that links LIHEAP recipient data with data on homes
weatherized with utility and federal funding. Despite its shortcomings, it is the only data set that
can generate a reasonable approximation of need for weatherization in each utility's service
territory.
Option 3: A Combination of Factors
Since neither of the options discussed at the workshop generated a feasible funding
methodology, Staff developed a funding framework that incorporates, but does not solely rely
upon, the two previous options. Staff believes that the LIHEAP recipient data shortcomings
make those data unsuitable for establishing a strict funding mechanism. However, Staff believes
that if multiple downloads of the LIHEAP data produce consistent findings in the future, those
data may be sufficiently accurate to be included as one of several factors used to inform funding
decisions.
In the absence of a stand-alone waiting list methodology, Staff recommends that a
combination of factors be considered for funding decisions. Most importantly, Staff believes
that in order for a utility's funding to be increased, it must be shown that the program is cost-
effective. No program should receive a funding increase if it is not cost-effective according to
the criteria outlined in this report. After a program is determined to be cost-effective, at least
five factors should be examined to determine if a funding increase is appropriate.
1.Funding could be increased if the list of not-previously weatherized homes waiting
for weatherization (as indicated by the LIHEAP data) has increased significantly
since the last review.
2.Funding could be increased if a utility's program provides significantly less funding
on a per-capita basis than the cost-effective program of another utility operating
within the state of Idaho with comparable poverty levels in its service territory.
3.Funding could be increased if the utility is awarded a significant base rate increase.
Rate increases impact low income customers more adversely than other customers,
therefore it could be appropriate to provide increased funding for low income
weatherization when rates increase.
The DWH makes LIHEAP payments to each utility for LIHEAP participants.
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IPUC Staff Low Income Report
Attachment A
4.Funding could be increased if the utility does not have sufficient funds to acquire the
annually achievable low income energy savings potential as indicated by the utility's
most recent Conservation Potential Assessment (CPA). This criterion is similar to
how utilities fund other DSM programs.
5.Funding should not be increased if a utility's CAP agencies have been unable to
spend all of the available utility funding in the previous year.
While these criteria do not form a rigid funding mechanism, they do respond to the
Commission's order to incorporate multiple factors into a funding methodology, provide parties
with a more clear understanding of how Staff will analyze funding levels, and provide discretion
to establish funding levels that are specific to each utility. This methodology will also limit the
possibility of unintended consequences that a strict metric might impose, such as reduced
funding amounts if the LIHEAP list of not-previously weatherized homes were to decline.
Incorporating the findings of each utility's CPA will also more closely align low income
weatherization funding levels with the method used to determine funding levels for other DSM
programs.
Staff agrees with Rocky Mountain Power that the Commission-ordered funding amounts
are not maximum amounts, and that if a program is cost-effective, each utility may fund beyond
the Commission-ordered minimum. Avista exceeded its program budget in 2010 and recovered
the overage through its tariff rider. Idaho Power has not exceeded the funding for its base-rate
funded low income program, but has increased funding for low income customer by creating a
second weatherization program funded by the tariff rider, Weatherization Solutions for Eligible
Customers (WSEC), to serve customers whose income slightly exceeds the limits to qualify for
its original low income weatherization program. These examples show that the Commission-
ordered funding does not strictly limit funding—utilities are free to fund more cost-effective low
income weatherization through their tariff riders, just as they would any other DSM program. If
WAQC is determined to be cost-effective, Staff believes that Idaho Power could provide more
funding for that program through the tariff rider without seeking a Commission order, even
though most of that program is funded through base rates.
Idaho Power has long believed that low income weatherization funding "should be based
on each utility's need for cost-effective [Low Income Weatherization Assistance] LIWA services
rather than an unrelated level of parity across the different regions of Idaho."55 To develop a
funding mechanism that meets this goal, Idaho Power suggested beginning with the LIHEAP
recipient list "(with proven consistency of counting methodology between agencies and counting
households, not individuals "56 and remove from the list all non-electrically heated homes,
remove all non-Idaho Power customers, remove auditor-affirmed incorrect (self-reported)
heating sources, remove auditor-affirmed households with no cost-effective weatherization
Case No. IPC-E-11-08, Drake Rebuttal, page 15.
