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HomeMy WebLinkAbout20200313Goralski Direct.pdfRECEI\,/ED ntil HiiR 13 Pl{ 2: 07 lr,-nlJ3 FUtli-l'. i:-iTii:S CL'i,{Ml sst@r{ BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POhTER COMPANY FOR A DETERMTNATION OF 2019 DEMAND_ SIDE MANAGEMENT EXPENSES AS PRUDENTLY INCURRED. IDAHO POWER COMPANY DIRECT TESTIMONY OF PAWEL P. GORALSKI CASE NO. IPC-E-20-15 1 2 3 4 q 6 1 8 9 O. Pl_ease A. My name address is 1221, West state your name and business address. is Pawel- P. Goralski. My business Idaho Street, Boise, Idaho 83702. 10 O. By whom are you employed and in what capacity? A. I am employed by Idaho Power Company ("Idaho Power" or "Company") as a Regulatory Analyst in the Regulatory Affairs Department. O. Please describe your educational background. A. In May of 2007, T received a Bachelor of Administration degree in Finance from Boise State University in Boise, Idaho. I have also attended "The Basics: Practical Regulatory Training for the El-ectric Industryr " an el-ect.ric utility ratemaking course of fered through the New Mexico State University's Center for Public Utilities, "Electric Utility Fundamental-s and Insights, " an electric utility course offered by Western Energy Institute, and "Electric Rates Advanced Courser " an el-ectric utility ratemaking course offered through Edison Electrlc Institute. O. Please describe your work experience with Idaho Power. A. In 2071, T was hired as a Regulatory Analyst in the Company's Regulatory Affairs Department. My primary responsibillties include supporting the Company's class cost-of-service actj-vities, supporting activities 11 L2 13 L4 15 L6 l1 18 t_9 20 2! 22 23 24 GORALSKI, Df Idaho Power Company I 25 1 2 3 4 5 6 1 I 9 associated with demand-side management (*DSM"), and I have been the Company's witness supporting its annual Fixed Cost Adjustment calculation and corresponding rates. O. What is the purpose of your testimony in this case? A. The purpose of my testimony is to present the Company's request for a determination that $45r079,479 of DSM expenses incurred for the acquisition of demand-side resources in 20L9 were prudently incurred. This amount includes $38,083,244 funded Ln 20L9 by the Idaho Energy Efficiency Rider ("Rider") and $6,996,236 of demand response program incentive payments funded through base rates and tracked annualJ-y through the Power Cost Adjustment (*PCA"). Additionally, the Company j-s requesting to remove separate reporting requirements for its Fl-ex Peak Program, as the same reporting is included as part of the Company's annua1 DSM Report filing. The 2019 energy savings represent Idaho Power's all- time highest annual incremental energy savings achievement since the establishment of the Idaho Rider in 2002. The 2019 Rider-funded DSM expenses for which ldaho Power is seeking a prudence determination is an 11 percent increase from the 2018 Rider-funded DSM expenses reviewed in last year's prudence case, Case No. IPC-E-19-11. This increase in 20L9 expenses was driven by a 71 percent increase in GORALSK], DI Idaho Power Company 10 11 L2 13 74 15 76 71 18 t9 20 27 22 23 24 2 25 1 system-wide energy savings from 20!8 energy savings when 2 considering Idaho Power's energy efficiency programs alone. 3 When the Northwest Energy Efficiency Alliance ("NEEA") 4 estj-mated savj-ngs are included, the 2019 energy savings 5 experienced an increase of 10 percent from 2078 l-evels. 6 My testimony will (1) provide a review of 2079 DSM 7 program performance, (2) discuss 2019 DSM expenses and 8 adjustments, (3) provide an overview of 201"9 cost- 9 effectj-veness and future i-mplementation of the Utility Cost 10 Test (*UCT") as the primary energy efficlency cost- 11 effectiveness test, (4) review eval-uation efforts, (5) 12 describe opportunities for stakeholder input, and (6) 13 request to remove separate Flex Peak Program reportlng L4 requirements. 15 I. 2OL9 DSM PROGRJA}T PEFS'OR!{AI{CE L6 O. What is Idaho Power's focus when evaluating program performance? A. Idaho Power takes its responsibility of prudently managing customer funds serj-ously and the Company bel-ieves it is important to get the maximum value for its customers. The Company's actions in 2079, and the content of the Demand-Side Management 2019 Annual- Report (*DSM 2019 Annual Report"), Attachment 1 to the Application filed in this proceeding, provide evidence supporting the conscientious work Idaho Power employees and leaders made L1 18 79 20 22 24 GORALSK], DI Idaho Power Company 2t 23 25 3 t_ 2 3 4 5 6 1 8 9 toward using customers' funds wisely to support DSM activities. 0. Please provide an overview of Idaho Power's DSM efforts in 2079. A. In 2019, on a system-wide basis, Idaho Power offered a broad portfolio of energy efficiency programs and demand response programs availabl-e to aII customer segments, participated in market transformation efforts through NEEA, and offered several educational- and behavioral initiatives incl-uding the Residential Energy Efficiency Education Initiative, seasonal contests, the School Cohort, the Home Energy Report Pi1ot, and other activities. Idaho Power also worked with its Energy Efficiency Advisory Group ("EEAG") to identify opportunities for increased effectiveness in program deJ-ivery and marketing. A summary of Idaho Power's 2019 DSM programs j-s provided in Table 1 below. 10 11 T2 13 74 15 L6 L1 18 L9 20 27 22 23 24 GORALSKI, DI Idaho Power Company 4 25 1 2 TalrJ.e 1. 2OL9 DSM Programs by Sector, Operational Type, and Location Program by Sector OperationalType State Residential A/C Cool Credit........... Easy Savings: Low-lncome Energy Efficiency Education Educational Distributions Home Energy Report Pilot Program Energy Efflcient Lighting Energy House Calls Heating & Cooling Efficiency Program....... Home Energy Audit Program Multifamily Energy Savings Program Oregon Residential Weatherization .................. Rebate Advantage Residential New Construction Pilot Program Shade Tree Project. Simple Steps, Smart Savings" Weatherization Assistance for Qualified Customers...... Weatherization Solutions for Eligible Customers Gommercia!/l nd ustrial Commercial and lndustrial Energy Efficiency Program Custom Prqects........ Green Motors-lndustrial New Construction........... . Retrofits Commercial Energy-Saving Kit............. Flex Peak Program Oregon Commercial Audits........... lrrigation I rri gation Efficiency Rewards Green Motors-lrrigation lrrigation Peak Rewards................... All Sectors Northwest Energy Efficiency Alliance Demand Response Energy Efficiency Energy Efficiency Energy Efflciency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efiiciency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efficiency Energy Efficiency Demand Response Energy Efficiency Energy Efficiency Energy Efficiency Demand Response Market Transformation ID/OR ID ID/OR ID ID/OR ID/OR ID/OR ID ID/OR OR ID/OR ID/OR ID ID/OR ID/OR ID ID/OR ID/OR ID/OR ID/OR ID/OR ID/OR OR ID/OR ID/OR ID/OR ID/OR 3 4 5 6 1 B TabIe 1 illustrates the broad availabj-1ity of programs offered by Idaho Power to its customers in energy Power'sefficiency, demand response, energy efficiency portfolio 1n a 2.12 benefit/cost ratio and education. Idaho was cost-effective, resulting when evafuated from a UCT GORALSKI, DI Idaho Power Company 5 1 perspective, a 2.72 benefit/cost ratio when eval-uated from 2 a Tota1 Resource Cost ("TRC") test perspectj-ve, and 2.79 3 benefit/cost ratio when eval-uated from a Particj-pant Cost 4 Test ("PCT") perspective. 5 The DSM 2019 Annual- Report provides detaj-Is for each 6 program, including a description of each program, 2079 7 performance and activities, cost-effectiveness, customer 8 satisfaction, and evaluation results when applicable. In 9 addition, the DSM 2019 Annual Report provides a description 10 of Idaho Power's DSM strategies for 2020. 11 a. What level- of incremental annual energy 72 efficiency savings was achieved in 20L9? 13 A. On a system-wi-de basis, Idaho Power achieved L4 203,041 megawatt-hours ("MWh") of incremental- annual energy 15 ef f iciency savj-ngs in 201,9. This value i-ncludes !84,934 L6 MWh from Idaho Power's energy efficiency programs and an L7 estimated 18,108 MWhl of energy efficiency market 18 transformation savings through NEEA initiatives. Chart 1 19 below shows the incremental annual energy efficiency 20 savings in MWh from 2002 to the current year. Al-so shown 27 in this chart are the total energy efficiency expenses for 22 each year in millions of dollars. 1 Because Idaho Power will not receive final 2019 savings from NEEA until May 2020, the NEEA-attributable savings i-s an estimate provi-ded to Idaho Power by NEEA. GORALSKI, DI Idaho Power Company 6 1 Chart 1. Increnental Annual Energry Efficiency Savings 2 (![I{h) and Energ'y Efficiency E:qrenses ($ nilJ.ions) 2OO2-2OL9 250,000 $45 $40 r Market Transformation (NEEA) (MWh) r lclaho Pou,er Program Savings (MWh) -EE expenses (no DR) 3 2002 2003 2004 2005 20xJ6 2fi7 2008 2009 2010 2011 20122013 20'14 20'15 2016 2017 20tB 2019 4 Note: 2019 NEEA market-transformation savings are estimated. 5 Q. In 20L9, did Idaho Power meet the energy 6 efficiency targets incl-uded in its 2017 Integrated Resource 7 Pfan (*IRP") ? I A. Yes. Chart 2 below shows the annual 9 incremental energy efflciency savings, in average megawatt- 10 hours ("aMW"), compared with the IRP targets for 2002 11 through 2019. 1.2 // 13 // L4 // 1s // 1"5 // 77 // 18 // GORALSKI, DI Idaho Power Company 200,000 150,000 100,000 50,000 ==oE"c Go Io lrJ $59 3$30 =o $25 Eoo. $20 fi s1s Eo'6 E$10 fr ED$sb UJ $00 1 1 Chart 2. Annua1 Increnental Energy Efficiency Savings 2 (av[v[) with IRP Targets (20O2-2OL9I 30 -*lPC Savings -lRP Targets 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 20',t3 2014 20',t5 2016 2017 2018 2019 ^25 ==9zooog .G 15 t,E;ro ED .EEs .E Eo 3 4 5 6 1 I 9 *NEEA codes and standards savings were removed because they are not i-ncl-uded in IRP targets. Did any programs experience large increases in prior year?savings from the o 10 A. Commercial exper j-enced 20L8. The l_ncrease an savr_ngs as wel-l- as Yes. The Custom Projects option in the and Industrial Energy Efficiency Program a 50 percent increase Ln 2019 as compared to11 72 13 general than 74 o. savj-ngs? A. 2078, Did any programs was due to more projects in several large projects. experience a decl-ine in 15 t6 Yes. Irrigation Efficiency Rewards energy Ll savings decreased by 47 percent to 10,013,455 kilowatt- 18 hours. The energy savings reduction j-s due to significant L9 reduction in Regional Technical Eorum ("RTE") measure GORALSKI, DI Idaho Power Company B 1 2 3 4 5 6 7 8 9 deemed savings rel-eased in the spring of 2078. The Company is participating in an RTE irrigation workgroup that wil-l help inform irrigation measure replacement practices that drive deemed savings. Residential- Energy Efficient Lighting and Educational- Distributions also both declined, by 74 percent and 33 percent, respectively. O. Was the savings decl-ine related to lighting anticipated? A. Yes. As mentioned in prior years' annual DSM filings, residential lighting savings were anticipated to decrease tn 2079 as implementation of the 2020 Phase II code required by the Energy Independence and Security Act of 2007 ("EISA") approached. Phase II requires most bulbs be 60-70 percent more efficient than incandescent light bul-bs. While energy savings from energy efficient lighting w1l-I be realized in grid savings and customer energy usage, energy savings wil-l- no longer count in energy efficiency program savings but will be accounted for in the Company's load forecast once it is part of standards. O. Will EISA become part of lighting standards in 2020? A. That remains uncertain at this time. Final rules issued by the Department of Energy in September 20L9 seek to limit definitions of general service incandescent light bulbs that woul-d elimj-nate parts of EISA from GORALSKI, DI fdaho Power Company 10 11 L2 13 74 15 L6 77 18 79 20 2L 22 23 24 9 25 1 becoming the standard. Several states and other entities 2 have begun 1ega1 action against the Department of Energy to 3 challenge the more limited definltion in the final rules. 4 Q. How is Idaho Power evaluating lighting energy 5 savings with the uncertainty of the EISA standard? 6 A. Idaho Power, with support from EEAG, continued 7 using the "period 1/pre-EISA" savings which assume EISA is B no longer in effect for both specialty bulbs and general 9 service j-ncandescent lamps for savings cal-culations for 10 2020. The Company will also continue to monitor how 11 utilities in the region incorporate the latest RTF numbers 72 beyond 2020. 