20141113final_order_no_33178.pdf

Office of the Secretary
Service Date
iSovember 13,2014
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DBA ROCKY MOUNTAIN )CASE NO.PAC-E-14-08
POWER FOR AUTHORITY TO MAKE )
REVISIONS TO ITS ELECTRIC SERVICE )
SCHEDULE 155,AGRICULTURAL ENERGY )ORDER NO.33178
SERVICES )
On August 22,2014.PacifiCorp dba Rocky Mountain Power (“Rocky Mountain”or
“Company”)filed an Application,pursuant to Idaho Code §ss 61-301,61-307,61-622,and 61-
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.Rocky Mountain requests that these three Electric Service Schedules be cancelled
effective November 1.2014.
On September 25,2014,the Commission issued a Notice of Application,Notice of
Intervention Deadline and Notice of M:odified Procedure with a 21 -day comment period.See
Order No.33138.Subsequently,Idaho Conservation League (“ICL”)filed a Petition to
Intervene and was granted permission to intervene as a party.See Order No.33152.
Commission Staff and ICL submitted written comments regarding the Company’s Application.
Rocky Mountain later submitted reply comments.
THE APPLICATION
Rocky iVountain states that in filing its Application it is seeking to:(1)consolidate
three non-residential energy efficiency programs into a single program,wattsmart Business;(2)
enable any future modifications to the tariff similar to Schedule 115 format;(3)increase
incentive levels;(4)expand the tariff to include energy management services and incentives;(5)
update and expand the prescriptive incentive offer;and (6)include a new offer for small
businesses.
The Company also included the direct testimony and exhibits of Ms.Kathryn C.
Hymas,Vice President of Rocky Mountain Power Finance and Demand-Side Management
(“DSM”)in support of its Application.
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Rocky Mountain requested that the Commission process its Application through
Modified Procedure.
STAFF COMMENTS
Staff recommended the Commission approve the Company’s Application.Staff
emphasized that its recommendation was not an endorsement of any particular program
expenditure and that it would analyze the prudency of the Company’s DSM expenditures in the
Company’s next DSM prudency case.
Staff stated that its analysis consisted of a review of the program changes,cost-
effectiveness calculations and compliance with the Demand Side Management Memorandum of
Understanding (“DSM MOU”).
According to Staff,the Company’s proposal attempts to increase program
participation and avoid participant confusion by consolidating its three non-residential programs
into a single Idaho program called “wattsmart Business.”The Company also proposes to modify
and expand some incentives due to code and standard changes,third-party recommendations,and
new market data.Prescriptive measures changes,such as lighting,HVAC,food service,
compressed air,farm and dairy have been modified and updated.
Staff believes that,with some customers,their current program could unintentionally
impede program performance by making customers move between different
commercial/industrial programs because the scope of a project changes.Staff believes the
Company’s proposed modifications may make the programs more comprehensive and increase
participation.Staff noted that the Company has previously consolidated its non-residential
programs in its Utah service territory.
Staff referred to the DSM MOU’s requirement that the Company analyze cost-
effectiveness from a variety of perspectives,including the Total Resource Cost (TRC)and the
Utility Cost Test (UCT)1,with the overall goal of being cost-effective.If a measure or program
is not cost-effective on a stand-alone basis,the utility must explain why the measure or program
was implemented or continued.During a DSM prudency review,Staff takes into consideration
the reasonableness of all measures and programs offered (or not offered)in the context of a
The TRC test reflects the program’s total cost and benefits to all customers in the utility’s service territory.A
benefit cost ratio greater than 1.0 means that the program is beneficial to the utility and its ratepayers on a total
resource cost basis.The UCT calculates a program’s costs and benefits from the utility’s perspective (i.e.,how the
program will impact the utility’s revenues requirement).
ORDER NO.33178 2
broad-based DSM portfolio.Staff notes that all measure categories are forecasted to pass either
the TRC or UCT on a stand-alone basis and the wattsmart Business program is cost-effective
from both the TRC and UCT.
Staff remarked that the Company’s approach puts an emphasis on systematically
changing individual or organizational behavior towards energy management.According to Staff,
these programs have been increasingly implemented around the country and in the Northwest
with demonstrated energy savings and overall cost-effectiveness.Staff believes the Company’s
additions and modifications to its program are appropriate.Rocky Mountain’s proposal consists
of traditional DSM offerings,such as capital projects,and relatively newer approaches such as
Energy Management.Staff believes the proposed changes appear to be reasonable and are
focused on improving participation.
ICL COMMENTS
ICL recommended the Commission approve Rocky Mountain’s Application,subject
to some minor changes.According to ICL,combining the existing separate programs into a
single wattsmart Business program will assist customer understanding and should reduce RMP’s
administrative burdens.
ICL expressed a concern that Rocky Mountain’s proposed procedure to make
program changes does not allow for public involvement until late in the process.ICL suggested
an informal comment opportunity provided by the Company.
ICL disagrees with Rocky Mountain’s assumption that no additional energy savings
will result from an on-site energy manager.ICL believes that this is a highly conservative
estimate,as merely having someone focused on energy will almost certainly result in savings
from simple things like turning off lights,or addressing malfunctioning equipment.
ICL believes that updating the baseline should depend on the lighting installed in
Rocky Mountain’s Idaho service territory,rather than a change in the standard.ICL
recommended the Commission require RMP to document their Idaho business customers have
actually converted from T12 to more efficient lights.