56 Underlining in the original.
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IPUC Staff Low Income Report
Attachment A
potential, and remove previously weatherized homes. Staff agrees that if the LIHEAP data were
sufficiently robust or able to be corroborated with either utility or Idaho Department of Health
and Welfare data, this method would be ideal. However, the absence of accurate data compels
Staff to recommend that other factors, in addition to the LIHEAP data, be considered to
determine funding levels.
Rocky Mountain Power says that it is "open to discussing funding methodologies.., that
incorporate the economic condition of a utility's service territory" if the program is cost-
effective. Avista has stated a preference for retaining CAPAI' s per capita funding methodology.
Recommendation 16: Staff recommends that no program should receive a funding
increase if it is not cost-effective according to the criteria outlined in this report. After a program
is determined to be cost-effective, at least five factors should be analyzed to determine if a
funding increase is appropriate.
1.Funding could be increased if the list of not-previously weatherized homes waiting
for weatherization (as indicated by the LIHEAP data) has increased significantly
since the last review.
2.Funding could be increased if a utility's program provides significantly less funding
on a per-capita basis than the cost-effective program of another utility operating
within the state of Idaho with comparable poverty levels in its service territory.
3.Funding could be increased if the utility is awarded a significant base rate increase.
Rate increases impact low income customers more adversely than other customers,
therefore it could be appropriate to provide increased funding for low income
weatherization when rates increase.
4.Funding could be increased if the utility does not have sufficient funds to acquire the
annually achievable low income energy savings potential as indicated by the utility's
most recent Conservation Potential Assessment (CPA). This criterion is similar to
how utilities fund other DSM programs.
5.Funding should not be increased if a utility's CAP agencies have been unable to
spend all of the available utility funding in the previous year.
Continue Funding Low Income Weatherization Programs at Current Levels
Staff concedes that by any measure, the need for low income weatherization exceeds
current funding levels. Staff also recognizes that reductions in federal funding and a continuing
poor economy further increase the demand for utilities to expand their funding commitments.
But Staff uses a cost-effectiveness standard to evaluate utility DSM programs. Staff must ensure
that these programs directly benefit the utility and its customers and are not viewed as public
assistance. Staff cannot recommend increases in low income weatherization funding if these
programs cannot reasonably be shown to be cost-effective without the addition of broadly-
defined non-energy benefits.
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IPUC Staff Low Income Report
Attachment A
After the adjustments to cost-effectiveness calculations and program implementation
improvements recommended in this report are applied, Staff believes that all three electric low
income weatherization programs will be either cost-effective or nearly cost-effective. However,
it will take some time for these changes to take effect. While Staff does not recommend funding
decreases until the programs are shown to be cost-effective, Staff does not recommend that
funding levels for these programs increase.
Staff recommends that a possible funding increase for Idaho Power be reviewed after the
results of its impact evaluation are published in spring 2013. This will allow parties to review
the cost-effectiveness of Idaho Power's program when those ratios include verified energy
savings, rather than the estimates generated by the EA5 software.
Staff recommends that a possible funding increase for Rocky Mountain Power be
reviewed after its new data collection system is fully implemented and after the 2012 program
data has been analyzed for cost-effectiveness under the recommendations in this report. Staff
anticipates that both of these requirements will be met when Rocky Mountain Power publishes
its annual DSM report in spring 2013.
Based on the low cost-effectiveness ratios and implementation recommendations, Staff
recommends that funding review for Avista's low income weatherization program is delayed
until at least 2014. Staff believes that the extra time will allow Avista and its CAP agency to
implement and review program changes for impacts on cost-effectiveness, and makes sure that
those improvements persist.
Recommendation 17: Staff recommends continued funding for Idaho Power, Avista, and
Rocky Mountain Power's low income weatherization programs at current levels. Staff believes
that funding increase requests for Idaho Power and Rocky Mountain Power could be considered
after both companies publish their annual DSM reports in spring 2013. Staff recommends that a
funding increase request for Avista be delayed until at least spring 2014 to allow time to
implement the more extensive program modifications and determine if those modifications
succeed and persist in improving cost-effectiveness.
