The URL can be used to link to this page

Home My WebLink About20080515Comments.pdfWELDON B. STUTZMAN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0318 IDAHO BAR NO. 3283 y i 5 Pi' 2: 33 Street Address for Express Mail: 472 WWASHINGTON BOISE ID 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ) IDAHO POWER COMPANY FOR AUTHORITY ) TO REVISE THE ENERGY EFFICIENCY ) RIDER, TARIFF SCHEDULE 91 ) ) ) ) CASE NO. IPC-E-08-3 COMMENTS OF THE COMMISSION STAFF COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its Attorney of record, Weldon B. Stutzman, Deputy Attorney General, and in response to the Notice of Application and Notice of Modified Procedure in Order No. 30520 issued on April 2, 2008, submits the following comments. BACKGROUND On March 14, 2008, Idaho Power Company fied an Application asking the Commission to approve an increase to its Energy Efficiency Rider (Rider) from 1.5% to 2.5% of base revenues effective June 1,2008. The Rider is a charge on customers' bils to fud conservation or demand-side management (DSM) programs implemented by the Company. The Commission initially approved a Rider in May 2002, and targeted an amount for collection at 0.5% of overall base revenue of each customer class. The initial charge for residential customers STAFF COMMENTS 1 MAY 15,2008 was set at $.30 per month and for irrigation customers it was capped at $15 per meter per month. At the 0.5% rate, the energy Rider provided approximately $2.6 milion anually for DSM programs. In May 2005, the Commission generally approved the Company's request to increase the Rider to 1.5% of base revenue applied uniformly to all customer classes. The Commission put a $1.75 monthly cap on the residential Rider charge and a cap of$50.00 per meter per month for irrigation customers. At the 1.5% rate, the energy Rider plus interest on the Rider balance provided approximately $8.6 milion in 2006 for DSM programs, while expenses charged to these programs totaled $8.8 milion and the year ended with a $5.9 milion positive Rider balance. In 2007 the Company collected approximately $9.0 milion from the Rider including interest on the balance, spent about $13.5 milion from the Rider fund, and ended that year with a $1.5 milion positive balance. The Application states that Idaho Power has been expanding its DSM programs and other energy efficiency initiatives since 2002, and anticipates that its DSM programs and initiatives will cost approximately $19.3 milion in 2008, $16.8 milion in 2009 and $17.0 milion in 2010, or $53 milion total for the years 2008-2010. By June 1,2008, the Application projected a $3.2 milion deficit in the Rider balance. However, in response to a data request received May 14,2008, the Company now estimates that the June 1, 2008, deficit wil be about $2.2 milion instead of $3.2 milion. The Company also cautioned that DSM expenditures, and thus the Rider balance, can deviate substatially from forecasts due to the lumpiness and unpredictability of large commercial and industrial DSM activity. Idaho Power proposes to increase the Rider from 1.5% to 2.5% of base revenue beginning June 1, 2008 to support expected conservation program expenditures. At that level, the Company projects a deficit of approximately $4.2 milion in the Rider balance by the end of2010. Accordingly, the Company also plans to request in its next general rate case authorization to include approximately $3.5 milion in anual labor and administrative expenses related to its planed DSM programs in its regular operations and maintenance expenses. If approved, the Company would use this $3.5 milion increase in base rates to pay for labor, contributions to the Northwest Energy Effciency Allance, and DSM deparmental costs not directly related to specific DSM programs. It is importt to note that Idaho Power now says it intends to pursue all cost-effective DSM regardless of any short-term Rider account deficits. (T. Tatum pre-fied testimony, p. 14) STAFF COMMENTS 2 MAY 15,2008 The Company also proposes to remove the current rate caps for residential and irrigation customers because DSM programs are now broadly available to all customer classes, all of which are benefitting from the Company's resource cost savings in proportion to their energy usage. Finally, the Application requests approval of revised language in the Energy Efficiency Rider tariff expanding the scope of Rider- fuded activities to include financial incentives for small-scale renewable energy projects (e.g. photovoltaic systems) to the extent that Idaho Power's program costs are shown to be cost-effective from the utilty's resource cost perspective. PROPOSED RATE INCREASE - PROJECTED REVENUES, EXPENSES AND BALANCE The curent rates in Schedule 91, Energy Effciency Rider, are 1.5% of base rates for each customer class, but with a residential cap of $1.75 per month and an irrigation cap of $50.00 per month per meter. The Application proposes to remove the two caps and increase the Rider rates to 2.5% of base rates for all customer classes, including its three special contract customers. Idaho Power projects the Rider increase and removal of caps to increase revenue available for DSM to $13.2 