20140707Application.pdf

ROCKY MOUNTAINPOA'ER RECEIVT i"}
A DIVISION OF PACIFICORP
July 7,2014
VA OWRNIGHT DELIWRY
Jean D. Jewell
Commission Secretary
Idatro Public Utilities Commission
472West Washington
Boise,ID 83702-5983
20ll| JUL -? [l{ 9: 58 salt Lake citv' utah 84111
uT Ltr?rufCotl tii i E s r cru
Re: CASE NO. PAC-E-14-07
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
REQUESTING A PRUDENCY DETERMINATION ON DEMAIID.SIDE
MANAGEMENT EXPENDITURES.
Dear Ms. Jewell:
Rocky Mountain Power, a division of PacifiCorp, hereby submits for filing an original and seven
(7) copies of its Application in the above referenced matter.
Also enclosed for filing are nine (9) copies of the testimony of Kathryn Hymas. One Copy of
Ms. Hymas' testimony has been designated as the "Reporter's Copy." In addition, a disk
containing a Word version of Ms. Hymas' testimony is enclosed for the Reporter.
If you have any questions about the enclosed documents, please contact Ted Weston at 801-220-
2963.
Sincerely,
201 South Main, Suite 2300
'ffirt,g-lL
Uy'ffrey K. Larsen
tan@^fr,
Vice President, Regulation & Gov't Affairs
Enclosures
Daniel E. Solander, (ISB# 8931)
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake Ciry, Utah 84l l l
Telephone: [phone]
Email : daniel.solander@fracifi com.com
Attorneyfor Roclgt Mountain Power
IN THE MATTER OF THE APPLICATION )
oF ROCKY MOUNTATN POWER )REQUESTINGPRUDENCY )
DETERMINATION ON DEMAND.SIDE )
MANAGEMENT EXPENDITURES. )
RECEIV* {}
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BEFORE THE IDAHO PUBLIC UTILITIES COMNIISSION
CASE NO. PAC.E-14-07
APPLICATION
COMES NOW, Rocky Mountain Power, a division of PacifiCorp (the "Company"),
in accordance with RP 052 and RP 201, et. seq., hereby respectfully applies to the ldaho
Public Utilities Commission (the "Commission") for an order designating Rocky Mountain
Power's demand-side management ("DSM") expenses in the amount of $25,765,486, as
prudently incurred.
In support of this Application, Rocky Mountain Power states as follows:
l. Rocky Mountain Power is authorized to do and is doing business in the state
of Idaho. The Company provides retail electric service to approximately 73,500 customers in
the state of Idaho and is subject to the jurisdiction of the Commission. Rocky Mountain
Power is a public utility in the state of Idaho pursuant to Idaho Code $ 6I-129.
2. [n support of this Application requesting that the Commission deem that the
Company's 2010 through 2013 DSM expenses were prudently incurred, the Company
presents the testimony of Ms. Kathryn C. Hymas, annual DSM reports for each year, results
of the program cost effectiveness analysis, and the third-party program evaluation reports.
APPLICATION OF
ROCKY MOTINTAIN POWER
Page I
BACKGROUND
3. The Company has offered a variety of DSM programs to its customers since
the 1970s. All of the DSM programs offered by Rocky Mountain Power in Idaho have been
designed to be cost-effective. On March 2,2006, the Commission approved an enhanced set
of DSM programs and cost recovery through Schedule l9l, Customer Efficiency Services
Rate, which was applied to customers' bills beginning May 1, 2006.
4. This filing and the Annual DSM reports are consistent with the Memorandum
of Understanding the Company entered into in Case No. GNR-E-12-01, as approved by
Order No. 32788 ("MOU"). Rocky Mountain Power filed annual reports with the
Commission for program years 2010, 2011, 2012, and 2013. These reports followed the
format set forth in the MOU and included: Table of Contents, Introduction, Cost
Effectiveness, Program specific sections, and Evaluations. Program performance, including
expenditures, savings and assessments of cost effectiveness, as well as the balancing account
activity associated with Schedule l9l was also included in the annual reports.
5. The Company's DSM portfolio consists of seven distinct programs offering
incentives for a wide variety of energy efficiency measures to the Company's residential,
business and agricultural customers and participation in the irrigation load management
program to the Company's agricultural customers. The Company continues to work with
customers and the Commission to provide a comprehensive suite of DSM programs that
provides the greatest opportunity for participation by all customer sectors.
