20240315IPC Direct Thompson.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2023 DEMAND-
SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.

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CASE NO. IPC-E-24-11

IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
ROBERT Z. THOMPSON
RECEIVED
Friday, March 15, 2024 1:29PM
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, lighting, 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 $38,778,378 of 12
DSM expenses for the acquisition of demand-side resources 13
in 2023 was prudently incurred. This amount includes 14
$30,323,272 funded in 2023 by the Idaho Energy Efficiency 15
Rider (“Rider”) and $8,455,107 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 2023 DSM 19
program performance, (2) discuss 2023 DSM expenses and 20
adjustments, (3) provide an overview of the cost-21
effectiveness results for 2023, (4) review program 22
evaluation efforts, and (5) describe the input stakeholders 23
provided during the year. 24
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THOMPSON, DI 4
Idaho Power Company
Q. Are you sponsoring any exhibits? 1
A. Yes. I am sponsoring the following exhibits: 2
Exhibit Description
Exhibit No. 1 2023 Idaho DSM Expenses and Adjustments
for Prudence Filing
Exhibit No. 2 2023 Cost-Effectiveness Summary by
Program Sector and Portfolio
Exhibit No. 3 2023 DSM Evaluation Plan
I. 2023 DSM PROGRAM PERFORMANCE 3
Q. What is Idaho Power’s focus when evaluating 4
program performance? 5
A. Idaho Power takes its responsibility of 6
prudently managing customer-funded DSM activities 7
seriously, and the Company believes it is important to 8
provide its customers with the maximum value from these 9
activities. The Company’s actions in 2023, and the content 10
of the Demand-Side Management 2023 Annual Report (“DSM 2023 11
Annual Report”), Attachment 1 to the Application filed in 12
this proceeding, provides evidence supporting the 13
conscientious work Idaho Power employees made toward using 14
customers’ funds wisely to support DSM activities. 15
Q. Please provide an overview of Idaho Power’s 16
DSM activities in 2023. 17
A. On a system-wide basis, Idaho Power offered a 18
broad portfolio of energy efficiency and demand response 19
programs available to all customer segments, and the 20

THOMPSON, DI 5
Idaho Power Company
Company also participated in market transformation efforts 1
through the Northwest Energy Efficiency Alliance (“NEEA”). 2
Idaho Power also finished up its ductless heat pump market 3
transformation pilot program offered in conjunction with 4
Avista Utilities. Finally, the Company offered several 5
educational and behavioral initiatives including the 6
Residential Energy Efficiency Education Initiative, 7
seasonal contests, the School and Campus Cohorts, and the 8
Industrial Energy Efficiency Cohort. 9
The Company leveraged its Energy Efficiency Advisory 10
Group (“EEAG”) to solicit input and feedback on ways to 11
identify opportunities to increase program effectiveness, 12
delivery, and marketing. A summary of Idaho Power’s 2023 13
DSM programs is provided in Table 1 below. 14
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THOMPSON, DI 6
Idaho Power Company
Table 1. 2023 DSM Programs by Sector, Operational Type, 1
and Location 2
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
Heating & Cooling Efficiency Program .......................... Energy Efficiency ID/OR
Home Energy Audit ....................................................... Energy Efficiency ID
Home Energy Report Program ...................................... Energy Efficiency ID
Multifamily Energy Efficiency 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
3
Table 1 illustrates the broad availability of 4
programs offered by Idaho Power to its customers in energy 5
efficiency, demand response, and education. Idaho Power’s 6
energy efficiency portfolio was cost-effective, resulting 7
in a 2.06 benefit/cost ratio when evaluated from a Utility 8

THOMPSON, DI 7
Idaho Power Company
Cost Test (“UCT”) perspective, a 1.51 benefit/cost ratio 1
when evaluated from a Total Resource Cost (“TRC”) test 2
perspective, and a 1.89 benefit/cost ratio when evaluated 3
from a Participant Cost Test (“PCT”) perspective. 4
Attachment 1 to the Application, the DSM 2023 Annual 5
Report, provides details for each program, which include: a 6
program description, 2023 performance results, program 7
activities, cost-effectiveness ratios, marketing 8
activities, customer satisfaction, upcoming 2024 plans, and 9
evaluation results when applicable. Also included in 10
Attachment 1 are: Supplement 1: Cost Effectiveness 11
(“Supplement 1”), which provides detailed cost-12
effectiveness data by program and measure, and Supplement 13
2: Evaluation (“Supplement 2”), which provides copies of 14
the Company’s evaluation, reports, and research conducted 15
in 2023. 16
Energy Efficiency 17
Q. What level of incremental annual energy 18
efficiency savings was achieved in 2023? 19
A. On a system-wide basis, Idaho Power achieved 20
139,683 megawatt-hours (“MWh”) of incremental annual energy 21
efficiency savings in 2023. This value includes 115,769 MWh 22
from Idaho Power’s energy efficiency programs and an 23

THOMPSON, DI 8
Idaho Power Company
estimated 23,914 MWh1 of energy efficiency market 1
transformation savings through NEEA initiatives. Chart 1 2
below shows the incremental annual energy efficiency 3
savings in MWh from 2002 to the current year. Also shown in 4
this chart are the total energy efficiency expenses for 5
each year in millions of dollars. 6
Chart 1. Incremental Annual Energy Efficiency Savings 7
(MWh)and Energy Efficiency Expenses ($ millions) 2002-2023 8
9
Note: 2023 NEEA market-transformation savings are estimated. 10
Q. Did Idaho Power meet the energy efficiency 11
targets included in its most recently filed 2023 Integrated 12
Resource Plan (“IRP”)? 13
A. Yes. In 2023, Idaho Power achieved 15.9 14
average megawatts (“aMW”) of incremental energy efficiency 15
savings, including NEEA estimated energy savings, which 16

1 Because Idaho Power will not receive final 2023 savings from
NEEA until the second quarter 2024, the NEEA-attributable savings is an
estimate provided to Idaho Power by NEEA.

