20060901Petition.pdf

~ ~~~
~OUNTAIN RECEIVED
200& SEP : I AI1 9:
201 South Main, Suite 2300
Salt lake City, Utah 84111
September 1 , 2006
ID/\HO PUBLIC
UTILITIES COi''Ii',dSSION
VIA FEDERAL EXPRESS
Idaho Public Utilities Commission
472 West Washington
Boise, ill 83702-5983 PAC-t.--CJb-
Attention:Jean D. Jewell
Commission Secretary
Re:In the Matter of the Petition ofPacifiCorp to Determine the Appropriate Payment
Structure of Schedule 21
PacifiCorp (d.a. Rocky Mountain Power) hereby submits for filing an original and seven copies of its
Petition of PacifiCorp to Determine the Appropriate Payment Structure of Schedule 21.
Service of pleadings, exhibits, orders and other documents relating to this proceeding should be served on
the following:
Dean Brockbank
PacifiCorp
201 South Main Street, Suite 2200
Salt Lake City, Utah 84111
Dean. Brockbank(fYPacifi Corp. com
Brian Dickman
PacifiCorp
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Brian.Di ckman(fYPacifi Corp. com
It is respectfully requested that all formal correspondence and Staff requests regarding this material be
addressed to:
Bye-mail (preferred):datarequest~pac ifi corp. com
By regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon, 97232
By fax:[phone]
Sincerely,
f\
~)
f)O1J'1,l#~ t'\/I/1.-1/I/'"
D. Douglas farson V~/
Vice President, Regulation
Enclosures
Dean Brockbank
PacifiCorp
201 South Main Street, Suite 2200
Salt Lake City, Utah 84111
Telephone: [phone]
FAX: [phone]
Dean. Brockb ank((l),Pacifi Corp .com
Attorneys for PacifiCorp
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
ACIFICORP TO DETERMINE THE
APPROPRIATE PAYMENT STRUCTURE OF SCHEDULE 21
CASE NO. P AC-O6-
PETITION FOR DECLARATORY
ORDER
COMES NOW, PacifiCorp, d/b/a Rocky Mountain Power ("PacifiCorp" or the
Company ) and, pursuant to Rule of Procedure 1 0 I , hereby petitions the Idaho Public Utilities
Commission ("IPUC" or the "Commission ) to issue an Order confirming that PacifiCorp
current Schedule No. 21 , as approved in Order No. 29952 and Tariff Advice 06-, continues to
be just and reasonable and in the public interest. This Petition is based on the following:
In Commitment I13b adopted in Order No. 29998, Case No. PAC-05-, the Company
agreed to include in the direct testimony of its next general rate case an analysis of the costs and
benefits of changing its current practice of matching 50 percent of federal contributions for low-
income weatherization measures to matching at a higher percentage amount. Commitment I13b
was accepted based on a previous stipulation in Case No. P AC- E-05-, Order No. 29833, which
proposed a general rate case was to be filed by the Company no later than April 29, 2006 to
address an unresolved and unrelated cost of service issue.
PETITION OF P ACIFICORP
II.
On June 21 2006, the Company made three applications with the Commission to adjust
rates for tariff Schedule Nos. 10 400, and 401 (Case Nos. P AC-06-, P AC-06-, and P AC-
06-9). The above applications are based on settlement agreements reached between
PacifiCorp and the representatives of customers served under the respective rate schedules.
PacifiCorp contends that, pending Commission approval of the applications, a general rate case
would no longer be needed during 2006.
In an attempt to honor its commitment made in Case No. P AC-05-, the Company
sought agreement from the Community Action Partnership Association of Idaho ("CAP AI") to
address the issues raised in Commitment I13b in a filing other than a general rate case. Such an
agreement was reached, and on June 19 2006, the Company and CAPAI executed the stipulation
attached hereto as Exhibit 1. As part of the stipulation PacifiCorp agreed to make this filing
before the Commission no later than September 1 , 2006. PacifiCorp also agreed to (1) contribute
$10 000 each to SouthEastern Idaho Community Action Agency ("SEICAA") and Eastern Idaho
Community Action Partnership ("EICAP") to be used as energy assistance for the Lend-a-Hand
program during the 2006-2007 heating season, and (2) support legislation sponsored by CAP AI
during the 2007 Idaho general legislative session that would give the Commission authority to
approve discount rates for low-income customers that are requested by utilities.
III.
PacifiCorp has had programs in place to assist households in financial crisis with their
energy needs for many years. Its Low Income Weatherization program has been in effect since
1988 with over 600 homes completed to date. The Company has also donated, and solicited
donations, to the Lend-a-Hand energy assistance program for many years through envelopes
PETITION OF P ACIFICORP
distributed in November and February billings. PacifiCorp has matched all contributions to
Lend-a-Hand since November 2000. PacifiCorp recognizes the importance of providing
services to households with limited income. This is also illustrated by the additional low-income
commitments described in Section V below.
PacifiCorp partners with EICAP in Idaho Falls and SEICAA in Pocatello to provide
energy efficiency services at no cost to income-qualifying households through its Low Income
Weatherization Program (Schedule No. 21). This program is a demand side management
DSM") program intended to reduce electricity consumption and monthly bills by increasing the
efficiencies oflow-income homes. PacifiCorp reimburses the agencies 50 percent of the cost of
installing approved measures while matching federal grants are available to the agencies so that
the services are provided at no charge to participating households.
Pursuant to Commitment I13a, Case No. P AC-05-, and as approved by the
Commission in Tariff Advice 06-, effective August 2006 PacifiCorp will reimburse the
agencies up to 100 percent of the cost of installing approved measures if government funds are
exhausted. Also effective August 1 , 2006 , the previous maximum average investment per
household of $1 ,500 is no longer applicable. Instead, PacifiCorp will reimburse costs as
described above with no maximum or average payment applied, providing the partnering
agencies more flexibility in administering the program. The Company also continues to
reimburse its partnering agencies 15 percent of the Company s rebates on each completed home
to cover their administrative costs. Total PacifiCorp funding available is subject to a cap of
$150 000 annually.
IV.
As a DSM program, funding for Schedule No. 21 is recovered from utility customers
PETITION OF P ACIFICORP
through the Schedule No. 191 Customer Efficiency Services Rate Adjustment. PacifiCorp
provides financial assistance to its partnering agencies on approved measures under Schedule
No. 21. The agencies use a Department of Energy approved audit to determine if shell measures
including insulation and window replacements, are cost effective in electrically heated homes.
