HomeMy WebLinkAbout20210315Goralski Direct and Exhibits.pdf BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
OF IDAHO POWER COMPANY FOR A DETERMINATION OF 2020 DEMAND- SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
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CASE NO. IPC-E-21-04
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
PAWEL P. GORALSKI
GORALSKI, DI 1
Idaho Power Company
Q. Please state your name and business address. 1
A. My name is Pawel P. Goralski. My business 2
address is 1221 West Idaho Street, Boise, Idaho 83702. 3
Q. By whom are you employed and in what capacity? 4
A. I am employed by Idaho Power Company (“Idaho 5
Power” or “Company”) as a Regulatory Consultant in the 6
Regulatory Affairs Department. 7
Q. Please describe your educational background. 8
A. In May of 2007, I received a Bachelor of 9
Business Administration degree in Finance from Boise State 10
University in Boise, Idaho. I have also attended “The 11
Basics: Practical Regulatory Training for the Electric 12
Industry,” an electric utility ratemaking course offered 13
through the New Mexico State University’s Center for Public 14
Utilities, “Electric Utility Fundamentals and Insights,” an 15
electric utility course offered by Western Energy 16
Institute, and “Electric Rates Advanced Course,” an 17
electric utility ratemaking course offered through Edison 18
Electric Institute. 19
Q. Please describe your work experience with 20
Idaho Power. 21
A. In 2017, I was hired as a Regulatory Analyst 22
in the Company’s Regulatory Affairs Department, and in 2020 23
I was promoted to my current position of Regulatory 24
Consultant. My primary responsibilities include supporting 25
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Idaho Power Company
the Company’s class cost-of-service activities, supporting 1
activities associated with demand-side management (“DSM”), 2
and I have been the Company’s witness supporting its annual 3
Fixed Cost Adjustment calculation and corresponding rates. 4
Q. What is the purpose of your testimony in this 5
case? 6
A. The purpose of my testimony is to present the 7
Company’s request for a determination that $47,010,777 of 8
DSM expenses incurred for the acquisition of demand-side 9
resources in 2020 was prudently incurred. This amount 10
includes $40,477,043 funded in 2020 by the Idaho Energy 11
Efficiency Rider (“Rider”) and $6,533,734 of demand 12
response program incentive payments funded through base 13
rates and tracked annually through the Power Cost 14
Adjustment (“PCA”). 15
My testimony will (1) provide a review of 2020 DSM 16
program performance, including impacts from the COVID-19 17
pandemic, (2) discuss 2020 DSM expenses and adjustments, 18
(3) provide an overview of the economic test results for 19
2020 as the Company has transitioned to the Utility Cost 20
Test (“UCT”) as the primary energy efficiency cost-21
effectiveness test, (4) review evaluation efforts, and (5) 22
describe the input stakeholders provided during the year. 23
GORALSKI, DI 3
Idaho Power Company
I. 2020 DSM PROGRAM PERFORMANCE 1
Q. What is Idaho Power’s focus when evaluating 2
program performance? 3
A. Idaho Power takes its responsibility of 4
prudently managing customer funds seriously, and the 5
Company believes it is important to get the maximum value 6
for its customers. The Company’s actions in 2020, and the 7
content of the Demand-Side Management 2020 Annual Report 8
(“DSM 2020 Annual Report”), Attachment 1 to the Application 9
filed in this proceeding, provide evidence supporting the 10
conscientious work Idaho Power employees and leaders made 11
toward using customers’ funds wisely to support DSM 12
activities. 13
Q. Please provide an overview of Idaho Power’s 14
DSM efforts in 2020. 15
A. The 2020 energy savings achievement remained 16
strong and represents Idaho Power’s second highest annual 17
incremental energy savings achievement since the 18
establishment of the Rider in 2002. This was a slight 3 19
percent decrease from the all-time highest annual 20
incremental energy savings achieved in 2019. 21
On a system-wide basis, Idaho Power offered a broad 22
portfolio of energy efficiency programs and demand response 23
programs available to all customer segments and also 24
participated in market transformation efforts through the 25
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Idaho Power Company
Northwest Energy Efficiency Alliance (“NEEA”). In 1
addition, the Company offered several educational and 2
behavioral initiatives including the Residential Energy 3
Efficiency Education Initiative, seasonal contests, the 4
School Cohort, the Home Energy Report Program, and Water 5
and Wastewater Cohort continuation. 6
As described further in my testimony, in response to 7
the COVID-19 pandemic, the Company modified DSM activity to 8
prioritize the safety of customers, contractors, and Idaho 9
Power staff, while balancing opportunities to maintain 10
program performance. Idaho Power also solicited input from 11
its Energy Efficiency Advisory Group (“EEAG”) on ways to 12
adjust programs impacted by COVID-19 and identify 13
opportunities to increase program effectiveness, delivery, 14
and marketing. A summary of Idaho Power’s 2020 DSM 15
programs is provided in Table 1 below. 16
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Idaho Power Company
Table 1. 2020 DSM Programs by Sector, Operational Type, 1 and Location 2
Program by Sector Operational Type State
A/C Cool Credit ............................................................. Demand Response ID/OR
Easy Savings: Low-Income Energy Efficiency Education Energy Efficiency ID
Educational Distributions ............................................... Energy Efficiency ID/OR
Home Energy Report Program ............................... Energy Efficiency ID
Energy Efficient Lighting ............................................... Energy Efficiency ID/OR
Energy House Calls ...................................................... Energy Efficiency ID/OR
Heating & Cooling Efficiency Program .......................... Energy Efficiency ID/OR
Home Energy Audit Program ........................................ Energy Efficiency ID
Multifamily Energy Savings Program ............................ Energy Efficiency ID/OR
Oregon Residential Weatherization............................... Energy Efficiency OR
Rebate Advantage ........................................................ Energy Efficiency ID/OR
Residential New Construction Pilot Program ................ Energy Efficiency ID/OR
Shade Tree Project ....................................................... Energy Efficiency ID
