HomeMy WebLinkAbout20080424Comments.pdfSCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0320
BARNO. 1895
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER FOR AN INCREASE TO THE )
SCHEDULE 191 CUSTOMER EFFICIENCY )
SERVICES RATE ADJUSTMENT AND )
ENHANCEMENT TO ENERGY EFFICIENCY )
PROGRAMS FOR COMMERCIAL, )
INDUSTRIAL, AGRICULTURAL AND )RESIDENTIAL CUSTOMERS. )
CASE NO. PAC-E-08-1
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its
attorney of record, Scott Woodbury, Deputy Attorney General, and in response to the Notice of
Application, Notice of Modified Procedure and Notice ofComment/rotest Deadline issued on
February 28, 2008 in Case No. PAC-E-08-1, submits the following comments.
BACKGROUND
On February 14,2008, PacifiCorp dba Rocky Mountain Power (PacifiCorp; Company)
fied an Application with the Idaho Public Utilties Commission (Commission) requesting
authority to: (1) adjust the collection rate of the existing demand side management (DSM) cost
recovery mechanism (Schedule i 91) from 1.5% to 3.72% of retail revenue; (2) add a new energy
effciency program for commercial and industrial customers; and (3) change existing programs for
STAFF COMMENTS 1 APRIL 24, 2008
business and residential customers to improve program performance. The Company originally
proposed an April i, 2008, effective date. Due to a customer notification problem, Staff
requested that the Company modify its requested effective date and on February 19,2008, the
Company complied by modifying its Application for a May 1, 2008 effective date.
PROPOSED RATE INCREASE
Schedule No. 191 - Customer Efficiency Services Rate Adjustment
The Application proposes to increase the collection rate for Schedule No. 191 from 1.5%
to 3.72% of retail revenue for an increase of2.22% to total rates. The 1.5% rate is sufficient to
fund about $2.0 milion of energy efficiency programs each year. The proposed 3.72% rate is
expected to collect about $4.9 milion per year ($9.7 millon over two years) and is designed to
fund projected program activity for 2008 and 2009 and retire the curent back balance of
$349,000 by the end of2009.
Schedule No. 191's balancing account has not funded, and is not yet proposed to fud,
customer incentive payments in the irrigation load control program (Schedules 72 and 72A). The
incentive payments in this program for 2006 and 2007 combined were $2.7 milion and are
expected to increase to $3.9 milion in 2008 and to $5.6 milion in 2009. These annual credit
amounts are includable as power supply costs in the Company's base rates. Equipment and
administrative costs for this program, totaling $ i.2 milion for 2006-2007, are expected to
increase to $4.0 milion total for 2008-2009 and wil continue to be recovered from Schedule
191' s balancing account in addition to the expected total of $5.4 milion for all other programs
over this two-year period.
The Application specifically does not propose changing or addressing such issues as
account balance administration or prudence review of programs. These issues are intended to be
addressed during general rate cases as outlined in Order No. 29976.
The Company has informed Staff that with this rate increase and the proposed program
changes and additions, it intends to pursue all cost-effective energy efficiency and demand
response programs regardless of the Schedule 191 account balance. If and when the account
balance is in or approaching a deficit, the Company wil ask for an additional Schedule 191 rate
increase, but it wil not let an existing or approaching deficit deter its program activity.
STAFF COMMENTS 2 APRIL 24, 2008
DESCRIPTION OF REVISIONS TO EXISTING PROGRAMS
Schedule No. 118 - Home Energy Savings
The Home Energy Savings program has been offered since May 31, 2006, and provides
incentives for more effcient residential products and services for new and existing homes. The
program's equipment categories include appliances, lighting, heating, cooling, insulation and
windows, and services such as duct sealing and air conditioning equipment tune-ups. The
program's web site is ww.homeenergysavings.netlidaho/home and provides information such as
incentive levels and eligible equipment specifications. PacifiCorp says it is changing the program
to increase paricipation and to better align incentive levels with Idaho markets for the following
measures: washing machines, dishwashers, water heaters, lighting, evaporative cooling,
insulation and heat pumps. The specific program changes are listed on page 8 of the Application.