Background and Program Summary: Low Income Energy Conservation Education
Programs
The Commission has approved funding for Low Income Energy Conservation Education
(Con-Ed) Programs for all three utilities while leaving program design, implementation, and
management to the discretion of the utilities and the CAPs. While the three utilities' Low
Income Weatherization Programs are well-established and quite similar regarding program
delivery, their low income energy Con-Ed Programs are in the early stages of development. The
Con-Ed programs' shared goal is to help low income customers reduce their energy consumption
or teach them how to maximize the benefits of the weatherization measures they receive.
In general, some uncertainty has surrounded the low income Con-Ed Programs. This
uncertainty partly stems from the Con-Ed programs' historical pairing with low income
40
IPUC Staff Low Income Report
Attachment A
weatherization programs. The Commission has granted funding for Con-Ed programs without
explicitly designating how the funds should be spent or indicating the appropriate level of utility
oversight. After receiving funding, the utilities, CAPAI and the CAPs developed plans on how
to spend the funds allocated. Staff believes funding was provided to allow for experimentation
with program design and delivery.
CAPAI will evaluate Rocky Mountain Power's Con-Ed Program for 2011 and 2012, with
a report due by June 2013. Staff believes that an independent, third-party evaluation of all three
utilities' programs may be needed in the future. Staff continues to have some concerns about the
efficacy of these programs as currently designed, and looks forward to reviewing CAPAI's
analysis of Rocky Mountain Power's Con-Ed program.
In Staff's opinion, Con-Ed Programs are separate, stand-alone programs. Con-Ed
Program delivery and strategy does not duplicate weatherization services, so delivery and
strategy of the two programs are unlikely to align; they should, however, be complementary.
Staff has several expectations for these programs. As funders, utilities should be involved in the
design, delivery, and oversight of the programs. Each program should benefit low income
customers in Idaho and have clearly defined target audiences and goals. Program budgets should
reflect how utility funding will be used.
Treating the low income weatherization and Con-Ed Programs as separate programs also
makes sense from the standpoint of determining cost-effectiveness. As is the case for other
education programs in which energy savings are very difficult to determine, standard cost-
effectiveness tests are meaningless when applied to Con-Ed programs. Moreover, the cost-
effectiveness of a weatherization program is reduced when the cost of a Con-Ed Program is
included because there is often no corresponding verifiable benefit in terms of energy savings.
At current funding levels, the impact on cost-effectiveness is quite small; however, if funding
amounts grow, the negative impact will become more significant.
Idaho Power's Con-Ed Program has the largest budget ($125,000 annually) and has been
in place the longest of the three utilities' Con-Ed programs. Designed in 2009, the program
funds distribution of energy efficiency kits and in-house workshops run by Community
Education Specialists in each of the five CAP agencies located in Idaho Power's service
territory. The program targets Idaho Power customers who heat their homes electrically, receive
LIHEAP benefits, and are not on the weatherization assistance priority list. 57 The CAP agencies
provide participants with kits and information about energy efficiency and behavioral steps that
can be taken to reduce residential energy usage.
Energy efficiency kits include CFLs, low-flow showerheads, and other low cost, easily-
installed measures. 58 In 2010, the CAP agencies distributed all 2,594 kits purchased by Idaho
" Individuals over 60 years old, families with children under 6 years old, and persons with disabilities are prioritized
for weatherization services. Idaho Power's Low Income Energy Conservation Program targets customers who do
not meet these criteria and therefore are less likely to receive weatherization assistance. 58 Each kit cost about $40 and contains two compact fluorescent bulbs, rope caulk, set of "draft stopper" outlet
gaskets, 1.5 GMP kitchen aerator with flip, Oxygenic low flow shower head, digital thermometer, LED Nightlight,
41
IPUC Staff Low Income Report
Attachment A
Power, but in 2011 the CAP agencies distributed only 1,460 of the 2,127 kits that were
purchased. Due to the difficulty in getting low income customers to attend educational
workshops, most customers now receive a kit during the LIHEAP intake interview and are
provided with one-on-one energy Con-Ed counseling. Of Idaho Power's $125,000 annual
program funding amount, 30% is allocated for delivering the program and 70% is used to buy
kits.