milion in 2008, to $16.9 milion in 2009, and to $17.3 millon in 2010. (see T. Tatu, Exhibit No.4) The Company projected its DSM expenses wil increase to $19.3 milion in 2008, drop to $16.8 milion in 2009, and then increase slightly to $17.0 milion in 2010. (Tatu, Exhibit No.3, Table I) However, given the previously mentioned $1.0 milion reduction in the projected Rider deficit ($2.2 milion instead of$3.2 milion) by June 1,2008, it is likely that Mr. Tatum's pre-filed projections would change if his testimony were amended today. Given the $1.5 milion positive Rider account balance at the beginning of2008, if the Rider is increased as proposed by the Company, the account balance was projected to have a $4.6 milion deficit by the end of2008. This deficit balance was projected to decrease only slightly to $4.2 milion by the end of201O. But if at the conclusion of its next general rate case, the Company is allowed to begin recovering about $3.5 milion ofDSM overhead expenses from its base rates, then the Company projects it will have a $2.5 milion positive account balance by the end of2010. (Tatum, Exhibit No. 3, Tables II and III) As previously noted and demonstrated, all of these projections are subject to customer choices and circumstances that are not predictable. It is also worth noting that in response to a staff request, the Company provided program-level expense detail for 2008 forecast (Attachment B), but could not provide such detail for 2009 and 2010 forecasts because those" ...long term expense projections ... are estimated at the customer class level not the program leveL." STAFF COMMENTS 3 MAY 15,2008 Idaho Power does not actually propose collecting additional DSM overhead expenses from base rates in this Application. Nor does the Company request that its past DSM expenses be determined by the Commission to have been reasonably and prudently incured. These issues are intended to be addressed in the Company's next general rate case. DEMAND SIDE MANAGEMENT (DSM) PROGRAMS Attachment A provides anual sumaries of reported program costs and energy or peak demand savings for each of Idaho Power's DSM programs from 2002 though 2007. Expected program costs in 2008 are listed in Attchment B, which was provided by Idaho Power on May 14, 2008, in response to a data request. Following are brief descriptions of the recent histories of each of Idaho Power's curent, major DSM Rider-funded programs based on information in its DSM Anual Reports and expense projections for 2008 based on Idaho Power's May 14,2008 response. Residential Programs Air Conditioning Cycling - the number of participants more than doubled from 2005 to 2006 and again from 2006 to 2007 when it had nearly 14,000 paricipants. The peak kilowatt (KW) savings increased from less than 3 MW in 2005 to nearly 11 MW by 2007, while Idaho Power's total costs increased from $0.8 milion in 2005 to $2.4 milion in 2007. In 2008 Idaho Power projects that it will spend $3.7 milion of DSM Rider fuds for this program. Energy House Calls - This program consists primarily of sealing ducts in mobile homes and until early 2007 was funded by the Bonnevile Power Administration (BP A) but is now funded by Idaho Power's DSM Rider. Paricipation dropped by nearly half in 2005 from the prior year and has slowly declined each year since then, as have the costs and the savings. In 2007 Idaho Power's Rider fuded about $250,000 on top ofBPA's $80,000. The Company projects it will spend $343,000 of Rider fuds on the program in 2008. Energy Star Homes - The number of new Energy Star homes and the total energy savings dropped by about 30% from 2006 to 2007, which is not unexpected given the general housing decline. The estimated percentage of Energy Star homes compared to total new homes increased from 3.9% in 2006 to 5.0% in 2007. Idaho Power's Rider fuded nearly $500,000 in 2006 and again in 2007, but that is projected to decrease to less than $400,000 in 2008. Much of the marketing for this program is performed through the Northwest Energy Efficiency Allance (NEEA). STAFF COMMENTS 4 MAY 15,2008 Rebate Advantage - This program to encourage purchases of energy effcient mobile homes was funded by BP A until early 2007. Paricipants increased by 20% from 2006 to 2007 after being nearly unchanged for the prior three years. In 2007 Idaho Power's Rider funded nearly $60,000 for this program on top ofBPA's $25,000. Rider fuding is expected to more than double in 2008. Energy Star Lighting (CFLs) - Historically, Idaho Power's CFL promotions have been leveraged and timed with promotions by NEEA and BP A. In 2007 Idaho Power's Rider provided a about $520,000 and is projected to provide about $750,000 in 2008. Heating and Cooling Effciency - This program to train heating and cooling technicians and provide incentives to customers essentially began in late 2007 and the Rider provided nearly $500,000 for the year. Idaho Power projects the costs will nearly double in 2008. Appliance Effciency - Idaho Power projects that in 2008 it will spend $300,000 on this new program that provides incentives for purchases of energy efficient appliances such as washing machines and refrigerators. Low-Income