These changes do not require tariff changes and it is not necessar for the Commission to approve
them.
PacifiCorp's expenses for this program totaled to about $332,000 for 2006-2007 and they
are expected to increase to about $ 1.1 milion for 2008-2009. First-year megawatt-hour (MWh)
anual savings are expected to increase from about 770 MWh for 2006-2007 to about 7,121 MWh
for 2008-2009.
Schedule No. 155 - Irrigation Energy Savers
The only change proposed to Schedule No. 155 is removal of the "fuding availabilty"
language. Irrigation equipment exchange has been available since spring 2006 and PacifiCorp
says it is the most popular measure in the Irrigation Energy Savers program. The Company says
customers are now primarily interested in system upgrades, including the installation of varable
frequency drives on pumps. Based on the program focus moving from an equipment exchange
approach to an analysis-based approach, the Company is seeking proposals for program
administration to help ensure that program delivery is done by an administrator with the best
combination of competitive pricing and experience in irrgation and electric energy efficiency.
PacifiCorp's expenses for this program totaled to about $521,000 for 2006-2007 and they
are expected to increase to about $1.3 millon for 2008-2009. First-year megawatt-hour (MWh)
anual savings are expected to increase from about 4,533 MWh for 2006-2007 to about 5,294
MWh for 2008-2009.
STAFF COMMENTS 3 APRIL 24, 2008
Schedule No. 115 - FinAswer Express
The FinAswer Express program's prescriptive incentives for common energy efficiency
measures has been available to Idaho business customers since January 2006. PacifiCorp says the
changes proposed in this fiing are based on proven program design and delivery experience in
other jurisdictions and are designed to increase participation using the best available data on
market costs and appropriate incentive levels. The changes: (1) add new measures eligible for
prescriptive incentives; (2) add a separate incentive table for lighting retrofits and new
construction/major renovation, and (3) revise some delivery mechanisms, including moving
incentives from point of purchase to post-purchase applications for both premium effciency
motors and lighting for new construction and major renovation. In addition, incentive caps will
be applied to projects rather than to individual measures. Details of the FinAswer Express
changes are in Attachment 5 of the Application and the analysis supporting the changes is in
Attachment 7.
The Application states that FinAswer Express was designed as a complement to the
Energy FinAnswer program that it operates in other states, but which it was unable to implement
in Idaho due to funding limitations. As a result, the Company says that customer requests for
services provided under the FinAnswer Express, the only non-irrigation commercial program,
have exceeded available funding and applicants are being placed on a waiting list.
PacifiCorp's expenses for this program totaled to about $345,000 for 2006-2007 but due
to the new Energy FinAnswer program, they are expected to drop to about $242,000 for 2008-
2009. First-year megawatt-hour (MWh) savings are expected to decrease from about 3,103 MWh
for 2006-2007 to about793 MWh for 2008-2009.
DESCRIPTION OF NEW PROGRAM
Schedule No. 125 - Energy FinAswer
PacifiCorp proposes to offer the Energy FinAswer program to provide funding for
energy engineering in addition to incentives of $0.12 per kilowatt-hour (kWh) for first-year
energy savings and $50 per average monthly kilowatt (kW) demand savings, up to 50% of the
approved project cost. The program is designed to target comprehensive projects requiring
project-specific analysis and wil operate as a complement to the FinAnswer Express prescriptive
STAFF COMMENTS 4 APRIL 24, 2008
program. Details of the program are in Attachment 5 of the Application and the analysis
supporting this new program is in Attachment 6.
A similar program was offered by PacifiCorp for 15 years under Schedules 120 and 122,
but new participation in that program was ceased on January 12,2006, due to fuding limitations.
