20140909Reply Comments.pdf

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JULIAA HILTON
Corporate Gounsel
[e-mail]
September 9,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-O4
2013 DSM Expenditures Prudency - ldaho Power Company's Reply
Comments
Dear Ms. Jewell:
Enclosed forfiling in the above matterare an originaland seven (7) copies of ldaho
Power Company's Reply Comments.
Sincerely, .y'a/
.l-t/,u,
Yulia A. Hilton
JAH:evp
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
JULIA A. HILTON (lSB No. 7740')
ldaho Power Company
1221West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attomey for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2013 DEMAND.
SIDE MANAGEMENT EXPENDITURES
AS PRUDENTLY INCURRED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. !PC-E-14-O4
IDAHO POWER COMPANY'S
REPLY COMMENTS
ldaho Power Company ("ldaho Powe/' or "Company") hereby respectfully
submits to the Idaho Public Utilities Commission ("Commission") its Reply Comments in
the above-captioned proceeding.
I. INTRODUCTION
ldaho Power filed its Application on March 14, 2014, requesting that the
Commission find that it prudently incuned $25,951,486 in Demand-Side Management
("DSM') expenses in 2013, including $21 ,748,331 in ldaho Energy Efficiency Rider
("Ride/') expenses, and $4,203,155 of Demand Response ("DR") program incentives
included in the 2014 Power Cost Adjustment ('PCA'). The Commission Staff ("Staff'),
Idaho Conservation League ("lCL"), and lndustrial Customers of ldaho Power (.lClP')
submitted comments on the Company's Application on July 29, 2014.
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
!n their comments, Staff agreed that the Commission should find that the
Company prudently incurred DSM-related expenses of $25,951,486. Staff comments at
3. However, Staffs recommendation came with strong criticism of the Company and its
DSM programs, including a recommendation that the Commission direct the Company
to provide the Energy Efficiency Advisory Group ('EEAG') with a DSM action plan
describing how the Company will increase acquisition of cost-effective energy efficiency
in the upcoming year. Staff Comments at 13.
ICL also recommended that the Commission find ldaho Powe/s 2013 DSM
expenses of $25,951,486 prudent. ICL Comments at 1. Additionally, ICL recommends
that the Commission base its determination of cost-effectiveness on the Utility Cost Test
('UCT'), deem the Company's administration of most of its DSM programs as
imprudent, and provide fonuard-looking guidance to explicitly review avoided cost
calculations and prudently administer the Company's relationship with the Northwest
Energy Efficiency Alliance ('NEEA'). ICL Comments at 18-19.
lClP stated that Idaho Poweds DSM expenditures were in accordance with
agreed upon guidelines set forth in the Memorandum of Understanding for Prudency
Determination of DSM Expenditures ("MOU'). lClP Comments at 1-2. However, lClP
recommends that the Commission require ldaho Power to take measures to reverse the
downward trend in energy efficiency achievement. lClP Comments at 7.
II. REPLY COMMENTS
None of the comments filed recommend a disallowance to the Company's
request that the Commission find its 2013 DSM-related expenditures were prudently
incurred. Nonetheless, the Company has concerns about many issues raised in
comments.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
A. ldaho Power's Actions are lntended to Maximize Enerqv Efficiencv and
Demand Response at the Lowest Cost.
1. Idaho Power is Committed to Pursuino all Cost-Effective DSM.
Staff suggests that the Company is non-compliant with the Commission's
directive to pursue all cost-effective energy efficiency. Staff Comments at 3-5. Staff
misconstrues the Company's intent and actions, particularly as related to the
Company's participation in NEEA and the Company's request to temporarily suspend
two of its demand response programs. ldaho Power worked extensively and
collaboratively with NEEA and other funders to create a new funding model that will
a!!ow ldaho Power to gain the value it can from NEEA without providing funding for
programs that do not directly benefit ldaho Powe/s customers.
Similarly, the Company's request to temporarily suspend two of its three demand
response programs was based upon a desire to get stakeholder input as soon as it
became apparent that the Company's DR programs would not meet traditiona! cost-
effectiveness tests because there were no near-term peak-hour capacity deficits
identified in the Peak Load and Resource Balance analysis prepared for the 2013
lntegrated Resource Plan ("lRP"). This request for temporary suspension was done
quickly in order to resolve the immediate problem, and ultimately, an agreement was
reached in Case No. IPC-E-13-14 that provided for a certain level of DR regardless of
need and contained program changes that reflected stakeholders' input and ultimately
resulted in lower costs for customers. ldaho Power believes that the time and effort that
went into the DR proceedings demonstrates its commitment to providing cost-effective
DSM and ensuring customer funds are prudently spent.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
Staff incorrectly alleges that the Company failed to analyze the drop in DSM
alternative costs. Staff Comments at 4. As stated on pages 14-15 of the Company's
Reply Comments in case IPC-E-13-08:
ldaho Power had addressed this issue with Commission
Staff on several occasions, including the November 2012
and May 2013 EEAG meetings. The calculation of the DSM
alternative costs using the IRP preferred portfolio is one of
the last steps in the preparation of the IRP and, as a result,
the Company did not have the 2013 DSM alternative costs
finalized until shortly before the 2013 IRP was completed
and filed in June 2013,
The Company discussed the impacts of the lower avoided costs with the EEAG at both
the September 18,2013, and November 14,2013, EEAG meetings. And in a March 17,
2014, EEAG conference call, the Company discussed potential changes and updated
savings and DSM alternative costs for its commercial energy efficiency programs.
Thus, ldaho Power analyzed the impacts of the decrease in alternative costs and
discussed its analysis with the EEAG on multiple occasions.
2. Declininq Enerqv Savinqs are not an Accurate Measure of the Companv's
Commitment to DSM.
Staff criticizes the Company for the decline in energy savings. Staff Comments
at 5. The Company takes its mandate to pursue all cost-effective energy savings
seriously and is continuously endeavoring to increase program participation and cost-
effective energy savings. ldaho Power believes that the level of participation in its
programs is an appropriate additional metric to measure program performance. ln 2013
participation increased for eight of the twelve residential energy efficiency programs
offered by ldaho Power. However, overall residential savings decreased. !n contrast
both participation and energy savings increased for the 2013 lrrigation Efficiency
Rewards program.