Weatherization - This program is curently not fuded from the DSM-Rider and is listed here only to provide a more complete picture of overall DSM activity. Idaho Power has provided more than $1.2 milion annually from base rates for this program since 2005. Commerciallndustrial Programs Building Effciency - The number of paricipants has been up and down again since 2005 for this new construction/major addition program, but Idaho Power's program costs have been steadily climbing as have the energy savings. In 2007 the DSM Rider provided about $660,000 and is projected to provide $800,000 in 2008. Easy Upgrades - This program was officially launched early in 2007 after being included in the 2006 IRP as a cost-effective resource. Most of the actual activity occurred in the latter half of2007 and the Rider provided $680,000. In 2008 the Rider is projected to provide nearly $1.4 milion. Custom Effciency - As a result of the 2006 IRP, this program grew from an expansion of the former Industrial Efficiency program that was originally identified in the 2004 IRP. In 2007, 49 large commercial and industrial customers paricipated with $3.0 milion of Rider-provided fuds. In 2008 Idaho Power projects the Rider will fud $4.7 millon for these large projects, but this is the program with the lumpiest and most unpredictable fuding needs. STAFF COMMENTS 5 MAY 15,2008 Irrigation Programs Irrigation Effciency - This program was significantly expanded in 2006. The costs and energy savings shr by about 1/4th in 2007, while the number of paricipants increased by nearly half. In 2007 the Rider provided $1.9 millon and is projected to provide a slightly lower amount in 2008. Irrigation Peak Rewards - The number of participants and Idaho Power's costs have slowly increased from 2005 to 2007. The Rider provided $1.5 milion in 2007 and is projected to provide the same amount in 2008. Regional Market Transformation Idaho Power has a five-year contract with the Northwest Energy Efficiency Allance (NEEA) for $1.3 milion anually in exchange for its paricipation in and benefit from NEEA' s regional energy efficiency market transformation activities. This contract rus from 2004 through 2009 and the monetar obligation is fuded from its Idaho DSM Rider, caryover from past contributions to NEEA, and from its Oregon service area. In addition to the 28,601 MWh that NEEA attributed to Idaho Power proportionately to its fuding level in 2007, some of Idaho Power's own DSM activities rely upon research, testing, marketing and demonstration programs performed or administered by NEEA. Renewable Energy Program Proposal The Application proposes that the Energy Effciency Rider be modified to allow fuding of renewable energy projects, e.g. photovoltaic systems. Mr. Tatu explains this proposal in more detail on pages 16-18 of his testimony, but does not provide a cost estimate. In short, because photovoltaic systems are not generally cost-effective, the Company would suspend its requirement that projects must be cost-effective from a total resource cost (TRC) perspective. Apparently Idaho Power believes it can offer financial incentives sufficient to encourage such systems, but stil small enough that they are cost-effective from the utilty's perspective. The limited perspective of the utility cost test ignores the possibilty that such projects may not be cost-effective for participants or for society as a whole. COST-EFFECTIVENESS OF IDAHO POWER'S DSM PROGRAMS Idaho Power's Technical Appendix D to its 2006 Integrated Resource Plan (lRP) states that for planning and evaluating the cost-effectiveness of its DSM programs, the Company follows the cost- effectiveness guidelines of the Electric Power Research Institute's (EPRI) 1991 End-Use Technical STAFF COMMENTS 6 MAY 15,2008 Assessment Guide (End-Use TAG) and the California Stadard Practices Manual: Economic Analysis of Demand-side Programs and Projects. i Mr. Tim Tatum's testimony (page 8) references the table ofDSM portfolio options at the bottom of page 73 of the 2006 IRP Technical Appendix D (Tatum Exhibit No.2) in stating that each of the DSM programs is expected to be cost-effective from both the total resource cost (TRC) perspective and the utilty cost test (UCTi perspective. However, the table he references actually shows only the expected cost-effectiveness of each customer sector's total DSM portfolio of programs, rather than the cost-effectiveness of individual programs. Idaho Power's 2004 and 2006 Integrated Resource Plans (lRP) provide somewhat more detail regarding cost-effectiveness of programs under consideration, but they are typically high-level reviews of potential programs that might be designed and implemented in the future. The anual DSM reports fied by the Company provide details of costs, energy savings and peak demand reduction achievements, but because these reports do not assign monetar values to the savings, they provide only cost per kWh savings or cost per kW savings and do not provide actual cost-effectiveness statistics. On May 14,2008, Idaho Power provided actual cost-effectiveness results of its 2007 program activity in the form of a cost effective limit (CEL), which is