20060203Clarification petition and motion.pdf

825 E. Mu/tnomah St.
Portland OR 97232
,--
- PACIFICORP .- :J r;' j j : f.. i
PACIFIC POWER UTAH POWER
February 2 2006
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UTii tTi;~~; CD:"; i ;S!C;~
Idaho Public Utilities Commission
4 72 West Washington
Boise, ill 83702-5983 A-c - E-oS
Attention:Jean D. Jewell
Commission Secretary
Re:In the Matter of the Application ofPacifiCorp d.a. Utah Power & Light
Company for Approval of a new DSM cost recovery mechanism and enhanced
energy efficiency programs for Commercial, Industrial, Agricultural and
Residential Customers
PacifiCorp (d.a. Utah Power & Light Company) hereby submits for filing an original and eight
copies of its Petition for Clarification and Motion for Unconditional Approval.
Service of pleadings, exhibits, orders and other documents relating to this proceeding should be served
on the following:
Lisa Nordstrom (ISB No. 5733)
PacifiCorp
825 NE. Multnomah, Suite 1800
Portland, OR 97232
Tel: [phone]
Fax: [phone]
Email: lisa.nordstrom~pacificorp.com
It is respectfully requested that all formal correspondence and Staff requests regarding this material be
addressed to:
Bye-mail (preferred):da tareq uest~pac ifi corp. com
By regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 800
Portland, Oregon, 97232
By fax:[phone]
Sincerely,~~U4~.
D. Douglas Larson
Vice President, Regulation
Enclosures
. ;~Li
Lisa D. Nordstrom (ISB No. 5733)
P ACIFICORP
825 N.E. Multnomah, Suite 1800
Portland, OR 97232
Tel: [phone]
Fax: [phone]
Email: lisa.nordstrom~pacificorp.com
Attorneys for PacifiCorp
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
PACIFICORP DBA UTAH POWER & LIGHT ) CASE NO. PAC-05-
COMPANY FOR APPROV AL OF A NEW
DSM COST RECOVERY MECHANISM AND )
ENHANCED ENERGY EFFICIENCY PETITION FOR CLARIFICATION
PROGRAMS FOR COMMERCIAL AND MOTION FOR
INDUSTRIAL, AGRICULTURAL AND UNCONDITIONAL APPROVALRESIDENTIAL CUSTOMERS
COMES NOW, PacifiCorp, d/b/a Utah Power & Light Company ("PacifiCorp" or the
Company ), in accordance with RP 325 and RP 056, and hereby requests that the Idaho Public
Utilities Commission (the "Commission ) clarify its Order No. 29952 or, in the alternative
unconditionally approve the proposed demand-side management ("DSM") program offerings
and tariff rider requested in this docket. PacifiCorp s Petition for Clarification and Motion for
Unconditional Approval are based on the following:
I. PROCEDURAL HISTORY
On September 6, 2005 , PacifiCorp filed an Application requesting Commission approval
of a portfolio of energy efficiency and DSM programs for its commercial, industrial, agricultural
and residential customers in the state of Idaho. The Company also requested approval of a cost
recovery mechanism and related deferred accounting authorization. On September 30, 2005 , the
Commission issued a Notice of Application in this docket. The Commission Staff conducted
public workshops in Preston and Rigby, Idaho in October 2005 prior to the Commission holding
public hearings in Rexburg and Preston, Idaho in November 2005.
After receiving public testimony and comments filed by Staff and customers, the
PETITION FOR CLARIFICATION AND
MOTION FOR UNCONDITIONAL APPROVAL
Commission issued Order No. 29952 on January 12, 2006. While supporting PacifiCorp
pursuit of cost-effective DSM and energy efficiency programs, the Commission was concerned
that potential DSM residential program benefits were disproportionate to the funds to be
collected from the residential class. Thus, the Commission approved the Application subject to
the filing of a "specific program proposal" addressing this issue with the following ordering
paragraph on page 10 of Order No. 29952:
In consideration of the foregoing and as more particularly
described and qualified above, IT IS HEREBY ORDERED and the
Commission does hereby approve conditionally the Application of
PacifiCorp in Case No. PAC-05-10 subject to program filing,
review and approval.