Avista's $50,000 annual budget for its low income Con-Ed Program funds low income
outreach and energy conservation education activities by the CAP agency serving northern Idaho
and eastern Washington. 59 In 2010, the Lewiston-based Community Action Partnership created
a full-time Home Energy Conservation Educator position. The Educator meets with program
participants at agency offices or during one-on-one home visits, conducts in-house agency
workshops, and attends community or Avista-sponsored events. Participants are informed about
energy efficiency and behavioral steps that can be taken to reduce residential energy usage. In
general, participants either receive LIHEAP benefits or are presumed to be low income, but
attendance at workshops and events is not restricted to customers of Avista. A pilot program
targeting Avista's Washington and Idaho low income customers began in May 2011. Through
mid-April 2012, 21 Idaho households had participated in one-on-one home visits conducted
simultaneously with weatherization energy audits. Of the $40,000 paid by Avista in 2011, 70%
was allocated for the payment of the Home Energy Conservation Educator's salary and fringe
benefits, 15% for office space, 9% for travel, and 6% for administrative costs.
Rocky Mountain Power gave $50,000 to the two CAP agencies in its service territory to
develop an energy conservation program specifically targeted to Rocky Mountain Power's low
income customers. The resulting program is like Idaho Power's program (i.e., the program
provides in-house workshops and distributes energy efficiency kits), but it also includes one-on-
one home visits. The goal is to provide in-house workshops to 500 Rocky Mountain Power
customers who have electric space heating and receive LIHEAP benefits, but who have not
received weatherization assistance. Each workshop participant receives a kit that contains low-
cost energy saving items to install in his/her home including information about energy efficiency
and behavioral steps that can be taken to reduce residential energy usage.60
After a long delay, Rocky Mountain Power's Con-Ed Program was implemented in June
2011 with the goal of serving 500 households. 6' By the end of 2011, 168 households had
received energy Con-Ed and an energy efficiency kit. To increase workshop participation, the
CAPs expanded the Con-Ed Program to include Rocky Mountain Power customers with gas
installation guide with energy savings information, set of sticker/magnets, CFL informational brochures with
mercury safety information, and educational and cross-marketing literature,
Energy service providers within the CAP service area in Idaho include co-ops, municipalities, and Avista. Based
upon historical data, Avista serves about 75% of the area's customers.
60 Each kit costs about $15 and contains three Energy Star compact fluorescent bulbs, a refrigerator temperature
card, a kitchen sink aerator, a package of 10 outlet sealers, and a luminescent night light.
61 In April 2009, the Commission approved $50,000 in Con-Ed program funding in Case No. PAC-E-08-07, Order
No. 30783.
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IPUC Staff Low Income Report
Attachment A
space heating. As of July 1, 2012, 252 households (51% of the goal) had completed the
program.
Of the $50,000 allocated for the program, 15% was used to buy 500 kits and 85% went to
program delivery. Rocky Mountain Power says its $50,000 budget was a one-time amount,
whereas Staff and CAPAI maintain that it is an annual budget. The issue remains unresolved.
Staff doubts the Commission intended for one utility to provide one-time funding while the other
two utilities fund annually. While CAPAI and the CAP agencies have had problems setting up
the Con-Ed program and spending the original funding allocation, Staff supports annual funding.
Rocky Mountain Power told Staff that it is willing to provide funding on an annual basis but that
the funding amount should be changed.
Because these programs are still evolving, the utilities, CAP agencies, and CAPAI agreed
during the workshop that there is no need to increase annual funding levels for any of the
utilities' Con-Ed programs now. Rocky Mountain Power believes that its funding amount should
be decreased to better match the other two utilities on a per residential customer basis.62 Staff
recognizes that it has taken Rocky Mountain Power's CAPs more than two years to spend the
Con-Ed funding amount. This suggests that $50,000 is an excessive annual funding amount. 63
Further, Rocky Mountain Power's funding level is the same as Avista's even though Rocky
Mountain Power has about half as many electric residential customers. Staff concludes that
Rocky Mountain Power's funding amount is too large, and should be reduced to $25,000
annually, which is about $0.44 per residential customer.
