20141114Comments.pdf

DONALD L. HOWELL, II
DAPHNE HUANG
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 3 34-03 t2t 33 4-03 18
IDAHO BAR NOS .336618370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER REQUESTING A
PRUDENCY DETERMINATION ON ITS
DEMAND.SIDE MANAGEMENT
EXPENDITURES FOR YEARS 2010.2013.
il0v lh r:{r6
CASE NO. PAC.E.IA.O1
COMMENTS OF THE
COMMISSION STAFF
i"liilii ii'...'.'..
ii I i-i :; ili. ;,i.' i i:l.,:(ji'
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission by and through its attorneys submits
the following comments regarding the above referenced case.
BACKGROUND
On July 7,2014, PacifiCorp dba Rocky Mountain Power ("Rocky Mountain Power" or
"the Company") filed an Application requesting the Commission find that the utility prudently
incurred $25,765,486 in demand-side management (DSM) expenditures for the years 2010
through 2013. This amount includes $17,664,805 funded through Schedule 191 (Customer
Efficiency Services Rate Adjustment) and $8,100,681 from Irrigation Load Control incentive
payments. "DSM" generally refers to utility activities and programs that encourage customers to
use less overall energy or use less energy during peak usage hours. Rocky Mountain's energy
efficiency programs include: Low Income Weatherization/Education (Schedule No. 21);
FinAnswer Express (Schedule No. I l5); Refrigerator Recycling (Schedule No. 1 17); Home
Energy Saver (Schedule No. I l8); Energy FinAnswer (Schedule No. 125); and Agricultural
STAFF COMMENTS NOVEMBER 14,2014
Energy Services (Schedule No. 155). Rocky Mountain also offers a peak reduction program, the
Irrigation Load Control Program. In this Application, the Company is requesting permission to
recover its DSM expenses from the deferral account and is not requesting an increase in its DSM
tariff Rider (Schedule No. 191).
Rocky Mountain asserts that its six energy efficiency programs resulted in gross energy
savings of 55,435,250 kwh for the years 2010-2013. The Company acknowledges that two of
the six energy efficiency programs were not cost-effective in all years, First, the Agricultural
Energy Service Program was not cost-effective in 2013 when its benefit/cost ratio for the Total
Resource Cost (TRC) testl was 0.84. Second, the Low Income Weatherization Program was not
cost-effective under the TRC or Utility Cost Test (UCT) in any of the years under review. The
Company reports that it has taken actions to improve the cost-effectiveness of the Low Income
Weatherization Program. Id. at 16.
STAFF ANALYSIS
Staff has reviewed the Company's Application along with the accompanying Testimony
and Exhibits of Kathryn Hymas. Staff performed an audit of the Company's internal controls
and processes, interviewed program managers, and reviewed different projects for proper
documentation, including invoices, engineering estimates, and post-installation verification.
Throughout its audit, Staff discovered the Company has rigorous intemal controls designed to
prevent the imprudent use of Rider funds. Staff also believes that the intemal controls help
ensure the correct benefits and costs are allocated properly to each of the Company's
jurisdictions. Based upon the results of the audit, Staff recommends that the Commission
approve the Company's requestthat$25,765,486 in DSM expenses from 2010-2013 were
prudently incurred. This amount consists of $17,664,805 in Rider funded expenditures and an
additional $8,100,681 in incentive payments associated with the Idaho lrrigation Load Control
([C) progrErm.
' The Company calculates cost-effectiveness from several perspectives. The TRC compares the total cost of a
supply side resource to the total cost of a demand side resource; the UCT compares the total utility cost to the total
benefits associated with displacing or deferring supply side resources; the participant cost test (PCT) compares total
participant costs to the total participant savings; the ratepayer impact perspective (RIM) compares the impact of a
demand side resource on utility rates.
STAFF COMMENTS NOVEMBER 14,2014
The comments below discuss StafPs calculation and verification of the Rider balance and
expenses, the acquired savings, and each of the Company's program offerings. Additionally,
Staff discusses the Company's marketing activities and the progress of the Company's Low
Income Weatherization Assistance (LIWA) and education programs.
