20120626Comments.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
RECEIVED
2012 JUN 26 PMI2:8
IDAHO P!)BL UTUJTI ES COMMISSON
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER'S ) CASE NO. PAC-E-12-10
APPLICATION TO REVISE ELECTRIC )
SERVICE SCHEDULE 115 FINANSWER ) COMMENTS OF THE
EXPRESS. ) COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, comments as follows on the
Application of PacifiCorp dba Rocky Mountain Power ("Company") to revise Electric Service
Schedule 115, FinAnswer Express.
BACKGROUND
On May 15, 2012, the Company applied to the Commission for an order approving
proposed revisions to Electric Service Schedule 115, FinAnswer Express, effective July 14,
2012. Application at 1. The Company asks that the matter be processed under Modified
Procedure. Id. at 3.
The Company says it intends the FinAnswer Express Program (the "Program") to help
commercial and industrial customers reduce their electricity needs by implementing energy
efficient measures. The Program is available to commercial and industrial customers under
General Service Rate Schedules 6, 6A, 7, 7A, 9, 12, 19, 23, 23A, 24, 35, 35A and to dairy barns
served under residential rate schedules. Customers who receive service on Schedule 10 are
STAFF COMMENTS 1 JUNE 26, 2012
ineligible for the Program because they receive energy efficiency services and incentives through
the Irrigation Energy Savers plan (Schedule 155). Goddard Direct at 2.
With this Application, the Company proposes to update the Program to: (1) align with
new federal lighting standards expected to be effective July 14, 2012; (2) align with upcoming
changes to other codes, standards, third party specifications and new market data; and (3)
increase the participation in, and the comprehensiveness of, the Program by adding new
measures for appliances, dairy/farm equipment, and small compressed air. Application at 2-3.
The Company describes proposed changes such as Retrofit Lighting Changes, New
Construction/Major Renovation Lighting Changes, removing Motor Incentives, modifying
HVAC Incentives, Mechanical and Other Energy Efficiency Measure Changes, Building
Envelope Changes, Food Service Equipment Incentives, Office Equipment Incentives, and other
changes. See Goddard Direct at 2-14.
The Company also proposes to streamline Program administration by offering the
Program through a "flexible tariff' that would enable the Company to manage Program details
such as qualifying equipment and services, incentive amounts, dates for incentive availability
and other terms and conditions using the Company's web site instead of the Schedule 115 tariff
sheets. The Company's Application attaches the details the Company proposes to manage
through the "flexible tariff." These include definitions, incentive tables, and general incentive
information. The Company says hardcopies of "Program materials will be available upon
request from [sic] customers who do not have web access." Id. at 3.
The Company includes a flow chart describing how it will manage future changes to
Program details. Goddard Direct at 17. The Company says it will notify customers of changes
by posting the changes on the Company's web site. The Company will also notify its staff,
Program delivery contractors, and participating vendors so they can inform customers about the
changes. Id. at 17-18.
STAFF ANALYSIS
Staff has reviewed the Company's Application and supports the Company's proposals to
modify the Program and establish a flexible tariff for Schedule 115. Staffs analysis is discussed
below.
STAFF COMMENTS 2 JUNE 26, 2012
Lighting Incentives
On July 14, 2012, the U.S. Department of Energy will implement changes to the federal
lighting standards that will eliminate the manufacturing and importation of many low-cost,
inefficient light bulbs. Light bulbs manufactured in the United States, or imported for sale in the
United States, will need to meet higher efficacy (lumen/watt) requirements. These new lighting
efficiency standards will produce a corresponding increase in lighting retrofit projects throughout
the Company's service territory. However, the new efficiency standards will require the
Company to increase its deemed baseline for retrofits. This will decrease the available savings
for these projects and significantly impact the Program's cost-effectiveness. To address this
concern, the Company proposes to adjust the incentive amounts and qualifications for lighting
retrofits and eliminate incentives for certain lighting upgrades. Staff has reviewed the proposed
changes necessitated by the standards change and supports the Company's adjustments.
Motors Incentives
As of January 15, 2011, incentives are no longer available for National Electrical
Manufacturers Association Premium Efficiency motors. Table 2a of the Company's current
Schedule 115 tariff lists the incentives paid for these motors. Because these incentives are no
longer being paid, the Company proposes removing this table from the tariff.
Heating, Ventilation, and Air Conditioning (HVAC) Incentives
On January 1, 2010, a new part-load cooling metric for unitary HVAC equipment greater
than 65k Btu/hour took effect in the American Society of Heating, Refrigerating and Air
Conditioning Engineers standards. The new metric, called the Integrated Energy Efficiency
Ratio (JEER), replaces the previous metric, the Integrated Partial Load Value. The JEER is a
single number figure expressing cooling part-load EER efficiency for commercial unitary air-
conditioning and heat pump equipment based on weighted operation at various load capacities
for the equipment. The Air-Conditioning, Heating, and Refrigeration Institute only reports JEER
values in its equipment directory.
To address these changes and the anticipated increase in federal minimum efficiency
requirements expected in September 2012 for packaged terminal heat pumps and air
conditioners, the Company proposes revising the Program's eligibility requirements, incentives,
and minimum efficiency requirements. The Company also proposes to add ground-source and
groundwater-source heat pumps and heat pump loops to the Program to increase its
comprehensiveness.
