HomeMy WebLinkAbout20230315Direct R. Thompson.pdf
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2022 DEMAND-
SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
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)
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)
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CASE NO. IPC-E-23-10
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
ROBERT Z. THOMPSON
RECEIVED
Wednesday, March 15, 2023 4:00:39 PM
IDAHO PUBLIC
UTILITIES COMMISSION
THOMPSON, DI 2
Idaho Power Company
Q. Please state your name and business address. 1
A. My name is Robert Z. Thompson. I go by my 2
middle name, and therefore, Zack Thompson is my preferred 3
name. My business address is 1221 West Idaho Street, Boise, 4
Idaho 83702. 5
Q. By whom are you employed, and in what 6
capacity? 7
A. I am employed by Idaho Power Company (“Idaho 8
Power” or “Company”) as a Regulatory Analyst in the 9
Regulatory Affairs Department. 10
Q. Please describe your educational background. 11
A. In May of 2008, I received a Bachelor of Arts 12
degree in Business, Organizations, and Society with a minor 13
in Economics from Franklin & Marshall College in Lancaster, 14
Pennsylvania. In May of 2014, I received a Master of 15
Business Administration degree with a specialization in 16
Finance from Louisiana State University in Baton Rouge, 17
Louisiana. I have also attended “The Basics: Practical 18
Regulatory Training for the Electric Industry,” an electric 19
utility ratemaking course offered through the New Mexico 20
State University’s Center for Public Utilities, “Electric 21
Utility Fundamentals and Insights,” an electric utility 22
course offered by Western Energy Institute, and “Electric 23
Rates Advanced Course,” an electric utility ratemaking 24
course offered through Edison Electric Institute. 25
THOMPSON, DI 3
Idaho Power Company
Q. Please describe your work experience with 1
Idaho Power. 2
A. In 2020, I was hired as a Regulatory Analyst 3
in the Company’s Regulatory Affairs Department. My primary 4
responsibilities include supporting activities associated 5
with demand-side management (“DSM”) as well as rate design 6
for the small general service, large general secondary 7
service, and irrigation customer classes. 8
Q. What is the purpose of your testimony in this 9
case? 10
A. The purpose of my testimony is to present the 11
Company’s request for a determination that $39,896,437 of 12
DSM expenses for the acquisition of demand-side resources 13
in 2022 was prudently incurred. This amount includes 14
$31,585,110 funded in 2022 by the Idaho Energy Efficiency 15
Rider (“Rider”) and $8,311,328 of demand response program 16
incentive payments funded through base rates and tracked 17
annually through the Power Cost Adjustment (“PCA”). 18
My testimony will: (1) provide a review of 2022 DSM 19
program performance, (2) discuss 2022 DSM expenses and 20
adjustments, (3) provide an overview of the cost-21
effectiveness results for 2022, (4) review program 22
evaluation efforts, and (5) describe the input stakeholders 23
provided during the year. 24
THOMPSON, DI 4
Idaho Power Company
I. 2022 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-funded DSM activities 5
seriously, and the Company believes it is important to 6
provide its customers with the maximum value from these 7
activities. The Company’s actions in 2022, and the content 8
of the Demand-Side Management 2022 Annual Report (“DSM 2022 9
Annual Report”), Attachment 1 to the Application filed in 10
this proceeding, provide evidence supporting the 11
conscientious work Idaho Power employees made toward using 12
customers’ funds wisely to support DSM activities. 13
Q. Please provide an overview of Idaho Power’s 14
DSM activities in 2022. 15
A. On a system-wide basis, Idaho Power offered a 16
broad portfolio of energy efficiency and demand response 17
programs available to all customer segments, and the 18
Company also participated in market transformation efforts 19
through the Northwest Energy Efficiency Alliance (“NEEA”). 20
In addition, the Company offered several educational and 21
behavioral initiatives including the Residential Energy 22
Efficiency Education Initiative, seasonal contests, the 23
School Cohort, and the continuation of the Water and 24
Wastewater Cohort. 25
THOMPSON, DI 5
Idaho Power Company
The Company leveraged its Energy Efficiency Advisory 1
Group (“EEAG”) to solicit input and feedback on ways to 2
identify opportunities to increase program effectiveness, 3
delivery, and marketing. A summary of Idaho Power’s 2022 4
DSM programs is provided in Table 1 below. 5
Table 1. 2022 DSM Programs by Sector, Operational Type, 6
and Location 7
Program by Sector Operational Type State
Residential
A/C Cool Credit ............................................................. Demand Response ID/OR
Easy Savings: Low-Income Energy Efficiency Education Energy Efficiency ID
Educational Distributions ............................................... Energy Efficiency ID/OR
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 ....................................................... Energy Efficiency ID
Home Energy Report 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 Program ........................ Energy Efficiency ID
Shade Tree Project ....................................................... Energy Efficiency ID
Weatherization Assistance for Qualified Customers ..... Energy Efficiency ID/OR
Weatherization Solutions for Eligible Customers........... Energy Efficiency ID
Commercial/Industrial
Commercial and Industrial Energy Efficiency Program
Custom Projects ....................................................... Energy Efficiency ID/OR
Green Motors—Industrial .................................... Energy Efficiency ID/OR
New Construction ..................................................... Energy Efficiency ID/OR
Retrofits .................................................................... Energy Efficiency ID/OR
Commercial Energy-Saving Kits.................................... 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
THOMPSON, DI 6
Idaho Power Company
Table 1 illustrates the broad availability of 1
programs offered by Idaho Power to its customers in energy 2
efficiency, demand response, and education. Idaho Power’s 3
energy efficiency portfolio was cost-effective, resulting 4
in a 2.02 benefit/cost ratio when evaluated from a Utility 5
Cost Test (“UCT”) perspective, a 1.43 benefit/cost ratio 6
when evaluated from a Total Resource Cost (“TRC”) test 7
perspective, and a 2.01 benefit/cost ratio when evaluated 8
from a Participant Cost Test (“PCT”) perspective. 9
The DSM 2022 Annual Report provides details for each 10
program, which include: a program description, 2022 11
performance results, program activities, cost-effectiveness 12
ratios, marketing activities, customer satisfaction, 13
upcoming 2023 plans, and evaluation results if applicable. 14
Filed in conjuction with the DSM 2022 Annual Report are: 15
Supplement 1: Cost Effectiveness (“Supplement 1”), which 16
provides detailed cost-effectiveness data, and Supplement 17
2: Evaluation (“Supplement 2”), which provides copies of 18
the Company’s evaluation, reports, and research conducted 19
in 2022. 20
Energy Efficiency 21
Q. What level of incremental annual energy 22
efficiency savings was achieved in 2022? 23
A. On a system-wide basis, Idaho Power achieved 24
169,889 megawatt-hours (“MWh”) of incremental annual energy 25
THOMPSON, DI 7
Idaho Power Company
efficiency savings in 2022. This value includes 145,440 MWh 1
from Idaho Power’s energy efficiency programs and an 2
estimated 24,448 MWh1 of energy efficiency market 3
transformation savings through NEEA initiatives. Chart 1 4
below shows the incremental annual energy efficiency 5
savings in MWh from 2002 to the current year. Also shown in 6
this chart are the total energy efficiency expenses for 7
each year in millions of dollars. 8
Chart 1. Incremental Annual Energy Efficiency Savings 9
(MWh)and Energy Efficiency Expenses ($ millions) 2002-2022 10
11
Note: 2022 NEEA market-transformation savings are estimated. 12
Q. Did Idaho Power meet the energy efficiency 13
targets included in its 2021 Integrated Resource Plan 14
(“IRP”)? 15
1 Because Idaho Power will not receive final 2022 savings from
NEEA until the second quarter 2023, the NEEA-attributable savings is an
estimate provided to Idaho Power by NEEA.