Simple Steps, Smart Savings™ ..................................... Energy Efficiency ID/OR
Weatherization Assistance for Qualified Customers ..... Energy Efficiency ID/OR
Weatherization Solutions for Eligible Customers........... Energy Efficiency ID
Commercial/Industrial
Commercial and Industrial Efficiency Program
Green Motors—Industrial Energy Efficiency ID/OR
New Construction ..................................................... Energy Efficiency ID/OR
Retrofits .................................................................... Energy Efficiency ID/OR
Commercial Energy-Saving Kit ..................................... Energy Efficiency ID/OR
Flex Peak Program ....................................................... Demand Response ID/OR
Oregon Commercial Audits ........................................... Energy Efficiency OR
Small Business Direct Install.......................................... Energy Efficiency ID/OR
Irrigation
Irrigation Efficiency Rewards ......................................... Energy Efficiency ID/OR
Green Motors—Irrigation .......................................... Energy Efficiency ID/OR
Irrigation Peak Rewards ................................................ Demand Response ID/OR
All Sectors
Northwest Energy Efficiency Alliance ............................ Market Transformation ID/OR
3 Table 1 illustrates the broad availability of 4
programs offered by Idaho Power to its customers in energy 5
efficiency, demand response, and education. Idaho Power’s 6
energy efficiency portfolio was cost-effective, resulting 7
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Idaho Power Company
in a 2.71 benefit/cost ratio when evaluated from a UCT 1
perspective, a 2.08 benefit/cost ratio when evaluated from 2
a Total Resource Cost (“TRC”) test perspective, and a 2.45 3
benefit/cost ratio when evaluated from a Participant Cost 4
Test (“PCT”) perspective. 5
The DSM 2020 Annual Report provides details for each 6
program, which include: a program description, 2020 7
performance results, program activities, cost-effectiveness 8
ratios, customer satisfaction, and evaluation results when 9
applicable. In addition, the DSM 2020 Annual Report 10
provides a description of Idaho Power’s DSM strategies for 11
2021. 12
Energy Efficiency 13
Q. What level of incremental annual energy 14
efficiency savings was achieved in 2020? 15
A. On a system-wide basis, Idaho Power achieved 16
196,809 megawatt-hours (“MWh”) of incremental annual energy 17
efficiency savings in 2020. This value includes 180,818 18
MWh from Idaho Power’s energy efficiency programs and an 19
estimated 15,991 MWh1 of energy efficiency market 20
transformation savings through NEEA initiatives. Chart 1 21
below shows the incremental annual energy efficiency 22
1 Because Idaho Power will not receive final 2020 savings from NEEA
until the second quarter 2021, the NEEA-attributable savings is an estimate provided to Idaho Power by NEEA.
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Idaho Power Company
savings in MWh from 2002 to the current year. Also shown 1
in this chart are the total energy efficiency expenses for 2
each year in millions of dollars. 3
Chart 1. Incremental Annual Energy Efficiency Savings 4 (MWh)and Energy Efficiency Expenses ($ millions) 2002-2020 5
6
Note: 2020 NEEA market-transformation savings are estimated. 7
Q. In 2020, did Idaho Power meet the energy 8
efficiency targets included in its 2017 Integrated Resource 9
Plan (“IRP”)? 10
A. Yes. In 2020, Idaho Power achieved 22 average 11
megawatt-hours (“aMW”) of incremental energy efficiency 12
savings, including NEEA estimated energy savings, which 13
exceeded the economic technical achievable potential 14
included in the 2017 IRP of 15 aMW. The energy efficiency 15
potential identified by the potential study for program 16
year 2020 assumed federally mandated lighting standards 17
would be in place; however due to changes in those federal 18
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Idaho Power Company
standards, the Company’s programs claimed savings in 2020 1
associated with lighting that were not anticipated at the 2
time the targets were established. 3
Q. Did any programs experience large increases in 4
savings from the prior year? 5
A. Yes. Three programs had significant increases 6
in savings in 2020 as compared to 2019: The Commercial & 7
Industrial (“C&I”) Program Custom Projects option 8
experienced a 33 percent increase due to the completion of 9
several large long-term projects, the Home Energy Report 10
Program experienced a 23 percent increase, which was 11
attributable to the full program rollout to 127,138 12
participants in 2020 compared to the 2019 pilot program 13
which included 24,976 participants, and the Irrigation 14
Efficiency Rewards Program experienced a 28 percent 15
increase in savings due to an increase in the number of 16
projects under the Custom Incentive option. 17
Q. Did the COVID-19 pandemic impact the Company’s 18
DSM activity? 19
A. Yes. Several programs experienced changes due 20
to the impacts of the COVID-19 pandemic. During the 21
initial months of the pandemic, Idaho Power suspended 22
activity that included person-to-person interactions such 23
as installers in customer homes, in-person trade shows, in-24
person vendor trainings, and contractors working at 25
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business sites. These modifications were necessary and 1
prudent in the interest of safety for customers and those 2
employees and contractors involved in administering the 3
programs. The DSM 2020 Annual Report provides tables 4
summarizing the impacts of COVID-19 on Residential and C&I 5
programs on pages 3-4. 6
Through consultation with EEAG and other 7
stakeholders, the Company adapted and was still able to 8
achieve near-record savings for the 2020 program year. For 9
example, trainings and workshops were moved to a virtual 10
format, and Idaho Power tailored its marketing to provide 11
energy efficiency savings tips for residential customers 12
who may be working or schooling from home. 13
While in-person activity for the Small Business 14
Direct Install (“SBDI”) program was suspended during part 15
of the year, the Company was able to resume customer 16
installations in October 2020 when safety protocols for 17
contractors and customers were applied and in place. 18
Despite the challenges, the program achieved first year 19
savings of 780 MWh. 20
Q. Does the Company engage in customer education 21
and outreach activities for which it cannot quantify or 22
report savings? 23
A. Yes. The Company engages in significant 24
educational awareness activities and marketing efforts that 25