The Company says the Energy FinAnswer program is designed to increase new
constrction participation and early program involvement to capture lost opportunities. In
addition to the improved customer incentives, other enhancements include design-team
honorariums (finder fees for new projects) and design-team incentives for new construction
projects exceeding the current Idaho energy code by at least 10%.
PacifiCorp estimates its costs for this program wil total to about $1.1 milion for 2008-
2009 and the first year annual savings for 2008 and 2009 combined at about 4,076 MWh.
TARIFFS BEING CANCELLED
Schedule Nos. 120 and 122 - Commercial Energy Services
The schedules for loan-based commercial energy efficiency were closed to new service
with the 2006 filing, but remained as approved schedules to administer existing loans. The
Application cancels these schedules.
ENERGY EFFICIENCY PROGRAMS NOT CHANGED BY THIS FILING
Schedule No. 117 - Refrigerator Recycling
This program was modified in June 2007 in recognition of changing estimates and
circumstances. PacifiCorp's expenses for this program totaled to about $266,000 for 2006-2007
and they are expected to increase to about $535,000 for 2008-2009. First-year megawatt-hour
(MWh) savings are expected to increase from about 1,315 MWh for 2006-2007 to about 4,198
MWh for 2008-2009.
Schedule No. 121 - Low-Income Weatherization Services
This program has been in place for 15 years and changes were last made in April 2007.
PacifiCorp's expenses for this program totaled to about $246,000 for 2006-2007 and they are
expected to increase to about $300,000 for 2008-2009. First-year megawatt-hour (MWh) savings
are expected to decrease from about 538 MWh for 2006-2007 to about 466 MWh for 2008-2009.
STAFF COMMENTS 5 APRIL 24, 2008
Schedule Nos. 72 and 72A - Irrigation Load Control Credit Rider
This program was enhanced per the agreement reached in the Company's general rate case
approved by the Commission in Case No. PAC-E-07-05. Additional modifications were
proposed in Tariff Advice No. 08-01 and approved by the Commission on February 11,2008.
Changes included new incentive levels, reduction in maximum dispatch hours, increase in
dispatch duration, and revision of the minimum pump size.
PacifiCorp's Schedule 191 fuded expenses for this program totaled to about $1.2 milion
for 2006-2007 and they are expected to increase to about $4.1 milion for 2008-2009. The
Company's expenses includable in base rates for this program totaled to about $2.7 milion for
2006-2007 and they are expected to increase to about $9.5 milion for 2008-2009. Peak load
savings are expected to increase from 50 MW in 2006 and 2007 to 150 MW in 2008 and 200 MW
in 2009.
Northwest Energy Effciency Allance (NEEA)
For over 10 years PacifiCorp has actively paricipated with other utilties in the Northwest
Energy Efficiency Alliance's (NEEA) efforts to more effectively transform energy effciency
markets. PacifiCorp's $360,534 annual funding share ofNEEA's $20+ milion budget for the
Company's Idaho operations is specified in a multi-year contract. This anual amount is paid
from Schedule 191's balancing account. It is shown as $720,000 for 2006-2007 and for 2008-
2009 on Attachment C.
NEEA estimates that its first year annual energy savings for PacifiCorp's Idaho service
area at about 11,000 MWh based on PacifiCorp's Idaho funding share of total NEEA savings.
Monsanto's Special Contract Interrptible Rate
Although Monsanto's special contract, interrptible service rate is not affected by the
Application and is not funded by Schedule 191, it deserves to be mentioned in these comments as
being one ofPacifiCorp's demand-side management tools available to meet its system peak load.
The abilty ofPacifiCorp to interrpt this 150-plus MW load when necessar or economical
provides reliabilty and economic benefits to all ofPacifiCorp's customers and Monsanto is
compensated by having lower rates than it would otherwse have.