Rider Balance and Expenses
Staff has calculated the balance in the Company's DSM tariff Rider account as of
December 31,2013 to be a surplus (Company owes Customers) of $625,565. Table I below
illustrates the beginning and ending balances for 2010 through 2013.
Table I
2010 20t1 20t2 2013
Beginning Balance
Tariff Rider Revenue
Carrying Charges
DSM Expenditures
Ending Balance
$(2,238,820) $(3,845,842) $(1,564,181) $ 370,754
5,939,833 5,356,975 5,245,005 4,024,339
(31,829)(24,350)t2l 70,042
(7.sls.026) (3.050.96s) (3.310.191) 8.779.570)
sri 84s 842) sfi s64 r8r) S 170.754 s 625.565
The $8,100,681 in Irrigation Load Control (ILC) program expenses related to demand response
credits are not included in the table above. In April 2011, the Commission ordered ILC expenses
to no longer flow through the Company's DSM Rider and instead be system-allocated with
Idaho's share of program costs shifted to base rates. Order No. 32196. The $8.1 million in
incentive payments is already reflected in base rates. An additional $4.2 million in
administrative costs for 2010 was charged to the Rider and has been included in the table above.
Although the Company recovered the 2010 incentive payments through base rates, it still seeks a
prudency determination on those funds.
In 2011 the Company changed its reporting for the DSM Rider account from cash basis
to accrual basis. Table 1 above reflects accrued expenses and Rider balances as reported in the
annual DSM reports. The amount for which the Company seeks a prudency determination is
based on cash accounting, thus the expenses reflected above do not match with the Company's
Application. The actual prudently incurred expenses by year are shown below:
STAFF COMMENTS NOVEMBER 14,2014
YEAR
20r0
20t0
20tl
2012
2013
EXPENDITURES
$ 7,515,026
$8,100,68 1 (load control incentives)
$ 2,815,694
$ 3,459,989
$ 3,874.096
$25,765,486
Energy Savings
Staff compared the Company's acquired energy savings to its Conservation Potential
Assessment (CPA) and the Integrated Resource Plan (IRP) to determine if the Company is
pursuing all cost effective DSM. A CPA is developed by an independent evaluator
approximately every two years to estimate future DSM potential system-wide over a2}-year
period. The CPA includes two categories, technical potential and achievable technical potential.
Technical potential assumes all energy efficiency available is acquired. Achievable technical
potential assumes that 85o/o of the technical potential is achieved. This latter "ramp rate"
considers customer acceptance levels and is consistent with the Northwest Power Council's
methodology. The CPA results are important because they help evaluate the IRP process. The
IRP methodology bundles measures with similar levelized costs and selects cost-effective
resources.
From 2010 -2013, the Company acquired 55,435 MWh of energy savings. This
outpaced its IRP savings by 17,327 MWh, but fell short of its achievable technical potential
derived from its CPA by 2,974 MWh. The Company's acquired savings each year surpassed its
annual IRP target with the exception of 2010. However, the Company's acquired savings
exceeded their CPA achievable technical potential in20l2 and2013. Table 2 as follows
summarizes and compares the Company's acquired energy savings to its CPA and IRP goals
from 2010-2013.
STAFF COMMENTS NOVEMBER 14,2OI4
Program 2010 *2011*2012*2013*
Low Income
Weatherization-21
78,448 276,486 279,528 113,440
Home Enersv Savinss-l 1 8 3,662,254 2.6sr.341 2,916,774 2,800,547
See va later. refrieerator-1 17 1,138,658 1,037,069 898,533 772,235
Subtotal Residential 4,979,360 3,964,896 4.094.835 3.686.222
Enersv FinAnswer-125 1,609,040 532.t35 342,904 2,528,961
FinAnswer Express-l 15 3,864,185 2,442,275 4,884,553 5.836.802
Subtotal
Commercial/Industrial
5,473,225 2,974,410 5,227,457 8,365,763
Agricultural Energy
Services-1 55
2,742,918 2,574,126 3,292,325 8,159,713
Subtotal Asricultural 2.742.918 2.574.126 3,292,325 8,159,713
Total Enersy Efficiency r3.09s.s03 9.513.432 12,614,617 20.211.698
IRP Goal 15,145,000 6,856,000 8,482,000 10.690.000
CPA Achievable Technical
Potential
23,065,000 g,6g4,ooo 11,088,000 14,563,000
Table 2
*Savings reported as kWh/Yr gross savings at generation.