THOMPSON, DI 8
Idaho Power Company
A. Yes. In 2022, Idaho Power achieved 19.4 1
average megawatt-hours (“aMW”) of incremental energy 2
efficiency savings, including NEEA estimated energy 3
savings, which exceeded the economic technical achievable 4
potential included in the 2021 IRP of 16 aMW. The 2022 5
savings represent enough energy to power approximately 6
14,900 average homes in Idaho Power’s service area for one 7
year. 8
Q. How did 2022 savings compare to 2021? 9
A. Overall portfolio savings increased by 26,968 10
MWh, or 19 percent, year-over-year compared to 2021 with 11
the main drivers being the Commercial & Industrial (“C&I”) 12
Energy Efficiency Program Custom Projects, New 13
Construction, and Retrofits options. The projects within 14
these options can vary greatly in size, scale, and 15
completion, which can cause changes in overall portfolio 16
savings performance annually. These three program options 17
combined drove 53 percent of the increase in annual 18
incremental savings. A couple other notable drivers were 19
increases in savings associated with Home Energy Reports, 20
Energy Efficient Lighting, and Educational Distributions. 21
As noted in last year’s prudence request, the dip in 22
savings experienced between 2020 and 2021 was largely 23
driven by a reduction in Custom Projects. 2022 portfolio 24
results were positively impacted by several projects within 25
THOMPSON, DI 9
Idaho Power Company
that program option being completed within the program 1
year. The Company anticipates the overall portfolio will 2
see lower incremental savings in the coming years due to 3
Energy Independence and Security Act of 2007 (“EISA”) 4
lighting standards being fully adopted in 2023. 5
Q. Does the Company engage in customer education 6
and outreach activities for which it cannot quantify or 7
report savings? 8
A. Yes. The Company engages in significant 9
educational awareness activities and marketing efforts that 10
are likely to result in energy savings experienced by 11
customers but are not quantified or claimed as part of 12
Idaho Power’s annual savings. These efforts are designed to 13
reach all customer segments and are more fully explained 14
throughout the DSM 2022 Annual Report. In 2022, this 15
included activity such as: holding virtual and in-person 16
technical trainings and workshops with customers, producing 17
the Energy@Work and Irrigation newsletters, participating 18
in several different types of agricultural shows, hosting 19
or participating in vendor workshops promoting irrigation 20
system efficiency, publishing residential energy efficiency 21
guides which showcased behavioral changes to save energy, 22
attending other outreach activities such as home shows, and 23
supporting the Integrated Design Lab. 24
// 25
THOMPSON, DI 10
Idaho Power Company
Demand Response 1
Q. What level of capacity was available from 2
Idaho Power’s demand response programs in 2022? 3
A. The total available capacity of Idaho Power’s 4
three demand response programs (A/C Cool Credit, Flex Peak 5
Program, and Irrigation Peak Rewards) was approximately 312 6
megawatts (“MW”). This value represents the total enrolled 7
MW from participants adjusted for an expected maximum 8
realization rate. 9
Q. What level of non-coincident demand reduction 10
was provided? 11
A. The Company’s demand response programs 12
provided actual non-coincident demand reduction of 200 MW 13
during the 2022 program season. The 200 MW maximum load 14
reduction is less than 312 MW of total demand response 15
program capacity because the three demand response programs 16
are not always dispatched together during a single event 17
day and the four irrigation groups are also not always 18
dispatched coincidentally. Chart 2 below reflects the 19
annual available peak demand reduction capacity and actual 20
load reduction in MW since 2004 and the associated annual 21
expenses in millions of dollars. 22
// 23
// 24
// 25
THOMPSON, DI 11
Idaho Power Company
Chart 2. Peak Demand Reduction Capacity (MW) and Demand 1
Response Expenses ($ millions) 2004-2022 2
3
II. 2022 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 $31,585,110 of Rider funds and paid $8,311,328 in 9
demand response program incentives, for a total of 10
$39,896,437 spent on demand-side resource acquisition in 11
2022. Idaho Power requests that the 2022 Rider-funded DSM 12
expenses, and the 2022 demand response program incentives 13
recovered through base rates and tracked through the PCA, 14
be reviewed together for a prudence determination. Exhibit 15
No. 1 to my testimony, 2022 Idaho DSM Expenses and 16
Adjustments for Prudence Filing, shows a breakout of these 17
expenses by program, customer sector, and funding source. 18
THOMPSON, DI 12
Idaho Power Company
This year’s Rider-funded DSM expenses increased 1
$3,662,770, or 13 percent, compared to the DSM expenses 2
reviewed in last year’s prudence case, Case No. IPC-E-22-3
08. As described more fully above, the increase in 2022 4
expenses was primarily driven by an increase in large 5
projects participating in the C&I Program Custom Projects, 6
New Construction, and Retrofits options with total expenses 7
in those three options amounting to $16,301,141 or 8
$1,925,959 more compared to 2021. 9
Q. Please compare the dollar amounts in Exhibit 10
No. 1 to your testimony with Appendix 2, 2022 DSM expenses 11
by funding source (dollars), of the DSM 2022 Annual Report. 12
A. For clarity and ease of understanding, Exhibit 13
No. 1 ties to Appendix 2, which is found on page 186 of the 14
DSM 2022 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 $31,673,550. All values in Exhibit No. 1 19
represent DSM expenses for the Idaho service area only. 20
Three prior year-end and three current year-end accounting 21
adjustments were necessary to accurately arrive at the 22
total 2022 expenses for purposes of the prudence 23
determination. These six adjustments are listed in Exhibit 24
No. 1 under the Adjustments section as 2021 Commercial & 25
THOMPSON, DI 13
Idaho Power Company
Industrial, 2021 Residential New Construction, 2021 SBDI: 1
Small Business Direct Install (“SBDI”), 2022 Commercial & 2
Industrial Overhead, 2022 Residential Energy Efficiency 3
Education, and 2022 Residential Energy Efficiency Overhead. 4
Q. Please describe the prior year-end accounting 5
adjustments included in Exhibit No. 1. 6
A. The first adjustment of $1,044 was associated 7
with the Commercial & Industrial program where an expense 8
should have been charged to the Oregon Rider instead of the 9
Idaho Rider in 2021. The correction to reduce the Idaho 10
Rider was made in 2022, and therefore $1,044 needs to be 11
added back to avoid understating the 2022 prudence request. 12
The second adjustment of $1,356 is associated with 13
Idaho activity for the Residential New Construction Program 14
that was incorrectly charged to the Oregon Energy 15
Efficiency Rider in 2021. The correction adding the expense 16
to the Idaho Rider was made in 2022, and therefore $1,356 17