Other measures are available to increase electric efficiencies such as water heating measures in
homes with electric water heaters and efficient lighting and refrigerators in all homes.
PacifiCorp previously provided the Commission an analysis of the Low Income
Weatherization Program in support of proposed program revisions in September 2005. That
analysis included the results of a cost effectiveness study and is provided with this petition as
Exhibit 2 (refer to page 11-2 for cost effectiveness calculations). At that time and under the
reimbursement policy of 50 percent matching rebates, the program narrowly passed the Utility
Cost Test under the IRP Decrement approach for quantifying the expected benefits.
If the reimbursement portion is increased, the Company is concerned that fewer
PacifiCorp customers will be provided weatherization services. An increase in the Company
reimbursement would mean a larger percentage of program costs would be covered through
funds collected from Schedule No. 191 and a smaller percentage through federal tax funds.
Because total program expenditures are capped, the total cost to the utility would remain
relatively unchanged, but the benefits of the program would be reduced due to fewer homes
receiving installed measures. Not only would fewer low-income customers in the Company
service area receive energy efficiency services, but the benefit of reduced energy usage and
lower incremental power costs would no longer be shared by PacifiCorp s Idaho customers
making the program less cost effective. In fact, the benefits of the energy efficiency services
could be shifted to customers of another gas or electric provider through federal funds no longer
PETITION OF P ACIFICORP
available to PacifiCorp customers. PacifiCorp believes that the costs and the benefits of the
weatherization program should be aligned and that the cost effectiveness ofthe program should
be maintained.
As an example, if on average the cost of completing energy efficiency services on a
qualifying home is $3 000, the Company s reimbursement for measures plus the 15 percent
administrative cost rebate would total $1 725. At this rate, 87 homes could be completed with
PacifiCorp s annual budget of $150 000. Reimbursement of 75 percent of costs under this
scenario results in the potential completion of 58 homes, and reimbursement of 100 percent of
costs results in only 45 homes completed annually. This example illustrates that considerably
fewer PacifiCorp customers would benefit from these energy efficiency services if the funding
policy is revised.
An updated cost effectiveness analysis is provided as Exhibit 3. This update provides
cost effectiveness results under three reimbursement scenarios:
PacifiCorp reimburses 50% of costs, federal funding covers 50%
PacifiCorp reimburses 75% of costs, federal funding covers 25%
PacifiCorp reimburses 100% of costs, federal funding covers 0%
As shown in Table 3 of Exhibit 3 , under a 50 percent reimbursement scenario the program
continues to pass the Total Resource Cost Test and the Utility Cost Test. Under a 75 percent
reimbursement scenario, the program no longer passes the Utility Cost Test (Table 6). And
finally, under a 100 percent reimbursement scenario, the program fails both the Total Resource
Cost Test and the Utility Cost Test (Table 9).
As stated in Section III of Exhibit 2, PacifiCorp plans to have an impact evaluation
completed on program results once the Low Income Weatherization Program revisions approved
in January 2006 (Order No. 29952) have been in place for two years. The evaluation plan is
PETITION OF P ACIFICORP
included in Section III of Exhibit 2. The Company will review these results in 2008 to determine
if program changes should be made, including changes to the reimbursement policy. In addition
the Company will file a report by May I of each year, beginning May 2007 detailing its Idaho
DSM activities and program cost effectiveness, including the Low Income Weatherization
Program.
PacifiCorp has a variety ofprojects in place and under development to assist low-income
customers. Providing weatherization services is an important component in its mix of offerings.
The Company made three additional commitments in Case No. P AC- E-05-8 that will benefit
low-income households. In Commitment 114, PacifiCorp committed to a total contribution level
from all sources to low-income bill payment assistance in Idaho of $40 000 annually for a five
year period beginning July 1 , 2006. This ongoing contribution will substantially increase annual
funds. Through Commitment 115 PacifiCorp will provide shareholder funding to study an
arrearage management project. In Commitment 141 , PacifiCorp agreed to initiate a collaborative
effort to track low-income issues by identifying and collecting data pertinent to low-income
customers in the Company s Idaho service area.
VI.
The current 50 percent reimbursement policy is consistent with the low-income
weatherization programs the Company offers in its other service areas. This policy allows
customers to receive benefits from their tax dollars as well as cost-effective services from this
demand-side management program. Using federal grants to cover 50 percent of program costs
provides benefits to all PacifiCorp customers in Idaho regardless of income or participation in
the Low Income Weatherization Program because all customers benefit from cost effective
PETITION OF P ACIFICORP
energy efficiency investments. PacifiCorp requests that the Commission determine the current
payment structure is appropriate based on the reasons stated above.
VII.
Service of pleadings, exhibits, orders and other documents relating to this proceeding
should be served on the following:
Dean Brockbank
PacifiCorp
201 South Main Street, Suite 2200
Salt Lake City, Utah 84111
Dean. Brockb ank0),P acifi Corp. com
Brian Dickman
One Utah Center, Suite 2300
201 South Main
Salt Lake City, UT 84111
Brian.Di ckman0),P acifi Corp. com
In addition, it is respectfully requested that all formal correspondence and Staff requests
regarding this material be addressed to:
datarequest((j)pacificorp. com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
VIII.
WHEREFORE, PacifiCorp respectfully requests the Commission determine and declare
that PacifiCorp s current Schedule No. 21 , as approved in Order No. 29952 and Tariff Advice
06-, continues to be just and reasonable and in the public interest. PacifiCorp will follow this
petition with direct testimony sponsored by a Company witness, to be filed by September 15
2006. PacifiCorp requests that this Petition be processed under modified procedure pursuant to
Rules 201 through 204 of the Commission s Rules of Procedure.
PETITION OF P ACIFICORP
Respectfully submitted this 1st day of September 2006.
By D~ r1"kJ~kln",4.
/ '
Dean Brockbank --('1- /
Attorney for PacifiCorp
PETITION OF P ACIFICORP
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 31 th day of August 2006, I served a true and correct
copy of the foregoing PETITION upon the following named parties by the method indicated
below, and addressed to the following:
Brad Purdy
Attorney at Law
Community Action Partnership Association
ofIdaho
2019 N. 1 ih Street
Boise, ill 83702
Hand Delivered
u.S. Mail
Overnight Mail
FAX
~t'--L1~,\ ?--i)L\.u.