To determine the energy savings for its prescriptive programs, the Company uses
measure-level savings estimates from the Regional Technical Forum (RTF) and "RMP deemed"2
savings. The Company's deemed savings are calculated using the results of its impact
evaluations and the RTF methodology. During Staff s audit, Rocky Mountain explained that
while it supports and frequently uses the methodology of RTF estimates, the secondary data on
which the RTF relies often comes from very urban service territories that may not reasonably
reflect the baselines, market characteristics, customer usage patterns, and other assumptions in
Rocky Mountain's rural service territory.
In addition, Rocky Mountain maintains a transparent and detailed Technical Resource
Library (TRL) that documents the sources, dates, methodology, and workpapers used to derive
all prescriptive savings estimates. Staff reviewed the TRL during its audit and believes it will
2 Th" RTf is a NW Power and Conservation Council advisory committee that develops standards to estimate
savings from energy efficiency measures. The Company has confirmed that in this case, "deemed" means
"prescriptive."
STAFF COMMENTS NOVEMBER 14,2014
continue to be useful for additional audits if Staff has future concerns over the derivation of
Rocky Mountain's savings. Consequently, Staff believes that the Company's approach to
calculating its prescriptive savings is reasonable.
The current filing is the Company's first prudency request under the 2009 DSM
Memorandum of Understanding (MOU). Staff notes the Company's annual reporting has
gradually aligned with the intent of the MOU for reporting purposes. For example, the Company
now includes a more comprehensive measure list in its 2012 and 2013 reports. However, Staff
believes the Company's annual DSM reports should include a more detailed description of the
assumptions used to calculate cost effectiveness. Consequently, Staff recommends the Company
work with Staff on its reporting measures so that these are included.
All standard service classes fund DSM programs through Schedule No. 191, which
specifies a uniform percentage to be applied to a customer's monthly bill. Staff reviewed the
energy savings over the period to determine whether energy savings parity exists between
customer classes. Although yearly fluctuations exist, a four-year average of energy savings
yielded residential savings of 30%o, commercial/industrial of 40%o, and agricultural at30o/o.
Beginning in2012, the Company no longer includes its evaluation, measurement and verification
costs as a program expense, but as a portfolio cost. Therefore, it was difficult to determine
whether the Company's expenditures were equitable for the customer classes.
The Company did not provide funding for the Northwest Energy Efficiency Alliance
(NEEA). Staff believes this is reasonable because the Company's largely agricultural and
industrial load characteristics did not compare with NEEA's more urban, residential market
transformation efforts.
Staff also compared the measures offered in the Company's Utah service territory to
those offered in its Idaho service territory. With the recent Commission approved "wattsma.rt"
Business tariff, all non-residential measures offered in Utah are also offered in Idaho except the
agricultural prescriptive measures. Per Commission Order No. 32879, these agricultural
measures were removed. See Staff comments on page 13 for further discussion. The Company
offered several residential measures in Utah not offered in Idaho. However, these measures are
intended to reduce cooling load, which the Company believes is less prevalent in its Idaho
service territory.
STAFF COMMENTS NOVEMBER 14,2014
DSM Marketing
Staff thoroughly reviewed the Company's marketing and outreach efforts. The Company
uses a variety of media channels to reach out to customers. Some examples include: print, bill
inserts, radio, digital ads, email blasts, social media, and TV spots. While Staff is satisfied with
the messaging content, Staff notes that despite the Company's efforts, a majority of industrial
and commercial customers are unaware of the Company's energy efficiency programs. Staff
believes the lack of a structured non-residential marketing plan could be the primary cause of
low non-participant awareness.
The Company's third party evaluator conducted a non-participant study for its non-
residential programs. The evaluator concluded that 72%o of Rocky Mountain's industrial
customers and 57Yo of its commercial customers were unaware of the Company's efficiency
incentives and technical assistance. According to the evaluation, "low awareness that RMP
offers technical assistance and incentives may limit participation by eligible customers."