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
Staff claims that the Company's reasons for declining energy savings do not fully
explain the decline, citing six reasons why the Company's summary within the Demand-
Side Management 2013 Annual Report ("DSM 2013 Report") is inaccurate. Staff
Comments at 5-6. As stated in the DSM 2013 Report:
The reduction in savings in the residential sector was due, in
part, to new lower deemed-savings amounts approved by
the RTF and ldaho Power continuing to offer some programs
only to customers with electrically heated homes. Some of
the energy-savings reduction in the industrial sector is due to
the natural ebb and flow of projects. lndustrial projects can
take years to complete, and the savings are recorded in the
year a project is completed. Fewer projects were completed
for the industrial sector in 2013. The decrease in the
commercial sector was due to some of the same reasons as
the industrial sector; however, in the commercial sector,
some trade allies report that the improved economy
decreases the amount of retrofit projects they were able and
willing to pursue and complete, turning their attention insteadto new construction projects. Additionally, the overall
reduced energy savings in 2013 may be caused, in part, by
ldaho Poweds and the region's increased evaluation,
measurement, and verification (EM&V) activities.
DSM 2013 Report at 10.
ln support of the Company's reasoning, lClP recognizes that the programs have
matured over the years and that the "declining effectiveness may be unsurprising in light
of technica! improvements and market transformation." lClP Comments at 3. The six
points made by Staff on pages 5-6 of their comments are addressed each in turn below:
First, Staff states that the decrease in residentia! energy savings due to changes
in Regional Technical Forum ("RTF") savings estimates were partially offset by an
increase in the savings estimates for the irrigation sector and the Green Motors program
for industrial projects. Staff Comments at 5. There are severa! factors affecting the
reduction in energy savings, and the reduction in the RTF savings estimates was the
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
biggest contributing factor in the reduction of energy savings in the residential sector.
While the increase in RTF savings estimates in the irrigation sector offset much of the
reduction in RTF savings estimates in the residential sector, the impact on residential
savings cannot be ignored. The RTF savings estimates for measures included in ldaho
Powe/s residential programs decreased 42 percent between 2012 and 2013 while at
the same time participation in most of the residential programs increased. The
reduction in RTF savings estimates on residential program savings was partially
mitigated by an increase in participation in most ldaho Power residential programs,
resulting in a decrease in reported savings for the residential sector of 28 percent. The
information that ldaho Power provided through discovery (attached hereto as
Attachment 1-ldaho Powe/s response to Staffs Production Request No. 6) in this
case demonstrated that, if the 2012 RTF savings estimates are applied to 2013
residential program participation, total savings for the residential sector would increase
by nine percent.l Savings estimates from the RTF for the residential sector have
steadily declined since 2009. For example, compact fluorescent light bulbs (CFL)
Kilowatt-hour ("kWh") savings were estimated to be 24 kwh per year per bulb in 2009.
Now, the weighted average savings per bulb is 9 kWh per year. Refrigerator recycling
was 682 kWh per year in 2009; it is now 424 kWh per year. Ductless Heat Pumps had
a savings value of 3,500 kWh per year during the regional pilot from 2009-2012, while
the weighted average is now 2,740 kWh per year. The most recent data available from
the Northwest Power and Conservation Council ("Council") shows that regional DSM
savings decreased from 2011 to 2012 (see slides 8 and 12), and demonstrated
decreased utility energy efficiency savings and a forecast reduction in 2013-2015 (see
' The percentages above were not explicitly shown in the DR, but can be derived from the
numbers provided in the attachment to DR 6.
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
slide 14 of Progress Toward the dh Plan's Regionat Conseruation Goalg 2012
Achievements 201T2015 Projections, Northwest Power and Conversation Council
Meeting, January 15,2014. http://rtf.nwcouncil.oro/consreporU2012/ click on link titled
"presentation."
Second, Staff suggests removing the Company's "self-imposed" restriction of
offering some programs only to customers with electrically heated homes in order to
access untapped energy savings. Staff Comments at 5. While this may provide access
to more energy savings, these would not be cost-effective energy savings. As ldaho
Power has described in the last several DSM Annual reports, even the inclusion of
natural gas savings benefits do not make some programs cost-effective from the Total
Resource Cost ("TRC") benefiUcost test.2 Additionally, non-electric benefits do not
apply to the UCT, so gas benefits would not improve the cost-effectiveness of measures
or programs when Iooked at from the UCT perspective. Idaho Power does not include
measures for gas-heated homes in its programs because the measures are nof cosf-
effective even with the inclusion of gas savrngs. Idaho Power must comply with the
MOU and Commission orders or guidance on cost-effectiveness and prudent program
administration in order to offer programs and individual measures that are cost-effective
from the TRC, UCT, and Participant Cost Test (PCT) perspectives. MOU at 6 and 9.
Third, Staff criticizes the Company for citing a natural ebb and flow of industrial
projects as a factor in the decline in overall 2013 savings, asserting that if this were true
Staff would expect to see variations of this magnitude in the past. Staff Comments at 6.
And fourth, Staff disagrees that the improving economy decreases commercial savings
' Measures in the ENERGY STAR@ Homes Northwest section, are not cost-effective from the
Total Resource Cost perspective even with the inclusion of gas savings benefits. DSM 2012 Annual
Report, Supp. 1 a|28. ln the Home lmprovement program section, non-electrically heated homes are not
cost-effective from both the Utility Cost and the Total Resource Cost perspective. DSM 2012 Annual
Report, Supp. 1 at 36-39.