13 O. Does the Company engage in customer education 14 and outreach activities for which it cannot quantify or 15 L6 L7 1B 1,9 20 21 22 report savings? A. Yes. The Company engages in significant educational and awareness activities and marketing efforts that are likely to result in energy savings experienced by the customer but are not quantified or cl-aimed as part of Idaho Power's annual savings. These efforts are designed to reach all- customer segments and are more fully explained on pages l-2 of the DSM 2019 Annual- Report. In 201-9 this included activity such as: holdlng technical trainings with customers, participating in Irrigation expos, hosting workshops to promote the Irrigation Efficiency Rewards GORALSKT, Dr 10 Idaho Power Company 23 24 25 1 2 3 4 5 6 1 B 9 program to existing irrigation customers, publ-ishing residential energy efficiency guides, attending other outreach activities such as home shows, and financi-al1y supporting the Integrated Design Lab. O. What level of demand reduction capacity was available from Idaho Power's demand response programs in 20!9? A. The total available capacity of Idaho Power's three demand response programs was approximately 391 megawatts ("MW") . This val-ue represents the total- demand response capacity cal-culated using the total enrolled MW from participants with an expected maximum real-ization rate for those participants in all three demand response L4 programs. The provided actua1 demand reduction of 10 11 L2 13 t-5 programs the 2079333 MW during reflects the annual program season. Chart 3 below available peak demand reduction Ioad reduction in MW since 2004 and the L6 18 L7 capacity and actual 19 associated annual expenses in millions of dol-lars. 20 2t 22 23 24 GORALSKT, Dr 11 Idaho Power Company 25 1 Chart 3. Peak Denand Reduction Capacity (!fiD and Denand2 Response E:qrenses ($ niJ.lions) 2OO4-2OL9 500 4g) $25.00 -Actual load reduction -Available capacity - Demand Response Expenses $z).00 $15.00 $10.00 $5.00 0 $0.@ 2@4 200s 2@6 2007 2008 2009 2010 2011 2012 20't3 2014 201s 2016 2017 2018 2019 II. 2OL9 DSM EXPENSES E}ID ADWSTI{ENTS O. What amount of DSM expenses is the Company requesting the Idaho Public Utilities Commission ("Commission") find were prudently incurred? A. In the delivery of energy efficiency, demand response, and market transformation programs, ds well- as education and administratlve costs, Idaho Power expended $38,083,244 of Rider funds and $6,996,236 of demand response program incentives, for a total of $45r019,419 spent on demand-side resource acquisition in 2019. Idaho Power requests that the 20L9 Rider-funded DSM expenses, and the 20L9 demand response program incentives recovered through base rates and the PCA, be reviewed together for a prudence determination. With this filing, Idaho Power requests the Commission issue an order finding GORALSKT, Dr 72 Idaho Power Company oc : =o E oe.xuJ E o Botr t,C(E Eo6 9om3F 3so(,o3 3ooo t zso o€zmotE r50 agE,*ox3s0o. 3 4 5 6 7 I 9 10 11 !2 13 74 1_5 L6 l7 18 1 that these funds were prudently incurred. Exhibit No. 1 to 2 my testimony, 2019 ldaho DSM Expenses and Adjustments for 3 Prudence FiTing, shows a breakout of these expenses by 4 program, customer sector, and funding source. 5 Q. Pl-ease compare the dollar amounts in Exhibit 6 No. 1 to your testimony with Appendix 2, 2019 DSM expenses 1 by funding source (doLLars), of the DSM 2019 Annual Report. 8 A. For clarity and ease of understanding, Exhibit 9 No. 1 ties to Appendix 2, which is found on page 160 of the 10 DSM 2019 Annual Report. The first col-umn of AppendLx 2 1l- labeled "Idaho Rider" and the first column of Exhibit No. 1 72 labeled "Rider Expenses" match at the row labeled "Total 13 Expenses" in Exhibit No. 1 and "Grand Total" in Appendtx 2 14 in the amount of $38,069,980. Al-1 val-ues in Exhibit No. 1 15 represent DSM expenses for the Idaho service area only. 16 One prior year accountj-ng adjustment to this total was Ll necessary to accurately arrive at the total 2019 expenses 18 for purposes of the prudence determination. That L9 adjustment is listed on Exhibit No. 1 under the Adjustments 20 section as "Multifamily Energy Savings Program. " 27 O. Pl-ease describe the prior year-end accounting 22 adjustment included in Exhibit No. 1. 23 A. During 20L8, Oregon activity for the 24 Multifamily Energy Savings Program totaling $13,264 in 25 program expenses was charged to the Idaho Energy Efficiency GORALSKT, Dr 13 Idaho Power Company 1 2 3 4 5 6 7 I 9 Rider and shou1d have been charged to the Oregon Energy Efficiency Rider. Idaho Power made a correcting accounting entry in 20L9 to move the charges to the Oregon Energy Efficiency Rider and credit the amount to the Idaho Energy Efficiency Rider. The reversing entry is excluded from 2019 DSM expenses to accurately represent the amount incurred related to 2079 DSM efforts. O. What was the year-end 20L9 balance of the Rider? A. The Rider account balance at December 31, 20L9, had a negative, or under collected balance of $311,045. Table 2 below shows the January 20L9 beqinninq 13 bal-ance, the funding plus interest 1tems, 20L9. expenses, and the 74 ending balance as of December 31, 15 TabJ.e 2. Idaho Energy Efficiency Rider (ilan Dec 2019) 10 11 72 ldaho Energy Efficiency Rider 2019 Beginning Balance 2019 Funding plus Accrued lnterest asoI12131l19 Total 2019 Funds 2019 Expenses as of 12131119 Ending Balance as of 12131/19 $5,258,957 32,499,978 37,758,935 (38,069,980) $(311,045) III. 2OL9 COST-EE'FECTIVENESS OVERVIEW 0. What is Idaho Power's overall goal when it comes to DSM cost-effectiveness tests? A. Prlor to the actual implementation of energy efficiency or demand response programs, Idaho Power performs a preliminary cost-effectiveness analysis to GORALSKI, DI L4 Idaho Power Company 16 11 1B t9 20 2t 22 1 assess whether a potential program design or measure will- 2 be cost-effective from the perspective of Idaho Power and 3 its customers. Idaho Power relies on the resul-ts of the 4 UCT, TRC test, and PCT to measure cost-effectiveness. 