Q{avigant, Energy FinAnswer Evaluation, pg. 56.) Both programs are marketed primarily
through local trade allies with support from the Company's consultants, and customer and
community mangers. In response to Staff s production request to provide marketing plans for all
its programs, the Company provided marketing plans for its residential programs only. While
Staff recognizes that local trade allies have a vested interest to market the Company's efficiency
programs, Staff believes the Company should develop a more structured method to advertise its
non-residential DSM programs. Staff notes that a majority of agriculture non-participants were
aware of the Company's incentives and technical assistance, but believes the Inigation Load
Control program is the basis of such high awareness. A non-participant study for the residential
sector was not conducted.
Staff was unable to determine the Company's total marketing expenditures compared to
its total DSM budget because marketing costs are embedded in the program administrator's cost.
Staff was able to determine the Company's marketing efforts rely upon a combination of extemal
marketing firms, internal marketing and its third-party program administrators.
The Company is aware of its marketing challenges and has informally indicated it will
work to enhance its marketing and outreach efforts in part through its recent wattsmart Business
tariff.
STAFF COMMENTS NOVEMBER 14, 2OI4
Residential Programs
Rocky Mountain Power offers three residential programs: See Ya Later, Refrigerator
(SYLR), Home Energy Savers (HES), and Low Income Weatherization. The Company has
effectively augmented and adapted residential program delivery in addition to instituting new
programs when necessary.
1. SYLR. Rocky Mountain Power's refrigerator/freezer recycling program, SYLR, is
similar to programs offered by many other utilities in the region and throughout the country. But
in addition to picking up the refrigerator or freezer for decommissioning and recycling, Rocky
Mountain takes the opportunity to deliver an energy savings kit to the participating customer at
the same time. The savings kit includes "two CFLs, a refrigerator thermometer card, energy-
savings educational materials, and information on other efficiency programs relevant to
residential customers."3 While these supplemental measures generate only about 5 percent of the
program's total energy savings, it is an effective method for leveraging the existing program to
generate extra energy savings. The savings kit educates customers on the Company's other
incentive programs and offers additional ideas about how to use energy more efficiently.
However, the program is not without its challenges. Pickups are scheduled an average of
17 days after the initial customer request and are only available on weekdays.a The Company's
rural customers often wait longer than 17 days for their refrigerator to be picked up. Although
participants report high satisfaction with the program, the average age of participants is 59,
which could indicate that the long lead time on pickups makes it difficult for customers with full-
time weekday jobs to participate.
In order to capture the savings from those units when a customer cannot wait two weeks
for a pickup, Rocky Mountain has started incenting participating retailers to decommission and
recycle units collected from customers when the customer replaces an existing refrigerator.
Some retailers refurbish and sell collected units on the secondary market, so retailer pickups and
decommissioning can help reduce the influx of inefficient units into secondary markets.
2. HES. The Home Energy Savers (HES) program offers "upstream" incentives to
manufacturers to reduce retail prices on residential lighting and customer incentives for
3 Rocky Mountain Power, 2013 Idaho Energy Efficiency and Peak Reduction Annual Report, page24.
o Pickups are scheduled within a two-hour window, which is an improvement from the previous four-hour pickup
window.
STAFF COMMENTS NOVEMBER 14,2014
purchasing high-efficiency clothes washers, refrigerators, electric water heaters, windows,
insulation, and high-efficiency HVAC equipment and services. In general, this is another
example of a well-run and proactively managed efficiency program. For example, Rocky
Mountain recently added online applications for all of its appliance incentives. The online
application process automatically validates both customer eligibility (using Rocky Mountain
account numbers) and appliance eligibility (using model numbers) instantaneously. This method
saves the customer the trouble of trying to locate their model number on a qualiffing product list
and lets the customer know immediately whether their purchase qualifies for an incentive. In
addition, this method improves cost-effectiveness because the Company saves the administrative
expense of screening for non-qualifying applications. Since deployment of the online
application in late 2013, the Company has seen 50 percent of its applications submitted online
and expects that percentage to exceed 75 percent by the end of 2014. Further, Rocky Mountain
has begun offering incentives for appliances on the Consortium for Energy Efficiency (CEE) list,
which are appliances, rated 20 percent above code, rather than Energy Star models, which are
rated 10 percent above code. In addition to online applications, Rocky Mountain was one of the
first utilities to recognize the value of LED energy savings and began incenting them in August
2012, well ahead of many other utilities.
