20111202Eberle REBUT.pdf

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2311 DEC -2 At'i 9: 58
201 South Main, Suite 2300
Salt Lake City, Utah 84111
December 2, 2011
VI OVERNIGHT DELIVERY
Jean D. Jewell
Commssion Secreta
Idaho Public Utilties Commission
472 W. Washington
Boise,ID 83702
Attention: Jean D. Jewell
Commssion Secreta
RE: CASE NO. PAC-E-1l-12
In the Matter of the Application of PacifCorp dba Rocky Mountain Power for
Approval of Changes to Its Electrc Service Schedules and Price Increase of $32.7
Milion, or Approximately 15.0 Percent
Enclosed pleae fid the origial and nie (9) copies of rebutt testimony of Rebecca Eberle
filed on behalf of Rocky Mountain Power in response to testimony fied by the Communty
Action Parership Association of Idaho.
Please contact J. Ted Weston at [phone] if you have any fuer questions.
Very Truly Yours,
JJ!jA'~ ~(M/JJetC~.~:~l v v I
Vice President of Reguation
Rocky Mountan Power
Enclosures
CERTIFICATE OF SERVICE
I hereby certfy that on ths 2nd of December, 2011, I caused to be served, via e-mail
and/or US mail, a tre and correct copy of the foregoing document in PAC-E-11-12 to the
following:
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey,
Charered
201 E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
E-Mail: elo(fracinelaw.net
Tim Buller (E-mail Only)
Agrum, Inc./Nu- West Industres
3010 Conda Road
Soda Sprigs, ID 83276
E-Mail: tbuller(fagrum.com
Neil Price
Deputy Attorney General
Idao Public Utilities Commission
472 W. Washington (83702)
POBox 83720
Boise, ID 83720-0074
E-Mail: neiLprice(fpuc.idaho.gov
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
E-mail: tony(fyaneLnet
James R. Smith (E-mail Only)
Monsanto Company
P.O. Box 816
Soda Sprigs, Idaho 83276
E-Mail: jim.r.smith(fmonsanto.com
Ronald L. Willam
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID, 83702
E-mail: ron(fwillamsbradbur.com
Randall C. Budge
Raine, Olson, Nye, Budge & Bailey,
Charered
201 E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
E-Mail: rcb(fracinelaw.net
Brad Pudy
CAPAI
2019N. 17th St.
Boise, ID. 83702
E-mail: bmpurdy(fhotmaiLcom
Benjam J. Oto
Idao Conservation League
710 N. 6th St.
P.O. Box 844
Boise, Idaho 83702
E-mail: botto(fidahoconservation.org
Brubaker & Associates
16690 Swigley Ridge Rd., # 140
Chesterfeld, MO 63017
E-Mail: bcollnsCfconsultbai.com
Don Schoenbeck
RCS, Inc.
900 Washington St, Suite 780
Vancouver W A, 98660
E-Mail: dws(fr-c-s-inc.com
~. ;U~/Are n
Coordinator, Regulatory Operations
BEFORE THE mAHO PUBLIC UTILITIES COMMSSION
IN TH MATTER OF THE
APPLICATION OF ROCKY
MOUNTAI POWER FOR
APPROVAL OF CHAGES TO ITS
ELECTRIC SERVICE SCHEDULES
AND A PRICE INCREASE OF $32.7
MILLION, OR APPROXIMATELY
15.0 PERCENT
)
) CASE NO. PAC-E-1l-12
)
) Rebuttal Testimony of Rebecca Eberle
)
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ROCKY MOUNTAI POWER
CASE NO. PAC-E-1l-12
December 2011
1 Q.Please state your name, business address and present position with
2 PacifCorp dba Rocky Mountain Power (the "Company").
3 A.My nae is Rebecca Eberle. My business address is 825 NE Multnomah, Suite
4 800, Portland, OR 97232. My present position is Low Income Program Manager.
5 Qualications
6 Q.Please describe your educational and professional background.
7 A.I received a B.S. degree in Business Admstration, with a mior in Sociology
8 from Oregon State University. I joined the Company in June 1980 and have held
9 positions in the Customer Servce, Reguation and Demand-Side Management
10 Deparents. I began managing residential energy effciency programs including
11 low income weatherization programs in 1991. I curently manage a varety of
12 programs available to PacifiCorp's customers with limted incomes includig low
13 income weatherization, bil assistace discounts and fuel fuds such as Lend-A-
14 Hand.
15 Purpose of Testimony
16 Q.What is the purpose of your rebuttal testimony?
17 A.I am filing rebutt testimony to repond to the testimony of Ms. Teri Otens,
18 witness for the Community Action Parership Association of Idao ("CAP AI"),
19 specifically, Ms. Ottens' request for Low Income Weatherization assistace
20 ("LIW A") and energy conservation education fuding.