IDAHO POWER COMPANY'S REPLY COMMENTS - 7
as trade allies focus on new construction rather than retrofits because ldaho Power
offers a program for new construction projects - Building Efficiency - in order to capture
these savings. Staff points to the Building Efficiency program's above average savings
in 2012 and notes that 2013 appears to be more in line with the recessionary years of
2009 and 2010. ld. While the commercial-industrial sector savings as a whole has
declined over the years, the savings for each of the programs within that sector has
varied from year to year. The above average savings achieved by the Building
Efficiency program in 2012 combined with the decrease in the Custom Efficiency
program savings in 2013 makes the overall decrease in the sector for 2013 seem
dramatic at first glance, but Building Efficiency program projects commonly remain in
process for multiple years due to the long construction time-lines. The above-average
savings in the Building Efficiency program in 2012 was due to severa! long term projects
being completed in 2012. Two of the projects had been tracked in ldaho Poweds
system for 5 years - beginning in 2008 and completed in 2012. These large projects
have a significant impact on program savings. Eight percent of the projects completed
in the Building Efficiency program in 2012 accounted for 59 percent of the reported
savings for that year. Although the economy improved in 2013, ldaho Power did not
expect to see a rebound in the Building Efficiency program in the same time period due
to the long construction time-lines. The Building Efficiency program will likely
experience a lag in savings until some large projects are completed. ln 2012 and 2013
applications were received for several large projects. These projects are currently being
tracked, however the savings associated with these projects will likely not be accounted
for until 2015 or later when the projects are completed. The application process can
take several years to complete and includes the following steps; customer submits
IDAHO POWER COMPANY'S REPLY COMMENTS - 8
information about the proposed project, ldaho Power reviews information and provides
an estimate of the incentive amount based on estimated savings, customer then
evaluates options and commences construction. After the customer completes the
p@ect ldaho Power measures and verifies the savings, and an incentive is paid. Of the
59 Building Efficiency program projects completed in 2013, 12 applications were
received in 2013, 33 in 2012, eight in 201 1 , and six in 2010.
The Custom Efficiency program has a similar issue with long construction time-
lines. The DSM Annual Report only reports savings when the projects are completed
and the incentives are paid. The focus by Staff and ICL has been on the decline in
savings reported and incentives paid. Of the 73 Custom Efficiency projects completed
in 2013, 28 were initiated in 2013, 42 in 2012, and three in 20'11. The graph below
illustrates the cumulative savings based on applications that were received in a given
year. The savings based on applications received in 2013 were particularly high and
2014 is on track to have the highest savings potential enter the pipeline over the last
five years. However, the timing of these projects-when the projects will be completed,
inspected, incentives paid and the savings reported-remains uncertain and outside
ldaho Powe/s control.
IDAHO POWER COMPANY'S REPLY COMMENTS - 9
Custom Efficiency Applications (Savings)
70,000,000
60,000,000
l,!0tr
l!tA3
=Jf3Ec
50,000,000
40,000,000 +2OLO YTD Savings
-I-2011YTD Savings
+2OL2 YTD Savings
..X-2013 YTD Savings
+-2OL4 YTD Savings
30,000,000
20,000,000
10,000,000
*"$e\'o *$ .o s s|$si".t"..$"at
Fifth, Staff doubts that more stringent Evaluation, Measurement, and Verification
("EM&V") caused a decline because all but one of ldaho Powe/s program evaluations
conducted in 2013 were process evaluations. Staff Comments at 6. To clarify, both
ldaho Poweds and the regions EM&V activities impacted savings through changes in
the savings estimates from the RTF and other sources of savings information. DSM
2013 Report at 10. The evaluations that ldaho Power conducted in 2013 were process
evaluations which would not affect savings directly, and as noted previously, these
process evaluation reports were received late in 2013 and no recommended changes
could be incorporated before the year ended. lt is the six impact evaluations that were
completed at the end of 2012 and the changes in RTF savings estimates that were most
impactful on 2013 program savings. Staff repeatedly points to the steady decline in
savings from 2010 to 2013 and criticizes the Company for it. lt must be acknowledged
that the impact evaluations and the changes in RTF savings estimates have had an
impact on the reported savings over the years. To simply compare savings one year
IDAHO POWER COMPANY'S REPLY COMMENTS - 1O
over another or show a graph of annual percentage change in energy savings without
consideration of other factors such as participation levels, the timing of projects and
changes in savings estimates does not fully reflect all the factors that impact the
reported savings from year to year.
Staffs sixth and final point compares ldaho Power to other regional utilities and is
addressed in section 3 below.
3. Comoarino Savinqs Estimates Across Utilities lncorrectlv Assumes that
Underlvino Data is Similar.
Staff alleges that ldaho Power is the only utility that failed to rebound after a
decrease in energy savings in 2011. Staff Comments at 7. However, Staff fails to
acknowledge that ldaho Powe/s participation levels have increased and provides no
information that demonstrates that such a comparison is based upon accurate or similar
data. Staff acknowledges that "Rocky Mountain Power recently filed an Application
requesting a prudency determination for DSM Rider funds spent in ldaho for the years
2010-2013." Staff Comments at 6. Staff has "yet to fully investigate the information
provided" in PAC's Case No. PAC-E-14-07. ld. Avista has only recently filed for a
prudence determination on its 2013 DSM activities on August 12,2014, in case AVU-E-
14-07. The 2013 energy savings for all three utilities are sti!! under review in three open
cases. While Avista received a prudence determination on its 2010-2012 DSM
activities in April 2014, Rocky Mountain Poweds 2010-2013 and Avista's 2013 DSM
activities have not been fully vetted. lt is premature to draw conclusions for all three
utilities on activities and energy savings that have not been reviewed and approved by
the Commission. While comparing savings from different utilities is problematic, it is
also inaccurate to categorize ldaho Power as the only utility in the area with reduced
savings in recent years. For example, NV Energy has seen five years of constant
IDAHO POWER COMPANY'S REPLY COMMENTS - 11
savings reduction with the utility's customers saving 61 percent less in 2013 compared
to 2009. Karen Henry, NV Energy's Efficiency Programs Decline in 2013, (July 25,
2014), http://www.energymanagertoday.com/nv-energys-efficiency-programs-decline-
2013-01034201.
Furthermore, comparing ldaho's lnvestor Owned Utilities' ("!OUs") annual
reported energy savings can be problematic because the underlying data may be
dissimilar. Each utility has different savings estimates, participant cost information, and
DSM alternative costs that impact the savings reported and cost-effectiveness analyses.
Even for similar measures that are offered by each utility, the savings reported can vary
significantly due to each utility's differing eligibility requirements and assumptions
around efficiency specifications, baselines, realization rates, and climate zones. In
reviewing the 2009-2013 annua! reports for the three lOUs, the three utilities cite
different sources and use different per unit energy savings for similar measures in order
to calculate the reported annual energy savings. These sources can come from the
RTF, third-party evaluations and research, and internal engineering calculations.