Shelley Zoller
Regulation Department
PETITION OF P ACIFICORP
ACIFICORP DBA
ROCKY MOUNTAIN POWER
CASE NO. PAC-O6-
EXHIBIT NO.
IS CO NFID E NTIAL
Case No. P AC-06-
Exhibit No.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
P ACIFICORP
Idaho Low Income Weatherization Program:
Analysis in Support of Tariff Revision
September 2006
Final
Idaho Lo"" Income
Weatherization Program:
Analysis in
Support of Tariff Revision
Prepared for:
PacifiCorp
August 2005
Quantec Offices
6229 SE Milwaukie Ave.
Portiand, OR 97202
[phone]
[phone] fax
www.quantecllc.com
3445 Grant SI.
Eugene, OR 97405
[phone]
[phone] fax
1722 14th St., Suite 230
Boulder, CO 80302
[phone]
[phone] fax
6 Ridgeland Rd
Barrington, RI 02806
[phone]
[phone] fax
Prepared by:
Brian Hedman
M. Sami Khawaja, Ph.D.
Quantec, LLC
212 E Main SI., Suite G
Reedsburg, WI 53959
[phone]
[phone] fax
20022 Cove Circle
Huntington Beach, CA 92646
[phone]
~Pri"""'"~"",.dp-
Table of Contents
Program Description ........................................................ 1-
Other Program Costs.............................................................................. 1-
II.
III.
Cost Effectiveness...... ....................... .............................. 11-
Evaluation Plan ............................................................... 111-
Impact Evaluation........ ..........
......... ......... ........ .............. .....................
111-
Management & Reporting................................................................... III-
Timeline .............................................................................................. 111-
Appendix A. EP A Guidelines..................................................
Safe Disposal Requirements................................................................ A-
Section 608 of the Clean Air Act of 1990............................................ A-
low-Income Weatherization Program
Analysis in Support of Tariff Filing 08/22/05
Program Description
The current Low Income Weatherization Program has been in place for over
ten years. It is available to Utah Power customers with incomes at or below
150% of federal poverty guidelines that have installed electric heating
systems. Services are provided at no cost to participants because partnering
agencies are able to leverage Utah Power funding with federal and state funds
they receive. Utah Power offers rebates directly to the Eastern Idaho Special
Services Agency and the SouthEastern Idaho Community Action Agency
Agencies ) that administer the Program. The average annual number of
completions during the period 2000 through 2004 is 23.
Utah Power in consultation with their two partnering non-profit agencies is
proposing revisions to the current program (Schedule 21). There are four
goals to this effort.
1. To increase Utah Power customer participation numbers.
2. To provide incentives for the installation of additional cost effective
measures.
3. To offer rebates on measures that reduce electricity consumption in
homes regardless of heating source.
4. To reimburse agencies for services up to two times per home, one
time per measure. This allows the installation of new technologies
and/or measures that previously were not considered cost effective.
The agencies provided expected participation rates for the revised program
based on their historic weatherization program experience. Estimates are
presented in Table 1.1.
Table 1.1: Expected Annual Participation Rates
Electric Base Load Program Participants
Electrically Heated Homes
170
Proposed Rebates: The following summarizes Utah Power s proposed
reimbursement available to the Agencies for the installation of approved
measures and reimbursement on administrative costs:
A rebate averaging up to $1 500 per home annually (April 1 through March
31) will be provided towards the cost of installed qualifying Major and
Supplemental Measures. The following measure categories will be eligible for
rebates:
low-Income Weatherization Program
Analysis in Support of Tariff Filing 08/22/05
Weatherization Measures in Electrically Heated Homes
Compact Fluorescent Light Bulbs (CFLs)
Refrigerator Replacements
Water Saving Measures in Homes with Electric Hot Water Heaters
Weatherization
Major Measures with a Savings to Investment Ratio (SIR) of 1.0 or greater are
required (based on results of the State of Idaho Weatherization Energy
Analysis) on homes with an electric heating system that is operable and
permanently installed with the capacity to heat at least 51 % of the dwelling. If
physical barriers exist that prohibit the installation of a measure, the measure
is not required. A list of qualifying measures follows. Greater R-values than
listed below may be installed as long as audit results show it to be cost
effective:
Insulation up to R-48 for ceilings with less than R-30 in place.
Floor insulation over unconditioned spaces up to R-
Insulation (not urea-formaldehyde) up to R-26 for walls without insulation
installed
Class 40 replacement windows
Supplemental Measures qualify for a rebate when they are determined to be
cost effective.
Funding is available on the following Supplemental Measures installed in
electrically heated homes:
Attic ventilation when installed with ceiling insulation
Ground cover and water pipe insulation when installed with floor
insulation
Forced air electric space heating duct testing, insulation, and sealing in
unconditioned spaces
Weather stripping and/or caulking including blower door assisted air
sealing and duct sealing
Thermal doors
Timed thermostats on centrally controlled multi-room heating/cooling
systems
Funding is available on the following supplemental measures installed in all
homes:
Compact fluorescent light bulbs - limit 8 Energy Star certified bulbs per
home placed in fixtures that are on 2 hours or more per day.
low-Income Weatherization Program
Analysis in Support of Tariff Filing 08/22/05
Refrigerators identified in the Weatherization Assistance Program
Technical Assistance Center (W APT AC) database as having mean annual
usage of 900 kWh or greater may be replaced with an Energy Star model
with estimated annual consumption of 500 kWh or less. Replaced
refrigerators must be removed and recycled in accordance with EP A
guidelines.
Pipe insulation, energy-efficient showerheads, and aerators for homes with
an electric water heater.
Administrative Cost Reimbursement will be provided at 15% of Utah Power
reimbursement for Major and Supplemental Measures with a minimum of
$150 on homes with at least one major measure installed and $50 on homes
without the installation of a major measure, not to exceed the following per
building (Table 1.2).