Despite these accomplishments, Staff noticed two anomalies in the calculation of the
program's lighting savings. First, the 2011 impact evaluation found that the estimates for
lighting savings did not include a waste-heat factor. More efficient lighting produces
significantly less heat than incandescent lamps and therefore increases the amount of energy
needed for space heating. It is generally accepted practice for lighting calculations to include
this space heat penalty, but Rocky Mountain did not include it in either program planning or
program savings estimates until2012. Second, Staff noticed that the Company used Regional
Technical Forum (RTF) savings estimates for its residential lighting program until 201l, when it
began using the values from its impact evaluation. When asked about the shift, Rocky Mountain
advised Staff that its program had been developed around lamp wattage, so when the RTF began
grouping savings by lumen, those findings did not readily transfer into the Company's program.
Staff believes the Company's explanation for the change in lighting program savings is
reasonable.
STAFF COMMENTS NOVEMBER 14, 2OI4
3. Low Income Weatherization. Rocky Mountain Power provides $300,000 annually
to the Eastern Idaho Community Action Partnership (EICAP) and Southeastern Idaho
Community Action Agency (SEICAA) to provide low income weatherization services for
income qualifying customers. Idaho homes receiving weatherization funding through this
program decreased by 28 percent from 2012 to 2013. Most of the decline was attributable to
SEICAA, which weatherized only 23 homes in 2013. In response to discovery, Staff learned that
SEICCA is having difficulty finding electrically-heated, income qualified customers who are
willing to participate. Rocky Mountain has commiffed to o'provide a list of the 100 highest kWh
users that receive energy assistance in the counties that SEICAA serves in an effort to assist them
in identiffing potential participants." The Company also plans to "discuss additional ways to
help promote the program."s Staff believes this collaboration is necessary to improve program
participation.
In addition to the shortage of weatherization candidates, SEICCA had approximately 100
energy saving kits remaining at the end of 2013 from the original 500 ordered in late 2010. In
2013 SEICAA purchased 1,495 shower timers and 1,271night lights to help Rocky Mountain
comply with the 2011 Commission order to provide $25,000 in Conservation Education funding
annually.6 Staff supports Rocky Mountain's effort to increase participation for the low income
weatherization program and will continue to monitor the distribution of energy kits to determine
if more effective or complementary education methods should be adopted. Staff notes the
Company reported EICAP and SEICCA information differently in its Annual Report. Staff
recommends the Company use a similar reporting format for the EICAP and SEICAA Low
Income Education Program. This helps facilitate Staff s understanding of the similarities and
differences in each agency's program.
During Staff s audit of Rocky Mountain's prudency filing, it learned that CAP agencies
frequently do not replace inefficient refrigerators in low income homes because state rules
appear to require background checks for vendors who enter program participants' homes. Since
the cost-effectiveness of low income programs could be significantly improved by replacing
s Rocky Mountain Power, Response to IPUC Data Request 21.
u Energy saving kits are distributed to low-income RMP customers with electric space heating. The shower timers
and night lights will be added to kits, and also will be distributed as stand-alone items to customers who do not have
electric heat.
STAFF COMMENTS l0 NOVEMBER 14,2014
refrigerators, Staff recommends Rocky Mountain and the CAP agencies find ways to replace
more inefficient refrigerators through this program.
In response to Staff s production request, Rocky Mountain confirmed that it offers
several measures to its Utah residential customers that are not available to Idaho residents. Most
of the Utah-specific measures are intended to reduce cooling load which, according to the
Company, is less prevalent in the Company's Idaho territory. However, the Company offers
both a behavior-based program and an incentive program for new construction in its Utah service
territory, neither of which are available in Idaho. In 2015, the Company plans to expand its
residential behavior-based program, which are Home Energy Reports distributed by mail through
OPOWER to its Idaho customers.
