20170405Reply Comments.pdf

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April5,2017
VA OWRNIGHT DELIWRY
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Idaho Public Utilities Commission
472West Washington
Boise,ID 83702-5983
Attn: Diane Hanian
Commission Secretary
RE: Case No. PAC-E-16-14
In the Matter of the Application of Rocky Mountain Power Requesting a Prudency
Determination on Demand-Side Management Expenditures
Reply Comments
Please find enclosed an original and seven (7) copies of Rocky Mountain Power's Reply
Comments in the above referenced matter.
Informal questions related to this matter may be directed to me at [phone].
Sincerely,
ROCKY MOUNTAIN
POWER
A UVISION OF PACIFICORP
S
1407 W. North Temple, Suite 330
Salt Lake City, Utah 841l6
Michael S. Snow
Manager, DSM Regulatory Affairs
Enclosures
CERTIX'ICATE OX' SERYICE
I hereby certifr that on this 5m day of April,2ol7,I caused to be served, via e-mail, a true
and correct copy of the foregoing document in PAC-E-16-14 to the following:
Brad M. Pwdy
Attorney at Law
2019 N. tTth st.
Boise,lD 83702
208-384-1299
Email : [e-mail]
Ve,.
Katie Savarin
Coordinator, Regulatory Operations
Daniel E. Solander, (ISB# 8931)
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake Ciry, Utah 841l6
Telephone: [phone]
Email : [e-mail]
Attorneyfor RoclE Mountain Power
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )oF ROCKY MOUNTATN POWER )REQUESTING A PRUDENCY )
DETERMINATION ON DEMAND.SIDE )
MANAGEMENT EXPENDITURES. )
CASE NO. PAC.E.I6.I4
REPLY COMMENTS
COMES NOW, Rocky Mountain Power, a division of PacifiCorp (the "Company"), in
accordance with RP 052 and RP 201, et. seq., and hereby respectfully submits reply comments
to the Idaho Public Utilities Commission (the "Commission") in the above referenced matter.
BACKGROT]ND
1. On December20,20l6,the Idaho Public Utilities Commission ("Commission")
issued a Notice of Comments Deadline in Order No. 33679 for the above referenced matter,
allowing parties to file comments by March 15,2017, with the Company's reply comments
due by April 5, 2017. Commission Staff ("Staff') and Community Action Partnership
Association of Idaho ("CAPAI") filed comments March 15,2017. Rocky Mountain Power (the
"Company") provides these reply comments in response to comments filed by Staff and
CAPAI.
2. First, the Company notes that Staffs comments supported a finding that the
Company's 2014 through 2015 DSM tariff rider expenses were prudently incurred. CAPAI
also concluded the Company's 2014-2015 costs specific to the Low Income Weatherization
Program ("LIW Program") were prudently incurred.
REPLY COMMENTS OF
ROCKY MOLTNTAIN POWER
Page I
REPLY COMMENTS
3. Staff clarified in their comments that they prefer the Utility Cost Test ("UCT")
as the standard cost-effectiveness test over the Total Resource Cost Test ("TRC"), believing it
better reflects the value of energy efficiency as a resource to customers and therefore should
be weighted more heavily than other tests. The Company believes the TRC, UCT, and
Participant Cost Test evaluate energy efficiency programs from different perspectives, and
recommends continuing to screen programs using each test as a guideline. When prudency
determinations are sought for past expenditures, however, the Company may emphasize the
UCT in accordance with Staff s recommendation, focusing on Company-controlled benefits
and costs, to argue whether programs were cost-effective, but may not exclusively emphasize
the UCT over other tests.
4. Staff also recommended in their comments that going forward, the Company
conduct its Conservation Potential Assessment ("CPA") using utility, rather than total costs,
noting that the Commission has accepted this approach. The Company assumes the
"acceptance" referenced by Staff is for other utilities in Idaho and is unaware of a Commission
order that Rocky Mountain Power use the UCT for its CPA analyses for Idaho. If the
Commission does have a preference regarding the use of the TRC or the UCT for the
Company's CPA, the Company supports StafPs recommendationthatthe Commissionprovide
direction regarding this matter in its order.
5. CAPAI's comments recommended forming a working group to analyze
potential changes to the LIW Program to enhance its cost-effectiveness. The Company notes
that little has changed since the last collaborative and the additional costs associated with a
collaborative process only increase the burden on the LIW Program. Decrement values from
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
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the 2015 Integrated Resource Plan were the primary driver for reduced cost-effectiveness of
the LIW Program. Besides decrement values, another primary impact on the LIW Program's
cost-effectiveness is the Company's share of project costs. Pursuant to Order No. 32151, the
Company is mandated to fund 85 percent of eligible project costs, which is much higher than
typical energy efficiency incentives, which adversely impacts cost-effectiveness of the LIW
Program.
6. The Company continually analyzes its progrErms and makes ongoing
adjustments to incentives and measures in response to market conditions, such as changes in
materials costs, product availability, and price competition. Third party evaluations are also
conducted on a regular basis to help inform cost-effectiveness and recommendations for
improvement. A third party evaluation of the LIW Program is currently in process, and is
expected to be published in the third quarter of 2017.If the evaluation yields anything new,
the Company will take the appropriate action to improve the LIW Program. At this time, the
Company does not believe a working group would be a productive way to improve the cost-
effectiveness of the LIW Program.
REQUEST FOR RELIEF
WHEREFORE, Rocky Mountain Power respectfully requests that the
Commission: (l) find that the20l4 through 2015 DSM expenditures were prudently incurred;
(2) provide guidance whether the UCT or TRC should be used for the conservation potential
analysis; and (3) deny CAPAI's request to form another working group to evaluate the LIW
Program.
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
Page 3
DATED this 5tr Day of April2Dl7.
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
Respectfully submitted,
By
Daniel E. Solander
Attorney for Rocky Mountain Power
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