the calculation of levelized benefits per kilowatt-hour (kWh) using hourly load-shaped values for the estimated savings achieved by each DSM measure. The CEL metric appears to be appropriate, but it is different than what is normally reported to the Commission. The CEL is described in more detail on page one of Attachment C. Pages 2 and 3 of this Attachment list for 2007 each energy efficiency program Idaho Power costs, total resource costs, estimated anual energy savings and lives of those savings, the levelized utility and total resource costs per kWh saved and the levelized benefits (CEL) per kWh saved. As explained in the Attachment, simple division of the CEL by the levelized cost/Wh i Both manuals are good, commonly used tools for evaluating DSM cost-effectiveness, but the Staff has notified representatives of all Idaho electricity utilties of a potential disagreement with how ta credits are treated in the TRC formula. This has little impact, parly because Staff believes the VCT is the most important of the four standard tests. 2 The VCT perspective actually indicates the cost-effectiveness of utilty programs for customers as a whole, since they eventually pay the utilty's costs. STAFF COMMENTS 7 MAY 15,2008 produces the benefit/cost ratio. By this metric, given the inherent assumptions and unverified data and calculations, all of Idaho Power's 2007 energy efficiency programs are reported as having been cost- effective from both the UCT and the TRC perspectives. CUSTOMER COMMENTS AND STAFF RESPONSE As of Mayl4, 2008, the Commission had received four comments from the public. Three of these people seemed to be generally in favor of Idaho Power increasing its DSM Rider commensurate with its increased DSM program activity, but with some suggestions. The person entirely opposed to the Rider increase is a senior citizen living on a fixed income who said she already conserves electricity any way she can to keep her bil low, and that the surcharge "... means I have to pay for the rich who don't conserve." One person said the Rider ought to apply only to energy charges and not base fees. And one person questioned whether Idaho Power's funding for its share of the Northwest Energy Efficiency Alliance (NEEA) was cost-effective, whether the fuds sent to NEEA might be more cost-effectively spent within Idaho Power's service area, and whether Idaho Power has incorporated energy efficiency within its own buildings and operations. Staff appreciates these comments and acknowledges that even small additional rate increases create hardships for some customers. Nevertheless, Staff believes expansion of cost-effective DSM programs wil ultimately reduce all customers' bils below what they would otherwise be absent such programs. While it is true that customers who are able and willng to paricipate in the programs wil benefit more than those who don't paricipate, the latter group, even those who are already conserving, will also benefit indirectly from the Company's power supply costs being lower than they otherwse would be. The Staff philosophically agrees that the DSM Rider should apply only to energy and demand charges and not to monthly customer charges. However, in recognition that if the Rider did not apply to the monthly fixed charge it would have to be set at a slightly higher rate, and because even at 2.5% the customer charge par of the Rider equates to only 1 O~ for residential customers, and because there may be a biling cost issue, the Staff does not oppose the Rider's application to total base revenues. Staff believes the customer who commented on this issue may have been misled by the Company's use of the term "base revenues," which is only meant to exclude such items as the power cost adjustment charge and does not mean that the Rider applies only to monthly fixed charges. Staff agrees that it is legitimate to question whether Idaho Power's involvement with NEEA continues to be the best use of its DSM fuds and whether the energy savings allocated by NEEA to STAFF COMMENTS 8 MAY 15,2008 Idaho Power's service area can be substantiated. These types of questions apply to all DSM measures and programs, not just to NEEA. But given the regional market transformation natue of NEE A and the integration of its programs with Idaho Power's own programs, answering these questions is more diffcult. Over the past decade, Staff believes Idaho Power's customers have realized a net benefit from the Company's involvement with NEEA. Staff is also aware that NEEA has recently changed its governance, that Idaho Power's own DSM program funding needs have greatly expanded, and that the 2007 Idaho Energy Plan adopted by the Idaho Legislatue recommends that Idaho's utilities continue paricipating in regional market transformation efforts. Staff believes that it is important to continue monitoring Idaho Power's paricipation in NEEA and weighing the benefits it provides with the costs that it requires. Finally, Staff notes that Idaho Power's internal effciency efforts for its own buildings and operations are described on page 50 of its Demand Side Management 2007 Annual Report. STAFF ANALYSIS Staff supported Idaho Power's initiation