THOMPSON, DI 9
Idaho Power Company
exceeded the economic technical achievable potential 1
included in the 2023 IRP of 12.2 aMW. The 2023 savings 2
represent enough energy to power approximately 12,253 3
average homes in Idaho Power’s service area for one year. 4
Q. How did 2023 DSM program year compare to 2022? 5
A. In the 2023 program year, several of the 6
Company’s DSM programs outperformed their savings and 7
participation as compared to the 2022 program year. These 8
programs include Educational Distributions, Commercial & 9
Industrial (“C&I”) Energy Efficiency Program Custom 10
Projects, C&I Flex Peak Program, and Irrigation Peak 11
Rewards. The Educational Distributions and C&I Energy 12
Efficiency Custom Projects increased their combined total 13
energy savings by over 4,700 MWh. The C&I Flex Peak and the 14
Irrigation Peak Rewards demand response programs increased 15
their combined total of participating sites by 409 with the 16
C&I Flex Peak program increasing its demand response 17
capacity by over 8 megawatts (“MW”). The Company was also 18
able to launch a brand-new Multifamily Energy Efficiency 19
Program that customers can leverage along with the other 20
C&I Energy Efficiency Program offerings such as New 21
Construction, Retrofits, and Custom Projects. 22
Overall portfolio savings decreased by 29,883 MWh 23
year-over-year compared to 2022 with the main drivers being 24
the C&I Energy Efficiency Program New Construction and 25

THOMPSON, DI 10
Idaho Power Company
Retrofits options as well as the Home Energy Reports 1
(“HER”) program. The projects within C&I Energy Efficiency 2
Program can vary greatly in size, scale, and the timeframes 3
it takes to complete them, which can cause changes in 4
overall portfolio savings performance annually. The New 5
Construction and Retrofits options combined drove about 83 6
percent of the decrease in annual incremental savings 7
compared to 2022. The HER program experienced a decrease in 8
savings as well due to the anticipated program attrition 9
associated with the conclusion of the first 3-year 10
treatment period. The Company has entered into an agreement 11
with a new HER program implementer for another 3-year 12
treatment period from 2024 through 2026. The Company is 13
exploring the potential to add a new wave of residential 14
customers to the program, and if successful in that, the 15
Company anticipates savings to increase for 2024 as 16
compared to the 2023 program year. 17
Q. Does the Company engage in customer education 18
and outreach activities for which it cannot quantify or 19
report savings? 20
A. Yes. The Company engages in significant 21
educational awareness activities and marketing efforts that 22
are likely to result in energy savings experienced by 23
customers but are not quantified or claimed as part of 24
Idaho Power’s annual savings. These efforts are designed to 25

THOMPSON, DI 11
Idaho Power Company
reach all customer segments and are more fully explained 1
throughout the DSM 2023 Annual Report. In 2023, this 2
included activities such as: holding virtual and in-person 3
technical trainings and workshops with customers, producing 4
the Energy@Work and Irrigation newsletters, participating 5
in several different types of agricultural shows, hosting 6
or participating in vendor workshops promoting irrigation 7
system efficiency, publishing residential energy efficiency 8
guides that showcased behavioral changes to save energy, 9
attending other outreach activities such as home shows to 10
discuss energy efficiency with customers one-on-one, and 11
supporting the Integrated Design Lab. 12
Demand Response 13
Q. What level of capacity was available from 14
Idaho Power’s demand response programs in 2023? 15
A. The total available capacity of Idaho Power’s 16
three demand response programs (A/C Cool Credit, Flex Peak 17
Program, and Irrigation Peak Rewards) was approximately 316 18
MW. This value represents the total enrolled MW from 19
participants adjusted for an expected maximum realization 20
rate. 21
Q. What level of non-coincident demand reduction 22
was provided? 23
A. The Company’s demand response programs 24
provided actual non-coincident demand reduction of 240 MW 25

THOMPSON, DI 12
Idaho Power Company
during the 2023 program season. The 240 MW maximum load 1
reduction is less than 316 MW of total demand response 2
program capacity for a variety of reasons including, but 3
not limited to, the three demand response programs are not 4
always dispatched together during a single event day, the 5
four irrigation groups are also not always dispatched 6
coincidentally, and events are not always called during the 7
demand response season when the total program capacity is 8
available. Chart 2 below reflects the annual available peak 9
demand reduction capacity and actual load reduction in MW 10
since 2004 and the associated annual expenses in millions 11
of dollars. 12
Chart 2. Peak Demand Reduction Capacity (MW) and Demand 13
Response Expenses ($ millions) 2004-2023 14
15
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THOMPSON, DI 13
Idaho Power Company
II. 2023 DSM EXPENSES AND ADJUSTMENTS 1
Q. What amount of DSM expenses is the Company 2
requesting the Commission find were prudently incurred? 3
A. In the delivery of energy efficiency, demand 4
response, and market transformation programs, Idaho Power 5
expended $30,323,272 of Rider funds and paid $8,455,107 in 6
demand response program incentives, for a total of 7
$38,778,378 spent on demand-side resource acquisition in 8
2023. Idaho Power requests that the 2023 Rider-funded DSM 9
expenses, and the 2023 demand response program incentives 10
recovered through base rates and tracked through the PCA, 11
be reviewed together for a prudence determination. Exhibit 12
No. 1 to my testimony, 2023 Idaho DSM Expenses and 13
Adjustments for Prudence Filing, shows a breakout of these 14
expenses by program, customer sector, and funding source. 15
Q. Please compare the dollar amounts in Exhibit 16
No. 1 to your testimony with Appendix 2, 2023 DSM expenses 17
by funding source (dollars), of the DSM 2023 Annual Report. 18
A. For clarity and ease of understanding, Exhibit 19
No. 1 ties to Appendix 2, which is found on page 184 of the 20
DSM 2023 Annual Report. The first column of Appendix 2 21
labeled “Idaho Rider” and the first column of Exhibit No. 1 22
labeled “Rider Expenses” match at the row labeled “Total 23
Expenses” in Exhibit No. 1 and “Grand Total” in Appendix 2 24
in the amount of $30,229,460. All values in Exhibit No. 1 25