Table 1.2: Program Administration
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. "
Maximum
: "...'
we 1n9 n 1n9.,
, p .':" """""",' "" ""'" '" ""' "" "", '
' aymen
Minimum Payment - $150
w/major measure, $50 without
major measure
1 to 4 $350
5 to 10 $800
11t015 200
16 to 20 $1,400
21 to 25 600
26 to 30 800
31+100
Table 1.3 displays the assumptions used in the Program design and in
conducting cost-effectiveness analysis. The u.S. DOE estimates the average
cost per home throughout the nation is $2 744 (based on the 2005 DOE
Weatherization Guideline). The average total cost of homes completed
through the Utah Power program in 2004 was $1 678. Expected savings are
based on an Oakridge National Laboratory study of weatherization programs.
These savings include the Major Measures and Supplemental Measures with
the exception of CFLs, and refrigerator replacements, which are separately
estimated below. We used a 30-year economic life for the weatherization
component of the Program. Overall weatherization measures were assumed to
have a 30-year economic life.
low-Income Weatherization Program
Analysis in Support of Tariff Filing 08/22/05
Table 1.3: Weatherization Assumptions
...
"I.ii.'.. Inputs,
' '
Dat~s()urCe Estimate'l()utP4is.1111'11.'.111'1 IIICalculatio"..
Number of Homes Annually Agencies Total Annual Savings (kWh)150 710
Total Utah Power Annual Contribution $15 750
National Average Total Cost S. DOE $2,744 to Admin Cost
IAverage Total Savings (kWh) *ORNL ICON-488 153 Total Utah Power Annual Rebate $105 000
0212003
~verage Admin Cost Utah Power $225 Total Annual Utah Power Cost $120,750
~verage Rebate per Home Utah Power 500 Total Annual Cost $192 080
* Includes Major Measures and Supplemental Measures except as noted below.
Compact Fluorescent Light Bulbs (CFL)
Utah Power will pay 50% of the bulb cost for up to eight ENERGY STAR (ID
certified CFLs per home, to be placed in lighting fixtures that are in use for
two or more hours/day. Table 1.4 displays the assumptions used in the CFL
portion of the Program and in conducting cost-effectiveness analysis.
Estimates of CFL cost were derived from several other recent programs. The
average wattage of replaced bulbs, installed bulb wattage, and expected
number of hours of use were derived from PacifiCorp s evaluation of its CFL
program in Utah. The total number of CFLs to be installed is determined by
multiplying the expected participation level from Table 1.1 (170 households)
by eight. The program requirements will limit installations of CFLs to
locations with at least two hours of use per day. With a minimum of two hours
per day, we assumed an overall average use time of three hours per day across
the installed CFLs. Average energy savings as a result of CFL replacement is
calculated as the difference in wattage between the average incandescent light
bulb (70 Watts) and the replacement CFL (20 Watts), multiplied by hours of
use per day (3 hours) and days per year (365). This product is then converted
to kWh by dividing by 1 000. The economic life of a CFL light bulb (9 years)
is determined by assuming 10 000 hours of burn time divided by the annual
hours of use (10 000/(3*365)). Agency administrative payments are limited to
15% of the Utah Power estimated contribution of$1 700.
low-Income Weatherization Program
Analysis in Support of Tariff Filing
1-4
08/22/05
Table 1.4: CFL Assumptions
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No. CFLs per Home Program Total Annual No. CFLs 360
Average Cost per CFL Various $2.Avg. CFL Savings (kWh)54.
Average Existing Wattage Utah Eva!.Total Annual Savings (kWh)74,460
Average New Wattage Utah Eval Total Utah Power Annual $255
Contribution to Admin Cost
Total Utah Power Rebate $1,700
Average No Hours per Day Utah Eva!.Total Annual Utah Power Cost 955
Total Annual Program Cost 655
Rebate as % of CFL Cost Utah Power 50%Economic Life (Years)
Refrigerators
Refrigerators can be replaced where existing models are listed in the
W APTAC database as having annual mean usage of 900 kWh or greater.
Replacement refrigerators will be ENERGY STAR-certified models with
annual consumption levels of 500 kWh or less. Replaced refrigerators will be
removed and recycled according to Environmental Protection Agency (EP
guidelines. 1
Table 1.5 displays the assumptions used in the refrigerator replacement portion
of the Program and in conducting cost-effectiveness analysis. The
consumption data are based on metered units from a similar program run in
Utah during 2003. We assumed a 19-year economic life for a new refrigerator.
Utah Power s total annual cost is set at 50% of the cost of replaced
refrigerators. As mentioned above, the administration fee is limited to 15% of
Utah Power contribution.
Existing refrigerators consuming over 900 kWh annually can be cost-effectively
replaced. For detailed information concerning EP A Guidelines, please refer to Appendix
low-Income Weatherization Program
Analysis in Support of Tariff Filing 08/22/05
Table 1.5: Refrigerators Assumption
Inputs
. .'
, s
Data Estimate
. .
Outputs
. ..
Estimateource
' ," "
Number of Refrigerators Tested Agencies 153 No. Refrigerators Replaced
Proportion ofTested Replaced Utah Pgm 44%Avg Annual Savings (kWh)510
Avg Cost per New Unit Agencies $600 Total Annual Savings (kWh)101 653
Avg Cost Per Tested Unit Agencies Total Annual Equip Cost $40 800
Avg Consumption of Existing Unit (kWh)Utah Pgm 944 Total Annual Testing Cost
~vg Consumption of New Unit (kWh)Utah Pgm 434 Total Utah Power Contribution 060
to Admin Cost
Rebate as % of Unit Cost Utah Power 50%Total Utah Power Rebate $20,400
Economic Life (Years)Total Annual Utah Power Cost $23,460
Total Annual Cost $43 860
. The WAPT AC database will be used in lieu of testing
Hot Water Measures
Table 1.6 displays the assumptions used in the design of the hot water portion
of the Program, and in conducting cost-effectiveness analysis. The segment of
clients likely to have gas heat with electric hot water was estimated at 10%
(approximately 17 households). The program will install low-flow
showerheads, kitchen and bathroom aerators and pipe wraps for these
customers. Energy savings estimates were obtained from the evaluation of the
2002 California Low Income Energy Efficiency program . As in the
components above, Utah Power s contribution to administration cost will be
limited to 15% ofthe total rebate amount for measures installed.