of its 0.5% DSM tarff Rider and programs in 2002 (Case No. IPC-E-OI-13), the increase in the Rider to 1.5% in 2005 (Case No. IPC-E-04-29), and supports this increase in the Rider to 2.5% of base revenues. Staff recognizes that rate increases, even this relatively small 1.0% increase, are never popular. However, Staff is aware that even more expensive supply-side alternatives can and will be avoided to the extent that more customers use electricity more efficiently. Idaho Power will need additional resources to meet its future load. Cost-effective demand-side management (DSM), including energy efficiency programs and load management programs, is a significant, albeit insufficient, resource available to help ensure reasonable system reliabilty. The least costly electricity resource alternative is customers increasing the efficiencies of, and efficient use of, their buildings, appliances, lights, irrigation systems, and industrial processes without utilty intervention and administration. Staff believes the second least costly electricity resource is available when utilties or other entities prudently administer cost-effective programs that provide monetar incentives and educational opportities for customers to increase their effciencies. The most expensive electricity resources are additional generation, transmission and distribution facilties, regardless of whether the generation facilties are thermal, hydro, wind, solar, or other alternatives. It is evident that most customers, left on their own, do not use electricity as efficiently as rational economic theory suggests they should, probably due to a combination of Idaho Power's STAFF COMMENTS 9 MAY 15,2008 historically low electricity rates, lack of knowledge and misconceptions about efficiency, and a perceived need for inordinately high implicit discount rates, i.e. individuals and businesses often, if not usually, require assurance that rates of retur for energy efficiency investments are much higher than for competing, alternative investments. The need for unusually high rates of retu for energy efficiency investments may be due to a skewed perception of risk, misinformation, and/or other factors. Whatever the reasons, the result is that Idaho Power's own analyses, as well as regional and national analyses, show that there remain many efficiency programs that utilties or other entities can administer cost-effectively. Even though such administration creates additional costs, the programs can be cost-effective to the extent that the cash incentives and/or educational efforts result in customers sufficiently improving their energy efficiencies beyond what they would do without such programs and in amounts sufficient to cost-effectively recoup the necessary program administration costs. If prudently managed, these programs are designed and expected to be less costly than currently available supply-side resources. As can be seen by the past DSM program detail shown in Attchment A, all major customer classes are receiving benefits of Idaho Power's DSM programs. Precise comparisons among customer classes of DSM Rider revenue collected, program dollars spent and energy savings received are complicated by low-income weatherization costs in base rates, programs that were fuded by the Bonnevile Power Administration (BPA) until early 2007, imprecise allocation of NEE A savings, and by the peak savings goals of air conditioning cycling and irrigation scheduling programs. Stil, rough comparisons do suggest that no major customer classes are being disproportionately advantaged or disadvantaged by the distribution of the programs. Staff has reviewed the Application's proposed DSM fuding level and believes it is reasonable to continue funding the Company's DSM program activity. Staff has also reviewed the Company's program cost-effectiveness screening method and believes it is reasonable. On May 13,2008, the Staff was provided actual cost-effectiveness results of Idaho Power's 2007 program activity. Staff has not been provided all data, assumptions and calculations used to arive at these results, but it is not necessar to have such information at this time. Instead, when reviews of program processes and results are required for a prudency determination of past DSM efforts during future rate cases, all necessary calculations and supporting information is expected to be made available. Staff does not believe it is appropriate for Idaho Power to begin using DSM Rider fuds to promote renewable energy projects, especially those that are not cost-effective for paricipants or from STAFF COMMENTS 10 MAY 15,2008 a total resource cost perspective, regardless of the Company's belief that it can provide sufficiently small incentives for these projects that they remain cost-effective from the utilty perspective. In addition to being generally opposed to siphoning DSM Rider funds away from DSM programs that are cost-effective for paricipants as well as for the utilty, Staff believes that use ofDSM fuds for such projects that fail all but one of the four major cost-effectiveness tests would have the potential to undermine the credibilty of all DSM programs. Staff believes it is both