Table 5: Current Conservation Education Funding
Category Idaho Power Avista Rocky Mountain
Funding Level $125,000 $50,000 $50,000
Number of Electric
Residential Customers 391,759 10460964 57,187
Funding per Customer $0.32 $0.48 $0.87
Table 6: Staff's Proposed Conservation Education Funding
Category Idaho Power Avista Rocky Mountain
Funding Level $125,000 $50,000 $25,000
Number of Electric
Residential Customers 391,759 104,609 57,187
Funding per Customer $0.32 $0.48 $0.44
62 In its calculation, Rocky Mountain Power used slightly higher customer number for Idaho Power than Staff used.
The lower customer count increased Idaho Power's funding per customer from $0.03 to $0.32.
Rocky Mountain Power's Con-Ed program spent $7,500 in 2010 and $42,500 in 2011. The 2011 expenditure
allowed the CAPs to stockpile kits.
64 In Order No. 32650, the Commission granted Avista's request to suspend their natural gas DSM portfolio.
Therefore, Avista's Con-Ed program should be based on their electric residential customer count. Using only
Avista's electric residential customer count increases its per-customer funding amount from $0.30 (based on both
electric and gas customer count) to $0.48.
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IPUC Staff Low Income Report
Attachment A
Staff recommends that the Commission make a determination that $25,000 program
funding be provided on an annual basis. Staff recommends that the Commission order be
effective no sooner than June 2013. Staff anticipates that the CAPs will be able to serve Rocky
Mountain Power customers through the 2012-2013 heating season with the large, existing
stockpile of energy efficiency kits.
Recommendation 18: Staff recommends that utilities' annual DSM reports separately
address their Low Income Energy Conservation Education Programs. At a minimum, Staff
expects each report to describe program design, identify target audience(s), gauge the program's
success in meeting its goals, indicate how utility funding was used, and describe how the
program benefits the utility's customers. As with other education programs in which energy
savings are often very difficult to determine, the Con-Ed programs should not be subjected to
standard cost-effectiveness tests like the TRC and UCT. Staff recommends maintaining the
current annual Con-Ed program funding level for Avista and Idaho Power. Staff recommends
that the Commission adjust Rocky Mountain Power's funding to $25,000 beginning in June 2013
with the clear understanding that this amount should be funded annually.
Low Income Weatherjzatjon and Energy Conservation Education Programs Conclusion
Staff believes that current cost-effectiveness methodologies should be changed as
recommended in this report to more accurately measure the value of low income weatherization
programs. While all three utilities' programs in Idaho face challenges, Staffs analysis suggests
that all of the programs can be a cost-effective DSM resource for ratepayers over the medium to
long-term. While Staff cannot support an increase in low income weatherization funding
immediately, Staff believes that current funding levels for all three utilities are sufficient to
continue program activities while cost-effectiveness is being examined in more detail.
Therefore, Staff recommends that funding levels for all weatherization programs remain
unchanged until at least spring 2013 for Idaho Power and Rocky Mountain Power, and 2014 for
Avista.
The Low Income Energy Conservation Education Programs are still in the early stages of
development and Staff anticipates further refinements will be made to each program. Although
Staff believes the Con-Ed programs are separate, stand-alone programs to which standard cost-
effectiveness test do not apply, program success must still be measured and customer benefits
identified. Staff recommends maintaining the current annual Con-Ed program funding level for
Avista and Idaho Power, and adjusting Rocky Mountain Power's funding to $25,000 annually.
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IPUC Staff Low Income Report
Attachment A
Appendix 1: Low Income Workshop Agenda
Idaho Public Utilities Commission
Workshop on Low Income Weatherization and Energy Conservation Education Programs
funded by Avista, Idaho Power, and Rocky Mountain Power
Workshop Goal: "The purpose of the workshop is for the utilities, interested persons, and
Commission Staff to explore in greater detail issues related to the funding, implementation, and
evaluation of utility low-income weatherization and energy conservation education programs.