Moreover, even when the utilities use a similar source such as the RTF on a specific
measure, each utility has different approaches of how and when to apply updated
savings assumptions. Unless each IOU has the same eligibility requirements and
utilizes the same methodology to apply the same savings for each measure, comparing
ldaho Powe/s annual reported energy savings to other utilities may lead to an
inaccurate interpretation of each utility's DSM activities.
Comparing participation could be a slightly better metric for comparisons;
however, even participation counts are reported differently by counting at the unit,
customer, or project leve!. A "unit" for a commercial Heating, Ventilation or Air-
IDAHO POWER COMPANY'S REPLY COMMENTS - 12
Conditioning ("HVAC") measure could also be defined as "per equipment" or "per ton."
Participation counts between years may also become skewed as measures are
removed due to cost-effectiveness reasons or added due to one-time initiatives.
Because each IOU is unique, a simple comparison of percent change in annual savings
is not an accurate assessment of a particular utility's supposed successes or failures.
4. ldaho Poweds Enerov Efficiencv Potential Alions with its Peer Utilities.
Staff claims that ldaho Power's achievable potential as a percentage of economic
potential as defined by the ldaho Power Energy Efficiency Potential Study performed by
EnerNOC Utility Solutions Consulting, February 15, 2013, ("EnerNOC Study") is very
low compared to other regional and national utilities and drastically deviates from the
rest of the region. Staff Comments at 11. However, a recent study by the American
Council for an Energy-Efficient Economy ('ACEEE Study") finds ldaho Poweds
performance to be solidly in the pack of utility performance measurements of other
utilities in the region. Of those regional utilities that perform 16-20 year studies, the
table below shows their cumulative percent of energy efficiency achievable potential
and the average annual percent of achievable potential as compared to the baseline.
Percent of Baseline
Cumulative Energy
Efficiency Potential
Average Annual
Energy Efficiency
Potential
Pacaflccorp (2o13
study)
12.00%0.6%
ldaho Power 12.20o/o 0.6%
Puget Sound 16.00%O.$Yo
Avista (WA & OR)17.600/o 0.9o/o
*Cracking the TEAPOT: Technical, Economic, and Achievable Energy Efficiency Potential Studies,
ACEEE, August 2014, Report U1407, page 25. http://www.aceee.org/research-reporUu14O7.
IDAHO POWER COMPANY'S REPLY COMMENTS - 13
Additionally, of the utilities whose long-term studies were analyzed and those that
showed achievable potential as a percentage of economic potential, Avista's (51.3
percent) ranked lower than ldaho Powe/s (53.5 percent). ld. at 27
Staff defines economic and achievable potential by quoting the EnerNOC Study.
Staff Comments at 11, fn 9. However, Staff utilized only a small portion of the EnerNOC
Study's definition of economic potential to imply that all economic potential is
achievable. The EnerNOC Study's entire definition of economic potential is:
Economic potential is sfi/ a hypothetical upper-boundary of
saving potential as it represents only measures that are
economic but does not yet consider customer acceptance
and other factors.
ldaho Power Energy Efficiency Potential Study, EnerNOC Utility Solutions Consulting,
February 15,2013, page 2-14 (emphasis added). lt is inappropriate to use economic
potential as a realistic goal for achievable potential.
Staff criticizes ldaho Power and EnerNOC Utility Consulting Solutions
("EnerNOC") for its lack of workpapers supporting the assessment of achievable
potential. Staff Comments at 12. Staff alleges that the Company has not provided
information about the gap between economic and achievable potential identified in the
EnerNOC Study to the EEAG. Staff Comments at 11. ldaho Power relies on the
expertise of EnerNOC, its third-party consultant, to make this determination. The
"heaviest scrutiny" is reserved for assumptions and methodologies for estimating
achievable and program potential because assumptions about market and program
barriers are hard to quantify and often left to analysts' professional judgment. ACEEE
Study at 7. EnerNOC's Study states that it used several factors to determine the ramp
rates to define achievable potential, including ldaho Powe/s past DSM achievements,
program history over the last five years, as well as the Council ramp rates. EnerNOC
IDAHO POWER COMPANY'S REPLY COMMENTS - 14
Study page 6. At ldaho Powe/s request, EnerNOC presented the potential study to the
EEAG on two different occasions: at a December 4,2012 regular EEAG meeting and at
a May 19, 2014 special half-day EEAG workshop that concentrated on the energy
efficiency potential identified in the EnerNOC Study. In both of these meetings,
representatives from EnerNOC were available to clarify information or answer
questions.
Staff calculates the opportunity cost of the Company not achieving the full
economic potential identified in the EnerNOC Study. Staff Comments at 12. Staff
inappropriately assumes that economic potential is achievable potential. Both the
EnerNOC Study and the ACEEE Study appropriately consider achievable potential as a
subset of economic potential. Reliance on Staffs incorrect assumption that all
economic potential is achievable would result in an overstatement of energy efficiency
capabilities in the longterm lRP planning process, which would undermine the accuracy
of the process and could understate the need for other resources.
B. If Warranted. Discussions About Future DSM Activities and Expenditures
Should be Addressed in a Separate Proceedins.
A number of comments were directed at issues that are arguably outside the
scope of this case. This docket is intended to assess whether the Company's 2013
DSM-related expenditures were prudently incurred. Arguments related to future DSM-
related expenditures and how cost-effectiveness is assessed in the future would more
appropriately be brought before this Commission in a separate case so that all parties
would be able to advocate for their preferred approach in addressing future DSM
issues. ldaho Power has responded to some of the parties comments about future
activities in order to more fully inform the Commission of alternate points of view on an
issue and to point out where the Company is taking action.
IDAHO POWER COMPANY'S REPLY COMMENTS - 15
1. Staffs Request to Evaluate Funds Not Spent is lnappropriate.
Staff believes that the approximately $22 million in 2013 Rider expenses were
prudently incurred; however, Staff suggests that what may not be prudent is the
Company's decision to "not spend" customer funds. Staff Comments at 4. ldaho Power
is concerned about a potential review of prudence for funds that are not spent. ln
determining what DSM expenditures to make, ldaho Power relies upon input and
feedback from the EEAG to identify new cost-effective programs and/or modifications to
existing programs. To the extent Staff wishes to make detailed specific proposals on
cost-effective energy efficiency programs, it first should do so at the EEAG. Staffs
opinions on appropriate "spending levels" may not be shared by all, or a majority of,
EEAG members.