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Idaho Power Company
are likely to result in energy savings experienced by 1
customers but are not quantified or claimed as part of 2
Idaho Power’s annual savings. These efforts are designed 3
to reach all customer segments and are more fully explained 4
throughout the DSM 2020 Annual Report. In 2020, this 5
included activity such as: holding virtual technical 6
trainings and workshops with customers, producing the 7
Energy@Work newsletters, participating in the Idaho 8
Irrigation Equipment Association Winter Show, hosting or 9
participating in vendor workshops promoting irrigation 10
system efficiency, participating in agricultural shows, 11
publishing residential energy efficiency guides which 12
showcased behavioral changes to save energy, attending 13
other outreach activities such as home shows, sponsoring 14
virtual webinars, and financially supporting the Integrated 15
Design Lab. Several of these activities were held in 16
person before moving to a virtual format after March 2020. 17
Q. Did the Company discontinue any programs 18
during 2020? 19
A. Yes. Idaho Power’s Energy Efficient Lighting 20
and Simple Steps, Smart SavingsTM programs, which are both 21
part of the regional Simple Steps, Smart SavingsTM (“Simple 22
Steps”) program administered by the Bonneville Power 23
Administration (“BPA”), were discontinued by BPA in 24
September 2020 at the end of BPA’s fiscal year. The 25
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regional program promoted the purchase of energy efficient 1
lighting and appliances through a point-of-sale buydown. 2
BPA’s decision to end the Simple Steps program was made in 3
the fourth quarter of 2019 based on projections the program 4
would no longer be cost effective after 2020. The decrease 5
in cost-effectiveness was due to the ongoing lighting 6
market transformation towards high-efficiency lightbulbs, a 7
decrease in deemed savings, and administrative costs from 8
the contractor. The decision to discontinue the program 9
was later supported by the deactivation of the Regional 10
Technical Forum (“RTF”) workbook on claimed savings for 11
showerheads in mid-2020. Idaho Power committed to 12
participate through the end of the regional program, 13
September 2020, and expected the program to remain cost-14
effective. 15
The mail-by-request Energy-Saving Kits (“ESK”), 16
which are part of the Educational Distributions program, 17
were discontinued in December 2020 after it was determined 18
the kits would no longer be cost effective going forward. 19
However, the Student Energy Efficiency Kits and Welcome 20
Kits will continue to be offered as part of the Educational 21
Distributions program. 22
The decision to discontinue the Energy Efficient 23
Lighting and Simple Steps, Smart SavingsTM programs, as well 24
as the ESK offering under the Educational Distributions 25
GORALSKI, DI 12
Idaho Power Company
program, was finalized after discussions with EEAG. The 1
Company has committed to exploring the feasibility of 2
implementing cost-effective variations of these programs in 3
the future. 4
Demand Response 5
Q. What level of demand reduction capacity was 6
available from Idaho Power’s demand response programs in 7
2020? 8
A. The total available capacity of Idaho Power’s 9
three demand response programs was approximately 366 10
megawatts (“MW”). This value represents the total demand 11
response capacity calculated using the total enrolled MW 12
from participants with an expected maximum realization rate 13
for those participants in all three demand response 14
programs. The programs provided actual demand reduction of 15
336 MW during the 2020 program season. Chart 2 below 16
reflects the annual available peak demand reduction 17
capacity and actual load reduction in MW since 2004 and the 18
associated annual expenses in millions of dollars. 19
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Idaho Power Company
Chart 2. Peak Demand Reduction Capacity (MW) and Demand 1 Response Expenses ($ millions) 2004-2020 2
3
II. 2020 DSM EXPENSES AND ADJUSTMENTS 4
Q. What amount of DSM expenses is the Company 5
requesting the Commission find were prudently incurred? 6
A. In the delivery of energy efficiency, demand 7
response, and market transformation programs, Idaho Power 8
expended $40,477,043 of Rider funds and $6,533,734 of 9
demand response program incentives, for a total of 10
$47,010,777 spent on demand-side resource acquisition in 11
2020. Idaho Power requests that the 2020 Rider-funded DSM 12
expenses, and the 2020 demand response program incentives 13
recovered through base rates and the PCA, be reviewed 14
together for a prudence determination. Exhibit No. 1 to my 15
testimony, 2020 Idaho DSM Expenses and Adjustments for 16
GORALSKI, DI 14
Idaho Power Company
Prudence Filing, shows a breakout of these expenses by 1
program, customer sector, and funding source. 2
This year’s Rider-funded DSM expenses increased 6 3
percent compared to the DSM expenses reviewed in last 4
year’s prudence case, Case No. IPC-E-20-15. The increase 5
in 2020 expenses was primarily driven by slightly higher 6
costs to acquire savings in the Educational Distributions 7
Program and the C&I Program Custom Projects and Retrofits 8
options due to a reduction in lighting claimed savings. 9
Q. Please compare the dollar amounts in Exhibit 10
No. 1 to your testimony with Appendix 2, 2020 DSM expenses 11
by funding source (dollars), of the DSM 2020 Annual Report. 12
A. For clarity and ease of understanding, Exhibit 13
No. 1 ties to Appendix 2, which is found on page 152 of the 14
DSM 2020 Annual Report. The first column of Appendix 2 15
labeled “Idaho Rider” and the first column of Exhibit No. 1 16
labeled “Rider Expenses” match at the row labeled “Total 17
Expenses” in Exhibit No. 1 and “Grand Total” in Appendix 2 18
in the amount of $40,409,911. All values in Exhibit No. 1 19
represent DSM expenses for the Idaho service area only. 20
One prior year-end and two current year-end accounting 21
adjustments were necessary to accurately arrive at the 22
total 2020 expenses for purposes of the prudence 23
determination. These three adjustments are listed in 24
Exhibit No. 1 under the Adjustments section as 2019 Idaho 25
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Idaho Power Company
Labor Prudence Adjustment, Green Power, and SBDI: Small 1
Business Direct Install. 2
Q. Please describe the prior year-end accounting 3
adjustment included in Exhibit No. 1. 4
A. In 2020, Idaho Power made an adjustment of 5
$51,166 to 2019 DSM labor expense in conformance with 6
Commission Order No. 34827 in the Company’s 2019 DSM 7