Following the workshop, Commission Staff shall prepare and submit a report of its findings and
recommendations."
Notice of Public Workshop, Case No. GNR-E-12-01
Location: Hearing Room, Idaho PUC, 472 W. Washington Street, Boise, Idaho
Dates: March 19 & 20, 2012
Monday, March 19, 2012
10AM-4:30 PM
10:00 - 10:30 AM - Workshop Overview
• Welcome & workshop logistics
• Introductions
• Workshop goal & agenda
10:30 AM - 1:00 PM - Program cost-effectiveness & evaluation
• Review Total Resource Cost Test (TRC) and Utility Cost Test (UCT)
• Review Savings to Investment Ratio (SIR)
• Explanation of avoided costs
• Summary of current programs' cost-effectiveness
• Explore major differences among utilities' TRC/UCT calculations
• Energy savings estimates
EA4/5 audit, deemed savings, and billing analysis
• Net to Gross Factor
Appropriate percentage to claim
• Percentage of cost paid by utility for each measure
Fixed or variable percentage per measure
• Utility's internal administration costs
What is included and not included
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IPUC Staff Low Income Report
Attachment A
• Third-party program evaluation costs
Included in single year CE or amortized over several years
Included at program or portfolio level
• Energy Conservation "Adder"
10% added to avoided cost
10% added to TRC
• Non-Energy Benefits
Health and Safety measures as NEBs
Reduction in arrearages
Reduction in bad debt
Reduction in disconnection expenses
NEBs not easily quantified
Others
• Creating a Low Income TRC
• Evaluation Methods
o Alternatives or complements to billing analysis
o Billing analysis methodology
Control for rate increases and economic fluctuations
Control for savings attributed to service disconnections
Control for previously weatherized homes
Other possible improvements
o Measure life benefits for reduction in arrearages
1:00 - 2:30 PM - Break for lunch (on your own)
2:30 - 3:30 PM - Wrap up discussion on cost-effectiveness (if necessary)
3:30 - 4:30 PM - Program implementation
• Fixed annual funding (use it or lose it) or roll-over of unspent funds
• Approved measures: per project or per program
• Capture of project-level data to enable evaluation & program management
Tuesday, March 20, 2012
9:00AM-4:30PM
9:00 - 11:00 AM - Determination of need for & appropriate funding level for Low-Income
Weatherization Programs
• Determining need
o Number of low-income customers in service territory/poverty rates
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IPUC Staff Low Income Report
Attachment A
• Number of low income homes needing weatherization
• Number of electrically-heated low-income homes
• Number of customers on CAPs' waiting lists
• "Parity" based on number of customers served by each utility
• Other factors
• Possible metrics for determining program funding level
LOWINCOME ENERGY CONSERVATION EDUCATION PROGRAM
11:00 AM - 12:00 PM - Program overview
• Staff summary of program status
• Stand-alone program - not part of Low Income Weatherization Program and not subject
to standard cost-effectiveness tests (TRC & UTC)
• Determining need - what sets it apart from utilities' energy efficiency/energy
conservation efforts targeted to other customers or specific constituencies (schools,
seniors, etc.)
12:00 PM - 1:00 PM - Break for lunch (on your own)
1:00 PM - 3:30 PM - Program design/funding/evaluation
• Program design
o Curriculum
o Distribution of products & educational materials
o Client selection (who gets what)
• Similarity among CAPs
• Evaluation methods
• Program funding level
• Allocation of funding among CAPs
NEXT STEPS
3:30 - 4:30 PM - Determination of next steps
• Following the workshop, Staff will prepare and file a report providing Staff's findings &
recommendations to the Commission.
• Any areas of general agreement among workshop participants will be noted in the report.
• The report will include recommendations on whether further proceedings and/or hearings
are necessary.
• After submission of Staff's report, participants and other interested parties will have an
opportunity to file comments with the Commission.
