20230714Exhibit 6 - NEEA EM&V Report Addendum.pdf

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-10

IDAHO POWER COMPANY

DRAKE, DI
TESTIMONY

EXHIBIT NO. 6

ADM Associates, Inc
3239 Ramos Circle
Sacramento, CA 95827
916-363-8383
Avista Utilities
1411 E Mission Ave
Spokane, WA 99202

SUBMITTED TO: IDAHO POWER COMPANY &
AVISTA UTILITIES
SUBMITTED ON: JUNE 15, 2023
SUBMITTED BY: ADM ASSOCIATES, INC.
Addendum: Evaluation of NEEA
Impacts Allocated to Idaho Power
Company and Avista Utilities
Within the State of Idaho

Idaho Power Company
1221 W Idaho St
Boise, ID 83702

Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
Page 1 of 16

Addendum ii
Table of Contents
1. Response to NEEA’s Feedback ............................................................................................................. 4
1.1 Summary ..................................................................................................................................................... 4
1.2 Recommendation #5 .................................................................................................................................. 4
1.3 Recommendation #6 .................................................................................................................................. 6
1.4 Recommendation #8 .................................................................................................................................. 8
1.5 Recommendation #9 ................................................................................................................................ 11
1.6 Overall Conclusions .................................................................................................................................. 12

Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
Page 2 of 16

admenergy.com | 3239 Ramos Circle, Sacramento, CA 95827| 916.363.8383 iii
List of Tables
Table 1-1: NEEA Response to Recommendation #5 ..................................................................................... 5
Table 1-2: NEEA Response to Recommendation #5 Examples ..................................................................... 5
Table 1-3: NEEA Response to Recommendation #6 ..................................................................................... 7
Table 1-4: NEEA Response to Recommendation #6 Examples ..................................................................... 8
Table 1-5: NEEA Response to Recommendation #8 ..................................................................................... 9
Table 1-6: NEEA Response to Recommendation #8 Examples ................................................................... 10
Table 1-7: NEEA Response to Recommendation #9 ................................................................................... 11
Table 1-8: Revised Findings and Recommendations .................................................................................. 12

Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
Page 3 of 16

Addendum 4
1. Response to NEEA’s Feedback
ADM Associates (herein referred to as the “Evaluators”) developed a report summarizing the
evaluation, measurement, and verification (EM&V) of the Northwest Energy Efficiency Alliance (NEEA)
activities and energy impact estimates as it relates to savings allocated to Idaho Power Company (IPC)
and Avista Utilities (Avista) within the state of Idaho for the program years 2017-2021.
NEEA’s executive team reviewed the evaluation findings and recommendations and submitted a
response to IPC and Avista. ADM reviewed NEEA’s response and is supplying this addendum to
recharacterize language previously provided in the evaluation report and to clarify final conclusions
and recommendations resulting from this evaluation.
1.1 Summary
Upon review of the evaluation report, NEEA provided responses to conclusions and recommendations
from the evaluation work summarized above. In this addendum, the Evaluators elaborate on the
following recommendations:
◼ Recommendation #5: The Evaluators recommend that measure-level values are detailed as
accurately as possible, and that each field is completed in the workbook to allow for year-over-
year tracking of regional units, baseline units, retirement units, and unit energy savings values
over time. (Based on Finding #3 and Finding #10)
◼ Recommendation #6: The Evaluators recommend that NEEA distribute naturally occurring
baseline units more equitably between local program units and total regional units. (Based on
Finding #11)
◼ Recommendation #8: The Evaluators recommend that third-party evaluations are completed for
the federal standards claimed by NEEA, as well as any federal standards in which NEEA hopes to
claim savings for in the future. Using the quantitative estimate of NEEA influence, the Evaluators
recommend that NEEA calculate a naturally occurring baseline for each standard. (Based on
Finding #15)
◼ Recommendation #9: The Evaluators recommend an evaluation is completed for each code
update to estimate NEEA’s qualitative and quantitative influence towards the code update.
(Based on Finding #17)
The Evaluators outline the revised recommendations in the sections below.
1.2 Recommendation #5
The Evaluators summarize the Evaluators’ findings and recommendations, NEEA responses, and the
Evaluator’s summarizing response for Recommendation #5.
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
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Addendum 5