5 Idaho Power reviews the cost-effectiveness results 6 for each program and measure on an annual basis to 7 determine whether the program should continue or be 8 modified in some way to ensure it remains cost-effectj-ve on 9 an ongoing basis. If a measure or program is found to not 10 be cost-effective, Idaho Power will work with EEAG to get 11 i-nput before making its determination on modifying, 12 continuing, or discontinuing an offering. 13 The cost-effecti-veness test methodologies and L4 assumptions are described in more detail in the first pages 15 of SuppJement 7: Cost-Effectiyeness ("Supplement l"), 76 included in Attachment I to the Application in this L7 proceedlng. 18 A. Transition to UCT. 19 O. Has the Commission provided direction on the 20 primary cost-effectiveness test to use in evaluation of 2L energy efficiency in the IRP going forward? 22 // 23 // 24 // 2s // GORALSKT, Dr 15 Idaho Power Company 1 2 3 4 5 6 7 8 9 A. Yes. As directed in Case No. IPC-E-19-71,2 the UCT perspectj-ve will be the primary test for evaluating energy efficiency cost-effectiveness in the IRP. O. How is the Company implementing the UCT as the primary cost-effectiveness test in Idaho? A. Changes to the cost-effectiveness test for energy efficiency will be carried out over the 2020 program year to synchronize with the Company's annual- pJ-anning cycle. The Company is in the process of implementing the UCT as the primary perspective as it moves into the 202L IRP pJ-anning cycIe. A new DSM Potential Study based on the Utility Cost perspective is currently underway and is expected to be finalized in the second quarter of 2020. This timeline provides an opportunity for the Company to engage EEAG in the review of the impacts to current and potential programs, as wel-I as incorporate EEAG's feedback in developing the underlying energy efficiency assumptions inc1uded in the Potential Study. The Company will- also evaluate immediate opportunities to add measures that are cost-effectj-ve under the UCT perspective to existing programs during 2020. z fn Final Order No. 34469 the Commission directed Idaho Power use the UCT perspective for DSM programs i-n the integrated resource planning context. Order Nos. 34469 at 9 and 34503 at 4. GORALSKT, Dr 16 Idaho Power Company 10 11 1-2 13 L4 15 L6 77 t8 t9 20 2t 22 23 1 2 3 4 5 6 1 B 9 O Did the Company make any decisions to discontinue any programs or measures from cost- effectiveness results under the UCT or TRC test in 201,9? A No. B. 2OL9 Cost-Effectiveness Results. O. What were the results of the 201,9 cost- effectiveness analyses? A. Exhibit No. 2 Lo my testimony, 2079 Cost- Effectiveness Summary by Program, Sector, and PortfoJio, shows the results of the TRC test, UCT, and PCT for every energy efficiency program, aggregated by sector and for the portfolio. As shown in Exhibit No. 2 and below in Tabl-e 3, all tests achieved benefit/cost ratlos over 1.0 by sector and portfol-io. Table 3. 2OL9 Benefit/Cost by Sector & PortfoJ-io 10 11 72 l_3 L4 15 16 On an individual program basis, these results tl reflect that, using 2019 DSM program year costs and 18 benefits, 1l of the 16 energy efficiency programs offered 19 in Idaho for which the Company calculates cost- 20 effectiveness had benefit/cost ratios greater than 1.0 for 2l both the TRC test and UCT. GORALSKT, Df 11 Idaho Power Company Sector Uti1ity Cost Test (UCT) Total Resource Cost (TRC) Test Participant Cost Test (Pcr) Residential 1.90 2 .29 7.76 Commerc ia I / I ndus t ria I 3. 55 2 .0L 2 .09 Irrigation 2.46 3. 13 3.16 Portfolio 2.72 2.12 2 .19 1 The PCT ratios cannot be calculated for those 2 programs that do not have a direct customer cost; these are 3 shown as *N/A" on Exhibit No. 2. The details of these 4 calculations are found in Supplement I of the DSM 2019 5 Annual Report. 6 Q. Did Idaho Power calculate cost-effectj-veness 7 for each measure within each energy efficiency program it I offers? 9 A. Yes. In 2019, Idaho Power evaluated the 10 benefits and costs of 285 measures from both the TRC test 11 and the UCT perspective. The resul-ts of these cal-cul-ations 72 along wlth measure assumption detail-s and source 13 documentation can be found in Supplement 1 to the DSM 2019 t4 Annual Report. 15 O. How did Idaho Power address any individual- 76 measures that are not cost-effective based on one or more 77 tests? 18 A. The cost and benefi-t values used in the t9 various analyses are based on markets, technologies, 20 economic inputs, savings estimates, and cost estimates, 2L which can change over tj-me. When a measure is determined 22 not to be cost-effective at a specific point in time, Idaho 23 Power first evaluates whether the inputs used in the 24 calculati-ons are still applicable and then determines if 25 measure parameters should be modified or whether the GORALSKT, DI 18 fdaho Power Company 1 2 3 4 5 6 7 I 9 measure should be el-iminated. For additional detail- on measure analysis, please refer to Supplement 1 to the DSM 20L9 Annual- Report. O. Does Idaho Power evaluate cost-effectiveness for its three demand response programs? A. Yes, cal-culated for the however, benefit/cost ratios are not three demand response programs. determine the cost-Instead, the effectiveness methodol-ogy used to of the demand response programs compares the 10 annual cost of operating Idaho Power's demand response 11 portfolio to the l-evelized annual cost of a 170 MW deferred L2 resource over a 20-year life.3 In 2019, the system-wide 13 cost of operating the three demand response programs was t4 approximately $8.3 million ($7.a million of incentives and 15 $0.9 million of other costs). The amounts attributabl-e to t6 $7.8 million ($7.0 mill-ion L1 other costs) . Idaho programs were dispatched total- costs would haveL9 for the full 60 hours allowed, the been approximately $11.5 million on a system-wide basis. Using the 20t1 IRP, acknowledged by the Commission in Order No. 33983, Case No. IPC-E-17-LL, the maximum annual cost of running all three demand response programs 3 Demand response valuatlon methodology was reached by settlement agreement and approved i-n Commission Order No. 32923 as part of Case No. rPC-E-13-14. GORALSKT, Dr 19 Idaho Power Company the ldaho-only jurisdiction were of incentives and $0.8 million of Power estimated that if the three1B 20 2L 22 23 1 for the maximum al-l-owable hours of 60 hours should be no 2 3 4 5 6 7 I 9 more than $l-9.8 million, leading Idaho Power to conclude that its three demand response programs were cost-effective in 2019. 