20141024Reply Comments.pdf

ROCKY MOUNTAIN lir[f;[l\rl1i]
m*F,"* ?grh gcT zb AH g: t+? 201 south Main, suite2300
Salt Lake City, Utah 84111
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October 23,2014
YA ELECTRONIC FILING
AND OWRNIGHT DELIWRY
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, D 83702
Re: CASE NO. PAC-E-14-08
IN THE MATTER OF THE APPLICATION OF ROCKY MOTINTAIN POWER
FOR AUTHORITY TO CANCEL ELECTRIC SERYICE SCHEDULES I.15, 125,
AND 155 AND REPLACE WITH NEW SCHEDTJLE 140 WITH CHANGES
Dear Ms. Jewell:
Please find for electronic filing Rocky Mountain Power's reply comments in the above
referenced matter. The Company has also shipped for overnight delivery an original and seven
(7) copies of its reply comments.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801\ 220-
2963.
Sincerely,
fu*wlKathryn Hymas
Vice President, Finance and Demand Side Management
Enclosures
CC: Benjamin Otto/ICL
Daniel E. Solander (ISB # 8931)
Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lake city, UT 841l1
Telephone : (80 l) 220 -40 I 4
Fax: [phone]
E-mail: daniel.solander@pacifi corp.com
Attomey for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF' THE
APPLICATION OF PACIFICORP DBA
ROCKY MOTINTAIN POWER TO
CAI\CEL ELECTRIC SERVICE
SCHEDULES 115, 125, AND 155 AI\D
REPLACE WITH NEW SCHEDULE I4O
WITH CHANGES
CASE NO. PAC-E-14.08
REPLY COMMENTS OF
ROCKY MOTJNTAIN POWER
COMES NOW PacifiCorp, dba Rocky Mountain Power ("RMP"
"Company"), and hereby responds to Idaho Conservation League's Comments
above referenced case.
BACKGROTJNI)
On August 22,2014, the Company filed an Application, pursuant to Idaho Code
$$ 6l-301, 6l-307,61-622, and 6l-623,with the Commission seeking to consolidate
Electric Service Schedules: No. 115 - FinAnswer Express; No. 125 - Energy FinAnswer;
and No. 155 - Agricultural Energy Services, with modification, under a new Electric
Service Schedule No. 140, Non-Residential Energy Efficiency.
On October 16, after review and analysis of the Application, the Idaho Public
Utilities Commission staff ("Staff') and Idaho Conservation League ("lCL") submitted
comments. Staffs comments recommended the Commission approve the Application,
or the
in the
and ICL's comments recommended the Commission approve the Application, subject to
minor changes.
ICL COMMENTS
ICL opposes the Company's proposal to discontinue the New Construction
Design Assistance, Design Honorarium and Design Team Incentives, and recommends
the Company continue to offer these programs in the combined wattsmart Business
portfolio.r In addition, ICL proposed the following modifications to the Company's
Application: (2) to allow for stakeholders to review and comment on proposed changes at
the same time as Commission Staff through informal comment;2 (3) update programs to
reflect changing codes and that updating the baseline should depend on the lighting
installed in the Company's Idaho service territory, rather than a change in the standard;
(4) the Company should document that their Idaho business customers have actually
converted from T12 to more efficient lights;3 and (5) Lastly, ICL submits the Company
should include additional measures beyond lighting, specifically measures to address
office equipment as well as heating and cooling needs.a
RMP REPLY COMMENTS _ ICL
The Company proposed removing the incentive for New Construction Design
Assistance, the Design Honorarium and Design Team Incentives due to the
comprehensiveness of the new offering and the low participation in these offerings. The
proposed streamlined program simplifies customer participation and provides the
elements of the existing programs that have been moving the market. The new program
t ICL Comments at 2.
2 ICL Comments at 3.
3 ICL Comments at 6.o Id.
focuses the customers' program participation and the Company's resources on the
program features that are most effective at delivering energy savings projects.
While comments from interested stakeholders as described by ICL are valued, the
Company does not feel that mandating an informal comment period for interested
stakeholders is required. Notwithstanding, the Company will ensure ICL or other
interested stakeholders are given the opportunity to informally review proposed changes
at the same time as Staff and provide comments.
The Company agrees with ICL that updating the baseline should align with the
lighting installed in the Company's Idaho service territory. This research was completed
and the Company recommends the Commission not mandate another lighting baseline
study. Given that the general service fluorescent lighting federal standard (effective July
14,2012 for lamps) applies to lighting manufacturers and imports of lighting, and does
not necessitate customers change their lighting until it fails, the baseline change for Idaho
was made approximately 18 months later on January 1,2014 after conducting research in
2013 to inform the timing for the change. The research built upon work undertaken by the
Bonneville Power Administration and included sales and survey data from commercial
lighting contractors, distributors and manufacturers as well as recent program participants
in PacifiCorp service territories (ID, UT, WY, WA and CA). The research concluded that
January l, 2014 was an appropriate time to make the baseline change. Based on this
research, the Company does not believe additional research work to document that Idaho
business customers have actually converted from T12 to more efficient lights has added
value.
With respect to additional measures, the Company recommends approval of the
small business lighting as submitted in the Application. However, the Company will
continue to review other possible qualiffing measures for the small business offering that
are found to be cost effective, and will bring those measures forward for Staff and
stakeholder input prior to implementation.
CONCLUSION
Based on the Application and these reply comments, the Company recommends
the following:
. Approve the discontinuance of the New Construction Design Assistance, Design
Honorarium and Design Team Incentives
o Not mandate an informal comment period for interested stakeholders to comment
on proposed changes
o Not require additional research on Idaho business customers' conversion from
Tl2 to more effrcient lights
. Approve the small business lighting as submitted in the Application.
Respectfully submitted this 23'd day of October,2014.
Q;.1 4fih
Daniel E. Solander
Attorney for Rocky Mountain Power