Table 1-1: NEEA Response to Recommendation #5
Finding
◼ Finding #3: The Evaluators found that the methodology in which savings were
estimated across measures was inconsistent. For some measures, service territory
methodology was used, and for others, funder share allocation methodology was
used.
◼ Finding #10: The database review revealed that a variety of fields (measure life,
UES) were empty across measure types due to lack of savings claimed for the
measure, which made verification of values difficult and complicates tracking of a
measure progress over time.
Recommendation
◼ Recommendation #5: The Evaluators recommend that measure-level values are
detailed as accurately as possible, and that each field is completed in the workbook
to allow for year-over-year tracking of regional units, baseline units, retirement
units, and unit energy savings values over time.
NEEA Response
◼ In the savings workbook provided annually to each funder, NEEA already enters all
data fields for active programs and measures within each program for which we are
reporting savings. NEEA references all the data sources in the workbook.

1.2.1 Evaluator Examples
In response to NEEA feedback, the Evaluators provided examples of incomplete and inconsistent data
provided in NEEA’s annual reports delivered Idaho Power Company and Avista Utilities between the 2017
and 2021 program years. The table below summarizes the Evaluator’s examples as well as NEEA’s
response to said examples.
Table 1-2: NEEA Response to Recommendation #5 Examples
Evaluator
Examples
◼ The inconsistency in allocation method within a single program year is observed in
the Avista 2017 and 2018 workbooks. In both years, most measures displayed
service territory share, but a handful showed funder share allocation. Although we
see that this practice does not continue into more recent years (2019-2021), we
note that this should be an area to consider in quality assurance and quality
control.
NEEA Response
◼ NEEA allocates the savings using the most disaggregated data available. The data
sources can range from service-territory level to regional. When NEEA only has
regional data, the reports allocate the savings using funding shares.
◼ Of the 30 observations provided, only 4 of the measures (13%) had savings. The
savings for these measures amounted to approximately 1% of the Net Market
Effects. In all four cases, NEEA did not have data/analysis available that would have
provided a more accurate estimate of the service territory allocation.
◼ NEEA provides all detailed data annually as called out in recommendation #5. The
only missing data, as finding #10 states, were fields intentionally left empty due to
NEEA not reporting savings for that measure.

Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
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Addendum 6

1.2.2 Recommendation #5 Summary
The Evaluators provide the following feedback to NEEA’s response summarized above.
◼ The Evaluators understand that measure-level values are dependent on resolution of data
available to NEEA. To the fullest extent possible, the Evaluators recommend NEEA weigh
regional savings most aligned with funder-selected methodology. Therefore, although the
approved service territory share methodology is not entirely feasible with the data available, the
results in some way consider the allocation methodology perspective when summarizing results.
◼ In addition, the Evaluators recommend that for any measures NEEA currently does not claim
savings, these measure line items are removed from funder annual reports. This will ensure that
funders only receive complete and verified reports.

1.3 Recommendation #6
The Evaluators summarize the Evaluators’ findings and recommendations, NEEA responses, and the
Evaluator’s summarizing response for Recommendation #6.
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
Page 6 of 16

Addendum 7

Table 1-3: NEEA Response to Recommendation #6
Finding
◼ Finding #11: The database review revealed that NEEA’s current method for
distribution of modeled naturally occurring baseline units between local program
and NEEA efforts is not reasonable. A portion of energy-efficient technology sales
are due to naturally occurring baseline. NEEA nets out modeled naturally occurring
baseline to avoid claiming savings for units that would have been sold had no
program or NEEA-effort been provided within the market. However, the method in
which these baseline units are netted out is not distributed equitably. For some
measures, NEEA estimates that a large proportion of local program units are
baseline, and therefore a larger proportion of the remaining net market effects is
assigned to NEEA efforts. The Evaluators raise concern for this assumption, as it is
unlikely locally incentivized, rebated measures display the same free ridership as
non-incentivized measures in the region.
Recommendation
◼ Recommendation #6: The Evaluators recommend that NEEA distribute naturally
occurring baseline units more equitably between local program units and total
regional units.
NEEA Response
◼ NEEA disagrees with ADM’s assertion that the distribution method of baseline units
NEEA uses is not reasonable or equitable. A foundational principle of NEEA, as an
alliance, is that local programs support market adoption and are therefore a part of
the market transformation taking place. NEEA’s baseline market share estimate
represents the adoption that would have occurred without the intervention of
NEEA or its funders’ local programs, so NEEA’s approach assumes that a portion of
the baseline market share applies to the local incentive units.
◼ Regarding the question of equitability, NEEA does not assign savings to NEEA
efforts separately from funder programs; rather, it measures the full market
transformation savings from our collective efforts (Co-created Savings) and reports
that to funders. To help our funders avoid double-counting, in our savings reports
we net out local program savings. The remaining savings, called net market effects
savings are not representative of distinct NEEA efforts, nor do they reflect
attribution.