47
IPUC Staff Low Income Report
Attachment A
Appendix 2: Utility Low Income Matrices
Idaho Utility Funded Low Income Weatherization Program Overview
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IPUC Staff Low Income Report
Attachment A
Idaho Utility Funded Low Income Weatherization Cost-Effectiveness Calculations
TRC 1.66 .66 .18 .70
UCT 3.27 .66 .18 .70
CE based on
verified energy No Yes Yes Yes
savings
EA4 adjusted EA4 adjusted Billing analysis
Energy Savings EA4 Energy for billing for billing from '06
Estimates Audit estimate analysis from analysis from Cadmus Cadmus impact Cadmus impact evaluation evaluation evaluation
Equal to
% Savings proportion of
Claimed per funding per 100% 100% 100%
Home measure (up to
100%), up to 85%
per home
Net to Gross 80% 100% 100% 100%
10% of company 15% of 15% of 15% of company
% Admin to CAPs funded amount company company funded amount
per home funded amount funded amount per home per home per home
% Health and 15%ofannual 15% of 15% of 15%ofannual
Safety Measures total project cost company company total project cost
to CAPs funded by funded amount funded amount funded by
company per home per home company
Conservation 10% added to 10% added to In 2011 PTRC,
Adder None avoided cost avoided cost 10% added to
TRC
$1 invested for $1 invested for
Non-Energy None included health and health and Only in 2011 Benefits safety is $1 safety is $1
NEB NEB
Evaluation costs System level, System level, Program level in
incorporated for Program level in then allocations then allocations evaluation year.
CE at program or the evaluation are applied for are applied for May move to
portfolio level year states and states and sector sector or
sector portfolio level.
49
IPUC Staff Low Income Report
Attachment A
Idaho Utility Funded Low Income Weatherization Program Implementation
EA4 tool used to
have utility fund Yes No No No measures with
highest SIR
85% per house.
2010 % of Varies from 0- Up to 100% of Up to 100% of 75% of each
Measures Funded 100% by measure each measure each measure measure
based on SIR
85% per house.
2011 % of Varies from 0- Up to 100% of Up to 100% of 85% of each
Measures Funded 100% by measure each measure each measure measure
based on SIR
Measure By home using Pre-approved Pre-approved By home using
Approval EA4 list list EA4
Evaluation TBD in 2012 Method Billing analysis Billing analysis Billing analysis
Yes, but only 1 Yes, RMP goes
DOE/CAP Audits electrically Yes, Yes, once a year. No
(QA Inspections) heated home occasionally. occasionally. problems getting
audited electrically
heated homes.
Low Income Energy Conservation Education Funding
$50,000
2010 $125,000 $40,000 total, Included in annually/one-
annually annually electric amount time is
unresolved
2011 $125,000 $50,000 total
annually Included in
$50,000
annually/one-
annually (October 2011) electric amount time is
unresolved
50
IPUC Staff Low Income Report
Attachment A
Appendix 3: Non-Energy Benefits
Utility and Ratepayer Benefits
• Reduction in cost of collection for past due bills
o Fewer utility disconnections and reconnections
o Reduced utility bill arrearages
o Reduced cost of premise visits, handling payment arrangements and late
payments, etc.