2. Staffs Request for an Action Plan is Unnecessarv.
Staff requests that the Commission order the Company to provide the EEAG with
a DSM action plan describing how the Company will increase its acquisition of cost-
effective energy efficiency over the next year. Staff Comments at 13. The information
that Staff requests is included within the Company's DSM 2013 Report and is already
available to all EEAG members. ln addition to summarizing the Company's DSM
programs for the prior year, each program section in the DSM Annual Report contains
subsections describing the plans and strategies for that DSM program in the upcoming
year. For examples please refer to the 2014 Strategies section for the Custom
Efficiency program (page 90), the lrrigation Efficiency Rewards program (page 109),
and NC Cool Credit program (page 28) of the DSM 2013 Report.
https://www.idahopower.com/pdfs/AboutUs/RatesReoulatorv/Reports/2O13DSMAnnual
Report.pdf. The Company regularly updates the EEAG on current program activities
IDAHO POWER COMPANY'S REPLY COMMENTS - 16
and discusses future plans to drive participation as well as future program ideas.
Therefore, a separate and additiona! action plan is unnecessary.
3. The Role of EEAG.
ICL alleges that ldaho Power has not worked collaboratively with EEAG or NEEA
in addressing Idaho Powe/s concerns about NEEA's funding mode!. ICL Comments at
18. ldaho Power played an active and collaborative role in shaping NEEA's 2015-2019
business plan with a goal of establishing a new funding model that would ensure that all
of Idaho Poweds contributed funds create value for ldaho Power customers. ldaho
Power openly discussed its concerns with the EEAG beginning in late 2012 and
continually provided updates to EEAG throughout 2013 and 2014. EEAG meetings are
open to the public, however, not all discussions on the topic were appropriate for public
disclosure. At the February 6, 2014, EEAG meeting, Idaho Power provided specific
updates to the EEAG regarding developments in the NEEA activities. Additionally,
ldaho Power held a confidential EEAG webinar on April 24, 2014, where the group
discussed detailed information about NEEA's business plan and areas where the
Company felt it could provide the same services at a lower cost or more effectively.
ldaho Power continued to update the EEAG on NEEA's alternative funding model
concept.
Contrary to ICL's assertion, Idaho Power worked extensively with NEEA to
resolve its concerns about NEEA's previous funding model. ldaho Power provided
notice to NEEA in December of 2012 of its intent to withdraw from the next funding
cycle (2015-2019), identifying NEEA's current funding model design as a chief concern.
ldaho Power also notified the EEAG of its notice to NEEA in December of 2012. This
early notice provided a lengthy time period in which ldaho Power could continue to work
IDAHO POWER COMPANY'S REPLY COMMENTS . 17
with NEEA on alternative funding mode! ideas. ldaho Power has a representative on
the NEEA Board of Directors who also served on the Altemative Funding Model
Working Group Committee ("AFM Committee"). This AFM Committee provided NEEA's
executive committee with a white paper that addressed possible solutions and primary
goals in addressing funding options. Ultimately, the AFM Committee's efforts resulted
in unanimous approval by the NEEA board of a funding model that provides for NEEA's
core funding as well as optional funding activities. Idaho Power and the rest of the
NEEA funders are currently in active discussions with NEEA to finalize their 2015-2019
funding cycle agreements.
While lCL is concerned that the Company does not collaborate with the EEAG,
ldaho Power also has concerns that the EEAG is not being utilized as intended. As
stated in Order No. 28894 at 7 and in the EEAG charter, the role of the EEAG is to
advise ldaho Power on new program selection, program prioritization, existing program
enhancement and modifications, program evaluation and measurement of savings,
cost-effective methods and criteria, incentive level recommendations, and existing
program activity reporting. ldaho Power has continually attempted to utilize the skills
provided by the EEAG to add value to its programs and use the experience and
expertise within the group to provide guidance to the Company. The Company has
increased the number of meetings, offered to meet with EEAG members outside of
structured meetings, and included confidential discussions about sensitive topics when
appropriate. However, an aggressively critical subset within the EEAG membership has
overpowered discussions and made collaborative work difficult. When discussions are
repressed, Idaho Power may miss out on valuable input from EEAG members or other
meeting attendees. Regardless of differences among constituents, ldaho Power seeks
IDAHO POWER COMPANY'S REPLY COMMENTS. 18
to engage all EEAG members as allies in pursuing cost-effective energy efficiency. lt is
unfortunate that the tone of certain participant comments within the EEAG meetings can
and does make it difficult for EEAG guidance to work as intended.
4. Process Evaluation Results Obtained in 2013.
Staff criticizes the Company for failing to make immediate changes based upon
criticisms and suggestions in process evaluations received mainly in December 2013.
Staff Comments at 8. The Company conducts third-party process evaluations in order
to improve processes associated with the Company's programs, and impact evaluations
to validate energy savings. When warranted, the Company makes changes to those
processes or energy savings calculations. These evaluations and ldaho Powe/s future
plans for process improvement or changes to energy savings calculations based upon
their results (when possible and when timing permits), are included in the DSM Annual
Report. DSM 2013 Report, Supplement 2: Evaluation. Staffs criticisms are based on
process evaluations that, with one exception, were received in December of 2013:
therefore the Company was unable to respond to them during the 2013 calendar year.
It is unreasonable to think that the Company can react to evaluations received in
December with program changes prior to the publication of the DSM Annual Report in
March. Staff and lntervenors should work with the Company through the EEAG to use
process evaluations as a method to make continuous program improvements going
forward, not as a means to criticize the Company's program administration before
allowing the Company an opportunity to address or incorporate suggested program
modifications.
IDAHO POWER COMPANY'S REPLY COMMENTS - 19
5. Prooram-Specific Concerns.
Some comments included recommendations for different cost-effectiveness tests
or program-specific changes. While ldaho Power believes that these issues are better
addressed in another forum (either through the EEAG or in a forward-looking
Commission case), the Company will nonetheless reply.