1.3.1 Evaluator Examples
The distribution of local program baseline units refers to the value characterized in the annual reports as
“retirement units replaced by local programs.” In response to NEEA feedback, the Evaluators provided
examples of retirement units in which local programs were over decremented, referring to line items
provided in Idaho Power Company and Avista Utilities annual reports. The table below summarizes the
Evaluator’s examples as well as NEEA’s response to said examples.
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
Page 7 of 16

Addendum 8

Table 1-4: NEEA Response to Recommendation #6 Examples
Evaluator
Examples
◼ The Evaluators found that the retirement units for some measures were distributed
entirely to local programs, rather than total regional units. Therefore, a large
portion of local program units were nullified. Although this does not affect the
aggregate total net market units for the measure, it underestimates the proportion
of total net market units that the local program units account for. We provided
examples referencing the 2021 annual report for Idaho Power for the clothes
washers, clothes dryers, and refrigerators.
NEEA Response
◼ In the examples provided, the "retirement units replaced by local programs" is the
estimate of local program units allocated to Baseline.
◼ The share of the local program units allocated to baseline looks high because the
report does not show the market shares.
◼ NEEA provided to the Evaluators back-end calculations portraying how baseline
units are calculated for each measure.

1.3.2 Recommendation #6 Summary
The Evaluators provide the following feedback to NEEA’s response summarized above.
◼ In reviewing the example NEEA provided for calculating total regional unit baseline and local
program unit baseline units, the Evaluators rescind our Recommendation #6. NEEA currently
integrates a method for distributing retirement units replaced by local programs proportional to
estimated market baseline.

1.4 Recommendation #8
The Evaluators summarize the Evaluators’ findings and recommendations, NEEA responses, and the
Evaluator’s summarizing response for Recommendation #8.
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
Page 8 of 16

Addendum 9

Table 1-5: NEEA Response to Recommendation #8
Finding
◼ Finding #15: NEEA contracts third-party evaluators to conduct “influence
evaluations” for each standard, which summarizes NEEA’s overall qualitative and
quantitative influence towards federal standards updates. NEEA uses the
quantitative assessment as an estimate of federal standards naturally occurring
baseline. The Evaluators found that some of these influence scores were not
integrated properly to estimate baseline units. The Evaluators also found more
than half (13 of 25) federal standard measures lack influence evaluations.
Recommendation
◼ Recommendation #8: The Evaluators recommend that third-party evaluations are
completed for the federal standards claimed by NEEA, as well as any federal
standards in which NEEA hopes to claim savings for in the future. Using the
quantitative estimate of NEEA influence, the Evaluators recommend that NEEA
calculate a naturally occurring baseline for each standard.
NEEA Response
◼ NEEA does not agree with these two assertions: that influence scores were not
integrated properly and that reported energy savings lacked evaluations. The
variance was either due to rounding or a reduction of the percentage based on
NEEA’s participation (Fluorescent Lamp Ballasts).
◼ There is one case (Pumps) where the assumptions contained a preliminary value
and is to be updated based on the final evaluation value1.
◼ In cases where NEEA reported co-created energy savings and ADM is stating no
evaluation was conducted, they are mistaken. NEEA reviewed all appliance
standards for which we claimed co-created savings and confirmed evaluations are
available in each instance.

1.4.1 Evaluator Examples
In response to NEEA feedback, the Evaluators provided examples of the 13 federal standards update
savings claimed by NEEA in which no influence evaluations were conducted. The table below
summarizes the Evaluator’s examples as well as NEEA’s response to said examples.