THOMPSON, DI 14
Idaho Power Company
represent DSM expenses for the Idaho service area only. 1
Three prior year-end accounting adjustments and two current 2
year-end accounting adjustments were necessary to 3
accurately arrive at the total 2023 expenses for purposes 4
of the prudence determination. These five adjustments are 5
listed in Exhibit No. 1 under the Adjustments section as 6
2022 Commercial & Industrial Overhead, 2022 Residential 7
Energy Efficiency Education Initiative, 2022 Residential 8
Energy Efficiency Overhead, 2023 Irrigation Peak Rewards, 9
and 2023 Residential New Construction. 10
Q. Please describe the prior year-end accounting 11
adjustments included in Exhibit No. 1. 12
A. The first adjustment of $6,998 was associated 13
with the C&I Energy Efficiency program where the expense 14
should have been charged to O&M instead of the Idaho Rider 15
in 2022. The correction to reduce Idaho Rider expenses was 16
made in 2023, and therefore $6,998 needs to be added back 17
to avoid understating the 2023 prudence request. 18
The second adjustment of $1,289 is associated with 19
Idaho activity for the Residential Energy Efficiency 20
Education Initiative that was incorrectly charged to O&M in 21
2022 instead of the Idaho Energy Efficiency rider. The 22
correction adding the expense to the Idaho Rider was made 23
in 2023, and therefore $1,289 needs to be subtracted from 24

THOMPSON, DI 15
Idaho Power Company
the 2023 prudence request because it was already deemed 1
prudent by the Commission in the 2022 request. 2
The final adjustment of $89,680 was associated with 3
a program administration fee the Company paid in 2022 that 4
was refunded in 2023 due to services not being rendered. 5
The correction to reduce Idaho Rider expenses was made in 6
2023, and therefore, $89,680 needs to be added back to 7
avoid understating the 2023 prudence request. 8
Q. Please describe the current year-end 9
accounting adjustments included in Exhibit No. 1. 10
A. Two accounting adjustments to the Rider for 11
2023 were identified through Idaho Power’s year-end review 12
of expenses and the corrections were made after the 2023 13
year-end financial books were closed. 14
The first adjustment results in a reduction of 15
$1,771 which was related to expenses associated with the 16
Irrigation Peak Rewards program that should have been 17
charged to O&M, rather than the Idaho Rider. 18
The second adjustment results in an addition of $194 19
associated with the Residential New Construction program 20
where the expense was initially charged to the Oregon Rider 21
instead of the Idaho Rider. 22
Q. What amount of Rider-funded employee DSM-23
related labor expense did the Company incur in 2023? 24

THOMPSON, DI 16
Idaho Power Company
A. The 2023 total Rider-funded DSM employee labor 1
expense incurred by the Company was $3,625,290. 2
Q. What amount of 2023 DSM-related labor is the 3
Company requesting be funded through the Rider? 4
A. The Company is requesting $3,449,976 in 2023 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 2023 9
DSM labor expense was $175,313 over the cap as detailed in 10
Table 2 below. 11
Table 2. Labor Expense Calculation
2022 Total Actual Labor Expense $ 3,392,286
2022 FTEs* ÷ 24.14
2022 Actual Average Wage per FTE $ 140,545
2% Cap x 1.02
2023 Maximum Average Wage per FTE $ 143,356
2023 FTEs* x 24.07
2023 Maximum Allowed Labor Expense $ 3,449,976
2023 Total Actual Labor Expense - $ 3,625,290
Amount Under/(Over) Maximum Allowed Labor Expense $ (175,313)
*24.14 and 24.07 are rounded values. 12
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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 17
Idaho Power Company
Q. What was the year-end 2023 balance of the 1
Rider? 2
A. The Rider account balance on December 31, 3
2023, had a positive, or over-collected, balance of 4
$700,361 compared to an under-collected balance of 5
$3,767,319 on December 31, 2022. Table 3 below shows the 6
January 2023 beginning balance, funding plus accrued 7
interest, expenses, and the ending balance as of December 8
31, 2023. 9
Table 3. Idaho Energy Efficiency Rider (January-December 10
2023) 11
Idaho Energy Efficiency Rider
2023 Beginning Balance $ (3,767,319)
2023 Funding plus Accrued Interest as of 12/31/23 34,697,140
Total 2023 Funds 30,929,821
2023 Expenses as of 12/31/23 (30,229,460)
Ending Balance as of 12/31/23 $ 700,361
12
III. 2023 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 18
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 19
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. 2023 Cost-Effectiveness Results 24
Q. What were the results of the 2023 cost-25
effectiveness analyses? 26
A. Exhibit No. 2 to my testimony, 2023 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 20
Idaho Power Company
energy efficiency program aggregated by sector and for the 1
overall portfolio. As shown in Table 4 below, the overall 2
DSM Portfolio achieved benefit/cost ratios greater than 1.0 3
for each of the three cost-effectiveness tests. All three 4
of the program sectors achieved benefit/cost ratios 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. 2023 Benefit/Cost by Sector & Portfolio 8
Sector Utility Cost
Test (UCT)
Total
Resource Cost
(TRC) Test
Participant
Cost Test
(PCT)
Residential* 1.12 0.95 3.38
Commercial/Industrial 2.74 1.48 1.63
Irrigation 2.06 2.22 2.29
Portfolio* 2.06 1.51 1.89
*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 1.12 0.95 3.38 0.87 0.74 2.73
Portfolio 2.06 1.51 1.89 1.97 1.47 1.88
19