needs to be subtracted from the 2022 prudence request 18
because it was already deemed prudent by the Commission in 19
the 2021 request. 20
The final adjustment of $7,260 associated with SBDI 21
corrected a duplicate transaction. An amount of $7,260 of 22
Idaho SBDI expenses had originally been charged to the 23
Oregon Rider. When this was discovered in 2021, the Company 24
transferred the amount to the Idaho Rider, but the 25
THOMPSON, DI 14
Idaho Power Company
transaction was duplicated adding the amount twice. The 1
duplicate transaction was identified and reversed in 2022, 2
and therefore, $7,260 needs to be added back to avoid 3
understating the 2022 prudence request. 4
Q. Please describe the current year-end 5
accounting adjustments included in Exhibit No. 1. 6
A. Three accounting adjustments to the Rider for 7
2022 were identified through Idaho Power’s review of end of 8
year expenses and the corrections were made after the 2022 9
year-end financial books were closed. The first adjustment 10
results in a reduction of $6,998, which was related to 11
expenses associated with Commercial & Industrial Overheads 12
that should have been charged to O&M, rather than the Idaho 13
Rider. 14
The second adjustment requires inclusion of $1,289 15
associated with the Residential Energy Efficiency Education 16
that was initially charged to O&M instead of the Idaho 17
Rider. 18
Finally, a reduction of $89,680 was necessary to 19
remove a program administration fee the Company paid in 20
2022 that was refunded in 2023 due to services not being 21
rendered. 22
Q. What amount of Rider-funded employee DSM-23
related labor expense did the Company incur in 2022? 24
THOMPSON, DI 15
Idaho Power Company
A. The 2022 total Rider-funded DSM employee labor 1
expense incurred by the Company was $3,392,286. 2
Q. What amount of 2022 DSM-related labor is the 3
Company requesting be funded through the Rider? 4
A. The Company is requesting $3,381,085 in 2022 5
DSM labor expense be collected through the Rider. This 6
amount is appropriately recovered through the Rider as it 7
is equal to the Commission’s authorized labor cost cap 8
detailed in Order Nos. 348742 and 35270.3 The actual 2022 9
DSM labor expense was $11,201 over the cap as detailed in 10
Table 2 below. 11
Table 2. Labor Expense Calculation
2021 Total Actual Labor Expense $ 3,205,211
2021 FTEs* ÷ 23.34
2021 Actual Average Wage per FTE $ 137,334
2% Cap x 1.02
2022 Maximum Average Wage per FTE $ 140,081
2022 FTEs* x 24.14
2022 Maximum Allowed Labor Expense $ 3,381,085
2022 Total Actual Labor Expense - $ 3,392,286
Amount Over Maximum Allowed Labor Expense $ (11,201)
*23.34 and 24.14 are rounded values. 12
13
// 14
2 In the Matter of Idaho Power Company’s Application for a
Determination of 2019 Demand-Side Management Expenses as Prudently
Incurred, Case No. IPC-E-20-15, Order No. 34874, p. 5 (Dec. 18, 2020).
3 In the Matter of Idaho Power Company’s Application for a
Determination of 2020 Demand-Side Management Expenses as Prudently
Incurred, Case No. IPC-E-21-04, Order No. 35270, p. 9 (Dec. 27, 2021).
THOMPSON, DI 16
Idaho Power Company
Q. What was the year-end 2022 balance of the 1
Rider? 2
A. The Rider account balance on December 31, 3
2022, had a negative, or under-collected, balance of 4
$3,767,319 compared to an under-collected balance of 5
$6,937,705 on December 31, 2021. Table 3 below shows the 6
January 2022 beginning balance, funding plus accrued 7
interest, expenses, and the ending balance as of December 8
31, 2022. 9
Table 3. Idaho Energy Efficiency Rider (January-December 10
2022) 11
Idaho Energy Efficiency Rider
2022 Beginning Balance $ (6,937,705)
2022 Funding plus Accrued Interest as of 12/31/22 34,843,936
Total 2022 Funds 27,906,231
2022 Expenses as of 12/31/22 (31,673,550)
Ending Balance as of 12/31/22 $ (3,767,319)
12
III. 2022 COST-EFFECTIVENESS OVERVIEW 13
Q. What is Idaho Power’s overall goal when it 14
comes to DSM cost-effectiveness tests? 15
A. Idaho Power strives to ensure that DSM funds 16
collected from customers are utilized to support the 17
pursuit of cost-effective energy efficiency and demand 18
response programs, with the limited exception of certain 19
policy considerations. This goal is achieved by applying a 20
multi-step process. Prior to the actual implementation of 21
energy efficiency or demand response programs, Idaho Power 22
THOMPSON, DI 17
Idaho Power Company
performs a preliminary cost-effectiveness analysis to 1
assess whether a potential program design or measure will 2
be cost-effective from the perspective of customers as well 3
as the Company. Idaho Power measures cost-effectiveness 4
under three tests: the UCT, the TRC test, and the PCT. A 5
review of each test allows for an economic assessment of 6
the life-cycle costs and benefits of a DSM investment from 7
the perspective of DSM program participants, Idaho Power, 8
and non-participating customers. 9
Idaho Power also reviews the cost-effectiveness 10
results for each program and measure on an annual basis to 11
determine whether a program should continue or be modified 12
so it remains cost-effective on an ongoing basis. If a 13
measure or program is identified as non-cost-effective, 14
Idaho Power seeks EEAG input before making its 15
determination on modifying, continuing, or discontinuing an 16
offering. 17
The cost-effectiveness test methodologies and 18
assumptions are described in more detail in the first pages 19
of Supplement 1, included in Attachment 1 to the 20
Application in this proceeding. 21
Q. Does Idaho Power believe its application of 22
the standard economic tests is consistent with Commission 23
directives? 24
THOMPSON, DI 18
Idaho Power Company
A. Yes. Idaho Power believes its application of 1
the three economic tests is consistent with prior 2
Commission directives, as described in Order No. 33365:4 3
We thus find it reasonable for the Company to 4
continue screening potential programs using 5
each test as a guideline, and to advise us on 6
how the Company's programs fare under each 7
test. When the Company ultimately seeks to 8
recover its prudent investment in such 9
programs, however, we believe the Company may 10
(but need not exclusively) emphasize the UCT—11
and that test's focus on Company-controlled 12
benefits and costs—to argue whether the 13
programs were cost-effective. As always, the 14
Company ultimately must persuade us that its 15
program investments were prudent under the 16
totality of the circumstances. 17
18
Because Idaho Power must ultimately demonstrate to 19
the Commission that its program investments were prudent 20
under "the totality of the circumstances", the Company 21
continues to evaluate performance from the three 22
perspectives. 23
A. 2022 Cost-Effectiveness Results 24
Q. What were the results of the 2022 cost-25
effectiveness analyses? 26
A. Exhibit No. 2 to my testimony, 2022 Cost-27
Effectiveness Summary by Program, Sector, and Portfolio, 28
shows the results of the UCT, TRC test, and PCT for every 29
4 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 (Aug. 28,
2015).