Prudence filing, Case No. IPC-E-20-15. The $51,166 2019 8
DSM labor disallowance was credited back to the Rider in 9
October 2020 when Order No. 34827 was received. To 10
accurately reflect 2020 DSM spending, an adjustment is 11
necessary to add $51,166 back to the 2020 expenses to 12
reflect the expenses incurred related to 2020 DSM efforts. 13
Q. Please describe the current year-end 14
accounting adjustments included in Exhibit No. 1. 15
A. During the year-end financial close process, 16
two accounting adjustments to the Rider for 2020 were 17
identified, and the corrections were made in January and 18
February of 2021. The first adjustment reverses a credit 19
of $57 that was incorrectly applied to the Rider during 20
2020 instead of the Company’s Green Power program, which is 21
a non-Rider funded program. The second adjustment adds 22
$15,910 of expenses associated with activity for the SBDI 23
Program that occurred in Idaho that were incorrectly 24
charged to the Oregon Energy Efficiency Rider in 2020. 25
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Idaho Power Company
Q. What amount of Rider-funded employee DSM-1
related labor expense did the Company incur in 2020? 2
A. The 2020 total Rider-funded DSM employee labor 3
expense incurred by the Company was $3,408,382 as it 4
related to managing the DSM program portfolio and pursuing 5
energy efficiency educational and awareness campaigns. 6
Q. What amount of 2020 DSM-related labor is the 7
Company requesting be funded through the Rider? 8
A. The Company is requesting $3,303,013 of the 9
total $3,408,382 in 2020 DSM labor expense to be collected 10
through the Rider. The Company believes it was necessary 11
to spend $3,408,382 for 2020 DSM labor to support the 12
pursuit of cost-effective energy efficiency in the 13
Company’s Idaho service area, but as part of this prudence 14
request, the Company has only included Rider-funded labor 15
based on the annual labor cost cap detailed in Order No. 16
34874. The Company continues to include all program 17
expenses, including total labor, in its cost-effectiveness 18
determinations, and only seeks a prudence determination for 19
the amount based on the Commission’s authorized 20
methodology. 21
Q. How did the Commission state the maximum 22
amount of DSM labor expense be calculated in the Company’s 23
annual prudence request? 24
A. In Order No. 34874, the Commission stated: 25
GORALSKI, DI 17
Idaho Power Company
“The Company shall apply the 2% cap to actual average wages 1
per FTE going forward. The baseline for the 2% cap shall 2
be the prior year’s actual average wages per FTE.” 3
Q. Did the Company apply the Commission’s method 4
to determine the amount of labor to be funded by the Rider? 5
A. Yes. Table 2 shows the calculation of the 6
2020 labor expenses applied to the Idaho Rider. The 7
Company applied a 2 percent cap to the 2020 DSM labor 8
expense increase based on the prior year’s actual average 9
wages per FTE, as directed by the Commission, and found 10
$105,369 was in excess of the maximum allowed labor 11
expense. This amount is not included in Rider-funded 12
expenses for 2020 DSM prudence. 13
Table 2. Labor Expense Calculation
2019 Total Actual Labor Expense $ 3,293,785
2019 FTEs ÷ 25.52
2019 Actual Average Wage per FTE $ 129,067
2% Cap x 1.02
2020 Maximum Average Wage per FTE $ 131,648
2020 FTEs x 25.09
2020 Maximum Allowed Labor Expense* $ 3,303,013
2020 Total Actual Labor Expense - $ 3,408,382
Amount in Excess of Maximum Allowed Labor Expense $ (105,369)
*2020 maximum allowed labor expense calculated based on actual 2020 FTE 14 equal to total hours/1,912, not displayed rounded value of 25.09. 15 16
Q. What was the year-end 2020 balance of the 17
Rider? 18
A. The Rider account balance on December 31, 19
2020, had a negative, or under-collected balance of 20
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$12,230,374. Table 3 below shows the January 2020 beginning 1
balance, funding plus accrued interest, expenses, and the 2
ending balance as of December 31, 2020. 3
Table 3. Idaho Energy Efficiency Rider (January-December 4 2020) 5
Idaho Energy Efficiency Rider
2020 Beginning Balance $ (311,045)
2020 Funding plus Accrued Interest as of 12/31/20 28,490,581
Total 2020 Funds 28,179,537
2020 Expenses as of 12/31/20 (40,409,911)
Ending Balance as of 12/31/20 $ (12,230,374)
6
III. 2020 COST-EFFECTIVENESS OVERVIEW 7
Q. What is Idaho Power’s overall goal when it 8
comes to DSM cost-effectiveness tests? 9
A. Idaho Power strives to ensure that DSM funds 10
collected from customers are utilized to support the 11
pursuit of cost-effective energy efficiency and demand 12
response programs, with the limited exception of certain 13
policy considerations. This goal is achieved by applying a 14
multi-step process. Prior to the actual implementation of 15
energy efficiency or demand response programs, Idaho Power 16
performs a preliminary cost-effectiveness analysis to 17
assess whether a potential program design or measure will 18
be cost-effective from the perspective of customers as well 19
as the Company. Idaho Power measures cost-effectiveness 20
under three tests: the UCT, the TRC test, and the PCT. A 21
review of each test allows for an economic assessment of 22
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the life-cycle costs and benefits of a DSM investment from 1
the perspective of DSM program participants, Idaho Power, 2
and non-participating customers. 3
Idaho Power also reviews the cost-effectiveness 4
results for each program and measure on an annual basis to 5
determine whether a program should continue or be modified 6
so it remains cost-effective on an ongoing basis. If a 7
measure or program is identified as non-cost-effective, 8
Idaho Power seeks EEAG input before making its 9
determination on modifying, continuing, or discontinuing an 10
offering. 11
The cost-effectiveness test methodologies and 12
assumptions are described in more detail in the first pages 13
of Supplement 1: Cost-Effectiveness (“Supplement 1”), 14
included in Attachment 1 to the Application in this 15
proceeding. 16
Q. Does Idaho Power believe its application of 17
the standard economic tests is consistent with Commission 18
directives? 19
A. Yes. Idaho Power believes its application of 20
the three economic tests is consistent with prior 21
Commission directives, as described in Order No. 33365:2 22
We thus find it reasonable for the Company to 23 continue screening potential programs using each 24
2 In the Matter of the Application of Idaho Power Company for a Determination of 2014 Demand-Side Management Expenditures as Prudently
Incurred, Case No. IPC-E-15-06, Order No. 33365, p. 9-10.