1. Weatherization Assistance for Qualified Customers (*I{AQC) and Weatherization Solutions ("So1utions") Prograns. What were the cost-effectiveness results for 10 the WAQC and Sol-utions programs? 11 A. As shown in Exhibit No. 2, the WAQC and t2 Sol-utions programs, both of which are offered to limited- 13 income customers, did not achj-eve the 1.0 benefit/cost 74 ratio threshold in 2019 under the TRC test and UCT. The 15 PCT is not calculated for these programs because the t6 programs impose no direct costs on the participants. l7 a. Why does the WAQC program continue to not be 18 cost-effective and how does Idaho Power attempt to improve 19 ir? 20 A. The IilAQC program provides real and substantial 27 per-home savings, but due to the costs of comprehensive 22 whole-house weatherization, it is difficul-t for the val-ue 23 of the savings to outweigh the costs. The weatherization 24 services provided through the WAQC program are consistent 25 with the Idaho State Weatherization Assistance Program 26 ("WAP") guidelj-nes and are offered at no charge to the 27 participant. This program is designed for l-imited-income GORALSKT, Dr 20 Idaho Power Company 1 customers and Idaho Power bel-ieves there are other benefits 2 Lo this program that are difficult to quantify, such as 3 health and safety measures. In 2019, 189 homes and four 4 buildings housing nonprofi-t agencies in Idaho were 5 weatherized through the WAQC program. 6 This program is offered in coordination with the 7 state WAP under U.S. Department of Energy guidelines; 8 changes to this program must be made by the state WAP. 9 Q. Why does the Solutions program continue to not 10 be cost-effective and how does Idaho Power attempt to 11 improve it? t2 A. Simil-ar to the WAQC program, the Solutions 13 program provJ-des real and substantial per-home savings, but 74 due to the costs of comprehensive whole-house 15 weatherizatron, 1t is difficult for the value of the L6 savings to outweigh the costs. Like the WAQC program, the 71 Sol-utions program i-s offered to customers who may not have 18 the income to participate in other residential energy L9 efficiency programs. Idaho Power believes there are 20 unquantifiable non-energy benefits to program participants, 2L such as increased safety and comfort. Idaho Power 22 continues to work with its program stakeholders and vendors 23 to streamline operations and adjust offerings to make this 24 program more cost-effective. 25 GORALSKT, Dr 2L Idaho Power Company The Company has continued a participation requirement for the Sol-utions program introduced in 3 requiring 1andlords to fund at l-east 10 4 pro j ect. In 2019, the Company hel-d the percent of average cost per 1 2 5 6 1 I 9 home constant from the 2074 l-evel for contractors, which helped reduce the 20L6, the the weatherization cost of the program. whole-house philosophy average per-home cost. through the t-0 The Company contj-nues by allowing a $6,000 rn 2079, 129 homes in program. the programs are UCT, unless the to support the annual maximum Idaho were weatherized 11 0 Does Idaho Power 12 WAQC and Solutions programs in plan to continue to offer the the future? 13 A Yes. Whil-e the Company has identified that t4 not cost-effective under the TRC test or 15 Commission directs otherwj-se, Idaho Power L6 wil-l- continue its efforts to improve the cost-effectiveness of these programs whil-e at the same time offering them to the Company's limited-income customers on an ongoing basis. 2. Energ'y House Calls. L1 18 19 20 O. What were the cost-effectiveness results for 21 Energy House Cal-l-s in 2019? 22 A. Energy House Calls had a cost-effectiveness 23 rati-o of 0.96 under the UCT, and 1.30 for the TRC test. 24 The PCT is not calculated because the program does not have 25 direct participant costs. GORALSKT, Dr 22 Idaho Power Company 1 2 3 4 5 6 7 I Y O. What contributed to the UCT being l-ess than 1. 0 in 201,9? A. The cost of lmpact and process eval-uations was the main factor contributing to the unfavorable UCT results in 201,9 for Energy House Cal-l-s. Evaluations typically occur every 3-4 years, but because the expense is incurred in a single year, it can impact the program's cost- effectiveness in the year the program was evaluated. Whil-e the UCT is below 1.0 when including total evaluation costs in the 20L9 program cost-effectiveness calculation, the UCT and TRC ratlos for the program improve to 1.05 and L.42, respectively, when assuming only one-third of the evaluation cost is included, and to 1.11 and 1.49 when 10 11 t2 13 74 15 27 the evaluation costs. Does EEAG support reporting cost-effectiveness L6 with and without evaluation costs? 77 Yes. fn a 2078 EEAG meeting, EEAG expressed cost-effectiveness in this manner18support when the for evaluatj-ng 79 cost of an eval-uation on a smal-l- program may 20 excluding 0. di sproport ional Iy 3. Heating A impact the cost-effectiveness results. & Coo].inq Efficiency Program. 22 What were the cost-effectiveness resul-ts for 23 the Heating & Cooling Efficiency Program in 2079? 24 o GORALSKT, Dr 23 Idaho Power Company 25 1 2 3 4 5 6 't I 9 10 11 L2 13 t4 15 t6 t1 18 L9 20 2L 22 23 A. The Heating & Cooling Efficiency cost-effectiveness ratio of 1.56 under the UCT, the TRC test, and 1.48 for the PCT. the had Program had a 0.77 for O. Did cost-effectiveness decrease from 2018? A. Yes. The program experienced a slight decrease in cost-effectiveness under both the UCT and TRC, mainly due to application of 2011 Avoided Costs, which are slightly below the 20L5 Avoided Costs that were used in the 20!8 cost-effectiveness evaluation. O. Does the Company plan to make changes to the program in 2020? A. No. However, Idaho Power expects the RTF may update workbooks throughout this year to reflect reductions in savj-ngs for ductless heat pumps and removal- of savi-ngs for commissj-on, controls, and sizing. Idaho Power anticipates that any changes to the program offerlng as a resul-t of those RTF updates wil-1 be implemented in the 2021 program year. 4. Residential. New Construction Pi1ot Progr:rn. O. What were the cost-effectiveness resul-ts for Residential New Construction Pilot Program in 2019? A. The Residential- New Construction Pilot Program a cost-effectiveness ratio of 1.58 under the UCT, 0.83 24 for the TRC test, and 1.55 for the PCT. GORALSKT, Dr 24 Idaho Power Company 25 l_ 2 3 4 5 6 7 8 9 O. Why did the TRC test cost-effectiveness fal-l bel-ow 1. 