THOMPSON, DI 19
Idaho Power Company
energy efficiency program aggregated by sector and for the 1
overall portfolio. As shown in Table 4, the overall DSM 2
Portfolio achieved benefit/cost ratios greater than 1.0 for 3
each of the three cost-effectiveness tests. All three of 4
the program sectors achieved benefit/cost ratios of greater 5
than or equal to 1.0 from the UCT and PCT perspectives with 6
the Residential Sector having a TRC less than 1.0. 7
Table 4. 2022 Benefit/Cost by Sector & Portfolio 8
Sector Utility Cost
Test (UCT)
Total
Resource Cost
(TRC) Test
Participant
Cost Test
(PCT)
Residential* 1.00 0.76 2.89
Commercial/Industrial 2.71 1.34 1.71
Irrigation 2.69 2.54 2.66
Portfolio* 2.02 1.43 2.01
*Does not include Weatherization Assistance for Qualified Customers Program
9
Q. Did the Company quantify the Residential 10
Sector and DSM Portfolio cost-effectiveness, including the 11
costs and benefits of the Weatherization Assistance for 12
Qualified Customers (“WAQC”) program? 13
A. Yes. Table 5 below shows the cost-14
effectiveness of the Residential Sector and the Overall DSM 15
Portfolio with and without the WAQC program included. 16
Table 5. Residential and Portfolio Cost-Effectiveness with 17
and without WAQC 18
Sector WAQC Not Included WAQC Included
UCT TRC PCT UCT TRC PCT
Residential 1.00 0.76 2.89 0.84 0.67 2.56
Portfolio 2.02 1.43 2.01 1.94 1.40 2.00
19
THOMPSON, DI 20
Idaho Power Company
While the WAQC program remains non-cost-effective 1
from an economic perspective, it provides real savings to 2
customers that would otherwise likely be unable to afford 3
to weatherize their homes and offers health and safety 4
benefits to customers in need that are not quantified 5
through the economic tests. 6
Q. What assumptions were utilized to calculate 7
the sector and portfolio cost-effectiveness for 2022? 8
A. Idaho Power relies on research conducted by 9
third parties to obtain savings and cost assumptions for 10
various measures. The Company fixes savings assumptions 11
when budgets and goals are established for the next 12
calendar year unless codes and standards change, or program 13
updates necessitate a need to use updated savings. The 14
remaining inputs are obtained from the Company’s IRP 15
planning process. Because the 2021 IRP was not acknowledged 16
at the time 2022 DSM program planning occurred, Idaho Power 17
used the avoided costs from the acknowledged 2019 Second 18
Amended IRP. 19
To calculate the sector cost-effectiveness, Idaho 20
Power includes the benefits and costs associated with 21
programs that produce quantifiable energy savings. The 22
portfolio cost-effectiveness is the sum of all energy 23
efficiency activities, including those that do not have 24
savings associated with them, such as overhead expenses. 25
THOMPSON, DI 21
Idaho Power Company
Q. What are the results of specific program cost-1
effectiveness? 2
A. As reflected in Exhibit No. 2 to my testimony, 3
2022 Cost-Effectiveness Summary by Program, Sector, and 4
Portfolio, on an individual program basis, 9 of the 17 5
energy efficiency programs offered in Idaho for which the 6
Company calculates cost-effectiveness had benefit/cost 7
ratios greater than 1.0 under the UCT. 8
The PCT ratios cannot be calculated for programs 9
that do not have a direct customer cost, and the PCT is 10
shown as “N/A” in Exhibit No. 2 for those programs. The 11
details of these calculations are found in Supplement 1 of 12
the DSM 2022 Annual Report. 13
Q. Did Idaho Power calculate cost-effectiveness 14
for each measure within each energy efficiency program it 15
offers? 16
A. Yes. In 2022, Idaho Power evaluated the 17
benefits and costs of 300 measures. The results of these 18
calculations, along with measure assumption details and 19
source documentation, can be found in Supplement 1 to the 20
DSM 2022 Annual Report. 21
Q. How did Idaho Power address any individual 22
measures that are not cost-effective based on one or more 23
tests? 24
THOMPSON, DI 22
Idaho Power Company
A. The cost and benefit values used in the 1
various analyses are based on markets, technologies, 2
economic inputs, savings estimates, and cost estimates, 3
which can change over time. When a measure is identified as 4
non-cost-effective at a specific point in time, Idaho Power 5
first evaluates whether the inputs used in the calculations 6
are still applicable. Then the Company determines if the 7
measure parameters should be modified or if the measure 8
should be eliminated altogether. For additional detail on 9
measure analysis, please refer to Supplement 1 to the DSM 10
2022 Annual Report. 11
B. Non-Cost-Effective Programs 12
1. Income Qualified Weatherization 13
Q. Please explain what drivers influence the 14
cost-effectiveness results for the WAQC and Weatherization 15
Solutions for Eligible Customers (“Solutions”) programs? 16
A. The WAQC and Solutions programs provide real 17
and substantial per home savings, but due to the costs of 18
comprehensive whole-house weatherization, it is difficult 19
for the value of the savings to outweigh the costs. The 20
weatherization services provided through the WAQC program 21
are consistent with the Idaho State Weatherization 22
Assistance Program guidelines, and both the WAQC and 23
Solutions programs are offered at no charge to the 24
participant. Please refer to pages 94 and 103 in the DSM 25
THOMPSON, DI 23
Idaho Power Company