ICL believes that the Commission should focus primarily on the UCT for
determining cost-effectiveness. ICL Comments at 5. Until or unless the Company is
directed by the Commission, the Company will continue to follow the MOU and
endeavor to operate programs that meet all cost-effective tests as ordered by the
Commission. ICL asserts that ldaho Power should increase the incentive for the
Ductless Heat Pump pilot to increase participation. ICL Comments at 9. While the pilot
program passes the UCT, it fails the TRC test, and the Company believes that it should
not make changes to programs that would make them less cost-effective.
ICL criticizes the Company for its processes in the Energy Efficient Lighting
program, labeling the requirement for a program specialist to perform a line item review
of invoices as "onerous and cumbersome." ICL Comments at 9. ldaho Power believes
that it is important to review invoices to ensure that customer funds are prudently spent.
Furthermore, the specific process referenced is necessary as a control to meet the
financia! reporting requirements of the Sarbanes-Oxley Act.3 While it would certainly be
easier to skip this process, Idaho Power has a fiduciary responsibility and must ensure
all of its legal and regulatory requirements are met.
Some additional ICL recommendations have already been addressed by ldaho
Power. ICL suggests that ldaho Power should expand a portion of the Energy House
3 Sarbanes-Oxley Act (SOX) is a United States Federal law, enacted in July 30, 2002. lt
describes specific mandates and requirements for financial reporting mostly for all U.S. Public Company
boards.
IDAHO POWER COMPANY'S REPLY COMMENTS - 20
Calls program to other housing stock. ICL Comments at 10. ldaho Power presented its
research on expanding duct sealing to other residential housing stock at the August 19,
2014, EEAG meeting, obtained input from the EEAG on how to move fonruard, and is in
the process of implementing this expansion. ICL also criticized the Company's Home
Products program claiming that the process for customers to claim incentives; requiring
after purchase submission of receipts, is cumbersome. ICL Comments at 14. ldaho
Power researched options to redesign the program to increase participation and
maintain cost-effectiveness. ldaho Power presented this information at the August 19,
2014, EEAG meeting and received input from EEAG members on such options.
C. Marketinq Concerns.
lCL and Staff raise several concerns regarding the Company's marketing efforts,
alleging that ineffective marketing of its DSM programs may be a cause of declining
energy savings. ldaho Power's marketing activities and efforts are supported by
national marketing practices in the utility industry and have proven to be as effective as
comparable utilities.
1. ldaho Poweds Customer Awareness of its Enerqv Efficiencv Proorams is
Comparable to Reoional Utilities.
Staff raises marketing concerns as a possible cause of the Company's declining
energy savings. Staff Comments at 7. Staff concluded that levels of awareness of
ldaho Powe/s energy efficiency programs as reported in the J.D. Power and Associates
Customer Satisfaction Studies (the "Studies") were evidence of ineffective marketing of
ldaho Power's DSM programs. ld. However, when compared to a relevant group of
other western utilities including Avista, Pacific Power, Rocky Mountain Power, Portland
General Electric, Northwestern Energy, and NV Energy, ldaho Power customers are
just as aware as the customers of the average utility in this peer set. The Studies report
IDAHO POWER COMPANY'S REPLY COMMENTS - 21
.J.D. Power & Associates
methodology chante ln 201l Awareness of Energy Efficiency Programs
ldaho Power vs. Peer Set
Residential
+Peer Set Lou,
f pggTSet Mean
*Peer Set High
*Fldaho Power
2009 2010 2011*
Source: t.D. Power ond Associotes Electric Utility Residential
Cu stom e r Satisfoction Stu di es
2012 2013
Peer set includes: Avista, Pacific Power, Rocky Mountain
Power, Portland General Electric, NV Energy,
Northwestern Ener8y
that 50 percent of Idaho Powe/s residential customers and 55 percent of its business
customers are aware of its energy efficiency programs.
For residential customers in 2013, the highest awareness score among this peer
set of utilities was 56 percent, the lowest score was 46 percent, and the average was 51
percent.
ldaho Power's 50 percent awareness for residential customers is just below the
average peer set score, which is not statistically significant.
For business customers in 2013, the highest awareness score among the group
was 66 percent, the lowest score was 47 percent, and the average was 54 percent.
IDAHO POWER COMPANY'S REPLY COMMENTS - 22
Awareness of Energy Efficiency Programs
ldaho Power vs. Peer Set
-aFlow
-r!rlvlg36
..*-Hi8h
-t-ldaho Power
2012
Source: t.D. Power ond Associates Electric Utility Business
Cu stomet Soti sfocti on Stud i es
2013
Peer set includes: Avista, Pacific Power, Rocky
Mountain Power, Portland General Electrig NV
Energy, Northwestern Energy
ldaho Powe/s 55 percent awareness for business customers is just above the
average peer set score, and the difference is not statistically significant.
ldaho Power's energy efficiency awareness scores for both residential and
business customers is comparable to the average utility in a relevant peer set.
Therefore, if energy efficiency program awareness is a measurement of marketing
effectiveness, it is safe to say ldaho Powe/s marketing efforts are no less effective than
the average peer set utility.
2. Idaho Powe/s Marketino Efforts are Effective. Widespread. and Onqoino.
Staff and ICL criticize the Company's marketing efforts, but offer no substantive
research to support their claims. Staff Comments at 7 and ICL Comments at 7-8.
IDAHO POWER COMPANY'S REPLY COMMENTS.23
There are many factors impacting a custome/s decision to implement energy
efficient measures, and marketing alone is not sufficient to increase adoption rates.
Awareness is only one of many factors in the consumer decision making process.
Consumers need to first recognize they have a need or a problem. Consumers seek
information to solve a problem, evaluate altematives, and then choose a product or
service. The utility's marketing challenge is to present customers with information or
motivation when the customer needs it. As explained by a leading expert, consumers
don't know about products and services until they have a reason to know about them.
Engel, Blacl<well and Kollaf Five Step Model of Consumer Buying Decision Process
1968. Belch, 2009, page 113, Advertising and Promotion: An lntegrated Marketing
Communications Perspective.