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Idaho Power Company
test as a guideline, and to advise us on how the 1
Company's programs fare under each test. When the 2 Company ultimately seeks to recover its prudent 3 investment in such programs, however we believe the 4
Company may (but need not exclusively) emphasize the 5 UCT-and that test's focus on Company-controlled 6
benefits and costs-to argue whether the programs 7 were cost-effective. As always, the Company 8 ultimately must persuade us that its program 9
investments were prudent under the totality of the 10 circumstances. 11
12 Because Idaho Power must ultimately demonstrate to 13
the Commission that its program investments were prudent 14
under "the totality of the circumstances", the Company 15
continues to evaluate performance from the three 16
perspectives. 17
Q. Has the Commission subsequently issued a 18
determination on the proper economic test perspective for 19
energy efficiency resources in the IRP? 20
A. Yes. In Order No. 34469 issued in Case No. 21
IPC-E-19-11, the Commission ordered “that Idaho Power use 22
the UCT perspective for integrated resource planning.” 23
A. 2020 Cost-Effectiveness Results 24
Q. What were the results of the 2020 cost-25
effectiveness analyses? 26
A. Exhibit No. 2 to my testimony, 2020 Cost-27
Effectiveness Summary by Program, Sector, and Portfolio, 28
shows the results of the UCT, TRC test, and PCT for every 29
energy efficiency program aggregated by sector and for the 30
overall portfolio. As shown in Exhibit No. 2, and below in 31
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Table 4, all three program sectors and the overall DSM 1
portfolio achieved benefit/cost ratios greater than 1.0 2
from the perspective of all three cost-effectiveness tests. 3
Table 4. 2020 Benefit/Cost by Sector & Portfolio 4
Sector Test (UCT) Cost Test
Residential 1.64 1.91 6.41
Commercial/Industrial 3.18 1.62 1.58
Irrigation 4.01 4.09 3.96
Portfolio 2.71 2.08 2.45
5
On an individual program basis, 11 of the 16 energy 6
efficiency programs offered in Idaho for which the Company 7
calculates cost-effectiveness had benefit/cost ratios 8
greater than 1.0 under the UCT. 9
The PCT ratios cannot be calculated for programs 10
that do not have a direct customer cost, and the PCT is 11
shown as “N/A” in Exhibit No. 2 for those programs. The 12
details of these calculations are found in Supplement 1 of 13
the DSM 2020 Annual Report. 14
Q. Did Idaho Power calculate cost-effectiveness 15
for each measure within each energy efficiency program it 16
offers? 17
A. Yes. In 2020, Idaho Power evaluated the 18
benefits and costs of 281 measures. The results of these 19
calculations, along with measure assumption details and 20
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source documentation, can be found in Supplement 1 to the 1
DSM 2020 Annual Report. 2
Q. How did Idaho Power address any individual 3
measures that are not cost-effective based on one or more 4
tests? 5
A. The cost and benefit values used in the 6
various analyses are based on markets, technologies, 7
economic inputs, savings estimates, and cost estimates, 8
which can change over time. When a measure is identified 9
as non-cost-effective at a specific point in time, Idaho 10
Power first evaluates whether the inputs used in the 11
calculations are still applicable. Then the Company 12
determines if the measure parameters should be modified or 13
if the measure should be eliminated altogether. For 14
additional detail on measure analysis, please refer to 15
Supplement 1 to the DSM 2020 Annual Report. 16
B. Transition to UCT for Energy Efficiency Program 17
Implementation and Evaluation 18
Q. Has the Commission’s directive to rely on the 19
UCT for resource planning impacted program implementation 20
and evaluation? 21
A. Yes. After reviewing Commission Order Nos. 22
33365 and 34469 and consulting with EEAG, the Company is 23
now primarily relying on UCT cost-effectiveness to screen 24
and make program continuation decisions in its Idaho 25
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service area. Considering the most recent Commission 1
order, coupled with the previous Commission findings that 2
Idaho Power can emphasize the UCT for prudence 3
determinations, the Company will focus the remainder of its 4
program-specific cost-effectiveness discussion on programs 5
that did not pass the UCT for program year 2020. 6
1. Income Qualified Weatherization 7
Q. What were the cost-effectiveness results for 8
the Weatherization Assistance for Qualified Customers 9
(“WAQC”) and Weatherization Solutions for Eligible 10
Customers (“Solutions”) programs? 11
A. As shown in Exhibit No. 2, the WAQC and 12
Solutions programs, both of which are offered to limited-13
income customers, did not achieve the 1.0 benefit/cost 14
ratio threshold in 2020 under the UCT. 15
In 2020, Idaho Power contracted with a third-party 16
consultant to conduct a billing analysis of 2016-2018 17
weatherization jobs for both the WAQC and Solutions 18
programs. The analysis estimated the electric energy 19
savings of the weatherization jobs by comparing whole-home 20
energy usage of the participants, before and after the 21
weatherization jobs, to a matched comparison group. The 22
results of the analysis showed that savings for 23
weatherization jobs have decreased relative to savings 24
reported in previous years. To address the decrease in 25
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energy savings, and thus cost-effectiveness, Idaho Power is 1
working with EEAG, as well as the weatherization managers 2
that oversee the weatherization work, to discuss ways to 3
improve the cost-effectiveness of the programs. 4
Q. Why do the WAQC and Solutions programs 5
continue to not be cost-effective, and how does Idaho Power 6
attempt to improve them? 7
A. The WAQC and Solutions programs provide real 8
and substantial per home savings, but due to the costs of 9
comprehensive whole-house weatherization, it is difficult 10
for the value of the savings to outweigh the costs. The 11
weatherization services provided through the WAQC program 12
are consistent with the Idaho State Weatherization 13
Assistance Program (“WAP”) guidelines, and both the WAQC 14
and Solutions programs are offered at no charge to the 15
participant. These programs are designed for limited-16
income customers, and Idaho Power believes there are other 17
benefits to these programs that are difficult to quantify, 18
such as health and safety measures. In 2020, 115 homes in 19