THOMPSON, DI 21
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 2023? 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 the most 16
recently acknowledged IRP at the time 2023 DSM program 17
planning occurred, Idaho Power used the avoided costs from 18
the 2021 IRP in its cost-effectiveness analysis. 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 22
Idaho Power Company
Q. What are the cost-effectiveness results for 1
each of the Company’s DSM programs? 2
A. As reflected in Exhibit No. 2 to my testimony, 3
2023 Cost-Effectiveness Summary by Program, Sector, and 4
Portfolio, on an individual program basis, 9 of the 15 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
It should be noted that the PCT ratios cannot be 9
calculated for programs that do not have a direct customer 10
cost, and the PCT is shown as “N/A” in Exhibit No. 2 for 11
those programs. Additionally, the new Multifamily Energy 12
Efficiency Program has “N/A” for all benefit/costs ratios 13
due to the fact the program launched on November 1, 2023 14
and did not realize any savings/benefits during the 15
remainder of the year. The details of the other 16
calculations are found in Supplement 1 of the DSM 2023 17
Annual Report. 18
Q. Did Idaho Power calculate cost-effectiveness 19
for each measure within each energy efficiency program it 20
offers? 21
A. Yes. In 2023, Idaho Power evaluated the 22
benefits and costs of 295 measures. The results of these 23
calculations, along with measure assumption details and 24

THOMPSON, DI 23
Idaho Power Company
source documentation, can be found in Supplement 1 to the 1
DSM 2023 Annual Report. 2
Q. How did Idaho Power address any individual 3
measures that are not cost-effective based on one or more 4
tests? 5
A. The cost and benefit values used in the 6
various analyses are based on markets, technologies, 7
economic inputs, savings estimates, and cost estimates, 8
which can change over time. When a measure is identified as 9
non-cost-effective at a specific point in time, Idaho Power 10
first evaluates whether the inputs used in the calculations 11
are still applicable. Then the Company determines if the 12
measure parameters should be modified or if the measure 13
should be eliminated altogether. For additional detail on 14
measure analysis, please refer to Supplement 1 to the DSM 15
2023 Annual Report. 16
B. Non-Cost-Effective Programs 17
1. Income Qualified Weatherization 18
Q. Please explain what drivers influence the 19
cost-effectiveness results for the WAQC and Weatherization 20
Solutions for Eligible Customers (“Solutions”) programs? 21
A. The WAQC and Solutions programs provide real 22
and substantial per home savings, but due to the costs of 23
comprehensive whole-house weatherization, it is difficult 24
for the value of the savings to outweigh the costs. The 25

THOMPSON, DI 24
Idaho Power Company
weatherization services provided through the WAQC program 1
are consistent with the Idaho State Weatherization 2
Assistance Program guidelines, and both the WAQC and 3
Solutions programs are offered at no charge to the 4
participant. Please refer to pages 88 and 98 in the DSM 5
2023 Annual Report for the savings, costs, and the number 6
of homes weatherized in 2023. 7
Q. Does Idaho Power plan to continue offering the 8
WAQC and Solutions programs in the future? 9
A. Yes. While the Company has identified that the 10
programs are not cost-effective under the UCT, unless the 11
Commission directs otherwise, Idaho Power will continue to 12
offer them to the Company’s limited-income customers on an 13
ongoing basis. The Company will also continue to consult 14
the EEAG and weatherization managers who oversee the 15
weatherization work to look for ways to improve outreach 16
and the cost-effectiveness of these programs as 17
opportunities are available. 18
2. Rebate Advantage 19
Q. What were the cost-effectiveness results for 20
the Rebate Advantage program? 21
A. As shown in Exhibit No. 2, the Rebate 22
Advantage Program achieved a UCT ratio of 0.98 and a TRC 23
ratio of 0.93. The program was just slightly under 1.0 from 24
the UCT prospective, which was primarily driven by the 25

THOMPSON, DI 25
Idaho Power Company
updated avoided costs from the 2021 IRP used to evaluate 1
the cost-effectiveness for the 2023 program year. The 2
Rebate Advantage program was found to be cost effective in 3
2022, with a UCT ratio of 1.18, based on the avoided costs 4
from the then-most recently acknowledged IRP, which was the 5
2019 Second Amended IRP at the time 2022 DSM program 6
planning occurred. 7
Notably, the savings assumptions between the 2022 8
and 2023 program years remained the same for the Rebate 9
Advantage program. However, because the life cycle of 10
program measures range between 43 and 45 years, the 11
decrease in the avoided costs in later years in the 2021 12
IRP, as compared to the 2019 Second Amended IRP, 13
contributed to the decline of the program’s cost-14
effectiveness from 2022 to 2023. For 2024, the Company 15
anticipates the Rebate Advantage program will be cost-16
effective because the 2023 IRP avoided costs were used for 17
2024 program planning and will therefore be used to 18
evaluate 2024 program cost-effectiveness. The 2023 IRP 19
avoided costs are greater than the 2021 IRP avoided costs 20
through 2034 along with an increased capacity benefit, 21
which is why the Company is optimistic the Rebate Advantage 22
program will be cost-effective going forward. 23
// 24
// 25

THOMPSON, DI 26
Idaho Power Company
3. Shade Tree Project 1
Q. What were the cost-effectiveness results for 2
the Shade Tree Project? 3
A. As shown in Exhibit No. 2 the Shade Tree 4
Project achieved a UCT ratio of 0.31 and a TRC ratio of 5
0.42 for the 2023 program year as compared to UCT and TRC 6
ratio of 1.02 and 1.21 for 2022, respectively. This was 7
driven by the results of the impact evaluation conducted in 8
2023 that significantly reduced the savings from how the 9
Company had previously calculated them. The 2023 cost-10
effectiveness ratios also include the expenses associated 11
with the program’s evaluation conducted in 2023. If the 12
evaluation expenses were removed from the program’s cost-13
effectiveness calculations, the UCT and TRC would be 0.33 14
and 0.45 respectively. 15
Q. Please explain the drivers contributing to the 16
decrease in overall savings. 17
A. The third-party evaluator identified two main 18
drivers contributing to a decrease in overall savings: (1) 19
an increased tree mortality rate, and (2) the introduction 20
of a heating penalty as described below. 21
The mortality rate of trees in certain parts of the 22
state turned out to be higher than previously expected, 23
where trees did not survive after being planted at a 24
customer’s residence or were not planted at all. 25