STAFF COMMENTS 6 APRIL 24, 2008
COST-EFFECTIVENESS OF PACIFICORP'S PROGRAMS
PacifiCorp informed Staff that it follows the 2001 version of the California Standard
Practice Manual i for estimating and evaluating the cost-effectiveness of its programs. Under
these guidelines, the Application's Attachment 2 preliminarily represents that all of the programs
listed were cost-effective in 2007 from the total resource cost (TRC) perspective, the program
administrator (utilty cost test, UCTi perspective, and the participant perspective. As is usually
expected, none of the programs listed in Attachment 2 passed the rate impact (RIM) test. 3 Staff
notes that the Company's 2007 Annual Demand Side Management Report, fied on March 17,
2008, indicates slightly better overall results for 2007 than the preliminar results shown in
Attachment 2. Attachment 4 indicates all of the listed current and proposed programs for 2008-
2009 are expected to be similarly cost-effective. Both the Company's 2007 Idaho Irrigation Load
Control Report dated 12/18/07 and the 2007 Annual DSM Report indicate that that program
passes all relevant cost-effectiveness tests, including the RIM test.
CUSTOMER COMMENTS
The Application included the requisite customer notice and press release. Both documents
met the requirements of Rule 102, Notices to Customers of Proposed changes in Rates in the
Utility Customer Information Rules (UCIR), IDAPA 31.21.02102. The Company included the
customer notice with biling statements beginning Februar 25,2008, continuing for
approximately 30 days until all customers received the notice.
As of April 23, 2008, four Rocky Mountain Power customers had submitted comments on
the Application. All four said the Commission should not approve the proposed rate increase to
fud more energy efficiency efforts. Commentators said the Company should work to improve
efficiency of its product without charging customers; efficiency program costs should be fuded
from Company profits and/or only by those who paricipate in the programs; that rates have
1 Although the California Manual is a good, commonly used tool for evaluating DSM cost-effectiveness, the Staffhas
notified representatives of all Idaho utilties of a potential disagreement with how tax credits are treated in the TRC
formula. This has little impact, partly because Staff believes the VCT is the most important of the four standard tests.
2 The VCT perspective actually indicates the cost-effectiveness of utilty programs for customers as a whole, since
they eventually pay the utilty's costs.
3 The RIM perspective indicates only if rates wil increase or decrease as a result of DSM program costs and the
utilty's fixed cost losses. The Idaho Commission rejected passing this test as a requirement for DSM programs in
Order No. 22299 issued in 1989. Stil, it provides useful information to compare different programs and options.
STAFF COMMENTS 7 APRIL 24, 2008
already increased enough to be a hardship and are high enough to encourage conservation; and
that the commentators have already funded their own efficiency improvements, so why should
they help pay for everyone else's. A representative of Agrium-Nuwest said that due to the way
the program is structured, that customer is not able to get much benefit from the program.
Staff appreciates these comments and acknowledges that additional rate increases create
hardships for some customers and are not welcome by any. Nevertheless, Staff believes
expansion of demand-side management (DSM) programs will ultimately reduce customers' bils
below what they would otherwise be absent such programs. While it is true that customers who
are able and wiling to participate in the programs wil benefit more than those who don't
paricipate, the latter group will also benefit indirectly from the Company's power supply costs
being lower than they otherwise would be. It is Staffs understanding that PacifiCorp has
demonstrated to the representative of Agrium-Nuwest that that customer is already receiving
more efficiency benefits than it has paid in efficiency costs and that it may be eligible for
additional cost effective efficiency support with the expansion of the programs and their fuding.
STAFF ANALYSIS
Staffsupported PacifiCorp's initiation of its customer services effciency rate and
programs in Case No. P AC-E-05-1 0 and continues to do so now. Staff recognizes that another
rate increase, even this relatively small 2.22% increase, wil be difficult for some customers to
endure. However, Staff is also well aware that even more expensive supply-side alternatives can
and wil be avoided to the extent that more customers use electricity more efficiently.
Attachment A depicts PacifiCorp's projected system-wide energy demand from 2008 to
2017, the existing resources that are available to meet that demand, and the resulting significant
resource deficit. Clearly the Company will need additional resources in the near future.