2022 Annual Report for the savings, cost, and the number of 1
homes weatherized in 2022. 2
Q. Does Idaho Power plan to continue offering the 3
WAQC and Solutions programs in the future? 4
A. Yes. While the Company has identified that the 5
programs are not cost-effective under the UCT, unless the 6
Commission directs otherwise, Idaho Power will continue to 7
offer them to the Company’s limited-income customers on an 8
ongoing basis. The Company will also continue to consult 9
the EEAG and weatherization managers who oversee the 10
weatherization work to look for ways to improve outreach 11
and the cost-effectiveness of these programs as 12
opportunities are available. 13
2. Discontinued Programs in 2022 14
Q. Which programs did the Company discontinue in 15
2022? 16
A. The Company discontinued both the Energy House 17
Calls and Multifamily Energy Savings Programs on June 30, 18
2022 and December 31, 2022, respectively due to the 19
expectation that these programs will not be cost-effective 20
as currently structured going forward. After evaluating the 21
programs internally using Regional Technical Forum (“RTF”) 22
savings and 2021 IRP avoided costs, as well as 23
incorporating input from its EEAG, the Company determined 24
it was prudent to end the programs at this time. The 25
THOMPSON, DI 24
Idaho Power Company
Company will continue to evaluate potential program 1
structures with the objective of increasing the 2
availability of cost-effective offerings to customers with 3
manufactured homes and multifamily dwellings. The Company 4
discussed its plans for the programs at the February 2022, 5
May 2022, and August 2022 EEAG meetings. 6
3. Programs to be Discontinued in 2023 7
Q. Is the Company planning on discontinuing any 8
of its programs in 2023? 9
A. Yes. the Company is discontinuing both its 10
SBDI and Commercial Energy-Savings Kits (“CSKs”) Programs 11
in 2023 on March 31, 2023 and June 30, 2023 respectively. 12
The SBDI program had a defined time-period in which the 13
program was offered based on the contractual agreement with 14
the third-party vendor completing the work. All of the 15
program savings come from lighting measures, and the 16
program was originally intended to be offered for a limited 17
time from November 2019 to December 2022 (it was extended 18
to March 2023 due to delays caused by COVID-19). The 19
program was successfully utilized by customers throughout 20
the entirety of the Company’s service area. The Company 21
does not expect a renewed contract with the existing vendor 22
would result in a cost-effective program, and as a result, 23
it is not proposing to continue the offering at this time. 24
THOMPSON, DI 25
Idaho Power Company
The Company discussed its plans at the November 2022 and 1
February 2023 EEAG meetings. 2
The Company will also discontinue its CSKs in 2023. 3
Idaho Power discussed the cost-effectiveness challenges 4
facing the offering at the August 2021, November 2021, and 5
November 2022 EEAG meetings. In 2021, the RTF deactivated 6
the workbooks and zeroed out the savings for both pre-rinse 7
spray valves and advanced power strips. As a result, very 8
little differentiated the three CSK configurations for 9
restaurants, retail, and offices. Based on feedback from 10
EEAG at the November 2021 meeting, the Company began 11
offering a streamlined kit in 2022. 12
The savings for CSKs is largely based on the assumed 13
installation rates for each kit item. The 2022 evaluation 14
recommended the Company reconsider the inclusion of the 15
exit signs retrofit kits and the aerators due to low 16
install rates and the associated lower savings. The Company 17
had already reduced the number of exit sign retrofit kits 18
and aerators when designing the streamlined kit option but 19
did not remove them completely. Additionally, the 20
evaluators recommended the removal of the LED lightbulbs 21
from the kit. In June 2023, EISA lighting standards will 22
take effect, at which point certain lighting savings will 23
no longer be claimed by utility programs. The updated 24
standards have a significant impact on the CSKs, as the 25
THOMPSON, DI 26
Idaho Power Company
kits offer two different kinds of LED lightbulbs. Once the 1
LED bulbs are removed, the only items remaining in the kit 2
would be one-exit sign retrofit kit, one-kitchen aerator, 3
and one-bathroom aerator which already have low 4
installation rates. Also, the savings for the faucet 5
aerators are dependent on the commercial customer having 6
electric water heat. As a result, the Company has concluded 7
the CSKs will not be cost-effective going forward, leading 8
to its decision to end the CSK offering on June 30, 2023. 9
The Company discussed its plans at the February 2023 EEAG 10
meeting. 11
4. Home Energy Reports 12
Q. What were the cost-effectiveness results for 13
the Home Energy Reports program? 14
A. As shown in Exhibit No. 2, the Home Energy 15
Report program achieved a one-year UCT of 0.71 and a TRC of 16
0.79,5 which was an improvement from the 2021 one-year UCT 17
and TRC ratios of 0.57 and 0.62 respectively. The Company 18
also calculated a life cycle cost-effectiveness for the 19
program that results in a UCT of 1.17 and a TRC of 1.29. 20
The life cycle cost-effectiveness uses savings generated 21
through 2026. 22
5 UCT and TRC ratios include costs associated with the 2022 impact
evaluation. UCT would be 0.74 and TRC would be 0.81 without evaluation
expenses.