1 NEEA does not request any revisions or comment regarding this statement.
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
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Addendum 10

Table 1-6: NEEA Response to Recommendation #8 Examples
Evaluator
Examples
◼ The Evaluators found that the following standards were claiming savings, but
lacked influence evaluation documentation, both in requested information during
the evaluation, and during independent research to locate an influence evaluation:
o Battery standards in Oregon
o Commercial HPWH (Existing)
o Commercial HPWH (New construction)
o Residential AC
o Clothes Dryers
o Residential Heat Pumps
o Nonresidential ceiling fans
o Nonresidential ceiling fan kits
NEEA Response
◼ For the following measures, NEEA provided program-level evaluation reports
completed by third party evaluators:
o Battery standards in Oregon2
o Commercial HPWH (Existing) 3
o Commercial HPWH (New construction)4
◼ For the following measures, no influence evaluation was conducted. NEEA never
reported Net Market Effects from these standards. The measures are listed in the
Table View of the Savings reports because they were part of NEEA's database for
other reporting purposes. The Table View of the report is meant to be a database
view of the savings reported on the individual tabs.
o Residential AC
o Clothes Dryers
o Residential Heat Pumps
o Nonresidential ceiling fans
o Nonresidential ceiling fan kits
o Residential ceiling fan light kits

1.4.2 Recommendation #8 Summary
The Evaluators provide the following feedback to NEEA’s response summarized above.
◼ In reviewing the document provided for the battery standards in Oregon, the Evaluators found
that the program evaluation documentation does not sufficiently estimate NEEA influence
towards the standard. The influence evaluations completed for other standards provide clear
objectives and conclusions towards NEEA proportional influence towards quantitative savings.
Although the document provided in replacement of a battery standards influence evaluation
provides verification for estimating energy savings in Oregon overall, the report does not
provide a clear quantitative estimate for NEEA influence towards the standard update.
◼ NEEA confirmed that the Evaluators used the correct influence percentage (24%) for the Pumps
standard.
◼ In reviewing the document provided for the commercial heat pump water heater standard for
existing and new construction facilities, the Evaluators again found that the program evaluation

2 https://neea.org/img/uploads/long-term-monitoring-and-tracking-report-on-2011-activities.pdf
3 https://neea.org/img/documents/Heat-Pump-Water-Heater-Benefit-Cost-Model-Review.pdf
4 Ibid.
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
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Addendum 11

documentation does not sufficiently estimate NEEA influence towards the standard. The
influence evaluations completed for other standards provide clear objectives and conclusions
towards NEEA quantitative and proportional influence towards quantitative savings. However,
the documents provided in replacement of an influence evaluation for these standards does not
estimate or conclude a clear influence value towards NEEA efforts.
◼ In reviewing the remaining measures (residential AC, clothes dryers, residential heat pumps,
nonresidential ceiling fans, nonresidential ceiling fan kits, and residential ceiling fan kits), the
Evaluators recognize that savings claimed for these standards are negligible (demonstrating
1.9E-17 aMW savings in total). Therefore, the Evaluators rescind our conclusion for completing
influence evaluations for these standards in which no measurable savings are claimed.
1.5 Recommendation #9
The Evaluators summarize the Evaluators’ findings and recommendations, NEEA responses, and the
Evaluator’s summarizing response for Recommendation #9.
Table 1-7: NEEA Response to Recommendation #9
Finding
◼ Finding #17: Currently, NEEA does not complete third-party evaluations of NEEA
“influence” towards codes updates as is currently done for federal standards
updates. Therefore, NEEA currently claims 100% savings for code-built homes. As
summarized in the standards influence evaluations summarized in Table 3-35, NEEA
influence towards standards ranges between 2.6% and 61%. If codes are evaluated
similarly, and portray a similar range of influence, NEEA code savings could be
significantly overrepresenting savings. NEEA’s current policy is to report 100% of
code-built residential and commercial building savings (while integrating
compliance rates) for 10 years after the effective code update date. Currently,
NEEA does not maintain a model to estimate naturally occurring baseline over time,
as it does for its energy efficiency measures. Essentially, the current NEEA
methodology assumes that there would be a 10-year lag in current residential and
commercial building code if NEEA did not participate in code update efforts.
Recommendation
◼ Recommendation #9: The Evaluators recommend an evaluation is completed for
each code update to estimate NEEA’s qualitative and quantitative influence
towards the code update.
NEEA Response
◼ NEEA already conducts third-party evaluation of its energy codes work. Since the
current influence approach’s application to reported energy savings was
recommended by CEAC, any changes would need to be discussed by that
committee. Possible implementation in 2025 with cost implications to be
determined.
◼ As outlined in Finding #17, NEEA’s significant influence in the state building energy
code process is distinct from federal appliance standards and therefore we would
like to understand ADM’s basis for this recommendation before suggesting any
changes to process or reporting. If there were a change, their most likely would be
cost implications to NEEA.

