20110429Application.pdf

~.. ROCKY MOUNTAINPOER
A DIISION OF PACFlRP
RECEIVED
201 South Main, Suite 2300
ior l APR 29 AM 10= 24 Salt Lake City, Utah 84111
April 29, 2011
VI OVERNIGHT DELIVERY
Idaho Public Utilities Commission
472 West Washigton
Boise, ID 83702-5983
Attention:Jean D. Jewell
Commssion Secreta
Re: Case No. PAC-E-l1-13
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAI POWER
SEEKIG AUTHORIZATION TO SUSPEND FUTUR PROGRA
EVALUATIONS OF SCHEDULE 21, LOW INCOME WEATHERIZATION
SERVICES OPTIONAL FOR INCOME QUALIFG CUSTOMERS.
Rocky Mountan Power, a division ofPacifiCorp, hereby submits for filing an original and seven
(7) copies of its Application in the above referenced matter.
Communcations regarding ths Application should be addressed to:
Ted Weston
Idaho Reguatory Affai Manager
201 South Main, Suite 2300
Salt Lake City, UT 84111
Telephone: [phone]
Facsimile: [phone]
E-mail: Ted.Weston(ßPacifiCorp.com
Danel Solander
Senior Counsel
201 South Mai, Suite 2300
Salt Lake City, UT 84111
Telephone: [phone]
Facsimile: [phone]
E-mail: Daniel.Solander(ßPacifiCorp.com
It is respectfuly requested that all formal corrspondence and Sta requests regardig ths
material be addressed to:
Bye-mail (preferred):dataequest(facificorp.com
By reguar mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Idaho Public Utilties Commssion
April 29, 2011
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Any inormal inquies may also be diected to Ted Weston at 801-220-2963.
Sincerely,
Or~) LVl/1~tIy K. Laren l l
Vice President, Reguation
Enclosures
Mark C. Moench
Danel E. Solander
201 South Mai, Suite 2400
Salt Lake City UT 84111
Telephone: [phone]
FAX: [phone]
Email: daei.solander~pacificorp.com
RECEIVED
20tl APR 29 AM 10= 24
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAI POWER SEEKIG )
AUTHORIATION TO SUSPEND FUTU )
PROGRA EVALUATIONS OF SCHEDULE 21, )
LOW INCOME WEATHERIATION SERVICES)
FOR INCOME QUALIFYIG CUSTOMERS )
CASE NO. PAC-E-11-13
APPLICATION
COMES NOW, Rocky Mounta Power, a division of PacifiCorp (the
"Company"), and in acordace with RP 052 and RP 201, et. seq., hereby applies to the
Idaho Public Utilties Commssion (the "Commssion") for an Order removig futue
obligations for the Compay to perform program evaluations of its Low Income
Weatherization Servce Optiona for Income Quaifyg Customers program offered
under Schedule 21. In support of the Application, Rocky Mountain Power sttes as
follows:
1. PacifiCorp is an electrcal company and public servce company doing business in
the state of Idao as Rocky Mounta Power, subjec to the jursdiction of the
Commission with regard to its public utility operations. PacfiCorp also provides retal
electrcity service in the states of Oregon, Californa, Uta, Washigton, and Wyomig.
PacifiCorp's address is 201 S. Mai St., Salt Lake City, Uta 84111.
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2. Communcations regarding ths Application should be addrssed to:
Ted Weston
Idaho State Manger
Rocky Mounta Power
201 South Mai Strt, Suite 2300
Salt Lake City, UT 84140
Telephone: [phone]
Facsimile: (801) 220- 2798
E-mail: Ted.Weston(ßPacifiCorp.com
Danel E. Solander
Senior Counel
Rocky Mounta Power
201 South Main, Suite 2300
Salt Lake City UT 84111
Telephone: [phone]
Facsimle: [phone]
E-mail: danieL.solander(ßPacifiCorp.com
In addition, PacifiCorp respectfly requests that all data requests regarding ths
matter be addressed to:
Bye-mail (preferred):dataeguest(ßpacificorp.com
By regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
Informal inquies may be directed to Ted Weston, State Manger [phone].
3. Rocky Mountain Power parers with two non-profit weatherization agencies tht
instal energy effciency measures in income eligible households at no-cost to the
residents. These agencies include Eastern Idao Communty Action Parership in Idao
Falls and Southastern Idao Communty Action Agency in Pocatello.