THOMPSON, DI 27
Idaho Power Company
The evaluator also recommended applying a heating 1
penalty for electrically heated homes to account for the 2
additional heating that would be needed in the cooler 3
months due to the shade provided by the tree. Savings were 4
reduced by subtracting the additional energy needed to heat 5
the home in the cooler months from the energy benefits of 6
the tree’s shade in the warmer months. Adding this penalty 7
greatly reduced total savings on electrically heated homes. 8
Q. Has the Company discussed the status of the 9
program with EEAG? 10
A. The Company received the preliminary Shade 11
Tree Project evaluation report on January 12, 2024 and 12
briefly discussed the preliminary evaluation results with 13
its EEAG at the February 8, 2024, EEAG meeting. The Company 14
has engaged in discussions with the third-party evaluator 15
that conducted the 2023 impact evaluation to assess 16
possible cost-effectiveness improvement recommendations. 17
Q. Does the Company anticipate continuing the 18
program through 2024? 19
A. Yes. Prior to receiving the evaluation results 20
and based on the information available to the Company at 21
that time, Idaho Power contractually committed to the 2024 22
Shade Tree Project events. The vendor requires a commitment 23
at least a year in advance in order to plant and grow the 24
trees to the preferred size for the events. However, the 25

THOMPSON, DI 28
Idaho Power Company
recently obtained information will better inform decisions 1
about the future of the program. The Company plans to share 2
this information at the May EEAG meeting and consult with 3
EEAG on potential next steps. 4
4. Heating and Cooling Efficiency Program 5
Q. What were the cost-effectiveness results for 6
the Heating and Cooling Efficiency program? 7
A. As shown in Exhibit No. 2, the Heating and 8
Cooling Efficiency Program achieved a UCT of 0.94 and a TRC 9
of 0.40 as compared to UCT and TRC ratio of 0.98 and 0.30 10
for 2022, respectively. 11
Q. What was the primary contributor to the 12
program not being cost-effective? 13
A. The main driver of the difference was the 14
decrease in overall savings, which was largely due to 15
updates in savings assumptions by the Regional Technical 16
Forum (“RTF”). The RTF is the source of most measure 17
savings assumptions within the program and many of those 18
assumptions changed between 2022 and 2023. The savings 19
decrease was primarily driven by two measures within the 20
program: smart thermostats and air-source heat pumps. 21
Smart thermostats made up 45 percent of the total 22
program participation and 14 percent of the total savings. 23
With the new RTF assumptions, the per unit savings declined 24

THOMPSON, DI 29
Idaho Power Company
by between 24 percent and 65 percent compared to the 1
savings in 2022. 2
Air-source heat pumps made up 17 percent of the 3
total program participation and 44 percent of the total 4
savings. On average, the per unit savings for air-source 5
heat pump measures declined by nearly 12 percent as 6
compared to 2022. 7
Additionally, ductless heat pumps made up 16 percent 8
of the program participation and 19 percent of the total 9
savings. While the savings assumptions did not change year 10
over year, the average savings per unit declined by nearly 11
16 percent due to the heating zone locations of the 12
participants in 2023 versus 2022. Savings vary by heating 13
zones and the participants in 2023 were in heating zones 14
with lower savings. 15
Q. Does Idaho Power expect the program to be 16
cost-effective going forward? 17
A. Yes. In November 2023, Idaho Power modified 18
the Heating & Cooling Efficiency program based on the 19
updated RTF savings and analyzed the program with the new 20
DSM avoided costs from the most recently filed 2023 IRP. 21
With these changes, the program is expected to be cost-22
effective in 2024 and beyond. 23
// 24
// 25

THOMPSON, DI 30
Idaho Power Company
5. Small Business Direct Install (“SBDI”) Program 1
Q. What were the cost-effectiveness results for 2
the SBDI Program? 3
A. As shown in Exhibit No. 2, the SBDI Program 4
achieved a UCT of 0.97 and a TRC of 1.48 as compared to UCT 5
and TRC ratio of 0.95 and 1.50 for 2022, respectively. The 6
2023 cost-effectiveness ratios also include the expenses 7
associated with the program’s evaluation conducted in 2023. 8
If the evaluation expenses were removed from the program’s 9
cost-effectiveness calculations, the UCT and TRC would be 10
1.08 and 1.64, respectively. 11
Q. What was the primary contributor to the 12
program not being cost-effective? 13
A. The short three-month operation of the program 14
before it was discontinued on March 31, 2023, along with 15
the costs associated with evaluation, were the primary 16
reasons the SBDI program was not cost-effective in the 2023 17
program year. 18
Q. Why did the Company complete an evaluation in 19
2023 if it already planned to end the program? 20
A. Because all program savings came from lighting 21
measures, the Company had previously decided not to 22
continue the program past the contract end-date with the 23
vendor as it had determined that it would not be cost-24
effective in the longer term. However, after consultation 25

THOMPSON, DI 31
Idaho Power Company
with its EEAG during 2022 and into 2023, the Company 1
decided to conduct an impact evaluation on the program in 2
2023 to potentially inform a new small business targeted 3
energy efficiency program in the future. The Company is 4
exploring the potential to launch an updated and cost-5
effective small business lighting energy efficiency program 6
in the near future based on the 2023 SBDI evaluation 7
findings and further discussions and feedback from the EEAG 8
in 2024. 9
C. Demand Response Cost-Effectiveness 10
Q. Does Idaho Power evaluate cost-effectiveness 11
for its three demand response programs? 12
A. Yes. The methodology approved in Order No. 13
353365 is used to determine the cost-effectiveness of the 14
demand response (“DR”) programs and sets the maximum 15
avoided cost value. In accordance with the approved 16
methodology, the 2023 cost-effectiveness threshold for 17
demand response is $84.57 per kW year. 18
Q. How was the $84.57 determined? 19
A. Using the approved method, the avoided cost 20
calculation for the demand response programs is as follows: 21
// 22