Idaho were weatherized through the WAQC program. 20
For the Solutions program, the Company has continued 21
a participation requirement that was introduced in 2016 22
requiring landlords to fund at least 10 percent of the 23
project. In 2020, the Company held the average cost per 24
home constant from the 2014 level for the weatherization 25
GORALSKI, DI 25
Idaho Power Company
contractors, which helped reduce the cost of the program. 1
The Company continues to support the whole-house philosophy 2
by allowing a $6,000 annual maximum average per-home cost. 3
In 2020, 27 homes in Idaho were weatherized through the 4
Solutions program. Of the 27 homes that were weatherized, 5
15 were single-family, 11 were manufactured homes, and one 6
was a multi-family unit. 7
Q. Does Idaho Power plan to continue offering the 8
WAQC and Solutions programs in the future? 9
A. Yes. While the Company has identified that 10
the programs are not cost-effective under the UCT, unless 11
the Commission directs otherwise, Idaho Power will continue 12
to offer them to the Company’s limited-income customers on 13
an ongoing basis. The Company will also continue to 14
consult the EEAG and weatherization managers who oversee 15
the weatherization work to look for ways to improve the 16
cost-effectiveness of these programs. 17
2. Programs Impacted by COVID-19 18
Q. Did impacts from COVID-19 result in certain 19
programs not being cost-effective? 20
A. Yes. As previously discussed in my testimony, 21
due to safety concerns, in-home activity associated with 22
programs was suspended mid-March, meaning programs that 23
rely on direct install measures or in-home work to achieve 24
savings had reduced opportunities for participation. Due 25
GORALSKI, DI 26
Idaho Power Company
to this limitation, Energy House Calls and the Multifamily 1
Energy Savings Program had UCT ratios of 0.63 and 0.14, 2
respectively, in 2020. 3
Q. How has Idaho Power maintained program demand 4
for Energy House Calls and the Multifamily Energy Savings 5
Program once in-home activity is safe to resume? 6
A. While the in-home activity was suspended, the 7
Company’s program specialists have maintained a waitlist of 8
customers or buildings who are eligible for and desire to 9
participate in the programs. Marketing efforts related to 10
the programs have also continued. The overall level of 11
participation was not at a scale for the programs to 12
achieve cost-effectiveness in 2020. However, the Company is 13
confident that both Energy House Calls and the Multifamily 14
Energy Savings Program can be cost effective with a typical 15
year’s participation. At the time of this filing, the 16
Company believes with social distancing and proper safety 17
protocols the programs may be able to resume in-home 18
activity in 2021. The Company will continue to adhere to 19
local, state, and federal guidelines as the pandemic 20
evolves. 21
3. Discontinued Programs 22
Q. Did the Company discontinue any programs which 23
were no longer cost-effective? 24
A. Yes. As noted earlier, The Simple Steps, 25
GORALSKI, DI 27
Idaho Power Company
Smart SavingsTM Program had a planned sunset date of 1
September 2020, but the final year UCT cost-effectiveness 2
of 0.78 was lower than expected. Key final year 3
differences from prior-year expectations were large swings 4
in showerhead sales product mix skewing towards showerheads 5
that had large reductions in RTF savings assumptions and 6
incremental lighting savings reaching market saturation. 7
C. 2020 Demand Response Cost-Effectiveness 8
Q. Does Idaho Power evaluate cost-effectiveness 9
for its three demand response programs? 10
A. Yes, however, benefit/cost ratios are not 11
calculated for the three demand response programs. 12
Instead, the methodology used to determine the cost-13
effectiveness of the demand response programs compares the 14
annual cost of operating Idaho Power’s demand response 15
portfolio to the levelized annual cost of a single 170 MW 16
deferred resource over a 20-year life.3 In 2020, the 17
system-wide cost of operating the three demand response 18
programs was approximately $7.7 million ($6.9 million of 19
incentives and $0.8 million of other costs). The amounts 20
attributable to the Idaho-only jurisdiction were $7.3 21
million ($6.5 million of incentives and $0.8 million of 22
other costs). Idaho Power estimated that if the three 23
3 Demand response valuation methodology was reached by settlement agreement and approved in Commission Order No. 32923 as part of Case No. IPC-E-13-14.
GORALSKI, DI 28
Idaho Power Company
programs were dispatched for the full 60 hours allowed, the 1
total costs would have been approximately $10.9 million on 2
a system-wide basis. 3
Using the 2017 IRP, acknowledged by the Commission 4
in Order No. 33983, Case No. IPC-E-17-11, the maximum 5
annual cost of running all three demand response programs 6
for the maximum allowable hours of 60 hours should be no 7
more than $19.6 million, leading Idaho Power to conclude 8
that its three demand response programs were cost-effective 9
in 2020. 10
IV. EVALUATION ACTIVITY OVERVIEW 11
Q. What is the Company’s approach to DSM program 12
evaluation? 13
A. To ensure the ongoing cost-effectiveness of 14
programs through validation of energy savings and demand 15
reduction, and to guide the efficient management of its 16
programs, the Company relies on evaluations by third-party 17
contractors chosen through a competitive bidding process. 18
Idaho Power uses industry-standard protocols, internal 19
analyses, and regional and national studies to inform its 20
internal and external evaluation efforts. The Company has 21
generally conducted impact evaluations every three years, 22
and process evaluations for relatively new programs, or 23
when a program has significant changes. Supplement 2: 24
Evaluations (“Supplement 2”) to the DSM 2020 Annual Report 25
GORALSKI, DI 29
Idaho Power Company
provides additional information regarding how Idaho Power 1
evaluates its programs. 2
Q. How does Idaho Power utilize the evaluations 3
described above? 4
A. Idaho Power uses the results of its 5
evaluations to inform decisions related to program 6
improvement, to compare processes to industry best 7
practices, and to benchmark and validate reported program 8
savings. 9
Q. What evaluation activities took place in 2020? 10
A. In addition to the annual cost-effectiveness 11
analyses that the Company conducts for each program, Idaho 12
Power contracted with several vendors to conduct impact, 13