21 Q.Is the LIW A program funded with revenues obtained through the
22 Company's general rates that are the focus of this proceeding?
23 A.No. LIWA is fuded through the revenue obtained through Schedule 191,
Eberle, Re - i
Rocky Mountan Power
1 Customer Effciency Services. Consequently it would appear tht ths request
2 would more appropriately be handled in Case No. P AC-E-l1-13 as it is
3 specifically related to the Low Income Weatherition Progr available though
4 Schedule 21.
5 CAP AI Funding Request - LIW A Program
6 Q.
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What is Ms. Ottens request related to Rocky Mountain Power's LIW A
Program?
Ms. Ottens proposes Rocky Mountan Power's fuding level should be set to
equa AVISTA's fuding on a per capita basis.
What is Rocky Mountain Power's current funding level of the LIW A
program on a per capita basis?
Agencies can bil Rocky Mounta Power up to $300,000 anually for the
services they provide though the LIWA program. Using Ms. Ottens' figue for
Rocky Mountan Power's residential customers of 56,430, ths is an anual
fuding investment of$5.32 per residential customer.
At what level is Ms. Ottens proposing Rocky Mountain Power fund the Low
Income Weatheriation program?
Ms. Otens proposes Rocky Mounta Power's fuding level be set at $377,517
anualy, or in other words, Ms. Ottens is requestig a 26 percent increase to
LIW A fuding.
How was the proposed increase calculated?
Ms. Ottens states that her proposed increase of $77,517 is based on A vista's per
capita investment in their Low Income Weatherization program. She states that
Eberle, Re - 2
Rocky Mountan Power
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A vista curently fuds their program at $6.69 per residential cusomer and if
Rocky Mountain Power's fudig was increased to $377,517 anualy, the per
capita anual investment would also tota $6.69 per residential customer.
Is it reasonable to compare the per capita funding for Avista's and Rocky
Mountain Power's Low Income Weatheriation programs in this manner?
No. Comparson of the fuding provided by Avista and Rocky Mountain Power is
diffcult, at best, because A vista provides electrc and natual gas service whereas
Rocky Mounta Power provides electrc service only. Ms Ottens fails to
acknowledge that A vista expenditus are for both its gas and electrc low income
weatherization programs. As Ms. Stacey Donohue of the Idaho Public Utilties
Commssion Sta testified to:l
"If A vista continues to spend 60% of its low income program
budget on electric measures, then (using Ms. Ottens' methodology)
the $420,000 budget divided by Avista's 105,286 electrc
residential customers (FERC Form No.1, 2010, pg. 304) equates
to a $3.98/customer expenditue."
The Company believes ths is a more appropriate comparson to the Rocky
Mountain Power expenditue of $5.32 per customer provided by Ms. Otens.
What percent of Rocky Mountain Power's customers heat using gas?
Approximately fort-six percent of the Company's residential customers in Idaho
heat with natual gas. To my knowledge the natual gas providers don't fud any
LIWA programs in Rocky Mountain Power's service terrtory. Obtaining fuding
from natual gas providers in Rocky Mountai Power's servce area at a rate that
matches the fuding A vista applies to natual gas servce homes may be a more
appropriate mean of increasing LIWA progr fudig. I don't believe it is
i Case No. IPC-E- i i -08 (page 3, lines 20-24).
Eberle, Re - 3
Rocky Mountain Power
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appropriate to compare fudig from an electrc only utility to fuding from a gas
and electrc utilty solely on a per capita basis as Ms. Ottens has proposed.
Why isn't basing funding solely on per capita investment reasonable?
As Ms. Donohue suggested in her testimony, it may be more advantageous to
households thoughout Idaho to determe fuding based on customer nees.
Do you agree with Ms. Ottens' statement that it is likely that Rocky
Mountain Power's customers wil have to wait for an average of eight years
and quite possibly might never receive benefits under the program?
No, I don't believe ths is likely. Although the Company specifically requested the
information used by CAP AI to support its calculation, CAP AI was not able to
provide ths inormation at the time my testimony was due. CAP AI's response to
the Company's data request 17 askig for the number of quaifying customers on
the waiting list as of December 31,2010 and October 31, 2011 states:
"The number of eligible customers on the waiting list changes
constatly. It is not known what the exact number of customers on
the waiting list was on December 31, 2010 without uneasonable
effort and recalculation of data no longer curent."
The agencies' list of customers interested in weatherization services is likely a
moving taget. A number of households may receive services within a year. Many
applicants may not be served by Rocky Mounta Power and may reside in homes
that ar not heated with electricity, so fuding may be dependent on other sources.
Some may not quaify for a varety of reasons, some may move out of the
agency's jursdiction and there may be a few where their landlord does not want
to paricipate. As Ms. Ottens' states, ths is diffcult to predict with precision.
Eberle, Re - 4
Rocky Mountan Power
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Are there ways of improving upon the allocation of Rocky Mountain Power's
funding?
Yes. Curently fuding is allocated evenly between Eastern Idaho Communty
Action Parership ("EICAP") and SouthEastern Idao Communty Action
Agency ("SEICAA"). Based on the response from CAP AI to Rocky Mounta
Power's data request 16, SEICAA has a longer weatherization waiting list, so the
Company would like to work with the agencies to determine the most appropriate
means of allocating the fuding between the two agencies.