appropriate and productive for all DSM costs, including administrative overhead, to be recovered through the DSM tariff Rider. As such, the costs are more readily transparent and the increased Rider level is more likely to catch the attention of customers. Such increased attention creates potential DSM education and marketing opportunities. Furhermore, we believe the increased transparency of recovering DSM overhead costs from the Rider funds provides more assurance that cost-effectiveness calculations wil include these costs, whether such calculations are formally done by the Company or more casually by the public. Therefore, we suggest that Idaho Power reconsider proposing in its next rate case that DSM overhead expenses be recovered from base rates. Given the level of uncertainty of Idaho Power's projected DSM Rider revenue needs, given that the Staff does not recommend that renewable energy projects be fuded from Rider revenue, and given that the Company has not yet fied the rate case in which it said it intends to ask that DSM general administrative costs be recovered from base rates, Staff does not believe it is necessary at this time to recommend a higher DSM Rider rate than the requested 2.5% of base revenues. Instead, Staff suggests that the Company determine whether it needs a higher DSM Rider rate after the conclusion of its rate case or when it becomes evident that a higher rate is necessar for its long-term DSM program activity level, whichever occurs sooner. CUSTOMER RELATIONS COMPLIANCE Idaho Power filed an Application to revise the Energy Effciency Rider on March 14,2008. A press release concerning the Application was included with that fiing. The Customer Notice was filed with the Commission on March 26, 2008. The Notice combined information for three cases: IPC-E- 08-03 (Energy Efficiency Programs), IPC-E-08-04 (Fixed Cost Adjustment) and IPC-E-08-01 (Danskin CTI Plant). The Notice was included as a bil insert in statements mailed to customers beginning March 26, 2008, and ending April 24, 2008. In Order No. 30520, the Commission established a deadline of May 15,2008, for filing comments in this case. STAFF COMMENTS 11 MAY 15,2008 The Commission approved a 3-year pilot program for the Fixed Cost Adjustment (FCA) in Case No. IPC-E-04-15, Order No. 30267. Rather than implementing the FCA as a stand-alone charge on customers' bils, the FCA was to be included as par of the existing Conservation Program Funding Charge, which already appeared as a separate line item on bils. Idao Power is proposing to change the line item description to read "Energy Efficiency Services". Given the fact that the FCA and Conservation Program Funding Charge have been combined for puroses of bil presentment, Staff agrees that the Company's proposed description is more appropriate and supports this change. RECOMMENDATIONS Staff recommends that Idaho Power's Energy Effciency Rider (tarffSch. 91) be increased to 2.5% of base revenues and that the caps currently in effect for the residential and irrigation customer classes be removed. Staff recommends that the Commission approve the Company's suggestion to rename the biling line item that includes the FCA and Conservation Program Funding Charge to read "Energy Effciency Services". Staff recommends denial of the Schedule 91 tariff change that would allow use of Energy Effciency Rider fuds for the promotion of renewable energy projects. Finally, Staff recommends that Idaho Power be required to report actual cost-effectiveness results in its futue DSM anual reports. Respectfully submitted this \ ~ day of May 2008. ~~ Weldon B. Stutzman Deputy Attorney General Technical Staff: Lynn Anderson Nancy Hylton i:umisc/commentsipce08.3wsladenhdes STAFF COMMENTS 12 MAY 15,2008 kW h / y e a r K W Ho u s e C a l l s $ 2 5 1 , 7 4 3 5 2 3 , 8 0 9 He a t i n g / C o o l i n g $ 4 8 2 , 0 5 1 1 , 5 7 5 CF L R e s , L i g h t $ 5 1 9 , 8 1 8 6 , 7 1 8 , 5 2 1 6 6 3 En , S t a r H o m e s $ 4 5 1 , 7 7 5 5 9 8 , 7 9 3 5 7 6 Re b a t e A d v t g . $ 5 8 , 8 5 4 3 6 5 , 2 5 8 ~S _ ~ y ~ ! ~ ~ ~ t _ _ _ _ _ _ _ _ _ _ . t _ l _ , _ ~ ? _ ~ ~ ~ ? _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ; P _ , 2 ~ _ ~ Co m m , B l d g , $ 6 6 1 , 4 8 5 2 , 7 8 5 , 4 6 8 4 4 9 Ea s y U p g r a d e s $ 6 8 0 , 3 7 6 4 , 9 5 6 , 9 2 8 7 4 6 !~ _ ~ ~ _ ~ ! ~ i . : ~ L _ _ _ _ _ _ _ _ _ _ _ J . _ _ ~ _ , _ ~ ? _ ~ ~ ~ L _ _ ~ ~ ! ~ ~ ~ ! ? _ ~ ? _ _ _ _ ~ _ ' _ ~ ? _ ~ Ir r i g a t i o n E f f , $ 1 , 8 8 1 , 1 1 6 1 1 , 5 6 1 , 3 5 8 3 , 4 0 7 !r r ~ ~ : . t ~ ~ _ ~ _ ~ ! p _ _ _ _ _ _ _ J . _ _ _ 1 _ , _ ~ ? . Q ~ ~ 9 _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ ~ _ ' _ ~ ~ ~ Co m m e r c i a l E d u , $ 2 5 , 4 2 7 Di s t r b , E f t , I n i t . $ 6 , 5 1 4 Ad m i n / A n a l y s e s $ 6 4 7 , 7 8 9 '_ ~ å " , _ _ _ _ " _ _ _ _ ' kW h / y e a r KW , Re s , C o o l i n g $ 15 , 6 4 7 0 CF L R e s , L i g h t $ 11 0 , 0 3 6 2, 3 2 1 , 4 2 2 I IC F L T w i s t $ En , S t a r H o m e s $ 46 1 , 3 1 5 89 6 , 1 3 0 En . S t a r H o m e s $ kW h / y e a r K W ~5 : _ ~ Y ~ ~ ! ~ _ I i _ _ _ _ _ _ _ _ _ _ _ S _ _ _ 1 _ , ~ ? . Q ~ ~ ? _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ ~ ~ ~ ~ Co m m , B l d g , $ 3 5 6 , 2 1 8 7 0 4 , 5 4 1 Co m m . R e t r o f i t $ 3 0 , 2 3 8 0 In d u s t r i a l $ 1 , 5 7 8 , 9 7 5 1 8 , 6 6 4 , 9 9 2 ._ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Ir r i g a t i o n E f t , $ 2 , 6 9 1 , 1 9 3 1 6 , 4 4 5 , 6 3 9 .1 ! ! ! ~ ~ _ ~ ~ ~ ~ _ S ~ ! p _ _ _ _ _ _ _ L _ 1 _ ' _ ~ ? _ ~ ~ ~ ~ _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ? _ ~ ~ ~ ? _ ~ Ed u c a t i o n $ 3 , 3 0 3 Di s t r b . E f t , I n i t . $ 1 5 , 7 7 8 0 Ad m i n / A n a l y s e s $ 2 5 7 , 3 1 6 NE E A I d a h o $ 8 7 2 , 5 7 0 1 4 , 9 9 3 , 0 8 6 73 , 1 5 2 24 7 , 0 7 1 1, 3 8 6 , 3 1 7 41 1 , 7 7 8 ~S _ ~ y ~ ! ~ ~ ~ _ _ _ _ _ _ _ _ _ _ _ J _ _ _ _ _ _ _ _ ~ ~ _ ~ ~ ~ ? _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ ! ? g Co m m , B l d g , $ 1 8 6 , 2 9 0 4 7 4 , 4 3 5 Bl d g , O p , T r a i n . $ 1 , 7 5 0 4 3 4 , 1 6 7 !~ _ q ~ _ ~ ! ~ ~ ~ _ _ _ _ _ _ _ _ _ _ _ J _ _ _ _ _ _ 1 _ ' ~ ? _ ~ ~ ~ ? _ ~ _ _ _ _ ~ ; ! ~ _ ~ ~ ! ~ ~ ~ _ _ _ _ _ _ _ _ _ _ Ir r i g a t i o n E f f , $ 1 0 3 , 8 2 3 6 9 8 , 3 8 4 !r r ~ ~ : . t ~ ~ _ ~ _ ~ ! p _ _ _ _ _ _ _ _ s _ _ _ _ _ ) . _ ' ~ ? ~ ~ ~ ~ _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - ~ g ! ? _ ~ ? Ed u c a t i o n $ Di s t r b , E f f , I n i t . $ Ad m i n / A n a l y s e s $ L1 W A ( n o n Ri d e r ) $ 1, 2 9 5 , 5 8 8 3, 2 2 6 , 2 0 5 L1 W A ( n o n Rid e r ) $ 1 , 3 7 5 , 4 2 2 2, 7 9 5 , 5 2 5 L1 W A ( n o n rid e r ) $ 1, 3 7 0 , 0 9 9 3, 1 7 9 , 3 1 1 Ot h , I P C n o n Ri d e r $ 26 9 , 4 5 5 1, 4 9 2 , 5 8 2 1, 1 0 7 Ot h , I P C n o n Rid e r $ 21 1 , 4 6 0 1, 2 9 1 , 6 2 3 83 6 Ot h . I P C n o n Rid e r $ 15 3 , 0 3 7 70 6 , 3 9 4 1, 4 4 9 NE E A c a r r y o v e r $ 39 4 , 6 0 2 8, 6 8 1 , 6 7 2 NE E A c a r r y o v e r $ 36 8 . 9 3 0 6, 3 3 9 , 2 0 4 NE E A c a r r y o v e r $ 80 0 , 0 9 1 10 , 0 3 0 , 2 0 8 To t a l Id a h o D S M $ 1 5 , 4 4 7 , 1 0 5 88 , 1 1 1 , 0 6 7 5 6 , 5 3 4 To t a l Id a h o D S M $ 1 0 , 8 0 0 , 7 2 6 64 , 4 5 2 , 1 6 3 3 5 , 8 1 4 To t a l Id a h o D S M $ 6, 8 5 7 , 1 0 4 34 , 8 4 3 , 5 6 3 4 4 , 3 8 9 % c h n g . p r i o r y r . 43 % 37 % 58 % % c h n g . p r i o r y r . 58 % 85 % -1 9 % % c h n g . p r i o r y r . 13 6 % 93 % 64 0 % kW h / y e a r K W En , S t a r H o m e s $ 1 2 9 , 8 2 5 1 0 1 , 2 0 0 ~S _ ~ y ~ ! ~ ~ ~ _ _ _ _ _ _ _ _ _ _ _ J . _ _ _ _ _ ~ ? _ ~ ~ ~ ? _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ g _ ~ Co m m , B l d g , $ 2 8 , 8 2 1 Ai r C a r e P i l o t $ 7 2 !~ _ ~ ~ _ ~ ! ~ i ~ ~ _ _ _ _ _ _ _ _ _ _ _ J . _ _ _ _ _ ~ ~ _ ~ ~ ~ ? _ ~ _ _ _ _ _ ~ ! ? _ ~ ~ ! ~ _ ~ ? _ _ _ _ _ _ _ _ _ _ _ Ir r i g a t i o n E f f , $ 7 3 , 1 8 8 8 0 2 , 8 1 2 !r r ~ ~ : . t ~ ~ _ ~ _ ~ ! p _ _ _ _ _ _ _ J . _ _ _ _ _ ~ ~ 2 ~ ~ ? _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ _ , ~ ~ 2 Sc h o o l O p , T r a i n , $ 4 3 , 9 6 9 6 5 0 , 0 0 0 Ed u c a t i o n $ 2 3 , 4 4 9 kW h / y e a r K W CF L C o u p o n s $ 3 0 5 , 6 8 3 3 , 5 9 6 , 1 5 0 En . S t a r H o m e s $ 1 3 , 5 9 7 ~5 : _ ~ Y ~ ~ ! ~ _ I i _ _ _ _ _ _ _ _ _ _ _ L _ _ _ ~ ? ~ ~ ~ ? _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ; ? . ~ AC T r a d e I n $ 6 , 6 8 7 1 4 , 4 5 4 Ai r C a r e P i l o t $ 3 , 3 6 4 3 3 , 9 7 6 In d u s t r i a l $ 1 , 3 0 3 -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Ir r i g a t i o n E f f , $ 8 , 9 7 5 3 6 , 7 9 2 Pe a k S t u d y $ 3 9 , 3 2 1 Sc h o o l O p . T r a i n . $ 4 8 , 8 5 3 1 , 0 7 5 , 0 0 0 Ed u c a t i o n $ 5 , 1 0 0 L1 W A ( n o n r i d e r ) $ 49 5 , 6 6 4 1, 2 7 1 , 6 7 7 L1 W A ( n o n r i d e r ) $ 27 8 , 0 2 9 70 0 , 0 0 0 e s t . NE E A I d . R e v . S h a r . $ 1, 1 8 8 , 7 7 4 12 , 9 3 6 , 3 3 1 e s t NE E A I d . R e v . S h a r . $ 1 , 2 1 7 , 5 9 0 11 , 5 0 7 , 9 0 0 To t a l Id a h o D S M $ 2, 9 0 7 , 1 0 8 18 , 0 1 4 , 5 5 3 5, 9 9 9 To t a l Id a h o D S M $ 2 , 2 0 2 , 9 9 9 16 , 9 6 4 , 2 7 2 15 9 % c h n g . p r i o r y r . 32 % 6% 3 6 7 3 % % c h n g . p r i o r y r . 36 % kW h / y e a r KW L1 W A ( n o n ri d e r ) NE E A I d . R e v . S h a r , To t a l Id a h o D S M $ 2 3 1 , 3 5 2 $ 1 , 1 7 , 5 9 0 $ 1 , 6 1 4 , 3 0 6 o e n ( ' ; i ~S ' e i ~ v: : : ( l ~ -- ( ' Z : : 00 0 S OQ S ' ( l ~ - : : ;: " " - g n ; i ¡; t p oOQ1W Residential AC Cool Credit ENERGY STARlB Homes Heating & Cooling Effciency Residential Retrofit Lighting Appliance Effciency Energy House Calls Radiant Barrier Rebate Advantage Total Residential Expenses Commercial/Industrial Building Effciency Custom Effciency Easy Upgrades Total Commercial/Industrial Expenses Irrigation Irrigation Effciency Irrigation Peak Rewards Total Irrigation Expenses Other DSM Administration & Overheads Energy Effciency Advisory Group Local Energy Effciency Funds Northwest Energy Effciency Alliance Commercial Energy Effciency Education Residential Energy Effciency Education Total Other Expenses Totals $ 2008 Expenses $ 3,699,203 361,780 959,589 748,843 299,513 343,643 162,942 125,652 6,701,164 " 799,060 4,712,861 1,364,051' 6,875,972 1,845,421 1,519,100 3,364,520 1,195,657 2,977 14,250 873,996 135,781 128,966 2,351,627 19,293,284 Response prepared by Pete Pengily, Customer Research and Analysis Leader, Idaho Power Company, in consultation with