The only residential energy efficiency program not offered in Idaho targets new
construction. The Company has acknowledged this shortcoming and discussed it with Staff.
Since new construction has been sluggish in Rocky Mountain's Idaho territory, Staff understands
that this has not been a high priority. However, Staff encourages the Company to continue
monitoring the market for evidence that this program should be offered.
Non-Residential Programs
The Company's two commercial and industrial programs, Energy FinAnswer and
FinAnswer Express, operate in tandem to provide custom and prescriptive incentives.
Agricultural Energy Services provides custom and prescriptive incentives for the irrigation
customer class.
l. Energy FinAnswer. This program provides custom incentives for large,
comprehensive projects including new construction and retrofits. Interestingly, lighting projects
are generally not offered in this program. The Company administers the program, but outsources
implementation to energy engineering firms and trade allies in order to perform energy analysis,
quality assurance and savings verification. While conducting an on-site audit of the Company's
programs, Staff thoroughly reviewed the Company's extensive verification process. For
example, after a customer signs a letter of intent to use the Company's energy effrciency
services, a pre-approved energy engineering firm is selected to physically inspect the industrial
site. A report is generated resulting in an energy analysis that lists all energy efficiency
measures, expected savings and costs, and incentive levels. This report is then peer-reviewed by
11STAFF COMMENTS NOVEMBER14,2OI4
a separate engineering firm for quality control before the report is sent to the customer. This
level of review is important to include early in the process because it is the information
customers use to make large investment decisions. This level of quality control is completed for
all custom projects.
Following project completion, the same engineering firm that conducted the initial energy
analysis then conducts post-installation verification. Most custom projects undergo
commissioning, which is usually a 3-4 week process before the incentive is paid. A final
inspection report documents measures installation and energy savings. The appropriate invoices
are also collected to verify installed measure costs. Following this report, the Company conducts
another layer of verification. The Program Manager then signs a compliance form that goes to
the Commercial and Industrial (C&I) Director. Some of the Company's engineering firms
believe that the extent of reporting "and associated quality control reviews were by far the most
rigorous that they had seen among different programs over time" (Navigant, Energy FinAnswer
Evaluation, pg. 53). Staff encourages the Company to continue being thorough with its reporting
and quality control.
2. FinAnswer Express. This program provides prescriptive incentives for new or
retrofit projects, such as lighting, HVAC, motors, building envelope, and other equipment
measures. The program also offers customer incentives and technical analysis. According to
StafPs review, the majority of savings are derived from lighting, a trend Staff expects to increase
in the future. The Company outsources its program administration to Nextant (commercial
projects) and Cascade Energy (industrial/agricultural projects) for trade ally coordination,
training and application processing services. A series of quality controls exist, such as lighting
calculators to determine energy savings, post-inspection requirements to veri$ measure
installation and mandatory receipt/invoice submittal.
Staff reviewed the Company's impact evaluation conducted by Navigant for the 2009-
2011 program years. The evaluation concluded that the 2011 program year was cost effective
from the UCT perspective, but failed the TRC with a benefit/cost ratio of 0.91. Accordingly, the
primary cause of the program failing the TRC in2011 was due to the inclusion of Office of
Energy Resources (OER) projects that used additional measures. When OER projects were
excluded, the program was cost effective from all perspectives.
STAFF COMMENTS t2 NOVEMBER 14,2OI4
The Company incented 11 OER projects in 2011 and l3 projects in20l2, resulting in
547,389 kWh total OER savings. The Company generally maximizes its energy efficiency
programs by offering measures with the highest amount of savings. However, OER projects
consisted of measures that were not offered by the Company. Because the TRC calculation
includes all costs and all savings, Rocky Mountain had to include the high incremental cost of
those lower savings measures that were not offered by the Company. Navigant concluded that
the incremental cost of measures installed in 2011 was about 160% of the incremental cost of
measures installed in 2010, while the net evaluated savings for 2011 was about 600/o of the
savings reported in 2010. An impact evaluation for 2012 was not completed by the time of the
prudency filing. Staff expects that a future 2012 impact evaluation could yield similar cost
effectiveness results. Even though prescriptive commercial and industrial programs are usually
quite cost-effective and the OER projects lowered the TRC cost-effectiveness, the Company was
not out of compliance with the DSM MOU because the program was cost-effective from the
UCT perspective. Further, the Company was consistent in following its tariff language that
provided incentives for all individually qualiffing measures, even if the total project was not
cost-effective.