5 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 32
Idaho Power Company
(Levelized Fixed Costs – Additional Benefits) 1
x Effective Load Carrying Capacity (“ELCC”) of Annual 2
Demand Response Capacity Compared to Proxy Resource 3
= $ per kW year Demand Response Avoided Costs 4
Each of the three components have been updated and 5
are: 6
1. From the 2021 IRP, the 2023 levelized fixed 7
cost value of a Simple-Cycle Combustion Turbine (“SCCT”) 8
was determined to be $134.63 per kW per year. 9
2. From the 2021 IRP, to determine the 10
additional ancillary benefits provided by the SCCT compared 11
to DR, an analysis was performed where DR was replaced with 12
an equivalent SCCT and the fixed costs of the SCCT were 13
removed from the model. The result of this analysis showed 14
there were no additional benefits associated with the SCCT 15
because the cost of the fuel and SCCT plant Operations and 16
Maintenance (“O&M”) required to meet the demand response 17
demand. 18
3. The updated ELCC of approximately 316 MW of DR 19
capacity compared to a SCCT utilizing 2021 IRP assumptions 20
is 62.82 percent. 21
($134.63 - $0.00) * 62.82% = 22
$84.57 per kW year Demand Response Avoided Cost 23
Additional details of the methodology are included 24
in Supplement 1. 25

THOMPSON, DI 33
Idaho Power Company
Q. What were the total and per kW costs of the 1
Company’s demand response programs? 2
A. In 2023, the system-wide cost of operating the 3
three demand response programs was approximately $11.3 4
million ($8.9 million of incentives and $2.4 million of 5
other costs). The amounts attributable to the Idaho-only 6
jurisdiction were $10.7 million ($8.4 million of incentives 7
and $2.3 million of other costs). Table 6 below shows the 8
2023 dollar per kW year costs for each program and the 9
overall demand response portfolio assuming the programs 10
were dispatched for the maximum 60 hours. Idaho Power 11
estimates that if the three programs were dispatched for 12
the full 60 hours allowed, the total costs would have been 13
approximately $12.9 million on a system-wide basis. 14
Table 6. Demand Response Program 2023 $ per kW year 15
Program $ per kW year
Residential A/C Cool Credit $29.93
C&I Flex Peak $36.40
Irrigation Peak Rewards $42.57
Total Demand Response Portfolio $40.80
16
Q. Were the demand response programs cost-17
effective? 18
A. Yes. All three of the Company’s demand 19
response programs, as well as the demand response 20
portfolio, had a cost per kW less than the 2023 threshold 21
of $84.57, meaning the programs and the portfolio were 22
cost-effective. 23

THOMPSON, DI 34
Idaho Power Company
Q. Does Idaho Power have a plan to evaluate the 1
avoided cost equation used to determine the cost-2
effectiveness of the Company’s demand response programs? 3
A. Yes. The Company believes there should be 4
further discussions regarding the best method(s) for 5
evaluating the Company’s DR programs and commits to working 6
with Staff and stakeholders to this end. Through the 7
Company’s ongoing evaluation conducted to date utilizing 8
the cost-effectiveness methodology that was approved by the 9
Commission in Order No. 35336 in Case No. IPC-E-21-32, 10
Idaho Power has identified several different methods that 11
could potentially be used to evaluate DR cost-effectiveness 12
moving forward. Idaho Power anticipates engaging with Staff 13
and potentially other stakeholders on this topic in the 14
coming months as it explores the potential expansion of 15
other DR opportunities. 16
In the event the Company determines that changes to 17
the DR programs are needed, having an avoided cost 18
calculation recommendation that was collaboratively 19
developed would help ensure a proposal that balances the 20
costs and benefits of DR is brought before the Commission 21
for its review. 22
// 23
// 24
// 25

THOMPSON, DI 35
Idaho Power Company
IV. EVALUATION ACTIVITY OVERVIEW 1
Q. What is the Company’s approach to DSM program 2
evaluation? 3
A. To ensure the ongoing cost-effectiveness of 4
programs through validation of energy savings and demand 5
reduction, and to guide the efficient management of its 6
programs, the Company utilizes evaluations conducted by 7
third-party contractors chosen through a competitive 8
bidding process. Idaho Power uses industry-standard 9
protocols, internal analyses, and regional and national 10
studies to inform its internal and external evaluation 11
efforts. The Company has generally conducted impact 12
evaluations every three years, and process evaluations for 13
relatively new programs, or when a program has significant 14
changes. Supplement 2 to the DSM 2023 Annual Report 15
provides additional information regarding how Idaho Power 16
evaluates its programs. 17
Q. How does Idaho Power utilize the evaluations 18
described above? 19
A. Idaho Power uses the results of its 20
evaluations to inform decisions related to program 21
improvement, to compare processes to industry best 22
practices, and to benchmark and validate reported program 23
savings. 24
// 25

THOMPSON, DI 36
Idaho Power Company
Q. What evaluation activities took place in 2023? 1
A. In addition to the annual cost-effectiveness 2
analyses that the Company conducts for each program, Idaho 3
Power contracted with several third-party evaluators to 4
conduct impact and process evaluations in 2023. Evaluations 5
conducted by these evaluators were on the following 6
programs: 7
 Impact and process evaluation on the Home Energy 8
Audit Program. 9
 Impact evaluations on Residential New 10
Construction Program, Shade Tree Project, Small 11
Business Direct Install, and the Irrigation 12
Efficiency Rewards Program. 13
In addition to these third-party evaluations, Idaho 14
Power completed internal analyses of the Irrigation Peak 15
Rewards, C&I Flex Peak, and A/C Cool Credit demand response 16
programs. 17
The impact evaluations that were conducted in 2023 18
analyzed reported savings from the 2022 program year. 19
Realization rates were as follows: 20
 Home Energy Audit: 102 percent. 21
 Residential New Construction Program: 100 22
percent. 23
 Shade Tree Project: 70 percent. 24
 Small Business Direct Install: 100 percent. 25