THOMPSON, DI 27
Idaho Power Company
Q. What are the Company’s plans regarding 1
continuation of the Home Energy Reports program? 2
A. The Company believes the program will be cost 3
effective in 2023 because of the additional capacity 4
benefits that are included in the 2021 IRP avoided costs 5
where this year’s cost-effectiveness was calculated using 6
the 2019 Second Amended IRP avoided costs. Additionally, 7
the evaluation results showed the overlap percentage used 8
to calculate savings to avoid double counting with similar 9
programs savings was less than initially thought. 10
Therefore, program savings had a realization rate over one 11
hundred percent as shown later in my testimony in the 12
Evaluation Section. 13
Q. What other factors will the Company consider 14
when evaluating the cost-effectiveness of the Home Energy 15
Reports program? 16
A. As I noted, the program is cost-effective when 17
evaluated over the life cycle of the program. Typically, 18
Idaho Power evaluates cost effectiveness based on the value 19
associated with incremental savings achieved in the program 20
year and savings expected through the duration of the 21
measure life. A behavioral program, like Home Energy 22
Reports, has a “measure life” of 1-year, however, it is 23
expected that savings will continue to accrue (at a 24
degraded level) for at least 2-years after the program 25
THOMPSON, DI 28
Idaho Power Company
concludes. Accordingly, Idaho Power will continue to 1
evaluate the appropriateness of reporting this program’s 2
cost-effectiveness on a life-cycle basis. 3
5. Heating and Cooling Efficiency Program 4
Q. What were the cost-effectiveness results for 5
the Heating and Cooling Efficiency program? 6
A. As shown in Exhibit No. 2, the Heating and 7
Cooling Efficiency Program achieved a UCT of 0.98 and a TRC 8
of 0.30. The program was just slightly under 1.0 from the 9
UCT prospective, which was primarily driven by the 10
evaluation costs the program absorbed associated with the 11
2021 impact and process evaluation that was completed in 12
2022. If the evaluation costs are removed, the UCT ratio 13
for the program would be 1.00. 14
Q. Does the Company anticipate seeking any 15
modifications to the program aimed at improving cost-16
effectiveness? 17
A. Yes. The Company anticipates making program 18
changes in 2023 that it expects will have a positive impact 19
on cost-effectiveness. These modifications may include 20
removal of some measures, modifications to adjust measures, 21
and incentive adjustments to measures. The Company will 22
consult with EEAG prior to making any future program 23
decisions. 24
// 25
THOMPSON, DI 29
Idaho Power Company
C. Demand Response Cost-Effectiveness 1
Q. Does Idaho Power evaluate cost-effectiveness 2
for its three demand response programs? 3
A. Yes. The methodology approved in Order No. 4
353366 is used to determine the cost-effectiveness of the 5
demand response (“DR”) programs and sets the maximum 6
avoided cost value. In accordance with the approved 7
methodology, the 2022 cost-effectiveness threshold for 8
demand response is $82.91 per kW year. 9
Q. How was the $82.91 determined? 10
A. Using the approved method, the avoided cost 11
calculation for the demand response programs is as follows: 12
(Levelized Fixed Costs – Additional Benefits) 13
x Effective Load Carrying Capacity (“ELCC”) of Annual 14
Demand Response Capacity Compared to Proxy Resource 15
= $ per kW year Demand Response Avoided Costs 16
Each of the three components have been updated and 17
are: 18
1. From the 2021 IRP, the 2022 levelized fixed 19
cost value of a Simple-Cycle Combustion Turbine (“SCCT”) 20
was determined to be $131.60 per kW per year. 21
2. From the 2021 IRP, to determine the 22
6 In the Matter of Idaho Power Company’s Application for Approval
to Modify its Demand Response Programs, Case No. IPC-E-21-32, Order No.
35336, p. 9-10 (Mar. 4, 2022).
THOMPSON, DI 30
Idaho Power Company
additional ancillary benefits provided by the SCCT compared 1
to DR, an analysis was performed where DR was replaced with 2
an equivalent SCCT and the fixed costs of the SCCT were 3
removed from the model. The result of this analysis showed 4
there were no additional benefits associated with the SCCT 5
because the cost of the fuel and SCCT plant O&M required to 6
meet the demand response demand. 7
3. The updated ELCC of approximately 312 MW of DR 8
capacity compared to a SCCT utilizing 2021 IRP assumptions 9
is 63 percent. 10
($131.60 - $0.00) * 63% = 11
$82.91 per kW year Demand Response Avoided Cost 12
Additional details of the methodology are included 13
in Supplement 1. 14
Q. What were the total and per kW costs of the 15
Company’s demand response programs? 16
A. In 2022, the system-wide cost of operating the 17
three demand response programs was approximately $9.9 18
million ($8.7 million of incentives and $1.2 million of 19
other costs). The amounts attributable to the Idaho-only 20
jurisdiction were $9.4 million ($8.3 million of incentives 21
and $1.1 million of other costs). Table 6 below shows the 22
actual 2022 dollar per kW year costs for each program and 23
the overall demand response portfolio. Idaho Power 24
estimated that if the three programs were dispatched for 25
THOMPSON, DI 31
Idaho Power Company
the full 60 hours allowed, the total costs would have been 1
approximately $12.0 million on a system-wide basis. 2
Table 6. Demand Response Program 2022 $ per kW year 3
Program $ per kW year
Residential A/C Cool Credit $30.99
C&I Flex Peak $23.34
Irrigation Peak Rewards $40.97
Total Demand Response Portfolio $38.42
4
Q. Were the demand response programs cost-5
effective? 6
A. Yes. All three of the Company’s demand 7
response programs, as well as the demand response 8
portfolio, had a cost per kW less than the 2022 threshold 9
of $82.91, meaning the programs were cost-effective. 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 utilizes evaluations conducted by 17
third-party contractors chosen through a competitive 18
bidding process. Idaho Power uses industry-standard 19
protocols, internal analyses, and regional and national 20
studies to inform its internal and external evaluation 21
efforts. The Company has generally conducted impact 22
evaluations every three years, and process evaluations for 23
THOMPSON, DI 32
Idaho Power Company
relatively new programs, or when a program has significant 1
changes. Supplement 2 to the DSM 2022 Annual Report 2
provides additional information regarding how Idaho Power 3
evaluates its programs. 4
Q. How does Idaho Power utilize the evaluations 5
described above? 6
A. Idaho Power uses the results of its 7
evaluations to inform decisions related to program 8
improvement, to compare processes to industry best 9
practices, and to benchmark and validate reported program 10
savings. 11
Q. What evaluation activities took place in 2022? 12
A. In addition to the annual cost-effectiveness 13
analyses that the Company conducts for each program, Idaho 14
Power contracted with several third-party evaluators to 15
conduct impact and process evaluations in 2022. Evaluations 16
conducted by these evaluators were on the following 17
programs: 18
Impact and process evaluations on Commercial 19
Energy-Savings Kits, C&I New Construction, and 20
C&I Retrofits programs. 21
Impact evaluation on Home Energy Reports. 22
In addition to these third-party evaluations, Idaho 23
Power completed internal analyses of the Irrigation Peak 24
THOMPSON, DI 33
Idaho Power Company
Rewards, Flex Peak, and A/C Cool Credit demand response 1
programs. 2
The impact evaluations that were conducted in 2022 3
analyzed reported savings from the 2021 program year. 4
Realization rates were as follows: 5
Commercial Energy-Savings Kits: 43.82 percent. 6
C&I New Construction Program: 102.5 percent. 7
C&I Retrofits Program: 96.4 percent. 8
Home Energy Reports: 109.65 percent. 9
The final reports for these evaluations, and the 10
market effects evaluations conducted by NEEA, are included 11
in Supplement 2 to the DSM 2022 Annual Report. 12
Q. Does Idaho Power have a DSM program evaluation 13
plan for 2023-2024? 14
A. Yes. The evaluation plan is included as 15
Exhibit No. 3 to my testimony and is also included in 16
Supplement 2 to the DSM 2022 Annual Report. In 2023, Idaho 17
Power’s evaluation plan includes the following third-party 18
evaluations: 19
Impact and process evaluations for Home Energy 20
Audit. 21
Impact evaluations for Residential New 22
Construction Program, Shade Tree Project, Small 23
Business Direct-Install, and Irrigation 24
Efficiency Rewards. 25
THOMPSON, DI 34
Idaho Power Company
Q. Has the Company completed the Commission’s 1
directive to complete an independent Evaluation, 2
Measurement, and Verification (“EM&V”) of NEEA savings? 3
A. In August 2022, the Company contracted with an 4
independent evaluator to verify the accuracy of NEEA 5
claimed savings, as directed by the Commission in Order No. 6
35720.7 In part, the scope of the evaluation includes 7
clarifying the savings NEEA claims, verifying the 8
allocation of savings to NEEA member utilities, and 9
determining the cost-effectiveness of the savings for the 10
member utilities based on the utilities’ DSM avoided cost. 11
Idaho Power reviewed an initial draft report in 12
February 2023 and has asked the evaluator to clarify 13
several items prior to finalizing the report. The Company 14
expects to receive the final report in the coming weeks and 15
will develop a plan of action based on the final 16
recommendations and findings identified in the report. 17
Because the report was not complete prior to the 18
preparation of this case, Idaho Power anticipates filing a 19
supplemental application by no later than the end of June 20
2023, where it will file the report with the Commission in 21
7 In the Matter of Idaho Power Company’s Application for a
Determination of 2020 Demand-Side Management Expenses as Prudently
Incurred, Case No. IPC-E-21-04, Order No. 35270, p. 9 (Dec. 27, 2021).