The Company recently filed an Application to condense its non-residential programs into
a single wattsmart Business tariff. Case No. PAC-E-14-08. Staff supported the Company's
proposal because it believed the current structure of the Company's non-residential programs
could unintentionally impede program performance by making customers move between
different programs due to a change in project scope midstream. Staff believes the Company's
proposed modification may make the programs more comprehensive and increase participation.
OrderNo.33178.
3. Irrigation. In May 2013, the Company submiued an Application (PAC-E-13-10) to
suspend its prescriptive measures for DSM Schedule 155, (Agricultural Energy Services). In its
filing, the Company proposed to suspend thenozzle exchange program and the pivot and linear
equipment measures because the multi-year, third-party analysis (2009-2011) concluded the two
options made the entire program cost-ineffective. By eliminating the poor-performers and
continuing to offer the custom option, the Company believed the program would be cost-
effective from all perspectives over the 2014-2016 timeframe. In that case, Staff reviewed
program energy savings, cost-effectiveness and program participation. Over the three-year
13STAFF COMMENTS NOVEMBER 14,2014
period, the prescriptive measures caused the entire program to fail the TRC. The UCT also
failed in each year except2009 when the TRC was L09. The Commission approved the request
in August 2013. Order No. 32967. Staff believes the Company's filing was prudent and
necessary given the cost-effectiveness of the program.
The program experienced a considerable increase in savings in 2013 that coincided with
the planned expiration date of the two options. Staff believes the expiration date may have
contributed to the considerable increase in participation. Staff notes some utilities have used the
expiration date as a marketing strategy, such as Avista's Tl2to T8 lighting transition, which also
yielded significant unexpected savings.
Tariff Compliance
Staff reviewed the Company's Schedule No. l9l for compliance and discovered
Schedule No. 8 to be subject to Schedule No. 191 charges. However, Schedule No. 8 no longer
exists. Consequently, Staff recommends the Company submit a corrected tariff that accurately
shows customer schedules subject to Schedule No. 191 changes.
STAFF RECOMMENDATION
Based on Staff s analysis, it believes the Company's DSM efforts were prudent. Staff
recommends the Commission:
1. Find that the Company prudently incurred DSM expenditures of $25,765,486. This
amount consists of $17,664,805 in energy efficiency expenses and $8,100,681 in
expenses associated with the Idaho Irrigation Load Control program.
2. Require the Company to work with Staff on adequate reporting assumptions used in
reporting cost-effectiveness.
3. Require the Company to use a similar reporting format for EICAP and SEICAA Low
Income Education program.
4. Require the Company to submit a revised Schedule No. 191 tariff to accurately reflect
customer schedules subject to its changes.
5. Require the Company and the CAP agencies to research and report to Staff options for
replacing more refrigerators through the Low Income Weatherization program.
STAFF COMMENTS 14 NOVEMBER 14,2014
,L
Respecttully submitted this ///day ofNovember 2014.
Donald L. Howell, II
Deputy Attorney General
Technical Staff: Stacey Donohue
Nikki Karpavich
Donn English
Curtis Thaden
i:umisc/comments/paoe l4.Tdhdjhsdnkdcct comments
STAFF COMMENTS l5 NOVEMBER 14,2OI4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY oF NOVEMBER 2014,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-14-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWNG:
TED WESTON
DANIEL E SOLANDER
ROCKY MOLINTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 841I I
E-MAIL: ted.weston@facifi corp.com
daniel. solander@pacifi corp.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE TD 83702
E-MAIL: [e-mail]
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERI'IELD MO 63017
E-MAIL : [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp. com
RANDALL C BUDGE
RACINE OLSON NYE BUDGE
& BAILEY
PO BOX l39l
POCATELLO ID 83204
E-MAIL : [e-mail]
E.MAIL ONLY
JAMES R SMITH
MONSANTO COMPANY
j im.r. [e-mail]
CERTIFICATE OF SERVICE