4. An evaluation of Rocky Mounta Power's Schedule 21, Low Income
Weatherition Services Optional for Income Quaifyg Customers, is atthed. The
program evaluation was performed by The Cadmus Group, Inc., based on program
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activities in 2007 though 2009. Durg the thee-yea period evaluated, the Company
provided reimburements to the agencies that included a rebate of 75 percent of the cost
of insling approved measures, and a 15 percent adstrtive cost reimburement. A
maximum of $150,000 in progr fuding was available anualy durng ths period.
The remainng 25 percent of the costs for installed measures were covered through fuds
leveraged from federal fuding sources received by the agencies.
5. On Febru 28,2011 the Commssion issued Order No. 32196, Cas No. PAC-
E-10-07, revising the anual program fuds available from a maximum of $150,000 to
$300,000 maximum. Rocky Mountain Power's reimbursement sharng with the agencies
of the cost of instaling approved measurs was also increased from 75 percent to 85
percent of the cost of approved measurs with the 15 percent adstrative cost
reimburement remainng in place.
6. The program evaluation performed by The Cadmus Group, Inc. includes the
review of processes and impacts. It provides kWh savigs determined thrugh biling
analyses, as well as estiates for non-energy benefits. Rocky Mounta Power's
portolio of energy effciency progr are cost-effective, but the cost-effectiveness
calculations included in the attched evaluation indicate that Schedule 21 is not cost-
effective from the Tota Resource Cost (TRC), Utilty Cost (UCT) or Raepayer Impact
(RI) perspectives uness non-energy benefits are included. When these additional
estimated benefits are added, the TRC indicates the program is cost-effective.
7. The costs included in the analyses are only those incured by Rocky Mounta
Power and do not include the leveraged fuds the agencies receive from federal sources.
There are many factors involved in the treatment of homes tht are inabited by limted
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income familes that cause a reduction in expected kWh savigs. These factors include,
but are not limted to: (1) Poor housing stock; (2) heating systems which were not in
workig order often add use once repaid; and (3) the number of famly members
sometimes increases as additional people move in afer the home is trated.
8. Rocky Mounta Power recognzes the importce of our Low Income
Weatherization Progr and the benefit to our customers by reducing kWh usage and
helping to make paricipant's bils more afordable, as well as increasing their comfort..
However, as described in the atthed Low-Income Weatherition program evaluation,
due to many factors the program is not cost-effective. To ths end, we respectfully
request the Commission acknowledge the program as an acceptable par of Rocky
Mounta Power's progr portfolio, and fid that it should continue.
9. The additiona costs of program evaluations will fuer erode the cost-
effectiveness of the Company's demand-side mangement programs. The Cadmus
Group's progr evaluation of Schedule 21, Low Income Weatherization Services
Optional for Income Quaifyg Cusomers, demonstrates that it is not cost-effective
under the TRC, UCT, and RIM perspetives. The Company believes that the cost-
effectiveness will be fuer eroded with the recent increase to cost sharg
requirements.
1 In an effort to reduce futue admistrative costs associated with ths
progr Rocky Mountain Power respetfuly requests tht the Idaho Public Utilties
Commission remove any futue obligation for progr evaluations of the Low Income
Weatherization Services Optiona for Income Qulifying Cusomers progr.
10. Rocky Mounta Power believes tht consideration of the proposals contained in
Order No. 32196 increased the Compay's porton of costs covere from 75% to 85%, effecive
December 28, 2010.
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ths Application does not requie an evidentiar proceedig, and accordingly the
Company requests that ths Application be processed under RP 201 allowig for
consideration of issues under modified procedur, i.e., by wrtten submissions rather th
by an evidentiar hearg.
WHREFORE, Rocky Mounta Power respectfuly requests that the
Commssion issue an Order under Modfied Procedur removing the Company's
obligation to pedorm futue progr evaluations of Schedule 21 Low Income
Weatherition Servces Optiona for Income QualifYng Customer.
DATED: April 29, 2011.
Respectfly submittd,I~ 'J,i '.) I. -1 IL4.~L / '~~V'-/l~1¿tlDanel E. Solanaer / (/ . . / ..
Attorney for Rocky Mountan Power
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