process, and other evaluations in 2020. Evaluations 14
conducted by these vendors were on the following programs: 15
• Impact and process evaluations on Educational 16
Distributions and Irrigation Efficiency Rewards. 17
• Impact evaluation on Rebate Advantage. 18
• Process evaluation on Home Energy Reports. 19
• Joint billing analysis for the WAQC and 20
Solutions. 21
• Program summary reports and savings analyses for 22
Home Energy Reports, Residential Energy-Saving 23
Kits, Student Energy Efficiency Kits and 24
Commercial Energy-Saving Kits. 25
GORALSKI, DI 30
Idaho Power Company
• Additionally, Idaho Power completed internal 1
analyses of the Irrigation Peak Rewards, Flex 2
Peak, and A/C Cool Credit demand response 3
programs. 4
Three of the impact evaluations that were conducted 5
in 2020 analyzed reported savings from the 2019 program 6
year. Realization rates were as follows: 7
• Educational Distributions – 97.2% for overall 8
savings; 100% for number of kits. 9
• Rebate Advantage – 100%. 10
• Irrigation Efficiency Rewards – 97.4% overall kWh 11
(100% Menu and 95.42% Custom). 12
The final reports for these evaluations, and the 13
market effects evaluations conducted by NEEA, are included 14
in Supplement 2 to the DSM 2020 Annual Report. 15
Q. Does Idaho Power have a DSM program evaluation 16
plan for 2021-2022? 17
A. Yes. The evaluation plan is included as 18
Exhibit No. 3 to my testimony and is also included in 19
Supplement 2 to the DSM 2020 Annual Report. In 2021, Idaho 20
Power’s evaluation plan includes the following third-party 21
evaluations: 22
• Impact and process evaluations for Heating & 23
Cooling Efficiency and C&I Custom Projects 24
option. 25
GORALSKI, DI 31
Idaho Power Company
• Impact evaluations for A/C Cool Credit, Flex 1
Peak, Irrigation Peak Rewards. 2
• Process evaluation for Small Business Direct-3
Install. 4
• Home Energy Reports savings analysis. 5
V. STAKEHOLDER INPUT 6
Q. What is the EEAG? 7
A. In 2002, Idaho Power formed the EEAG to 8
provide input on enhancing existing DSM programs, 9
recommending new energy efficiency measures, and 10
implementing energy efficiency programs. Members include 11
customer representatives from residential, irrigation, 12
commercial, and industrial sectors, and technical experts, 13
as well as representatives for limited-income individuals, 14
environmental organizations, state agencies, county and 15
city governments, the Commission, the Public Utility 16
Commission of Oregon, and Idaho Power. 17
Q. What is the structure of EEAG meetings? 18
A. The EEAG generally meets quarterly in-person 19
at Idaho Power’s corporate offices and through webinars as 20
needed. Due to COVID-19 safety protocols, all but one EEAG 21
meeting was held virtually in 2020, and the Company found 22
the transition to virtual meetings was successful in 23
maintaining member participation. 24
GORALSKI, DI 32
Idaho Power Company
The agenda during EEAG meetings is varied, but 1
typically includes: new energy efficiency program ideas, 2
new measure proposals, marketing methods, specific measure 3
details including cost-effectiveness, the status of energy 4
efficiency expenses, Idaho and Oregon Rider funding, 5
program and project updates, and general information on DSM 6
issues. When appropriate, the Company invites experts to 7
speak on evaluations, research, and other topics of 8
interest to enhance EEAG’s understanding. 9
Q. How did Idaho Power solicit guidance from the 10
EEAG during the 2020 program year? 11
A. The Company held six EEAG meetings throughout 12
2020, one in-person and five webinars. During these 13
meetings, Idaho Power discussed and requested 14
recommendations on a broad range of DSM issues. As 15
explained in greater detail in the DSM 2020 Annual Report, 16
the list below includes some of the topics Idaho Power 17
worked with the EEAG on for development, design, promotion, 18
or input: 19
• COVID-19 Impacts: The Company provided status 20
updates on affected programs throughout the year. 21
The Company shared how it was making activity 22
modifications and EEAG members provided feedback 23
on offering increased virtual program workshops, 24
trainings, and ways to leverage digital and print 25
GORALSKI, DI 33
Idaho Power Company
marketing channels to provide energy efficiency 1
tips for customers who may be spending more time 2
at home. 3
• WAQC and Solutions: Idaho Power reviewed with 4
EEAG the results of the third-party energy 5
savings evaluation completed for the Company’s 6
WAQC and Solutions programs. The Company 7
highlighted that future program cost-8
effectiveness would be impacted by incorporating 9
the lower energy savings assumptions from the 10
evaluation and discussed several potential ideas 11
to improve program cost-effectiveness. One EEAG 12
recommended exploring the potential of measure 13
lists. EEAG members also asked additional 14
questions on the types of measures installed and 15
other program funding sources. 16
• Educational Distributions: With the decision to 17
sunset ESKs, an EEAG member suggested a “last 18
chance” marketing tactic to help promote a final 19
push before the program’s end. This resulted in 20
successfully distributing the remaining ESKs in 21
inventory to customers. 22
• Energy Efficient Lighting/Simple Steps, Smart 23
Savings™: With the BPA-administered program 24
ending September 30, 2020, Idaho Power consulted 25
GORALSKI, DI 34
Idaho Power Company
with EEAG on pursuing a buydown program for 1
measures in markets that still have cost-2
effective savings potential. EEAG was supportive 3
of the idea and appreciated Idaho Power’s work 4
with Energy Trust of Oregon in exploring 5
potential lighting options for a new program 6
offering. 7
Q. Did Idaho Power work with Commission Staff 8
(“Staff”) in response to concerns raised in 2019 DSM 9
Prudence Comments? 10
A. Yes. The Company met with Staff on January 11
15, 2021 to better understand Staff’s concerns and 12
recommendations for potential adjustments to the Company’s 13
demand response programs. During the meeting, several 14
aspects of the Company’s demand response programs were 15
discussed, including the Value of Demand (“VOD”) 16
calculation and the ability to meet coincident peak when 17
capacity deficient. As part of the discussion, the Company 18
and Staff found an opportunity to update the Effective Load 19
Carrying Capacity (ELCC) portion of the VOD calculation 20
annually to more accurately reflect the availability of 21
demand response programs to meet peak load. 22
GORALSKI, DI 35
Idaho Power Company