The Commission also indicated that it was "prepared to adopt a one and half percent (1.5%)
tariff rider with no caps to fund PacifiCorp s energy efficiency and DSM programs once a
program plan has been filed, reviewed and approved.Id.
II. PETITION FOR CLARIFICATION AND
MOTION FOR UNCONDITIONAL APPROV AL
To best address the Commission s concerns and enable the Company to properly
administer its Idaho DSM programs, PacifiCorp seeks clarification on the following issues:
Does the Commission s conditional approval extend to all new program
offerings in the Company s Application, or merely to the 1.5% tariff rider?;
and
Does the Commission s conditional approval allow the Company to initiate
new programs with the effective date of January 12, 2006 and begin directing
costs, as they occur, into a DSM balancing account for eventual recovery
through the tariff rider mechanism once implemented?
In Section IV below, PacifiCorp presents a "program plan" as referenced on page 10 of
Order No. 29952 that describes the Company s proposed residential program offerings, an
PETITION FOR CLARIFICATION AND
MOTION FOR UNCONDITIONAL APPROVAL
equitable application of tariff funds to all customer classes, and a timeline for program
implementation. Assuming the Commission finds PacifiCorp s program proposal acceptable, the
Company requests that the Commission approve its program offerings and tariff rider without
condition.
III. BACKGROUND
PacifiCorp appreciates the Commission s general support of its DSM Application and
seeks to present a plan that addresses the Commission s concern regarding customer class
equity/access to tariff rider funding and Staffs concern that tariff rider funding may be
insufficient to support the forecasted program costs.
PacifiCorp s Application called for the introduction of three new programs, the
enhancement of two existing programs, closing two programs to "new service " and the creation
of a tariff rider funding mechanism to fund DSM investments on a prospective basis. The
Application stated that business programs were forecasted to consume approximately 87% of the
available funding compared to 13% for residential programs. Reference Appendix 1 - Original
Attachment 1 - Table 1 for more information on the cost and savings projections, as well as the
suite of programs initially proposed by PacifiCorp in its Application. Given that residential
customers were forecasted to contribute 39% of the funding through the tariff rider, the
Commission determined in Order No. 29952 that too much disparity would exist between
residential spending opportunity and funding contribution.
Staff Comments filed November 3 2005 noted that the Company s program spending
projections posed a second concern: that PacifiCorp forecasted program expenditures at a level
greater than the funding of the 1.5% tariff rider could support over the three-year projection
period. PacifiCorp acknowledged this as a possibility but believed this concern was manageable
for several reasons. First, although program costs were estimates based on the best information
at hand, actual program costs would be subject to market acceptance and may vary. Second, the
speed at which program awareness and participation would occur was also an estimate. Third
the Company has experience managing outreach activities and vendor relationships to influence
to some degree the activity commensurate with available funding. PacifiCorp also envisioned
that after 20-24 months of program implementation that both the Commission and Company
would be in a better position to review the adequacy of the 1.5% tariff rider collection
PETITION FOR CLARIFICATION AND
MOTION FOR UNCONDITIONAL APPROVAL
mechanism and discuss possible adjustments if appropriate.
After analyzing the impacts of filing a supplemental residential program proposal "
quickly as possible" per the Commission s direction in Order No. 29952, coupled with the
delayed implementation of the tariff rider, PacifiCorp is concerned that it may not be able to
comply with the Commission s request and still effectively manage the uncertainty in market
acceptance of the programs and their associated costs. As a result, PacifiCorp recommends
changes to the original implementation plan described in the Application filed September 6
2005 , as described in Section IV below.
IV. AMENDED PROGRAM IMPLEMENTATION PLAN
PacifiCorp respectfully submits the following amended implementation plan for
Commission consideration:
1. Defer the implementation of the Energy FinAnswer program until a later date, relying
more heavily on its companion program, FinAnswer Express, to address the needs of
the commercial and industrial customer sectors.