THOMPSON, DI 35
Idaho Power Company
this docket. At that time, Idaho Power will identify its 1
near-term plan associated with addressing any findings. 2
V. STAKEHOLDER INPUT 3
Q. What is the EEAG? 4
A. In 2002, Idaho Power formed the EEAG to 5
provide input on enhancing existing DSM programs, 6
recommending new energy efficiency measures, and 7
implementing energy efficiency programs. Members include 8
customer representatives from residential, irrigation, 9
commercial, and industrial sectors as well as technical 10
experts, representatives for limited-income individuals, 11
environmental organizations, state agencies, county and 12
city governments, the Commission, the Public Utility 13
Commission of Oregon, and Idaho Power. 14
Q. What is the structure of EEAG meetings? 15
A. The EEAG generally meets quarterly in-person 16
at Idaho Power’s corporate offices and through webinars as 17
needed. All EEAG meetings were held virtually in 2022, and 18
the Company believes the member participation and input 19
remained strong in the virtual format. 20
The agenda during EEAG meetings is varied, but 21
typically includes: program and project updates, new energy 22
efficiency program or measure proposals, marketing methods, 23
specific measure details including cost-effectiveness, the 24
status of energy efficiency expenses, and general 25
THOMPSON, DI 36
Idaho Power Company
information on DSM issues. When appropriate, the Company 1
invites experts to speak on evaluations, research, and 2
other topics of interest to enhance EEAG’s understanding. 3
Q. How did Idaho Power solicit guidance from the 4
EEAG during the 2022 program year? 5
A. In 2022, the Company held four virtual EEAG 6
meetings, and during these meetings, Idaho Power discussed 7
and requested recommendations on a broad range of DSM 8
issues. As explained in greater detail in the DSM 2022 9
Annual Report, the list below includes some of the topics 10
Idaho Power worked with the EEAG on for development, 11
design, promotion, or input: 12
Energy Efficient Lighting: The Company will 13
continue offering the Lighting Buydown Program 14
through June 30, 2023. After that date, the 15
Department of Energy OE will begin enforcing 16
federal EISA lighting standards with financial 17
penalties to those retailers that continue to 18
sell inefficient lightbulbs. This allows the 19
Company and customers to realize lighting savings 20
as long as possible. 21
Heating & Cooling Efficiency: Idaho Power began 22
offering two new measures through the program on 23
July 1, 2022 that provide a cash incentive to 24
customers who install a central A/C or a ground 25
THOMPSON, DI 37
Idaho Power Company
source heat pump. The incentives apply to both 1
existing homes and new construction. 2
Welcome Kits: Idaho Power continued to contract 3
with a third-party vendor to distribute energy 4
efficiency kits to the company’s first-time 5
customers. With EEAG collaboration, the kit 6
contents were adjusted to improve cost-7
effectiveness. 8
VI. CONCLUSION 9
Q. Do you believe that the information contained 10
in this testimony and attached exhibits supports a prudence 11
determination for 2022 DSM expenses? 12
A. Yes. The DSM 2022 Annual Report details Idaho 13
Power’s DSM offerings in program specific sections. Based 14
on the DSM 2022 Annual Report, the testimony set forth 15
above, and the attached exhibits, Idaho Power respectfully 16
requests the Commission determine that $39,896,437 was 17
prudently incurred for the acquisition of demand-side 18
resources in 2022. 19
Q. Does this conclude your testimony? 20
A. Yes, it does. 21
THOMPSON, DI 38
Idaho Power Company
ATTESTATION OF TESTIMONY 1
2
STATE OF IDAHO ) 3
) ss. 4
County of Ada ) 5
6
I, Robert Z. Thompson, having been duly sworn to 7
testify truthfully, and based upon my personal knowledge, 8
state the following: 9
I am employed by Idaho Power Company as a Regulatory 10
Analyst in the Regulatory Affairs Department and am 11
competent to be a witness in this proceeding. 12
I declare under penalty of perjury of the laws of 13
the state of Idaho that the foregoing pre-filed testimony 14
and exhibits are true and correct to the best of my 15
information and belief. 16
DATED this 15th day of March 2023. 17
18
19
Robert Z. Thompson 20
21
SUBSCRIBED AND SWORN to before me this 15th day of 22
March 2023. 23
24
25
Notary Public for Idaho 26
Residing at Ada County Idaho 27
My commission expires: 09/10/2026 28
29
30
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-10
IDAHO POWER COMPANY
THOMPSON, DI
TESTIMONY
EXHIBIT NO. 1
Expenses Rider Expenses
Demand Response
Program Incentives
Recorded in PCA Total Expenses
Energy Efficiency/Demand Response
Residential
A/C Cool Credit 429,722$ 375,320$ 805,042$
Easy Savings: Low-Income Energy Efficiency Education - - -
Educational Distributions 1,061,898 - 1,061,898
Energy Efficient Lighting 505,430 - 505,430
Energy House Calls 36,734 - 36,734
Heating & Cooling Efficiency Program 636,597 - 636,597
Home Energy Reports 964,709 - 964,709
Home Energy Audit 184,650 - 184,650
Multifamily Energy Savings Program 32,634 - 32,634
Rebate Advantage 157,746 - 157,746
Residential New Construction 236,962 - 236,962
Shade Tree Project 128,673 - 128,673
Weatherization Solutions for Eligible Customers 198,198 - 198,198
Commercial/Industrial
Custom Projects 8,753,084 - 8,753,084
New Construction 2,762,412 - 2,762,412
Retrofits 4,785,645 - 4,785,645