VI. CONCLUSION 1
Q. Do you believe that the information contained 2
in this testimony and attached exhibits supports a prudence 3
determination for 2020 DSM expenses? 4
A. Yes. The DSM 2020 Annual Report details Idaho 5
Power’s DSM offerings in program specific sections. Based 6
on the DSM 2020 Annual Report, the testimony set forth 7
above, and the attached exhibits, Idaho Power respectfully 8
requests the Commission determine that $47,010,777 of DSM 9
expenses incurred for the acquisition of demand-side 10
resources was prudently incurred. 11
Q. Does this conclude your testimony? 12
A. Yes, it does. 13
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-21-04
IDAHO POWER COMPANY
GORALSKI, DI
TESTIMONY
EXHIBIT 1
Expenses Rider Expenses
Demand Response
Program Incentives
Recorded in PCA Total Expenses
Energy Efficiency/Demand Response
Residential
A/C Cool Credit 405,402$ 332,420$ 737,822$
Educational Distributions 3,912,564 -3,912,564
Energy Efficient Lighting 1,603,129 -1,603,129
Energy House Calls 40,492 -40,492
Heating & Cooling Efficiency Program 578,893 -578,893
Home Energy Audit 128,547 -128,547
Multifamily Energy Savings Program 83,951 -83,951
Rebate Advantage 174,670 -174,670
Residential New Construction 471,542 -471,542
Shade Tree Project 27,652 -27,652
Simple Steps, Smart Savings ™93,865 -93,865
Weatherization Solutions for Eligible Customers 198,226 -198,226
Commercial/Industrial
Commercial Energy-Saving Kits 97,645 -97,645
Custom Projects 17,533,047 -17,533,047
FlexPeak Program 84,716 247,383 332,099
New Construction 2,278,454 -2,278,454
Retrofits 3,481,992 -3,481,992
SBDI: Small Business Direct Install (c)322,463 -322,463
Irrigation
Irrigation Efficiency 3,165,075 -3,165,075
Irrigation Peak Rewards 264,843 5,953,930 6,218,773
Energy Efficiency/Demand Response Total 34,947,166$ 6,533,734$ 41,480,900$
Market Transformation
NEEA 2,649,749 -2,649,749
Market Transformation Total 2,649,749$ -$ 2,649,749$
Other Programs and Activities
Commercial/Industrial Energy Efficiency Overhead 393,112 -393,112
Energy Efficiency Direct Program Overhead 322,964 -322,964
Residential Energy Efficiency Education Initiative 209,644 -209,644
Residential Energy Efficiency Overhead 985,565 -985,565
Other Programs and Activities Total 1,911,284$ -$ 1,911,284$
Indirect Program Expenses
Energy Efficiency Accounting & Analysis 929,467 -929,467
Energy Efficiency Advisory Group 4,448 -4,448
Special Accounting Entries
Special Accounting Entries (32,203)-(32,203)
Indirect Program Expenses Total 901,712$ -$ 901,712$
Total Expenses 40,409,911$ 6,533,734$ 46,943,645$
Adjustments
Prior year-end accounting adjustments:
2019 Idaho Labor Prudence Adjustment (a)51,166 51,166
Current year-end accounting adjustments:
Green Power (b)57 57
SBDI: Small Business Direct Install (c)15,910 15,910
2020 Prudence Filing Total 40,477,043$ 6,533,734$ 47,010,777$
(a) $51.2K adjustment for 2019 labor expenses per Order No. 34827. Credit was applied to the Idaho Rider in 2020.
(b) Credit to the Idaho Rider that should have been applied to Green Power, a non-rider program. The correction was made in 2021.
(c) Idaho Rider expenses of $15.9K that were initially charged to the Oregon Rider. The correction was made in 2021.
Idaho Power Company
2020 Idaho DSM Expenses and Adjustments for Prudence Filing
Exhibit No. 1
Case No. IPC-E-21-04
P. Goralski, IPC
Page 1 of 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-21-04
IDAHO POWER COMPANY
GORALSKI, DI
TESTIMONY
EXHIBIT 2
Program/Sector
Utility Cost Test
(UCT)
Total Resource Cost
(TRC)
Participant Cost
(PCT)
Educational Distributions 1.45 2.19 N/A
Energy Efficient Lighting 4.56 4.20 7.77
Energy House Calls 0.63 0.77 N/A
Heating & Cooling Efficiency Program 1.66 0.81 1.46
Multifamily Energy Savings Program 0.14 0.28 N/A
Rebate Advantage 1.69 0.98 2.17
Residential New Construction 1.54 1.20 2.26
Shade Tree Project*N/A N/A N/A
Simple Steps, Smart SavingsTM 0.78 3.24 13.23
Weatherization Assistance for Qualified Customers 0.20 0.33 N/A
Weatherization Solutions for Eligible Customers 0.13 0.23 N/A
Residential Energy Efficiency Sector 1.64 1.91 6.41
Commercial Energy-Savings Kits 1.24 2.38 N/A
Custom Projects 3.26 1.61 1.42
New Construction 3.40 2.63 3.14
Retrofits 3.25 1.35 1.56
Small Business Direct Install 1.04 1.61 N/A
Commercial/Industrial Energy Efficiency Sector **3.18 1.62 1.58
Irrigation Efficiency 4.00 4.09 3.96
Irrigation Energy Efficiency Sector ***4.01 4.09 3.96
Energy Efficiency Portfolio 2.71 2.08 2.45
2020 Benefit/Cost Tests
2020 Cost-Effectiveness Summary by Program, Sector, and Portfolio
* Shade Tree Project tree distributions were suspended in 2020 due to COVID-19, no newly-planted trees in 2020 to report energy savings.
** Commercial/Industrial Energy Efficiency Sector cost-effectiveness ratios include savings and participant costs from Green Motors Rewinds.
*** Irrigation Energy Efficiency Sector cost-effectiveness ratios include savings and participant costs from Green Motors Rewinds.
Exhibit No. 2
Case No. IPC-E-21-04
P. Goralski, IPC
Page 1 of 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-21-04
IDAHO POWER COMPANY
GORALSKI, DI
TESTIMONY
EXHIBIT 3
2022 2021 2020 2019 2018 2017 2016 2015 1 2014 2013 2012 2011 2010
Educational Distributions I/P
Energy Efficient Lighting I I P
Energy House Calls I/P I P
Heating & Cooling Efficiency Program I/P I/P P I P
Home Energy Audit P I P
Home Energy Reports I/O O P/O O O
Multifamily Energy Savings Program I/P I/P
Rebate Advantage I I/P I
Residential Energy Efficiency Education Initiative O P
Residential New Construction Pilot Program I/P
Shade Tree Project O P
Simple Steps, Smart Savings™
Weatherization Assistance for Qualified Customers O O P I
Weatherization Solutions for Eligible Customers O O P I
Commercial Energy-Saving Kits
Custom Projects I/P I P I/P I P
New Construction I/P I P I I P
Retrofits I/P I P I P I P
Small Business Direct-Install P
Irrigation Efficiency Rewards I/P I/P P/O P/I P
A/C Cool Credit O I O I O O O O O O P O
Flex Peak Program O I O O O O O O P/O O
Irrigation Peak Rewards O I O O O O O O O O O
1 Energy efficiency programs evaluated in 2015 have since been eliminated or combined into another program.
Evaluation Type: I = Impact, P = Process, O = Other
Program not yet in existence
Residential Energy Efficiency Programs
Commercial/Industrial Energy Efficiency Programs
Demand-Response Programs
Irrigation Energy Efficiency Programs
Customer Relations and Energy Efficiency 2021-2022 Program Evaluation Plan
Exhibit No. 3
Case No. IPC-E-21-04
P. Goralski, IPC
Page 1 of 1