0 in 201,9? A. The TRC test (and PCT) calcul-ation includes updated participant costs which have increased from the costs used in 2018. O. What changes has Idaho Power recently made which may improve TRC test cost-effectiveness in 2020? A. The Compdny, with feedback from EEAG, has recently updated the program to include tiered j-ncentives, allowing for savings 10 percent and 15 percent above building code to al-so receive incentives. Previously, homes needed to be 20 percent above building code to qualify for a $1,500 incentive. Now homes 10 percent above code qualify for a $1,000 incentive, 15 percent above code qualify for a $1r 500 incentive, and 20 percent or more above code qualify for a $2,000 incentive. This may drive a greater vo1ume of homes qualifying for the program with lower participant-cost measures, which would improve the TRC test and PCT cost-effectiveness. IV. E1TAIUATION ACTIVTTY OVERVIEW a What is the Company's approach to DSM program 22 eval-uation? 23 A To ensure the ongoing cost-effectiveness of 24 10 11 72 13 L4 15 16 L7 18 19 20 2t programs through val-idation reduction, and to guide the of energy savings and demand efficient management of its GORALSKT, Dr 25 Tdaho Power Company 25 1 2 3 4 5 6 1 8 9 programs, the Company rel-ies on evaluations by third-party contractors chosen through a competitive bidding process. Idaho Power uses industry-standard protocols, internal analyses, internal- and regional and national studies to inform its and external evaluation efforts. The Company has generally conducted impact evaluations and process eval-uations for relatively when a program has significant changes. Evaluations ("Supplement 2") to the DSM every three years, new programs, SuppTement 2079 Annual Report Poweradditional information regarding how Idaho its programs. How does Idaho Power utilize the evaluations above? or 2 10 provides eval-uates 0 11 L2 13 described 15 A. Idaho Power uses the results of its evaluations to inform decisions rel-ated to program improvement, to compare processes to industry best practices, and to benchmark and val-idate reported program savlngs. 0. What evaluati-on activities took place 1n 20L9? A. In addition to the annual cost-effectiveness 16 77 18 79 20 2l analyses that the !4 23 22 20L9, Idaho Power 24 assurance and risk management company, to conduct program impact and program process evaluations for the Energy House CalIs and Resj-dential New Construction program. DNV GL25 Company conducts for each contracted with DNV GL, a program, r_n globa1 quality GORALSKI, DI 26 Idaho Power Company 1 also conducted impact evaluations for the Commercial- and 2 Industrial- Energy Efflciency Program, Retrofits and New 3 Construction options. Resource Action Programs conducted a 4 program summary anal-ysis for Residential Energy-Savings 5 Kj-ts. Aclara conducted a summary analys j-s for Home Energy 6 Reports. A savings estimate analysis was conducted by DNV 1 GL for the Shade Tree Project. Fina1ly, Idaho Power 8 contracted with DNV GL to determine the 2019 demand 9 reduction from the A/C Cool- Credit. 10 Eour of the impact evaluations that were conducted 11 in 2019 analyzed reported A/C Cool savings from the 20LB program 72 year, while the Credit impact evaluation analyzed Realization rates13 savings from the 20L9 program season. 74 were as follows: 15 a Energy House Cal-l-s realization rate of 99 percent Residential New Construction Pilot Program - realization rate of 100 percent New Construction option of the Commercial and Industrlal Energy Efficiency Program - realization of 100 percent Retrofits option of the Commercial- and Industrial- Energy Efficiency Program - realization of 99.4 percent L6 77 18 79 22 GORALSKT, Dr 27 Idaho Power Company a a 20 2t 23 24 a 25 1 2 3 4 5 6 1 8 9 a A/C Cool- Credit impact with the three A/C Cool estimates associated Credi-t event maximum total peak demand savings of days, with 2L, 463 kil-owatts For the Shade Tree Project, analysis was conducted by DNV GL to further savings estimate better determine potential tree l-ife and mortality rate. Idaho Power conducted internal analyses of the load 10 reduction from the 20L9 Irri-gation Peak Rewards GL determined the load demand response events related to and the Elex Peak reduction for the programs, and DNV A/C Cool Credit11 72 13 14 15 t6 l1 18 L9 20 2L 22 23 24 surveys, NEEA are Report. o plan for program. The final-reports for these eval-uatj-ons and studies, and the market effects eval-uations conducted by 2079 Annualincluded in Supplement 2 to the DSM Does Idaho Power have a DSM program eval-uatj-on 2020-2027? A. Yes, it is included as Exhibit No. 3 to my testimony, and is al-so included in Supplement 2 Lo the DSM 2079 Annual Report. In 2020, Idaho Power's evaluation plan includes third-party combination impact and process evaluations for the Educational- Distributions and Irrigation Efflciency Rewards, impact eval-uatj-ons for Rebate Advantage, WAQC, and Solutions, process evaluatj-ons GORALSKT, Dr 28 Idaho Power Company 25 1 for Home Energy Reports and Smal} Business Direct-Insta1l, 2 and statistical verification of Home Energy Reports. 3 In 2021, Idaho Power's evaluation plan includes 4 third-party combination impact and process evaluations for 5 the Heating & Cooling Efficiency Program, Multifamily 6 Energy Savings Program, all three options under the 7 Commercial- and Industrial Energy Efficiency Program I (Custom, New Construction, Retrofit), j-mpact eval-uations 9 for all- three demand response programs (A/C Cool Credit, 10 FIex Peak Rewards, Irrigation Peak Rewards) and process 11 evaluation for Home Energy Audits, statistical verification L2 of Home Energy Reports, and a field study for the Shade 13 Tree Project. This plan is intended to be used as a guide L4 and may change based on need, tlming, or other factors. 