Attachment B lists resource options identified by PacifiCorp to meet its increasing load.
Demand-side management (DSM), including energy efficiency programs and load management
programs, is a significant, albeit insufficient, resource available to help ensure reasonable system
reliability.
The least costly electricity resource alternative is customers increasing the efficiencies of,
and efficient use of, their buildings, appliances, lights, irrigation systems, and industrial processes
without utility intervention and administration. Staff believes the second least costly electricity
STAFF COMMENTS 8 APRIL 24, 2008
resource is available when utilities or other entities prudently administer cost-effective programs
that provide monetar incentives and educational opportunities for customers to increase their
effciencies. The most expensive electricity resources are additional generation, transmission and
distribution facilties, regardless of whether the generation facilities are thermal, hydro, wind,
solar, or other alternatives.
It is evident that most customers, left on their own, do not use electricity as effciently as
rational economic theory suggests they should, probably due to a combination of lack of
knowledge and a perceived need for inordinately high implicit discount rates, i.e. individuals and
businesses often, if not usually, require assurance that rates of return for energy effciency
investments are much higher than for competing, alternative investments. The need for unusually
high rates of return for energy effciency investments may be due to a skewed perception of risk,
misinformation, and/or other factors. Whatever the reasons, the result is that PacifiCorp's own
analyses, as well as regional and national analyses, show that there remain many efficiency
programs that utilties or other entities can administer cost-effectively. Even though such
administration creates additional costs, the programs can be cost-effective because the cash
incentives and/or educational efforts result in many customers improving their energy efficiencies
beyond what they would do without such programs. If prudently managed, these programs are
expected to be less costly than curently available supply-side resources.
The top portion of Attachment C lists each program's costs and the savings that
PacifiCorp contends each achieved for 2006 through 2007 and what the Company expects each
program to cost and achieve in savings for 2008 through 2009. These costs and savings exclude
those of Monsanto's interruptible special contract rates.
The bottom portion of Attachment C compares each customer class's expected 44-month
Schedule 191 revenue contributions to Schedule 191 program funding and electricity savings.
Although complicated by Irrigation Load Control's peak MW reduction goal and the exclusion of
more than half of its costs that are included in base rates, the comparsons do suggest that no
major customer classes are being disproportionately advantaged or disadvantaged by the
distribution of the programs' energy savings.
Staff has reviewed the Application's proposed program addition, changes and fuding
level requirement and believes they are reasonable. Staff has also reviewed the Company's
program cost-effectiveness results provided in the Application, in the Company's 2006 and 2007
STAFF COMMENTS 9 APRIL 24, 2008
Annual Reports, and in the Company's responses to information requests. The Staff has not been
provided all of the information necessary to verify the cost-effectiveness results and estimates and
it is not necessary to have all such information at this time. Instead, when reviews of program
processes and results are required for a prudency determination during future rate cases, all
necessary information is expected to be made available.
RECOMMENDATION
Staff recommends approval of the Schedule 191 rate increase from 1.5% of total bils to
3.72% of total bils as well approval of all other proposed tariff additions and changes necessar
to implement the new Energy FinAnswer program and changes to other programs.
Respectfully submitted this ¿;,17%ay of April 2008.
~.úir
Scott oodbury
Deputy Attorney General
Technical Staff: Lynn Anderson
Nancy Hylton
i:umisc:commentslpace08. i swdelanh
STAFF COMMENTS 10 APRIL 24, 2008
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s
.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF APRIL 2008,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-08-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
DANIEL SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solander(ipacificorp.com
BRIAN DICKMAN
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: brian.dickman(ipacificorp.com
DATA REQUEST RESPONSE CENTER
PACIFICORP
825 NE MUL TNOMAH STE 2000
PORTLAND OR 97232
E-MAIL: datarequest(ipacificorp.com
-.~_
SECRETAR
CERTIFICATE OF SERVICE