Deferring the implementation of the Energy FinAnswer program will free up sufficient
funding to allow for the expedited introduction ofthe supplemental residential proposal, the
Home Energy Efficiency Incentive program. This will provide greater flexibility in managing
the overall DSM program costs and reduce non-residential program costs to better address the
disproportionate residential benefit concern.
PacifiCorp continues to believe that the Energy FinAnswer program is a solid performer
and customers would find it helpful in enabling them meet their energy efficiency objectives.
PacifiCorp s plan is to defer, not eliminate, this program introduction into the Idaho market. The
Company would revisit the possible introduction of the program in approximately 12 months
once it can better assess long-term funding needs based the market performance of the remaining
programs.
Add the tarifflanguage "subject to funds availability" to business programs in order
to better manage potential requests for services from the business sectors that, if left
unchecked, could exceed forecasts and near-term funding availability.
PETITION FOR CLARIFICATION AND
MOTION FOR UNCONDITIONAL APPROV AL
Submit the final tariffs for the new and revised programs contained within the
Application (less the Low Income Weatherization program tariff!) with effective
dates of January 12, 2006. In addition, the Company would insert minor language
and symbol changes to accommodate for item #2 above and correct errors found
within the draft tariffs previously provided. With the exception of item #2 above
these corrections have been reviewed with Staff. The final tariffs to be submitted
are:
Schedule 155 - Irrigation Efficiency Program
Schedule 115 - FinAnswer Express Program
Schedule 117 - See Ya Later Refrigerator Program
Schedules 120/122 - Commercial Energy Services Programs (closing these to new
service)
Accelerate the introduction of the residential Home Energy Efficiency Incentive
program from July 2006 to May 2006. PacifiCorp anticipates filing the program for
Commission review and approval in April 2006. This newly proposed program is
described in further detail in the summary of residential offerings below.
Defer the implementation ofthe tariff rider from January 2006 to May 1 2006, to
adjust for the delayed implementation of the overall program portfolio and to better
correspond to the timeframe when the Home Energy Efficiency Incentive program
will become available.
For comparison purposes, reference Appendix 2 - Amended Attachment 1 - Table 1 for more
information on the cost and savings projections and suite of programs proposed in this amended
implementation plan. The table has been adjusted based on changes in program mix, increased
emphasis on residential programs, and differences in timing of program costs and funding
revenues.
In making these adjustments, PacifiCorp addresses both the customer equity issue as well
as Staffs forecasted expenditure issue. Based on the proposed changes in the implementation
plan over the first three years of the program portfolio, residential customers are forecasted to
contribute approximately 39% of the dollars and receive 36% of the benefit dollars, while
1 Final drafts ofthe Low Income Weatherization program, Schedule 21, were submitted February 1 2006 with an
effective date of January 12, 2006. The revised program is now available to customers.
PETITION FOR CLARIFICATION AND
MOTION FOR UNCONDITIONAL APPROV AL
business customers would contribute 61 % of the dollars and are forecasted to receive 64% of the
dollars. Spending over the three-year period is projected to average 1.55% of retail revenue
much closer to the 1.5% tariff rider collection rate approved by the Commission and within a
range the Company believes it can responsibly manage.
V. RESIDENTIAL PROGRAMS
In further support of the amended implementation plan proposed above, and in response
to the Commission s request for a more comprehensive program proposal for residential
customers, PacifiCorp offers the following supplemental information on the See Ya Later
Refrigerator program and soon-to-be-filed residential Home Energy Efficiency Incentive
program. It is the Company s hope that this additional information will demonstrate to the
Commission that ample opportunity now exists for residential customers to fully participate in
DSM programs, resulting in both the near-term bill savings and longer-term reduced system
costs.
See Ya Later Refrigerator program:
This program removes older, less efficient refrigerators and freezers from customer
homes (and the electrical grid) and recycles them to insure they are not re-sold (and re-connected
to the grid). Refrigerators available today use about 40% less energy than models manufactured
as recently as 15 years ago, resulting in an average per unit savings of 1 000 kWh. According to
Company survey data, 14% ofldaho s 48 000 residential customers have a second refrigerator.