15 V. STAKEHOIJDER INPUT 76 O. What is the EEAG? A. In 2002, Idaho Power formed the EEAG to provide input on enhancing existing DSM programs, recommending new energy efficiency measures, and implementing energy efflciency programs. Members include customer representatives from residential, irrigation, commercial, and industrial sectors, and technj-caI experts, as well as representatj-ves for limited-income individuals, environmental- organizations, state agencies, county and L1 18 l-9 20 22 23 GORALSKT, Dr 29 Idaho Power Company 2L 24 25 1 city governments, the CommJ-ssion, the Public Utility 2 Commission of Oregon, and ldaho Power. 3 Q. What is the structure of EEAG meetings? 4 A. The EEAG generally meets quarterly i-n-person 5 at Idaho Power's corporate offices and through webinars as 6 needed. The agenda during EEAG meetings is varied, but 7 typically includes: new energy efficiency program ideas and 8 new measure proposals, marketing methods, and specific 9 measure details incl-uding cost-effectiveness, the status of 10 energy efficiency expenses and the Idaho and Oregon Rider 11 funding, updates of ongoing programs and projects, and L2 general information on DSM issues and other important 13 issues occurrJ-ng in the region. When appropriate, the 14 Company invj-tes experts to speak on eval-uations, research, 15 and other topj-cs of interest to enhance EEAG's L6 understanding. L1 O. How did Idaho Power sol-icit guidance from EEAG 18 during the 2019 program year? 1,9 A. The Company held four in-person EEAG meetings 20 and one webinar. During these meetings, Idaho Power 27 discussed and requested 22 DSM j-ssues and requested reconrmendations on a broad range of feedback on new program ideas and and specific23 new measure proposals, marketing methods, 24 measure detai]s. GORALSKT, Dr 30 Idaho Power Company 25 1 2 3 4 5 6 1 I 9 As explained in greater detail Annual Report, the below list includes in the DSM 2019 some of the topics design,Idaho Power worked with EEAG on for development, promotion, or input: 1-0 o frrigatron Efficiency Rewards Proqram. Throughout 2019, Idaho Power discussed the measure savings of the Irrigation Efficiency Rewards program and suggested development of a workgroup that woul-d inform RTF irrigation measure deemed savings. The RTE formed an irrigation workgroup Ln 2079, in which Idaho Power participated, and the Company has continued to update EEAG on progress of the workgroup. o Heating & Cooling Efficiency Program - Smart Thermostats. The Company dj-scussed with EEAG the licensed contractor installation requirement of smart thermostats to qualify for the incentive. Idaho Power sought EEAG's input on changing the contractor requirement and most members of EEAG were in favor of removing the installation by contractor requirement. The Company made program changes to the Heating & Cooling Efficiency Program on January t, 2020, including removing the contractor installation requirement. GORALSKT, Dr 31 Idaho Power Company 11 L2 13 t4 15 t6 t7 18 19 20 27 22 23 24 25 I 2 3 4 q, 6 7 8 9 o Residential New Construction Pilot Program. The 10 Company explained a methodology change on how home efficiency above building code is calculated and potential negative impacts to future participation from the calculation change. The Company asked for feedback on program options and recelved EEAG support for a tiered incentive approach to mitigate potential negative i-mpacts on participation, which was instituted in the first quarter of 2020. Residential- Direct Instal-l- Programs. During an EEAG meeting, a member asked Idaho Power to research addj-tional weatherj-zation measures, specifically door sweeps, ds a 11 t2 13 L4 15 76 71 18 L9 20 2l 22 23 24 a potential After measure in its direct install programs. manual-s for savr_ngsresearching assumptions, difficult to reference the Company found savings were determine for Idaho Power's specific climate zone and appeared to be speci-fic to single-family homes. Idaho Power has requested the RTF to review this measure as a smal-l saver and j-t is part of the RTF's workplan for 2020. Dependi-ng on the results from the RTF, Idaho Power may incorporate door sweeps in its residential- dlrect install- programs. GORALSKT, Dr 32 Idaho Power Company 25 1 2 3 4 5 6 '7 8 9 o Idaho Power's DSM 2019 Annual- Report. The Company sought input from EEAG on ways to improve the report. One EEAG member suggested color coding the different sections of the report. As a resul-t, the Company col-or coded the headers, footers, major titles, and tabl-es in the 2079 Program Activities sub-sections as fol-lows: Residential Sector (orange), Commercial/Industrial Sector (green), Irri-gation Sector (bl-ue), and Other Programs and Activities section (purpl-e) . VI. ELEX PEAK PROGRA!{ REPORTING REQUIREI'IENTS v What are the current reporting requirements L4 for the Company's Flex Peak Program? 15 A As part of Case No. IPC-E-1-5-03 where the 76 Company response the El-ex to file t1 18 19 10 11 L2 13 filed to implement a Company-managed demand program for commercial- and industrial customers, the CompanyPeak Program, the Commission directed an end-of-season report each year within 80 days 20 after the Flex Peak Program season ends for that year as 2L part of the Ordera approving the program. 22 0. What information j-s requJ-red to be included 23 the Flex Peak Program reporting requirement? an GORALSKT, Dr 33 Idaho Power Company a Order NO. 33292, p. 8 1 A. The Commission ordered Idaho Power to report 2 program metrj-cs such as number of parti-cipants, MW of 3 demand response under contract, MW of demand response 4 realized and incented per dispatch, detailed program cost 5 analysis, among other metrics.s 6 Q. Does the Company report demand response 7 program performance in other reports? 8 A. Yes. Included in Supplement 2 are reports for 9 all- three of Idaho Power's demand response programs, 10 including the Flex Peak Program with all the Commission- 11 ordered metrics. L2 0. What change is the Company requesting with 13 Fl-ex Peak Program reporting? 