Table 1.6: Hot Water Measure Assumptions
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Input~
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Calculation
Percent of Participants with gas heat and Agencies 10% Annual Participants
ralectric hot water
Showerhead savings (kWh)2002 CA LlEE 230 Total Annual Savings (kWh)749
Aerators (kWh)2002 CA LlEE Total Annual Utah Power $97
Contribution to Admin Cost
Pipe Wrap 2004 CA DEER Total Annual Utah Power $323
Rebate
Measure Cost Iowa LI Pgm $38 Total Annual Utah Power Cost $420
Rebate as % of Unit Cost Utah Power 50%Total Annual Program Cost $ 743
Economic Life (Years)
2 Energy use data for over 41 000 refrigerators, refrigerator-freezers, and freezers has been
compiled by D&R International, Ltd., for DOE from the Directory of Certified
Refrigerators, Freezers, and Refrigerator Freezers published by the California Energy
Commission (CEC) from 1979 to 1992. See http://www.waptac.org/sp.asp?id=70.
Impact Evaluation of the 2002 California Low Income Energy Efficiency Program West
Hill Energy and Computing, Inc. October 11 , 2004
Low-Income Weatherization Program
Analysis in Support of Tariff Filing 08/22/05
Other Program Costs
Table 1.7 displays the estimated Utah Power program management and
administrative costs as well as the estimated cost of a third party evaluator.
Table 1.8 summarizes overall expected annual Program costs and savings.
Table 1.7: Other Program Costs
Utah Power Labor
Evaluation
$10 000
$10 000
*Includes program management, rebate processing and inspections.
** Evaluation costs are estimated to be $20 000, with evaluations occurring every two years.
Table 1.8: Combined Annual Program Costs and Savings
Utah Power ll.III.I."Totali
...'
..i KWh
Weatherization $120 750 $192 080 150,710
CFLs 955 655 74,460
Refrigerators $23,460 $43 860 102 680
Hot Water $420 $743 6,749
Other $20 000 $20 000
Total $166 585 $260,338 334 599
low-Income Weatherization Program
Analysis in Support of Tariff Filing 08/22/05
II.Cost Effectiveness
Cost-effectiveness tests were run for the Program as designed using the
following Standard tests:
Total Resource Cost (TRC): This test examines the program benefits and
costs from the Company and its customers' combined perspective. On the
benefit side, it includes reduction in supply costs. On the cost side, it
includes costs incurred by both Utah Power and the other funders. We also
include a TRC test that includes a 10% conservation adder (PTRC).
Utah Power (Utility Cost Test; UCT): From the Company s perspective
the benefits are in the form of avoided supply and line-loss costs. The
costs include administration, evaluation, and rebate costs associated with
the program.
Ratepayers: All ratepayers (participants and non-participants) may
experience an increase in rates to recover lost revenue. This test (entitled
Ratepayer Impact Measure, RIM) includes all the Company s program
costs as well as first-year lost revenues. On the benefits side, it includes all
avoided energy and capacity costs.
The participant test is included but no benefit cost ratio is calculated due to
zero participant costs. Cost-effectiveness assumptions are summarized in
Table 11.1.
Table 11.1: Program Cost-Effectiveness Assumptions
Energy Savings
Retail Rate
Discount Rate
Line Loss
Measure Life
Avoided Costs
Measure Cost
Incentive Amount
Results
Savings by measure
Average 2004 Residential Retail Rate
The US Treasury Long Term Composite bond rate of 4.60% posted on August 10
2005 was used for the TRC. Utah Power s estimated cost of capital of 7.18% was
used for the other tests.
10.23% from the 2004 Utah Power line loss study
Each measure has its own expected life.
Primary source is the 2005 Integrated Resource Plan 65% load factor decrement.
We also used the June 31 , 2005, official Company forward price curve as a
secondary data source.
Each measure has its own expected cost.
Varies by element. See previous sections.
The cost effectiveness of the Idaho Low Income Weatherization Program was
calculated using Quantec s Demand Impact and Cost Effectiveness (DICE)
low-Income Weatherization Program
Analysis in Support of Tariff Filing
11-
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model. The model distributes the estimated annual kWh savings across the
year based on hourly residential load shapes for each measure. Each of these
hourly savings values is multiplied by the associated hourly avoided-costs
from PacifiCorp s market price forecasts. These products are all discounted
back to the present. This approach accurately captures the hourly differences
in the value of a kWh during the year.
Cost effectiveness was calculated based on avoided costs estimated through
the August 2005 IRP decrement approach using a 65% load factor and on the
Company s official market price forecasts base case for Palo-Verde Hub
dated June 31 , 2005.
The proposed Program design passes the utility cost effectiveness tests from
the UCT perspective under both the forward price curve scenario and under
the IRP decrement . The program passes the TRC under the forward price
curve scenario and narrowly fails the TRC under the IRP 65% load factor
decrement scenario. Neither scenario reflects the additional benefits
associated with low-income weatherization to both the utility and the
participant. These additional benefits include decreases in collections and
arrearages, improved comfort, improved health, fewer work and school
absences, less frequent moves and more money to spend on other necessities.
Table 11.2: IRP Decrement (65% Load Factor)
All Measures,
.....,...'...'..'.."'
i.)//.
./.".......,........"...'..'..........'.....'
.i'
" '...', .'..'..'...".../).)....
AC:65%LoadFactor
""""""""""""""""" """"""""',"""
,m"""""""m
""""""""""" ,..' ... "...............'..."" '....'
Levelized$/kWh i..Costs
.."..,.....'
., ..' il3el1efits..NefBellefit ..
... .."
Ratio
Total Resource Cost Test 0552 $260 338 $243 705 $16,633 936
(PTRC) + Conservation Adder
Total Resource Cost Test (TRC)0552 $260 338 $221 550 $38 788 851
No Adder
Utility Cost Test (UCT)0353 $166 585 $177 086 $10 501 063
Rate Impact Test (RIM)$325 395 $177 086 $148 309 544
Participant Cost Test (PCT)$189 322 $189 322 I n/a
Lifecycle Revenue Impacts ($/kWh $0.0000039059 I
Table 11.3: June 31 , 2005 Base Case Forward Prices
Total Resource Cost Test 0552 $260 338 $349 279 $88 941 342
(PTRC) + Conservation Adder
Total Resource Cost Test (TRC)0552 $260 338 $317 527 $57 189 220
No Adder
Utility Cost Test (UCT)0353 $166 585 $245 576 $78 991 1.474
Rate Impact Test (RIM)$325 395 $245 576 $79 819 755
Participant Cost Test (PCT)$189 322 $189 322 n/a
Lifecycle Revenue Impacts ($/kWh $0.0000021021
4 The Utility Cost Test is often considered the appropriate test for low-income weatherization
programs since non-utility costs are federally funded.
low-Income Weatherization Program
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III.Evaluation Plan
The goals of the evaluation are to:
1. Estimate actual energy (kWh) and demand (kW) savings
2. Analyze Program cost effectiveness
The Company has committed to a process and impact evaluation at the end of
the second program year.