Customers face many barriers when choosing whether or not to engage in
energy efficiency programs that are not attributable to marketing. For instance, utility
bills may be small enough to ignore the need for energy efficiency. Customers often
don't have the time to determine what efficiency improvements are worth pursuing and
may feel the "hassle" of filling out forms and scheduling contractors is not worth the
benefits. (The Rocky Mountain lnstitute, TURBOCHARGING EFFICIENCY
PROGRAMS, Going for Broader and Deeper Savings 2011). Energy efficiency is a low
interest category for the majority of consumers. ((Gallup Poll: Most lmportant Problem,
Selected trend-January 2001-present. PollingReport.com-Problems and Priorities-
Kaiser Family Foundation.University of Texas Energy Poll-
http://www.utenergypoll.com/ut-energy-poll-shows-public-disconnect-on-energy-
issues/1050-2/ Pike Research Poll, 2011. http://ecoseed.oro/business/14138-most-
americans-u n i nterested-i n-enerov-efficiencv-home-im orovements-poll-savs)).
IDAHO POWER COMPANY'S REPLY COMMENTS -24
Americans claim to prioritize energy-efficient home improvements (26 percent)
over aesthetic ones, yet projects planned for the near future indicate a higher propensity
for remodeling kitchens and bathrooms than for energy-efficient improvements, like
adding insulation or replacing HVAC units. (Shelton Group/Energy Pulse 2013). The
National Resources Defense Council (NRDC) states that "energy efficient solutions
often are more expensive on a first-cost basis than inefficient solutions, few in the
economy are solely focused on energy efficiency and saving can be difficult to measure
(Choi Granade et a!. 2009 ix)." Natural Resources Defense Council, Precourt Energy
Efficiency Center and Lawrence Berkeley National Laboratory, When "Not Losing" is
Better Than "Winning": Using Behavioral Science to Drive Customer lnvestment ln
Energy Efficiency.
Staff refers to the non-participant survey performed by HANSA that cites
unfamiliarity as the top barrier to participation across audiences. Staff Comments at 8.
Based on a process evaluation recommendation in 2011 (Global Energy
PartnerVCadmus), ldaho Power conducted this HANSA Study to gain an understanding
of why customers do not participate in programs. ldaho Power surveyed only
customers who have not participated in energy efficiency programs. Of these non-
participants that responded to the survey "interest in participating in an energy efficiency
program in the future is in the mid{o-low range." HANSA Residential Study Page 11.
ln response to the HANSA Study, 2014 marketing plans include integrated
campaigns in February and September using a variety of marketing channels (print,
digital, television, and public relations) designed to raise awareness of all programs.
Staff cites the HANSA Study to assert that the vast majority of customers
surveyed from all sectors believe energy efficiency programs are highly important. Staff
IDAHO POWER COMPANY'S REPLY COMMENTS - 25
Comments at 8 (citing HANSA Study at 9). lt is common for people to respond to
surveys in a way that is altruistic and tends to put them in a positive light so the HANSA
Study finding is not surprising. This difference between a survey respondent's
intentions and actual actions is referred to as a "social desirability bias." For example,
in another study, 52-95 percent of customerc across multiple utility studies said they
were willing to pay more for green power. Farhar 1999, Willinoness to Pav for
Electricitv from Renewable Resources: A Review of Utilitv Market Research. However,
actua! participation rates in green power programs are much lower than those stated
intentions-1.5 percent was the median national participation rate across US green
power programs in 2012. Status and Trends in the U.S. Voluntarv Green Power Market
(2012 Data). NREL. lt's an over simplification to believe that the vast majority of
customers would sign up for programs if they were aware the programs existed.
3. Hiqh-Viewership Methods of Marketino are Costlv and Not Effective.
ldaho Power strives to fund effective marketing techniques to drive demand for
energy efficiency programs. Staff criticizes ldaho Power for failing to advertise through
high-viewership methods such as billboards, TV, and radio. Staff Comments at 8.
Billboards are effective for image campaigns, political campaigns, and immediate
product purchase (i.e., hotel accommodations next exit). Billboards offer very little time
to convey complex messages such as energy efficiency. Energy efficiency programs
need more customer attention to effectively communicate its message. ln 2014, the
Company began testing the use of television marketing to promote energy efficiency
programs. However, in the past, ldaho Power customers have expressed concern over
the perceived cost of broadcast television. According to 35 utility marketers across the
US, radio spots have a higher cost and low effectiveness when it comes to promoting
IDAHO POWER COMPANY'S REPLY COMMENTS - 26
energy efficiency. E-Source Utility Marketing Survey 2013, ldentifying What Works,
http://www.esource.com/system/files/files/2013-12/ESource-RES-WC-2013-12-
UMSurveyResults.pdf.
As a result, the majority of these national respondents avoid using radio. This is
not to say that ldaho Power would never use billboards or radio spots to market its
programs, however, it would likely limit its use of billboards or radio to instances where it
has a relatively simple message to convey. ldaho Power customers have consistently
indicated their preference for learning about energy efficiency through bill inserts and
direct mail. HANSA Study at 11. ldaho Power continues to use bil! inserts and direct
mail because year-after-year studies show they are effective.a
To further expand its energy efficiency offerings and participation ldaho Power is
implementing new programs and expanding its outreach to educate customers on
energy efficiency options. ln the residential sector, the Residential Shade Tree project
launched in 2013. ln 2014 the Home Energy Audit program launched and Light-
Emitting Diodes (LED) lamps were added to the Efficient Lighting program.
ln the commercial sector, early in 2013, the Company introduced two new
program offerings in Custom Efficiency-Refrigeration Operators Coaching for Energy
Efficiency (ROCEE) and Streamlined Custom Efficiency (SCE). In early 2014, Custom
Efficiency launched a third new initiative called the Wastewater Energy Efficiency
Cohort (WWEEC). All of these actions to drive savings have been shared with the
EEAG.
o When respondents were asked to identify the source of communication they recall receiving
from their utility, bill inserts had the highest recall at 44.3 percent with direct mail coming in second at
24.5 percent. J.D. Power 2014 Electric Utility Residential Customer Satisfaction Study. And in 2013,48
percent of See Ya Later, Refrigerator participants heard about the program through a bill insert.