1.5.1 Evaluator Examples
Additional examples were not provided to NEEA for this recommendation.
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
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Addendum 12

1.5.2 Recommendation #9 Summary
The Evaluators did not provide to NEEA specific examples towards Recommendation #9. Instead, the
Evaluators provide the following feedback.
◼ The Evaluators understand that NEEA’s current policy effectively claims savings for 1/3 of the
code life cycle by claiming 10 years of savings rather than 30 years of savings. Therefore, there
does exist some form of baseline integration to the savings claimed for codes. However, the
Evaluators note that NEEA’s 100% savings for 10 years policy arose from a decision made by the
Cost Effectiveness Advisory Group (CEAC) nearly 25 years ago. It is unclear whether this
assumption or policy has been reassessed since its original decision over two decades ago. Since
then, a framework for quantitatively estimating NEEA’s influence has been solidified for
standards. It is of the Evaluator’s view that a similar framework can be developed for
quantitatively estimating NEEA’s influence towards code updates. The Evaluators recommend
NEEA’s 100% savings claimed for 10 years policy is revisited by CEAC and further methods for
estimating NEEA influence and market baseline is explored when claiming code savings in future
program years.

1.6 Overall Conclusions
The Evaluators took into consideration NEEA’s responses and associated documents in order to provide
revised findings and recommendations for the evaluation, measurement, and verification (EM&V) effort
of the Northwest Energy Efficiency Alliance (NEEA) activities and energy impact estimates as it relates to
savings allocated to Idaho Power Company (IPC) and Avista Utilities (Avista) within the state of Idaho for
the program years 2017-2021. The findings and recommendations presented in the section below
provide the most up-to-date conclusions for this evaluation work.
1.6.1 Revised Findings and Recommendations
The Evaluators provide a summary of the revised findings and recommendations to the evaluation
report, based on additional feedback from NEEA.
Table 1-8: Revised Findings and Recommendations
Findings Recommendations
Finding #1: Utilities that fund NEEA can choose whether
savings are reported by allocation share methodology or
service territory methodology. The allocation share
methodology overrepresents out-of-state and out-of-
service territory savings across measures, codes, and
standards while simultaneously underrepresenting in-
state and in-service-territory savings across measures,
codes, and standards. However, the service territory
methodology accurately represents benefits directed to
Avista and Idaho Power customers within the state of
Idaho.
Recommendation #1: The Evaluators recommend
Avista and Idaho Power request NEEA to report
annual savings via the service territory methodology
for each measure claimed by NEEA for each Idaho
Power electric, Avista electric, and Avista gas.
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
Page 12 of 16

Addendum 13

Finding #2: The data NEEA utilizes to estimate net market
savings is available at resolutions that allow NEEA to
estimate precise savings for each utility service territory.
Finding #3: The Evaluators found that the methodology in
which savings were estimated across measures were
inconsistent. For some measures, service territory
methodology was used, and for others, funder share
allocation methodology was used.
Finding #4: NEEA prioritizes cost-effective savings in terms
of regional benefit. Therefore, savings and cost-
effectiveness are distributed across the region evenly,
despite observed distribution of savings across states.
Although this philosophy has merit, more precise
estimates of utility-level and program-level savings help
NEEA’s stakeholders relay relevant savings and cost-
effectiveness results to their respective regulatory
commissions. This remains critical, due to some state-level
commission orders to pursue all cost-effective energy
efficiency efforts.
Recommendation #2: The Evaluators recommend
that Avista and Idaho Power request annual savings
reports to include estimates of administrative costs,
incentive costs, and non-incentive costs by service
territory. This will allow each utility to calculate
more accurate cost-effectiveness tests for each
initiative to determine whether extension of
funding is a viable option within each utility’s
regulatory environment.
Finding #5: The interviews revealed that although the
three parties fundamentally want to improve energy
efficiency and increase market adoption of emerging
technologies, their preferred approaches to this shared
goal vary. Unlike the utilities, who strive to demonstrate
the cost-effectiveness of their initiatives and investments
on an annual or bi-annual cycle, NEEA operates on a five-
year funding cycle, which is different than the typical
annual or biannual utility planning cycle.
Recommendation #3: The Evaluators recommend
that NEEA work with utilities to accurately produce
service territory-level savings and to best serve each
state’s current regulatory environment and utility’s
localized concerns.
Finding #6: NEEA’s programs are designed with a broader
constituency in mind than that of its member utilities.
While the Idaho utilities’ programs are targeted to produce
benefits for their ratepayers, – NEEA is tasked with
developing programs that need to consider what is best for
the entire four-state region. At its core, NEEA’s ethos
assumes that changes made in one state will eventually
spillover into another state and that in the long run,
regional change will be realized.
Recommendation #4: The Evaluators recommend
that NEEA track progress for each code change
relative to administrative dollars spent towards
state-level codes and associated energy savings
accrued by each state-level code. With the 20-year
market transformation in mind, the service-
territory-level savings will still accrue over the 20-
year horizon, however, using this methodology,
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
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Addendum 14

