20180810Application.pdf

ROCKY MOUNTAIN
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August 10,2018
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1407 W. North Temple, Suite 330
Salt Lake Ciry, Utah 84116
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Idaho Public Utilities Commission
472West Washington
Boise,ID 83702-5983
Attn: Diane Hanian
Commission Secretary
RE CASE NO. PAC.E-I8-07
IN THE MATTER OF TIIE APPLICATION OF ROCKY MOUNTAIN POWER
REQUESTING A PRUDENCY DETERMINATION ON DEMAND.SIDE
MANAGEMENT EXPENDITURES.
Please find enclosed in the above captioned matter an original and seven (7) copies of Rocky
Mountain Power's Application requesting an order designating its demand-side management
expenses as prudently incurred for2016 and2017 program years.
For informal questions related to this matter, please contact me at [phone].
Sincerely,
Michael S. Snow
Manager, DSM Regulatory Affairs
Enclosures
DanielE. Solander, (ISB# 8931)
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake city, utah 84116
Telephone: [phone]
Email: [e-mail]
Attorneyfor Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
REC E IVT D
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IN THE MATTER OF THE APPLICATION )
oF ROCKY MOUNTAIN POWER )
REQUESTING A PRUDENCY )
DETERMINATION ON DEMAIID-SIDE )
MAI\IAGEMENT EXPENDITURES. )
CASE NO. PAC-E.18.07
APPLICATION
COMES NOW, Rocky Mountain Power, a division of PacifiCorp (the "Company"), in
accordance with RP 052 and RP 201, et. seq., and hereby respectfully applies to the Idaho
Public Utilities Commission (the "Commission") for an order designating Rocky Mountain
Power's demand-side management ("DSM") expenses in the amount of $8,539,263 as
prudently incurred ("Application") for 2016 and2017 program years.
In support of this Application, Rocky Mountain Power states as follows:
1. Rocky Mountain Power is authorized to do and is doing business in the state of
Idaho. The Company provides retail electric service to approximately 77,600 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 ldaho pursuant to Idaho Code $ 6l-129.
2. In support of this Application respectfully requesting the Commission's
determination that the Company's 2016 through 2017 program year DSM expenditures were
prudently incurred and in the public interest, the Company presents the annual DSM reports
for each year, results of the program cost effectiveness analysis, and third-party program
evaluation reports.
APPLICATION OF
ROCKY MOLTNTAIN POWER
Page 1
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 of them through Electric Service Schedule No. 191,
Customer Efficiency Services Rate Adjustment ("Schedule l9l"), which was applied to
customers' bills beginning May l, 2006.
4. This Application and the Annual DSM reports are consistent with the
Memorandum of Understanding the Company entered into in Case No. GNR-E-12-01, and
approved by Order No. 32788 ("MOU"). Pursuant to this MOU, Rocky Mountain Power has
filed annual reports with the Commission for program years 2016 and 2017 . For convenience,
the 2016 Idaho Annual DSM report and associated appendices are provided as Attachment
Nos. I and2, respectively, and the 2017 ldaho Annual DSM report and associated appendices
are provided as Attachment Nos. 3 and 4, respectively, to this Application. These reports
followed the format set forth in the MOU and include: 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, were also included in the annual reports.
5. During 2016 and20l7,the Company's DSM portfolio consisted of four distinct
energy efficiency programs, offering incentives for a wide variety of energy efficiency
measures to the Company's residential, business and agricultural customers. Agricultural
APPLICATION OF
ROCKY MOLNTATN POWER
Page 2
customers can also participate in the irrigation load management program.l The Company
continues to work with customers and the Commission to provide a comprehensive suite of
DSM programs that provide the greatest opportunity for participation by all customer sectors.
6. DSM programs offered by the Company provide a wide range of services and
financial incentives to assist customers with energy efficiency projects they wish to pursue.
The four DSM programs subject to Schedule 191 in 2016 and2017 were:
. Schedule2l - Low Income Weatherization/Low Income Education;
o Schedule 118 - Home Energy Saver;
o Home Energy Reports (no tariff); and
o Schedule 140 - Non-Residential Energy Efficiency (wattsmart Business)
Schedule 117, Residential Refrigerator Recycling, was suspended in November 2015 and
cancelled in April 2016.