Impact Evaluation
The impact evaluation will include collecting key data, selecting a random
sample of participants, estimating energy savings, and assessing cost
effectiveness. The impact evaluation approach will vary by type of measure
installed.
Weatherization/Shell
This is not expected to be a large part of the Program. Energy impacts will be
assessed through billing analysis, and demand impacts will be assessed using
residential load shapes from secondary sources.
Compact Fluorescent Light bulbs
The analysis will begin with the Program database for the number of CFLs
installed, initial and final wattage, and hours of use whenever available.
Program database will be used to verify number of CFLs installed, hours of
use, whether the replaced bulbs were in working condition, and number of
bulbs removed. It is recommended that this effort be enhanced with a survey
of about 100 participants to verify the information in the program database.
However, this may also lead to increasing overhead costs to prohibitive levels
given the size of this program.
The data collected will be used to estimate the energy (kWh) savings. The
evaluator will then use secondary lighting hourly use data to estimate the
Program demand (kW) impacts. Actual savings will be verified with billing
analysis as described below.
Refrigerators
The evaluator will utilize the metered data collected from the replaced
refrigerators for estimating the energy and demand impacts. If conducted
Low-Income Weatherization Program
Analysis in Support of Tariff Filing 111.
08/22/05
customer surveys will be used to verify the presence of new refrigerators.
Actual savings will be verified with billing analysis as described below.
Savings Analysis
Traditionally, "quasi experimental" research design is the most appropriate
method for conducting impact evaluations of demand-side management
programs. The approach consists of comparing the change in pre- to post-
program energy consumption between the participants and a "comparison
group of customers who, though eligible, did not participate. By accounting
for non-pro gram-related factors that can affect energy use from the pre- to the
post-program periods, the approach can provide estimates of "net" program
impacts.
Census Billing Analysis. A billing analysis will be conducted on all
participants that pass the screen for sufficient billing history. These data will
be compared to a group oflow-income customers that did not participate in
the Program.
Princeton Scorekeeping MethodS (PRISM), an established weather-
normalizing tool, will be used to calculate each individual customer s annual
energy consumption under average weather conditions. Utilizing historical
weather data and billing records, PRISM adjusts for the impact of weather
variations upon usage during both the pre and post periods. The result is
weather-normalized and annualized data that allow for the meaningful
interpretation of the true impact of the Program upon energy consumption.
The evaluator will use difference-of-means tests to analyze disparities
between the participants and non-participant billing data.
The evaluator will also analyze the differences between pre and post PRISM-
produced set temperatures for assessment of take back.
Savings by Agency and Measure Type. Utilizing the estimates from the
billing analysis and detailed statistical models, the evaluator will stratify
savings by agency and measure. This will provide valuable insight into the
Program s operation and overall economic performance. This analysis will
provide descriptive statistics on the frequency of installations for specific
measures and groups of interrelated measures. It will also provide estimates of
savings for groups of measures and can be compared to deemed savings to
assess possible discrepancies. Additionally, these data will be stratified by
In order to produce the most accurate results, PRISM models each participant's pre and
post periods separately, generating an individual normalized consumption record for each
period. Employing several stages, PRISM utilizes an iterative process to detennine the
appropriate model (Heating-Only or Heating & Cooling) that best fits the data based on
the usage characteristics exhibited by the participant.
low-Income Weatherization Program
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agency to provide additional insight into best practices and areas of
improvement.
Quantify Non-Energy Benefits. If surveys are conducted, the evaluator will
estimate non-energy benefits, where applicable.
Conduct Cost-Effectiveness Analysis
The evaluator will conduct a cost-effectiveness analysis using traditional
tools. The analysis will include the standard perspectives (i., utility,
ratepayers, participants, and society) and, as much as possible, non-energy and
environmental impacts (e., carbon dioxide reduction and reduction in forced
mobility). The benefits to Utah Power include the reduction in energy
consumption and the Company s avoided costs.
Program costs include administration, delivery, and actual payments made to
participants. Benefit/cost ratios will be computed from the various
perspectives.
Management & Reporting
The evaluator will deliver a draft and final report of findings. The final report
will reflect all the comments made by stakeholders. It will provide a complete
description of the relevant evaluation objectives and how they were achieved.
The final report is to contain the following elements:
Executive Summary
Description of the Program, its goals, and objectives
Statement of the evaluation goals and objectives
Discussion of methodologies
Implementation procedures and assumptions for each method
Data-collection procedures and methods
Sample design and sample attrition
Results and their interpretation (demonstrated clearly with charts and
tables)
Timeline
A process evaluation of the Program should be conducted approximately one
year after Program implementation to assure that the Program is operating as
planned. An impact evaluation should be conducted two years after Program
implementation to allow sufficient post-implementation billing data to be
available.
low-Income Weatherization Program
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Low-Income Weatherization Program
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Appendix A. EPA Guidelines
Safe Disposal Requirements
Under Environmental Protection Agency (EP A) rules , equipment that is
typically dismantled on site before disposal (e., retail food refrigeration
central residential air conditioning, chillers, and industrial process
refrigeration) has to have the refrigerant recovered in accordance with EP A'
requirements for servicing. However, equipment that typically enters the
waste stream with the charge intact (e., motor vehicle air conditioners
household refrigerators and freezers, and room air conditioners) is subject to
special safe disposal requirements.
Under these requirements, the final person in the disposal chain (e., a scrap
metal recycler or landfill owner) is responsible for ensuring that refrigerant is
recovered from equipment before the final disposal of the equipment.
However, persons "upstream" can remove the refrigerant and provide
documentation of its removal to the final person if this is more cost effective.