Finding #7: NEEA currently allocates code savings via
funder share methodology, which estimates a proportion
of total NEEA funding to each utility based on number of
electric retail customers and overall load. Therefore,
savings from code adoption in other states are in-part
assigned to Idaho. The Evaluators found that out-of-state
code building savings are currently being attributed to
Idaho utilities. The Evaluators are skeptical that spillover
from out-of-state code changes result in energy savings
within the state of Idaho. Although the barriers to code
adoption from one state to the next may be similar, there
is no evidence to suggest that these learnings transfer to
observable and measurable savings. NEEA has stated that
starting in 2022, code savings will be allocated via service
territory allocation.
actual market transformation effects of co-created
savings will be more accurately tracked.
Finding #8: The NEEA Cost Effectiveness Advisory
Committee (CEAC) meets quarterly with the NEEA
objectives to provide space for discussion around results
of recently completed evaluation, progress of field studies,
relevant updates to programs, and acceptance or
questioning of NEEA methodology towards calculation of
savings.
Finding #9: The Evaluators estimated verified Ex Post aMW
for the efficiency measures to display 39%, 52%, and 0%
realization rates for Idaho Power electric, Avista electric,
and Avista gas savings within the state of Idaho,
respectively. The difference in claimed savings and verified
savings is due to the change to using service territory
allocation rather than funder share allocation. The
efficiency measures category Ex Ante savings included
savings for measures completed in Washington, Oregon,
and Montana – therefore, for some measures, the funder
share allocation methodology underestimated Idaho-
specific savings while others overestimated out-of-state
savings. The overall effect of this change resulted in a
lower than 100% realization rate.
The Evaluators reference Recommendation #1: The
Evaluators recommend Avista and Idaho request
NEEA to report annual savings via the service
territory methodology for each measure claimed by
NEEA for each Idaho Power electric, Avista electric,
and Avista gas.
Finding #10: The database review revealed that a variety
of fields (measure life, UES) were empty across measure
types due to lack of savings claimed for the measure, which
made verification of values difficult and complicates
tracking of a measure progress over time.
Recommendation #5: The Evaluators recommend
that measure-level values are only included in
annual reports for measures in which savings are
claimed. In addition, the Evaluators recommend
NEEA continue to document each value as
accurately as possible, and that each field is
completed in the workbook to allow for year-over-
year tracking of regional units, baseline units,
retirement units, and unit energy savings values
over time.
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
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Addendum 15

Finding #11: The database review revealed that NEEA’s
current method for distribution of modeled naturally
occurring baseline units between local program and NEEA
efforts is reasonable.
Recommendation #6: Rescinded based on
additional information provided by NEEA.
Finding #12: The Evaluators reviewed the utilized UES via
the Regional Technical Forum (RTF) workbooks, field study
data, and simulation analysis findings and note no large
concerns with NEEA UES methodology or market baseline
assumptions.