PROGRAM EXPENDITURES
7 . The Company requests a Commission determination that the DSM expenditures
totaling $8,539,263, which represents $4,500,332 for 2016 and $4,038,931 for 2017, were
prudent and in the public interest. Expenditures by category are provided in Appendix 2,
(Auachment No. 2), of the 2016 Annual Report, and Appendix 2, (Attachment No. 4), of the
2017 Annual Report. These expenditures are categorized by program delivery administration,
Company administration, customer and dealer/trade ally incentives, engineering, evaluation,
marketing and program development. The expenditures submitted in this Application represent
1 In 201l, the Irrigation Load Control program was treated as a system-wide benefit and excluded from Schedule
191. Performance results were no longer included in the annual DSM reports, but were submitted as a confidential
document to the Commission.
APPLICATION OF
ROCKY MOLINTATN POWER
Page 3
the activities that took place during program years 201 6-20 I 7 through a year-end cost true-up
process.
8. The Company reports its Schedule l9l balancing account quarterly to
Commission Staff, and annually in the DSM Annual Reports. For added convenience, the 2016
and2017 balancing account activity is provided in Tables I and2 below.
Table I - 2016 Schedule 191 Balancing Account Activity
llrlonth
rfrflthly
Progrm Costs-
Fbred Aseets
fionthly Net
A6ucd Costs Rste RecoEry crrytrB
Chrge
AccruC E*
A6rmuliled
Bdilc
cs3h Balu
A6rmuhed
adilca
Dec-15 s 406,931 S 7L4,6a7
Jan-16 s 3(}8,498 S Ea,ll'c S (278,e63)S 3s1 5 4s6,atz S a28,687
s 293,643 s (7o"82o)S (2s4,38s)S 38o S 476,45s S zgz,sos
Mar-16 s 2a9,163 S 2e,o7s $ (222,a791 S 42s s 543,164 5 899,294
Apr-16 S zt6,aes s 62,898 S (234,788)S 47o S s8s,746 5 gga,zts
May-I6 S 332,7L7 S +r,ssc S (3s3,ss3)5 +zg S s6s,3aa S 1p2o,36s
Jun-16 S sss,4o7 s (4,eo1)S (ss6,4o1)s 471 S s64,86s S 1,o14,94s
Jul-16 S sos.s44 s (1u,4o6)S (847"814)S 328 5 222,924 S s6o,s97
Arg-16 S s69,za2 S (2,se8)S (710,166)s44 S (117,s16)S 217,160
Sep-16 s 367,84s s (62,38s)$ (s38"824)s (17o)S (28s,o6s)S (16,374)
Oct-16 s 267,111 5 zz,asz S (3s8,s13)s (27e)S (380,746)s (85,422)
Nov-16 s 281.83E S ssp2o S (2s8,6o4)s (324)S (3e7"s36)s 147,4e21
Dec-l6 S 661,4s2 S (7s.ss7)S (340,263)s (1s8)s (76.84s)S 194,942
2016 Totds s 4.soeroo S (3s"e6el S (4,99s,1ss1 s 1B7'
Table 2 -2017 Schedule 191 Balancing Account Activity
Illonth
Ulollthly
Protrflr C.Gts-
ftledAsts
Monthly iaet
Aocrued C,cte REte Remry CaryilE
Chrge
Asud Bsb
Acormuhed
Bdme
c,sh 8*
Am.rmuHed
Bdrte
S 194,942 s (76,84s)
$ 31o,zsg s (46,'181)S (3s7,238)s (roo) $ 61,382 $ (163,92s)S zso,sss S r+,ora S (342,420)S (181) S (30,218)S (270,142)
$ 269,92s S lzs,7szl S (287,oe3)S (233)S (78,3s1)S (288,s43)
$ tg2,ztz S 37,143 $ (26o,7so)s (273)S (12o,o19)S (367,3s4)
S 23s,6o4 S (16,8391 S (322.8711 S (3421 5 1224,4671 s (4s4,e63)
S 245,610 S (3,ss6)$ (s79,s16)s (s18)S (s62,427)S (78s,387)
S +zo,soa S s,szs S (818,042)S (B2r)S (948,342)S (1,181,281)
S 428,o3o S 50,406 S (fls,24s)S (1,076)S(1,11e,227)S (1,4o2,s72)
$ 393,321 S 41/29 S (s7o,B23l $ (1,243)S(1,2s3,249)S (1,s81,317)
S sge,szr s 2,e32 S (32s,7e6)S (1,2s3)S(1,1e2,836)S (l,s2383s)
s 60,683 S 129,654 S (323,103)S (1,37e)S(1,326,e81)S (1,787,634)
S 792.988 S (z61,sssl S (33o,4o7)S (1,297)S(1,127.2s1)S (1,326,350)
2(,17 Totds $ 3,969,5ss S 02,6se)$ (s,21o,3o31 $ (r,7s6l
Jan-17
Feb-'17
Mar-17
Apr-17
May-17
Jul-17