THOMPSON, DI 37
Idaho Power Company
 Irrigation Efficiency Rewards: 97.4 percent. 1
The final reports for these evaluations, and the 2
market effects evaluations conducted by NEEA, are included 3
in Supplement 2 to the DSM 2023 Annual Report. 4
Q. Does Idaho Power have a DSM program evaluation 5
plan for 2024-2025? 6
A. Yes. The evaluation plan is included as 7
Exhibit No. 3 to my testimony and is also included in 8
Supplement 2 to the DSM 2023 Annual Report. In 2024, Idaho 9
Power’s evaluation plan includes the following third-party 10
evaluations: 11
 Impact and process evaluations for Rebate 12
Advantage and C&I Energy Efficiency Program 13
Custom Projects. 14
 Impact evaluation for Educational Distributions. 15
V. STAKEHOLDER INPUT 16
Q. What is the EEAG? 17
A. In 2002, Idaho Power formed the EEAG to 18
provide input on enhancing existing DSM programs, 19
recommending new energy efficiency measures, and 20
implementing energy efficiency programs. Members include 21
customer representatives from residential, irrigation, 22
commercial, and industrial sectors as well as technical 23
experts, representatives for limited-income individuals, 24
environmental organizations, state agencies, county and 25

THOMPSON, DI 38
Idaho Power Company
city governments, the Commission, the Public Utility 1
Commission of Oregon, and Idaho Power. 2
Q. What is the structure of EEAG meetings? 3
A. The EEAG generally meets quarterly in-person 4
at Idaho Power’s corporate offices and through webinars as 5
needed. Three EEAG meetings were held in person with a 6
virtual option and one EEAG meeting was held virtually in 7
2023. The Company believes that member participation and 8
input remained strong during the 2023 EEAG meetings. 9
The agenda during EEAG meetings is varied, but 10
typically includes program and project updates, new energy 11
efficiency program or measure proposals, marketing methods, 12
specific measure details including cost-effectiveness, the 13
status of energy efficiency expenses, and general 14
information on DSM issues. When appropriate, the Company 15
invites experts to speak on evaluations, research, and 16
other topics of interest to enhance EEAG’s understanding. 17
Q. How did Idaho Power solicit guidance from the 18
EEAG during the 2023 program year? 19
A. In 2023, the Company held four EEAG meetings, 20
and during these meetings, Idaho Power discussed and 21
requested recommendations on a broad range of DSM issues. 22
As explained in greater detail in the DSM 2023 Annual 23
Report, the list below includes some of the topics Idaho 24

THOMPSON, DI 39
Idaho Power Company
Power worked with the EEAG on for development, design, 1
promotion, or input: 2
 Multifamily Energy Efficiency Program: With the 3
sunset of the previous direct install Multifamily 4
Energy Savings program on December 31, 2022, the 5
Company consulted with the EEAG to develop a new 6
cost-effective Multifamily Energy Efficiency 7
program that has a robust list of measures but 8
now requires customers to bear some of the cost. 9
The Company was able to successfully launch the 10
new program on November 1, 2023 and received 11
eight preliminary applications. 12
 C&I Flex Peak Incentive Structure: After 13
receiving feedback from customers in the C&I Flex 14
Peak demand response program and conducting its 15
own internal analysis, the Company requested 16
feedback from the EEAG on a new incentive 17
structure for the program that would reduce the 18
severity of the performance penalty, which in 19
turn, will incentivize increased participation in 20
the C&I Flex Peak demand response program. The 21
Company filed its request to update the incentive 22
structure based on EEAG’s input on October 2, 23
2023, in Case No. IPC-E-23-24. 24

THOMPSON, DI 40
Idaho Power Company
 Avoided Costs Used in DSM Program Planning and 1
Cost-Effectiveness: At the EEAG meeting on August 2
17, 2023, the Company presented its proposal to 3
use the avoided costs from the most recently 4
“filed” IRP rather than use the most recently 5
“acknowledged” IRP for DSM program planning. The 6
EEAG supported the proposal and agreed with the 7
premise that this would reduce the lag time 8
between when the avoided costs are updated and 9
used for program planning and cost-effectiveness 10
evaluations. As a result, beginning with the 2024 11
program year, the Company will now be using the 12
most current IRP information available for its 13
DSM planning, evaluations, and analyses. 14
VI. CONCLUSION 15
Q. Do you believe that the information contained 16
in this testimony and attached exhibits supports a prudence 17
determination for 2023 DSM expenses? 18
A. Yes. Based on the DSM 2023 Annual Report, the 19
testimony set forth above, and the attached exhibits, Idaho 20
Power respectfully requests the Commission determine that 21
$38,778,378 was prudently incurred for the acquisition of 22
demand-side resources in 2023. 23
// 24
// 25

THOMPSON, DI 41
Idaho Power Company
Q. Does this conclude your testimony? 1
A. Yes, it does. 2

THOMPSON, DI 42
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 2024. 17
18
19
Robert Z. Thompson 20
21
SUBSCRIBED AND SWORN to before me this 15th day of 22
March 2024. 23
24
25
Notary Public for Idaho 26
Residing at Ada County Idaho 27
My commission expires: 11/02/2024 28
29
30