If the final person in the disposal chain (e., a scrap metal recycler or landfill
owner) accepts appliances that no longer hold a refrigerant charge, that person
is responsible for maintaining a signed statement from whom the appliance is
being accepted. The signed statement must include the name and address of
the person who recovered the refrigerant, the date that the refrigerant was
recovered, or a copy of a contract stating that the refrigerant will be removed
prior to delivery. EP A does not mandate a sticker as a form of verification that
the refrigerant has been removed prior to disposal of the appliance. Such
stickers do not relieve the final disposer of their responsibility to recover any
remaining refrigerant in the appliance, unless the sticker contains a signed
statement that includes the name and address of the person who recovered the
refrigerant and the date on which was recovered.
The equipment used to recover refrigerant from appliances prior to their final
disposal must meet the same performance standards as equipment used prior
to servicing, but it does not need to be tested by a laboratory. This means that
self-built equipment is allowed as long as it meets the performance
requirements. For MV ACs and MV AC-like appliances, the performance
requirement is 102 mm of mercury vacuum; for small appliances, the recovery
equipment performance requirements are 90% efficiency when the appliance
compressor is operational and 80% efficiency when the appliance compressor
is not operational.
Technician certification is not required for individuals removing refrigerant
from appliances in the waste stream.
low-Income Weatherization Program
Analysis in Support of Tariff Filing 08/22/05
Section 608 of the Clean Air Act of 1990
SEe. 608. NATIONAL RECYCLING AND EMISSION REDUCTION
PROGRAM.
(a) In General -
(1) The Administrator shall, by not later than January 1 , 1992, promulgate
regulations establishing standards and requirements regarding the use
and disposal of class I substances during the service, repair, or disposal
of appliances and industrial process refrigeration. Such standards and
requirements shall become effective not later than July 1 , 1992.
(2) The Administrator shall, within 4 years after the enactment of the
Clean Air Act Amendments of 1990, promulgate regulations
establishing standards and requirements regarding use and disposal of
class I and II substances not covered by paragraph (1), including the
use and disposal of class II substances during service, repair, or
disposal of appliances and industrial process refrigeration. Such
standards and requirements shall become effective not later than 12
months after promulgation of the regulations.
(3) The regulations under this subsection shall include requirements that-
(A) reduce the use and emission of such substances to the lowest
achievable level, and
(B) maximize the recapture and recycling of such substances.
Such regulations may include requirements to use alternative substances
(including substances which are not class I or class II substances) or
minimize use of class I or class II substances, or to promote the use of safe
alternatives pursuant to section 612 or any combination of the foregoing.
(b) Safe Disposal.- The regulations under subsection (a) shall establish
standards and requirements for the safe disposal of class I and II substances.
Such regulations shall include each of the following-
(1) Requirements that class I or class II substances contained in bulk in
appliances, machines or other goods shall be removed from each such
appliance, machine or other good prior to the disposal of such items or
their delivery for recycling.
(2) Requirements that any appliance, machine or other good containing a
class I or class II substance in bulk shall not be manufactured, sold, or
distributed in interstate commerce or offered for sale or distribution in
interstate commerce unless it is equipped with a servicing aperture or
an equally effective design feature which will facilitate the recapture
of such substance during service and repair or disposal of such item.
low-Income Weatherization Program
Analysis in Support of Tariff Filing 08/22/05
(3) Requirements that any product in which a class I or class II substance
is incorporated so as to constitute an inherent element of such product
shall be disposed of in manner that reduces, to the maximum extent
practicable, the release of such substance into the environment. If the
Administrator determines that the application of this paragraph to any
product would result in producing only insignificant environmental
benefits, the Administrator shall include in such regulations an
exception for such product.
(c) Prohibitions. -
(1) Effective July 1 , 1992, it shall be unlawful for any person, in the
course of maintaining, servicing, repairing, or disposing of an
appliance or industrial process refrigeration, to knowingly vent or
otherwise knowingly release or dispose of any class lor class II
substance used as a refrigerant in such appliance (or industrial process
refrigeration) in a manner which permits such substance to enter the
environment. De minimis releases associated with good faith attempts
to recapture and recycle or safely dispose of any such substance shall
not be subject to the prohibition set forth in the preceding sentence.
(2) Effective 5 years after the enactment of the Clean Air Act
Amendments of 1990, paragraph (1) shall also apply to the venting,
release, or disposal of any substitute substance for a class I or class II
substance by any person maintaining, servicing, repairing, or disposing
of an appliance or industrial process refrigeration which contains and
uses as a refrigerant any such substance, unless the Administrator
determines that venting, releasing, or disposing of such substance does
not pose a threat to the environment. For purposes of this paragraph
the term "appliance" includes any device which contains and uses as a
refrigerant a substitute substance and which is used for household or
commercial purposes, including any air conditioner, refrigerator
chiller, or freezer.
low-Income Weatherization Program
Analysis in Support of Tariff Filing 08/22/05
Case No. P AC-06-
Exhibit No.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
P ACIFICORP
Quantec Memo Regarding Idaho Low Income
Program Cost Effectiveness Analysis
September 2006
-& ~
9 ~_!~~l
Rf/ising
,/",
bill' in "i/,drlies
Date:August 30,2006
Becky EberleTo:
From:Brian Hedman
Re:Idaho Low Income Program Cost Effectiveness Analysis
The tables below present the updated assumptions and cost effectiveness findings for the Idaho
Low Income Program under three scenarios: 50% cost sharing, 75% cost sharing and 100%
funding. The cost sharing is applied regardless of the total cost of the weatherization or
measures. The base assumptions were presented in Quantec document dated August 22, 2005
entitled "Idaho Low Income Weatherization Program: Analysis in Support of Tariff Revision
Cost Effectiveness Assumptions
The discount rates in Table 1 were obtained from two sources. For the TRC, the discount rate
used is the US Treasury Long Term Composite bond rate posted on August 28, 2006. The
discount rate for the Utility Cost, Rate Impact and Participant Cost tests is the system average
used in the 2004 IRP. Rocky Mountain Power also provided the values for line losses and the
residential retail energy rate.
Table 1: Common Inputs
Discount Rate for TRC test
Discount Rate for UTC, RIM, PART tests
Line Loss
Residential Energy Rate ($/kWh)
97%
18%
10.25%
$0.0404
Becky Eberle
August 30, 2006
Page 2
Scenario 1: 50% cost sharing
Table 2: Program Costs and Savings
(50% Cost Sharing)
Program
, ".