STAFF COMMENTS 3 JUNE 26, 2012
Mechanical and Other Energy Efficiency Measures (EEM)
In the current Schedule 115, the Mechanical and Other EEM table includes a small
number of measures from several categories including HVAC, building envelope, food service,
and office equipment. The Company proposes expanding these measure categories to increase
Program participation and comprehensiveness, and to streamline Program administration. Given
the number of new measures in each category, the Company will replace the Mechanical and
Other EEM table in each category with a new table. Most of the measures in the current
Mechanical and Other EEM table have been updated and moved into proposed new measure
tables as summarized below:
Food Service Equipment Incentives
The Company proposes to add a food service measure table to the Program details, which
includes residential refrigerators/dishwashers used in a business, ENERGYSTAR commercial
refrigerators/freezers, air-cooled ice machines, commercial dishwashers, electric insulated
holding cabinets, electric steam cookers, electric commercial fryers, electric convection ovens,
electric griddles, electric combination ovens, and LED refrigeration case lighting. The Company
will discontinue offering incentives for beverage machine occupancy sensors due to anticipated
federal code changes in 2012. The Company also will discontinue offering incentives for
refrigerated display occupancy sensors and replace them with a new measure for occupancy
sensors in refrigerated cases with LED lighting. The Program's residential dishwasher and
refrigerator incentives will align with the Company's Home Energy Savings program and enable
customers to acquire additional cost-effective savings.
Office Equipment Incentives
The Company plans to expand the measure for Plug Load Occupancy Sensors to include
Smart Plug Strips, which limit stand-by power consumption of plug-load appliances by
switching off power to the strip when a minimum electrical load is sensed. The Company will
also add a Network PC Management Software measure.
Additional New Measures
The Company also proposes adding Program measures to increase Program participation
and comprehensiveness. These new measure categories will include appliances, dairy/farm
equipment, and small compressed air. The incentives for residential appliances will align the
Program with the Company's Home Energy Savings Program and capture additional cost-
effective measures for commercial customers.
STAFF COMMENTS 4 JUNE 26, 2012
Flexible Tariff
The current Schedule 115 tariff outlines Program details such as qualifying equipment
and services, incentive amounts, and other terms and conditions. The current tariff sheet consists
of 13 pages of detailed information that the Company will need to frequently modify due to
rapidly changing codes, standards, and third party specifications for energy efficiency measures.
With the proposed measure changes, the Company estimates that the tariff would expand to over
30 pages. Staff does not believe that the Program's tariff needs to be detailed with such
granularity.
The Company's proposed flexible tariff would allow the Company to manage and publish
Program details on the Company's website, with hardcopies provided to customers upon request.
In addition, the flexible tariff will still allow for adequate Staff input. Before the Company
makes Program changes, it will provide Staff with its intended modifications and allow sufficient
time for Staff concerns to be resolved. The Company says that after Staff's concerns are
resolved, it will clearly post the final set of changes in its website at least 45 days before the
changes are to take effect.
This flexible tariff process is the one used for the Company's Home Energy Savers
Incentive Program (Schedule 118), which the Commission approved in 2006. Further, granting
the Company a flexible tariff is consistent with how the Commission has structured oversight of
Idaho Power and Avista's Demand Side Management (DSM) programs. Neither of those two
companies is required to get Commission approval for detailed program adjustments.
Cost-Effectiveness
The Company believes the Program will continue to be cost-effective with the proposed
changes. Except for the envelope measures, each of the Program's measure groups passes the
Total Resource Cost Test (TRC)'. The TRC ratio for the envelope measures is 0.916, although
this measure group is relatively small in the overall Program, and passes the enhanced PTRC
Test as well as the Utility Cost Test 2.
The Company must pursue all cost-effective energy measures. Accordingly, it must
improve its DSM by eliminating or modifying measures that are not to be cost-effective, and
'The TRC Test is a program cost-effectiveness test that reflects the program's total costs and benefits to all
customers in the utility's service territory. A benefit/cost ratio greater than 1.0 under the TRC Test means that the
program is beneficial to the utility and its ratepayers on a total resource cost basis.
The PTRC Test is an enhanced TRC test with a conservation adder. The UCT calculates a program's costs and
benefits from the utility's perspective (i.e., how the program will impact the utility's revenue requirement).
STAFF COMMENTS 5 JUNE 26, 2012
implement measures that it believes will be cost-effective. Though Staff supports the
Company's proposed changes, a third-party impact evaluation will need to be completed to
determine the Program's actual electricity savings.
STAFF RECOMMENDATIONS
Staff recommends the Commission approve the Company's Application and proposed
changes to the Company's Program. Staff reminds the Company that approval of this
Application does not guarantee that the Commission will find that Program expenditures were
prudent. Program expenditures will be evaluated for prudency when the Company seeks a
determination on its entire DSM portfolio.
Respectfully submitted this 2 day of June 2012.
Karl T. Klein
Deputy Attorney General
Technical Staff: Donn English
Stacey Donohue
umise:comment&'pae 12.1 Okkdesd comments
STAFF COMMENTS 6 JUNE 26, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF JUNE 2012,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. PAC-E-12-10, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareguest(Zlpacificorp.com
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 5 MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel. [e-mail]
SECRETARY
CERTIFICATE OF SERVICE