74 15 respect to A. reporting Elex Peak The Company requests to requirements by ellminating streamline the current the L6 Program l7 after season end. reporting requirement to Idaho Power commi-ts to separate annual be filed B0 days continue to 1B L9 20 21 22 23 report on the Flex Peak Program, and its response programsr ds part of its annual centralizinq aLL demand response program single case and on a single schedule. two other demand DSM fiJ-ing, reporting in a GORALSKT, Dr 34 Idaho Power Company 24 s rd. 1 2 3 4 5 6 7 8 9 VII. CONCLUSION o.Do you believe that the information contained in this testimony and determination for 2019 attached exhibits supports a prudence expenses ? 2019 Annual Report detaj-l-s Idaho Power's DSM offerj-ngs in program specific sections. Based on the DSM 2019 Annual Report, the testimony set forth above, and the attached exhibits, Idaho Power respectfully requests the Commission determine that $45,019,419 of DSM expenses j-ncurred for the acquisj-tj-on of demand-side resources were prudently incurred. Additionally, the Company requests to streamline reporting processes by el-iminating the separate, annual Fl-ex Peak Program reporting requirement in Case No. IPC-E-15-03, as the same information is incl-uded in the Company's annual DSM filing. O. Does thj-s conclude your testimony? A. Yes, it does. GORALSKT, Dr 35 Idaho Power Company DSM A Yes. The DSM 10 11 L2 13 1,4 15 L6 L7 1B 19 20 21, 22 23 24 25 1 2 3 4 5 6 1 I 9 ATTESTATION OF TESTIMONY STATE OF IDAHO County of Ada I, Pawel- P. Goral-ski, having been duly sworn to testify truthfulJ-y, and based upon my personal knowledge, state the following: I am employed by Idaho Power Company as a Regulatory Analyst in the Regulatory Affairs Department and am competent to be a witness in this proceeding. I decl-are under penalty of perjury of the laws of the state of Idaho that the foregoing pre-fil-ed testimony and exhibits are true and correct to the best of my information and belief. DATED this 13th day of March 2020. 10 11 t2 13 t4 15 t6 71 18 19 20 2t 22 23 March 2020. 24 25 26 21 28 29 30 31 0o uJ. ? 6,xo)zt: -l<;,*",MT",*ll Pawel- P. Goralski SUBSCRIBED AND SWORN to before me this 13th day of Not/iy itiat4)toi iaar,o Residing at Boise Idaho My commission expires:L2/20 2020 GORALSKT, Dr 36 Idaho Power Company KIMBERLY K. TOWELL coMMtSSloN #16958 NOTARY PUBLIC STATE OF IDAHO BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION GASE NO. IPC-E-20-15 IDAHO POWER COMPANY GORALSKI, DI TESTIMONY EXHIBIT NO. 1 ldaho Pourer Company 2019 ldaho DSM Expenses and Adjustments for Prudence Filing Eroenses Rider Ermnses Demand Response Program lncentives Recorded in PCA Total Exoenses En e tg y Ef f i c ie n cylDe m nd R6 po n se Residentirl A/C Cool Credit Educational Distributions Energy Effi cient LightirE Energy House Calls Healing & CoolirE Efficiency Program Home Energy Ardit Muttifamily Energy Savings Program Rebate Advantage Residential Nil Construclion Shade Tree Proict Simple Steps, Smart Savings n Weatherization Solutions for Eligible Customers Commerciamndustrial Commercial Energy-savings Kits(a) Custom Poects Flex Peak Program New Construction Retrofits lrrigation lrigation Efiicierry Re\,rrards lrioation Peak ReMrds $495,703 $ 2,989,1 84 2,026,977 143,570 478,560 230,786 't't5,560 148.220 534.1 18 147.7fi 87.599 936.721 351.2m $ 29/.,9',11 846,903 2,989,184 2,026,977 143.570 478,560 230,786 1't5.560 148.220 534,1 18 147,lfi 87,599 936,721 154,632 '11,614,380 75,306 3,365,862 6,1 31,1 17 1 54,632 1 1,614,380 370.2',t7 3,365,862 6,131,1 17 2.449.427 239.523 6,350,125 2,449,427 6,589,648 Enemv Eflicienculotemnd R6mse Iolr, S 3236aegB 3 6.996.236 $39.361.2jr1 Market Tr!nsformation Northv{est Enerov Efiiciencv Alliance 2,585,017 2.58,5.O17 To,f,l rems Commercial/lndustrial Energy Efficiency Overhead Energy Efriciency Oirect Program Overhead Residental Energy Efiiciency Edu€tion lnitiatiw Residential Enerov Efricienca Overhead 463,177 251,229 152,579 1,293,650 463,'t77 251,229 152,579 1.293.650 Other Proonms end Activitis Toral ,2,160,635 S s 2.160.635 lndirect Program Expenses Energy Effciency Ac@unting & Analysis Energy Efiiciency Advisory Group S pecial A6ou nti ng En tries 927,383 20.937 927,383 20,93? Sne.-iel A..drntihd Enlries 11 1too9 tndirect Prcqram Exrnses Iota, t 950.330 r t 959.330 Total ExDonses t 38.069.980 3 6,996,236 $45,066,215 Adiustments Prior year-end accounting adjustments: Multifamily Energy Savings Program(b)'t3,264 13,264 2019 Prudence Filino Total 38,083,2.14 $$6,996.236 $45,079,479 (a) This ptogtum was clered lo as ComreGbl Ed@lion lnitiali@ in 2018. (b) ThE ex,pn@ was chaqcd to tte ldaho dder in 201 8, and should heve b@n charyed to fiE Oogon dlet. fhe @reclion was mde in 201 I Exhibt No. 1 Case No. IPC-E-20-15 P. Goralski, IPC Page 1 of 1 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION GASE NO. IPG-E-20-15 IDAHO POWER GOMPANY GORALSK!, D! TESTIMONY EXHIBIT NO.2 2019 Cost-Effectiveness Summary by Program, Sector, and Portfolio 'Evaluaton cosB included in cosl-e,recfiyeness rafros. "' Commerciaundustrial Energy Effciency Sector cost-effecfiveness rafios ,nclude savings and pafticipant costs from Green Motors Rewinds."' lnigation Energy Efficiency Sector cost-efrectiveness ratios include savings and pa,licipanf cosfs frorn Green Motors Rewinds. 2019 BenefiUCost Tests Progra[y'Sector Utilaty Cost Test (ucr) Total Resource Cost(TRc) Participant Cost (PCT) Educational Distributions 206 3.32 N/A Eneroy Efficient Liohtino 4.O4 517 11.72 Eneroy House Calls'0.96 't.30 N/A Heatino & Coolino Efficiencv Prooram 1.56 o.77 't.18 Multifamilv Enerov Savinos Prooram 1.15 2.34 N/A Rebate Advantaoe 't 82 1.'t4 2.55 Residential New Construction*'1.58 0.83 1.55 Shade Tree Proiect 't.09 1.16 N/A Simple Steps, Smart Savinss 1.40 5.56 11 10 Weatherization Assistance for Oualified Customers 0.35 0.43 N/A Weatherization Solutions for Elioible Customers 030 0.43 N/A Residential Enerqy Efficiencv Sector 1.90 2.29 7.76 Custom Proiects*362 1.92 1.73 New Construction*315 2.88 3.52 Retrofits.3.68 'l 85 2.',t2 Commercial Energy-Savinqs Kits 1.57 2.52 N/A CommerEialrlndust.ial Eneroy Efficiency Sector **3.55 2.O1 2.09 lnioation Efficiency 2.44 3.13 316 lrrigation EnerEy Efficiency Sector "*2.16 3.13 3.16 Enerqv Effi ciency Portfolio 2.72 2.12 2.79 Exhibt No. 2 Case No. IPC-E-20-15 P. 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