~avings
, ' .i
' ,
C~tegory. .,
' .
ipadicip~rtJ~c;ost (*I~vvhL
Weatherization $103 243 150 710
CFLs (number of households)175 013 650
Refrigerators $24 150 105 700
Hot Water $445 146
Other Administrative Costs $20 000
Total $149,850 340,206
) Rocky Mountain Power costs only. Exogenous costs (federal) are not included in cost effectiveness determination.
Table 3: 2004 IRP 65% Load Factor Decrement, August 2005 Update
Total Resource Cost Test (PTRC)0313 $149 850 $303 348 $153,498
+ Conservation Adder
Total Resource Cost Test (TRC)0313 $149 850 $275 771 $125 921
No Adder
Utility Cost Test (UCT)0361 $149 850 $216,872 $67 022 1.45
Rate Impact Test (RIM)$279 506 $216 872 ($62 634)
Participant Cost Test (PCT)$191 806 $191 806 n/a
Lifecycle Revenue Impacts ($/kWh)$0.0000011827
Table 4: June 2006 Forward Price Curve: Base Case
AIlMeasures..
. ".. ,. ...'.., .. .,...,..'..'.,..'
AC:O6/30/06BaseCasePVm " "
'" "" "" ""'" , " "
: Levelized ii ..
. .'. .. (
Benefit/Cost
$/kWh \Q()sts,,Benefits .....
.,....'!.,
.Nef,*nefits .ii, Ratio, '
Total Resource Cost Test (PTRC)0313 $149 850 $342 992 $193 142
+ Conservation Adder
Total Resource Cost Test (TRC)0313 $149 850 $311 811 $161 961
No Adder
Utility Cost Test (UCT)0361 $149 850 $250 806 $100 956
Rate Impact Test (RIM)$279 506 $250 806 ($28 700)
Participant Cost Test (PCT)$191 806 $191 806 n/a
Lifecycle Revenue Impacts ($/kWh)$0.0000005419
Becky Eberle
August 30, 2006
Page 3
Scenario 2: 75% cost sharing
iIWW" Program SclVings
Category.
, ,,
.11,
'. ". "
1, Participants Cost i(kWh)
Weatherization $102,488 103 344
CFLs (number of households)120 070 560
Refrigerators $24 840 72,480
Hot Water $410 764
Other Administrative Costs $20 000
Total $149,809 233,148
) Rocky Mountain Power costs only. Exogenous costs (federal) are not included in cost effectiveness determination.
Table 5: Program Costs and Savings
(75% Cost Sharing)
Table 6: 2004 IRP 65% Load Factor Decrement, August 2005 Update
Total Resource Cost Test (PTRC)0456 $149 809 $207 954 $58 146
+ Conservation Adder
Total Resource Cost Test (TRC)0456 $149 809 $189 050 $39 241
No Adder
Utility Cost Test (UCT)0527 $149 809 $148 666 ($1 142)
Rate Impact Test (RIM)$235 530 $148 666 ($86 863)
Participant Cost Test (PCT)$131,481 $131,481 n/a
Lifecycle Revenue Impacts ($/kWh)$0.0000016402
Table 7: June 2006 Forward Price Curve: Base Case
AII.MeaslIres"I.'..I."I..I"',I""1 "
."',."".""..,"""."'""'.."".'."""'.."""."
ii"'
,,"/"'..".."....""."""""'.""'.' ".'."."'
AC:O6J30JO6 Base Case.PV
',"
" m
' ,,"'" """",",,, ,' ", """"""".""""".,,," ,,""" ""' ',.",.., """"""",."""".", " , ,...'..., ,,.'
.i "i "'
' ""
'i:ite veli~~.I'
/.'.."'..,./,' .,'. ..
SenefitlCost
l' $/kWh Costs !. Benefits
. ,. "
. NetSe~efits i" . Ratio
Total Resource Cost Test (PTRC)0456 $149 809 $235,124 $85 316
+ Conservation Adder
Total Resource Cost Test (TRC)0456 $149 809 $213 749 $63 941 1.43
No Adder
Utility Cost Test (UCT)0527 $149 809 $171 923 $22 114
Rate Impact Test (RIM)$235 530 $171 923 ($63 607)
Participant Cost Test (PCT)$131,481 $131,481 n/a
Lifecycle Revenue Impacts ($/kWh)$0.0000012011
Becky Eberle
August 30, 2006
Page 4
Scenario 3: 100% Payment
ii".i'.i'i.i.ii'.i/.'ii...i ii"i' " Programi?iii $ivings ' ,,Category i.i , i i.VParticipantsiii .i.iCost(*ii(kWh)
Weatherization $101,528 79,661
CFLs (number of households)116 296
Refrigerators $25,530 870
Hot Water $437 970
Other Administrative Costs $20 000
Total $149 611 179 797
J Rocky Mountain Power costs only. Exogenous costs (federal) are not included in cost effectiveness determination.
Table 8: Program Costs and Savings
(100% Payment)
Table 9: 2004 IRP 65% Load Factor Decrement, August 2005 Update
Total Resource Cost Test (PTRC)0590 $149 611 $160 334 $10 723
+ Conservation Adder
Total Resource Cost Test (TRC)0590 $149 611 $145 758 ($3 853)
No Adder
Utility Cost Test (UCT)0683 $149 611 $114 626 ($34 985)
Rate Impact Test (RIM)$213,423 $114 626 ($98 797)
Participant Cost Test (PCT)$101 375 $101 375 n/a
Lifecycle Revenue Impacts ($/kWh)$0.0000018656
Table 10: June 2006 Forward Price Curve: Base Case
i~.IIM~,a~lJr~~,.ii.ii"..ii,ili.:,
.......
iii..
/......
ii."ii'i..i.
~&:
~9f9?B.a~,(;ase PV ,
, " ,, "'" "'," "", """"""""'
i',l.e~enied lii ii'.i.i."i."I.li.BenefitlCost
'" $/kWh' .i'.' .""' Costs Benefits ."....., Net Benefits i'ii..
, ,
.i iRatio
Total Resource Cost Test (PTRC)0590 $149 611 $181 284 $31 673
+ Conservation Adder
Total Resource Cost Test (TRC)0590 $149 611 $164 804 $15 193
No Adder
Utility Cost Test (UCT)0683 $149 611 $132 559 ($17 052)
Rate Impact Test (RIM)$213,423 $132 559 ($80,864)
Participant Cost Test (PCT)$101 375 $101 375 n/a
Lifecycle Revenue Impacts ($/kWh)$0.0000015269