Finding #13: The Evaluators found that NEEA calculates
cost-effectiveness of its portfolio using the total regional
savings rather than the net market effects. The Evaluators
determined that this methodology raises concern, and the
NEEA cost-effectiveness tests currently account for all
measure, standard, and code completions across the
entire region, effectively double counting local program
savings and simultaneously claiming naturally occurring
baseline savings. Because Avista and Idaho Power
calculate their own internal cost effectiveness tests, this
finding does not impact Idaho Power or Avista reporting.
However, the Evaluators highlight this finding, as NEEA
savings allocation and cost allocation methods are not
currently consistent with regulatory requirements.
Recommendation #7: In the case that cost
effectiveness tests are completed using NEEA-
reported savings, the Evaluators recommend that
Avista and Idaho Power calculate cost-effectiveness
using net market effects rather than total regional
savings, as is consistent with current regulatory
requirements to report gross savings that would not
have occurred without program intervention.
Finding #14: The Evaluators estimated verified Ex Post
aMW for the standards efforts to display 34% and 50%
realization rates for Idaho Power electric and Avista
electric within the state of Idaho, respectively. Avista gas
did not claim any savings for standards. The difference
between claimed savings and verified savings is due to the
change to using service territory allocation rather than
funder share allocation. A minor cause of discrepancy is
due to corrected baseline units using influence evaluation
values.
The Evaluators reference Recommendation #1: The
Evaluators recommend Avista and Idaho Power
request NEEA to report annual savings via the
service territory methodology for each measure
claimed by NEEA for each Idaho Power electric,
Avista electric, and Avista gas.
Finding #15: NEEA contracts third-party evaluators to
conduct “influence evaluations” for each standard, which
summarizes NEEA’s overall qualitative and quantitative
influence towards federal standards updates. NEEA uses
the quantitative assessment as an estimate of federal
standards naturally occurring baseline. The Evaluators
found that some of these influence scores were not
integrated properly to estimate baseline units. The
Evaluators also found a small number (3 of 19) federal
standard measures in which savings are claimed by NEEA
lack influence evaluations.
Recommendation #8: The Evaluators recommend
that third-party influence evaluations are
completed for the federal standards in which
energy savings are claimed by NEEA, as well as any
federal standards in which NEEA hopes to claim
savings for in the future. This third-party evaluation
must include the objective to quantitatively
estimate NEEA influence towards the standard
update as a proportion of incremental savings. This
influence evaluation is suitable for removing the
market baseline counterfactual in which NEEA did
not participate in standards update efforts.
Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
Page 15 of 16

Addendum 16

Finding #16: The Evaluators estimated verified Ex Post
aMW for the code efforts to display 137%, 125%, and 87%
realization rates for Idaho Power electric, Avista electric,
and Avista gas savings within the state of Idaho,
respectively. The difference between claimed savings and
verified savings is due to the change to using service
territory allocation rather than funder share allocation.
Overall, the funder share allocation underestimated Idaho-
specific code savings using the current NEEA policy of
claiming 100% code after code is implemented.
The Evaluators reference Recommendation #1: The
Evaluators recommend Avista and Idaho Power
request NEEA to report annual savings via the
service territory methodology for each measure
claimed by NEEA for each Idaho Power electric,
Avista electric, and Avista gas.s
The Evaluators reference Finding #10 also applies for the
codes review: The database review revealed that a variety
of fields (measure life, UES) were empty across measure
types due to lack of savings claimed for the measure, which
made verification of values difficult and complicates
tracking of a measure progress over time
The Evaluators reference Recommendation #5: The
Evaluators recommend that measure-level values
are only included in annual reports for measures in
which savings are claimed. In addition, the
Evaluators recommend NEEA continue to document
each value accurately and that each field is
completed in the workbook to allow for year-over-
year tracking of regional units, baseline units,
retirement units, and unit energy savings values
over time.
Finding #17: Currently, NEEA does not complete third-
party evaluations of NEEA “influence” towards codes
updates as is currently done for federal standards updates.
Therefore, NEEA currently claims 100% savings for code-
built homes. As summarized in the standards influence
evaluations summarized in Table 3 35, NEEA influence
towards standards ranges between 2.6% and 61%. If codes
are evaluated similarly, and portray a similar range of
influence, NEEA code savings could be significantly
overrepresenting savings. NEEA’s current policy is to
report 100% of code-built residential and commercial
building savings (while integrating compliance rates) for 10
years after the effective code update date. Currently, NEEA
does not maintain a model to estimate naturally occurring
baseline over time, as it does for its energy efficiency
measures. Essentially, the current NEEA methodology
assumes that there would be a 10-year lag in current
residential and commercial building code if NEEA did not
participate in code update efforts.
Recommendation #9: The Evaluators recommend
an evaluation is completed for each code update to
estimate NEEA’s qualitative and quantitative
influence towards the code update, or,
alternatively, incorporating a quantitative method
for isolating incremental savings due to NEEA-
specific efforts approved by a third-party evaluator.
Finding #18: The Evaluators reviewed simulation model
methodology used by NEEA to estimate code savings and
found that UES methodology for code savings do not
present any concerns.

Exhibit No. 6
Case No. IPC-E-23-10
T. Drake, IPC
Page 16 of 16