o Fewer notices and collection calls
o Reduced need for special handling of bill payment assistance, e.g., LIHEAP
• Reduction in utility bad debt
Benefit to Weatherization Recipient/Property Owner
• Improved ability to pay bills due to lower energy costs
• Fewer utility disconnections
• Decreased utility bill arrearages
• Reduced need for bill payment assistance, e.g., LIHEAP
• Frees up household income for other needs
• Improved health and safety
• Fewer illnesses in household
• Reduction of chronic health problems, e.g., asthma
• Eliminates need to use unsafe alternative heating and lighting equipment due to
disconnection of utility service or equipment malfunction or failure, resulting in
fewer fires
• Improved comfort of occupants due to increased energy efficiency and equipment
repair/replacement
• Increased capital value/resale value of house
• Insurance
o Lower rates
o Improved ability to obtain insurance
• Tax benefits
o Credits from State or Federal government for energy efficiency investments; most
likely to accrue to property owners who financially contribute towards cost of
weatherization
• Reduction in mobility
o Ability to stay in home due to decreased energy use and improved infrastructure
51
IPUC Staff Low Income Report
Attachment A
• Equipment
• Longer life/delayed need to replace
• More reliability
• Less maintenance and repair
Societal Benefits
• Increased awareness of how to conserve energy and use energy more efficiently
• Increased stability of families due to reduction in mobility
• Ability to stay in home due to decreased energy use and improved infrastructure
• Improved public health and safety
• Fewer illnesses and chronic health problems originating in low income homes
• Reduced transmission of disease
• Fewer fires due to use of unsafe alternative heating or lighting equipment
• Reduced need for bill payment assistance increases availability of funds for others
• Preservation of low income housing by making structural repairs
Economic Benefits
• Income generated from employment in weatherization services industry
• Federal taxes generated from employment
• Avoided cost of unemployment benefits
Other
• Environmental concerns
• Reduction in CO2 and other pollutants - included in conservation adder
• Fish and wildlife mitigation
• Reduced usage of water and sewer
• Reduced transmission and distribution line losses - included in avoided cost
• National security enhanced by reduced reliance on foreign oil and increased reliance on
domestic fuels and conservation
52
IPUC Staff Low Income Report
Attachment A
Appendix 4: List of Low Income Workshop Participants
NAME Or2anization E-MAIL
Stacey Donohue IPUC
Bev Barker IPUC
Randy Lobb IPUC
Karl Klein IPUC
Nikki Karpavich IPUC
nikki.karpavich(puc.idaho.gov
Donn English IPUC
Curtis Thaden IPUC
stacey.donohuepuc.idaho.gov
beverly.barkerpuc.idaho.gov
randy.lobb2ipuc.idaho.gov
[e-mail]
[e-mail]
curtis.thadenpuc.idaho.gov
Bryan Lanspery IPUC
bryan.lansperycpuc.idaho.gov
Wayne Hart IPUC
Pete Pengilly Idaho Power
Theresa Drake Idaho Power
Cheryl Paoli Idaho Power
Jeff Bumgamer PacifiCorp
- ieff.burngarnercpacificorp.com
wayne.hartpuc.idaho.gov
ppengilly(idahopower.com
[e-mail]
[e-mail]
Esther (iiezendanner PacifiCorp [e-mail]
Becky Eberle PacifiCorp [e-mail]
Christina Zamora CAPAI czamora(capai.org
Julia Campbell SEICAA icampbell(seicaa.org
Ron Corta CCOA - WX [e-mail]
Kevin Viggers El-Ada CAP kviggers(gestoffice.net
Brad Purdy CAPAI [e-mail]
Teri Ottens CAPAI [e-mail]
Mary Chant CAPAI mchant(caai.org
Deb Hemmert SEICAA dhemmePseicaa.org
Bruce Folsom Avista [e-mail]
Jon Powell Avista [e-mail]
Nancy Hirsh NW Energy Coalition nancy(nwenergy.org
Chris Drake Avista [e-mail]
Linda Gervais Avista linda. gervaise(avistacorp.com
Greg Said Idaho Power gsaididahopower.com
Liz Woodruff Snake River Alliance lwoodruffsnakeriveralliance.org
Ted Weston Rocky Mountain Power [e-mail]
Carol Teats CCOA - Aging, Weatherization carolZuiccoaidaho.org
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IPUC Staff Low Income Report
Attachment A
Lisa Stoddard Community Action Partnership
[e-mail]
Lisa Nordstrom Idaho Power
lnordstrom@idahopowercom
Tami White Idaho Power [e-mail]
Darlene Nemnich Idaho Power [e-mail]
Julia Hilton Idaho Power ihi1tonidahopower.com
Randy Wright SCCAP randy2Isccap-id.org
Brad Simmons EICAP bsimmonseicap.org
Rick Burgin SEICAA rburginseicaa.org
Lenora M. Snipe ShoBan Consumer Services [e-mail]
Jacki L. Wynn ShoBan Consumer Services [e-mail]
Ben Otto ICL botto(idahoconservation.org
Lori Blattner Intermountain Gas 1ori.blattnerintgas.com
Byron Defenbach Intermountain Gas byron.defenbach(intgas.com
Lynn Young (Tuesday only) AARP 1ynnyoungspro.net
54
IPUC Staff Low Income Report
Attachment A