Commercial Energy-Saving Kits 21,604 - 21,604
FlexPeak Program 84,582 283,651 368,233
Small Business Direct Install 1,317,820 - 1,317,820
Irrigation
Irrigation Efficiency 1,950,122 - 1,950,122
Irrigation Peak Rewards 569,467 7,652,357 8,221,825
Energy Efficiency/Demand Response Total 24,818,689$ 8,311,328$ 33,130,017$
Market Transformation
NEEA 2,650,440 - 2,650,440
Market Transformation Total 2,650,440$ -$ 2,650,440$
Other Programs and Activities
Commercial/Industrial Energy Efficiency Overhead 826,911 - 826,911
Energy Efficiency Direct Program Overhead 296,204 - 296,204
Residential Energy Efficiency Education Initiative 287,839 - 287,839
Residential Energy Efficiency Overhead 1,528,355 - 1,528,355
Other Programs and Activities Total 2,939,309$ -$ 2,939,309$
Indirect Program Expenses
Energy Efficiency Accounting & Analysis 1,236,470 - 1,236,470
Energy Efficiency Advisory Group 15,575 - 15,575
Special Accounting Entries
Special Accounting Entries 13,068 - 13,068
Indirect Program Expenses Total 1,265,112$ -$ 1,265,112$
Total Expenses 31,673,550$ 8,311,328$ 39,984,878$
Adjustments
Prior year-end accounting adjustments:
2021 Commercial & Industrial (a)1,044 1,044
2021 Residential New Construction (b)(1,356) (1,356)
2021 SBDI: Small Business Direct Install (c)7,260 7,260
Current year-end accounting adjustments:
2022 Commercial & Industrial Overhead (d)(6,998) (6,998)
2022 Residential Energy Efficiency Education (e)1,289 1,289
2022 Residential Energy Efficiency Overhead (f)(89,680) (89,680)
2022 Prudence Filing Total 31,585,110$ 8,311,328$ 39,896,437$
(a) 2021 Oregon Rider expense that was initially charged to the Idaho Rider. The correction was made in 2022.
(b) 2021 Idaho Rider expense initially charged to the Oregon Rider. The correction was made in 2022.
(c) Duplicate 2021 Idaho Rider transaction. The correction was made in 2022.(d) 2022 O&M expense initially charged to the Idaho RIder. The correction was made in 2023.
(e) 2022 Idaho Rider expense initially charged to O&M. The correction was made in 2023.(f) Program administration fee charged to the Idaho Rider in 2022 and refunded in 2023.
Idaho Power Company
2022 Idaho DSM Expenses and Adjustments for Prudence Filing
Exhibit No. 1
Case No. IPC-E-23-10
R.Z. Thompson, IPC
Page 1 of 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-10
IDAHO POWER COMPANY
THOMPSON, DI
TESTIMONY
EXHIBIT NO. 2
Program/Sector
Utility Cost Test
(UCT)
Total Resource
Cost (TRC)
Participant Cost
(PCT)
Educational Distributions 1.31 1.62 N/A
Energy Efficient Lighting 1.68 1.52 4.35
Energy House Calls1 0.70 0.77 N/A
Heating & Cooling Efficiency Program 0.98 0.30 0.76
Home Energy Reports2 0.71 0.79 N/A
Multifamily Energy Savings Program3 0.49 0.68 N/A
Rebate Advantage 1.18 0.54 1.56
Residential New Construction 1.45 0.84 1.70
Shade Tree Project 1.02 1.21 N/A
Weatherization Assistance for Qualified Customers 0.17 0.32 N/A
Weatherization Solutions for Eligible Customers 0.15 0.23 N/A
Residential Energy Efficiency Sector4 1.00 0.76 2.89
Commercial and Industrial Energy Efficiency Program
Custom Projects 2.88 1.12 1.17
New Construction 4.25 3.64 5.41
Retrofits 2.01 1.11 1.61
Commercial Energy-Savings Kits 0.78 0.87 N/A
Small Business Direct Install 0.95 1.50 N/A
Commercial/Industrial Energy Efficiency Sector5 2.71 1.34 1.71
Irrigation Efficiency 2.69 2.54 2.66
Irrigation Energy Efficiency Sector6 2.69 2.54 2.66
Energy Efficiency Portfolio7 2.02 1.43 2.01
1 Program closed June 30, 2022
2 Cost-effectiveness based on 2022 savings and expenses. Cost-effectiveness ratios are also calculated for the program life-cycle and are 1.17 and 1.29 for the UCT and TRC respectively.
3 Program closed December 31, 2022
4 Residential sector cost-effectiveness excludes WAQC benefits and costs. If included, the UCT, TRC, and PCT would be 0.84, 0.67, and 2.56 respectively.
5 Commercial/Industrial Energy Efficiency Sector cost-effectiveness ratios include savings and participant costs from Green Motors Rewinds.
6 Irrigation Energy Efficiency Sector cost-effectiveness ratios include savings and participant costs from Green Motors Rewinds.
7 Portfolio cost-effectiveness excludes WAQC benefits and costs. If included, the UCT, TRC, and PCT would be 1.94 , 1.40, and 2.00 respectively.
2022 Cost-Effectiveness Summary by Program, Sector, and Portfolio
2022 Benefit/Cost Tests
Exhibit No. 2
Case No. IPC-E-23-10
R.Z. Thompson, IPC
Page 1 of 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-10
IDAHO POWER COMPANY
THOMPSON, DI
TESTIMONY
EXHIBIT NO. 3
2023 2022 2021 2020 2019 2018 2017 2016 2015 1 2014 2013 2012 2011 2010
Educational Distributions I/P
Energy Efficient Lighting
Energy House Calls I/P I P
Heating & Cooling Efficiency Program I/P I/P P I P
Home Energy Audit I/P I P
Home Energy Reports I P
Multifamily Energy Savings Program I/P I/P
Rebate Advantage I I/P I
Residential New Construction Pilot Program I I/P
Shade Tree Project I O P
Weatherization Assistance for Qualified Customers O O O P I
Weatherization Solutions for Eligible Customers O O O P I
Commercial Energy-Saving Kits I/P
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 I P
Irrigation Efficiency Rewards I I/P I/P P/O I/P P
A/C Cool Credit O O I O I O O I I I O P O
Flex Peak Program O O I/O O O O O I/O I/O P/O O
Irrigation Peak Rewards O O I/O O O O O O I/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 2022-2023 Program Evaluation Plan
Exhibit No. 3
Case No. IPC-E-23-10
R.Z. Thompson, IPC
Page 1 of 1