IDAHO POWER COMPANY'S REPLY COMMENTS -27
ldaho Power successfully conducted a Small Business Relationship Campaign
from May 2013 through July 2013 to build relationships with business customers and to
educate them about ldaho Power's DSM programs and how to use electricity wisely.
ldaho Power customer representatives contacted customers and produced and
distributed customer newsletters. Idaho Power developed a small business strategy to
bring a greater focus on its "main street" business customers with the primary goa! of
strengthening the Company's relationships. The Company's three-pronged strategy
was to: (1) send targeted letters to small business customers, (2) conduct face-to-face
visits with small business customers, and (3) continue to produce and distribute
customer publications such as the Easy Upgrades bill insert (August 2013') and the
Energy @ Work newsletter (spring & fall). Customer representatives conducted 4,049
visits with small businesses, which was 161 percent of goal. Letters were mailed to
1O,3OO small business customers. All of these activities help to increase program
participation in 2013 and 2014.
ln late 2013, the Company formed an internal New ldeas Team to investigate
new energy savings opportunities and to examine those measures identified as having
significant potential in the EnerNOC Study. Four new program/measure ideas were
presented by ldaho Power and discussed at the August 19,2014, EEAG meeting.
III. CONCLUSION
A decline in energy efficiency savings does not indicate the Company's
commitment to DSM is waning. The Company takes its mandate to pursue all cost-
effective energy savings seriously and is continually endeavoring to increase program
participation and savings regardless of the challenges it is facing in today's
environment. These challenges include a negative dynamic in the EEAG, lower
IDAHO POWER COMPANY'S REPLY COMMENTS - 28
avoided costs, and the impact of the transforming market through lower deemed
savings estimates because the baseline from which savings are measured is becoming
more efficient. Despite these challenges, Idaho Power continues to work with its
stakeholders through the EEAG to optimize its current programs and to explore and
implement new programs and initiatives.
ldaho Power has conformed to the guidelines of the MOU signed by Staff and
ldaho's investor-owned utilities and has provided evidence that the Company's 2013
DSM expenses were prudently incurred. For the reasons set forth above, Idaho Power
requests that the Commission find that the Company prudently incurred $25,951,486 in
DSM-related expenditures, which amount includes $21,748,331 in Rider funds, and
$4,203,155 of demand response incentives included in the 2014 PCA. The Company
requests that the Commission limit its order in this case to a determination of whether its
2013 DSM expenditures were prudently incurred.
Respectfully submitted this gth day of September 2014.
for ldaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 29
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 9th day of September 20141 served a true and
correct copy of IDAHO POWER COMPANY'S REPLY COMMENTS upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
D. Neil Price
Deputy Attomey General
!daho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Customerc of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
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IDAHO POWER COMPANY'S REPLY COMMENTS - 30
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. IPC-E-14-04
IDAHO POWER GOMPANY
ATTACHMENT 1
REQUEST NO. 6: The Company has indicated that the decrease in acquired
energy savings can be attributed, in part, to reduced deemed savings estimates
approved by the Regional Technical Forum. Please provide a list of all measures
offered by the Company that were affected by changes in RTF estimates. Please also
include the energy savings for those measures using both the previous RTF deemed
savings amount and the new RTF deemed savings amount.
RESPONSE TO REQUEST NO. 6: ln recent years, the Regional Technical
Forum ("RTF') has implemented savings guidelines and protocols, increased
responsiveness to regional program evaluations, and frequently responded to measure
baseline changes whether due to codes and standards or sales based data. ln order to
evaluate the savings impacts due strictly to RTF deemed savings value updates, ldaho
Power analyzed the impact to 2013 program performance with the changes that
occuned between the 2A12-2013 program years to the deemed values. These changes
affected six programs: Ductless Heat Pump Pilot; Energy Efficient Lighting; Home
Products; See ya later, refrigeratoP; lrrigation Efficiency Rewards; and Green Motors
Rewinds (agricultural and industrial).
Please see the Excel file provided on the non-confidential CD. The attachment
has eight worksheets, including a summary worksheet, and seven program measure
specific worksheets indicating the impact to savings due to RTF deemed savings
updates. Please see the table below for definitions of the columns used in the Excel
file.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. T
COLUMN TITLE DESCRIPTION AND NOTES
Program lmpacted ldaho Power proqram
Measure Description Affected measure within Drooram
2013 Participation The number of units associated with the measure
description that received incentives durino 2013
2013 Average per Unit Deemed
Savings (kWh)
Represents the 2013 weighted average unit deemed
value on the summary tab, represents the actual
deemed value on the program tabs, and will match
values in the 2013 Supplement 1
2013 Savings Using 2013 Unit
Deemed Savinos (kwh)
Savings calculated using 2013 deemed values and
unit counts
2012 Average per Unit Deemed
Savings (kwh)
Represents the 2012 weighted average unit deemed
value on the summary tab, represents the actual
deemed value on the program tabs, and will match
values in the 2012 Supplement 1
2013 Savings Using 2012 Unit
Deemed Savinos (kwh)
Savings calculated using 2012 deemed values and
unit counts
Difference (kwh)Net difference in savings calculation methods 12013 -
201211
Percentage Change Percentage change in savings between 2013 and
2012 usino the different deemed values
Additional Notes Additional information
The summary analysis shows that the savings both increased and decreased for
specific measures and programs. The residential sector had the largest decrease in
savings and laryest number of programs affected. Using 2013 participation numbers
and 2012 deemed values, the residential sector would have reported 25,702,238
kilowatt-hours ("kWh") of savings compared with the reported savings for 2013 of
17,005,274 kWh of savings ln the 2013 DSM Annual Report. Both lrrigation Efficiency
Rewards and the Green Motors programs showed increases due to RTF updates. The
lnigation sector increased by 5,431,367 kwh when comparing savings using 2012 and
2013 deemed values.
The Green Motors program for industrial projects showed a small increase of
18,841 kWh due to changes in savings between the two comparison years. With the
exception of the Green Motors Rewinds measures for industrial projects, the RTF
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMTSSION STAFF TO IDAHO POWER COMPANY - 8
changes had little impact in the commercial/industria! sector. The Easy Upgrades
program sources a few measures from the RTF; however, those savings assumptions
did not change between 2012 and 2013.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9