Does Rocky Mountain Power have a good workig relationship with the
weatheriing agencies in its service territory?
Yes. Rocky Mounta Power is gratefu for the valuable services provided by
employees of EICAP and SEICAA to our income eligible customers. The
Company appreciates the positive relationship we maita with their sta.
14 CAP AI Funding Request - Conservation Education
15 Q.Please summarie the background of the $50,000 one-tie conservation
16 education funding.
17 A.As par of the stipulation approved by the Commission in Case No. P AC-E-08-07
18 dated Febru 4, 2009, which CAPAI was a par to, Rocky Mountai Power
19 commtted to a one-time payment of $50,000 for conservation education.
20 Paragraph 8 of that stipulation states:
21 ". . . the Paries agre that a tota of $50,000 of demand-side22 mangement progr fuds will be made available to
23 Southtern Idaho Communty Action Agency and Eastern Idao
24 Communty Action Parership to be used to support conservation
25 education as a component of Rocky Mounta Power's low income
26 weatherization program, Schedule 21. Pares agree that it is the
Eberle, Re - 5
Rocky Mountan Power
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responsibilty of the Communty Action Parership Association of
Idao to propose said education program to Rocky Mounta
Power by May 1, 2009 and that the proposal will conta fuding
proportioning the $50,000 between the two agencies, objectives
and any savings estiates to assist in program evaluations and
reporting requiements. The Paries agree tht the low income
weatherization program (Schedule 21) and the conservaton
education component of the program is in the public interest and is
determined to be cost-effective even though the explicit
quatification of benefits may not be possible, and fuermore, the
Paries agree to support the justification and recovery of these costs
through the demand-side management surcharge fuding."
What is the status of the conservation education funded by Rocky Mountain
Power?
The curculum was developed by CAP AI staf and provided to the Company in
final form in March 2011. Our two parnerig agencies, EICAP and SEICAA
began providing the energy conservation curculum and distbutig energy
effciency kits in May 2011 to income eligible Rocky Mounta Power customers.
As of August 23,2011,36 households had paricipated in the energy conservation
program; the agencies agreed to provide an update on their progress in December.
What is the cost of the conservation education per participant?
The kits were purchased at a cost of $15 each and include thee compact
fluorescent light bulbs, a kitchen aerator, outlet gasets, a night light and a
refrgerator/freezer temperatue card. With a paricipant goal of 500 households,
the fuding per paricipant totas $100 with $15 covering the effciency kit and
$85 fuding the agencies cost to distrbute the kits and provide the curculum
consisting of one group session and one in-home session.
Eberle, Re - 6
Rocky Mounta Power
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What are some issues that have occurred in the offering of conservation
education?
Rocky Mounta Power is very appreciative of the effort of the conservation
education staff from EICAP and SEICAA. They are very commtted to these
efforts.
From my perspective there have been two obstacles in developing and
implementig customer conservation education. The first obstcle was that
implementation was delayed because CAPAI was devoting its efforts to initiatig
conservation education in Idao Power's serce area. And secondly, with the
total fuding amount of $50,000 it became apparent that the services provided to
Rocky Mounta Power's customers had to go beyond the distrbution of a kit and
a group effciency presentation. Providing a group session and an in-home session
to households is valuable but may be an insurountable component of the
offering.
How do you suggest energ conservation be provided to income eligible
Rocky Mountain Power customers in the future?
I suggest that Rocky Mountain Power continue to work directly with the st of
the two local agencies, Commission Sta, and CAP AI to determine: (1) what is
the best approach for agency staff to provide conservation education services to
households; (2) what is the agencies' cost of providing energy consrvation
servces; and (3) what is an achievable anua paricipation goal.
Eberle, Re - 7
Rocky Mounta Power
1 Q.Does your testimony address the issues Ms. Ottens' testimony raises related
2 to Case No. PAC-E-ll-13?
3 A.No. These issues were appropriately addressed in Case No. PAC-E-ll-13.
4 Conclusion
5 Q.Does the Company support CAP AI's per capita LIW A funding Proposal and
6 position on conservation education?
7 A.No. The Company does not support ths specific proposal becaus, as I have
8 demonstrated, CAP AI's per capita comparson to A vista is inappropriate. When
9 you correctly adjust Avista's fuding to exclude gas customers, Rocky Mountan
10 Power's per capita fuding level is actuly be higher than A vista's.
11 The Company agrees with Ms. Donohue's suggestion (CASE No. IPC-E-
12 1 I -08, page 4, lines 19-20) that the issue of equitable fuding would be best
13 resolved though a collaborative effort among staeholders.
14 As mentioned earlier the $50,000 conservation education fuding was
15 made in Febru 2009. As of August 2011 only 36 of the 500 kits ha been
16 placed in households. However, the Company has initiated discussions and held
17 two meetings with representatives from the two local agencies, Commssion Sta
18 and CAP AI in an effort to develop a conservation education program that will
19 have a positive impact on all paries, most importtly our income eligible
20 customers.
21 Q.Does this conclude your testiony?
22 A.Yes.
Eberle, Re - 8
Rocky Mountain Power