Are-17
S€p-17
Dec-16
Jun-17
Oct-17
Dec-17
APPLICATION OF
ROCKY MOLINTAIN POWER
Page 4
Feb-16
ilov-l7
ENERGY EFFICIENCY SAVINGS AND COST EFFECTIVENESS
9. The annual energy efficiency portfolio savings achieved through the
Company's DSM programs were 19,450 MWh in20l6 and 15,830 MWh for 2017, measured
at the customers' meter.
10. The Company examines its programs from all cost effectiveness tests, including
the PacifiCorp Total Resource Cost ("PTRC"), Total Resource Cost ("TRC"), Utility Cost Test
("UCT"), Ratepayer Impact Measure ("RIM"), and Participant Cost Test ("PCT") at the
measure category, program-level, sector-level and portfolio. The TRC test has been the
primary determinant for program planning and reporting. Pursuant to Commission Order No.
33766, issued May 18, 2017,the Company now uses the UCT as the primary determinant for
cost effectiveness with the goal of having the TRC also passing. The Low Income
Weatherization program also uses the PTRC test authorizedby Commission Order No. 32788,
issued April12,2013.
I l. The portfolio was cost effective for each year with a benefit to cost ratio greater
than 1.0 for both the UCT and TRC. Program level cost-effectiveness for the Appliance
Recycling program was not calculated for 2016 due to its cancelation March 1,2016.2
However, the minimal expenditures and savings were included in the residential level and
portfolio level cost-effectiveness calculations. The Low Income Weatherization program was
not cost-effective from the UCT in either year, but was cost effective from the PTRC in both
years. All other programs passed with a benefit/cost ratio greater than 1.0.
12. The Low Income Weatherization program was not cost-effective from the UCT,
but passed the PTRC as shown in Table 3 below. The PTRC cost-effectiveness test included
2 Order No. 33497
APPLICATION OF
ROCKY MOUNTATN POWER
Page 5
health, safety, and repair measures as a dollar of non-energy benefits for each dollar of cost as
well as non-energy benefits as allowed per Commission Order No. 32788. Costs to the program
include program administration and labor costs. Program level cost effectiveness excludes
evaluation costs.3
Table 3 - Low Income Weatherization Cost-Effectiveness
Benefit/Cost Test 2016 2017
PTRC (TRC + 10yo conservation adder)1.04 1.45
UCT 0.81 0.46
The Low Income Weatherization program was not cost effective from the UCT perspective in
either year. The program benefits, based on the 2015 Integrated Resource Plan ("IRI"';
decrement values, were lower than the program costs. The program costs include the required
funding amount per Commission Order No. 32196. The most recent Low Income
Weatherization evaluation for program years 2013-2015 calculated a combined-year UCT of
0.63 and a PTRC of 1.07. The evaluation cost effectiveness included non-energy benefits
(health, safety and repair costs; reduced payment assistance and arrearage) and was calculated
using the 2013 IRP decrementvalues for 2013 and 2014,andthe 2015 IRP decrement for 2015.
The Company continues to monitor the program's costs, benefits and subsequent cost
effectiveness.
ENERGY EFFICIENCY TARGETS
13. Provided in Table 4 is a comparison of the Company's energy efficiency
portfolio performance with the achievable technical potential identified in the Company's
conservation potential assessment ("CPA") and the IRP selections over the 2016-2017 period.