ICL opposes the Company’s proposal to discontinue the New Construction Design
Assistance,Design Honorarium and Design Team Incentives,and recommended the Company
continue to offer these programs in the combined wattsmart Business portfolio.
ORDER NO.33178 3
While ICL supports the Company’s proposal to target small businesses,ICL believes
that the Company should include additional measures beyond lighting,specifically measures to
address office equipment as well as heating and cooling needs.ICL argues that Rocky Mountain
should encourage parties to wring the maximum amount of savings from each interaction.ICL
recommended the Commission approve the proposed small business offering and encourage
Rocky Mountain to expand its program measures.
ICL lauded Rocky Mountain for proposing important changes to its non-residential
programs.According to ICL,Rocky Mountain’s proposals,overall,reflect best practices of
leading programs around the country.ICL made the following recommendations:(1)approve
the consolidation of non-residential programs into wattsmart Business;(2)allow a flexible tariff
provided that stakeholders may comment on changes in the same manner and timing as
Commission Staff;(3)approve the Energy Management Offering including the co-funding of an
on-site energy manager;(4)approve updated prescriptive incentives based on revised RTF
savings and changes in codes and standards actually reflected in RMP’s Idaho service territory;
and (5)approve the Small Business Offering and encourage RMP to add additional measures
beyond lighting.
COMPANY REPLY COMMENTS
The Company submitted reply comments in response to ICL’s proposed changes to
Rocky Mountain’s Application.The Company stated that it 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.
While Rocky Mountain values customer input,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 JCL that updating the baseline should align with the
lighting installed in the Company’s Idaho service territory.This research was completed and the
Company recommended the Commission not mandate another lighting baseline study.Given
that the general service fluorescent lighting federal standard (effective July 14,2012 for lamps)
ORDER NO.33178 4
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 1,2014,was an appropriate time to
make the baseline change,Thus,the Company does not believe additional research to document
that Idaho business customers have actually converted from T12 to more efficient lights provides
added value.
The Company recommended approval of the small business lighting as submitted in
the Application.However,the Company will continue to review other possible qualifying
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.
In conclusion.Rocky Nountain made the following recommendations based on its
original Application and reply comments:approve the discontinuance of the New Construction
Design Assistance,Design Honorarium,and Design Team Incentives;not mandate an informal
comment period for interested stakeholders to comment on proposed changes;not require
additional research on Idaho business customers’conversion from T12 to more efficient lights;
and approve the small business lighting as submitted in the Application.
COMMISSION FINDINGS
The Commission has reviewed Rocky Mountain’s filing and considered the parties’
various recommendations regarding the Company’s proposed consolidation of 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.The Commission finds that the Company’s proposal to
consolidate the aforementioned Electric Service Schedules is fair,just and reasonable.The
Commission agrees that the consolidation of these schedules represents a necessary
‘streamlining”of the Company’s service offerings.
The Commission recognizes ICL’s recommendation to increase customer
participation in these types of proceedings.Nonetheless,the Commission finds that a separate
ORDERNO.33178 5
proceeding to solicit customer input through an “informal”process is unnecessary.The
Commission is satisfied that customers currently have an adequate opportunity to comment in
these types of proceedings.Specifically,the Commission notes that Rocky Mountain has
committed to allow its customers,including groups such as ICL,to its review proposals and
provide opportunities for them to comment contemporaneously with Staff.
Additionally,the Commission approves the discontinuance of the New Construction
Design Assistance,Design Honorarium,and Design Team Incentives as proposed in the
Company’s Application.Staff and ICL did not object to the discontinuance of these program
incentives.
The Commission approves the Small Business Lighting offer proposed by the
Company.The Commission finds that utilizing Company-approved and managed contractors to
assist small business customers to identify energy efficiency upgrades,estimate savings and
incentives,and install high-efficiency equipment is a worthy endeavor that may yield significant
energy conservation savings.
Finally,the Commission cannot identify any benefit derived from mandating the
Company to conduct additional research on Idaho business customers’conversion to more
efficient lighting.The new federal fluorescent lighting standard for manufacturers and imports
went into effect in 2012,and will necessitate a conversion to more efficient lighting as small
business customers replace their lighting.
CONCLUSIONS OF LAW
Rocky Mountain Power is an electrical corporation.The Commission has jurisdiction
and authority over Rocky Mountain and the issues in this case under Title 61 of the Idaho Code
and the Commission’s Rules of Procedure,IDAPA 31.01.01.000,et.seq.
ORDER
IT IS HEREBY ORDERED that Rocky Mountain’s Application to consolidate its
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,is approved.
IT IS FURTHER ORDERED that the discontinuance of certain incentives and the
implementation of a new Small Business Lighting offer,as discussed more fully above,are also
approved.
ORDERNO.33178 6
THIS IS A FINAL ORDER.Any person interested in this Order may petition for
reconsideration within twenty-one (21)days of the service date of this Order.Within seven (7)
days after any person has petitioned for reconsideration,any other person may cross-petition for
reconsideration.See Idaho Code §61-626.
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this ,
day of November 2014.
ATTEST:
Jean D Jewell
C’bmmission Secfetary
O:PAC-E-I 4-08np2
MARSHA H.SMITH,COMMISSIONER
MACK A,REDFORD,
ORDERNO.33178 7