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-24-11

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 1,536,873$ 365,690$ 1,902,563$
Educational Distributions 880,568 - 880,568
Energy Efficient Lighting 278,610 - 278,610
Heating & Cooling Efficiency Program 593,407 - 593,407
Home Energy Audit 230,011 - 230,011
Home Energy Report Program 883,505 - 883,505
Multifamily Energy Efficiency 22,758 - 22,758
Rebate Advantage 130,233 - 130,233
Residential New Construction Program 195,102 - 195,102
Shade Tree Project 262,344 - 262,344
Weatherization Solutions for Eligible Customers 84,428 - 84,428
Commercial/Industrial
Custom Projects 11,221,008 - 11,221,008
New Construction 2,139,603 - 2,139,603
Retrofits 3,002,681 - 3,002,681
Commercial Energy-Saving Kits 53,167 - 53,167
Flex Peak Program 135,731 694,935 830,665
Small Business Direct Install 357,404 - 357,404
Irrigation
Irrigation Efficiency 1,474,741 - 1,474,741
Irrigation Peak Rewards 616,755 7,394,482 8,011,237
Energy Efficiency/Demand Response Total 24,098,928$ 8,455,107$ 32,554,034$
Market Transformation
NEEA 2,589,987 - 2,589,987
Market Transformation Total 2,589,987$ -$ 2,589,987$
Other Programs and Activities
Commercial/Industrial Energy Efficiency Overhead 890,300 - 890,300
Energy Efficiency Direct Program Overhead 290,729 - 290,729
Residential Energy Efficiency Education Initiative 359,242 - 359,242
Residential Energy Efficiency Overhead 1,204,872 - 1,204,872
Other Programs and Activities Total 2,745,144$ -$ 2,745,144$
Indirect Program Expenses
Energy Efficiency Accounting & Analysis 952,424 - 952,424
Energy Efficiency Advisory Group 14,422 - 14,422
Special Accounting Entries
Special Accounting Entries (171,445) - (171,445)
Indirect Program Expenses Total 795,401$ -$ 795,401$
Total Expenses 30,229,460$ 8,455,107$ 38,684,566$
Adjustments
Prior year-end accounting adjustments:
2022 Commercial & Industrial Overhead (a)6,998 6,998
2022 Residential Energy Efficiency Education Initiative (b)(1,289) (1,289)
2022 Residential Energy Efficiency Overhead (c)89,680 89,680
Current year-end accounting adjustments:
2023 Irrigation Peak Rewards (d)(1,771) (1,771)
2023 Residential New Construction (e) 194 194
2023 Prudence Filing Total 30,323,272$ 8,455,107$ 38,778,378$
(a) 2022 O&M expense initially charged to the Idaho Rider. The correction was made in 2023.(b) 2022 Idaho Rider expense initially charged to O&M. The correction was made in 2023.
(c) Program administration fee charged to the Idaho Rider in 2022 and refunded in 2023.
(d) 2023 O&M expense initially charged to the Idaho Rider. The correction was made in 2024.(e) 2023 Idaho Rider expense initially charged to the Oregon Rider. The correction was made in 2024.
Idaho Power Company
2023 Idaho DSM Expenses and Adjustments for Prudence Filing
Exhibit No. 1
Case No. IPC-E-24-11
R.Z. Thompson, IPC
Page 1 of 1

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-24-11

IDAHO POWER COMPANY

THOMPSON, DI

TESTIMONY

EXHIBIT NO. 2
Program/Sector
Utility Cost Test
(UCT)
Total Resource
Cost (TRC)
Participant Cost
(PCT)
Educational Distributions 1.76 2.07 N/A
Energy Efficient Lighting1 1.69 1.51 4.07
Heating & Cooling Efficiency Program 0.94 0.40 0.88
Home Energy Reports 1.32 1.45 N/A
Multifamily Energy Efficiency Program2 N/A N/A N/A
Rebate Advantage 0.98 0.93 4.23
Residential New Construction 1.05 1.25 3.85
Shade Tree Project 0.31 0.42 N/A
Weatherization Assistance for Qualified Customers 0.14 0.23 N/A
Weatherization Solutions for Eligible Customers 0.13 0.19 N/A
Residential Energy Efficiency Sector3 1.12 0.95 3.38
Commercial and Industrial Energy Efficiency Program
Custom Projects 2.91 1.44 1.41
New Construction 2.78 2.74 3.81
Retrofits 2.35 1.17 1.53
Commercial Energy-Savings Kits1 1.02 1.17 N/A
Small Business Direct Install4 0.97 1.48 N/A
Commercial/Industrial Energy Efficiency Sector5 2.74 1.48 1.63
Irrigation Efficiency 2.05 2.22 2.29
Irrigation Energy Efficiency Sector6 2.06 2.22 2.29
Energy Efficiency Portfolio7 2.06 1.51 1.89
1 Program closed June 30, 2023.
2 Program launched on November 1, 2023 and incurred costs, but no savings were realized in 2023.
3 Residential sector cost-effectiveness excludes WAQC benefits and costs. If included, the UCT, TRC, and PCT would be 0.87, 0.74, and 2.73 respectively.
4 Program closed March 31, 2023.
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 1.97, 1.47, and 1.88 respectively.
2023 Cost-Effectiveness Summary by Program, Sector, and Portfolio
2023 Benefit/Cost Tests
Exhibit No. 2
Case No. IPC-E-24-11
R.Z. Thompson, IPC
Page 1 of 1

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-24-11

IDAHO POWER COMPANY

THOMPSON, DI

TESTIMONY

EXHIBIT NO. 3

2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 1 2014 2013 2012 2011 2010
Educational Distributions I I/P
Energy House Calls I/P I P
Heating & Cooling Efficiency Program I/P 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
Rebate Advantage I/P I I/P I
Residential New Construction 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 I P
New Construction I/P I/P I P I I P
Retrofits I/P 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 I/P O O O I O I O O I I I O P O
Flex Peak Program I/P O O O I/O O O O O I/O I/O P/O O
Irrigation Peak Rewards I/P O 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 2024-2025 Program Evaluation Plan
Exhibit No. 3
Case No. IPC-E-24-11
R.Z. Thompson, IPC
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