3 Evaluation costs are included at the sector level and portfolio for cost effectiveness.
APPLICATION OF
ROCKY MOUNTATN POWER
Page 6
Consistent with the Northwest Power and Conservation Council's regional power plans, the
Company's CPA uses acquisition ramp rates and assumes that 85 percent of the technical
potential is achievable over 20 years to account for real world constraints affecting the
acquisition of energy efficiency resources. Absent the achievability assumption and ramp rates,
all discretionary resources (those that can technically be acquired at any time) would be
available at the start of the planning period, which is unrealistic from both a planning and
acquisition standpoint.
Table 4 -Achievable Technical & IRP Selections
* Potential from 2015 DSM Potential Study and selections from 2015 IRP Update** Potential from2017 DSM Potential Study and selections from 2017 IRP
14. As shown in Table 4, from 2016 through20lT the Company acquired 39,066
MWh, at generator, of energy efficiency savings in Idaho, exceeding the IRP selections for the
same period of 33,370 MWh. IRP savings are based on assumed typical acquisition rates,
whereas actual program performance can fluctuate from year to year based on factors such as
economic conditions, the timing of large project completions, etc.
PROGRAM EVALUATIONS
15. Evaluations are conducted using best-practice approaches and techniques
including those outlined in the National Action Plan for Energy Efficiency Program Impact
Evaluation and the California Evaluation Framework guides. The Company conducts process
and/or impact evaluations to ensure the ongoing cost effectiveness of its energy efficiency
programs through validation of energy savings and to provide information to assist in program
management.
APPLICATION OF
ROCKY MOUNTATN POWER
Idaho MWh Savinqs (at senerator)Source ofSavings 2016*2Ol7r,*2016-2017 Total
Achievable Technical Potential 26,461 29,672 56,133
Integrated Resource Plan Selections 15,800 17,570 33,370
Energy Effi ciency Portfolio Performance 21,551 17,514 39,066
Page 7
16. Process evaluations assess program delivery, from design to implementation, in
order to identify efficiencies, what worked, what did not work, constraints, and potential
improvements. Identiffing opportunities for improvement is essential to making corrections
along the way.
17. Impact evaluations determine the impacts (e.g. energy and demand savings) that
directly result from a program. They also support cost effectiveness analyses aimed at
identiffing relative program costs and benefits.
18. Evaluations are based on credible and transparent methods focused on
successfully capturing the savings created by the programs. Evaluations develop retrospective
estimates of energy savings attributable to a program. While retrospective in nature, the
information obtained will be used to inform future potential assessments, plans, forecasts and
targets.
19. Copies of the Company's most recent process and impact evaluations for its
Idaho programs can be found at http://www.pacificorp.com/es/dsm/idaho.html or on the CD
accompanying this Application. Each of these evaluations were completed by third party
consulting firms.
MODIFIED PROCEDURE
20. 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 201 et seq. The Company stands ready to present testimony in support of this Application
if the Commission determines a technical hearing is required.
APPLICATION OF
ROCKY MOLINTAIN POWER
Page 8
2t
COMMUNICATIONS AND SERVICE OF PLEADINGS
Communications regarding this Application should be addressed to:
Ted Weston
Daniel E. Solander
Michael S. Snow
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
Fax: [phone]
Emai I : [e-mail]
daniel.solander@nacifi com.com
michae l. [e-mail]
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]
michael. snow@pacifi corp.com
By regular mail Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
REQUEST FOR RELIEF
22. WHEREFORE, for the reasons set forth above Rocky Mountain Power
respectfully requests that the Commission approve this Application by: (1) issuing an order
authorizing that this matter be processed by Modified Procedure; and (2) issuing a final order
designating Rocky Mountain Power's 2016 and 2017 total DSM expenditures of $8,539,263
as prudently incurred.
APPLICATION OF
ROCKY MOLTNTAIN POWER
Page 9
DATED this lOth Day of August, 2018.
Respectfully submitted,
tht^By
Daniel E. Solander
Attorney for Rocky Mountain Power
APPLICATION OF
ROCKY MOTINTAIN POWER
Page 10