Lisa Nordstrom, Attorney II, Idaho Power Company, Case No. IPC.E-oa-os 5/1412008 Attchment B Case No, IPC-E-08-3 Staff Comments 05/15/08 Co s t E f f e c t i v e L i m i t (C E L ) .' ~ T h e ( l e v e 1 i z e d ) l i f e c y c l e b e n e f i t o f a p r o g r a m e x p r e s s e d i n a p e r ki l o w a t t - h o u r v a l u e ( c e n t s / k W h ) En e r g y s a v i n g s a r e ' s h a p e d b y t h e h o u r l y e n d - u s e s h a p e o f th e me a s u r e ( s ) " , . . . . . . In O r e g o n t h e C E L : f o r e n e r g y e f f i c i e r i c y p . r o g r a m s i s g i v e n i 0 % ad d i t i o n a l v a l u e : , ~ I f t h e e E L i s d i v i d e d b y t h e l e v e l i z e d p r o g r a m c o s t s - e i t h e r f r o m a DC p e r s p e c t i v e o r a TR C pe r s p e c t i v e a n a n n u a l b e n e f i t c o s t r a t i o i s pr o d u c e d Re s p o n s e p r e p a r e d b y P e t e P e n g i l y , C u s t o m e r R e s e a r c h a n d A n a l y s i s L e a d e r , I d a h o P o w e r Co m p a n y , i n c o n s u l t a t i o n w i t h L i s a N o r d s t r o m , A t t o r n e y I I , I d a h o P o w e r C o m p a n y . ) (. oc : ( " ~ VI . . I I : : "" ' ' ' ' ' i ' ' ' ~ ¡ : ~ ~ ~ . _ . _ - ~ 7 . ' " ~ - ' ' ' ' , C ' " ' ' ' ' ' ' ' ' ~ ' " " " = " " , e ' , ' ë ' : - " ~ _ _ . . . . . . _ ' _ , , , " , . . . . . . . . , . , , , _ ô ( " Z e " C a s e N o . I P C . E . O a - í S 00 0 0 S S ; . g 5 / 1 4 / 2 0 0 8 S ' " . . '" ( ' ( " ( " ~: : , (' ¡ ¡ t ; .. 0 o e r .. w w .. - " . , . . ' Re s i ; d e n t i a l P r o g r a m s · e E L , Le v e l i z e d Le v e l i z e d C o s t s Be n e f i t s An n u a l Me a s u r e To t a l 20 0 7 P r o g r a m A c t i v i t y Ut i l t y C o s t Re s o u r c e C o s t En e r g y Li f e Ut i l t y Re s o u r c e CE L (d o l l a r s ) (d o l l a r s ) (k W h ) (Y e a r s ) (C e n t s / k W h ) (C e n t s / k W h ) (C e n t s / k W h ) En e r g y E f f c i e n c y Re s i d e n t i a l '. En e r g y H o u s e C a l l s $3 3 6 , 3 7 2 , $ 3 3 6 , 3 7 2 69 9 , 8 9 9 20 3. 9 4 ø 3. 9 4 ø 9, 5 4 ø EN E R G Y S T A R ( I H o m e s N o r t h w e s t $4 7 5 , 0 4 4 $5 6 6 , 2 4 7 62 9 , 6 3 4 25 5, 6 1 ø 6, 6 9 ø 10 , 5 4 ø EN E R G Y S T A R ( I L i g h t i n g $5 5 7 , 6 4 6 $6 6 8 , 7 5 6 7, 2 0 7 , 4 3 9 7 1, 2 5 ø 1, 5 0 ø 11 , 5 4 ø Or e g o n R e s i d e n t i a l W e a t h e r i z a t i o n $3 , 7 8 1 $5 , 5 8 9 9; 9 7 1 25 2. 8 2 ø 4, 1 7 ø 9, 9 4 ø .. , "' '" $8 9 , 2 6 9 55 4 , 0 1 8 i Re b a t e A d v a n t a g e $1 8 2 , 1 5 2 45 1, 0 2 ø 2, 0 9 ø 11 , 8 8 ø We a t h e r i z a t i o n A s s i s t a n c e f o r Q u a l i f i e d ", , Cu s t o m e r s $1 , 3 2 3 , 6 2 3 $1 , 7 9 8 , 8 0 4 3, 3 3 8 , 1 2 6 25 2. 9 5 ø 4. 0 1 ø 9. 9 4 ø Re s p o n s e p r e p a r e d b y P e t e P e n g i l y , C u s t o m e r R e s e a r c h a n d A n a l y s i s L e a d e r , I d a h o P o w e r Co m p a n y , i n c o n s u l t a t i o n w i t h L i s a N o r d s t r o m , A t t o m e y I T , I d a h o P o w e r C o m p a n y . o e l n ; i ~ S - l : : : ;: t : , ~ ~ -- n z ; : ~ 0 0 S S' ( 1 -: : "i S " i . . l: ( 1 n n (J : : , (1 ¡ ; t ¡ N 0 o 0 0 .. w VJ Ca s e N o . I P C . E - Q S - Q 3 5/ 1 4 1 2 0 0 8 \\ .+ . : ¡ . . . . - - . _ . . _ - . ~ co r m m e r c i a II I n d u s t r i a l & Ir r i g ! a t i o n P r o g r a m s - C E L Le v e l i z e d Le v e l i z e d C o s t s Be n e f i t s Me a s u r e To t a l 20 0 7 Pr o g r a m A c t i v i t y Ut i l t y C o s t Re s o u r c e C o s t ,A n n u a l E n e r g y Li f e Ut i l t y Re s o u r c e CE L (d o l l a r s ) (d o l l a r s ) :r k W h ) ,( Y e a r s ) (C e n t s / k W h ) (C e n t s / k W h ) (C e n t s / k W h ) , Co m m e r c i a l l l n d u s t r i a l Bu i l d i n g E f f c i e n c y $6 6 9 , 0 3 2 $8 2 9 , 6 0 0 2, 8 1 7 , 2 4 8 12 2, 6 0 ø 3, 2 2 ø , 1 1 . 7 3 ø Ea s y U p g r a d e s $7 1 1 , 4 9 4 $1 , 8 8 2 , 0 3 5 5, 1 8 3 , 6 4 0 12 1. 5 0 ø 3. 9 7 ø 8, 0 8 ø Cu s t o m E f f i c i e n c y $3 , 1 6 1 , 8 6 6 $7 , 0 1 2 , 6 8 6 , 2 9 , 7 8 9 , 3 0 4 12 1, 1 6 ø 2, 5 8 ø 8. 7 0 ø Ir r i g a t i o n , Ir r i g a t i o n E f f c i e n c y R e w a r d s $2 , 0 0 1 , 9 6 1 $8 , 6 9 4 , 7 7 2 12 , 3 0 4 , 0 7 3 - 8 2. 3 7 ø 10 , 2 9 ø " 11 , 2 3 ø "'- . "" " \ " Re s p o n s e p r e p a r e d b y P e t e P e n g i l l y , C u s t o m e r ' R e s e a r c h a n d A n a l y s i s L e a d e r , I d a h o P o w e r Co m p a n y , i n c o n s u l t a t i o n w i t h L i s a N o r d s t r o m , A t t o r n e y I I , I d a h o P o w e r C o m p a n y . ou : ( J ~ ~ S ' ~ i : v: : : r ¿ ~ ô( J Z e - 00 0 0 S ~' ( l -: : "" " " - ~ g n ( J (l i i t r v. b o 0 0 .. , v. v . Ca s e N o . I P C . E . o a - 0 3 5/ 1 4 / 2 0 0 8 i I " i \ CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF MAY 2008, SERVED THE FOREGOING COMMNTS OF TH COMMSSION STAF, IN CASE NO. IPC-E-08-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: LISA D NORDSTROM BARTON L KLINE IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: lnordstromCfidahopower.com bklineCfidahopower .com TIMOTHY E TATUM JOHNRGALE IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: ttatumCfidahopower.com rgaleCfidahopower .com 'XJ~_SECRETA CERTIFICATE OF SERVICE