6. The seven DSM programs offered by the Company from 2010 through 2013
that were subject to Schedule 191 provided a wide range of services and financial incentives
APPLICATION OF
ROCKY MOUNTAIN POWER
Page2
to of assist customers with energy efficiency projects they wished to pursue. The DSM
programs were as follows:
Schedule 2l -Low Income Weatherization/ Low Income Education
Schedule 72 & 72A - Irrigation Load Control (effective in 2011 these program
expenditures were no longer included in Schedule I 9l . Schedule 72 & 72A were later
cancelled.l)
Schedule 115 - FinAnswer Express
Schedule 117 - Residential Refrigerator Recycling
Schedule 118 - Home Energy Saver Incentive
Schedule 125 - Energy FinAnswer
Schedule 155 - Agricultural Energy Services
ENERGY EFFICIENCY SAVINGS
7. The annual energy efficiency program savings of the Company's DSM
programs were as follows: 2010 energy efficiency program savings at the meter were 11,963
MWh and the Company's Irrigation Load Control program had participating loads under
management of 283 MW at meter. 201I energy efficiency program savings at the meter were
8,688 MWh and the Irrigation Load Control program reported participating load under
management of 258 MW at meter. 2012 energy efficiency program savings at the meter
were 11,420 MWh. In 2011, the Irrigation Load Control program was treated as a system-
wide benift. Performance results for 2012 were no longer included in the annual DSM reports
but were submitted as a confidential document to the Commission. 2013 energy efficiency
program savings at the meter in were 18,324 MWh.
I Case No. PAC-E-12-14, Order No. 32760.
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 3
8. The cost effectiveness results show that of the seven programs for which the
Company achieved energy savings, five of the programs had a benefit/cost ratio greater than
1.0 for both the TRC and UCT in all years. The Agricultural Energy Services program was
cost effective for both TRC and UCT for all years except in 2013 when the benefit/cost ratio
for the TRC was 0.84. The Low Income Weatherization program was not cost effective for
the TRC or UCT in any of the years.
PROGRAM EVALUATIONS
9. Evaluations are conducted using best-practice approaches and techniques
including those outlined in the National Action Plan for Energy Efficiency ("NAPEE")
Program Impact Evaluation and the California Evaluation Framework guides. The Company
conducts process and/or impact evaluations on energy efficiency and load management
programs to ensure the ongoing cost effectiveness of its programs through validation of
energy savings and to provide information to assist in management of its programs.
10. Process evaluations assess program delivery, from design to implementation,
in order to identiff bottlenecks, efficiencies, what worked, what did not work, constraints,
and potential improvements. Identifying opportunities for improvements is essential to
making corrections along the way.
I 1. Impact evaluations determine the impacts (e.g. energy and demand savings)
that directly result from a program. Impact evaluations also support cost effectiveness
analyses aimed at identiffing relative program costs and benefits.
12. Evaluations are based on credible and transparent methods and efforts to be
successful in capturing the savings that programs offer. Evaluations develop retrospective
estimates of energy savings attributable to a program. While evaluations will be retrospective
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 4
in nature, the information obtained will be used to inform future potential assessments, plans,
forecasts and targets.
13. The Company completed five process and impact evaluations during 2010.
Each of these evaluations was completed by third party consulting firms. Three of the five
programs evaluated during 2010 had a TRC and UCT benefit/cost ratio greater than 1.0.
Additional details on these two evaluations are presented in Ms. Hymas' testimony.
14. Two evaluations were completed by third party consulting firms in 2011. A
process and impact evaluation was conducted on the Low Income Weatherization program.
The cost effectiveness results of the 2007-2009 program evaluation found the program to not
be cost effective without non-energy benefits. The Irrigation Load Control program was
evaluated for 2009 and 2010 to determine demand impacts of the programs.
15. The Company completed tvro process and impact evaluations during 2012.
These evaluations were completed by third party consulting firms. All programs evaluated
during 2012had a TRC and UCT benefit/cost ratio greater than 1.0.
16. Four process and impact evaluations were completed during 2013. Each of
these evaluations was completed by third party consulting firms. All programs evaluated
during 2013 had a TRC and UCT benefit/cost ratio greater than 1.0 except for Agricultural
Energy Services program. The full results of these evaluations are presented in Ms. Hymas'
testimony and exhibits.
MODIFIED PROCEDURE
17. Rocky Mountain Power believes that a technical hearing is not necessary to
consider the issues presented herein and respectfully requests that this Application be
processed under Modified Procedure, i.e., by written submissions rather than by hearing. RP
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 5
201 et seq. Rocky Mountain Power has, however, contemporaneously filed Ms. Kathryn
Hymas' testimony in support of this Application. The Company stands ready to present the
testimony in support of this Application in a technical hearing if the Commission determines
such a hearing is required.
COMMUNICATIONS AI\[D SERYICE OF PLEADINGS
18. Communications regarding this Application should be addressed to:
Ted Weston
Daniel E. Solander
201 South Main, Suite 2300
Salt Lake City, Utah 841I I
Telephone : (80 l) 220 -29 63
Fax: [phone]
Email : [e-mail]
daniel.solander@fracifi corp.com
In addition, the Company respectfully requests that all data requests regarding this matter be
addressed to one or more of the following:
By e-mail (preferred): [e-mail]
By regular mail: Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
REQUEST FOR RELIEF
19. WHEREFORE, Rocky Mountain Power respectfully requests that the
Commission issue a final order designating Rocky Mountain Power's 2010 through 2013
DSM expenditures of $25,765,486 as prudently incurred.
APPLICATION OF Page 6
ROCKY MOUNTAIN POWER
DATED ttris Tmday of July, 2014.
Respectfu lly submitted,
Daniel E. Solander
Attorney for Rocky Mountain Power
APPLICATION OF
ROCKY MOUNTAIN POWER
PageT