The same data indicates 72% have a stand-alone freezer. These customers may request See Ya
Later Refrigerator program services by calling a toll-free number. The third-party
implementation contractor handles all services related to picking up the equipment, recycling it
and disbursing the customer incentive payment. The proposed implementation contractor for
Idaho is the same one that currently delivers the program in Utah (and has since June 2003),
where 99% of participating customers reported they were "very satisfied" or "satisfied" with
program services during the most recent evaluation. The vendor also began delivering the
program within the Company s Washington service area in April 2005 and has been met with
positive customer participation.
The benefit-to-cost ratios for this program are strong - more than $3 in benefits are
PETITION FOR CLARIFICATION AND
MOTION FOR UNCONDITIONAL APPROV AL
projected for each $1 in program costs. These benefit-to-cost results are the highest of the
proposed Idaho programs within any customer class. Third-party evaluation results for two
program years in Utah demonstrate similar robust benefit-to-cost ratios. Other utilities that have
run or are running refrigerator retirement programs include the Los Angeles Department of
Water & Power, Southern California Edison, Pacific Gas & Electric Company, Nevada Power
Company, Puget Sound Energy, and Snohomish County Public Utility District.
Home Energy Efficiency Incentive program:
This newly proposed program will provide a broad platform to deliver incentives for
more energy efficient products and services to be installed or received by Idaho residential
customers with a new or existing home. While the product and service mix is undergoing
comprehensive analysis, broad categories under consideration include appliances, water heaters
lighting, heating and cooling equipment, windows, and insulation.
This program is being designed to leverage marketing and delivery through local businesses and
service providers to minimize costs and direct the largest share of the program budget to
incentives. To this end, two incentive delivery options will be employed: 1) a retailer buy-down
for lighting equipment, resulting in the retailer offering a lower price to the customer, and 2) a
post-purchase delivery for all other types of equipment or services. Incentives for some
measures may be offered seasonally to complement other offerings, while others will be offered
year round. Proof of professional installation will be required where necessary to insure energy
savings. Measure mix and specifications will be reviewed and adjusted on a regular basis to
reflect sales volumes, codes and standards, and program impacts. The Home Energy Efficiency
Incentive program is currently forecasted to spend over 40% of the three-year residential
program spending estimates (for all residential programs combined) and contribute over 50% of
the residential program energy savings (again, for all residential programs combined). The
program is on a design path to be available to Idaho residential customers in May 2006
contingent on approval of the final program by the Commission. For more information on the
Home Energy Efficiency Incentive program and other programs within the Company s amended
implementation plan refer to Appendix 2 - Amended Attachment 1 - Table
PETITION FOR CLARIFICATION AND
MOTION FOR UNCONDITIONAL APPROV AL
VI. CONCLUSION
PacifiCorp believes that the evidentiary record in this proceeding is sufficient for the
Commission to issue its Order clarifying Order No. 29952 as requested above or, in the
alternative, unconditionally approve the tariff rider and proposed program offerings in
PacifiCorp s Application based upon the program plan discussed herein. Because an extended
period for clarification could impact the availability ofthe new program offerings for irrigation
customers this season, PacifiCorp requests that the Commission expedite its review of this
Petition to whatever extent possible.
The Company respectfully requests that the Commission clarify Order No. 29952 in the
manner described above or, in the alternative, approve PacifiCorp s program offerings and tariff
rider without condition if its program plan satisfies the Commission s concerns identified in that
Order.
Dated this 2nd day of February, 2006.
Respectfully submitted
ae~ IJ
1L Lisa D. Nordstrom
Attorney for PacifiCorp
PETITION FOR CLARIFICATION AND
MOTION FOR UNCONDITIONAL APPROV AL
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 2nd day of February 2006, I served a true and correct
copy of the within and foregoing PETITION FOR CLARIFICATION AND MOTION FOR
UNCONDITIONAL APPROVAL upon the following named parties by the method indicated
below, and addressed to the following:
Jean Jewell, Commission Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720-0074
Boise, ID 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
~~
?Z~Lisa D. Nordstrom
Attorney for PacifiCorp
PETITION FOR CLARIFICATION AND
MOTION FOR UNCONDITIONAL APPROVAL
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